How much development, and where – general comments:
We accept that development has a part to play in ensuring the people of Greater Cambridge have suitable homes and employment, and recognise that our area hosts jobs with national and international significance. However, we think that the specific number of jobs needs to be revised to take account of the potentially huge repercussions of Brexit and COVID. These are likely to have implications for the amount, type and location of land needed. Specifically, we strongly believe that the ‘predict and provide’ approach being taken to determine “how much development” is flawed and will lead to highly negative outcomes.
● This approach fails to take environmental constraints as its starting point. The carbon budget referred to previously is one such constraint. Water supply, and the ability to process wastewater, is another. The Planning Authority has emphasised that “delivery of the proposals in the plan is contingent on water supply being adequate without causing further environmental harm”. They have said that the planned reservoirs and improvements to supply will likely be delivered too late in the planned period to meet the preferred development trajectory. Interim measures are being investigated by the water industry but there are no firm plans yet. The Draft Regional Water Plan for Eastern England is not expected until next year. Given these considerations, it is clearly premature to proceed on the assumption that it will be possible to deliver the ‘desired’ level of development. We understand that the ambitious new standards set out in the First Proposals (for example on energy and water efficiency) cannot be applied to the major developments that have already been granted outline permissions. Furthermore, building that takes place under Permitted Development Rights cannot be required to comply with these policies. This only serves to strengthen the point that the level of development planned for our region will have massive environmental consequences which cannot be fully mitigated through efficiency standards, however ambitious.
● The justifications for seeking continued high growth of the Greater Cambridge economy are flawed. The language used, suggesting the Greater Cambridge economy is special or unique, echoes the government’s rhetoric about the OxCam Arc, which has been pulled apart by commentators including Smart Growth UK [1]. Furthermore, as the Planning Authority acknowledges, our booming economy has come at the cost of a huge housing affordability problem. We do not see evidence that any attempt is being made to learn from the failures of previous policies. For example, how will the Local Plan ensure that new developments are for local people, not dormitories for London commuters or merely opportunities for investors? What evidence is there that the proposed growth will address the problems faced by the poorest people in our society or reduce inequality within the region? Furthermore Cambridge is a city with the highest level of inequality in the UK. So our present high growth has not been good for all Cambridge citizens.
● The approach places too much emphasis on modelled growth in employment. The high uncertainty levels involved in making such forecasts, particularly in light of Brexit and COVID-19, are acknowledged. It therefore seems inappropriate that the Local Authority is using these figures to argue for a higher housing allocation than that calculated by central government. Furthermore, given environmental constraints, the most likely growth forecast is not necessarily the most desirable. The Planning Authority should be looking to manage growth, not anticipate and stoke it.
● The approach does not take account of the changing national policy context. Current Local Authority housing allocations were calculated using an algorithm that measures housing demand based on market growth, prioritising house building in areas that are already booming. New Secretary of State Michael Gove has expressed his intention to review this approach with a view to achieving “a fairer and more equitable distribution of need across the country” [2].
During the First Proposal webinars, the Planning Authority indicated that the proposed levels of growth are necessary, and that their aim with the Local Plan is to deliver this growth in as sustainable a way as possible. Based on the above points, we contend that the proposed level of growth is neither necessary nor desirable.

[1] https://smartgrowthuk.org/wp-content/uploads/2021/09/The_Overheated_Arc_Part_3_September_2021.pdf
[2] https://www.planningresource.co.uk/article/1734830/we-want-fairer-distribution-housing-need-across-country-says-gove