How much development and where?

In order for rural villages to continue to thrive and sustain their local services and facilities it is imperative that sites are allocated on the edge of villages otherwise the services and facilities within them will decline and this will not address the local housing need. Given the framework boundaries will continue there is limited infill opportunities and therefore some housing on the edge of villages would be more appropriate.

In order for rural villages to continue to thrive and sustain their local services and facilities it is imperative that sites are allocated on the edge of villages otherwise the services and facilities within them will decline and this will not address the local housing need. Given the framework boundaries will continue there is limited infill opportunities and therefore some housing on the edge of villages would be more appropriate.

In order for rural villages to continue to thrive and sustain their local services and facilities it is imperative that sites are allocated on the edge of villages otherwise the services and facilities within them will decline and this will not address the local housing need. Given the framework boundaries will continue there is limited infill opportunities and therefore some housing on the edge of villages would be more appropriate.

In order for rural villages to continue to thrive and sustain their local services and facilities it is imperative that sites are allocated on the edge of villages otherwise the services and facilities within them will decline and this will not address the local housing need. Given the framework boundaries will continue there is limited infill opportunities and therefore some housing on the edge of villages would be more appropriate.

This is to express support for your policy regarding where developments should be, in particular the statement that you do not propose lots of village growth. Our small villages are an attractive feature of the Cambridgeshire countryside, and many have already absorbed significant growth, to the point where more will irretrievably damage their character and destroy a priceless asset.

The section 'how much development and where' starts with the idea that development should happen and then concedes that it will be directed to where it has least climate impact. This seems the wrong way around. The climate crisis should be the starting point of the plan. It should start by asking 'Given the urgency and severity of climate change, how should we plan for truely sustainable neighbourhoods based around meeting needs locally and building resilient communities'. We are in extraordinary times and a radical change in approach is necessary

It is better to have larger settlements less dependent on cars and close to employment.

The proposal to develop land in and around Cambridge is generally clear, well thought out and balances various important issues including anticipated need, climate change, and making use of existing sites. The plan forecasts around 40000 new homes over the period, which assuming a conservative mean of 2 people per home is at least an additional 80000 people in the GC area. Transport links in Cambridge are already unfit to cope with existing demand leading to significant congestion and making it dangerous for active travel. Current transport proposals do not adequately deal with these significant issues.

The number of homes being targeted appears too high. An initial high-level observation is that ~48 000 new homes on top of ~124 000 that exist today, a huge increase of nearly 40%, is unquestionably character changing. And not in a positive way.

2041 is a long time away and we have seen how monumentally working habits have shifted in the last 18 months during the pandemic. Working from home, or at the very least hybrid working, is now widely accepted. This trend has been irreversible kicked into gear and there is no returning to the world pre-2020. As such, whilst still offering some value, the absolute requirement to have housing located adjacent (or at least in relatively close proximity) to job locations is starting to diminish. Devon and Cornwall have seen major spikes in demand from those working in urban locations (e.g. London) that are now expecting to work from home for several days per week (or full time). The same logic will apply in the Cambridge area for many jobs, meaning that there is unlikely to be a requirement for substantially more homes than previously forecast by 2041, and there may even be a reduced requirement. This is despite a more rapidly growing forecast of local jobs (which may or may not be correct).
Hence some demand for housing can actually be satisfied by sites outside of Greater Cambridge (and potentially a long way afield) without significant detrimental impact on the environment (or at least substantially less than has been modelled).
That being said, for those not seeking to work from home (at least part time), housing in close proximity to jobs remains important. Hence there will of course be a significant demand for future housing, though this may largely be met by the previous forecast of approximately 37 000 new homes by 2041. In this context, SCDC’s aims and objectives for locating housing serving local jobs in the areas where those jobs will arise is valid. This points very clearly to any future additional sites beyond those identified in the First Proposals needing to focus on the area south of Cambridge. New settlements remain the best overall method for achieving new housing (see my response on policy S/DS).
With regard to the First Proposals, notwithstanding my comments on whether the number of homes being targeted may be too high, and a general future aim to focus further development on the areas south of Cambridge, the specific sites identified to meet the targeted number of homes do appear to be largely sensible. SCDC has correctly focused on large sites within the Cambridge city limits and on new settlements, with only very limited development within villages. Whilst the level of development within villages is still too high, the efforts to minimise this are recognised. In relation to Green Belt land in particular, it is of vital importance that an even greater reluctance to release this land for development is adhered to in the future. The exceptional circumstances cited to this point for some sites are debateable as to how exceptional they really are – and this is a slippery slope that is best avoided altogether.

West Wickham Parish Council supports the spatial strategy and level of development proposed for villages.

The Trumpington Residents' Association supports the general principles. We note that larger scale developments are being focused on the edge of Cambridge to the north west, north and north east of the city centre and new settlements such as Cambourne, Northstowe and Waterbeach (Figure 4), with limited additional housing in the immediate area of Trumpington.

With respect to Fig. 4, we are critical of the omission of the housing which is proposed as part of the Cambridge Biomedical Campus development: it is very misleading to omit this (c. 5000 homes, Site 056).

Object – whilst we have no objection to the principle of the proposals, the delivery of 44,000 new homes and 19 new sites should be increased to cover the number of houses developable under site JDI number 40509; Land to the south of Babraham Road and east of site H1c, Sawston which has been incorrectly omitted from the assessment. Site 40509 performs equitably with some of the current sites included for allocation and exceeds them in terms of access to amenities and sustainability. If the assessment is to be equitable, then site 40509 must be included going forward or the existing allocations within the rural Southern Cluster and Rest of the rural area should be omitted. The reason the claim that site 40509 has been incorrectly omitted is being made is set out below:

We submitted a site under the original call for sites JDI number 40509; Land to the south of Babraham Road and east of site H1c, Sawston. It appears on the First Conversation Site Submission Map.

On review of the Greater Cambridge Local Plan – First Proposals documentation we have concerns that there has been an error in the assessment of this site.

On review of the HEELA in the First Proposals Document Library,:
• Site 40509 is Listed in Appendix 1 – Full List of Sites.
• It is not included in Appendix 2 which is the Not Deliverable/Developable lists. One therefore assumes it is considered to be a deliverable/developable site.
• A version of the site reference (40509a) appears in Appendix 3 which are the discounted sites, with the justification of it being a ‘duplicated site’.
• It appears in Appendix 4 with a detailed proforma showing it as having one Amber and two Green assessments – see attached extract.

In accordance with the information in the HEELA, we have then reviewed the Strategy Topic Paper. The Strategy Topic Paper confirms that all sites which met the Key Criteria for assessment should be:

‘• Locations with sustainable access: Rural Centres and Minor Rural Centres, but also Group villages with very good Public Transport Access.
• Sites with a green or amber rating in the Housing and Employment Land Availability Assessment’

both of which site 40509 complies with, being on the edge of Sawston which is a Rural Centre with good access to amenities and having met the Amber/Green HEELA threshold.

However, the Strategic Topic Paper makes no reference to site 40509. The site location falls under the ‘Other Site Allocations in the Southern Rural Cluster’ section but does not appear in either the ‘New Allocations’, ‘Continuing Allocations’ or ‘Allocations Not Proposed to be Taken Forward’ subsections. As a new site which met the threshold for assessment within the Strategic Topic Paper, presumably it should be referenced somewhere as either included or not included?

The Strategic Topic Paper assessment refers to the need to continue with the allocation of site H/1:c. Site 40509 abuts Site H/1:C and could therefore reasonably be confused with being part of it. We had assumed the reference within the Appendix 3 of the HEELA to site 40509a being a duplicate was an administration error and that the site was inputted twice, however, with it not appearing within the Strategic Topic Paper, it appears that it has been confused as being part of Site H/1:C and therefore incorrectly removed from assessment going forward.

To address this issue and remove our objection:
• the site should be removed from the HEELA Appendix 3 as a duplicate.
• It should then appear within the Strategic Topic Paper as a site which meets the Key Criteria.
• It should appear in the assessment of ‘Other Site Allocations in the Southern Rural Cluster’
• Based on the fact that it performs equally in terms of Amber and Red and is in a more sustainable location than some of the currently allocated sites within the Southern Rural Cluster, on the basis of the best performing sites being taken forward, it should be included as an allocated site.

44,400 new houses from 2020 to 2041 in addition to the existing 124,389 => 35.7% growth in 21 years. The existing housing stock will take the available carbon budget and the available water supply without a solution to those problems this growth is irresponsible. Just saying that this problem is out of scope for the local plan or you are “only acting under orders” from the planning inspectorate does not wash for me. This local plan will make things a lot worse. You need to work with others to identify solutions before going ahead with this.

Bartlow Parish Meeting strongly supports the proposals, and in particular the section that we want "our rural villages to continue to thrive and sustain their local services, but we don’t want to encourage lots of new homes in places where car travel is the easiest or only way to get around." The emphasis on putting planned growth where the infrastructure is there to support it is entirely correct.

Climate and environment good.
Overoptimistic and unrealistic vision of growth. Number of homes, residents and businesses, too high for natural resources available.
N East Cambridge plan not necessary and too large. Should be stopped immediately. New City District not needed. If relocation of water treatment approved will be insufficient water for needs of the further homes and jobs planned. Already an oversupply of residential homes within the city boundaries. 10 storey buildings too high; 4 stories max. anywhere. 300 homes per hectare still too dense. Only local shops, Newmarket Road etc. nearest. Huge impact on Milton Road/Elizabeth Way/ A10 north. No mention of retired for balanced community.

Encouraging more jobs and homes counter-productive to climate change efforts.
Far too ambitious for the water that is and will be available. Higher than government advised

Greater Cambridge is experiencing unprecedented levels of economic growth, relating to an increase in jobs of over 32% across the plan period. This approach acknowledges the level of economic growth required and that the previous Local Plan Strategy severely underestimated the level of economic growth attainable. The recognition of this economic growth potential is supported, but it must also be acknowledged that over recent years jobs have been created faster than new homes have been built. This has led to reliance on employee in-commuting from surrounding areas to fulfil the employment requirements, conflicting with the Council’s aspirations for sustainable communities and the aim to adopt an environmentally sensitive approach. In reality this means that it is essential for the Plan to recognise these pressures and respond intuitively with regard to providing more supply into the local housing market area, at appropriate locations that meet the needs of the new employees and in-migration residents. The most effective way for the Council’s development strategy to respond to these influences is through a substantial increase in housing provision, which is recommended to be at least 15% above that currently proposed. Such a level of increase would be able to reflect the level of economic growth that has been experienced across Greater Cambridgeshire and will reflect the aspirations for further investment in job creation and industry that is envisaged through the emerging strategy. The correlation between economic growth and housing provision must be recognised for the strategy to be effective, positively prepared and aspirational.
The strategy of directing development to areas that have the least climate impact is recognised as a sustainable approach, however this approach ignores the requirements or rural communities and related economic production.
Nonetheless concern is raised in respect of the approach to dealing with villages in the emerging Local Plan where only low levels of new homes are proposed. This would lead to an outcome that would run counter to the national policy objective of supporting and promoting the provision of mixed and balanced communities. This could lead to a trend of the vitality and long-term future of rural communities being threatened.

Greater Cambridge is experiencing unprecedented levels of economic growth, relating to an increase in jobs of over 32% across the plan period. This approach acknowledges the level of economic growth required and that the previous Local Plan Strategy severely underestimated the level of economic growth attainable. The recognition of this economic growth potential is supported, but it must also be acknowledged that over recent years jobs have been created faster than new homes have been built. This has led to reliance on employee in-commuting from surrounding areas to fulfil the employment requirements, conflicting with the Council’s aspirations for sustainable communities and the aim to adopt an environmentally sensitive approach. In reality this means that it is essential for the Plan to recognise these pressures and respond intuitively with regard to providing more supply into the local housing market area, at appropriate locations that meet the needs of the new employees and in-migration residents. The most effective way for the Council’s development strategy to respond to these influences is through a substantial increase in housing provision, which is recommended to be at least 15% above that currently proposed. Such a level of increase would be able to reflect the level of economic growth that has been experienced across Greater Cambridgeshire and will reflect the aspirations for further investment in job creation and industry that is envisaged through the emerging strategy. The correlation between economic growth and housing provision must be recognised for the strategy to be effective, positively prepared and aspirational.
The strategy of directing development to areas that have the least climate impact is recognised as a sustainable approach, however this approach ignores the requirements or rural communities and related economic production.
Nonetheless concern is raised in respect of the approach to dealing with villages in the emerging Local Plan where only low levels of new homes are proposed. This would lead to an outcome that would run counter to the national policy objective of supporting and promoting the provision of mixed and balanced communities. This could lead to a trend of the vitality and long-term future of rural communities being threatened.

The Plan recognises that due to Greater Cambridge’s strong economy, over recent years, new jobs have been created faster than new homes have been built. This has led to higher house prices and increased commuting into the area.
We therefore consider that the Plan should be aiming to deliver enough homes to meet and boost the area’s housing delivery in order to help reduce these trends of high house prices and high levels of commuting as soon as possible.
In particular, we note that the Development Strategy Topic Paper outlines that both the Employment Land and Economic Development Evidence Study and the Greater Cambridge Housing and Employment Relationships Report show that should the Authority plan for the minimum housing figure set by the government’s standard method alone, this would not support the levels of employment provision expected to arise within Greater Cambridge between 2020 and 2041.
The Plan therefore proposes to deliver what is referred to as the “medium level of homes” which have been calculated in response to the “central employment scenario” or “medium level of jobs” as defined within the Council’s Employment Land Review. The medium level of jobs is considered to be the most likely outcome as it takes into account long term historic patters of employment including the fast growth of key sectors in the Greater Cambridge economy. It is therefore considered to be a broadly logical basis for setting a housing figure for Greater Cambridge. It is noted that this results in a need for 44,400 homes overall (an annual need of 2,111 dwellings), which is taken forward in Policy S/JH: New jobs and homes.
We do welcome the approach of setting a higher housing figure based on the area’s strong economic growth. However, we also believe the Plan should seek to accommodate further housing growth, should either the planned supply not come forward as anticipated or if other economic drivers (which are not currently known), such as growth of existing industries within the area occurring faster than currently anticipated during the plan period. This will ensure the Plan is responsive to changing circumstances during the Plan period.

Many of the housing and mixed-use allocations that have been outlined in the First Proposals document (Figure 4) have been carried forward from the Councils’ existing Local Plans. As these sites have already been through an examination process Huntingdonshire District Council have no objections to the location of these developments.

Figure 4 also identifies accelerated delivery at Waterbeach and Northstowe. At Northstowe, supporting documents identify that this will be as a result of using modern methods of construction Huntingdonshire District Council concur that off-site modular construction can assist in accelerating delivery on sites. The Council would like to ensure that faster delivery on sites does not impact on infrastructure provision and services in the surrounding areas, this would include access to GP surgeries, transport networks etc and recreational pressure on green infrastructure e.g. Fen Drayton Lakes.

The Councils’ major locations for growth are directed towards “where it has the least climate impact, where active and public transport is the natural choice, where green infrastructure can be delivered alongside new development, and where jobs, services and facilities can be located near to where people live.” Huntingdonshire District Council agree that this is the most sustainable growth option and can reduce the climate impact of commuting. The Council concurs that 2041 is an appropriate date for this plan period given the level of uncertainty over the routing and delivery timeframes of major transport infrastructure projects including East-West Rail and the Oxford to Cambridge expressway. It is considered that it may be appropriate for subsequent plan reviews to consider a longer plan period to reflect these major infrastructure projects and to consider other large scale strategic sites to reflect these opportunities.

It is also agreed that growth in rural areas should be based around where there are good public transport links and services. This provides opportunities to promote reduced car travel. To encourage a shift towards more sustainable modes of travel these principles must be fully integrated into the design of new development and available by the time the first residents occupy properties or businesses move in (as appropriate). This will help to ensure that residents and employees adopt sustainable transport choices from day one, reducing the draw towards car usage as a result of an initial lack of alternatives.

Alongside the growth of the Cambridge Urban Area and on the edge of the City, the First Proposals document states that Greater Cambridge wants to make “the most of their existing and planned public transport links to Cambridge and other centres.” Relying on planned transport projects will leave the Plan vulnerable to challenge and exposed at a late stage of the process if delivery of these projects is delayed. We believe more focus should be given to growth around existing infrastructure such as the railway line to the south west of Cambridge which links existing communities into London and Cambridge.
The Shared Planning Service should do more analysis on this sustainable transport corridor. In particular, Meldreth and Melbourn (considered together) form an extremely sustainable area to live and work and travel sustainably to other central areas for work and leisure.
The Shared Planning Service should look at existing settlements and make sure that development helps to increase natural organic growth of these settlements. It should be seen as an opportunity to increase the viability of smaller settlements by locating growth within the existing communities rather than focusing the majority of all growth numbers to relatively new communities on greenfield land surrounding Cambridge.
By not allocating significant growth in the areas such as Meldreth/ Melbourn, Greater Cambridge are missing an opportunity to harness the existing qualities of existing communities.

The scale and high density of housing development at North East Cambridge is not supported

Greater Cambridge Shared Planning specifies that neither the Local Plan nor NECAAP require the relocation of CWWTP ie neither is dependent on it (Ref. Page 6 Appendix 2 PINS Scoping Opinion - GCP's response to Scoping Report - https://infrastructure.planninginspectorate.gov.uk/wp-content/ipc/uploads/projects/WW010003/WW010003-000028-WW010003%20-%20Scoping%20Opinion.pdf

The housing development allocated to S/NEC is reliant upon the relocation of CWWTP to the Green Belt

There is no existing or emerging  Local Plan allocation or justification for development of the Green Belt to accommodate or fulfil S/NEC

There is no operational requirement for AW to relocate to the Green Belt, the existing site was future proofed in 2016 and has capacity to accommodate the scale of development presented in the emerging Local Plan and beyond.  The single driver for relocation is at the request of Cambridge City Council to seek a viable alternative site for CWWTP in order to release a brownfield site for housing development . This interdependency cannot be separated in consideration of the effect of S/NEC Policy.

S/NEC policy is one step away from housing development on the Green Belt with no allocation or examination in a Local Plan, it is dependent on it.

S/NEC should be removed from the Local Plan until after the DCO outcome or an alternative presented that is attainable without relying on the relocation of CWWTP and can be examined under the usual Local Plan Sustainability Appraisal.

A medium level of redevelopment (Option2) of NEC was identified as deliverable without relocation of CWWTP in the AAP Options Consultation 2014. This included a forecast of 15,000 jobs matching  those now allocated in S/NEC and  440 homes.     

The  4,000 homes  allocated to S/NEC in the plan period to 2041  could be reallocated elsewhere within the City boundary eg an additional 1,000 Cam Airport ; 1-2,000 Cam Bio-Medical Campus; 1,000 identified Areas of Major Change.

The balance to full build out of NECAAP beyond the plan period could be accommodated by Cambridge Airport (up to 7,000 allocated to full build out) and further allocations eg as identified in S/CB & S/NS at which time planned sustainable transport developments will be in place addressing Carbon emissions for work journeys.

If DCO successful counted houses  gained counted as ‘windfall’ in plan period

A case can be made on the basis of sustainability eg unknown water resource; impact of COVID  on home working,  preferred housing locations and demand for office space for a reduced Growth Option to Medium or Minimum. In either case this would reduce the requirement of additional housing in the plan period by at least 2,500 determining 1500 only of the 4,000 homes allocated to S/NEC requiring re-allocation amongst other sites.

All emerging Local Plans are required to be flexible, in addition, during the plan period 5 year reviews protect from over or under development. However, in the case of S/NEC the housing allocation is driving the DCO process and there is no flexibility. If successful, within 2 years only despite neither the Local Plan or NECAAP requiring it or there being any allocation of Green Belt been made in a Local Plan, relocation of AW to the Green Belt will go ahead with all the environmental consequences associated with it. 

S/NEC, as presented in the Local Plan, is not flexible and the environmental effects as a result of the requirement of the relocation to fulfil it are contrary to the Aims and Vision of the Local Plan and environmental Policies GP/GB; BG/GI ; BG/RC ; BG/PO ; BG/EO.

The development targets for housing in Greater Cambridge 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 .

The Medium plus Growth Option is not supported, a Minimum or Medium Growth Option is recommended requiring an additional 3,000 homes (rounded & incl 10% buffer) and Medium Option an additional 8,500 homes (rounded & inlc 10% buffer). [figures pg.84 of the SA and pg.42 of Development Strategy Topic Paper]

The development strategy of Densification is not supported; greater focus on bringing sustainable transport initiatives to the fore from outside the Greater Cambridge Area for example improved rail links, Newmarket /Ipswich line are recommended for example

The housing development at North East Cambridge is not supported, a focus on employment growth in the area and improved sustainable public transport from within Cambridge City, Greater Cambridge and the wider region is recommended.

I applaud the desire to minimise environmental impact, and therefore to avoid encouraging “lots of new homes in places where car travel is the easiest or only way to get around”. However, this plan should also be aiming to reduce the environmental impact of transport, and to that end public transport to villages needs to be significantly improved.

In many villages car transport will nevertheless have to remain a mainstay of local transport, and if there is a significant move to electric vehicles, the plan needs to ensure that the electricity supply infrastructure is sufficient to meet this need.

Housing targets for Greater Cambridge 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. Minimum/Medium Growth Options can be justified with the known limitations of sustainability. Greater focus on bringing sustainable transport initiatives to the fore in the plan period from outside the Greater Cambridge Area eg improved rail links, Newmarket /Ipswich are recommended. Housing development at NEC is not supported, a focus on employment growth in the area only supported by sustainable public transport within the City and wider Region is recommended.

It is agreed that the rate and position of new development should be governed by local need, and by local we are referring to local jobs to reduce travel to work times and, more importantly, to be more sustainable.

We note that previous plans, that many large scale developments have been included mainly to the North of Cambridge (e.g. Northstowe, Marleigh, Waterbeach and Darwin Green) the last of which was included in the 2008 Plan but Darwin Green within the parish of Impington) has still not had a single house built. Unfortunately, the major growth in jobs has occurred to the South of the City, primarily on the Biomedical campus. This requires increased traffic to work through and around Cambridge City. We understand the new Plan can not undo the previous allocations even though they by their location offend against the sustainable development location ideals incorporated in the draft plan. However, we would expect there to be new policies in the new local plan to outweigh the negative effects by placing more stringent requirements on developers for sustainability criteria.

The plan is based on job “needs” in the area, translated into housing “needs”. However, these are based mostly on projections of previous growth rates, with insufficient challenge as to whether similar continued growth is either “needed” by the citizens of Cambridge, or indeed feasible without very significant worsening of the following factors that are already acknowledged to be key problems for Cambridge:
* transport infrastructure
* housing affordability
* water scarcity
* social and economic inequality
* access to shared civic spaces
* access to green spaces
* ecosystem pollution and the generation of waste products
Endless growth is of course not theoretically possible in a physical world of limited resources. There are always factors which increasingly make further growth more unattractive, costly, and dangerous to the entities living in the growth system. What models does the Planning Service have to determine likely limits to growth of the Cambridge economy?

This consultation process was begun before COVID, when the world was significantly different. Lessons from past pandemics (e.g. black death and 1918 flu) teach us we must not underrate the capability that these events have to rewrite the society’s rules: where and how people work will change as jobs move to virtual and/or remote locations. Furthermore, some sources are predicting global population _decline_ as a potential scenario. Combining these long-term effects with short-term impacts from UK govt anti-immigration policies suggests that overall housing need should be re-evaluated and may, in fact, be far too high as stated here.

44,000 homes is too many because the region is already environmentally stressed and economically overheated..
The constraints on water supply and disposal and the infrastructure such as electricity and transport are serious and must be recognised. Higher rates of growth could be counter-productive if traffic congestion gets worse and further environmental degradation occurs through drying up of rivers and unacceptable sewage releases

For this reason we would only support the absolute minimum number of new homes, ie around 37400, of which most are already in the planning pipeline.

Development should be focussed on upgrading and retrofitting existing buildings, unless it could be shown that this would result in higher lifetime carbon emissions than demolition and new build.

We support proposals for change of use of existing buildings, where this can be done without compromising the standards of the result (eg for habitable space, light and energy efficiency of residential units) or for the community.

We support proposals for change of use of existing buildings, where this can be done without compromising the standards of the result (eg for habitable space, light and energy efficiency of residential units) or for the community.

As a consequence of the last local plan there are 35,000 housing units in the pipeline. We don’t understand why this plan has exceeded the government target. Growth in Cambridge is outstripping infrastructure in transport, water supply, wastewater management and the effects on facilities within the historic city. Coton Parish Council is concerned about the level of growth along the A428 corridor and on the W and NWC site. The greenbelt and natural environment of the Coton Corridor are vital to the wellbeing of the population and should not be turned into a new transport corridor to serve unsustainable growth.

Broad context
The plan area has an economic dynamic driven, in the main, by firms meeting exogenous demands for their expertise, intellectual property and products. This has resulted in local demands for employment space and houses that outrun the growth of property provision. In consequence both rents and house prices have risen sharply.
The exogenous growth achieved by Cambridge firms is broadly beneficial to the UK economy as a whole and derives significantly from investment in research and development. It is possible that the levelling-up agenda may lead to some scaling back of central Government funding for Cambridge-based R&D, although the findings of recent research suggest this would be damaging to the national economy, as our area is notably outstanding in the commercialisation of R&D. Moreover our area is also notable for the expenditure on R&D by businesses (BERD).

The decision not to use the Standard Method set out in the NPPF and PPG as the basis for estimating housing needs and jobs is clearly wise given the distinctive nature of the local economy. However, deciding what level and trajectory of jobs increase to project as the basis for the plan is far from straightforward. This would have been true even in times of a settled global economy. In present times there are multiple and various further complications.

Issues which are problematic for forecasting
Even prior to Covid, there were signs of some waning enthusiasm for globalisation and consequently a certain amount of on-shoring. The disruption to supply chains from the pandemic and geo-political concerns about national security, notably in relation to China and Russia, are likely to prompt further re-adjustments to business location. Policy responses to climate change will have further impacts on both consumption and where goods are produced that have implications across the UK as a whole.

More locally, both individuals and companies are in the process of adjusting to new ways of working. People who can work more from home may seek more domestic space than hitherto and be willing to live further away from their workplace in order to afford it. Equally, some firms may be expected to re-evaluate space requirements if their employees come in less often.

Projecting forwards is especially tricky when timeseries-based trends are quite likely to have been disrupted by turning points. For a number of data sets, such as commuting, this is exacerbated by their latest evidence being from the 2011 census. By Spring 2022 more recent data will start to become available, but they will have been gathered, thanks to Covid, during a period of great disruption and uncertainty.

These issues are compounded by the fact that the economic geography of the area covered by the plan is unhelpful – though combining SCDC and CCC is a significant improvement. More specifically, the cheaper housing that Cambridge so desperately needs can most realistically be looked for to the North, East and (possible a lesser extent) the West but, as clearly shown in the map of currently proposed sites for development, it is to the East and, to a lesser extent, the North that the plan boundaries are most tightly drawn – thereby excluding settlements such as Ely, and Newmarket.

A final point underlining the fragility of forecasts is that given the size of greater Cambridge, the strategic decisions of a few key players can radically change the context. For instance, how likely is it that a forecaster would have predicted the arrival of Astra Zeneca? And, looking forwards, how certain are we of the intentions of the Marshall Group – who have just indicated that they will sell their motor business?

In view of the difficulties summarised above, I have tried to consider whether the impacts from over-allocating land for jobs is better or worse from making an under-allocation. My tentative conclusion is that over-provision but it is very tricky to think through all the impacts and attaching weights to their reflect their relative importance is inevitably subjective. A more robust conclusion is that it is vital for implementation of the plan to be informed by a regular review of the quantum, composition and location of job growth and to be agile in making appropriate adjustments across the full range of topics that the plan covers.

I would like to know if you have planned for water provision for all of these developments? Where will they source water and what are you going to do to maintain the health of the Cam and its associated chalk streams. Our water courses are the blood that sustains us. Without a healthy water course there is no point in talking about the other environmental measures you are taking.