The emerging Policy J/NE New employment development proposals sets out whether proposals for employment uses within Classes E(g), B2 and B8 will be supported. According to the emerging policy, such developments will only be allowed at sites set out in the Proposed Policy S/DS: Development strategy, within towns and villages where it is of an appropriate scale, in a list of ‘established employment areas in the countryside’ or where expansion of existing businesses fulfil a number of criteria (described in the justification). The emerging policy, then, states at the end that “Large scale national and regional warehousing and distribution centres will not be supported in Greater Cambridge”.

From our review, it appears that this approach has been justified by the following paragraph:
“A need for additional space for warehousing and distribution (Use Class B8) was identified in the Greater Cambridge Employment Land and Economic Development Evidence Study (November 2020) and potential sites are proposed to be allocated (see the Strategy section of this consultation). However, whilst we need to meet the needs for local distribution, as a central location the area may be desirable to national distributors. Given the very high land take of this type of use, the local pressures on land supply for a range of uses, and the greenbelt location, it is proposed that the plan continues to not support large scale regional and national distribution proposals.”

The 2020 ELEDES that underpins the emerging Policy J/NE identifies a combined office, R&D, industrial and storage and distribution need of about 664,300 sq.m, of which just over 46,930 sq.m relates to storage and distribution uses (within B8 Class). When these figures are compared with the identified supply position, it results in a shortfall of 24,470 sq.m for storage and distribution space, and a combined shortfall of c.76,940 sq.m for the industrial and distribution space across Greater Cambridge to 2041 according to the Council’s evidence.
A detailed review by Lichfields of the 2020 ELEDES (as set out in Appendix 1) indicates a number of deficiencies in the evidence which has been produced, which we consider point to a significantly greater level of need for B8 storage and distribution floorspace in Greater Cambridge than is recommended in the study. This is set out in Chapter 2 of Appendix 1. A briefing note summarising these findings was shared with Greater Cambridge planning policy team on 26 November 2021.

In short, the review indicates that the requirements identified in the 2020 ELEDES for storage and distribution floorspace are at least 50% to 115% lower than the level of need within Greater Cambridge when considering the latest data, and applying a more consistent approach in estimating employment needs. It should be noted that these reflect net requirements, without considering any allowances for flexibility or losses replacement. Most importantly, these requirements relate to local, indigenous requirements for small businesses operating in storage and distribution-based sectors across the area and does not reflect the strategic requirements that are identified across the appropriate market area as set out in the PPG Paragraphs 26 and 31 and NPPF Paragraph 83.

In our view, the need for storage and distribution has been effectively overlooked by the emerging Local Plan, counter to the NPPF’s requirement for planning policies to accommodate the bespoke locational requirements for storage and distribution operations of all scales, and the PPG’s guidance in ‘How can local authorities assess need and allocate space for logistics?’ (Paragraph 31). On this basis, we have identified the lack of the evidential basis to robustly justify the emerging Policy J/NE stating that large scale national and regional warehousing and distribution centres will not be supported in Greater Cambridge, which clearly undermines the soundness of the Plan as currently proposed.

We recommend that Greater Cambridge must therefore now seek to properly assess and have regard to the requirements for storage and distribution operations of all scales and in suitably accessible locations in line with NPPF, taking account of the relevant FEMA and PMA, and to provide for such facilities. This requires a full assessment of strategic distribution needs, and an appraisal of all the available supply options to accommodate those needs, once identified. This is critical in order for the emerging Local Plan to be compliant with NPPF (Paragraphs 32 and 83) and PPG on Economic Need (Paragraph 31).

In the current absence of available evidence being prepared for the Councils, Lichfields has reviewed the existing evidence base and undertaken analysis of strategic distribution needs. This analysis was supported by detail market evidence from two of the most active commercial agents across the market, namely Savills and Bidwells (these market reports comprise part of Appendix 1). Both the market reports support that there is high demand for more additional employment space to serve Greater Cambridge and the wider market.

Our analysis as presented in Appendix 1 indicates that the appropriate scale of storage and distribution requirements arising in Greater Cambridge as part of the requirement identified across the relevant strategic logistics Property Market Area (PMA), which extends beyond the identified Functional Economic Market Area (FEMA) to parts of Northamptonshire, Bedfordshire, Hertfordshire, Essex and Suffolk, is estimated to be between 69.0 ha and 85.5 ha. This range reflects patterns of Greater Cambridge’s economic activity and employment representation across the market. This need is at least 500% to 630% above the proposed B8 requirements estimated by the 2020 ELEDES.

Lichfields scrutinised the identified supply across Greater Cambridge, and concluded that there is evidently only one site of 14ha developable area that can be genuinely regarded as suitable and available to accommodate strategic distribution uses. This represents just 2.8% of the requirement identified across the PMA, 8.7% of the FEMA’s equivalent and 16%-20% of the need identified in Greater Cambridge itself. Synthesising the analysis, there is a shortfall of storage and distribution employment land in Greater Cambridge between 55.0 ha and 71.5 ha across the Plan period to 2041.

Some of this shortfall must be accommodated within Greater Cambridge rather than those areas that have historically been relied upon to accommodate logistics need across the PMA (such as Peterborough and Northamptonshire) to avoid compromising the functioning of Greater Cambridge’s economy and to avoid a sub-optimal distribution network resulting in longer journeys by road and higher vehicle emissions.

Synthesising the above, the emerging Local Plan needs to consider updated evidence and to subsequently increase the employment supply across Greater Cambridge by allocating additional land of between 55.0 ha and 71.5 ha which is suitable, available and deliverable across the Plan period to 2041. This will align with NPPF and enable the soundness of the Local Plan.