The emerging Policy S/JH: New jobs and homes identifies that the GCLP will provide 58,500 new jobs over the Plan period from 2020 to 2041.

The Greater Cambridge Employment Land Review & Economic Development Evidence Study (the ‘2020
ELEDES’), which has informed the emerging proposals, concluded that the recommended lower and upper
forecast range referred to as central growth (+58,400 jobs) and higher growth (+78,700 jobs), respectively,
“should be used for Local Plan purposes”. However, paragraph 6.33 in the 2020 ELEDES states that:
“It is recommended that in planning positively for growth, the KS2 Higher Scenario is planned for
regarding B1a/b floorspace, without making any implied assumptions regarding jobs growth [Lichfields’
emphasis]. This is recommended to ensure a flexible employment land supply encouraging growth in
existing businesses and attracting inward investment. It also broadly aligns with completions trends and
market feedback.”

Of note, the higher growth (i.e. recommended scenario) relates to an additional 78,700 jobs across the plan
period (see 2020 ELEDES paragraph 6.11, pg.97). Therefore, there is an internal inconsistency across the
Local Plan and its supporting evidence, and it is not clear how the recommended higher growth scenario of
78,700 jobs has been translated into the Local Plan’s lower provision of 58,500 jobs.

It should be also highlighted that the labour demand scenario is used to inform the employment space
requirements for office and R&D uses, while light industrial, general industrial and storage and distribution
space requirements have been based on the past trends scenario, and particularly a projection of the annual
net completions between the monitoring years of 2011/12 and 2017/18, which is considered a very short
period of time to inform policy recommendations over the next 20 years.

According to 2020 ELEDES Table 10 (pg.94), the job growth associated with “2011-17 annual average
change”, which is understood to reflect the recommended scenario for the industrial/warehousing uses,
equates to 125,200 jobs across all sectors for the 2020 to 2041 period. There is no available data provided in
terms of how these jobs are distributed across the various employment segments. As a result, there is no
transparent evidence of how the proposed jobs growth is distributed across the various employment space
types and on this basis, we consider that the evidence in relation to jobs growth estimation lacks
transparency and robustness.

Moreover, it is understood that the estimation of the office and R&D jobs growth is based on a series of
forecasts highlighting a policy-on view on how those sectors (which are considered historically as the key
drivers of the local economy) are expected to grow further. The emphasis on office-based segments appears
to characterise the approach in the Local Plan as a whole, and which therefore does not acknowledge the
importance of other economic sectors, including logistics and industrial-based activity.

Furthermore, paragraphs 6.36 to 6.37 state:
“6.36 The labour demand forecasts for B1c/B2 floorspace should be viewed cautiously. Recent completions trends show a slow down in light / heavy industrial floorspace loss as the manufacturing and related sector of the economy stabilises after a period of decline. Market feedback suggests demand for light industrial floorspace which is reflected in gains in South Cambridgeshire and market pressure in Cambridge [Lichfields emphasis]. It is recommended that industrial floorspace losses are limited in the city to avoid constraining business and industrial activity. In reality there may be some further losses in Cambridge, which should be minimised, but gains in South Cambridgeshire are expected regardless.

6.37 Similarly, with B8 warehousing needs, the completions trends show a higher level of floorspace than the labour demand model with losses in Cambridge and gains in South Cambridgeshire. The logistics sector is experiencing a high level of change due to increases in e-commerce and greater levels of automation particularly in larger units [Lichfields emphasis]. This may change the relationship between labour requirements and floorspace needs. Given delivery has been steady in South Cambridgeshire across the tested completion periods whilst losses have increased in Cambridge and are likely to continue, it is recommended that the recent net trends are planned for.”

Although the evidence demonstrates clearly that there are specific market signals showing ‘market pressure’ in Cambridge City together with demand for larger units as e-commerce increases and automation evolves, both the evidence and the emerging policies choose to ignore these signals and driven by policy choices to focus on the office-based economy. This is contrary to:
• NPPF Paragraph 81: ‘Significant weight should be placed on the need to support economic growth and productivity, taking into account both local business needs and wider opportunities for development’,
• NPPF Paragraph 82 ‘planning policies should: d) be flexible enough to accommodate needs not anticipated in the plan, allow for new and flexible working practices…and to enable a rapid response to changes in economic circumstances’; and
• NPPF Paragraph 83 that sets the requirement for the policies to recognise and address the specific locational need of (inter-alia) storage and distribution operators at a variety of scales and in suitably accessible locations.

Therefore, we conclude that the evidence that informs the emerging policy over the next twenty years is not proportionate nor it is objective. This contradicts with NPPF Paragraph 35 point ‘a) Positively prepared’ that requires the plans ‘to seek to meet the area’s objectively assessed need’ and point ‘b) Justified’ that requires ‘an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence’.
Lichfields has reviewed the existing evidence and prepared an updated the analysis in relation to logistics requirements across the Plan period in Greater Cambridge (Appendix 1). Based on our analysis, there are various inconsistencies and deficiencies within the Councils’ evidence that, in our view, means the anticipated B8 and the combined Eg(iii)/B2/B8 requirements and jobs growth are significantly underestimated.

In particular, both jobs scenarios of 58,400 or 78,700 additional jobs across the Plan period suggest that over the next 20 years B8 jobs will grow by 457 jobs or 21.7 jobs per annum, while the combined Eg(iii)/B2/B8 equivalent will decrease by 1,339 jobs or by -63.7 jobs per annum across the Plan period (Table 13, pg.99). This contradicts the market signals and recent activity that highlight pressures to identify additional employment land in Greater Cambridge to avoid losing businesses that want to either invest or expand in the area.

Lichfields’ updated assessment of logistics land requirements (as set out in Appendix 1) suggests that additional B8 job growth of around 3,100 jobs to 5,700 jobs should be anticipated across the Plan period, once the strategic logistics requirements are considered as identified by NPPF and PPG.

As a result, it is not considered that the emerging policy is soundly-based. There is need for the supporting evidence to objectively and robustly identify employment requirements across office, industrial and storage and distribution uses rather than taking a policy-on view that largely focuses on office growth and does not adequately assess the needs arising for other segments of the economy.