S/JH: New jobs and homes

New jobs

2.14. The Cambridge economy is internationally significant and sits at the heart of three economic corridors. Its’ influence therefore extends far beyond Greater Cambridge. There are really important key sectors located here; research & development, professional services, health and care. Nevertheless, the joint authorities recognise the need for a mixed economy providing a wide range of jobs, whilst maintaining the global reputation of Greater Cambridge for innovation.
2.15. The evidence base documents within the First Proposals consultation make clear that the effect of this highly successful local economy is that it comes at a cost; high house prices and low levels of affordability, leading to increased commuting distances and associated carbon emissions impacts. There is also a potential threat of de-population from Greater Cambridge with economic migration to more affordable areas, especially if working patterns in the knowledge economy are increasingly flexible and supported by technological advances.
2.16. We understand that the approach taken to forecasting jobs has involved looking back, to review both recent and longer-term employment trends, but also a look forward using the standard regional economic forecast as a baseline. The conclusions set out in the evidence base have been towards promoting a ‘central scenario’ seen as ‘most likely’ accounting for longer terms patterns of employment growth, but with acknowledgement of recent fast growth in key sectors.
2.17. However, there has also been a ‘higher scenario’ considered, which is seen as ‘plausible’, and which places greater weight on the recent fast jobs growth in the key sectors. It is also noted that there has also been accelerated growth in jobs generally in recent years.
2.18. There is a difficulty (that is recognised in the GL Hearn ‘Housing and Employment Relationships Report’) in delivering the homes to match job provision, and a recognition that existing (2011 Census) commuting patterns would expect Greater Cambridge to continue to be a net importer of labour. The minimum growth model takes the number of houses that would derive from the Government standard method to calculate the number of jobs that this would support; whereas the higher growth model takes more specific account of evidence of job forecasting in Greater Cambridge, and uses that to calculate the homes required to support it.
2.19. MGH asserts that, if the objective of the plan is a successful economy that can continue to thrive and meet the local authority carbon emissions targets, it will need the homes to match jobs, or commuting will increase. Alternatively, the policy would need to be to deliberately constrain job growth, which, in our view, does not comply with government policies or the Arc strategy. Given the very particular, arguably exceptional, ambitions for growth in Greater Cambridge the latter approach would be unlikely to be found sound.
2.20. Savills undertook an Employment Market Assessment in July 2020, on behalf of MGH, which indicates that the Cambourne office market, while smaller compared to other urban areas in the region, has a diverse business sector base comprised of companies in the knowledge economy. This mix is comparable to that found in Cambridge and signifies that Cambourne is already seen as an attractive office location. Cambourne’s office rents are competitive compared to other regional markets in the wider area and there is a good level of high-quality office premises.
2.21. The industrial market in Cambourne was assessed in the same study as being limited at present, compared to main industrial locations at Bedford and Cambridge and, to a lesser degree, Biggleswade and Huntingdon. Bedford and Cambridge dominate the ‘large sheds’ market (over 10,000 sqm) while the other locations cater more for ‘mid box’ industrial sheds (2,000 - 5,000 sqm). However, much of this stock is assessed to be in need of renewal, which could provide an opportunity for Cambourne in the near to medium-term.
2.22. The Employment Market Assessment also indicated that the new EWR station and other mass transit proposals would enable a significantly larger labour catchment to access North Cambourne via public transport modes. We estimate that this could achieve a theoretic modal shift from car to rail within the 30 and 45-minute drive time catchments of more than 50%. This point is explored in further detail in Section 4 of our vision document. This shift would help underpin future investment, given the importance placed by businesses in having access to suitably qualified staff.
2.23. Much of the existing and future (once EWR is operational) local labour catchments have skill levels higher than the national average, which would benefit office-based occupiers in particular. The Savills employment study also identified the positive impact that new rail stations across the UK have had on their local commercial markets within a 2-mile radius. These positive impacts included reduced vacancies, higher rents, and increased leasing activity and new deliveries compared to their relevant regional markets. Based on these factors we estimate that Cambourne could capture up to 15% of future office growth within its office market area and up to 5% of its industrial market area.
2.24. From the Savills Employment Market Assessment this translates to:
• 37ha of office land (or 185,000 sqm of office floorspace) over 20 years or 55ha (278,000 sqm) over a 30-year period, based on a 50% plot ratio;
• 11ha of industrial land (or 43,000 sqm of industrial floorspace) over 20 years or 16ha (65,000 sqm) over a 30-year period, based on a 40% plot ratio.
2.25. Our ambition for North Cambourne, contained within the vision document and illustrative masterplan, therefore indicates much more than the 40,000 sqm of employment space shown in the previous SHLAA submission.
2.26. The masterplan in the vision document shows a large area of employment space together with the homes that can be accommodated at North Cambourne, that equates to just over 1 job per home. We would also wish to generate more jobs within the existing areas of Cambourne, in order to rectify the current imbalance of 0.35 jobs per home that presently exists within the settlement and which gives rise to high levels of out-commuting.
2.27. Overall, the importance of a job led approach, incorporating a realistic assessment of local economic factors and the ability to deliver housing that supports the labour market in a sustainable way, is critical to the strategic policy for Greater Cambridge and meeting the wider economic objectives for the Arc. These objectives will be supported by the growth proposed at North Cambourne.
New homes
2.28. The recognised need is to provide homes consistent with the forecast jobs (as detailed in the ‘Housing and Employment Relationships’ report).
2.29. The Greater Cambridge LPAs have explained that the proposed housing quantum is derived from understanding workplace populations, commuting patterns and resident populations, and has also involved testing likely commuting patterns. The housing forecast is associated with the most likely central employment scenario, and assumes that all the additional homes generated by forecast jobs above those supported by the standard method will be provided in full within Greater Cambridge.
2.30. The table below identifies the scenarios in the First Proposals consultation that have been assessed in seeking to identify the overall position on Objectively Assessed Need. Importantly, we understand that the jobs are proposed across all employment sectors, including business, retail, leisure, education and healthcare.
Homes 2020 - 2041 Jobs 2020 - 2041
Minimum Growth – Gov Standard Method 36,700 45,800
Per annum 1,743 homes 2,181 jobs
Central Scenario – ‘Most likely’ 44,400 58,500
Per annum 2,111 homes 2,786 jobs
Higher Scenario – ‘Plausible’ 56,500 78,700
Per annum 2,690 homes 3,748 jobs
Table 2.1 – Homes and Jobs Scenarios in the First Proposals Local Plan 2041

2.31. The table above suggests a changing factor of 1.24 to 1.31 to 1.39 jobs per home, as the numbers increase. We suggest that this, in turn, could potentially increase the amount of displacement and commuting. This is particularly relevant in Cambourne, where the job to home ratio is currently low. Furthermore, it is accepted by the joint authorities that planning for the standard method of calculating homes would increase the risk of higher levels of commuting.
2.32. It is also notable that an independent economic review has suggested an even higher number of jobs could be created, based on the recent accelerated growth in some sectors. The consultation document highlights that the Cambridgeshire and Peterborough Independent Economic Review (CPIER) says: “A distinguishing feature of [Cambridgeshire and Peterborough] is how strongly it has grown recently… This has been driven primarily, but not entirely, by rapid business creation and growth in the south – Cambridge and South Cambridgeshire.”.
2.33. In conclusion, MGH would strongly support the higher scenario for jobs and housing that has been assessed, given that it is seen as ‘plausible’, and also that the recent trend demonstrates accelerated growth in jobs in Greater Cambridge. It is this level of growth in jobs that should guide the housing targets in order to avoid local labour shortages causing damage to the economic potential of the area and / or giving rise to longer distance commuting, which will render the 2030 and 2050 net zero carbon targets unachievable.

The predicted growth forecasts and housing requirements must be revisited in the light of Covid and homeworking.

The existing allocations for employment must be fully utilised before any further release of land (eg S/CBC/A) is permitted. Moreover, no further allocations should be permitted until water supplies have been secured.

see attached

OBJECT

The Greater Cambridge City Deal recognised the relationship between housing and economic growth, and that the shortage of available and affordable housing within Greater Cambridge has an impact on house prices, commuting patterns, and recruitment and retention of employees. The Cambridgeshire and Peterborough Devolution Deal committed to delivering substantial economic growth and to double economic output during the next 25 years. The 2018 Cambridgeshire and Peterborough Independent Economic Review (CPIER) identified that recent employment growth has been faster than anticipated, and the aim of doubling economic output in the area by 2040 was realistic. It was suggested in CPIER that economic growth could be achieved by attracting knowledge-intensive businesses that would not locate elsewhere in the UK, by delivering new housing, and by prioritising infrastructure projects. The National Infrastructure Commission, the Cambridge and Peterborough Combined Authority and the Greater Cambridge Greater Peterborough Enterprise Partnership acknowledge and support the economic growth potential of the Greater Cambridge area, and consider that there is a need to substantially increase housing delivery in order to support that economic growth and address the significant housing affordability issues that exist. At present there is an imbalance between rates of economic growth and housing delivery in Greater Cambridge.

All these factors support a significantly higher number of homes than are proposed in the preferred ‘medium plus’ growth option of Policy S/JH. It is considered that the ‘medium plus’ growth option makes insufficient upward adjustments to the housing requirement (from Section Id.2a of the Planning Practice Guidance) to take into account growth strategies, strategic infrastructure improvements and housing affordability in Greater Cambridgeshire. The ‘medium plus’ growth option also does not reflect the anticipated growth aspirations of the Oxford to Cambridge Arc Spatial Framework, or that the economic success of Greater Cambridge is of national significance.

It is suggested that the emerging GCLP should have selected the higher growth level option to support economic growth, address housing affordability, and reduce in-commuting. The higher growth level option will require infrastructure funding, but there are existing transport improvements already planned for Greater Cambridge and further investment in infrastructure (e.g. water and electricity) will need to be secured as part of the Oxford to Cambridge Arc.

Requested Change

It is requested that housing and jobs requirements in Policy S/JH are based on delivering the higher growth level option.

OBJECT

The Greater Cambridge City Deal recognised the relationship between housing and economic growth, and that the shortage of available and affordable housing within Greater Cambridge has an impact on house prices, commuting patterns, and recruitment and retention of employees. The Cambridgeshire and Peterborough Devolution Deal committed to delivering substantial economic growth and to double economic output during the next 25 years. The 2018 Cambridgeshire and Peterborough Independent Economic Review (CPIER) identified that recent employment growth has been faster than anticipated, and the aim of doubling economic output in the area by 2040 was realistic. It was suggested in CPIER that economic growth could be achieved by attracting knowledge-intensive businesses that would not locate elsewhere in the UK, by delivering new housing, and by prioritising infrastructure projects. The National Infrastructure Commission, the Cambridge and Peterborough Combined Authority and the Greater Cambridge Greater Peterborough Enterprise Partnership acknowledge and support the economic growth potential of the Greater Cambridge area, and consider that there is a need to substantially increase housing delivery in order to support that economic growth and address the significant housing affordability issues that exist. At present there is an imbalance between rates of economic growth and housing delivery in Greater Cambridge.

All these factors support a significantly higher number of homes than are proposed in the preferred ‘medium plus’ growth option of Policy S/JH. It is considered that the ‘medium plus’ growth option makes insufficient upward adjustments to the housing requirement (from Section Id.2a of the Planning Practice Guidance) to take into account growth strategies, strategic infrastructure improvements and housing affordability in Greater Cambridgeshire. The ‘medium plus’ growth option also does not reflect the anticipated growth aspirations of the Oxford to Cambridge Arc Spatial Framework, or that the economic success of Greater Cambridge is of national significance.

It is suggested that the emerging GCLP should have selected the higher growth level option to support economic growth, address housing affordability, and reduce in-commuting. The higher growth level option will require infrastructure funding, but there are existing transport improvements already planned for Greater Cambridge and further investment in infrastructure (e.g. water and electricity) will need to be secured as part of the Oxford to Cambridge Arc.

Requested Change

It is requested that housing and jobs requirements in Policy S/JH are based on delivering the higher growth level option.

OBJECT

The Greater Cambridge City Deal recognised the relationship between housing and economic growth, and that the shortage of available and affordable housing within Greater Cambridge has an impact on house prices, commuting patterns, and recruitment and retention of employees. The Cambridgeshire and Peterborough Devolution Deal committed to delivering substantial economic growth and to double economic output during the next 25 years. The 2018 Cambridgeshire and Peterborough Independent Economic Review (CPIER) identified that recent employment growth has been faster than anticipated, and the aim of doubling economic output in the area by 2040 was realistic. It was suggested in CPIER that economic growth could be achieved by attracting knowledge-intensive businesses that would not locate elsewhere in the UK, by delivering new housing, and by prioritising infrastructure projects. The National Infrastructure Commission, the Cambridge and Peterborough Combined Authority and the Greater Cambridge Greater Peterborough Enterprise Partnership acknowledge and support the economic growth potential of the Greater Cambridge area, and consider that there is a need to substantially increase housing delivery in order to support that economic growth and address the significant housing affordability issues that exist. At present there is an imbalance between rates of economic growth and housing delivery in Greater Cambridge.

All these factors support a significantly higher number of homes than are proposed in the preferred ‘medium plus’ growth option of Policy S/JH. It is considered that the ‘medium plus’ growth option makes insufficient upward adjustments to the housing requirement (from Section Id.2a of the Planning Practice Guidance) to take into account growth strategies, strategic infrastructure improvements and housing affordability in Greater Cambridgeshire. The ‘medium plus’ growth option also does not reflect the anticipated growth aspirations of the Oxford to Cambridge Arc Spatial Framework, or that the economic success of Greater Cambridge is of national significance.

It is suggested that the emerging GCLP should have selected the higher growth level option to support economic growth, address housing affordability, and reduce in-commuting. The higher growth level option will require infrastructure funding, but there are existing transport improvements already planned for Greater Cambridge and further investment in infrastructure (e.g. water and electricity) will need to be secured as part of the Oxford to Cambridge Arc.

Requested Change

It is requested that housing and jobs requirements in Policy S/JH are based on delivering the higher growth level option.

SmithsonHill supports an approach that reflects the continuing strength of the Greater Cambridge economy which is of national importance and the need to plan for higher employment plus the related housing figures.

USS strongly supports the Local Plan ambitions for 44,000 new homes and 58,500 new jobs across all
employment sectors, including business, retail, leisure, education and healthcare.

Hallam Land Management (HLM) consider the First Proposals do not plan for an appropriate quantum of new jobs and homes having regard to the available evidence.

A Review of Employment Needs Evidence has been undertaken and is submitted with these representations. The Plan should be planning for a minimum of 78,700 jobs and 56,900 new homes to 2041 (the higher growth scenario) for the reasons set out within the Review and summarised below.

In terms of the job growth target and employment floorspace requirement, the following comments are made:

1. In projecting past trends, the floorspace requirement will constrain jobs growth to levels below what has been forecast, particularly the level forecast by the Cambridge & Peterborough Independent Economic Review (2018) (CPIER);
2. The floorspace requirements do not take into account reductions in floorspace over the Plan period as older or lower quality employment land and buildings are redeveloped for alternative uses;
3. The implications of the growth in logistics arising from changes in the economy, including growth in online retailing, should be considered in light of the findings of the update to the Retail and Leisure Study; and,
4. The implications of the growth in Data Centres on the demand for employment floorspace over the Plan period should be considered.

In terms of the supply to meet the employment floorspace requirement, it is noted that a substantial proportion of the identified supply is not available until post 2041. It cannot therefore contribute to meeting the requirement and the jobs target. Additional supply is therefore required, in the form of new allocations.

In terms of the new homes target, HLM do not support the use of the ‘central scenario’ in planning for future population and housing growth. This level of housing growth in particular will constrain employment growth, and either limit Greater Cambridgeshire’s ability to achieve the ‘higher growth scenario’, or as a consequence place greater pressure on the local housing market, worsening affordability.

There is support for the higher growth scenario within the Council’s Employment Land Review (November 2020), and CPIER led by Kate Barker.

It is noted the Councils reject this level of growth on the basis they consider it is not the most likely future scenario. However, it is requested the Councils reconsider this matter in light of submissions made to this consultation, and look to plan to meet this higher growth requirement to ensure that economic growth is not out of kilter with the planned level of new homes.

In relation to the supply to meet the housing requirement, the Councils should be realistic as to the level of growth it considers can be delivered by 2041 on sites. Paragraph 73 criteria d) of the Framework requires the Councils to make a realistic assessment of likely rates of delivery, given the lead-in times for large sites.

This paragraph is particularly relevant to proposed allocations at North East Cambridge, Cambridge Airport, North West Cambridge, and Cambridge East where cumulatively 10,650 homes are planned to be delivered by 2041. This is in addition to existing commitments and assumptions related to windfalls in the City.

The rate of growth is ambitious, and the Councils will need to review its evidence on the issue of delivery prior to the submission of its Plan for Examination to ensure its assumptions are sound, and that the quantum of development is deliverable.

Similar comments are also made in relation to the changed assumptions around delivery rates at Northstowe and Waterbeach New Town which have not been evidenced (see representations made to Policy S/NS).

If the rate of delivery cannot be justified, the Councils should consider making further allocations to address any shortfall in meeting the housing requirement.

It is in this context that HLM consider the Plan should include a new settlement at Scotland Farm. This should either be in addition to the selected locations in order to bolster supply to meet the higher jobs and homes requirement, or as an alternative to those locations selected that are not taken forward in the Plan.

We object to the scale of growth proposed due to the lack of available water supply to support human needs without damaging the River Cam and its tributaries, including chalk streams. This includes impacts on water quality. We welcome that you have recognised this as an environmental limit to growth and that if it is not resolved the plan will not be found sound. Even if the water industry plans are put in place to address this problem prior to the Local Plan going for public examination, there will remain the risk that the water industry plans are delayed or not fully delivered. Therefore, you will need to set out in the draft plan how you intend to deal with this scenario.

Following the designation of our area as “water stressed” and the new evidence that has been obtained through your work, we are very concerned that the level of growth already in the 2018 Local Plan is beyond the environmental limits of our water supply. Water industry plans include reducing household consumption, and whilst this is in theory achievable it may not be achieved in practice. We would like to see policies or mechanisms within the draft Plan that set out how development approvals will be aligned to improvements in water supply, and what will happen if those improvements are not achieved. This is to avoid development running ahead at a faster pace than water supply improvements.

Accurately predicting future jobs and employment space, and their relationship to housing at the current time is incredibly difficult:
• The impact of Brexit on the local economy is not yet known. Many scientific and research projects were part funded by the EU.
• Some large employers are leaving Cambridge (Marshalls and the County Council).
• Hybrid/home-working will change the dynamic between where people work and where they live, this is likely to have a number of consequences for planning:
- hot-desking will increase in offices meaning that individual office buildings will support larger numbers of workers/jobs, this could decrease the amount of floor space required.
- People will commute fewer days per week and therefore will tolerate longer commutes in order to take advantage of cheaper housing (eg to afford home office space and/or garden space). On one hand this may make it harder for new housing in greater Cambridge to compete with cheaper housing further away. On the other there may be additional demand close to Cambridge for London commuters. Either way, it is unlikely that the aspiration to co-locate jobs and housing in Greater Cambridge will be achieved.
• The 2021 census might have given some answers but unfortunately this was carried out during the pandemic, meaning that an important source of planning information will not help as it should have.

Given such uncertainty, it is unlikely that the objectively assessed needs will be accurate. Therefore it is essential that there is ability within the plan to review and make adjustments over time to reflect reality. One danger is that employment land allocated for new towns is unused and applications are made for residential development instead, meaning that these settlements become residential dormitories contrary to the vision set out in the plan. As an example, we are aware that employment sites in Haverhill are now being used for residential, placing greater commuting burden on our area.

In 2019 we met with senior planning officers from East Cambs District Council. They were clear that housing provision in their district was providing housing overspill for Cambridge. They also want to create liveable communities that include employment but they reported that they were struggling to bring forward employment sites for development in places like Ely because of supply and demand provision in Cambridge. There is clearly a strong relationship between greater Cambridge and East Cambs and other market towns in terms of housing and employment provision and we would like to better understand what work has taken place to co-ordinate planning for this.

We act for various landowning clients and we are promoting sites in their ownership for residential development (please see separate representations to chapter S/RAA Allocations in the Rest of the Rural Area).

On behalf of our clients, we make the following comments on the Regulation 18 Preferred Options Consultation.

As set out in the general comments section Pigeon do not support the level of new housing growth proposed, and would encourage a more ambitious level of growth which reverses unsustainable commuting patterns and looks to meet the identified housing need.

Pigeon notes concerns relating to water supply necessary to accommodate a higher level of growth, however this could be addressed through a stepped requirement allowing for the necessary infrastructure to be delivered.

Pigeon supports an approach which identifies new housing targets for future neighbourhood areas which do not form part of the homes figures to be met by allocations.

The Councils are planning for relatively low levels of jobs and housing growth. Other job forecasting models predict much higher levels of growth, including a CPIER proxy developed by Cambridge Econometrics (but not endorsed by CPIER) of 92,100 additional jobs. The Councils’ preferred option is based on an employment growth rate to 2041 for life sciences and other key sectors as the lower quartile between the EEFM baseline and the historic growth rate between 2001-17, therefore planning for reduced economic development in those sectors. As a consequence, there is a likelihood that the Councils ‘preferred option strategy for the Local Plan is based on an under-forecast of employment growth and associated housing need.

We are concerned that actual employment growth to 2041 will not be matched by an adequate level of planned housing land, leading to an over-heated local housing market, increasing levels of in-commuting and commuting distances, congestion, loss of productivity, and harm to wellbeing and social inclusion.

We support the response from Cambridge Ahead.

Marshall recognises the level of growth that has been put forward by the GCSP and the proposed delivery of a number of homes that exceeds the standard methodology calculations. This submission is therefore made without prejudice to that position; however, Marshall does consider that there is opportunity through Policy S/JH to plan for even more ambitious growth.

Page 28 of the Preferred Options Local Plan consultation document explains that one of the alternatives that the GCSP considered was planning for the higher jobs forecast and level of homes associated with it. The report confirms that this alternative was rejected as it was considered that the higher jobs forecast was “not the most likely future scenario” (Page 28). Marshall supports and endorses much of the narrative in the draft Local Plan, which acknowledges the significance of the knowledge-intensive clusters and their importance to the reputation and resilience of the Cambridge economy, as well as recent trends of high economic growth. The scale of Cambridge East means that it is capable of delivering inclusive employment opportunities through the provision of a wide range of jobs for local people. Marshall are committed to delivering a scheme that can generate employment across a variety of sectors and that covers a range of different levels, not just highly skilled jobs. Marshall encourages the GCSP to reflect on the alternatives put forward for this policy and reconsider the opportunity to aspire for greater employment growth that captures the true economic potential of Greater Cambridge. Marshall would be pleased to submit further evidence to the GCSP.

Cambridge East has been identified as one of the key sites that can contribute to the delivery of new employment floorspace, new homes and other community facilities / services that meets the needs of Greater Cambridge. Marshall is pleased that the significant contribution which its land can make to the future wellbeing of Cambridge has been recognised through its draft allocation. Marshall is committed to working positively and proactively with the Councils to ensure that Cambridge East comes forward to optimise its social, environmental and economic potential.

Do we have resources for more development? In particular, Water is in short supply with over-abstraction threatening aquifers and rivers. Suitable transport infrastructure, not car based, with homes close to work.

It is proposed in the consultation that the new Local Plan should meet the following objectively assessed needs for development in the period 2020-2041:
• 58,500 jobs; and
• 44,400 homes (2,111 homes per year).
The consultation document explains that the Councils have chosen to plan for the ‘medium’ or ‘central’ growth levels from the strategic options set out in 2020 and within the Employment Land and Economic Development Evidence Study (November 2020). However, we would note that this Study (paragraph 5.22) itself recommends a preferred range “between a central and higher growth scenario”, rather than just the central growth scenario. Further, the Economic Development Evidence Study should be updated to reflect the response to the Pandemic – which in the case of life science, biomedical and technology has been directed affected since the Study was prepared – to ensure the needs of these sectors are met.

The Cambridgeshire and Peterborough Independent Economic Review (CPIER, 2018) reported (page 9) that:
“Growth in employment has not been matched by corresponding house-building, or developments in infrastructure. Consequently, house prices have soared and journey times have increased as congestion has intensified. This has meant that many have been forced to endure unpleasant commutes, or been priced away from the city altogether due to the unaffordability of rents. This is bad for both people and business, and we believe is an unsustainable approach to growth.”

The Greater Cambridge Local Plan provides a key opportunity to redress the balance between economic growth and housing delivery, to ensure that growth is sustainable and achieves the stated objectives.

We are strongly of the view that a higher objectively assessed need (OAN) figure should be used for the Greater Cambridge area during the plan period 2020-2041 than is currently proposed through the First Proposals, and should reflect at the very least a medium-high economic scenario as recommended, accounting for an updated assessment of need for the reasons set out above.

The consultation document acknowledges the findings of the Greater Cambridge Housing and Employment Relationships Report (November 2020), namely that planning for the ‘standard method’ housing figure would not support the number of jobs expected to arise and that a higher OAN should therefore be chosen. However, we are concerned that planning for the “most likely level of new jobs” (page 25, First Proposals consultation document) and adopting the ‘medium +’ OAN figure does not include adequate contingency for a higher growth scenario – particularly if updated evidence in the light of the Pandemic were to suggest greater need for economic development than currently reported. A key risk is that by not planning for growth, the Local Plan will inhibit growth.

We are of the view that by adopting a higher OAN, informed by up-to-date economic needs for both jobs and homes, the Local Plan would allow for proactive and purposeful forward planning, facilitating and enabling the aspirational growth targets that could potentially be achieved.

We would highlight paragraph 81 of the NPPF in full:
“Planning policies and decisions should help create the conditions in which businesses can invest, expand and adapt. Significant weight should be placed on the need to support economic growth and productivity, taking into account both local business needs and wider opportunities for development. The approach taken should allow each area to build on its strengths, counter any weaknesses and address the challenges of the future. This is particularly important where Britain can be a global leader in driving innovation, and in areas with high levels of productivity, which should be able to capitalise on their performance and potential.”

We consider it to be essential that the vision for the future of the Greater Cambridge area embraces and harnesses the growth potential that it possesses. In land use planning terms, there is a fundamental need to plan for growth and to ensure that sites are allocated to support the development that is integrally linked to this growth.

We would note the conclusions of the Greater Cambridge Local Plan Strategic Spatial Options Assessment Sustainability Appraisal (November 2020) in relation to the growth scenarios (paragraph 4.4):
“…the maximum growth scenario tends to have more significant positive effects, particularly within the plan period, as larger individual developments are likely to be built within the plan period under this option. These have greater scope for providing new services and facilities and being designed in a way that encourages healthy lifestyles. In addition, a higher level of development may be able to provide the critical mass for provision of substantial new infrastructure and environmental enhancements, such as new green infrastructure and provide a greater diversity of homes and jobs.”

In a similar vein, we would also highlight the importance of supporting the delivery of affordable housing. A significant amount of affordable housing is provided alongside market housing in new residential developments. This provides an essential supply to assist in meeting local needs. However, as noted in the NPPF, a range of housing is required to offer choice, rather than an over-reliance on a certain type of housing in certain areas, in order to ensure that mixed and sustainable communities are created and maintained. This approach should include a range of medium and large sites within existing settlements such as villages. Whilst the strategy of focusing growth on new settlements will provide for emerging affordable housing needs, it will not necessarily address the existing local housing needs within the rural areas and villages, nor would it offer sufficient choice. People with local connections are often unable to afford market prices (either sale or rent) and have to move away from their local area and support network. The need to provide for a range of housing needs should be carefully considered in respect of both the OAN and the related spatial strategy.

Our promoted Site at ‘land east of Cambridge Road, Hardwick’ (Site No. 40414) provides the opportunity to deliver a mix of market and affordable housing within a sustainable extension to the existing village. The Site occupies a sustainable location adjacent to the functional village centre, and its development would deliver a range of benefits to the existing settlement and local population.

The Greater Cambridge Employment Land and Economic Evidence Study
(November 2020) identifies a higher jobs growth forecast and due to the significant number of jobs
further housing will be needed. Therefore, it is considered further homes are needed than 44,400 given
the strong relationship between homes and jobs and this is a reasonable alternative. We agree that
homes should include all types, sizes and tenures of housing which should also include self-build given
the significant demand.

OBJECT

The Greater Cambridge City Deal recognised the relationship between housing and economic growth, and that the shortage of available and affordable housing within Greater Cambridge has an impact on house prices, commuting patterns, and recruitment and retention of employees. The Cambridgeshire and Peterborough Devolution Deal committed to delivering substantial economic growth and to double economic output during the next 25 years. The 2018 Cambridgeshire and Peterborough Independent Economic Review (CPIER) identified that recent employment growth has been faster than anticipated, and the aim of doubling economic output in the area by 2040 was realistic. It was suggested in CPIER that economic growth could be achieved by attracting knowledge-intensive businesses that would not locate elsewhere in the UK, by delivering new housing, and by prioritising infrastructure projects. The National Infrastructure Commission, the Cambridge and Peterborough Combined Authority and the Greater Cambridge Greater Peterborough Enterprise Partnership acknowledge and support the economic growth potential of the Greater Cambridge area, and consider that there is a need to substantially increase housing delivery in order to support that economic growth and address the significant housing affordability issues that exist. At present there is an imbalance between rates of economic growth and housing delivery in Greater Cambridge.

All these factors support a significantly higher number of homes than are proposed in the preferred ‘medium plus’ growth option of Policy S/JH. It is considered that the ‘medium plus’ growth option makes insufficient upward adjustments to the housing requirement (from Section Id.2a of the Planning Practice Guidance) to take into account growth strategies, strategic infrastructure improvements and housing affordability in Greater Cambridgeshire. The ‘medium plus’ growth option also does not reflect the anticipated growth aspirations of the Oxford to Cambridge Arc Spatial Framework, or that the economic success of Greater Cambridge is of national significance.

It is suggested that the emerging GCLP should have selected the higher growth level option to support economic growth, address housing affordability, and reduce in-commuting. The higher growth level option will require infrastructure funding, but there are existing transport improvements already planned for Greater Cambridge and further investment in infrastructure (e.g. water and electricity) will need to be secured as part of the Oxford to Cambridge Arc.

Requested Change

It is requested that housing and jobs requirements in Policy S/JH are based on delivering the higher growth level option.

The policy of expanding provision for expanding employment is fundamentally flawed. In essence it is developer and Cambridge University led for their own profit with no consideration of the wider implications of the impact on the housing needs of local Cambridge people and the environment of our City. The local plan should be resisting further commercial development which is driving further inroads into the green belt and the destruction of the unique nature of Cambridge

OBJECT

The Greater Cambridge City Deal recognised the relationship between housing and economic growth, and that the shortage of available and affordable housing within Greater Cambridge has an impact on house prices, commuting patterns, and recruitment and retention of employees. The Cambridgeshire and Peterborough Devolution Deal committed to delivering substantial economic growth and to double economic output during the next 25 years. The 2018 Cambridgeshire and Peterborough Independent Economic Review (CPIER) identified that recent employment growth has been faster than anticipated, and the aim of doubling economic output in the area by 2040 was realistic. It was suggested in CPIER that economic growth could be achieved by attracting knowledge-intensive businesses that would not locate elsewhere in the UK, by delivering new housing, and by prioritising infrastructure projects. The National Infrastructure Commission, the Cambridge and Peterborough Combined Authority and the Greater Cambridge Greater Peterborough Enterprise Partnership acknowledge and support the economic growth potential of the Greater Cambridge area, and consider that there is a need to substantially increase housing delivery in order to support that economic growth and address the significant housing affordability issues that exist. At present there is an imbalance between rates of economic growth and housing delivery in Greater Cambridge.

All these factors support a significantly higher number of homes than are proposed in the preferred ‘medium plus’ growth option of Policy S/JH. It is considered that the ‘medium plus’ growth option makes insufficient upward adjustments to the housing requirement (from Section Id.2a of the Planning Practice Guidance) to take into account growth strategies, strategic infrastructure improvements and housing affordability in Greater Cambridgeshire. The ‘medium plus’ growth option also does not reflect the anticipated growth aspirations of the Oxford to Cambridge Arc Spatial Framework, or that the economic success of Greater Cambridge is of national significance.

If this does not happen, Northwest Biotherapeutics (NW Bio) are concerned that this could result in severe difficulties recruiting talent for the knowledge based jobs that NW Bio is creating in the Cambridge area. NW Bio is already experiencing difficulty with recruitment due to the lack of housing availability in the Cambridge area and the necessity for long commutes to jobs in this area. In addition, the situation will lead to a drain companies from Cambridge and the wider region, not because of lack of interest or commitment but because they are forced to relocate in order to grow and thrive. At present, the growth of Cambridge is being constrained and this is limiting job creation and innovation. There is a lack of good quality specialised laboratory space, resources and housing to support expanding employment opportunities. This is in comparison to the new biotech and technology hubs that are being created or expanded in Oxford and Manchester, as well as elsewhere in the UK, Europe, US and China.

NW Bio’s experience is that cutting edge regenerative medicine companies are investing heavily in key areas such as manufacturing and product development, to build new manufacturing facilities and core competencies in the UK. However, most of the infrastructure and manufacturing facilities have been in geographic areas such as Oxford and the South East (London, Surrey etc).

Despite AstraZeneca choosing to invest in infrastructure investment for research in the Cambridge area, the number of other companies investing into Cambridge has been very limited, often starting in the UK but rapidly moving to the US. NW Bio consider that this is because of a perception that the US is a more favourable market for investment, new facilities and job creation, as well as innovation and embracing risk.

In order to reverse the talent and company drain described above, it is suggested that the emerging GCLP should have selected the higher growth level option to support economic growth, address housing affordability, and reduce in-commuting. The higher growth level option will require infrastructure funding, but there are existing transport improvements already planned for Greater Cambridge and further investment in infrastructure (e.g. water and electricity) will need to be secured as part of the Oxford to Cambridge Arc.

Requested Change

It is requested that housing and jobs requirements in Policy S/JH be based on the higher growth level option.

39. The strategy should be reviewed. More small and medium sized sites should be allocated in the Rural Southern Cluster, provided the sites are very well served by sustainable transport, in order to:
• provide homes where the need is greatest,
• reduce the need for in-commuting by workers at the research parks, and reduce carbon emissions
• improve access to labour in the life science sectors of south Cambridge,
• speed up housing delivery in the first half of the plan
• reduce reliance on windfall sites
• greatly improve housing choices for residents and sustain the villages.

We are concerned that the proposed employment and housing strategy does not fulfil the areas economic potential and as a consequence will have negative, economic, environmental and social impacts.

It is considered that the ‘medium plus’ growth option makes insufficient upward adjustments to the housing requirement (from Section Id.2a of the Planning Practice Guidance) to take into account growth strategies, strategic infrastructure improvements and housing affordability in Greater Cambridge. The ‘medium plus’ growth option also does not reflect the anticipated growth aspirations of the Oxford to Cambridge Arc Spatial Framework, or that the economic success of Greater Cambridge is of national significance.

It is suggested that the emerging GCLP should have selected the higher growth level option to support economic growth, address housing affordability, and reduce in-commuting.

The reference is 40297 (Land adjacent to Babraham, CB22 3AF, CB22 3AP, CB22 3AG, CB22 3AZ). The boundary has not changed. Please see document attached S/JH Comments (1of 5 submissions due to high level of documents).

OBJECT

The Greater Cambridge City Deal recognised the relationship between housing and economic growth, and that the shortage of available and affordable housing within Greater Cambridge has an impact on house prices, commuting patterns, and recruitment and retention of employees. The Cambridgeshire and Peterborough Devolution Deal committed to delivering substantial economic growth and to double economic output during the next 25 years. The 2018 Cambridgeshire and Peterborough Independent Economic Review (CPIER) identified that recent employment growth has been faster than anticipated, and the aim of doubling economic output in the area by 2040 was realistic. It was suggested in CPIER that economic growth could be achieved by attracting knowledge-intensive businesses that would not locate elsewhere in the UK, by delivering new housing, and by prioritising infrastructure projects. The National Infrastructure Commission, the Cambridge and Peterborough Combined Authority and the Greater Cambridge Greater Peterborough Enterprise Partnership acknowledge and support the economic growth potential of the Greater Cambridge area, and consider that there is a need to substantially increase housing delivery in order to support that economic growth and address the significant housing affordability issues that exist. At present there is an imbalance between rates of economic growth and housing delivery in Greater Cambridge.

All these factors support a significantly higher number of homes than are proposed in the preferred ‘medium plus’ growth option of Policy S/JH. It is considered that the ‘medium plus’ growth option makes insufficient upward adjustments to the housing requirement (from Section Id.2a of the Planning Practice Guidance) to take into account growth strategies, strategic infrastructure improvements and housing affordability in Greater Cambridgeshire. The ‘medium plus’ growth option also does not reflect the anticipated growth aspirations of the Oxford to Cambridge Arc Spatial Framework, or that the economic success of Greater Cambridge is of national significance.

It is suggested that the emerging GCLP should have selected the higher growth level option to support economic growth, address housing affordability, and reduce in-commuting. The higher growth level option will require infrastructure funding, but there are existing transport improvements already planned for Greater Cambridge and further investment in infrastructure (e.g. water and electricity) will need to be secured as part of the Oxford to Cambridge Arc.

Requested Change

It is requested that housing and jobs requirements in Policy S/JH are based on delivering the higher growth level option.

The proposed housing requirement evidently aligns with the Central scenario (58,400 jobs) outlined in the Greater Cambridge Employment Land and Economic Development Evidence Study (November 2020) rather than the Higher Scenario, which results in the First Proposals failing to provide the housing infrastructure that would appear to be needed to accommodate a more ambitious level of employment growth.

The Context for Growth and Innovation

1 Paragraph 16b) of the National Planning Policy Framework (NPPF) states that Local Plans will be found sound if they are ‘positively prepared’. In respect of a Plan’s housing requirement, this means that a Plan must ‘as a minimum’ seek to meet the area’s objectively housing need. Paragraph 61 of the NPPF states that the calculation of an area’s minimum housing need should be informed by a local housing need assessment based on the Government’s standard method for calculating housing need. The same paragraph also goes on to confirms that a local planning authority can pursue an alternative minimum figure which “reflects current and future demographic trends and market signals”.

2 Paragraph 81 of the NPPF seeks that planning policies create conditions businesses can “invest expand and adapt”. Significant weight is placed upon the need to support economic growth, both local business needs and wider opportunities. Particular emphasis and importance is placed upon capitalising on opportunities where “Britain can be a global leader in driving innovation”.

3 In considering the jobs and housing requirement it is of vital importance to place great emphasis on the unique role and characteristics of Cambridge and its surroundings in terms of its international role in innovation and key role in the economy not only for the region, but also the wider UK.

4 The ‘Fast Growth Cities – 2021 and beyond’ (March 2021) evidence base document, prepared by Centres for Cities, identifies Cambridge as part of the ‘The Fast Growth Cities Group’ which encompasses some of ‘the most successful and innovative places in the UK”. The document also goes on to state that “Cambridge is one of the most important research and innovation-led employment hubs in the UK” and that Cambridge has “mature innovation systems in place with different strengths and capacity to benefit the entire UK”.

5 As was the case with the existing Local Plans for South Cambridgeshire and Cambridge City, there is a devolution deal in place between the seven local authorities in Cambridge and Peterborough, with the Cambridgeshire and Peterborough Combined Authority created in 2017. The Council’s ‘Development Strategy Topic Paper’ confirms that the aim is to double economic output within 25 years, with an uplift in GVA from £22bn to over £40bn. The Greater Cambridge City Deal also remains a relevant driver for growth in the area with its ambitions to speed up housing delivering, create 45,000 new jobs and provide £1bn of local and national public sector investment. The City Deal document reminds us that “Greater Cambridge competes on a global stage and is a gateway for high-tech investment into the UK. It is also the innovation capital of the country, with more patents per 100,000 population than the next six cities combined”.

6 Since the previous Local Plans were prepared Cambridge has now become an anchor of the national economic priority area known as the Oxford-Cambridge Arc which encompasses the entirety of the Cambridge City and South Cambridgeshire districts. The National Infrastructure Commission’s 2017 report “Partnering for Prosperity: a new deal for the Cambridge-Milton Keynes-Oxford Arc” confirmed that the Arc is home to some of the most productive and fast-growing cities and “has significant potential for transformative growth”. The Ministerial Foreword to ‘The Oxford-Cambridge Arc: Government ambition and joint declaration between Government and local partners’ (March 2019) cites that the Arc is an economic asset of “international standing” and is a place that provides the best of British business and innovation for the benefit of local communities and the wider country.

7 Central to the Arc realising its full potential and Cambridge fulfilling its role as a key anchor of the Arc is the delivering of new housing and infrastructure to complement and support economic growth. Indeed, significant investment has already been made in improving transport infrastructure with the completion of the A14 improvements between Huntingdon and Cambridge and in planning for the East West Rail route between Bedford and Cambridge. There is significant momentum behind planning for the economic prosperity of Cambridge and the surrounding area.

8 The July 2021, ‘Creating a vision for the Oxford-Cambridge Arc’ consultation document published by the Government states the following regarding housing supply in the Arc,

“We are concerned about the affordability and availability of housing in the Arc, and what this will mean for the Arc’s communities, economy and environment. Development of new homes is already happening in the Arc, but in the main centres this has not kept up with need. We also know people are being priced out of the area, increasing the need to make more polluting journeys for work and leisure, and making home ownership less likely for many.”

9 The consultation document confirms that a Spatial Framework will be developed to provide national planning policy for the Arc area. However, it is clear that Development Plans and local planning authorities will still have an important responsibility to bring forward Local Plans which deliver enough housing to support the four overarching policy pillars of the Spatial Framework: “the environment, the economy, connectivity and infrastructure and place-making”.

Employment Forecasting and Housing Growth

10 In the preparation of the GCLP there is great responsibility on the Councils to prepare a Plan which supports and complements Cambridge’s and the Arc’s national and international role in innovation and business. In addition, the GCLP can also plan positively to achieve economic growth whilst taking advantage of its excellent public transport links and the future benefits of East West Rail. The GCLP should embrace this opportunity of international importance and plan positively for housing to support significant levels economic growth, with residents in the area standing to benefit increased high quality employment opportunities and the committed investment in major transport infrastructure projects.

11 The Council’s Development Strategy Topic Paper (DSTP) summaries the approach the Councils have adopted to define the proposed GCLP housing requirement, drawing upon evidence base studies produced by GL Hearn. The GCLP evidence base indicates that standard method requirement figure for the GCLP area, without accounting for employment forecasting, is 36,600 dwellings. This housing requirement would support the creation of 45,800 jobs. Given the economic growth and investment in the area, and the provisions of the NPPF the Councils have undertaken further economic forecasting to establish potential jobs growth figures and the level of new housing needed to support this growth. The principle of this approach is supported by our client.

12 The Councils are choosing to support the central jobs forecast scenario in the preparation of the GCLP as set out in the Housing and Employment Relationship Report (November 2020) (HERR). This forecast results in a need to plan for 58,500 new jobs in the area over the plan period 2020-2041 and is based on long term patterns of employment continuing, with the year-on-year growth in jobs comparable to that experienced between 2001-2017 and 1991-2017. To support the central level of employment, the GCLP puts forward a medium housing requirement of 44,400 dwellings over the plan period.

13 The HERR also provides an alternative higher jobs forecast which has not been taken forward by the GCLP. The higher forecast could deliver 78,700 jobs over the plan period, this equates to an additional 20,200 jobs when compared to the medium jobs forecast pursed by the GCLP First Proposals. This forecast places greater weight on the fast growth experienced in the recent past, with the year on year growth in jobs higher than that seen between 2001-17 and 1991-17, but lower than the ‘fast growth’ period of 2010-17. To support 78,700 new jobs the GCLP would need to propose a housing target of 56,500 dwellings, 12,100 more dwellings than currently proposed in the GCLP First Proposals. Given the level of investment and momentum behind growth initiatives and funding in Cambridge we consider more likely that the faster growth in recent past will continue, rather than defaulting back to long term employment patterns continuing. Cambridge and its immediate environs has entered a new era of investment and growth.

14 Paragraph 5.22 of the HERR recommends a preferred range “between a central and higher growth scenario” to plan for employment change in Greater Cambridge. Notwithstanding this recommendation, the higher growth option is dismissed by the Council’s in the DSTP, with this option considered as “possible but not the most likely”. This conclusion is based on the “implication from wording in the Employment Land Review regarding the central scenario”. This wording is assumed to be that set out at paragraph 5.22 of the HERR which states that “all economies experience peaks and troughs, with the position at 2017 considered to be a peak or near peak. As a result the most realistic position by 2041 is one which sees outcomes fall back towards the longer term historic year on year absolute change”.

15 It is noted that ONS figures show that between 2000 and 2019 jobs in Cambridge city increased from 93,000 to 123,000, this equates to an average job increase of 1,000 per year. For the period 2014-2016 the job creation growth is reported at exactly 1,000 jobs per year. In the period 2017-2019 job creation increased by 5,000 which equates to an average of 1,666 jobs per annum. Accordingly, since the year considered above to be the ‘peak or near peak’ job creation in the city has not only increased, but it has also increased at a greater average rate than the proceeding period.

16 Job density (total jobs to population) in 2019 was at 1.41, a significant increase on the 1.33 ratio in 2017. Clearly there is a great need to rapidly and significantly increase housing supply in Greater Cambridge to support the current number of jobs in the city. To demonstrate the strong and unique nature of the Cambridge city economy, by comparison in 2019, job density was at a rate of 0.86 in the Eastern region and 0.87 in Great Britain.

17 In light of the recommendations of the HERR, the unique characteristics of Cambridge and the NPPF’s focus on planning policies supporting economic growth and driving innovation it is contended that the GCLP should be seeking to ensure that it is capable of supporting greater economic growth than currently proposed. The HERR recommends pursing a jobs target of between 58,500-78,700 a range of some 20,200 jobs – equivalent to 12,100 additional homes. This range is vast given the importance of the issue and the need for planning policies to be flexible and respond to changing circumstances (NPPF paragraph 33). The higher jobs growth should be planned for or as a minimum further work is required by the Councils to identify an appropriate point within this range for the GCLP to positively plan for. There is significant political, planning and investment momentum behind the economic growth of Greater Cambridge with this momentum set to continue in the 2020-41 plan period. This momentum should be supported by a GCLP which fully embraces the opportunity to deliver economic growth of national importance to support the innovation and science employment sectors which are of acknowledged international significance.

Neighbourhood Planning

18 Paragraph 66 of the NPPF makes it clear that strategic planning policies should identify the housing requirement for a designated Neighbourhood Plan Area. The First Proposals document confirms that the GCLP intends to include a policy which would see Neighbourhood Plans contributing towards meeting windfall housing numbers, with the Councils identifying an indicative housing requirement on an informal basis as when a Neighbourhood Plan Area is designated (or assumed when an existing Neighbourhood Plan is reviewed).

19 This approach in part aligns paragraph 67 of the NPPF which seeks a local planning authority to provide an indicative housing figure. However, as explained in Footnote 33 of the NPPF this approach is only needed when strategic housing policies are out of date or a Neighbourhood Plan Area comes forward after strategic policies have been adopted.

20 The GCLP should be allocating a proportionate housing requirement to established sustainable settlements, particularly those which have a Neighbourhood Plan or are a designated Neighbourhood Plan Area. It should also make it clear that the adoption of the GCLP will trigger the need to review adopted Neighbourhood Plans to assist in meeting housing need at sustainable settlements. This will allow rural communities to thrive and plan proactively and positively for their futures. As set out in our representations on Policy S/DS: Development Strategy it is vital that GCLP pursues a balanced spatial strategy which provides housing choice and benefits all sustainable communities.

21 The proposed approach to Neighbourhood Planning does not comply with the policies of the NPPF (paragraphs 66 and 67) and shines a light on a significant flaw in the proposed spatial strategy in respect of supporting established rural communities and the rural economy (paragraph 84 of the NPPF).

“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.”

• Despite being significant, the level of growth proposed is insufficient.
• Through their ongoing extensive and detailed research, Cambridge Ahead (likely the foremost authority on the mater of Cambridge’s economy and growth), have concluded/demonstrated as follows with respect to the ‘First Proposals’:
> If planned for well, higher growth rates than those proposed can be accommodated in a way that improves quality of life for existing and new residents in balance with the needs of the environment and the economy (i.e. in a sustainable way).
> The most recent growth data does not support the projections expressed in the ‘First Proposals’. This raises concerns that the Councils will again serially underestimate the opportunities that high growth creates.
> Cambridge Ahead’s view is that the long run rates in the ‘First Proposals’ are adopting an under-estimate and do not provide the best possible objective assessment of the area’s growth. As a result, the ‘First Proposals’ risk repeating the previous errors in the EEFM forecasts and ignoring the warnings flagged by the Cambridge Ahead’s CPIER.
> The three complementary arguments underlying the recommended annualised growth scenarios for the emerging Plan – KS3/1.1%, with the possibility of the slightly higher KS2/1.5% - have clear flaws, as set out in GL Hearn’s analysis. The historical reversion to the regional mean was notably higher than the recommended figure. The reasons put forward for discounting the recent performance of the higher exogenous sectors have not provided supporting evidence and therefore lack a credible evidential basis. In addition, the suggestion that the high growth between 2011-17 was peaking and is likely to regress to a future regional or national mean has not only been unconvincingly argued, but has now been convincingly rebutted by the continued high growth of the region.
> Accordingly, Cambridge Ahead do not feel that the recommended Plan annualised growth rates stand up to the test of providing an objective assessment for the region’s proposed future growth.
• Having regard to Cambridge Ahead’s findings therefore, higher rates of growth not just can be provided for (because they can be delivered sustainably) but should be provided for (in order that the levels of growth that current trends show are most likely to occur over the plan period are catered for).
• The growth in jobs and homes proposed in the ‘First Proposals’ and subsequent drafts of the emerging local plan should therefore be increased to the higher jobs and homes scenario (the ‘Maximum continue existing patterns’ scenario - 78,000 jobs and 53,500 homes).

“What alternatives did we consider?

1. Planning for the higher jobs forecast and level of homes associated with it. This alternative was rejected as this higher jobs forecast could be possible, but is not the most likely future scenario. As such we do not consider that it represents our objectively assessed need, and would therefore not be a reasonable alternative.”

• In view of the foregoing, the higher jobs forecast, and therefore the need for the higher level of homes associated with it (the ‘Maximum continue existing patterns’ scenario - 78,000 jobs and 53,500 homes), is not just possible but is what the evidence suggests is actually the most likely future scenario. Accordingly, this scenario is likely to represent the objectively assessed need for jobs and housing in Greater Cambridge and should be adopted by the ‘First Proposals’ and subsequent drafts of the emerging plan for this reason.

Our client supports setting a higher homes requirement to reflect forecast jobs growth.

Policy S/JH - New Jobs and Homes

Policy S/JH: New Homes and Jobs seeks to deliver 2,111 homes per annum (44,400 homes in total) set against a job forecast of 58,500 new jobs during the plan period. It is encouraging that this target has increased from previous iterations of the Local Plan and the standard method calculation, however we do not think it goes far enough in meeting the employment or housing needs of the district over the Plan Period.

The Cambridgeshire and Peterborough Independent Economic Review (CPIER 2018) has evidenced that job growth has been faster than expected and at a rate that is significantly higher than the Local Plan uses (1.1%) in its assumptions. All indications are that this growth is more than likely to continue. The report concludes that: "it is indisputable that high rates of employment growth have put great strain on the housing market in Cambridgeshire and Peterborough, particularly around Cambridge. The result is exceedingly high living costs, longer commutes, social stratification, and extra cost for business. Ambitions for house building should be increased to deal with a housing deficit that has grown up following under-projections of growth".

The HERR also provides an alternative higher job forecast which has not been taken forward by the GCLP. The higher forecast could deliver 78,700 jobs over the plan period, this equates to an additional 20,200 jobs when compared to the medium jobs forecast pursed by the GCLP First Proposals. This forecast places greater weight on the fast growth experienced in the recent past, with the year-on-year growth in jobs higher than that seen between 2001-17 and 1991-17, but lower than the ‘fast growth’ period of 2010-17. To support 78,700 new jobs the GCLP would need to propose a housing target of 56,500 dwellings, 12,100 more dwellings than currently proposed in the GCLP First Proposals.

Given the level of investment and momentum behind growth initiatives and funding in Cambridge we consider more likely that the faster growth in the recent past will continue, rather than defaulting back to long term employment patterns continuing. The emerging Local Plan therefore needs to plan for higher levels of employment growth and ensure there is a sufficient supply of employment land to meet demand.

Furthermore, whilst it is recognised that the Greater Cambridge regional economy is of national importance, and it is also fundamental that the emerging Local Plan delivers opportunities for all types of employment growth and not just those that relate to the more common tech and science park sectors associated with central Cambridge and its urban fringe. This is even more important given the increase in the price of commercial floorspace over recent years and the difficulty ‘lower value’ industries have in being able to locate in and around Cambridge. Affordability of commercial floorspace is becoming a significant issue and one that the Local Plan needs to comprehensively address.

There has been an overarching reluctance in South Cambridgeshire to support B2 and B8 employment uses along the primary transport corridors. Whilst the A14 corridor does have some logistics development it is very minor compared to the amount of development found along the A1 corridor at Peterborough. In considering new employment growth consideration should be given through the plan making process to identify potential employment sites which are located on key transport corridors (A14; M11 or A10) to ensure this employment sector is catered for and suitable sites are identifies throughout the district. This trend is supported by the report produced by Savills which accompanies these representations setting out the need to fully identify additional employment land to meet future demand.

Conclusion
The independent report produced by Savills has identified a rising demand for employment land and the need to allow for greater job creation through the Local Plan process than currently identified. Failure to identify sufficient land for employment development at Melbourn is a missed opportunity to deliver employment development in a highly sustainable location outside the green belt where there will be little impact on the environment or other site-specific designations. It is important that sites which are in locations capable of delivering B2/B8 employment uses or capable of accommodating existing businesses who wish to relocate are fully considered and identified through the Local plan process in order that the future demand can be met. The negative impacts of not allocating enough employment land includes constraining the number of small company’s start-ups and losing businesses who cannot find affordable accommodation in the District.

OBJECT

These representations are submitted on behalf of Endurance Estates, who has promoted land at Crow Green to the north-east of Caxton Gibbet for employment uses. The promoted development comprises mid-tech and advanced manufacturing employment uses and strategic logistics development. The site is located to the north of Cambourne, and the promoted development would increase employment opportunities at Cambourne. The site is located at a junction that is due to be upgraded as part of the proposed A428 Black Cat to Caxton Gibbet Improvements project being brought forward by National Highways. The site would also be well-related to the the Cambourne to Cambridge Better Public Transport project being delivered by the Greater Cambridge Partnership and the preferred routes for the East West Rail project including the proposed station at Cambourne.

These representations are supported by a Vision Document (Stephen George & Partners), Employment Need Report (Savills), Market Demand Report (Carter Jonas).

The Cambridgeshire and Peterborough Devolution Deal included a commitment to deliver substantial economic growth and to double economic output during the next 25 years. The 2018 Cambridgeshire and Peterborough Independent Economic Review (CPIER) identified that recent employment growth has been faster than anticipated, and the aim of doubling economic output in the area by 2040 was realistic. It was suggested in CPIER that economic growth could be achieved by attracting knowledge-intensive businesses that would not locate elsewhere in the UK, by delivering new housing, and by prioritising infrastructure projects. The National Infrastructure Commission, the Cambridge and Peterborough Combined Authority and the Greater Cambridge Greater Peterborough Enterprise Partnership acknowledge and support the economic growth potential of the Greater Cambridge area. The preferred growth option also does not reflect the anticipated growth aspirations of the Oxford to Cambridge Arc Spatial Framework, or that the economic success of Greater Cambridge is of national significance. As set out below, the employment land evidence and emerging GCLP does not plan for sufficient economic growth.

Barton Willmore, on behalf of Endurance Estates, have assessed the preferred jobs and housing targets in Policy S/JH. Policy S/JH takes forward the ‘Central’ growth scenario, based on employment growth of 58,500 jobs 2020-2041, at an average annual growth rate of 1.1%. However, the CPIER report identified that Cambridge and South Cambridgeshire Districts experienced average annual employment growth of 2.4% and 2.3% respectively according to Office for National Statistics data, between 2010 and 2016. This approach by CPIER results in an annual employment growth rate for Cambridge which is the same as the ONS rate (2.4%), but a significantly higher rate (4.2%) is calculated for South Cambridgeshire. Barton Willmore conclude that the Councils current objectively assessed need is far below the potential growth scenarios for the area and, therefore, will need to be revised up and supported by further site allocations in the development strategy.

Therefore, the emerging GCLP should have selected a higher growth level option to support economic growth, and made additional employment allocations to meet that growth..

Requested Change

It is requested that the housing and jobs requirements in Policy S/JH are reviewed to ensure they meet the growth potential of Greater Cambridge, and based on delivering a higher growth level option.