Comment

Greater Cambridge Local Plan Preferred Options

Representation ID: 59943

Received: 13/12/2021

Respondent: Fen Ditton Parish Council

Representation Summary:

a. It is not clear how the base number accounts for actual completions in 2020 and 2021. A buffer of 10% should not be added to what has already been built.
b. The 2021 census will give a more accurate base for the actual numbers of houses needed to meet the total need in 2041.
c. Employment patterns appear to be changing rapidly. If numbers of persons employed have dropped in addition to the noted drop or low growth in economic output, the overall employment target for 2041 may be too optimistic.
d. Changes to the planning regulations governing change of use should be assessed and the amount of qualifying space should be estimated, and impact on the high value jobs underpinning the growth aspiration and potential for conversion of such spaces to housing should be assessed.
e. Overall, if the jobs growth has been set back by the events of the last two years, it is necessary to either change the forecast housing need or remove/reduce the 10% buffer.
f. 2021 Census data should also be interrogated.
g. The proposed medium growth +10-% strategy is objectionable because they are over ambitious in the plan period and bring a high level of risk to Greater Cambridge and the Vision and Aims of the Local Plan.
h. The quoted planned average of 2,111 homes produced per year is not going to have a major impact on Cambridge high house prices or the provision of social and affordable housing for the lower paid of the 58,500 jobs.

Full text:

ECONOMIC GROWTH AND HOUSING NUMBERS
a. SCDC use 2020 as the base with requirements for housing numbers being additive since the 2011 census. It is not clear how the base number accounts for actual completions in 2020 and 2021. If so, a buffer of 10% should not be added to what has already been built.
b. The 2021 census will give a more accurate base for the actual numbers of houses needed to meet the total need in 2041. The process for inclusion of the true 2021 figure needs to be described if it is not available before the formal consultation.
c. Employment patterns appear to be changing rapidly with a drop off in retail (and, anecdotally, low value day trip tourism) for example. If numbers of persons employed have dropped in addition to the noted drop or low growth in economic output, the overall employment target for 2041 may be too optimistic. For example if employment and output are still at 2019/2020 levels, that would equate to around 10% of the Local Plan period to 2041. The impact should be assessed and announced before the formal consultation on the Local Plan commences.
d. Changes to the planning regulations governing change of use have been announced recently. The application of the new rules should be assessed and the amount of qualifying space should be estimated if is not already known. If the change is between retail/commercial uses then the impact on the high value jobs underpinning the growth aspiration should be assessed prior to the formal consultation. Any potential for conversion of such spaces to housing should also be assessed.
e. Overall, if the jobs growth has been set back by the events of the last two years, noting the recent ONS announcement that the Uk economy is 2.1 % smaller than in Q4 2019. it is necessary to either change the forecast housing need or remove/reduce the 10% buffer.
f. 2021 Census data should also be interrogated to quantify if population growth in GC and surrounding areas has stalled or even gone negative in parallel with the economic slowdown of the last two years. A degree of ex-migration may have occurred compared to the expected inward migration to the areas.
g. The proposed medium growth +10-% strategy is objectionable as it stands because they are over ambitious in the plan period and bring a high level of risk to Greater Cambridge and the Vision and Aims of the Local Plan . Indeed, the impact of large population increases in Greater Cambridge as a result of an unprecedented amount of new homes already in the pipeline, a 37% increase beyond existing homes in 2020, are yet to be known/tested and will not be known until mid-plan period and beyond. This high growth strategy may fail if sustainable solutions do not come to the fore in a timely way and the attractiveness of Cambridge for homes and business is eroded (CPIER 2018). The impact of this unprecedented high growth strategy already in progress and committed to needs to be evaluated before it is added to further. The Aims of the Local Plan: “Wellbeing & Social inclusion” and ˜Great Places” are of particular relevance and at risk.
h. The quoted planned average of 2,111 homes produced per year is not going to have a major impact on Cambridge high house prices or the provision of social and affordable housing for the lower paid of the 58,500 jobs. The City already has one of the highest relative levels of deprivation in England and Wales with 3 LSOA’s in bottom 20% ( CN-Oct 2020).