Comment

Greater Cambridge Local Plan Preferred Options

Representation ID: 60540

Received: 13/12/2021

Respondent: Beechwood Homes Contracting Ltd

Representation Summary:

In summary, it is considered that: Policy S/JH: New Jobs and Homes, in respect to ‘Housing Needs’
With regard to the Housing Requirement (Section 2.1 of the draft Plan): The draft Plan, knowingly, focusses only on the ‘most likely’ of just two employment growth scenarios, with no weighting given to the scenario that is based on the most recent trends. Were weighting to be given to the scenario that is based on the most recent trends, it is likely that the associated housing requirement would increase by c. 9% to 48,300 homes.

Full text:

Under proposed Policy S/JH: New Jobs and Homes (commencing page 24), and the sub-heading of
‘Proposed Policy Direction’ (also commencing page 24) the draft Plan states (again page 24) (our emphasis):
“We propose that the new Local Plan will meet the following objectively assessed needs for development in the period 2020-2041:
• 58,500 jobs
• 44,400 homes, reflecting an annual objectively assessed need of 2,111 homes per year, which is rounded for the plan.”

The ‘Development Strategy Topic Paper’ explains (page 23):
“The Greater Cambridge Housing and Employment Relationships Report identified that the medium level jobs would generate a need for 44,400 homes (reflecting an annual objectively assessed need of 2,111 homes per year, which is rounded for the plan period), assuming all
the additional homes to support the additional jobs (being those above the jobs supported by the standard method homes) are located in Greater Cambridge. This would have the effect of providing opportunities for workers in those additional jobs to live close to where they work.
The total homes associated with the medium jobs are considered to represent the objectively assessed need for homes in Greater Cambridge.”

The Topic Paper goes on to say (also page 23):
“The Report also demonstrated that if existing commuting patterns were carried forward, the homes that would be provided in Greater Cambridge would be 41,900. However, this approach is not consistent with the local plan theme of net zero carbon and there is no certainty that neighbouring authorities would plan for the additional homes in their local plans in order to support the economy in Greater Cambridge.“

It then notes (page 24):
“… the Employment Land Review stated that the higher employment scenario places greater weight on fast jobs growth [as] seen in the recent past, particularly in key sectors. By implication from the wording included in the Employment Land Review regarding the central scenario, this outcome is considered possible but not the most likely.

By this the Topic Paper is explicitly acknowledging that the Employment Land Review (2020) identified that the rate of jobs growth in Greater Cambridge as seen ‘in the recent past’ would result in a demand for housing in excess of either 41,900 or 44,400 homes. The Topic Paper also notes (page 20) that this relationship is addressed in the ‘Housing and Employment Relationships Report’, dated November 2020.

The table on page 21 of the Topic Paper provides a helpful summary, making it clear that if recent
jobs growth were to continue then the comparable housing need would be between 53,500 and
56,500 homes.

The ‘Greater Cambridge Employment Land and economic Development Evidence Study’, dated November 2020, explains (para. 5.17) that the two employment growth scenarios are:
• The ‘central’ growth scenario: considered the most likely outcome taking into account long term (2001 to 2017) patterns of employment growth; and
• The ‘higher growth scenario: a higher outcome placing greater weight on fast growth in the recent past.
Notably, the Study states that the methodology adopted is such that the ‘higher’ growth scenario figure is still lower than the year-on-year ‘fast growth’ seen during the period 2010 to 2017.
Whilst the ‘higher’ growth scenario might not be the most likely, it is the pattern of growth that has been experienced over recent years (noting that it is lower than the year-on-year ‘fast growth’ experienced between 2010 and 2017) and thus should not simply be dismissed in favour of what is considered to be the ‘most likely’ of just two scenarios.

Were a 2:1 weighting to be applied to the two (‘central’ and ‘higher’) scenarios, in favour of the
‘most likely’, but not dismissing the potential continuation of the most trends, one would arrive at a projected jobs growth of c. 65,200 and a consequential need for between c. 45,800 and 48,300 homes. Adopting the same approach that leads to the proposed housing requirement of 44,400 homes would result in a requirement for 48,300 homes – approximately 9% more than is proposed.

Instead, the Topic Paper dismisses the higher growth scenario and simply states (page 24):
“… As such, the maximum level of homes, associated with the higher employment scenario, is not considered to represent the objectively assessed need for homes in Greater Cambridge.…”

Summary
It is thus evident that:
• The draft Plan, knowingly, focusses only on the ‘most likely’ of just two employment growth scenarios, with no weighting given to the scenario that is based on the most recent trends.
• Were weighting to be given to the scenario that is based on the most recent trends, it is likely that the associated housing requirement would increase by c. 9% to 48,300 homes.

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