S/JH: New jobs and homes

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.

We consider that the Council’s should be aiming for the Higher Jobs Growth based figure which we consider should be c.58,400 homes over the proposed plan period in order to reduce inward commuting and deliver sufficient housing in order to bring down house prices given the affordability issues within Cambridge and South Cambridgeshire.

The intention of Policy S/JH will be to set out the levels of need in Greater Cambridge that development will meet over the Plan Period 2020 to 2041. The Objectively Assessed Need (OAN) has been calculated at 44,400 new homes, reflecting an OAN of 2,111 homes per year.

The overall housing need should be based upon a minimum (emphasis added) figure, in accordance with NPPF (2021) Paragraph 61. This is to ensure consistency with national policy and the Governments objective of significantly boosting the supply of homes (NPPF 2021; Paragraph 60).

Background studies undertaken to inform the emerging Local Plan (the Employment Land and Economic Development Evidence Study, November 2020 and Greater Cambridge Housing and Employment Relationships Report, 2020) found that the standard housing figure set by government would not support the number of jobs expected to arise between 2020 and 2041 and would risk increasing the amount of commuting required into the Greater Cambridge area. The OAN has therefore been calculated above the standard housing figure set by government and instead is based upon the most likely level of future jobs. This approach to determine a higher number of homes than the standard method is supported and in accordance with Paragraph 61 of the NPPF (2021). It is considered that the future jobs forecast provides exceptional circumstances to justify a higher level of homes based upon current and future demographic trends and market signals, taking into consideration that the Greater Cambridge economy is dynamic and does not align with national or regional job forecasts.

This is also acknowledged by Cambridge City Council, whom state “Cambridge is a successful city with a world-class reputation for education, science and innovation, research and knowledge-based industries, and its historic environment. It is a major focus for employment. The high-value Cambridge Cluster is crucial to the UK’s economy and its international competitiveness.” This underlines the importance of the Cambridge economy, and in turn the importance of supporting this economy through the delivery of sufficient housing, both to prevent long-distance commuting but also to address and prevent worsening of the existing affordability situation.

The Greater Cambridge Employment Land and Economic Development Evidence Study (November 2020) predicts the future jobs forecast for Greater Cambridge. The Study states that 81% (35,800) of the total jobs forecast in the 2018 adopted Local Plans between 2011 and 2031, were created between 2011 and 2017. This suggests that the economic growth potential in Greater Cambridge has previously been underestimated. As a result, the Study considers two job growth scenarios for the emerging Local Plan:

• Central (medium) growth scenario: considered the most likely outcome taking into account long term patterns of employment. Overall this scenario led to aggregate year on year growth comparable with that between 2001-2017 (and 1991 – 2017). A total of 58,500 jobs.
• Higher growth scenario: a higher outcome placing greater weight on fast growth in the recent past. Overall this scenario led to aggregate absolute year on year growth higher than that seen between 2001-2017 (and 1991-2017), but lower than the ‘fast growth’ period of 2010-2017. A total of 78,700 jobs.

The Study suggests that flexibility is provided in employment land in case the market delivers more jobs than anticipated, and this statement is also reflected within the First Proposals document.

We agree that the Greater Cambridge Local Plan should provide flexibility to facilitate higher job growth, and this should be considered and included within the Draft Local Plan. It is clear from the First Proposals’ evidence base that historically the employment growth across Greater Cambridge has been higher than predicted. This is also notwithstanding the recent introduction of Use Class E, which may see greater movement between the previous Class B Uses and additional employment sites coming forward with the potential intensification of existing employment sites, thereby increasing the need for housing land.

If the Local Plan does not incorporate adequate flexibility, it runs the risk of restricting jobs growth and failing to meet the economic objective of sustainable development, as set out at NPPF (2021) Paragraph 8(a). Flexibility is also required to ensure sustainable economic growth is positively and proactively encouraged, as required by Paragraph 82 of the NPPF.

In providing the required flexibility to facilitate higher jobs growth, it will be necessary for the Greater Cambridge Local Plan to also provide flexibility in the delivery of additional homes to support any additional jobs and to reduce levels of in and out commuting into Greater Cambridge, and the resulting impacts this would have on climate change and congestion. The First Proposal consultation document is clear that commuting from neighbouring authorities or further afield should be restricted, with climate change comprising one of the ‘big themes’ shaping the document.

Whilst it is acknowledged that the Councils are intending to allocate enough sites to provide approximately a 10% buffer to enable flexibility to deal with unforeseen circumstances (this is assumed in circumstances such that a site no longer comes forward for development, or delivery on a site is delayed), flexibility to support higher jobs growth should also be incorporated in the Local Plan.

This would ensure that the emerging Local Plan does not fall short of meeting criterion c) of Paragraph 82 of the NPPF (2021) by failing to provide sufficient housing to support economic growth.

To provide for appropriate flexibility for unforeseen economic growth, a range of additional contingency site allocations should be included within the housing trajectory. This will ensure the Local Plan is positively prepared, justified and effective in accordance with the NPPF (2021) tests of soundness. Land West of London Road Fowlmere lies adjacent to the expanding Manor Farm Business Park and offers a sustainable location for development, is immediately available for development and therefore able to contribute to the Councils’ short to medium housing delivery rates.

The Plan Period:
Emerging Policy S/JH sets out the levels of need that development will meet with regards to jobs, homes and accommodation for gypsies, travellers and travelling showpeople, within Greater Cambridge over the Plan period. The Plan period as set out within the First Proposals runs between 2020 and 2041.

With regards to the identified Plan period, it is considered that this should be extended to at least 2050 in order to align with the Plan period for the OxCam Arc’s Strategic Framework. This would help facilitate for properly planned strategic growth across the wider region over the next 30 years.

Furthermore, page 31 of the First Proposals states that “consistent with the new National Planning Policy Framework, our vision for Greater Cambridge looks not only to the plan period of 2041, but well beyond to 2050, reflecting that significant development identified in our strategy will continue beyond the plan period from the range of strategic sites identified, including the new settlements”. As the Councils allude to, Paragraph 22 of the NPPF now requires policies to be set within a vision that looks further ahead, this being “at least 30 years”, where larger scale developments such as new settlements or significant extensions form part of the strategy for the area. However, chapter 2 of the First Proposals which sets out the Council’s vision and aims and includes Policy S/JH, is titled ‘Greater Cambridge in 2041’; there needs to be clarity around the period that the Councils’ are establishing a vision and planning for and, having regard for the above comments related to the Plan period for the OxCam Arc and the Councils’ proposed use of large scale developments, it is again recommended that this is extended to at least 2050.

Objectively Assessed Needs:
Policy S/JH identifies that within the Plan period, the Local Plan will facilitate development to meet the objectively assessed needs (“OAN”) for 58,500 jobs and 44,400 homes, reflecting an annual OAN of 2,111 homes per year. It is welcomed that the Councils have sought to plan for growth that extends beyond the figure calculated using the standard method in national planning guidance. As identified within the Government’s ‘Indicative Local Housing Needs (December 2020 Revised Methodology)’ table, using the standard method would result in 1,085 homes per year for South Cambridge and 685 homes for Cambridge City, equating to 1,743 homes per year across both authorities, or 36,603 homes over a 21 year Plan period (such as that included within the First Proposals). If the Plan period were to be extended until 2050, using the OAN figure, this would equate to a total need for 63,330 new homes or, 52,290 homes using the Government’s standard method.

Paragraph 61 of the NPPF identifies that “exceptional circumstances” should justify an alternative approach to using the standard method. The evidence for the use of the alternative approach is included at page 22 of the Councils’ ‘Development Strategy Topic Paper’ which states that the ‘Employment Land and Economic Development Evidence Study’ and ‘Greater Cambridge Housing and Employment Relationships Report’, commissioned in parallel by the Councils, found that the standard method housing figure set by Government “would not support the number of jobs expected to arise between 2020 and 2041” and “it would also be a substantially lower annual levels of jobs provision that has been created over recent years”. Planning for this figure would “risk increasing the amount of longer distance commuting into Greater Cambridge, with the resulting impacts on climate change and congestion” and as such, as is also concluded by the Councils at page 23 of the Development Strategy Topic Paper, it cannot be considered that the standard method housing represents the OAN for homes and jobs within Greater Cambridge.

Growth Options:
In turning to look at the identified OAN set out within Policy S/JH, the OAN for 58,500 jobs over the Plan period is based on the ‘medium’ growth level as set out within the Local Plan ‘First Discussions’ consultation. A full range of previously identified growth options for homes, alongside the associated possible jobs outcomes, is included at page 21 of the Development Strategy Topic Paper. The growth options were informed by the work undertaken as part of the Employment Land and Economic Development Evidence Study and Greater Cambridge Housing and Employment Relationships Report and as such is underpinned by suitable evidence however, it is questionable as to whether the most appropriate growth scenario has been applied. Whilst the Councils are planning for ‘medium’ growth as the most likely level of new jobs, the Employment Land and Economic Development Evidence Study also identified a higher growth forecast, placing greater weight on the fast growth experienced in the recent years. The ‘maximum’ growth level would result in 78,700 jobs over the Plan period and 53,500 homes, equivalent to 2,549 homes per year. The Councils identify at page 25 of the First Proposals that they are “mindful” of the fast growth experienced in recent years, albeit it has not been reflected within Policy S/JH.

When referencing the higher employment scenario, the Development Strategy Topic Paper states at page 24 that “by implication from the wording included in the Employment Land Review regarding the central [medium] scenario, this outcome is considered possible but not the most likely”. Firstly, it is assumed that references to the “central” (otherwise known as the ‘medium’ scenario) is a typo and that this should read “higher” (or “maximum”). Secondly, if this growth option is “possible”, then the Councils should be planning for it. As identified within the NPPF, the planning system should be “genuinely plan-led” (paragraph 15) with plans “prepared positively, in a way that is aspirational” (paragraph 16) and strategic policies making sufficient provision for housing and employment development (paragraph 20). Subsequently, failure to plan for this possible growth could result in the Plan being contrary to national policy.

Furthermore, as is identified at page 11 of the Development Strategy Topic Paper, in 2017 the National Infrastructure Commission identified the OxCam Arc as a national economic priority. In light of this, whilst details regarding the quantum of development to be sought through the OxCam Arc Spatial Framework are yet to be determined, it is anticipated that proposed growth levels will be high in order to support the realisation of this national economic priority. Given that a forum for discussion between Greater Cambridge and the Government for the OxCam Arc is yet to be established (as discussed in response to ‘How much development where – general comment’), it is unclear as to what extent the identification of this economic national priority has fed into considerations regarding the Councils’ own future growth plans as set out within the First Proposals. Similarly, within the evidence base, it is not explicitly clear what assumptions have been made with regards to the implications key infrastructure projects such as the A248 improvement works and East West Rail proposals (as discussed in the Commissioners’ response to Policy S/DS) will have on attracting investment and subsequently growth, to the area.

In respect of the above, the Church Commissioners for England would urge the Councils to review the growth assumption applied in calculating the OAN and the justification for not using the ‘higher’ or ‘maximum’ levels.

The intention of Policy S/JH will be to set out the levels of need in Greater Cambridge that development will meet over the Plan Period 2020 to 2041. The Objectively Assessed Need (OAN) has been calculated at 44,400 new homes, reflecting an OAN of 2,111 homes per year.

The overall housing need should be based upon a minimum (emphasis added) figure, in accordance with NPPF Paragraph 61. This is to ensure consistency with national policy and the Governments objective of significantly boosting the supply of homes (NPPF Paragraph 60).

Background studies undertaken to inform the emerging Local Plan (the Employment Land and Economic Development Evidence Study, November 2020 and Greater Cambridge Housing and Employment Relationships Report, 2020) found that the standard housing figure set by government would not support the number of jobs expected to arise between 2020 and 2041 and would risk increasing the amount of longer distance commuting. The OAN has therefore been calculated above the standard housing figure set by government and instead is based upon the most likely level of future jobs. This approach to determine a higher number of homes than the standard method is supported and in accordance with Paragraph 61 of the NPPF, it is considered that the future jobs forecast provides exceptional circumstances to justify a higher level of homes based upon current and future demographic trends and market signals, taking into consideration that the Greater Cambridge economy is dynamic and does not align with national or regional job forecasts.

This is also acknowledged by Cambridge City Council, whom state “Cambridge is a successful city with a world-class reputation for education, science and innovation, research and knowledge-based industries, and its historic environment. It is a major focus for employment. The high-value Cambridge Cluster is crucial to the UK’s economy and its international competitiveness.” This underlines the importance of the Cambridge economy, and in turn the importance of supporting this economy through the delivery of sufficient housing, both to prevent long-distance commuting but also to address and prevent worsening of the existing affordability situation.

The Greater Cambridge Employment Land and Economic Development Evidence Study (November 2020) considers the future jobs forecast for Greater Cambridge. The study states that 81% (35,800) of the total jobs forecast in the 2018 adopted Local Plans between 2011 and 2031, were created between 2011-17. This suggests that the economic growth potential in Greater Cambridge has previously been underestimated. As a result, the Study considers two job growth scenarios for the emerging Local Plan:
• Central (medium) growth scenario: considered the most likely outcome taking into account long term patterns of employment. Overall this scenario led to aggregate year on year growth comparable with that between 2001-2017 (and 1991 – 2017). A total of 58,500 jobs.
• Higher growth scenario: a higher outcome placing greater weight on fast growth in the recent past. Overall this scenario led to aggregate absolute year on year growth higher than that seen between 2001-2017 (and 1991-2017), but lower than the ‘fast growth’ period of 2010-2017. A total of 78,700 jobs.

The Study suggested that flexibility is provided in employment land in case the market delivers more jobs than anticipated, and this statement is also reflected within the First Proposals document.
We agree that the Greater Cambridge Local Plan should provide flexibility to facilitate higher job growth, and this should be considered and included within the Draft Local Plan. It is clear from the First Proposals’ evidence base that historically the employment growth across Greater Cambridge has been higher than predicted. This is also notwithstanding the recent introduction of Use Class E, which may see greater movement between the previous Class B Uses and additional employment sites coming forward, thereby increasing the need for housing land.

If the Local Plan does not incorporate adequate flexibility, it runs the risk of restricting jobs growth and failing to meet the economic objective of sustainable development, as set out at NPPF (2021) Paragraph 8(a). Flexibility is also required to ensure sustainable economic growth is positively and proactively encouraged, as required by Paragraph 82 of the NPPF.

In providing the necessary flexibility to facilitate higher job growth, it will be necessary for the Greater Cambridge Local Plan to also provide flexibility in the delivery of additional homes to support any additional jobs and to reduce levels of in and out commuting into Greater Cambridge, and the resulting impacts this would have on climate change and congestion. The First Proposal consultation document is clear that commuting from neighbouring authorities or further afield should be restricted, with climate change comprising one of the ‘big themes’ shaping the document.

Whilst it is acknowledged that the Councils are intending to allocate enough sites to provide approximately a 10% buffer to enable flexibility to deal with unforeseen circumstances (this is assumed in circumstances such that a site no longer comes forward for development, or delivery on a site is delayed), flexibility to support higher jobs growth should also be incorporated in the Local Plan.

This would ensure that the emerging Local Plan does not fall short of meeting criterion c) of Paragraph 82 of the NPPF (2021) by failing to provide sufficient housing to support economic growth.

To provide for appropriate flexibility for unforeseen economic growth, a range of additional contingency site allocations should be included within the housing trajectory. This will ensure the Local Plan is positively prepared, justified and effective in accordance with the NPPF (2021) tests of soundness. Land to the East Side of Cambridge Road Melbourn offers a sustainable location for development and is immediately available for development, therefore able to contribute to the Councils’ short to medium housing delivery rates.

The Welding Institute (TWI)

Object

Policy S/JH: Level of Jobs and Housing

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. All these factors support flexible consideration to the evolution of the established employment clusters including Granta Park.


Requested Change

It is requested that jobs requirements in Policy S/JH are based on delivering the higher growth level option and focussing development towards existing employment clusters, such as Granta Park.

The Local Plan will facilitate development to meet the objectively assessed needs (“OAN”) for 58,500 jobs and 44,400 homes, reflecting an annual OAN of 2,111 homes per year. TMLC supports the position that Cambridge have sought to plan for growth that extends beyond the figure calculated using the standard method in national planning guidance. As identified within the Government’s ‘Indicative Local Housing Needs (December 2020 Revised Methodology)’ table, using the standard method would result in 1,085 homes per year for South Cambridge and 685 homes for Cambridge City, equating to 1,743 homes per year across both authorities.

Paragraph 61 of the NPPF identifies that “exceptional circumstances” should justify an alternative approach to using the standard method. The evidence for the use of the alternative approach is included at page 22 of the Councils’ ‘Development Strategy Topic Paper’ which states that the ‘Employment Land and Economic Development Evidence Study’ and ‘Greater Cambridge Housing and Employment Relationships Report’, found that the standard method housing figure set by Government “would not support the number of jobs expected to arise between 2020 and 2041” and “it would also be a substantially lower annual levels of jobs provision that has been created over recent years”. Planning for this figure would “risk increasing the amount of longer distance commuting into Greater Cambridge, with the resulting impacts on climate change and congestion” and as such, as is also concluded at page 23 of the Development Strategy Topic Paper, it cannot be considered that the standard method housing represents the OAN for homes and jobs within Greater Cambridge.

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.

Policy S/JH: New Jobs and Homes, in respect to ‘Housing Needs’

With regard to the Housing Requirement (Section 2.1 of the draft Plan):
o The draft Plan, knowingly, focusses only on the ‘most likely’ of just two employment growth scenarios, with no weighting given to the scenario that is based on the most recent trends.
o Were weighting to be given to the scenario that is based on the most recent trends, it is likely that the associated housing requirement would increase by c. 9% to 48,300 homes.

Please see attached letter and enclosures for further detail.

There appears to be a mis-interpretation of consultation response evidence. 49% is not a majority of respondents

Policy S/JH sets out the objectively assessed housing need of 44,400 homes (2,111 homes per annum). We agree with the reasons for discounting the alternative option of a lower figure calculated using the Standard Method and the potential consequences of not reflecting the likely forecast for future jobs; we query whether the Sustainability Appraisal (SA) should have considered the higher jobs forecast as a reasonable alternative. In relation this alternative, the SA states in its assessment of Policy S/JH, that planning for a higher jobs forecast is not considered to be a reasonable option due to this being possible, but not the most likely future scenario.

Given this scenario is a possibility, we consider it should be explored as a reasonable alternative within the SA, to ensure that a robust assessment is undertaken to support the objectively assessed housing need.

The general approach to identifying new rural allocations for housing is supported, but planning policies also need to identify opportunities for villages to grow and thrive (as required by the NPPF (Paragraph 79)) and detailed comments in this regard are made in relation to S/RSC and S/RRA.

OBJECT

The Cambridgeshire and Peterborough Devolution Deal committed to delivering substantial economic growth and to double economic output during the next 25 years. 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 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. 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 Cambridge.

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. A higher growth level option would be consistent with the Government’s aspirations for 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 Council states that the new Local Plan will meet the following objectively assessed needs for development in the period 2020-2041:

• 58,500 jobs; and,
• 44,400 homes.

The housing figure equates to an average of 2,114 homes per annum, with a suggestion that this will meet an objectively assessed housing need for 2,111 homes per annum that has been rounded upwards in deriving the total figure. It is noted that the Plan seeks to provide for approximately 10% more homes than are calculated as being needed, a total of around 48,840 homes.

In justifying a housing need figure above the Standard Method, the First Proposals cite evidence assembled in the two studies set out below:

• Greater Cambridge Local Plan: Housing and Employment Relationships (November 2020), GL Hearn; and
• Greater Cambridge Employment Land and Economic Development Evidence Study (November 2020), GL Hearn, SQW and Cambridge Econometrics

The latter of these two studies presents two alternative forecasts of potential economic growth over the Plan period:

• A Central Scenario under which 58,400 new jobs would be created, claimed to represent the ‘most likely outcome taking into account long term historic patterns of employment’ with the Housing and Employment Relationships study also describing it as ‘a ‘business as usual’ growth scenario’;
• A Higher Scenario under which 78,700 new jobs would be created, with this ‘higher outcome placing greater weight on fast growth in the recent past, particularly in key sectors’ and the Housing and Employment Relationships study describing it as ‘a plausible but more aspirational growth outcome’

The Housing and Employment Relationships study concludes that housing provision in line with the Standard Method will not support either of these economic growth scenarios. It estimates the housing need associated with supporting each would be as follows:

• Central scenario – 41,900 to 44,310 homes (1,996-2,110dpa) with the range reflecting alternative commuting assumptions, the upper end assuming that there is a 1:1 or balanced commuting ratio for new jobs and the lower end assuming continued in-commuting;
• Higher scenario – 53,500 to 56,490 homes (2,549-2,690dpa) with the range again reflecting alternative commuting assumptions

The emerging Local Plan is proposing to deliver 44,400 homes, which supports 58,500 new jobs, aligning with the Central Scenario for growth in the District over the Plan period.

As set out in the Council’s Topic Paper on the Development Strategy (September 2021) at Section 5.3, the evidence base has identified that Greater Cambridge is a centre of excellence and a world leading economy of international importance, of which Clare College contributes to. Whilst the focus is within the knowledge-based economy, other types of industry provide a wide diversification of jobs and services in Greater Cambridge, including education, retail, leisure, tourism and agriculture, all of which are highly important. This together with the important strategic position of Greater Cambridge within the Oxford-Cambridge Arc means that there is significant opportunity to plan for the higher jobs scenario, which in turn needs to be supported by a higher housing requirement to ensure that an appropriate level of market and affordable homes can be delivered within the Plan period. Of relevance to the College is also the need to deliver student accommodation for their undergraduate and postgraduate population and that the First Proposals document confirms that these units also contribute to the overall housing requirement.

Whilst the College support that the Council have set a housing figure higher than the Standard Method, the College would suggest that the Council could be more ambitious and plan for higher housing and employment growth in the District to align with their Local Plan evidence base.

Support the need to deliver 58,500 jobs, including for the education section. This should include all education sectors. We also support the target of 44,000 new homes up to 2041, which should include all types of housing, including student accommodation.

OBJECT

These representations are submitted on behalf of the North Barton Road Landowners Group (North BRLOG), who has promoted land north of Barton Road and at Grange Farm in Cambridge for a landscape-led urban extension. The promoted development is referred to as “South West Cambridge” in these representations. A number of technical reports and a Vision Document have been prepared for the promoted development, all of which were submitted at the Issues & Options stage of emerging GCLP. The findings of the technical reports and Vision Document are referred to in response to relevant policies in the GCLP Preferred Options consultation and the associated site assessments in the Housing and Economic Land Availability Assessment (HELAA) and Sustainability Assessment (SA).

The then named Greater Cambridge City Deal (now known as the Greater Cambridge Partnership) recognised the relationship between housing and economic growth, and that the shortage of available and affordable housing within Greater Cambridge has had an impact on house prices, commuting patterns, and recruitment and retention of employees. 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, 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. Neither does the ‘medium plus’ growth option reflect the anticipated growth aspirations of the Oxford to Cambridge Arc Spatial Framework, or recognise that the economic success of Greater Cambridge is of national significance.

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

A Housing and Economic Development Needs Assessment was prepared by Iceni Projects Ltd for North BRLOG, and was submitted with representations at Issues & Options stage for emerging GCLP; it is resubmitted with these representations. The Assessment examined the inter-related issues of economic growth, affordability and housing need in Greater Cambridge.

The evidence in the Assessment identifies a fundamental imbalance between rates of economic growth and housing delivery, which is leading to acute housing affordability issues. It is noted in the Report that median house prices are more than 11 times average earnings across the Greater Cambridge Area (with a higher ratio in Cambridge City). The undersupply of homes presents a fundamental challenge to the area’s future economic growth because workers are being priced out of the area and firms in the Greater Cambridge area finding it increasingly difficult to recruit.

It is recommended in the Assessment that planning for housing should be based on a blended economic growth rate of 2.8% per annum i.e. based on short-term economic trends to 2031 and longer-term economic trends thereafter; this recommendation is consistent with the findings of the Cambridge and Peterborough Independent Economic Review (CPIER), the Cambridgeshire and Peterborough Devolution Deal, and the Local Industrial Strategy for the area. It is common planning practice to seek to align housing and economic strategies.

Iceni’s analysis demonstrates that 101,200 dwellings are required in the Greater Cambridge area between 2017 and 2040, which equates to 4,400 dwellings per annum.

Requested Change

It is requested that the housing target in Policy S/JH is based on achieving a blended economic growth rate of 2.8% per annum. It is requested that the housing target should be 4,400 dwellings per annum for Greater Cambridge to meet this economic growth rate.

Jesus College (working with Pigeon Investment Management and Lands Improvement Holdings), a private landowner and St John’s College, control land to the west of the land identified in the First Proposals as Policy S/CBC – i.e. land east and west of Great Shelford and of the London Cambridge West Anglia Rail line and south of Addenbrookes Road, which is known as part of the Cambridge South development proposal.

The land is identified in the Vision 2050 produced by CBC Limited, representing the constituent institutions at Cambridge Biomedical Campus. Vision 2050 identifies the land as an integral part of the future Campus, as it grows and diversifies to become a fully integrated Innovation District of international importance. The land is not, however, identified for potential development in the First Proposals.

In our view, the First Proposals underestimate the scale of growth for which it would be appropriate to plan in the new Local Plan; underestimate the need for and important benefits of planning for the long term future of the Campus and fail to comply with the NPPF – particularly its requirement that local plans should take a long term view in planning for developments of strategic importance.

There is a case for a greater level of housing growth in its own right than that currently proposed, where First Proposals Policy S/JH looks to provide 58,500 jobs and 44,400 homes over the period 2020-2041. The proposed level of growth is unambitious and will not address marked problems of housing shortage and affordability.

Additionally, however, sufficient housing supply is essential to support Cambridge’s role as a nationally important economic hub. If that potential is to be achieved, the level and location of housing provision needs to be planned consistently.

Ensuring the homes are affordable and in sustainable locations where employment opportunities can be easily accessed should also be a priority for the Local Plan.

The Councils’ forecasted growth scenarios (medium and high) do not go far enough to reflect the potential growth scenarios for the area. We argue that a substantial increase in the Councils’ employment growth and housing delivery assumptions is required to ensure planned growth aligns with past performance and that aspired to in order to double GVA over the next 25 years.

The Councils’ approach to forecasting employment growth must also take into account suppressed demand and more accurately account for historic or current property market dynamics, as highlighted in the accompanying report by Savills.

The emerging Policy S/JH: New jobs and homes identifies that the GCLP will provide 58,500 new jobs over the Plan period from 2020 to 2041.

The Greater Cambridge Employment Land Review & Economic Development Evidence Study (the ‘2020
ELEDES’), which has informed the emerging proposals, concluded that the recommended lower and upper
forecast range referred to as central growth (+58,400 jobs) and higher growth (+78,700 jobs), respectively,
“should be used for Local Plan purposes”. However, paragraph 6.33 in the 2020 ELEDES states that:
“It is recommended that in planning positively for growth, the KS2 Higher Scenario is planned for
regarding B1a/b floorspace, without making any implied assumptions regarding jobs growth [Lichfields’
emphasis]. This is recommended to ensure a flexible employment land supply encouraging growth in
existing businesses and attracting inward investment. It also broadly aligns with completions trends and
market feedback.”

Of note, the higher growth (i.e. recommended scenario) relates to an additional 78,700 jobs across the plan
period (see 2020 ELEDES paragraph 6.11, pg.97). Therefore, there is an internal inconsistency across the
Local Plan and its supporting evidence, and it is not clear how the recommended higher growth scenario of
78,700 jobs has been translated into the Local Plan’s lower provision of 58,500 jobs.

It should be also highlighted that the labour demand scenario is used to inform the employment space
requirements for office and R&D uses, while light industrial, general industrial and storage and distribution
space requirements have been based on the past trends scenario, and particularly a projection of the annual
net completions between the monitoring years of 2011/12 and 2017/18, which is considered a very short
period of time to inform policy recommendations over the next 20 years.

According to 2020 ELEDES Table 10 (pg.94), the job growth associated with “2011-17 annual average
change”, which is understood to reflect the recommended scenario for the industrial/warehousing uses,
equates to 125,200 jobs across all sectors for the 2020 to 2041 period. There is no available data provided in
terms of how these jobs are distributed across the various employment segments. As a result, there is no
transparent evidence of how the proposed jobs growth is distributed across the various employment space
types and on this basis, we consider that the evidence in relation to jobs growth estimation lacks
transparency and robustness.

Moreover, it is understood that the estimation of the office and R&D jobs growth is based on a series of
forecasts highlighting a policy-on view on how those sectors (which are considered historically as the key
drivers of the local economy) are expected to grow further. The emphasis on office-based segments appears
to characterise the approach in the Local Plan as a whole, and which therefore does not acknowledge the
importance of other economic sectors, including logistics and industrial-based activity.

Furthermore, paragraphs 6.36 to 6.37 state:
“6.36 The labour demand forecasts for B1c/B2 floorspace should be viewed cautiously. Recent completions trends show a slow down in light / heavy industrial floorspace loss as the manufacturing and related sector of the economy stabilises after a period of decline. Market feedback suggests demand for light industrial floorspace which is reflected in gains in South Cambridgeshire and market pressure in Cambridge [Lichfields emphasis]. It is recommended that industrial floorspace losses are limited in the city to avoid constraining business and industrial activity. In reality there may be some further losses in Cambridge, which should be minimised, but gains in South Cambridgeshire are expected regardless.

6.37 Similarly, with B8 warehousing needs, the completions trends show a higher level of floorspace than the labour demand model with losses in Cambridge and gains in South Cambridgeshire. The logistics sector is experiencing a high level of change due to increases in e-commerce and greater levels of automation particularly in larger units [Lichfields emphasis]. This may change the relationship between labour requirements and floorspace needs. Given delivery has been steady in South Cambridgeshire across the tested completion periods whilst losses have increased in Cambridge and are likely to continue, it is recommended that the recent net trends are planned for.”

Although the evidence demonstrates clearly that there are specific market signals showing ‘market pressure’ in Cambridge City together with demand for larger units as e-commerce increases and automation evolves, both the evidence and the emerging policies choose to ignore these signals and driven by policy choices to focus on the office-based economy. This is contrary to:
• NPPF Paragraph 81: ‘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’,
• NPPF Paragraph 82 ‘planning policies should: d) be flexible enough to accommodate needs not anticipated in the plan, allow for new and flexible working practices…and to enable a rapid response to changes in economic circumstances’; and
• NPPF Paragraph 83 that sets the requirement for the policies to recognise and address the specific locational need of (inter-alia) storage and distribution operators at a variety of scales and in suitably accessible locations.

Therefore, we conclude that the evidence that informs the emerging policy over the next twenty years is not proportionate nor it is objective. This contradicts with NPPF Paragraph 35 point ‘a) Positively prepared’ that requires the plans ‘to seek to meet the area’s objectively assessed need’ and point ‘b) Justified’ that requires ‘an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence’.
Lichfields has reviewed the existing evidence and prepared an updated the analysis in relation to logistics requirements across the Plan period in Greater Cambridge (Appendix 1). Based on our analysis, there are various inconsistencies and deficiencies within the Councils’ evidence that, in our view, means the anticipated B8 and the combined Eg(iii)/B2/B8 requirements and jobs growth are significantly underestimated.

In particular, both jobs scenarios of 58,400 or 78,700 additional jobs across the Plan period suggest that over the next 20 years B8 jobs will grow by 457 jobs or 21.7 jobs per annum, while the combined Eg(iii)/B2/B8 equivalent will decrease by 1,339 jobs or by -63.7 jobs per annum across the Plan period (Table 13, pg.99). This contradicts the market signals and recent activity that highlight pressures to identify additional employment land in Greater Cambridge to avoid losing businesses that want to either invest or expand in the area.

Lichfields’ updated assessment of logistics land requirements (as set out in Appendix 1) suggests that additional B8 job growth of around 3,100 jobs to 5,700 jobs should be anticipated across the Plan period, once the strategic logistics requirements are considered as identified by NPPF and PPG.

As a result, it is not considered that the emerging policy is soundly-based. There is need for the supporting evidence to objectively and robustly identify employment requirements across office, industrial and storage and distribution uses rather than taking a policy-on view that largely focuses on office growth and does not adequately assess the needs arising for other segments of the economy.

Policy S/JH of the draft Local Plan identifies the proposed housing need for the plan period of 2020-2041. A housing requirement of 44,400 is stated, and equates to 2,111 dwellings per annum which is significantly above the minimum housing need established by the standard method (para 61 of the NPPF). The Council’s decision to create a higher housing target than what is required by the standard method is supported, provided that housing provisions can accommodate for a diversity of needs in Greater Cambridgeshire and are in accordance with national planning guidance.

It is urged that the council may take a more flexible approach towards the allocation and delivery of housing sites in Rural Areas. The Council has a duty to ensure that Green Belt land is protected, and not developed on unless there are no other suitable options available. The proposed approach is ignoring and indeed preventing obvious development opportunity sites such as farm buildings within/contiguous with settlements from being developed. Such sites would enable investment and regeneration in rural communities, whilst minimising the amount of greenfield land needed for housing.

The Council is required to provide a supply of housing for the next five years to ensure that it can meet its housing delivery targets. The Housing Delivery Study sets out the development trajectory for each site and the expected time frame for its completion. The council state that there is a housing supply of 5.15 years which is close to the minimum amount required. The uncertainty around the deliverability of sites means that there is reasonable potential for the council to not meet its housing targets if multiple developers fail to provide housing within the five year period. Therefore, it is proposed that the council should consider additional suitable housing sites through a more dispersed approach to development across settlements within the Plan area that could be delivered within the five year period to ensure that it can safely meet its housing target.

Greater Cambridge experienced a growth rate over 1% higher between 2010 and 2016 than the employment growth which is relied on in the First Proposals document. Our review of the evidence shows that the higher growth scenario is achievable and the chosen medium+ growth scenario falls significantly short of the growth potential of the area and fails to align with the aim of doubling GVA by 2042 through the city deal. As a result, further allocations will be needed and our promoted site at Westley Green (no. 40078) offers a significant opportunity to plug the gap in the development strategy.

Draft Policy S/JH clearly underestimates and fails to meet the need for employment floorspace, particularly Class B8 logistics floorspace in Greater Cambridge. This does not reflect national planning policy guidance set out in Paragraph 83 of the NPPF that calls for planning policies to recognise and address the specific locational requirements of different sectors, including storage and distribution operations at a variety of scales and in suitably accessible locations. Please see the detailed representations document which is submitted separately for further detail and background to these comments.

Changes Requested:
• The evidence base supporting the draft Local Plan is updated to reflect recent market and economic trends, particularly in terms of e-commerce and the impact this has had on demand for logistics floorspace.
• The scale of employment development envisaged within the evidence base and emerging Local Plan is significantly increased to align with economic trends and to take into account the wider ambitions for the region and the vision for the Oxford-Cambridge Arc.
• The Brickyard Farm site is allocated to assist in meeting the employment needs of Greater Cambridge.
• Ensuring policy sets the assessed land requirement as a minimum rather than a ceiling on employment-generating development in Greater Cambridge.
• The proposed Policy restriction on large scale regional and national warehousing and distribution within the area in draft Policy J/NE be removed to align with national planning policy guidance.

The widespread promotion of Neighbourhood Plans (page 24) is likely to act as a constraint on development in the rural area. Research on the progress and effectiveness of neighbourhood plans found that 55% of the draft plans published for consultation have ‘protectionist’ agendas and many are openly anti-development. Therefore, there is a likelihood that this agenda will create inevitable conflicts between the national aim to significantly boost housebuilding and local community NIMBYism. The idea of ‘top down’ housing targets being set by the local authority may also dissuade some areas from engaging with the neighbourhood planning process altogether.

A more pragmatic and flexible approach would be for the Greater Cambridge authorities to carry out up-to-date local housing need surveys for the whole area (e.g. at ward or parish level) to determine quantitative and qualitative need. Used as robust evidence for the determination of planning applications, this would be a fairer system which would guide development to the right locations and, given the reliance on the private housing building sector to deliver affordable housing, also ensure that housing needs are met across the whole District, more effectively tackling the chronic affordability issues present. The process could be managed and controlled by the relevant Council, with local input from the relevant Parish Council. A bottom-up approach where small to medium scale developments are planned for local people in housing need (those named on the housing register), would also be less controversial.

Additional commentary on the proposed housing and employment targets and overarching development strategy as outlined in Policy S/DS is provided in a separate report by Barton Willmore.

I fully endorse your comment on p 27 that delivery of the water infrastructure required to prevent further deterioration of local chalk aquifers is potentially a "deal-breaker" within the timescales of the Local Plan.

Housing figures are far too ambitious and unsustainable. Cambridge will be a much less pleasant place to live and does not support the needs/mental health of existing residents. Review required after COVID/Brexit. Not enough green spaces in Greater Cambridge and building unsustainably as described, will increase the stress and anxiety amongst existing residents. The number of houses planned, and the type of housing will not make any difference to affordability crisis, people will continue to have to live further out and commute. A lot of the apartments will be purchased by investors and won't help housing crisis.

The impact that the scale of planned housing and economic growth will have on existing health infrastructure needs to be carefully reviewed, and where improvements and/or new facilities are required to meet the needs of this new population, this should be supported through appropriate developer contributions.

The NHS, Council and other partners must work together to forecast the infrastructure and costs required to support the projected growth and development across the borough. A vital part of this is ensuring the NHS continues to receive a commensurate share of S106 and Community Infrastructure Levy (CIL) developer contributions to mitigate the impacts of growth and help deliver transformation plans. The cross-boundary impacts of developments also need to be considered, where NHS services often span multiple Local Planning Authority Boundaries.

The cumulative impact of the additional proposed site allocations, on top of those already allocated, needs to be carefully considered. It should be noted that the way in which health care services are delivered is constantly shifting, most recently highlighted by the coronavirus pandemic. It is essential that the mitigation to meet the needs of this new population is flexible to meet any changing NHS care model, particularly as this development is likely to come forward over a number of years.

Planning policy should support the need to deliver homes for NHS staff to meet need, particularly in areas where there is pressure on affordability which is impacting on the ability to attract and retain key staff.

Whilst Silverley Properties Ltd support that the Council have set a housing figure higher than the Standard Method, it is their view that the Council should be more ambitious in planning for what has been presented as a reasonable and higher forecast of employment growth. This is particularly when considering the important strategic position of Greater Cambridge within the Oxford-Cambridge Arc.

Cambourne Town Council is supportive of the level of development for employment and for homes if it is carefully located and is sustainable in line with the aims in the vision.

The level of growth suggested is far too high! Natural resources (especially water), and infrastructure (roads, sewers,…) cannot support 40000+ new homes.
I realise we might be constrained by government targets but economic regeneration in the north and west must be a better approach than building more in the eastern region. Greater Cambridge should demand that central government plans to do some actual levelling up via a planning strategy.
Further, I object to the way that Cambridge Ahead were allowed to influence the first consultation with their crazed vision of growth. That was rather undemocratic!

The following is a summary of the of the overarching representations submitted on behalf of Endurance Estates by Barton Willmore. The full report is appended to these site-specific representations for completeness.

The First Proposals draft Plan sets out that the Greater Cambridge Partnership will seek to deliver an objectively assessed need of 58,500 jobs and 44,400 (48,800 inc. 10% buffer) homes during 2020-2041. This represents the Councils’ medium+ growth scenario, with the maximum growth scenario (78,700 jobs and 56,500 homes) being discounted on the basis that it does not reflect the most likely level of jobs growth when reflecting on long-term employment patterns.

Within paragraph 5.22 of the Councils’ Employment Land and Economic Development Evidence Study, it is in fact recommended that a preferred range for jobs growth would be ‘between a central and higher growth scenario’.

The ‘central’ growth scenario represents an annual average employment growth rate of 1.1%. This is significantly below other assessments of growth for the Districts. The CPIER report quotes ONS 2010-2016 average growth rates of 2.4% and 2.3% across the City and South Cambridgeshire respectively, whilst their own ‘blended rate’ shows rates of 2.4% (equal to ONS) and 4.2% (significantly more than ONS).

These figures suggest that the First Proposals are not planning for sufficient employment growth and therefore not enough housing to support it.

The employment and housing growth figures for the Local Plan through to 2041 should be revised upwards substantially, in order to accommodate the demonstrable growth potential of the Districts.