S/JH: New jobs and homes

Introduction

Thakeham Homes Ltd (Thakeham) is pleased to be participating in this consultation and has outlined its position below in response to the consultation on the Greater Cambridge Local Plan – The First Proposals (1st November to 13th December 2021).

About Thakeham

Thakeham prides itself in being an infrastructure-led sustainable placemaker and is committed to creating new, extraordinary places, where the highest attention to detail makes a positive difference.

Thakeham build for the future, for communities and individuals. Our approach sets us apart from our competitors. We deliver our schemes with a focus on sustainable development, looking ahead of current housing standards. From 2025, all Thakeham Homes will be carbon neutral in production and zero carbon in lifetime use.

Each development is different and tailored to its locality with careful consideration of the area’s character, as well as the environment. As a sustainable placemaker first and foremost, Thakeham’s commitment to improving existing communities means its schemes are design and infrastructure-led; engaging with education, highways, healthcare, utilities and other local community, cultural and environmental stakeholders from the start of each project. The delivery of homes facilitates the delivery of physical, social and green/blue infrastructure which benefits the wider surrounding area, as well as the new residents, and ensures that Thakeham create sustainable places to live and work.

As one of 12 members of the NHS Healthy New Towns network, Thakeham is a committed advocate of developing healthy places in line with the Healthy New Town principles. But over time, we have realised that these principles are just the starting blocks, and at Thakeham, as a founder member of the HBF Future Homes Task Force, we are committed to delivering sustainable, zero carbon communities. Out approach sets us apart from our competitors. We deliver our schemes with a focus on infrastructure-led sustainable development.

Sustainability

There is an evident theme in Greater Cambridge in respect of environmental impact and the importance of ensuring any development, whether that be residential or infrastructure, seeks to minimise its impact. Thakeham would like to take this opportunity to outline the measures implemented on its developments to minimise environmental impacts as a direct and indirect result of development:

• From 2025, all Thakeham homes will be net-zero carbon in lifetime use.
• From 2025, all Thakeham homes will be carbon neutral in production. Our off-site panellised system will make construction more efficient, faster, enhancing quality and reducing construction traffic.
• Thakeham is committed to offsetting the embodied impact from the production of new houses, as well as development houses that are zero carbon in lifetime operation.
• Thakeham support the Wildlife Trust’s guidance on Homes for People and Wildlife. Our commitment is to at least 20% biodiversity net gain (double the government’s target within the recent Environment Act 2021) on all our developments post-2025 with attractive and functional green and blue infrastructure.
• Through placemaking and the implementation of sustainable travel plans, Thakeham prioritises walking and cycling over car travel, helping people make more sustainable choices around walking, cycling and taking public transport, as well as highlighting innovative car-sharing online platforms such as LiftShare to reduce single-occupancy car use and facilitating use of autonomous vehicle/pods.
• Thakeham provides electric car charging points at all of their homes both market and affordable alike, reducing barriers to customers purchasing emission-free vehicles.
• Thakeham is keen to champion low carbon transport in the local area, encouraging local transport services such as buses to electrify their fleet.
• Mechanical Ventilation with Heat Recovery (MHVR) is installed in our homes, which has a filter built-in to capture incoming pollution to provide fresh filtered air.
• Thakeham works with its supply chain with an aim that all mechanical plant on site is less than 18 months old, which means it is less polluting and more fuel efficient

Response to Options

Thakeham has reviewed the consultation documents and has chosen to comment on key questions and themes where relevant to our business to comment on.

Vision and development strategy
Section / Policy Your comments
Vision and aims Thakeham supports the Council’s vision for new development to come forward with sustainability and healthy place shaping at the forefront.

As we’ve touched on above, Thakeham support the focus on healthy place shaping, with a need to ensure that future development maximises opportunities for journeys to be made on foot or bicycle. This will necessitate ensuring new developments prioritise non- motorised transport and are easily accessible to full range of day-to- day services and facilities.

Thakeham has made a number of commitments in respect of its own carbon impact, ensuring that all its development will be net-zero carbon in lifetime use and carbon neutral in production by 2025.
Additionally, Thakeham has made a commitment to achieve 20% biodiversity net gain on all projects post-2025 which is double that set out in the Environment Act 2021.
How much development, and where – general comments Whilst Thakeham supports a weighted distribution of development towards the most sustainable locations and key employment hubs, we would emphasise the importance of a variety of growth locations and sizes to support housing growth. New settlements, strategic extensions and development in rural locations all form a key part in meeting varying housing needs and ensuring a consistent supply of housing delivery.
S/JH: New jobs and homes Thakeham is supportive of the Councils’ conclusions that adopting the suggested ‘standard method minimum homes and related jobs’ approach would not be appropriate for Greater Cambridge and would not support its economic growth aspirations.

It is acknowledged that the Councils’ have sought to accommodate an uplift to accommodate their economic growth aspirations, suggesting that the ‘medium level of homes’ approach is justified, resulting in a need for 44,400 homes over the plan period 2020-2041 amounting

the 2,111 homes per annum, alongside provision of 58,500 new jobs over the plan period.

Whilst the ‘maximum level of homes’ does not represent the Councils’ preferred approach; it is worth noting that this approach does acknowledge housing need arising out of fast job growth and therefore the Employment Land Review makes recommendations to provide more that the ‘medium’ scenario level of jobs to provide flexibility.

Thakeham is supportive of the Councils’ intention to accommodate their full objectively assessed needs for housing and jobs within the plan area. It is also acknowledged that a 10% buffer has also been added into their housing requirement to provide flexibility, amounting to a housing requirement of 48,840 over the plan period.

The Greater Cambridge Local Plan will need to ensure that it is planning for a sufficient number of new homes to support its economic growth aspirations. Whilst it is acknowledged that the medium option for new homes does incorporate an uplift for economic growth in the area, in addition to the application of a 10% buffer to reach the suggested housing requirement. Thakeham would suggest that the Councils undertake further work to ensure that the correct uplift has been applied to ensure that the Councils can meet their relevant aspirations in terms of job creation and growth, and as consequence provide the right level of housing to support this. This is important to ensure that existing employers in the area can continue to thrive and expand importantly retaining and attracting staff including graduates, in what is a global recruitment marketplace for many of the industries already located in Greater Cambridge. Further, in order to ensure Greater Cambridge continues to be a focus for inward investment into the UK, following on from the successes of the past, continued focus on supporting employment growth will be key and part of that will be providing housing to attract not just highly skilled staff but also for the variety of lower paid workers such as cleaners, delivery drivers and shop workers. These lower paid workers are necessary to support the wider community and economy such as in Greater Cambridge, where land and house prices are high. These people are either driven out, much has been the case in London and has been seen in parts of Greater Cambridge to more
affordable locations, but with the consequence of a longer commute,

or greater affordable housing provision is required to accommodate them.
S/DS:
Development strategy The first proposals consultation is suggesting a focus on existing commitments and expansion of existing sites to meet the suggested housing need. Where new sites are proposed these are focussed predominantly within and around the edge of Cambridge.

The background text to S/DS suggests that very limited development is proposed in rural areas due the Councils’ desire to focus growth to more readily sustainable locations. Whilst, as we have touched on above, Thakeham supports a weighted distribution of development towards the most sustainable locations and key employment hubs, we would emphasise the importance of a variety of growth locations and sizes to support housing growth. New settlements, strategic extensions and development in rural locations all form a key part in meeting varying housing needs and ensuring a consistent supply of housing delivery.
S/SH: Settlement hierarchy The settlement hierarchy seeks to group together similar settlements into categories that reflect their scale, characteristics and sustainability. It then seeks to limit development in any settlements which fall within the ‘Minor Rural Centre’ category and below.

Thakeham considers this view is overly prescriptive. The Settlement hierarchy identifies just 8 settlements which would have no limit on individual scheme size:

City: Cambridge
Town: Cambourne, Northstowe and Waterbeach New Town
Rural Centres: Bourn Airfield New Village, Histon & Impington, Great Shelford and Stapleford and Sawston

The Greater Cambridge Area covers a significant geographical area and this suggested policy approach limits development opportunities across the plan area. It is suggested that development at Minor Rural Centre’s should incorporate schemes of a maximum scheme size of 30 dwellings with lower tiers suggesting significantly less.

Policies should retain a flexible approach to ensure that promotion sites and applications can be assessed on a site by site basis on the
merits and positive contribution they could make to an existing and

future community. Development opportunities in these communities could have significant longer-term sustainability benefits by helping existing services remain, and where appropriate levels of growth are accommodated, new services could be provided as a result of development.

Climate change
Policy Your comments
Climate change - general comments Thakeham is supportive of the Councils’ objectives to enhance climate change resilience and transition Greater Cambridge to net zero carbon by 2050.

As a developer, Thakeham prides itself in the objectives it has set in respect of climate change and the impact development can have.
Thakeham has a key focus on sustainable practices both in construction and placemaking. Our approach sets us apart from our competitors. Thakeham’s schemes are delivered with a focus on sustainable development, looking ahead of current housing standards. From 2025, all Thakeham homes will be carbon neutral in production and zero carbon in lifetime use. Thakeham are a founding member of the HBF Future Homes Task Force, which examines
how the house building industry can work toward delivering net
zero carbon homes in order to support the Government’s target of the country delivering ne zero carbon emissions by 2050. Thakeham has a particular focus on first improving the fabric of buildings, constructed from sustainable timber sources, consideration of sustainable energy features and a sustainable procurement strategy which encourages the use of recycled materials. Thakeham intends to open a new MMC factory in the future, which will provide locally sourced MMC constructed homes further helping to reduce the environmental impact of construction.
CC/NZ: Net zero carbon new buildings Thakeham considers that the proposed policy direction is too prescriptive and does not provide sufficient flexibility for advances in technologies and Building Regulations. Policy wording should be less prescriptive on the measures used to achieve net zero carbon buildings, rather there should be sufficient flexibility to allow the methods for achieving such targets to be assessed on a site-by-site basis. This is critical as technology is advancing quickly and will
continue to do so during the lifetime of the emerging local plan and

consequently to set prescriptive policies will have the effect of the local plan being out of date before or at adoption.

As above, Thakeham prides itself in its own objectives for all its new homes to the zero-carbon in lifetime use and carbon neutral in production by 2025.

Biodiversity and green spaces
Policy Your comments
BG/BG: Biodiversity and geodiversity Thakeham is supportive of the policy direction of BG/BG and the Councils’ aspiration to require a minimum of 20% biodiversity net gain, whilst also acknowledging the difficulties this may bring for smaller sites with a suggested contribution mechanism to allow these sites to meet the requirements of the proposed policy. However, the current policy direction seeks to limit off-site habitat measures to align with the Greater Cambridge green infrastructure network strategic initiatives.
Whilst it is acknowledged that this may represent a preferred approach, this may cause issues in deliverability due to availability of such land. Policy BG/BG should incorporate sufficient flexibility to allow sites to achieve the required biodiversity net gain requirements by measures which are most appropriate to that site, if this requires off-site habitat creation there should be sufficient flexibility to allow consideration of all suitable options to ensure such requirements do not stifle development.

Thakeham itself has already made a commitment to achieve at least 20% biodiversity net gain as a result of our projects post- 2025.

Wellbeing and inclusion
Policy Your comments
Policy WS/HD: Creating healthy new developments Thakeham supports the objective and policy direction of Policy WS/HD, requiring health principles to be applied to new development, drawing on the ten principles developed from the Healthy New Towns Initiative.

In our view, relevant policies in respect of wellbeing and inclusion could go further to set out requirements on not only creating healthy new developments, but other measures which maximise wellbeing

benefits that developments can offer those who build them, those who live in them and the communities around them now and into the future.

Thakeham itself is passionate about having a positive impact on people’s wellbeing, constantly striving to deliver against our four key- focus areas:

• Building local communities via excellent placemaking that creates interconnected communities that challenge issues of loneliness and promoting healthy living, and via our long-term charity partnerships.
• Building future generations via our school
engagement programmes, including our industry leading holistic ecology programme ‘Eddie and Ellie’s Wild Adventures’ for primary age pupils, and providing inspiring careers support to secondary age pupils through our Cornerstone Employer status with The Careers Enterprise Company.
• Building a stronger Industry with our support of small and medium size enterprises and upskilling for local workers, supporting apprenticeships, and actively contributing to the diversification and upskilling of the construction sector.
• Building Sustainable places by tackling issues of climate change, biodiversity loss and societal disconnects via our ambitious Sustainability Strategy.
WS/IO: Creating inclusive employment and business opportunities through new
developments Thakeham is supportive of the policy direction of Policy WS/IO and as touched on above, adopts its own approach to creating inclusive employment and business opportunities through our support of small and medium size enterprises and upskilling for local workers, supporting apprenticeships, and actively contributing to the diversification and upskilling of the construction sector.

Homes policies
Policy Your comments
H/AH: Affordable housing Thakeham support the Councils’ policy direction in respect of Affordable Housing and the importance that such homes are built with inclusion, health and wellbeing at the forefront. Thakeham continues to provide policy compliant affordable housing across all of our developments whilst adopting a truly tenure blind approach to affordable housing which creates cohesive communities.

H/SS: Residential space standards and accessible homes Whilst Thakeham supports the Councils’ aspiration to see good quality homes delivered across their district, such policy requirement which seeks all dwellings to meet NDSS needs to be supported by robust evidence that there is a specific need to introduce such standards.

Any policy requirements in respect of housing accessibility requirements should be based off identified need, with sufficient flexibility incorporated to ensure that provision is directed to the right places. In particular, blanket policy requirements for M4(2) in all new developments should not be adopted as these requirements should be based off identified need, whilst requirements in relation to M4(3) can be particularly onerous and should only be directed to developments where there is an identified end user.
H/CB: Self- and custom-build homes Whilst Thakeham is supportive of self and custom build home provision in Greater Cambridge, it is not considered that a blanket policy as suggested by H/CB on developments of 20 or more is appropriate or feasible. Self and custom-build products should be directed towards key strategic allocations to ensure such homes are deliverable. Self and custom build home provision should also be based off identified need.

We trust that these representations are useful and clear, and we would be grateful for confirmation of receipt of our submission. In the meantime, please do not hesitate to contact me if you have any further queries or require any further information.

Water supply for the plan consultation on idea of 48,000 new households during building and completion after estimated 20 years:
a)Water to supply such a project is unsustainable. We are already in a place of deficit - the flow of the river Cam is substantially reduced due to increase in the area’s population.
. Anglia Water is driven to plan new sewage works on green belt land which was promised to not be touched - ie Green Belt.
. Any plans to “create green spaces and nature reserves in the area” would need water for plant/tree life, currently this is hard to sustain and we know drought in summer will only increase.
. Any idea that we take water from other areas of the UK is magical thinking - they will also be suffering water shortages.
. Building reservoirs in the Fens is way out as with climate crisis it is envisaged they will be flooded with salt water.

b)Ecological issues regarding development around the Biomedical Site/Addenbrookes/SCBC/A Nine wells etc - will have a negative impact on bio-diversity that will be difficult to mitigate. More loss on insect, plant & wild life bring a further loss to falling farm bird populations. It’ll be hard to irrigate the plantations.
. We need every bit of land to grow our food in order to be secure when markets for our food importation might change. We import more than 50 per cent of our needs. The area around nine-wells Trumpington etc was historically excellent for agriculture. I have knowledge of south Cambridgeshire villages and the land is a major farming area for grain.

c) We already have a need for housing for key workers and we are not organised enough to achieve this. Developers and planning is not on top of this problem. Hopefully residential development opportunity at Marshals Airport will help but that brings up the transport problem.

d) Travel south up Babraham Rd and up on the Gogs, look back on Cambridge and often one sees a grey fog - Cambridge is in a dip which one reason for pollution being so high here. We are top in the nation for traffic jams, these are pollution machines, even electric cars produce toxic emissions. We need some of the measures proposed to dissuade car use in the area. Yes, I would agree to road charges that bring a noticeable reduction in car use. There could be a badge scheme for vans that have to carry tools and equipment.

To sum up: Such growth for the sake of the economy is not what we should be looking at in this way at this time. The climate crisis, covid and other pandemics that will follow is changing our work and travel pattern. It is changing our needs regarding water and land use and "levelling up”. Also consider AI as a big factor , many of the implications are unknown.

The area is too complicatedly organised by local government divisions with no satisfactory overview. We need to work on the many existing problems (some mentioned above) first before we totally fall for the Government’s hopeful plans for the south East and the Arc that are not regarding the complications realistically.

The Federation of Cambridge Residents’ Associations (FeCRA) is a grassroots civic voice for everyone in Cambridge and for its environment. Residents want a say in shaping Cambridge’s development to ensure that the city grows in a way that is sustainable and inclusive, achieves balanced communities and addresses the issues of climate change and health, social equality and quality of life. Residents know their areas well, and they want to be involved in evidence gathering and data collection.

Over the last years residents' associations have organised successful discussions on parking, local election hustings, Greater Cambridge transport schemes, neighbourhood planning, heritage and public realm and green spaces and the river and biodiversity.

FeCRA’s well attended AGM events are organised on the same basis, featuring presentations from prominent experts including leading landscape architect Kim Wilkie, George Ferguson, former Mayor of Bristol and the distinguished Oxford ecologist Professor David Rogers. More recently, the Supersize Cambridge event which attracted 230 people and involved community reps from all over Cambridge highlighted concerns about employment led growth and the global interests driving this. FeCRA’s strength is in its network of members in all city neighbourhoods and good channels of communication with villages across South Cambs, along with the five OxCam Arc counties and Norfolk, Suffolk, Hert and Essex. The Federation is entirely voluntary and self funded.

A sense of neighbourhood and wellbeing and belonging and mutual support is especially important in a city which has earned the unenviable title of the most unequal city in the UK.

Draft Local Plan
How much development and where
Many residents are shocked at the level of growth proposed in the new Draft Local Plan and what they see as the plan’s failure to consider the overall environmental capacity and climate change impact and the effect on the historic environment (built and natural) in a holistic way. There is no mention of Covid and opportunities for city centre residential and/or other uses resulting from potential radical changes in retail and office working.
There is no consideration or assessment of current growth in the pipeline or of the success or failure of current Local Plan policies, no assessment of the cumulative impact of current growth, especially in terms of delivering the claimed nature and quality of development.

There is a complete dearth of new cultural or provision for other ‘city-scale’ needs which will put the city centre under even greater pressure.

Where is the overall vision of what Cambridge will be like in the future? Who is the city for? This plan does not make clear.

The question of how much development and where is premature pending the January 2022 consultation on the Regional Water Plan and the investigation of sewage infrastructure and sewage dumping by Anglian Water.

Inadequate Water Supply

Cambridge City and South Cambridgeshire already have an unsustainable supply of potable water. In August 2020, the Environment Agency, in response to a query on the viability of water supply to Northstowe Phase 3A wrote to Monica Hone of Friends of the Cam that 'current levels of abstraction are causing environmental damage. Any increase in use within existing licenced volumes will increase the pressure on a system that is already failing environmental targets', and 'many waterbodies did not have the flow to support the ecology.'
On the 1st July 2021, DEFRA announced that chalk streams would be given enhanced environmental protection, and published the Environment Agency document titled “Water stressed areas – final classification 2021” which included the fact that the supply areas of Cambridge Water and Anglian Water are areas of serious water stress, page 6.
According to Appendix 3, Cambridge Water needs to reduce abstraction by 22 megalitres per day from levels current at 1st July 2021, and Anglian Water needs to reduce abstraction by 189 megalitres per day from levels current at 1st July 202

Yet, one of Anglian Water’s proposed ‘solutions’ to this problem is to pump water from North Lincolnshire, which is also classified by the Environment Agency in the above report as a water stressed area.

The expectation that ‘green’ growth and River Cam Corridor nature tourism can fund a system of water management without addressing over- abstraction and sewage in the rivers

The local sewage system is currently inadequate. The inadequacy of the sewage system is evidenced by the number of sewage spills by smaller Anglian Water sewage works into the Cam Valley. Currently, there are no plans to improve failing combined sewer overflows (csos), just promises to monitor them more accurately. The Cam Valley upstream of Cambridge saw 622 hours of untreated wastewater enter the rivers in 2020, yet Anglian Water is proposing to move the one sewage works in the area which has been upgraded and has sufficient capacity until 2050, the main Cambridge works, into the Green Belt and to spend at least £227 million of public money to do so. This will be the subject of only a partial public inquiry because it has been submitted as a National Infrastructure project in order to minimise public scrutiny.

To date there have been no upgrades at any of the smaller works in the area while more and more taps are still being connected. The Environment Agency has already warned at least one Cambridgeshire local planning authority, East Cambs District Council, that they must stop looking at the sewage requirements of single planning applications and instead look at the cumulative effects.

How can anyone talk about ‘green’ growth and nature tourism when the water companies are over-abstracting and filling the Cam chalk streams with sewage.
New jobs and homes – the plan proposes 58,500 jobs and 44, 400 homes

The way in which this consultation is framed and the fact that it does not address how the region’s water crisis and wastewater and emission problems will be resolved ignores both environmental constraints and the failure of current policies to provide affordable housing. It does not give a true picture of the cost of such high employment growth for the UK’s driest city with a water crisis whose world famous river is drying up and dumped full of sewage.

It undermines the Government’s policy of ‘levelling up.
It completely ignores how the plan will ensure that new developments are for local people and not dormitories for London commuters or just opportunities for foreign investors.

New communities take time to emerge, if they do at all, but the issue is that many new developments are injected into places with existing communities that may suffer as a result, an issue this plan does not assess.

Professor Dieter Helm, Chair of the National Capital Committee has stressed the importance of long-term risk assessment in ensuring net environmental gain, in perpetuity, despite development. There is no evidence that this has been done.

There are massive environmental capacity issues which the Draft Local Plan does nothing to address, with inadequate space in city streets and public realm to cater for existing traffic, let alone approved growth already in the pipeline – even before considering these First Proposals. The capacity issues have to be tackled, with additional growth allowed only if they can be resolved.

Green Belt Assessment

The Green Belt assessment is not fit for purpose, because it ignores historic environment designations and landscape character constraints.

On the edge of Cambridge the serious landscape impacts of the Cambridge BioMedical Campus expansion southwards into the Green Belt open countryside towards the Gogs will severely damage this lovely setting of the city with its beautiful chalk downland views. The expansion and likely increase in footfall will hugely impact the small nature reserve of Ninewells, the reserve’s unique character and boskiness and farmland birds.
Building NE Cambridge will indirectly destroy the Green Belt by displacing the sewage works and using a lot of concrete which has a very high carbon footprint.
There is no operational need to move the treatment works as Anglian Water has confirmed. The relocation is taking place to enable development within Cambridge in which the water company is a beneficiary as co-developer. The current site is more than adequate for at least another 30 years and could be upgraded at far less cost. The existing treatment works at Milton is effective and has spare capacity. It was upgraded only recently, at a cost of £21 million in 2015, in order to support planned development in Cambridge and the surrounding area until 2050 and is being vacated only to enable redevelopment. We understand that the Milton Plant is currently only running at approximately 50% capacity. The CO2 cost embedded in the new structure and emitted in demolition and construction is sizable.

Many residents question why the works are being moved given the impact on the Green Belt, the loss of valuable farmland, and the harm to local communities, all of which are united in their opposition. They question how this complies with the guidance outlined in the HM Treasury’s Green Book Valuation of Wellbeing Guidance for Appraisal https://www.gov.uk/government/publications/green-book-supplementary-guidance-wellbeing especially as the Stantec Report prepared as part of the review of the Local Plan and the letter from the Environment Agency https://www.fecra.org.uk/docs/Env%20Agency%20re%20Northstowe%207%20August%202020.pdf make clear that any further development beyond that already planned is unsustainable as ‘current levels of abstraction are causing environmental damage. Any increase in use within existing licensed volumes will increase the pressure on a system that is already failing environmental targets’.

There is no mention in these plans of how relocation of the wastewater plant will address any of the concerns about all the sewage being dumped in the Cam or how Anglian Water proposes to make the River Cam clean and safe for all users. If you were going to spend £200m plus, or even a fraction of it, it should be spent on improving and updating the small local sewage works based around villages etc, which release sewage in the Cam via its tributaries, not on rebuilding something that is working well. In the case of these small poorly functioning sewage systems Anglian Water is almost solely responsible and that is what residents tell us this company should be focusing on, not this grandiose money-making scheme. The chair of Water Resources East, Dr Paul Leinster, is a member of the new Office for Environmental Protection. He is on public record as stating that what to do with the wastewater is one of the biggest problems for development in the region proposed by the government for the Oxford Cambridge Arc.
There are a number of SSSI’s close to the site which could be affected by its construction and operation: Brackland Rough, Cam Washes, Cherry Hinton Pit, Chippenham Fen and Snailawell Poors Fen (a RAMSAR site), Devils Dyke, Felan Dyke, Fulbourn Fen, Gog Magog Golf course, Great Wilbraham Common, Histon Road, Roman Road, Snailwell Meadows, Stow-cum-Quy Fen, Upware South Pit and Wicken Fen, which is another RAMSAR site.

Anglian Water recognises the likelihood that the surface water originating at the works at the Honey Hill site will drain towards Quy Waters protected waterbody and could contaminate it. Yet they have ignored the fact that contaminated groundwater in the chalk aquifer beneath the site could pollute these other receptors and protected rights (local well users) as well as other parts of the surface water drainage network.

The Honey Hill site is in the National Trust Wicken Fen Vision. This is a National Nature Reserve and a Nature Conservation Review site. It is a designated RAMSAR, SAC wetland site of international importance and part of the Fenland Special Area under the Habitats Directive. How does a scheme which robs East Cambridgeshire villages of their green belt and medieval river landscape setting and which impacts the Wicken Fen Vision correlate with protecting Green Belt land which is specifically designed to preserve the historic character of Cambridge and its green belt setting and the River Cam?
Democratic deficit in the process and evidence basis for the Draft Local Plan

Water Resources East have stated that their regional water plans which include plans for natural capital align with the Government's plans for growth. Sewage in rivers and chalk streams is a matter of national concern, yet Water Resources East say that sewage is not part of their remit. They have also said that there will not be public consultation on the regional water plan.

Meanwhile, the public consultation for the Draft Local Plan is taking place now, yet the consultation for the Regional Water Plan is not due until summer 2022. The public and councillors are forced to respond to Local Plan proposals with no idea whether, and if so, how, the water and sewage challenges can be resolved or what trade-offs have been proposed.

South Cambs. MP Anthony Browne has rightly expressed concerns about the Local Plan process and about water issues and transparency.

The Draft Local Plan has been prepared by the Greater Cambridge Shared Planning Service, but it appears to be inordinately influenced by the unelected Greater Cambridge Partnership which has business interests represented on its board.

Much of the text of the Draft Local Plan appears to be consistent with announcements made by the self- appointed Arc Leaders Group promoting the so-called Ox-Cam Arc. This flawed concept has been criticised for lack of transparency or accountability right across the five affected counties and one county, Buckinghamshire, has withdrawn entirely from this completely undemocratic, self-selecting, body.

At a presentation of growth scenarios for Cambridge Futures3 given by the Vice Chair of Cambridge Ahead Matthew Bullock and Dr Ying Jin in June 16, 2018 the audience pointed out that all of the scenarios for Cambridge Future 3 led to Cambridge having a much higher level of growth.

They highlighted that the growth scenarios made no mention of environmental capacity issues, nothing on climate change, quality of life, affordable housing or why people chose to live in and around Cambridge for cultural and green spaces reasons etc. At the presentation it was made clear that Cambridge Ahead & Cambridge University planned to monetise the model they had come up with.

So the model was not in any sense charitable work, it was completely commercial.
Bullock stressed how complex the model was that Dr Ying Jin and his team had come up with and that they would need to come up with a price for running the model with different input parameters.

This meant that Cambridge Ahead and Cambridge University controlled access to the model, limiting detailed scrutiny and testing by independent third parties.
Those working on the growth scenarios included officers and consultants from SQW – the same consultancy employed along with the real estate consultants GL Hearn by the planners to assess the modelling for the Draft Local Plan as ‘they were not conflicted’.

The presenters Matthew Bullock and Dr Yin Jing said that changing elements of the model and programming scenarios was technically challenging and slow, making it difficult or impossible to test a large number of scenarios.

They also said that they intended to monetise the model, e.g. by charging planning authorities, ONS (the Office of National Statistics) and developers to use it.

The business group Cambridge Ahead had a strong commercial motive for this modelling and the modelling evidence for a much higher level of growth and lots more houses to be built, gives a strong lead on where development should take place. Attendees at the Case for Cambridge Future 3 meeting pointed out that the pre-set "no holds barred" scenarios defined by Cambridge Ahead and Cambridge University and officers and consultants working with them would thus become the only options, even though there were likely to be many other scenarios that would produce better outcomes.
Thus the modelling that has been used to inform the Cpier Strategy cited in the Greater Cambs Employment Land and Economic Development Study Draft Local Plan does not take account of social justice, regional landscape strategy or address environmental capacity issues including those of the river, the city centre and the city’s green spaces. Nor does it consider how people want to live, respecting what communities value, and the issues of climate change, the natural world, water shortage, sewage etc.

This Draft Local Plan reflects those pre-determined scenarios of building on the urban fringes and transport corridors to support the high employment growth defined by Cambridge Ahead and the interests funding the research.

At the Case for Cambridge Future 3 meeting attendees referred to "No holds barred scenarios" and a number of people noted the 'densification' scenario assumed that Trumpington Meadows would be developed alongside Cambridge South station as a location for high density development which would assume a planning approach of creating new development which you “mitigate” by reserving areas of green spaces as ‘wild belt’. They pointed out the approach was to sell housing on that basis and then take it back afterwards for infill and that this was already happening at Cambourne.
The same point about infill and wild belt was made by David Plank of the Trumpington Residents Association regarding the recent presentation by the planners of the Draft Local Plan and the BioMedical Campus Expansion plans round Ninewells to the South Area Committee.
In August 2019 the FeCRA Committee wrote to the Deputy Leader of Cambridge City Council to express concern that the Shelford Local Plan workshop for city residents, cited as the formal first stage of public engagement on the Draft Local Plan had been organised at very short notice and with very little opportunity for city residents to engage in the first formal stage of the Local Plan Process.

FeCRA filmed all f the Local Plan Presentation on the 2018 Local Plan. The film is available for everyone to see. There was very positive feedback from Residents Association members but the presentation also flagged up major concerns about the ‘growth agenda’ and the apparent lack of transparency and democratic input around it.

We were told at that meeting that there would be an opportunity for residents to contribute to early discussions about the next LP, yet this Local Plan workshop was arranged at such short notice and at a time and place that made it difficult for many city residents to attend. Consequently very few city residents attended.

Green Infrastructure Modelling Workshops
In June 2020 Deputy Director of Greater Cambridge Shared Planning, Paul Frainer, writing to the FeCRA Committee, said:
‘Ahead of and separate to the Local Plan process, the Local Nature Partnership (as a separate body albeit with some local authority input) has identified priority projects it would support if funding were to become available in the short term, but no decisions have been made through the Local Plan process about which green spaces to prioritise.

The Local Plan green space evidence base study will identify priority projects, and will advise which should be included in the Local Plan, and which should be delivered through land management as opposed to development processes. This priority list will in future also inform biodiversity net gain offsetting, and bids for funding from other sources’.

The minutes for the June 2020 Natural Cambridgeshire board meeting states that the board will:
• ‘Work with developers to enhance nature either on site or through offsets’ –Cameron Adams, the Environment Agency
• ‘Consider how best to engage with farmers and other landowners, and help them get better returns from their investments’ –Rob Wise NFU
• ‘Collaborate with Natural Capital East’ –Cameron Adams
• ‘Review progress of Doubling Nature at end 2020’ –Richard Astle - Athene Communications
On 26 July 2020 the FeCRA Committee wrote to MPs, copied to the planners and Lead Councillors to express concern about the Greater Cambridge Green Infrastructure Online Survey - 27 July which had been framed again in a way that excluded residents from having a say, particularly about the river and its historic environment. They asked why this survey was linked to funding bids, S106 development sites and future parks accelerator plans and why there had been no assessment of impacts and issues arising from current and already approved growth on green spaces at this stage?

“Why is there no engagement with strategic environmental capacity issues as a vital part of the evidence base for the new Plan?” The Committee pointed out that the government’s plan for sustaining high growth and building one million houses in the OxCamArc is underpinned by Natural Cambridgeshire’s vision for “doubling local nature”, with urban fringe parks in the green belt. Plans for ‘linear river parks’ feature in council and development plans but there had been no consultation with friends or river groups or local councillors.

The River Cam is the only river in the country that is not back to normal flows, yet exponential growth fuels huge pressure upon our natural water supplies. Concerns about the impact of over-abstraction on the River Cam have been expressed but large development keeps getting approved.

Stage 3 of this Local Plan Green infrastructure consultation featured technical workshops, themed around the benefits that green infrastructure provides, to discuss the issues and opportunities arising from the survey responses.

Community reps and residents who had not been able to engage with this survey or who didn’t have funding bids with developers and NGO’s were not able to get a say at the next stage.

This letter followed concerns expressed to Greater Cambs Planners and Cllrs Katie Thornburrow and Bridget Smith that many residents had not been able to access the on line Green Infrastructure consultation hub and the inaccuracy of the mapping and data, highlighted by experienced university conservationists.

Addressing the challenges of climate change and health, social equality and quality of life benefits from local knowledge and the involvement of residents who know about water, flooding, wildlife and nature and managing green spaces and local resources in their areas, working with their elected councillors. Residents say that decisions about land use and ecology have been made by business and interest groups without local knowledge or accountability

The inspirational town planner Jan Gehl advocates that to build communities that work well where people, not cars, occupy the pavement, the evidence needs to be shown and environmental capacity issues need to be addressed. One should count all the pedestrians, cyclists and strollers going by, just as highway planners have long tallied up road users in vehicles and the number of people using the river and its green spaces.
Where is the evidence that this has been done in the Draft Local Plan? It has not been demonstrated that there is sufficient water supply within Greater Cambridge to support future development and existing ground water abstraction is impacting water flows within chalk streams in the region anday need to be reduced, especially in the light of climate change.

The situation with groundwater around Cambridge is critical: the whole Cam river system is in crisis
Using water more efficiently is important, but efficiency will not increase the maximum volume of water that can be supplied on a sustainable basis without impacting the environment.

As such REFUSAL of developments is necessary where there is no available water to supply them and/or the environmental impacts caused from supplying that water outweigh benefits of the grant of that permission.
A similar point applies to discharge, especially where this is to groundwater. Where a European site is affected, alternative locations and OROPI ( Overriding Reasons of Public Interest ) may need to be considered prior to any planning decision.

NPPF para 7 makes this point: "The purpose of the planning system is to contribute to the achievement of sustainable development. At a very high level, the objective of sustainable development can be summarised as meeting the needs of the present without compromising the ability of future generations to meet their own needs. "

The presumption in favour of sustainable development cannot be determined without sufficient information on the water demands of a development, how these will be met and the implications for the environment and future generations.

We strongly suggest that all planning applications should at application stage confirm their total required annual water usage and have accompanying documentation to confirm that such water can be supplied and discharged where applicable in a manner.

We suggest that all developments are subject to Habitat Regulations Assessment based on their cumulative and in-combination impacts on the available water supply.

Biodiversity
Conservation is essential to sustainable development and together with enhancement of biodiversity should be considered as a key element of good planning and design. 'Doubling nature', Biodiversity Net Gain (BNG) and Natural Capital Accounting (NCA) are being used as bargaining chips by developers. That broadly amounts to saying, 'No development means no funding for nature'. This is the antithesis of John Lawton's 2010 plea in 'Making Space for Nature' of significant funding for Nature conservation without any strings attached.
The concept of doubling nature is ill-defined - doubling what, exactly? The Draft Local Plan needs to define exactly how the concept will be understood and measured.

The global experience of Biodiversity Net Gain, reviewed by zu Ermgassen of DICE, University of Kent, is that it fails twice as often as it succeeds, even though it had the lower bar of No Net Loss, NNL rather than BNG.
The same group more recently showed that 95% of early-adopters of BNG practices in England are carrying out on site offsetting (something not covered at all in the new Environment Law), where the developer is the judge, jury and executioner of any offsetting plans. In any case, on site offsetting will not encourage many forms of wildlife and will be prone to the dog-fouling and trampling that harms many wildlife areas, even those remote from housing. Meanwhile, off-site off-setting is already damaging local communities in some rural areas.
Natural Capital Accounting is an untested concept. The monetary assessment of ecosystem services (the 'yields') is recognised as being inadequate at present, while assessing the monetary value of ecosystem stocks is more or less impossible (Ian Bateman, communicated to David Rogers). Yet the resulting monetary assessments may be used to trade away environmental for economic assets with a greater yield, for example a factory in a water meadow.

The natural environment is our vital life support system, and it is a dangerous delusion to imagine that it can be rendered easily into any economic framework, let alone the pre Dasgupta framework that gives GDP/GVA primacy over all other forms of stocks and yields.
Dasgupta defines wealth as the sum of natural, human and economic capitals and yields, and sustainability as the condition where this sum is either stable or increasing. Economic growth at the expense of natural capital and yields is therefore unsustainable.
We request that the Cambridge Local Plan adopts the Dasgupta definition of sustainability, i.e. definitely not the NPPF's false definition of 'sustainability', with the caveats mentioned above, especially the false or under-valuation of natural capital. This would provide a better starting point, and the Plan should be reworked in this context.

Sea level rise
Large areas of Cambridgeshire, including parts of the City of Cambridge, are subject to continuously increasing flood risk. Indeed, not only is sea level rising, the rate of sea level rise is increasing rapidly. For many years, since measurement began, sea level in the Wash was rising at a rate of 3mm per year. In 2019 it was measured by the Environment Agency in the Wash, and confirmed by IPCC figures globally, that the annual rate was now 3.3mm per year. In 2014, the IPCC report estimated a sea level rise of 1 metre by 2100. In 2019, the IPCC increased this estimate to 1.1 metres by 2100. In 2021, the IPCC has increased its estimate again, to a terrifying 2.4 metres by 2100. Meanwhile, the meteorological partnership Climate Central estimates a 4.7 metre sea level rise by 2100 if global temperatures rise by 2°C. Both the IPCC 2021 and the COP26 leadership have confirmed that the world is currently on track for a 2.4°C global temperature rise.

The other solution to Cambridgeshire’s water shortages being proposed by Water Resources East and Anglian Water is to build two reservoirs in the Fens, one in South Lincolnshire, the other in Cambridgeshire near the River Great Ouse. However, there is little point in building reservoirs in the Fens when it is clear that there is a high risk they will be flooded by saline water within decades.
As flood risk increases, the Fens will initially be subject to occasional and then annual flooding caused by water in its tidal rivers meeting increased volume of run-off from development. Eventually, the tidal inflow will prevail and flooding will become permanent as the sea level inexorably increases. However, even the first stage will have a significant negative effect on agriculture. The Treasury Green Book assumes loss of cropping for one year if sea water inundation occurs. In fact, as was found in the 1947 and 1953 floods, reduced crop yields last up to seven years due to the presence of a nematode in sea water.

Climate Change
We support regular reviews to keep pace with developing technology, standards, Government targets (e.g. the Heat and Buildings Strategy, not mentioned in the draft Plan) and rapidly developing guidance and best practice. There are also serious quality control challenges in relation to whether aspirational aims are actually delivered. Outline planning permissions must be subject to the aspirations articulated in the Draft Local Plan.

How will this be done?
The definition of a Net Zero Carbon building set out in the evidence Base does not include its embodied carbon: this is a very serious omission which undermines all claims made about the sustainability of new development, and raises questions about the claimed sustainability credentials of all the Growth options being proposed.

Projects proposed to help achieve net zero need to be both delivered and safeguarded throughout the Plan period, to ensure that the aims are delivered (e.g. need to ensure that biodiversity / natural capital / “doubling nature” ( sic) and any other such schemes are protected from subsequent inappropriate changes of use or management)

For all of these reasons we strongly object to the level of growth proposed in the new Draft Local Plan
Local government should not be planning more economic and population growth in this area or more housing than current government targets require, but prioritising social housing and new water infrastructure to reduce stress on our rivers and wildlife. It should be supporting the national ‘levelling up’ policy. It should be consistent with the government’s ‘brownfield first’ objective which will deliver badly needed homes faster. It should take into account the growing flood risk to large parts of the county and consequences for national food supply. It also needs to take into account the as yet, unknown, long-term effects on employment and travel behaviours of the COVID pandemic.

We request that this flawed Draft LP is rejected, re-written and re-submitted for full public consultation.

Greater Cambridge Employment and Housing Need
1 Introduction
1.1 This report has been prepared by Bidwells LLP, to support representations on the first proposals for the Greater Cambridge Local Plan (GCLP). The report explores the evidence on housing and employment need produced by the Greater Cambridge Shared Planning Team (GCSPT) that are preparing the GCLP for Cambridge City Council (CCC) and South Cambridgeshire District Council (SCDC).
1.2 The GCLP first proposals suggest requirements of 44,400 homes and 58,500 new jobs between 2020 and 2041. Accommodation for gypsies, travellers and travelling show people sites will be proposed but numbers are still to be confirmed.
1.3 The objective assessment of housing and employment need is a requirement of the National Planning Policy Framework (NPPF) and should adhere to the accompanying Planning Practice Guidance (PPG)
1.4 NPPF paragraph 8 explains that to achieve sustainable development, the planning system has three interdependent objectives:
“a) an economic objective – to help build a strong, responsive and competitive economy, by ensuring that sufficient land of the right types is available in the right places and at the right time to support growth, innovation and improved productivity; and by identifying and coordinating the provision of infrastructure;
b) a social objective – to support strong, vibrant and healthy communities, by ensuring that a sufficient number and range of homes can be provided to meet the needs of present and future generations; and by fostering well-designed, beautiful and safe places, with accessible services and open spaces that reflect current and
1.5 NPPF paragraph 11 then explains how the presumption in favour of sustainable
development functions for plan-making:
“a) all plans should promote a sustainable pattern of development that seeks to: meet the development needs of their area; align growth and infrastructure; improve the environment; mitigate climate change (including by making effective use of land in urban areas) and adapt to its effects;
b) strategic policies should, as a minimum, provide for objectively assessed needs for housing and other uses, as well as any needs that cannot be met within neighbouring areas, unless:
i. the application of policies in this Framework that protect areas or assets of
particular importance provides a strong reason for restricting the overall scale,
type or distribution of development in the plan area; or
ii. any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole.”
1.6 It is within this context that the GCSPT prepared or commissioned the following:
● The Employment Land and Economic Development Evidence Study (ELEDES)
● The Housing and Employment Relationships (HER) report
● The Development Strategy Topic Paper
● The Sustainability Appraisal (SA)
1.7 These reports are considered in the following three chapters with Chapter 5 providing conclusions and recommendations.
2 Employment Need
2.1 As set out in the previous chapter, the NPPF's economic objective set out in paragraph 8 is to:
"help build a strong, responsive and competitive economy, by ensuring that sufficient
land of the right types is available in the right places and at the right time to support
growth, innovation and improved productivity; and by identifying and coordinating the
provision of infrastructure;"
2.2 This should be read in the context of NPPF paragraph 16, which highlights that plans should be prepared positively, in a way that is aspirational but deliverable. NPPF paragraph 35 is also relevant, which makes clear that plans are 'sound' if they are positively prepared - providing a strategy which, as a minimum, seeks to meet the areas objectively assessed needs.
2.3 Chapter Six of the NPPF then sets out specific economic principles with paragraph 81 stating that:
"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."
2.4 The Government sees Cambridge’s life sciences cluster as a significant unique selling point for UK PLC when seeking trade partners globally, with UK Trade & Investment (UKTI, now part of the Department for International Trade) committing to help in securing inward investment as part of the 2014 Growth Deal. The importance of its success for the national economy post-Brexit and Covid-19 should not be underestimated. Indeed, the £2.9 billion it contributes to the UK economy was highlighted in the recent consultation on the Oxford-Cambridge Arc Spatial Framework.
2.5 NPPF paragraph 82 continues by making clear that planning policies should:
“a) set out a clear economic vision and strategy which positively and proactively encourages sustainable economic growth, having regard to Local Industrial Strategies and other local policies for economic development and regeneration;
b) set criteria, or identify strategic sites, for local and inward investment to match the strategy and to meet anticipated needs over the plan period;
c) seek to address potential barriers to investment, such as inadequate infrastructure, services or housing, or a poor environment; and
d) be flexible enough to accommodate needs not anticipated in the plan, allow for new and flexible working practices (such as live-work accommodation), and to enable a rapid response to changes in economic circumstances.”
2.6 Finally, NPPF paragraph 83 states that:
“Planning policies and decisions should recognise and address the specific locational requirements of different sectors. This includes making provision for clusters or networks of knowledge and data-driven, creative or high technology industries; and for storage and distribution operations at a variety of scales and in suitably accessible locations.”
2.7 What is very clear from the NPPF therefore is the importance of enabling aspirational sustainable economic growth, particularly in areas that benefit from specific clusters that are important to the UK economy and its share in the global economy. It is also clear that when determining the scale of economic growth a plan should seek to target, it should only be limited by what can reasonably be delivered, without constraint. Environmental or social constraints might be applied later in order to achieve a pattern of sustainable development, but the starting point for formulating policy should be deliverable, objectively assessed, economic growth.
2.8 The PPG is relatively limited on how the objectively assessed employment need should be determined. At paragraph 2a-027 it suggests that following sources of data:
• “sectoral and employment forecasts and projections which take account of likely
changes in skills needed (labour demand)
• demographically derived assessments of current and future local labour supply (labour supply techniques)
• analysis based on the past take-up of employment land and property and/or future property market requirements
• consultation with relevant organisations, studies of business trends, an understanding of innovative and changing business models, particularly those which make use of online platforms to respond to consumer demand and monitoring of business, economic and employment statistics.”
2.9 The paragraph ends by stating that:
“Authorities will need to take account of longer term economic cycles in assessing this data, and consider and plan for the implications of alternative economic scenarios.”
2.10 For the GCLP, employment need is calculated within the ELEDES.
2.11 The ELEDES recognises that forecasting employment is complicated, mostly due to the rapid changes seen in employment growth over the last decade compared to the decade before. As a result, there are several estimates of current employment across Greater Cambridge that cannot at this time be rationalised to form a single base to which then be used to forecast future employment need.
2.12 When published next year, the 2021 Census will assist in this and will result in much of the data on which the ELEDES is based on, from the 2011 Census onwards, being revised. In many areas these revisions will be minimal but areas that have seen substantial change, such as Greater Cambridge, are likely to see the greatest revisions. It is likely therefore that the ELEDES will require revision before the GCLP is adopted.
2.13 In essence the ELEDES relies heavily on the East of England Forecasting Model (EEFM), deviating from it only for key industrial sectors that the model is known to struggle with, namely the research and development, health and care, and professional services sectors.
2.14 The EEFM was originally designed by Oxford Economics and is currently owned by the East of England Local Government Association (EELGA). The most recent outputs of the model have been prepared by Cambridge Econometrics. These outputs are 2019 based and use the ONS 2016-based Sub National Population Projections (2016SNPP). The 2016SNPP has since been replaced by the 2018SNPP.
2.15 There have been a number of criticisms of the EEFM in recent years, most notably how the model is constrained to the 2016SNPP at the regional level. This means that any economic growth that would need a greater population than that seen in the 2016SNPP is effectively disregarded. In addition, many of the assumptions are fixed at the 2011 Census results, such as in the commuting matrix that determines residence employment, with no provision to modify these where more recent data suggest they are no longer appropriate.
2.16 Care therefore needs to be had in considering the results of the EEFM in a strategic planning context, where the NPPF requires the employment need to be unconstrained and objectively assessed.
2.17 Fundamentally, since the completion of the ELEDES, the EELGA has now decided to discontinue updating the EEFM. While the reasons for this are unclear, the fact that both the original designer, Oxford Economics, and the latest operator, Cambridge Econometrics, both produce economic projections that are not constrained by population, it is likely that it is no longer considered fit for purpose.
2.18 Despite this, this does not mean that the EEFM should be automatically disregarded. It does provide a good indicator of how the economy may develop within the context of the assumptions included in the model. Therefore, it is reasonable to assume as a baseline that employment growth would be 40,100 jobs between 2020 and 2041 as the ELEDES sets out. However, as is recognised, this would mean that those key sectors that the EEFM struggles with would be heavily constrained.
2.19 To remedy this the ELEDES takes these key sectors and considers them separately. It recognises that if historical average growth rates were to be applied, future growth would be exponential. In many cases exponential growth would not matter as the real increase in employment each year would be miniscule. However, based on the rapid growth seen in recent years in these key sectors, exponential growth would quickly become undeliverable. Therefore the ELEDES, quite rightly seeks to ‘dampen down’ this growth to a more realistic level.
2.20 However, what is concerning is that this dampening down is based on the EEFM baseline projection –the very projection that the ELEDES acknowledges fails to adequately address growth in the key sectors in the first place. Furthermore, the ELEDES only sets out two scenarios for this dampening down:
● The Central Growth Scenario (KS2) which is the lower quartile between the EEFM baseline projection and the historic growth rate between 2001 and 2017.
● The Higher Growth Scenario (KS3) which is the mid-point between the EEFM baseline projection and the historic growth rate between 2001 and 2017.
2.21 No consideration appears to have been given to a scenario using the upper quartile.
2.22 Fundamentally there appears to be little analysis of which quartile (which are in themselves arbitrary) might be the most appropriate beyond the assertion that the Greater Cambridge economy is at a peak and over the longer term growth will likely be lower than that seen in the past decade.
2.23 This fails to recognise the unique narrative behind the exceptional growth seen in the past decade.
2.24 The last Cambridgeshire Structure Plan and East of England Regional Spatial Strategy sought to heavily constrain development around Cambridge, in particular by limiting the amount of non-R&D floorspace that could be built. The Green Belt as well acted as a clear brake on development, preventing the expansion of Cambridge.
2.25 It was not until the currently adopted Cambridge City and South Cambridgeshire Local Plans started to be developed that these tight restrictions started to be loosened, in the context of the new NPPF, which promoted economic growth. Even then, many developments were affected by the 2008 recession and investment was hesitant until the plans were finally adopted in 2018. It was therefore only after 2018 that investment truly started to reflect its full potential. In the three short years since then, which have seen the Covid-19 pandemic and the realisation of Brexit, insufficient data is available to determine where in an economic cycle the Greater Cambridge economy might currently be.
2.26 Given that most of the data used in the ELEDES pre-dates 2018, prior to the adoption of the local plans, it is highly unlikely that it represents the peak in the Greater Cambridge economic cycle.
2.27 Assuming therefore that those key sectors that contribute such a significant proportion of the growth in recent years should reflect the lower quartile between the EEFM and historic growth rate is unreasonable. It would suggest that the mid-point or the upper quartile might be more appropriate, perhaps an even higher figure.
2.28 It is also important to not focus entirely on those key sectors. For every person working in those key sectors, there will need to be people working in other essential sectors if the local economy is to function. For example, there is little point in making specific provision for life scientists if provision is not also made for those teaching their children, serving them in the supermarket, or those building their new home.
2.29 The analysis in the ELEDES does not seem to recognise this ‘sticky’ relationship between sectors. If one sector is being uplifted from the EEFM baseline, all other sectors should also be uplifted to some degree to balance the economy.
2.30 At this stage, with the 2021 Census to be published early next year, it is not appropriate to provide an alternative analysis of employment need. However, it is likely that the answer is within Table 10 of the ELEDES. This shows that the lowest projected employment growth is derived from the EEFM at 40,100 jobs while the highest is from the 2011-2017 annual average change at 125,200 jobs.
2.31 This higher figure is likely to be too high, not least because (reflecting the NPPF) it is unlikely to be deliverable. The lowest the GCLP should be planning for is 45,761 jobs, which is linked to the Local Housing Need Standard Method (LHNSM), rather than the EEFM 40,100 jobs.
2.32 Realistically, employment need is likely to be the average between the 2001-2017 annual average change and 2011-2017 annual average change, 90,250 jobs. This closely reflects the CPEIR proxy result of 92,100 jobs. This would seem to best fit the requirements of the NPPF by reflecting an unconstrained view of employment growth while recognising what is realistically deliverable.
3 Housing Need
3.1 As set out in chapter one, the NPPF's social objective set out in paragraph 8 is to:“support strong, vibrant and healthy communities, by ensuring that a sufficient number and range of homes can be provided to meet the needs of present and future generations; and by fostering well-designed, beautiful and safe places, with accessible services and open spaces that reflect current and future needs and support communities’ health, social and cultural well-being;”
3.2 Housing is central to the NPPF and is referenced more than any other use. As set out in paragraph 60:
“To support the Government’s objective of significantly boosting the supply of homes, it is important that a sufficient amount and variety of land can come forward where it is needed, that the needs of groups with specific housing requirements are addressed and that land with permission is developed without unnecessary delay.”
3.3 To this end, the Government has introduced the Local Housing Need Standard Method (LHNSM) in paragraph 61 of the NPPF to determine the minimum number of homes that strategic planning policies should plan for. However, LHNSM is not the objectively assessed need for housing, which is the minimum amount of housing strategic policies should seek to achieve, as clearly set out in NPPF paragraph 11. It is therefore incumbent on a strategic plan-maker to determine if the objectively assessed need is higher or lower than the LHNSM. If the objectively assessed need is lower than the LHNSM, the LHNSM takes precedence and the objectively assessed need becomes largely irrelevant. If the objectively assessed need is higher than the LHNSM, the OAN takes precedence and the LHNSM becomes entirely irrelevant as it is a simple policy tool.
3.4 Paragraph 2a-010 of the PPG explains the circumstances where the objectively assessed need for housing is likely to be higher than the LHNSM, which does not:“predict the impact that future government policies, changing economic circumstances or other factors might have on demographic behaviour”.
3.5 The paragraph then provides some examples of circumstances where this might be appropriate such as growth strategies, strategic infrastructure improvements or unmet needs from neighbouring authority (the latter is not relevant in this case). The paragraph then notes that there might be other evidence to suggest significantly greater levels of housing need, such as Strategic Housing Market Assessments (SHMAs).
3.6 In the case of Greater Cambridge, the ELEDES clearly sets out the employment need would require more housing than suggested by the LHNSM. Therefore the LHNSM is no longer relevant and no further consideration is given to it in this report.
3.7 The HER report takes the two employment need scenarios set out in the ELEDES, as discussed in the previous chapter, and converts the number of jobs into homes.
3.8 To do this the HER needs to first determine the baseline resident population. In
Cambridge, this has always been an issue given its substantial student population and yet the HER analysis seems to misunderstand this. While the report does identify that the differences between official population estimates and the much higher estimates for the patient register are most likely due to students, it dismisses the patient register on the basis that too few dwellings have been delivered since 2011 to accommodate that population rise.
3.9 There are two issues with this. First, using dwellings as the measure ignores student housing entirely, which will have supported a considerable population. Second, where students are occupying market housing, they tend to do so at far greater densities (people per household) than families.
3.10 In terms of the first point, the Housing Land Supply report identifies that 1,112 dwellings were completed in Cambridge in 2017/18 and 868 dwellings in 2018/19. However the Housing Delivery Test (HDT) results suggests that the number of homes delivered, which includes communal establishments, was 1,145 and 1,098 respectively. This alone suggests 13% more homes than dwellings alone.
3.11 Rather than just blending the two sources of population data, it would be better to provide scenarios considering the implications of using the official estimates, the patient register and different blends of the two. This would allow the reader to understand the sensitivities involved.
3.12 Other economic variables such as unemployment rates, economic activity rates and double-jobbing are considered appropriate. The one exception however is the
commuting ratio applied.
3.13 It is welcome that the GCSLT have selected the 1:1 commuting scenario as the housing requirement to pursue. However, it is concerning that this 1:1 only relates to jobs in excess of those supported by housing equivalent to the LHNSM result using the 2011 Census ratio. As discussed above, the LHNSM is purely a policy tool for determining the minimum number of homes LPAs should seek to plan for. Its inaccuracies are well documented and there is no valid reason to include it in any form in a more comprehensive analysis of housing need.
3.14 As such, the modelling should be revised to consider the implications of a 1:1 commuting scenario on all jobs to be delivered by the GCLP. In addition, it would be appropriate to consider the implications of a further uplift in housing to remedy the rise in in-commuting as a result of the adopted local plans failing to provide sufficient housing for the actual growth in employment. This has led to housing pressures in surrounding areas that were not planned for and would perpetuate a pattern of unsustainable commuting unless addressed.
3.15 As discussed in the Development Strategy Topic Paper, the actual level of 44,400 homes pursued in the GCLP first proposals consultation is linked entirely to the selected employment need. If the employment need was deemed to be higher, the housing need would be higher too. This is entirely appropriate but highlights how fundamental it is to ensure the correct employment need is selected to avoid a repeat of the increased in-commuting seen as a result of proposals largely facilitated by the currently adopted local plans.
3.16 However, there also appears to be confusion by what is actually meant by ‘homes’ (referred to in the Topic Paper and GCLP first proposals) and ‘dwellings’ (refereed to in the HER). As discussed above, the two are not the same.
3.17 In determining the household formation rates, the HER would have first discounted an amount of the population each year that would live in communal establishments such
as student accommodation and care homes. For most age groups this is a fixed number of people living in communal establishments with the exception of those aged 75+ where the percentage of the population aged 75+ that lived in communal establishments is used. In both circumstances the data is taken from the 2011 Census and is assumed to remain fixed up until the base date of the projection (in this case 2020) through to the end of the projection.
3.18 In the case of the HER, it is clear that a considerable number of homes in communal establishments were delivered in 2017/18 and 2018/19, and it is highly likely that similar numbers were delivered each year since 2011. Therefore the starting assumptions for the base date are likely to be incorrect and this is likely to have influenced the household formation rates used.
3.19 Furthermore, because the number of people of an age that are likely to be students remains fixed, the projections cannot consider any additional need for student accommodation.
3.20 It is complex to model this within the projections and instead this additional growth is usually determined in consultation with the universities to take account of their specific plans for expansion. This doesn’t appear to have happened, which is surprising given that Greater Cambridge has one of the greatest concentrations of students relative to the size of its resident population.
3.21 Consequently, the housing requirement of 44,400 must be dwellings only because it does not include any consideration of communal establishments of any kind.
4 Sustainability Appraisal
4.1 The Sustainability Appraisals are required to incorporate the statutorily required Strategic Environmental Assessments (SEAs) of policies and plans. As part of this, there is a requirement for reasonable alternatives to considered on a like-for-like basis, allowing the reader to compare the environmental effects and wider sustainability issues associated with different development scenarios.
4.2 The quantum of development is but one area that logically should be subject to reasonable alternatives, particularly where the evidence base (both the ELEDES and HER) set out a series of scenarios for the decision maker (in this case the GTSPT) to consider before selecting the most appropriate as a matter of planning judgement. It is surprising therefore that the SA accompanying the GCLP first proposals fails to identify any reasonable alternatives relating to the quantum of development.
4.3 The reasons given for this are self-defeating. Two potential alternative options are considered before being discounted:
“B. Alternative option - Planning for the higher jobs forecast and level of homes associated with it. This alternative has not been assessed as it is not considered to be reasonable. This is because the 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.
C. Alternative option - Planning for the government’s standard method local housing need figure. This alternative has not been assessed as it is not considered to be reasonable. This is because it would not support the most likely forecast for future jobs. As such, the Councils do not consider that it represents our objectively assessed need, and would therefore not be a reasonable alternative. Failure to reflect that likely level of growth, would lead to increased commuting into the area (with consequent impacts on quality of life, wellbeing and carbon emissions objectives for the plan).”
4.4 It is agreed that Option C would not be reasonable given the overwhelming evidence that both employment and housing need are far greater than yielded from the LHNSM. That is not to say that a lower level of growth than the preferred option (Option A, the 44,400 homes and 58,500 new jobs set out in the first consultation) would be unreasonable and certainly, it would likely be helpful in teasing out the relative sustainability issues related to the quantum of development.
4.5 The justification for discounting Option B however is clearly erroneous. If it was only necessary to assess the “most likely future scenario”, there would be no assessment of alternatives of any kind. This is contrary to the entire purpose of SA and SEA.
4.6 The ELEDES makes clear that, while it concludes that the Central Growth Scenario (58,500 jobs) is the most likely, the Higher Growth Scenario is entirely possible. Indeed, as set out in this report it is entirely plausible and therefore reasonable.
4.7 To withhold the full assessment of Option B alongside Option A effectively blinds the decision maker to the differences in environmental effect and sustainability between them. The decision maker cannot conclude that however less likely Option B might be compared to Option A, whether the possibility of success outweighs or reduces the environmental impact.
4.8 This approach has been noted as a concern during the examination of the Babergh and Mid Suffolk Joint Local Plan13, which has been suspended pending further work by the Councils.
5 Conclusions and Recommendations
5.1 The objective assessments of employment and housing need supporting the GCLP first proposals consultation are substantial. They thoroughly consider the data complexities resulting from the rapid economic growth following the period of restraint demanded by the previous County Structure Plan. The employment need assessment in particular however considers that this rapid growth is unsustainable in the long term, and would likely fall back to an average rate of growth seen in the early 2000s, before proposals in the currently adopted local plans took shape.
5.2 Bidwells believe that this undermines the Cambridge Phenomenon that has been gathering pace since the 1960s, but is only now starting to convert the academic advances in life sciences into commercial success, a result of those local plans adopted in 2018. It suggests that the possibility that growth can be sustained is not worth considering and instead Greater Cambridge should be planning for a level of growth comparable to other areas that do not have a unique life sciences cluster, which contributes £2.9 billion annually to the UK economy.
5.3 This is happening at a time when the Covid-19 pandemic has highlighted the importance of all aspects of life science research, from rapidly developing a vaccine, designing effective equipment for rapidly increasing the number of intensive care beds, through to caring for those suffering the long term effects. It is also happening at a time when, following Brexit, the UK is seeking to determine its place in the global economy, outside of the EU.
5.4 While the UK has a lot to offer, the life science research undertaken in Cambridge, and across the whole Oxford to Cambridge Arc, is one of the most unique and highly valued. Now is not the time to constrain growth simply because it ‘might’ be less than what has been sustained previously.
5.5 Bidwells acknowledge that economic growth must be sustainable and that it would be inappropriate to determine a level of need that is undeliverable, as advocated by the NPPF. It is also acknowledged that it is difficult to determine exactly how much employment need there is in the context of such a vibrant economy. It is unique and therefore the approach to assessing need set out in the PPG is perhaps not the best. Certainly, extra care is needed when considering the veracity of economic models, such as the EEFM, that have consistently downplayed economic growth from key sectors over several iterations in recent years. It might therefore be more appropriate, at least as a reasonable alternative, to reverse the analysis and instead consider the available capacity for growth in the area and determine how this sits with the various economic projections under consideration.
5.6 On the subject of reasonable alternatives, the SA accompanying the GCLP first proposals consultation fails to even consider the potential effects of a higher level of economic growth. This is clearly unreasonable, the evidence base itself highlights the uncertainty as to the level of employment need and identifies methodologies and scenarios that would result in a considerably higher level of employment need than the first proposals suggest.
5.7 Lessons must be learnt from the currently adopted local plans that did not anticipate the rapidity of growth they would facilitate, which would inevitably lead to far greater growth over their full plan periods than was considered in their accompanying SAs. It is this failure to consider the possibility of higher rates of economic growth that has led to the increasing level of commuting into Greater Cambridge each day.
5.8 Finally, in terms of housing need, in the case of Greater Cambridge this is simply a function of facilitating economic growth and determining the acceptable level of commuting. The latter will inevitably be a strategic matter for the purposes of the Duty to Cooperate unless the GCLP can show that it is accommodating its full objectively assessed housing need.
5.9 At this stage, with such considerable uncertainty regarding the level of employment need, it is certainly the case that housing need is far higher than that set out in the first proposals consultation and therefore either more land needs to be allocated for housing or comprehensive discussions should be had with neighbouring authorities about how unmet need should be addressed. To facilitate these discussions, the GCSPT would first need to show that there were no more additional sustainable locations for development within their boundaries, which, given the considerable number of sites that are currently being promoted for development is highly unlikely.
5.10 Again, the SA fails to consider any alternative other than the level of need set out in the GCLP first proposals consultation. Quite clearly, if there is uncertainty about the level of employment need, there is also uncertainty about the level of housing need, and the SA should reflect that. Equally, in its consideration of reasonable alternatives, the SA fails to recognise that the greater in-commuting resulting from a higher employment need would be negated by increased housing. Its reasons for limiting the assessment of reasonable alternatives are self-defeating.
5.11 In terms of recommendations, it is clear that considerable more analysis is required to determine the most appropriate level of employment need in the context of the unique life science cluster in Greater Cambridge, which will in turn determine the housing need. This work cannot reasonably progress until the 2021 Census is published in early 2022 and much of the data post-2011, on which the GCLP first proposals is based, is revised. In the meantime however, the GCSPT could consider the realistic capacity for development within its boundaries – what could be achievable irrespective of need, based on the environmental and social constraints of the area. This work will be essential to determining if any unmet housing and/or employment needs exist for the purposes of the Duty to Cooperate, determining the level of employment and housing need that is actually deliverable, and convincing future government planning inspector(s) that the GCLP has been positively planned in the context of the significant weight the NPPF places on the need to support economic growth and productivity.

Local Plan ‘First Proposals’

As the public consultation on the First Proposals for the next Local Plan draws to a close, I am writing to restate my concerns about the damaging impact of your administration’s proposal to build 49,000 new houses and flats in Greater Cambridge.

We have already seen serious harm to our region’s chalk streams and the wildlife they support, due to over-abstraction from our chalk aquifer. This is a direct consequence of the high levels of development we have experienced in recent years.

The Environment Agency has now classed the Cambridge Water area as ‘seriously water stressed’. In November 2020, Stantec’s ‘Integrated Water Management Study’ concluded that your administration’s proposed housebuilding numbers for the next 20 years (a ‘medium’ growth scenario) would need ‘regional scale water supply solutions [that] are operational by the mid-2030s, and suitable interim measures’ but that there is ‘a high uncertainty associated with the interim measures’.

Against this backdrop, I am alarmed to see your First Proposals confirm plans to build 49,000 new homes in Greater Cambridge over the next 20 years. In South Cambridgeshire, this represents 53% more new homes than the Government suggests are needed. These extra homes will create a huge additional demand for water, but there is no confirmed plan in place for how this increased demand will be met. This an inherently risky and unsustainable approach to planning.

Cambridge Water is looking at bringing forward a new reservoir to serve South Cambridgeshire, but this has not been confirmed and the timescale for its delivery is unknown. It would most likely not be operational until the end of the next local plan period in 2040. In the meantime, interim measures will not be capable of meeting the increased water demand that would be generated by your administration’s house building proposals, without causing huge – and quite possibly irreparable – further damage to our region’s chalk waterways.
Solving our water problems will require a coordinated effort and commitment at national, regional and local level. It is a very complex task, requiring significant time and investment. Until we can be certain that a sustainable water supply can be provided, it is essential that there are strict controls on the level of development.

At this critical juncture, controlling the level of housebuilding is the single most important step that your administration can take to save our chalk streams and secure a sustainable water supply. I would therefore urge your administration to:
• reduce its housebuilding target in the Local Plan to (at most) the Government’s standard method figure; and
• work with me and others to make the case to the Department for Levelling Up, Housing and Communities for a downward adjustment of the standard method figure for Greater Cambridge, until such time as a comprehensive plan to protect the chalk aquifer is delivered by Cambridge Water and the Government

On behalf of our client, Cambridge Innovation Parks Ltd (CIPL), we write in response to the Greater Cambridge Local Plan Regulation 18 public consultation.
We have reviewed the draft Plan and supporting documentation and set out our comments below.

Cambridge Innovation Parks Ltd

CIPL is a locally based developer and investor who provides premium serviced office space alongside additional amenities to create an ideal environment for nurturing high-tech companies from their very inception through to the point at which they need to start scaling up and beyond.

CIPL seeks to achieve the highest standards of sustainable development and strives to positively influence and accelerate sustainable change in the wider environments and communities in which it lives and works.

CIPL owns sites to the north, south and west of Cambridge. The intention is to create some of the first fully and truly sustainable campuses, focusing not just on construction and operation but also including leading environmentally friendly approaches such as carbon off-setting. In December 2020, CIPL submitted a hybrid application (ref: 20/05253/FUL) for the first of these schemes, which involves the expansion of an existing business park close to Waterbeach Barracks, into a sustainable innovation park, known as Cambridge Innovation Park North (CIPN). In July 2021, South Cambridgeshire District Council (SCDC) Planning Committee resolved to grant planning permission, subject to a S106 Agreement, which is in its final stages of negotiation.

Cambridge Innovation Park West

CIPL has interests in land to the east and west of Cambourne, in between the A428 and St Neots Road. An indicative location plan is included at Appendix A of the proposed allocation and a further smaller plot detailed in Appendix B which lies adjacent to the proposed allocation. CIPL is currently preparing proposals to create its second highly environmentally sustainable business park which will bring numerous high-skilled jobs to the local area, supporting the local economy. It will be known as Cambridge Innovation Park West (CIPW). Both plots of land are available for the use.
CIPL is therefore wholly supportive of proposed employment allocation ref: S/RRA/SNR (Land to the north of St Neots Road, Dry Drayton), which proposes to allocate the 4.6ha site for the following employment uses:

• E(g)(i) Offices to carry out any operational or administrative functions;

• E(g)(ii) Research and development of products or processes; and

• E(g)(iii) Industrial processes

CIPL would however request that the allocation boundary be expanded to also include for the additional land (Appendix B) which can provide for development and other associated use and mitigation.
CIPL operates within and is fully aligned with the principles of the Oxford-Cambridge Arc – a Government initiative that aims to promote and accelerate the development of a unique set of educational, research and business assets and activities, to create an arc of innovation and entrepreneurial activity that will, in time, be ‘best in class'.

Whilst CIPL are supportive of the proposed allocation, they are also keen to seek the nearby smaller plot as detailed in Appendix B also be included as part of the proposed allocation as it is also available, suitable, achievable in the short term and would help provide more employment land and fully capitalise on the sustainable location.

The CIPW site will be the flagship campus adopting an all-encompassing approach to sustainability targeting established forward-thinking companies who share CIPL’s sustainability and wellness values. The intention is to deliver an exemplar site built to zero carbon standards bringing together tenants who share their values and creating a community nurtured by their surroundings.

Deliverability

CIPL is in early discussions with South Cambridgeshire District Council regarding its plans to develop the site into a sustainable innovation park, with the intention to submit a planning application in late 2022. Construction will begin on site soon after permission is granted, meaning that the site will be in use ahead of the intended start date of 2025 for the construction of the Bedford to Cambridge section of the EWR.

In accordance with the definition contained at Annex 2 of the NPPF, the site is deliverable as it is: a) available; b) suitable; and c) achievable:

Availability

As stated, CIPL has interests in the proposed allocation site and additional land which is available now for development, subject to planning. CIPL intends to submit a planning application in late 2022 with the view to construction commencing immediately after the grant of consent. As such, the site is considered deliverable in the short-term (i.e. the next 5 years).

Suitability

The sites are in a highly sustainable location, situated adjacent to a junction of the A428 - the main easterly route into and out of Cambridge, with links to the A14 and the M11.

CIPL has engaged with the consultation for the construction of the Bedford to Cambridge section of the EWR and supports the emerging preferred options for the new rail link (Route Alignment 1 and Route Alignment 9) which will connect communities between Oxford and Cambridge – a project which can bring significant economic benefits to the wider area and increase public transport connectivity to rural areas of Cambridge.

Furthermore, the sites lie adjacent to the aspirational route of the proposed automated busway which will further connect the site with the Cambridge area and introduce another sustainable mode of transport on offer.

This increased connectivity, coupled with the sites being located immediately adjacent to a junction of the A428 will ensure that the sites area highly accessible and well-connected employment campus which can harness a substantial workforce in the Cambridge area.

Achievability

Technical work is underway to inform the scheme design and forthcoming planning application. There are no known constraints that cannot be mitigated or would prevent a scheme coming forward in the short-term.

The sites are therefore clearly and demonstrably deliverable in the short-term and its proposed allocation (and expanded allocation) is therefore justified and should be carried forward through to adoption.

CIPL also supports emerging strategic policies S/JH (new jobs and homes), J/NE (new employment) and J/EP (supporting a range of facilities in employment parks), which the CIPW proposals would directly respond to. Indeed, substantial planned housing growth will generate additional employment land requirements. Furthermore, CIPW would contribute to the spatial distribution of employment land – providing significant and high-quality floorspace and shared campus-style facilities in a predominantly rural, yet sustainable location.

Next steps

CIPL is wholly supportive of proposed allocation ref: S/RRA/SNR and request that it be expanded to include the additional land. They are also supportive of the emerging direction of the Greater Cambridge Local Plan. CIPL is keen to work closely with the joint councils during the plan preparation phase and in the pre-application discussions for the CIPW proposals.

Please can you therefore ensure we are kept up to date on plan progress and please do not hesitate to contact me, should you require any further information about the site.

INTRODUCTION
1.1 This representation has been prepared by Strutt & Parker on behalf of Gonville & Caius College to support the promotion of land at Rectory Farm, Milton as part of the Greater Cambridge First Proposals Consultation 2021.

1.2 In September 2021 Greater Cambridge Shared Planning Service published the Greater Cambridge HELAA, which provided an initial assessment of the sites put forward for allocation as part of the Call for Sites consultation within Greater Cambridge.

1.3 This representation provides a response to the ‘First Proposals’ Consultations and covers the following topic. The representation has been structured to respond to relevant questions as set out within the First Proposals Consultation. In addition, a detailed assessment is provided in respect of the HELAA Assessment for the site.

1.4 The HELAA excludes the Rectory Farm site from allocation primarily on the basis of landscape issues and highways issues.

1.5 The site was originally submitted as part of the Call for Sites for up to 1,500 dwellings and 30,000 m2 of employment. For reasons explained at Call for Sites stage and set out within this representation it is considered that the site is suitable and deliverable in the medium term for a development of that scale.

1.6 It is considered that several of the assessments criteria, particularly regarding the landscape impact and the transport impact on the A14 should be re-categorised. This is particularly the case given that HELAA assessment appears to have been undertaken in isolation and has not given due consideration to the major transport projects being promoted along the A10 corridor. Further analysis of this is set out within section 7 of this report.

2. QUESTION: Do you agree that we should plan for an extra 550 homes per year, so that housing keeps up pressure with increased jobs in our area?

2.1 We agree that it is very important that housing delivery keeps up with demand for increased jobs within the area.

2.2 As part of the preparation of the emerging Greater Cambridge Local Plan, the Shared Planning Service has identified a need for 2,321 dwellings to be built per year. A significant proportion of this growth is made up of existing allocations within the Local Plan.

2.3 The initial evidence base and spatial options assessment for the emerging Local Plan, set three growth options; ‘minimum’ (40,300 dwellings - based upon standard methodology); ‘medium’ (46,200 dwellings- based upon economic forecast based upon long term historic employment) and ‘maximum’ (67,700 dwellings – based upon fast economic growth in the recent past). In view of this, the housing delivery target of 44,400 new homes over the plan period alongside 58,500 new jobs would fall between the ‘minimum ‘and ‘medium’ growth scenarios previously suggested.

2.4 As acknowledged within the Development Strategy Topic Paper, that accompanies this consultation it is acknowledged that the Greater Cambridge economy is dynamic and does not readily align with national or regional forecasts for job growth. In particular, it has a world- renowned life sciences cluster which has the potential to drive growth beyond typical regional or national rates. It is also acknowledged that in the recent past employment growth within the region has been significantly higher than predicted.

2.5 Accounting for the evidence set out within the Development Strategy Topic Paper, it is not clearly justified why only 44,400 new homes and 58,500 new jobs are proposed over the plan period. It is considered that this approach should be re-visited to increase both housing and employment allocations within the Local Plan. It is considered that the delivery of housing should be significantly increased, in line with the ‘maximum’ growth forecast, to align with economic growth within the recent past. The case for maximum growth forecast is further supported by significant transport investment within the area over the plan period. This includes schemes such as East- West Rail, Cambridge South Station and the delivery of a number of Rapid Transit Routes proposed by the Greater Cambridge Partnership.

2.6 The provision for lower growth scenarios does also not appear to be consistent with the government’s objectives for the Ox- Cam Arc as a centre for housing and employment growth.

3. QUESTION: Do you agree that new development should mainly focus on sites where car travel, and therefore emissions, can be minimised?

3.1 Yes, in principle the proposal to focus development on sites where car travel can be minimised is supported. National policy is clear within paragraph 79 of the NPPF that planning policies should identify opportunities for villages to grow and thrive, especially where they will support local services. The updated NPPF (2021), also provides additional emphases on the suitability of providing significant extensions to villages, provided that they are well located and designed.

3.2 The site at Rectory Farm is located in a very sustainable location, with the development not overly reliant on car travel, with many public transport options easily accessible. It is located centrally along a key growth corridor within the emerging Local Plan. To the north, is Waterbeach New Town, which has planning consent and an allocation for the delivery of over 5,000 dwellings within the plan period and the delivery of a further 4,000 dwellings after the end of the plan period. To the south is the North- East Cambridge Major area of change, which has a draft allocation for the delivery of 3,900 dwellings within the Local Plan period and 8,350 dwellings in total, along with the delivery of 15,000 new jobs.

3.3 It is clear from both the adopted and emerging Local Plan, that the A10 corridor from north- east Cambridge to Waterbeach is a key focus for growth. We fully support this approach. Consistent with this objective, it is considered that further growth should be provided on land to the west of Milton, at Rectory Farm. Rectory Farm is a particularly sustainable option for growth, given that it immediately adjoins the existing park & ride to the south of the site. In addition, the proposed ‘central option’ of the Cambridge to Waterbeach Rapid Transit Route immediately dissects Rectory Farm and has the ability to provide a bus stop within Rectory Farm, which could serve both the existing village of Milton and new job and housing growth at Rectory Farm. There is also the ability to provide ease of cycle access into the City from the site, via Waterbeach Greenway.

4. QUESTION: We think that the area of Milton Road in North-East Cambridge (including the current waste water treatment plant) can be developed into a lively and dense city district, after the water treatment plant relocated. What housing, jobs, facilitates or open spaces do you think this site should provide?

4.1 We support the proposed allocation and redevelopment of north- east Cambridge in principle and as set out in section 3 above, we consider that the corridor between north- east Cambridge and Waterbeach provides a sustainable transport corridor and should provide a focus for growth. However, we do consider that the GCSPS have taken an inconsistent approach in terms of the scoring of North- East Cambridge site within the HELAA than they have for land adjacent to Rectory Farm. Land within North- East Cambridge has a draft allocation for development, despite the fact that it is to a large extent reliant on the relocation of the Waste Water Treatment Works, which is subject to a complicated Development Consent Order approval process.

4.2 The Local Plan also references that the sustainability of North- East Cambridge will improve as a result of planned infrastructure projects such as the Chisholm Trail, Waterbeach to Cambridge Public Transport Corridor and Waterbeach Greenway. We fully support and agree that the delivery of these three important projects will improve the sustainability not only of North- East Cambridge, but also the settlements of Milton and Waterbeach. Within the HELAA Land at Rectory Farm has been deemed unsuitable on the basis of additional traffic pressure on the A14, however Cambridge North- East, which is both a significantly larger development and closer to the A14 has been deemed suitable on transport grounds. It is therefore unclear, why a different approach appears to have been taken between Cambridge North- East and land at Rectory Farm in this regard, which is not justified or sound in planning terms

4.3 Further analysis of this point is set out within our response to the HELAA, within section 7 of this report.

5. QUESTION: We think we should be very limited about the development we allow in villages, with only a few allocated sites in villages, with good public transport connections and local services. Which villages do you think should see new development of any kind?

5.1 The proposed strategy focuses on locating new development in and around Cambridge City, growing existing new settlements, with a small degree of growth in the rural southern clusters.

5.2 It is considered that additional growth should be provided within the most sustainable and largest villages within South Cambridgeshire, such as Milton. As set out in detail within our Call for Sites submission (which has been appended to this representation), Milton is arguably the most sustainable of the Minor Rural Service centres, given its very close proximity to Cambridge, its range of services and the ability to travel from Milton to Cambridge by sustainable transport means. Rectory Farm, is particularly sustainable given that it abuts Milton Park & Ride, which provides for direct and convenient bus access to the City.

5.3 The delivery of major transport schemes along the Waterbeach to Cambridge corridor will further improve the sustainability of Milton, particularly on its western side. The sustainability of Milton will be further enhanced by the additional of 15,000 jobs in north- east Cambridge, which will be very easily accessible by both bike and bus from land at Rectory Farm.

5.4 It is therefore considered that appropriate growth should be provided within the more sustainable, larger villages such as Milton.

6. QUESTION: What housing, jobs, facilities or open spaces do you think should be provided in and around these villages?

6.1 It is important that a range of housing, jobs and facilities are provided within larger villages as part of new allocations to allow them to thrive and remain vibrant. Gonville and Caius College are fully committed, to engagement with the Greater Cambridge Shared Planning Service and Milton Parish Council regarding the mix and type of housing to be delivered land at Rectory Farm.

6.2 The size of the site also means that there is capacity for up to 30,000 m2 of employment floor space included within the site. The College are flexible regarding the type of employment space to be delivered as part of the allocation, in order to meet the extensive demand for job growth along this corridor.

7. QUESTION: Are there any sites which you think should be developed for housing or business use, which we haven’t got on our map so far? Yes, the site at Rectory Farm should be allocated for mixed use development and would be a sound allocation as part of the emerging Local Plan.

7.1 The site was promoted originally at Call for Sites stage for a residential-led mixed use development for 1,500 dwellings and up to 30,000m2 of employment space. This section of the report re-assesses the sites suitability, and demonstrates that it is a suitable location for mixed use development. The site has scored red in the HELAA Assessment in respect of Landscape and Townscape Impact and Strategic Transport Matters. For reasons set out within this section, it is considered that these sections need to be re- scored within the HELAA.

INTRODUCTION
1.1 This representation has been prepared by Strutt & Parker on behalf of Gonville & Caius College to support the promotion of land at Rectory Farm, Milton as part of the Greater Cambridge First Proposals Consultation 2021.

1.2 In September 2021 Greater Cambridge Shared Planning Service published the Greater Cambridge HELAA, which provided an initial assessment of the sites put forward for allocation as part of the Call for Sites consultation within Greater Cambridge.

1.3 This representation provides a response to the ‘First Proposals’ Consultations and covers the following topic. The representation has been structured to respond to relevant questions as set out within the First Proposals Consultation. In addition, a detailed assessment is provided in respect of the HELAA Assessment for the site.

1.4 The HELAA excludes the Rectory Farm site from allocation primarily on the basis of landscape issues and highways issues.

1.5 The site was originally submitted as part of the Call for Sites for up to 1,500 dwellings and 30,000 m2 of employment. For reasons explained at Call for Sites stage and set out within this representation it is considered that the site is suitable and deliverable in the medium term for a development of that scale.

1.6 It is considered that several of the assessments criteria, particularly regarding the landscape impact and the transport impact on the A14 should be re-categorised. This is particularly the case given that HELAA assessment appears to have been undertaken in isolation and has not given due consideration to the major transport projects being promoted along the A10 corridor. Further analysis of this is set out within section 7 of this report.

2. QUESTION: Do you agree that we should plan for an extra 550 homes per year, so that housing keeps up pressure with increased jobs in our area?

2.1 We agree that it is very important that housing delivery keeps up with demand for increased jobs within the area.

2.2 As part of the preparation of the emerging Greater Cambridge Local Plan, the Shared Planning Service has identified a need for 2,321 dwellings to be built per year. A significant proportion of this growth is made up of existing allocations within the Local Plan.

2.3 The initial evidence base and spatial options assessment for the emerging Local Plan, set three growth options; ‘minimum’ (40,300 dwellings - based upon standard methodology); ‘medium’ (46,200 dwellings- based upon economic forecast based upon long term historic employment) and ‘maximum’ (67,700 dwellings – based upon fast economic growth in the recent past). In view of this, the housing delivery target of 44,400 new homes over the plan period alongside 58,500 new jobs would fall between the ‘minimum ‘and ‘medium’ growth scenarios previously suggested.

2.4 As acknowledged within the Development Strategy Topic Paper, that accompanies this consultation it is acknowledged that the Greater Cambridge economy is dynamic and does not readily align with national or regional forecasts for job growth. In particular, it has a world- renowned life sciences cluster which has the potential to drive growth beyond typical regional or national rates. It is also acknowledged that in the recent past employment growth within the region has been significantly higher than predicted.

2.5 Accounting for the evidence set out within the Development Strategy Topic Paper, it is not clearly justified why only 44,400 new homes and 58,500 new jobs are proposed over the plan period. It is considered that this approach should be re-visited to increase both housing and employment allocations within the Local Plan. It is considered that the delivery of housing should be significantly increased, in line with the ‘maximum’ growth forecast, to align with economic growth within the recent past. The case for maximum growth forecast is further supported by significant transport investment within the area over the plan period. This includes schemes such as East- West Rail, Cambridge South Station and the delivery of a number of Rapid Transit Routes proposed by the Greater Cambridge Partnership.

2.6 The provision for lower growth scenarios does also not appear to be consistent with the government’s objectives for the Ox- Cam Arc as a centre for housing and employment growth.

3. QUESTION: Do you agree that new development should mainly focus on sites where car travel, and therefore emissions, can be minimised?

3.1 Yes, in principle the proposal to focus development on sites where car travel can be minimised is supported. National policy is clear within paragraph 79 of the NPPF that planning policies should identify opportunities for villages to grow and thrive, especially where they will support local services. The updated NPPF (2021), also provides additional emphases on the suitability of providing significant extensions to villages, provided that they are well located and designed.

3.2 The site at Rectory Farm is located in a very sustainable location, with the development not overly reliant on car travel, with many public transport options easily accessible. It is located centrally along a key growth corridor within the emerging Local Plan. To the north, is Waterbeach New Town, which has planning consent and an allocation for the delivery of over 5,000 dwellings within the plan period and the delivery of a further 4,000 dwellings after the end of the plan period. To the south is the North- East Cambridge Major area of change, which has a draft allocation for the delivery of 3,900 dwellings within the Local Plan period and 8,350 dwellings in total, along with the delivery of 15,000 new jobs.

3.3 It is clear from both the adopted and emerging Local Plan, that the A10 corridor from north- east Cambridge to Waterbeach is a key focus for growth. We fully support this approach. Consistent with this objective, it is considered that further growth should be provided on land to the west of Milton, at Rectory Farm. Rectory Farm is a particularly sustainable option for growth, given that it immediately adjoins the existing park & ride to the south of the site. In addition, the proposed ‘central option’ of the Cambridge to Waterbeach Rapid Transit Route immediately dissects Rectory Farm and has the ability to provide a bus stop within Rectory Farm, which could serve both the existing village of Milton and new job and housing growth at Rectory Farm. There is also the ability to provide ease of cycle access into the City from the site, via Waterbeach Greenway.

4. QUESTION: We think that the area of Milton Road in North-East Cambridge (including the current waste water treatment plant) can be developed into a lively and dense city district, after the water treatment plant relocated. What housing, jobs, facilitates or open spaces do you think this site should provide?

4.1 We support the proposed allocation and redevelopment of north- east Cambridge in principle and as set out in section 3 above, we consider that the corridor between north- east Cambridge and Waterbeach provides a sustainable transport corridor and should provide a focus for growth. However, we do consider that the GCSPS have taken an inconsistent approach in terms of the scoring of North- East Cambridge site within the HELAA than they have for land adjacent to Rectory Farm. Land within North- East Cambridge has a draft allocation for development, despite the fact that it is to a large extent reliant on the relocation of the Waste Water Treatment Works, which is subject to a complicated Development Consent Order approval process.

4.2 The Local Plan also references that the sustainability of North- East Cambridge will improve as a result of planned infrastructure projects such as the Chisholm Trail, Waterbeach to Cambridge Public Transport Corridor and Waterbeach Greenway. We fully support and agree that the delivery of these three important projects will improve the sustainability not only of North- East Cambridge, but also the settlements of Milton and Waterbeach. Within the HELAA Land at Rectory Farm has been deemed unsuitable on the basis of additional traffic pressure on the A14, however Cambridge North- East, which is both a significantly larger development and closer to the A14 has been deemed suitable on transport grounds. It is therefore unclear, why a different approach appears to have been taken between Cambridge North- East and land at Rectory Farm in this regard, which is not justified or sound in planning terms

4.3 Further analysis of this point is set out within our response to the HELAA, within section 7 of this report.

5. QUESTION: We think we should be very limited about the development we allow in villages, with only a few allocated sites in villages, with good public transport connections and local services. Which villages do you think should see new development of any kind?

5.1 The proposed strategy focuses on locating new development in and around Cambridge City, growing existing new settlements, with a small degree of growth in the rural southern clusters.

5.2 It is considered that additional growth should be provided within the most sustainable and largest villages within South Cambridgeshire, such as Milton. As set out in detail within our Call for Sites submission (which has been appended to this representation), Milton is arguably the most sustainable of the Minor Rural Service centres, given its very close proximity to Cambridge, its range of services and the ability to travel from Milton to Cambridge by sustainable transport means. Rectory Farm, is particularly sustainable given that it abuts Milton Park & Ride, which provides for direct and convenient bus access to the City.

5.3 The delivery of major transport schemes along the Waterbeach to Cambridge corridor will further improve the sustainability of Milton, particularly on its western side. The sustainability of Milton will be further enhanced by the additional of 15,000 jobs in north- east Cambridge, which will be very easily accessible by both bike and bus from land at Rectory Farm.

5.4 It is therefore considered that appropriate growth should be provided within the more sustainable, larger villages such as Milton.

6. QUESTION: What housing, jobs, facilities or open spaces do you think should be provided in and around these villages?

6.1 It is important that a range of housing, jobs and facilities are provided within larger villages as part of new allocations to allow them to thrive and remain vibrant. Gonville and Caius College are fully committed, to engagement with the Greater Cambridge Shared Planning Service and Milton Parish Council regarding the mix and type of housing to be delivered land at Rectory Farm.

6.2 The size of the site also means that there is capacity for up to 30,000 m2 of employment floor space included within the site. The College are flexible regarding the type of employment space to be delivered as part of the allocation, in order to meet the extensive demand for job growth along this corridor.

7. QUESTION: Are there any sites which you think should be developed for housing or business use, which we haven’t got on our map so far? Yes, the site at Rectory Farm should be allocated for mixed use development and would be a sound allocation as part of the emerging Local Plan.

7.1 The site was promoted originally at Call for Sites stage for a residential-led mixed use development for 1,500 dwellings and up to 30,000m2 of employment space. This section of the report re-assesses the sites suitability, and demonstrates that it is a suitable location for mixed use development. The site has scored red in the HELAA Assessment in respect of Landscape and Townscape Impact and Strategic Transport Matters. For reasons set out within this section, it is considered that these sections need to be re- scored within the HELAA.

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. 70% 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 2070-2076 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.

Context
Housing underpins every objective of sustainable development in the NPPF; economic (building a strong economy and ensuring sufficient land of the right types is available in the right place), social (supporting strong communities by ensuring a sufficient number and range of homes can be provided and by fostering well-designed, safe places) and environmental (making effective use of land, improving biodiversity and moving to a low carbon economy). The NPPF goes on to set out that (para 61): “To support the Government’s objective of significantly boosting the supply of homes, it is important that a sufficient amount and variety of land can come forward where it is needed, that the needs of groups with specific housing requirements are addressed and that land with permission is developed without unnecessary delay.”
Housing also underpins the themes of the emerging GCLP, for example:
1 Climate Change – it is a recurring theme in the GCLP that one of the biggest contributors to climate change is in commuting to Cambridge. This is exacerbated by the current lack of affordable housing relative to quantum of jobs in Cambridge. Building enough new homes just to keep pace with job growth may simply maintain the current situation but planning for more jobs without the corresponding homes would exacerbate the issue further.
2 Biodiversity – new housing development can provide access to new formal and informal open spaces, taking pressures of existing habitats, whilst also delivering biodiversity net gain.
3 Jobs – at its most simple level job growth must be supported by housing growth to ensure a sufficient labour force is available. It is also key that these homes are in the right places, because businesses rely upon (and gain a competitive advantage from) having a workforce which can move readily to new employment opportunities. Jobs also need to be supported by a range of housing types and tenures to ensure that workers on all incomes can access employment, and the provision of new housing allows for delivery of affordable housing as well as specific types, such as key worker accommodation.
4 Infrastructure – development of housing is key to ensuring existing infrastructure can be retained (for example, ensuring public transport networks remain viable) and is also key to unlocking new infrastructure.
The intersection of housing with other themes is also noted within the GCLP itself, stating that: “Delivering new net zero carbon homes, across a variety of tenures, with sufficient indoor and outdoor space, designed to be adaptable throughout the lifetime of their occupants, and located close to jobs will provide many varied benefits for people and the planet. This theme therefore connects with most of the other themes. For example: net zero carbon homes (Climate Change) will help control energy costs making living costs more affordable, the creation of healthy new high quality developments with green spaces and other appropriate infrastructure (Biodiversity and Green Spaces, Wellbeing and Social Inclusion, Great Places, and Infrastructure) will improve the health and wellbeing of residents, and providing new homes will help businesses to meet their staffing needs (Jobs).” (GCLP First Proposals p.259)
The GCLP proposes a number of policies including for affordable housing, housing mix, density, specialist housing, self-build homes, build-to-rent homes, student accommodation and community-led housing.
Housing in the GCLP
On the basis of Section 5.0 (which set out that the GCLP should be more ambitious in its planned level of employment growth) we consider that commensurate increases would also be needed in housing growth to support this. As with employment, we consider that the housing requirement in the GCLP should be expressed as a minimum to ensure that there is flexibility to allow for higher housing growth in order to ensure Greater Cambridge’s potential is maximised.
In addition, we also make some observations below about identified housing delivery in the GCLP.
Build-out rates
As per para 10.19 of the October 2021 Housing Delivery Study (HDS), Waterbeach is assumed to deliver at 250dpa, but Bourn Airfield and Cambourne West are set to only deliver at 150dpa with the odd year of delivery rising to 200dpa. The clear evidence to justify this disparity in sites of a similar scale is unclear.
Northstowe is consistently assumed to deliver 250 dpa but within the next 4 years is to deliver in excess of 300dpa. This approach would not appear to have been taken with regard to Table 18 of the HDS, which sets out that average build out rate of urban extensions delivering 2,000+ homes are 225-275. We would consider that setting out an expected delivery of over 300dpa for multiple years is highly optimistic and it is not clear from the evidence base how this is justified, to ensure no optimism bias this should be lowered to a more realistic average build out rate of 250dpa, which fits within the identified range above, with a peak of 300dpa in 1 or 2 years if it can be evidenced.
Windfalls
We further note the high windfall figure of 450 dwellings per annum that is expected to be delivered across Greater Cambridge, see HDS (October 2021). It is noted that the historic windfall allowance has traditionally been 350dpa, however a recent review of the data suggests that c.500dpa has been delivered across the area over the longer term. The 450dpa is made up of the top end of the range for 240-255 for South Cambridgeshire and 185-195 for Cambridge City.
However, the evidence appears to show that the windfall figures are elevated between the years of 2013 to 2018, i.e. the years in which the adopted Cambridge Local Plan was at Examination in Public. It is not surprising that windfalls would be higher in this period as non-allocated sites came forward without the benefit of an up to date adopted local plan, in effect the majority of housing supply would have been a windfall. Comparing this data with windfalls delivered in the period either side is less. Furthermore, the windfall ranges concluded on for Cambridge and South Cambridgeshire above seem to align very closely with the historic windfall figures for sites ‘including gardens’. This would run contrary to the NPPF paragraph 71 which states that plans should consider the case for setting out policies to resist inappropriate development of residential gardens, including these in a long-term windfall allowance could perpetuate this trend.
Housing requirement buffer
The HDS confirms that it is a recommendation that ‘at least a 10%’ buffer is applied to ensure an ‘over-allocation’ of land against the eventual housing requirement. However, as we have demonstrated above in the case of South East Cambridge and as we detail regarding Greater Cambridge as a whole in respect to Theme 5 – Jobs, the economy in this location is particularly robust and has seen strong levels of growth, despite the downward pressures placed on economic growth due to Covid 19. It is therefore a realistic expectation that job growth could be considerably higher than projected by the currently adopted scenario, which is demonstrated clearly by the spatial strategy suggested within the Cambridgeshire and Peterborough Independent Economic Review (CPIER) have referred to within their report that employment growth rates are far higher than have been indicated by official figures and that growth can be expected to keep increasing. Noting the overall thread of sustainability running through the Local Plan, it would seem appropriate to provide a higher buffer of dwelling to facilitate houses close to local sources of employment which have seen higher growth rates over the past few years, notably biomedical and technology industries which are prevalent in South East Cambridge.

Context
The NPPF places great importance on building a strong, competitive economy, and states that: “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.” (Paragraph 81).
Planning policies and decisions should also “recognise and address the specific locational requirements of different sectors. This includes making provision for clusters or networks of knowledge and data-driven, creative or high technology industries.” (NPPF Paragraph 83).
The national and international significance of the Cambridge economy and its high technology clusters is recognised as a key component throughout the Reg 18 consultation. Cambridge has a leading presence in specialist sectors – including knowledge intensive businesses such as hightech manufacturing, life sciences and healthcare – and the retention and ongoing growth of these dominating sectors needs to be fully supported by the GCLP. The strength of Cambridge’s economy is typically attributed to the spatial concentration of local business networks within and on the edge of the city itself, which encourages sharing of knowledge and labour through economies of agglomeration, as well as the presence of a local, highly-skilled workforce which is driven by the esteemed Cambridge University and other research organisations. This was exemplified by the recent re-location of AstraZeneca’s global headquarters to the city in order to build on its relationship with leading research, academic and healthcare organisations based in and around Cambridge, which make it ‘one of the most exciting bioscience hotspots in the world’.
Future scale of employment growth in Cambridge
In this context, the Reg 18 consultation sets out the level of needs in Greater Cambridge that development will meet over the plan period of 2020 – 2041. For jobs, Policy S/JH proposes that the GCLP will meet the objectively assessed need for 58,500 new jobs, around 20,000 of which would be office and industrial jobs and the rest for jobs in services and support uses such as shops, schools and healthcare. This identified need is based on, albeit 100 jobs greater, the ‘Central Scenario’ (referred to as KS3) in the Greater Cambridge Employment Land and Economic Development Evidence Study (‘the employment evidence’). The Higher Scenario (KS2) forecast a need for 78,700 jobs over the plan period, compared to the central growth scenario of 58,400 jobs. Importantly, this is concluded to be the preferred – and recommended – range, and as such the two figures represent an upper and lower employment forecast to 2041. As it stands, the emerging GCLP only provides for the lowest identified need in this range (being just 100 jobs over the lower figure).
The authors of this study, GL Hearn, considered that the Central Scenario was appropriate over the Higher Scenario as per the below: “The reduction in growth rates is important to consider as it allows for the rate of growth in percentage terms to slow as the sectors expand, avoiding unrealistic absolute year-on-year changes in the sectors as they get larger.”
The highest growth projection scenario (KS1) was rejected because it “exceeds historic rates due to high long-term annual growth rates for growing individual sectors leading to disproportionate absolute change. This rate or level of growth should not be considered realistic given the population, development and environmental implications.”
Whilst it is noted that there is a possibility of individual sectors slowing in growth as they expand, those particular sectors which have primarily driven growth in Greater Cambridge such as tech and biomedical have not seen such a slowdown in growth. The assessment of the scenarios in the Greater Cambridge Employment Land and Economic Development Evidence Study looks at trends between 2001-2017 and 1991-2017, i.e. not taking into account growth in the past four years. Indeed, sectors such as tech and biomedical have accelerated over the Covid19 period and certainly since 2017. It is therefore considered that the evidence to support the adoption of the Central Scenario is lacking, and that the prevalence of these high growth sectors and their unfettered growth in challenging economic conditions would point to continued long term growth with associated higher long term job growth for Greater Cambridge. On this basis, planning for the ‘Central Scenario’ is not a sound, or realistic approach to planning for job growth in Greater Cambridge.
Further, the Reg 18 consultation acknowledges that the employment evidence suggested providing flexibility in employment land in case the market delivers more jobs than anticipated. This reflects the Cambridgeshire and Peterborough Independent Economic Review (CPIER), which considered employment projections that were even greater than the ‘Higher Scenario’ set out by the Councils. In their final report published in September 2018, the Independent Review judged that the most reasonable level of employment growth is that which assumes a continuation of recent higher employment growth rates, which have come in the context of nationally high employment growth, before gradually returning to longer-term levels. This would be in line with the much higher rates of growth that have been occurring in the Greater Cambridge area.
Importantly, the Independent Review also notes that there has been an under-projection of employment growth in the area; in other words, high employment growth has been unanticipated and therefore not built into targets. The East of England Forecasting Model (EEFM) is the primary model used to inform local plans in this region, and the report states that EEFM’s projections for employment growth in recent years fell below the actual output by a significant margin. In the aforementioned employment and economic evidence study, the Councils confirm that their preferred approach to employment forecasting involved using the EEFM; if employment growth continues to be significantly above that forecast by this model, then the GCLP will not provide for enough development (jobs and homes, which must be planned for in parallel to ensure unsustainable commuting patterns and worsening of affordability to not go unchecked). This is particularly significant given that the Reg 18 consultation is currently planning for the lower end of the recommended employment forecast.
The under-estimation of employment growth in Cambridge has been evident in recent years; since 2011 (the start of the current plan periods) Greater Cambridge has seen between 56% and 91% (depending on which source is used) of all jobs planned for in the 2011-31 period (41,400), despite only being around one-third of the way into the plan period. Given there is clear historic evidence of employment growth running higher than anticipated, it is vital that the GCLP recognises the likelihood of this continuing and allows for flexibility, particularly by expressing any employment figure in the plan as a clear ‘minimum’. The Council should also consider an early review mechanism if employment growth continues to run substantially above anticipated levels, in order that sufficient sites can be brought forward more quickly to accommodate this growth.
Taking the above points together, there is clearly justification for including higher employment related figures in the GCLP. The national importance of the Greater Cambridge economy, combined with world-renowned clusters and the strong performance of knowledge intensive sectors, has the potential to drive growth beyond the relatively modest figure in the emerging GCLP. The persistently higher growth rates in the Cambridge city region are also emphasised by other relevant stakeholders, including Cambridge Ahead. The need for flexibility to respond to economic opportunities is central to the NPPF (as cited above) but also the PPG (ID: 2a-027) with its requirement for plans to “consider and plan for the implications of alternative economic scenarios.”
Spatial options for employment
When considering the Spatial Strategy that the Greater Cambridge Local Plan is pursuing, it is notable from a review of the First Proposals map that there is a lack of new housing or employment allocations located on the south eastern edge of Cambridge. As can be identified through the existing allocations from the Cambridge City Local Plan within Policy S/EOC: (Other site allocations on the edge of Cambridge), there are a number of strong employment and housing sites which are being retained, but no further allocations to help strengthen and build those new communities which were started under the existing Local Plan, and provide no further options for growth for those important business locations. Notably within South East Cambridge, these include Peterhouse Technology Park and the allocations GB1 -4 which provide for both housing and employment uses.
This is particularly surprising given the locational advantages that this particular area on the edge of Cambridge benefits from, notably the upcoming delivery of the Cambridge South train station that is proposed at the Biomedical Campus. As is confirmed by the Transport and Works Act Order (TWAO) application made by Network Rail on the 18th June 2021 the proposed station will be supported by significant infrastructure upgrades, including the provision for 1,000 cycle parking spaces and improved roads/crossings to provide access to the station. As such, the station will be highly accessible by cycle, and sites with existing allocations such as the land south of Peterhouse will be easily accessible by cycle. It would therefore seem unnecessarily restrictive of Greater Cambridge to limit the allocations for employment growth in this area solely to the Biomedical Campus, and not to other strong employment locations such as those existing allocation sites GB3-4 which are within short public access of the new train station.
In addition to the overall need for new jobs, Table 3 in the Councils’ employment evidence also confirms that there is a demonstrable need for B1a/b uses, with projections showing that there will be a significant undersupply across the GCLP period even after the potential contribution of B1 mixed sites is taken into account. The evidence suggests that this reflects that most of the projected demand in B1b is assumed to be for research and development (R&D) employment, and that if the ‘higher growth scenario’ was achieved over the plan period then the current pipeline of supply is likely to be insufficient.
Businesses evidently want to tap into the location of Cambridge, and our site’s location to the south eastern edge of the city has existing connections to the rest of the Cambridge economy. Further Green Belt release would be justified in this area to facilitate further economic growth extensions at the PTP site in the context of Cambridge’s local need. This leads us on to the consideration of the identified locations for employment growth in the Reg 18 consultation.
The GCLP consultation sets out the proposed strategy for development in Greater Cambridge and Policy S/DS provides detail on where the homes and jobs identified in Policy S/JH should be provided in order to meet the vision and aims of the local plan. The growth strategy appears to be separated into five distinct locations – namely the Cambridge urban area, the edge of Cambridge, new settlements, the rural southern cluster, and the rest of the rural area – with the amount of proposed development differing in these areas according to their scale, characteristics and sustainability.
While the development strategy is not overtly clear on which sites will specifically include employment uses to accommodate the need for new jobs, Policy S/DS suggests that the overall focus for employment growth – some of which relates to mixed-use sites – will be at North East Cambridge, Cambridge East, Cambridge Biomedical Campus, Babraham Research Campus and other new or continued sites, primarily within the Cambridge urban area and existing business parks at the Rural Southern Cluster. The policy clearly lists the specific sites that will contribute to meeting the housing need requirement, setting out the quantum of homes to be delivered at those sites over the plan period, however it does not provide the same transparent approach with regards to the supply of jobs (i.e. sites for employment).
The GCLP provides further detail on new employment development proposals in Policy J/NE. This policy supports employment development in Cambridge at the sites set out in the development strategy and within appropriate mixed use areas of major change and opportunity areas, and states that other employment proposals in Cambridge will be considered on their merits where they are of an appropriate scale, character and accessible location. The policy goes on to specify a range of sites which are particularly suited to supporting the need of clusters, which include significant opportunities at:
• North East Cambridge
• West Cambridge
• North West Cambridge
• Cambridge Biomedical Campus
• Welcome Trust Genome Campus
• Granta Park
• Babraham Research Campus
• New Towns at Northstowe and Waterbeach.
While the policy recognises that cluster related employment is not restricted to these areas, the GCLP is not currently proposing to direct growth towards South East Cambridge – and neither is it identified as a proposed location for further employment development. It is considered that, given the need to plan for higher employment growth, the spatial approach and proposed allocations are somewhat limited and do not fully explore the potential of South East Cambridge to support other existing clusters. The site provides an opportunity to deliver additional employment land in a sustainable location; fundamentally, it can facilitate growth despite its current location within the Green Belt.
As such, the Councils should not arbitrarily limit themselves at this key stage in the local plan process by not countenancing Green Belt release, particularly in those locations such as South East Cambridge where there is already an established employment cluster that could suitably accommodate further development. The expansion of the PTP cluster should be specifically supported by the GCLP, and the Green Belt release of such sites could in fact lead to more sustainable outcomes, for example by facilitating a nature network as discussed in the previous section, and by delivering jobs in close proximity to homes.
The needs of specific sectors
Moreover, the specific need for further employment provision in specialist sectors – as identified throughout the GCLP and supporting employment evidence – means that there will be demand for further expansion of clusters that currently support these types of businesses and/or technologies. Arm Holdings (‘ARM’) is the anchor tenant at PTP and is a driving force in the global semiconductor (computer chip) industry. Its primary business is in the design of ARM processors (CPUs), for which it is considered to be market dominant, and it is one of the best-known ‘Silicon Fen’ companies (also known as the Cambridge Cluster).
There is currently a worldwide shortage in semiconductor production, which is not expected to end in the short-term, and ARM is therefore one of the companies that is well positioned to help address increasing industry demand. Millions of everyday products, such as cars, smartphones and fridges, rely on semiconductors and demand for new products that use semiconductors will only continue to grow. Further investment in semiconductor manufacturing capacity to boost supply is anticipated, and ARM is a leading global company set within the context of Cambridge’s economy which has an international reach. The demand for further expansion of ARM at PTP, which has emerged as a significant high-tech employment cluster, beyond 2041 can therefore be expected.
Considering the strength of and continued need for specialist sectors in Cambridge, it is also of importance that jobs in these sectors are unlikely to have been – or will continue to be – negatively impacted by COVID-19. The Reg 18 consultation document states that the employment evidence is based upon pre-COVID-19 data. However, the strength of Cambridge’s knowledge-intensive sectors, particularly its globally renowned life sciences cluster, has only been underscored by the recent COVID-19 pandemic and as a result, job growth has and will continue to trend upwards. A report by New London Architecture (NLA) highlights the contribution of the life sciences sector to the national economy and states that it is one of the most resilient sectors. While one of the most significant impacts of COVID-19 is the rise of homeworking, the nature of most jobs in life sciences requires employees to be physically present. As the economy adjusts to the ‘new normal’ it therefore seems apparent that both the global reach of Cambridge’s life sciences cluster and demand for space in this sector will only continue to grow.
How do other options compare?
New settlements
As previously noted, areas beyond Cambridge City are unproven employment markets; demand for employment space remains primarily in and on the edge of Cambridge City.
The emerging GCLP identifies Cambourne as a broad location for longer term strategic scale growth, with part of the settlement’s role to be a growing employment centre to provide local opportunities for its residents and nearby communities. However, Policy S/CB states that future development at Cambourne will need to consider: The economic role of the place, and which employment sectors would benefit from the location to support the needs of the Greater Cambridge economy. This suggests that there is no latent demand from existing occupiers or a particular need arising in this location for specific forms of employment space. As is confirmed below through a planning history review, existing provision on site includes predominantly general office space rather than research and technology companies which tend to gravitate to specialist clusters on the edge of Cambridge such as that at PTP. Policy S/NS sets out the direction for the three new settlements of Northstowe, the new town north of Waterbeach, and Bourn Airfield new village, which are proposed to continue to grow during the period of the new Local Plan and beyond, including elements of employment development.
Neither policy is clear on the amount or type of employment development that is to be allocated or supported in these new settlements. Historically, Cambourne and Northstowe have been delivering housing at relatively strong rates and are better associated with residential orientated development. A review of the relevant evidence and recent planning applications relating to potential employment development at the new towns indicates the following:
1 Waterbeach – Arguably the strongest potential new settlement for employment development due to the proximity of the existing Cambridge Innovation Park and Cambridge Research Park, which lie adjacent to the new town. Waterbeach is likely to build on the ICT/professional services and biotech sectors located at the existing parks and the site is coming forward through two large applications under two land ownerships.
Planning applications comprise: an outline application for 6,500 homes and 15,000m² of business (B1) floorspace, including small to medium sized offices, light industrial workshops, studios and maker spaces (reference S/0559/17/OL, approved 2019); an outline application for 5,500 homes and up to 22,400m² B1a office and 2,400m² B1c/B8 light industrial, storage and distribution space (reference S/2075/18/OL, awaiting decision); and a further application for the expansion of the Innovation Park, including new office buildings and floorspace (reference 20/05253/FUL, awaiting decision).
2 Cambourne – The extension of Cambourne (Cambourne West) is located immediately adjacent to the existing Cambourne Business Park, which contains larger scale office accommodation occupied by a mix of businesses in professional services, IT, telecommunications and research and development. The employment evidence confirms that the Business Park itself ‘has taken some time to work towards being an established employment location’, raising questions on the potential for the extension to deliver further employment space.
Outline planning permission was granted in 2017 for the Cambourne West extension (reference S/2903/14/OL), which included land for the provision of up to c.6ha of B1 employment space, anticipated to be small offices, R&D and clean technology businesses – however to date there does not appear to be further activity on this provision. Significantly, the land directly south of the Business Park is being promoted for residential development only; a screening opinion was recently submitted for 300 new homes (21/03771/SCRE).
3 Bourn Airfield – Located to the east of Cambourne, planning applications at Bourn Airfield suggest that the site is expected to deliver a mixed-use village comprising of 3,500 dwellings and supporting uses including 1,500m² of employment floorspace comprising offices, R&D and light industry (Class B1a, b and c uses) (reference S/3440/18/OL, awaiting decision). A further application, granted in January 2021, includes provision for an additional 24,620m² of employment space consisting of a mix of B1b (research and development), B1c (light industrial) and B8 (storage and distribution) (reference 20/02568/FUL).
4 Northstowe – The employment evidence makes clear that ‘Northstowe has a challenge in bringing forward employment under the current strategy’. The new town will eventually include up to 10,000 new homes and a range of other uses. Planning applications to date suggest that there will be a series of employment area parcels across the phases of development in association with the town centre and local centres, primarily for mixed B1 uses, however no employment floorspace has yet been completed within the new settlement which is in early phases of development. There are a number of other identified employment locations that are either established or seeking market position – including Cambourne and Waterbeach.
While this review provides an insight into potential employment development in the new town designated areas, it is not clear how much, and what type, of employment space is already permitted against that still being proposed in the emerging GCLP. As noted previously, the Reg 18 consultation does not set this out in a transparent way, and it is difficult to ascertain whether or not the importance (and delivery) of employment growth that is being proposed at these new towns is likely to materialise or be successful. If Cambridge wants to fully capitalise on its economic success then it must maximise the development potential of employment sites located close to established employment clusters which attract the best businesses and workers; this is an opportunity available to Greater Cambridge at Land South of Cambridge.

Policy S/JH of the Draft Local Plan proposes to 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
For housing, Paragraph 60 of the National Planning Policy Framework (NPPF) states that Local Plans should support the Government’s objective of significantly boosting the supply of homes, providing, as a minimum, the number of homes informed by a local housing need assessment, using the standard method in national planning guidance. National guidance says that there will be circumstances where it is appropriate to consider whether actual housing need is higher than that indicated by the standard method.
For Greater Cambridge the housing need using the Standard Method would equate to 1,743 homes per annum. However, rather than planning for the minimum calculation using the Standard Method, the Councils’ strategy is to propose a higher housing figure of 2,111 homes per annum. This higher figure is based on the medium growth scenario identified in the Greater Cambridge Employment Land and Economic Development Evidence Study, published in 2020. This study also set out a higher growth scenario placing greater weight on the high historic growth rate between 2001- 2017. Based on the higher growth scenario the modelling predicted that 78,700 jobs would be required over the plan period.
Whilst Miller is supportive of the Councils’ decision to plan for higher levels of growth than the standard method, it is disappointing that the Councils’ have decided to base their strategy on the medium rather that the higher growth scenario. The Greater Cambridge economy is dynamic and does not readily align with national or regional forecasts for jobs growth. It has a world-renowned life sciences cluster which has the potential to drive growth beyond typical regional or national rates.
We would strongly advise the Councils’ to ensure that their objectively assessed is more aligned with the higher jobs growth aspirations. An indicative calculation based on Cambridgeshire and Peterborough Independent Economic Review suggests that if the jobs growth is achieved, around 2,900 homes a year would need to be built in Greater Cambridge, an indicative total of 66,900 homes over 2020-2041.
As set out in the Government’s most recent consultation document the Arc has the potential to be one of ‘the most prosperous, innovative and sustainable economic areas in the world’. However this transformational growth will only be achieved if local authorities truly plan positively for the housing and economic needs of the area. On this basis we would strongly urge the Council to plan for the higher growth scenario which is more aligned with past growth rates in the Greater Cambridge area.

Policy S/JH of the Draft Local Plan proposes to 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
For housing, Paragraph 60 of the National Planning Policy Framework (NPPF) states that Local Plans should support the Government’s objective of significantly boosting the supply of homes, providing, as a minimum, the number of homes informed by a local housing need assessment, using the standard method in national planning guidance. National guidance says that there will be circumstances where it is appropriate to consider whether actual housing need is higher than that indicated by the standard method.
For Greater Cambridge the housing need using the Standard Method would equate to 1743 homes per annum. However, rather than planning for the minimum calculation using the Standard Method, the Councils’ strategy is to propose a higher housing figure of 2,111 homes per annum. This higher figure is based on the medium growth scenario identified in the Greater Cambridge Employment Land and Economic Development Evidence Study, published in 2020. This study also set out a higher growth scenario placing greater weight on the high historic growth rate between 2001- 2017. Based on the higher growth scenario the modelling predicted that 78,700 jobs would be required over the plan period.
Whilst Miller is supportive of the Councils’ decision to plan for higher levels of growth than the standard method, it is disappointing that the Council have decided to base their strategy on the medium rather that the higher growth scenario. The Greater Cambridge economy is dynamic and does not readily align with national or regional forecasts for jobs growth. It has a world-renowned life sciences cluster which has the potential to drive growth beyond typical regional or national rates.
We would strongly advise the Council to ensure that their objectively assessed is more aligned with the higher jobs growth aspirations. An indicative calculation based on Cambridgeshire and Peterborough Independent Economic Review suggests that if the jobs growth is achieved, around 2,900 homes a year would need to be built in Greater Cambridge, an indicative total of 66,900 homes over 2020-2041.
As set out in the Government’s most recent consultation document the Arc has the potential to be one of ‘the most prosperous, innovative and sustainable economic areas in the world’. However this transformational growth will only be achieved if local authorities truly plan positively for the housing and economic needs of the area. On this basis we would strongly urge the Council to plan for the higher growth scenario which is more aligned with past growth rates in the Greater Cambridge area.

This policy identifies an objectively assessed need of 44,400 new homes and 58,500 new jobs to be provided in the Greater Cambridge area up to 2041.
Continued economic growth across the Greater Cambridge area is of fundamental importance and needs to be properly considered and planned for through the Local Plan. Greater Cambridge forms part of the nationally significant Oxford to Cambridge Growth Arc, thus the role the GCLP plays is of pivotal importance in delivering transformational scales of growth.
It is essential that economic growth opportunities are recognised and maximised and the Councils work alongside other LPAs in the Arc to ensure that the potential is realised through robust housing and job requirements.
The Local Plan First Proposals document acknowledges the Councils’ commitment to the Cambridgeshire and Peterborough Devolution Deal. If the scale of job growth required by this is achieved, around 2,900 homes a year would be needed across Greater Cambridge, resulting in a housing requirement of 66,700 homes between 2017-2040- a significantly higher figure than the initial policy direction suggests.
Gladman strongly believe that the new Local Plan should be planning for a significantly higher number of homes than the minimum identified by the standard method if the plan is to align with the scale of economic growth planned for the Arc. While the housing requirement in this plan are above the standard method figure, Gladman believe that this figure will need to be higher yet, in order to achieve the economic growth aspirations of the area.
In this regard, Gladman refer to the Cambridgeshire and Peterborough Independent Economic Review (CPIER), published in 2018 which sets out a compelling case for higher levels of housing across the Greater Cambridge area. Of particular note is Key Recommendation 5, which points to the need to review the housing requirement based on the need for high economic growth. Importantly, the report warns of significant negative impacts to both the national and local economy should housing needs continue to be constrained.
The Arc aims to create 1,000,000 jobs before 2050. For this target to be realised, LPAs across the Arc must work together to ensure that appropriate job requirement figures are allocated to authorities that are capable of providing employment. At present the first proposals consultation suggests looking to providing 58,500 jobs between up to 2041. Gladman consider that Greater Cambridgeshire should be seeking to deliver significantly greater economic and employment growth to ensure the Arc economic aspirations are realised.
Further to this, the Local Plan needs to recognise the importance of the Councils’ position within the Oxford to Cambridge Growth Arc and the implications of this in terms of growth in the area. The Arc is a key economic priority and one of the publicly stated key objectives of the Arc is to deliver up to 1 million high quality homes across the area, up to 2050. Gladman believe it is of imperative importance that the new Local Plan seeks to deliver a higher number of homes than required by the standard method to ensure that it is in line with nationally significant economic growth. As outlined in the PPG, the standard method for assessing local housing need is the minimum starting point in determining the number of homes needed in an area. It doesn’t account for future government policy, changes in economic circumstances or other demographic changes that might affect the level of housing required in an area. For this reason, it is necessary to consider that housing need in an area may be higher than the standard method calculation and the plan should be positively prepared for this.
Gladman reserve the right to comment on housing and job growth proposals when these are developed further and the Draft Plan is issued for public consultation.

Draft Policy S/JH seeks to adopt a housing requirement of 44,400 new dwellings over the 21-year plan period to 2041, reflecting an annual objectively assessed need of 2,111 homes per year.
As is detailed in the ‘First Proposals’ consultation, it is expected that 1,771 homes per year could be provided within the Greater Cambridge area during the 2020-2041 Plan period based on existing commitments, which would exceed minimum annual local housing need in accordance with the Government’s standard method (1,743dpa). The Council claim that their evidence shows the need to plan for about 550 more homes per year in order to meet a rounded need for housing, relative to existing commitments (37,200 dwellings), effectively comprising:
• c.340 dwellings per annum to meet objectively assessed housing needs (2,111dpa)
• c.210 dwellings per annum as part of providing a 10% buffer
The PPG (Paragraph: 010 Reference ID: 2a-010-20201216), sets out some of the circumstances that could justify an uplift on the standard method. These include, but are not limited to, the presence of specific growth deals and the funding and provision of strategic infrastructure. As is set out further within this submission, the economic performance and aspirations of the Greater Cambridgeshire Plan area must be reflected in the housing requirement to be adopted and there is significant evidence that would support an a more meaningful uplift to the standard method than is currently being proposed.
The 2,111 dwellings per annum, referred to by the Council as their ‘consume own smoke’ scenario, applies a sensitivity test, in which there is a 1:1 commuting ratio for housing growth generated by additional jobs above those supported by the Standard Method, assuming that the total additional housing growth generated by additional jobs above those supported by the Standard Method would be delivered in full within the Greater Cambridge area.
The full range of previously identified growth level options are set out below.
It is noted that the ‘maximum continue existing pattern’ requirement of 2,549 dwellings per annum is referred to in the Housing and Employment Relationships (HER) report as being the ‘higher growth scenario’.
(a) The relationship of housing and future economic growth
The HER considers three scenarios for growth;
• Standard Method – Housing need derived from the Standard Method, converted to population and then employment growth;
• Central – Central growth employment forecast converted to population and housing; and
• Higher – Higher growth employment forecast converted to population and housing.
As is set out in the Greater Cambridge Employment Land and Economic Needs Study (ELENS), only a single economic model (Cambridge Econometrics (CE)) has been used to generate jobs forecasts. It is standard practice to triangulate all 3 models (Experian and Oxford Economics together with CE) given that there are methodological differences between them regarding how the various job forecasts are derived. This can mean that in certain circumstances, and in certain spatial areas, one may produce a more realistic, or appropriate, level of job growth than another.
The ELENS acknowledges that the Greater Cambridge economy is dynamic and does not readily align with national or regional forecasts for jobs growth. It has a world-renowned life sciences cluster which has the potential to drive growth beyond typical regional or national rates. Since 2011 the Greater Cambridge economy has grown faster than any time in the last three decades, driven by some key sectors.
In recognition of this the ELENS concludes that a preferred range between a central (58,500) and higher growth (78,700) scenario is recommended in respect of jobs growth. As is set out in the table above, the Council’s proposed housing requirement would support only the central economic scenario and fails to meet this recommendation.
The ‘higher’ growth scenario assumes the baseline forecast for most sectors but identifies higher growth sectors particular to Greater Cambridge, being Research & Development (R&D), Professional services, and Health & care (related to R&D). For these sectors, the forecast is increased to halfway between the baseline and the historic growth rate from 2001-17 to reflect their higher potential. It also considers multiplier effects of growth. Overall, this is a plausible but more aspirational growth outcome. Such an approach is entirely consistent with the PPG in terms of how it answers the question on how business needs should be assessed, taking into account evidence of market demand, stakeholder engagement and key sectors from an area’s Local Industrial Strategy (ID: 2a-026-20190220)
As is set out below, there is a strong justification for the adoption of the ‘higher growth scenario, that would ensure that housing growth mirrors jobs growth in the Plan area.
(b) Economic Growth and Investment in Greater Cambridge
Greater Cambridge forms part of the Oxford-Cambridge Arc (‘the Arc’) which is considered to be a globally significant area between Oxford, Milton Keynes and Cambridge. It supports over two million jobs, adds over £110 billion to the economy every year and houses one of the fastest growing economies in England.
In February 2021, the Government published its plan for developing “a spatial framework” for the Arc, including a timeline and how it will work with local partners. The plan cites studies that forecast that by 2050 the area would see economic output growing by between £80.4 billion and £163 billion per annum, with between 476,500 and 1.1 million additional jobs. The plan goes on to note that the Government has identified the Arc as a national economic priority area.
The proposed Oxford-Cambridge Spatial Framework will have the status of national policy and is intended to form a material consideration for plan-making alongside the National Planning Policy Framework.
The Government recently sought views on priorities for the Framework as part of consultation on the document ‘Creating a Vision for the Oxford-Cambridge Arc’ (ending October 2021). The latest consultation proposals set out that it will aim to guide sustainable planning and investment decisions under four policy pillars:
a) the environment;
b) the economy;
c) connectivity and infrastructure; and
d) place-making.

This recent consultation follows publication of an initial policy paper in February 2021 setting out the approach to developing the Framework. Paragraphs 2.10 and 2.11 of the policy paper set out in terms of the strategy for housing and planning in the Arc the role of the Framework will not be to make site allocations or to include detailed policies set elsewhere in national policy or better left to local plans (including for example, setting out the housing requirement). However, the policy paper emphasises the importance of meeting housing needs in full (including the delivery of affordable housing) and therefore relies on the calculation of minimum annual local housing need in accordance with the standard method as its starting point. Opportunities to increase levels of development above this minimum starting point are clearly anticipated as part of the Framework’s aspirations to support economic development and ensure a balance between the delivery of new jobs and homes (see paragraph 2.6).
Paragraph 3.8 of the policy paper sets out that the government expects:
“local planning authorities to continue to develop local plans before the publication of the Spatial Framework. These changes will sit alongside wider planning reforms, and as we take forward our response to the ‘Planning for the Future’ consultation, we will outline transitional arrangements and the role of the Spatial Framework within any new system.”
The development of the Spatial Framework will be supported by two further public consultations: Towards a Spatial Framework (Spring 2022) and Draft Spatial Framework (Autumn 2022). It is the Government’s intention to commence implementation of the Spatial Framework throughout in 2023.
In addition to the Arc, Greater Cambridge has benefitted from significant Central Government investment through the Greater Cambridge Partnership (formerly the Greater Cambridge Growth Deal. An initial £100m investment was received in 2015, with the second round of investment, totalling £400m, being received in 2020.
The initial investment supported work on the first phase of the Cambridgeshire Autonomous Metro (CAM), which has since been suspended following political pressure to scrap the proposals. In addition to this, significant infrastructure improvements, including, the Histon Road scheme, the Abbey Chesterton Bridge, Trumpington Park and Ride were supported.
The second tranche of money is expected to support housing and jobs growth across the Plan area, including delivering public transport schemes at Histon Road, Milton Road and West of Cambridge along with the enhancements to the energy-grid capacity across the area so as to ensure that housing and employment growth is not restricted.
Indeed, within the early evidence sitting behind the Greater Cambridge ‘First Proposals’ including the Housing and Employment Relationship Report (HER) November 2020, there is a recognition of the economic growth and infrastructure aspirations across the Plan area.
Despite this the Employment Land Review considered the central employment scenario, equivalent to the Councils’ medium level of jobs, to be the most likely outcome taking into account long term historic patterns of employment including the fast growth of key sectors for the Greater Cambridge economy in the recent past.
With a consistent record of jobs creation, and given the objectives and commitments made as part of the Greater Cambridge’s inclusion in the Arc, along with the significant levels of investment in the area, there is robust evidence that jobs growth targets, as with housing targets, should be aspirational and look to establish the county as a leading economic force in the UK. As such use of the higher scenario is fundamentally supported.
The PPG (Paragraph: 010 Reference ID: 2a-010-20201216) is clear that where there either growth strategies for the area that are likely to be deliverable, or strategic infrastructure improvements that are likely to drive an increase in the homes needed locally then in these circumstances increases in housing need are likely to exceed past trends. In order to be justified by relevant in evidence in accordance with paragraph 35 of the NPPF2021 preparation of an appropriate strategy for Greater Cambridge must likewise have regard to relevant market signals. The elements specified in the PPG comprise directly relevant market signals within the plan area that have been rejected during preparation of the ‘First Proposals’ and thus render the proposed approach unsound (not positively prepared and not justified).
(c) Market Demand
Importantly the PPG states that levels of housing need beyond the standard method will need to be assessed prior to, and separate from, considering how much of the overall need can be accommodated. It states that there will be situations where previous levels of housing delivery in an area are significantly greater than the outcome from the standard method and that this will need to be taken into account when considering whether it is appropriate to plan for a higher level of need than the standard model suggests.
Paragraph: 015 Reference ID: 2a-015-201902261 of the NPPG highlights that the consideration market signals to justify a higher requirement that that which results from the standard methodology can be considered sound. or calculating housing need. It is therefore also appropriate to consider signals such as historic delivery and affordability.
Taking COVID-19 into consideration, clearly, as demonstrated by output, demand is continuing to grow across the Plan area and can be aligned with the recent trends in jobs growth as is detailed further.
Greater Cambridge, like many parts of the East of England, is characterised by high housing costs and particular affordability pressures.
The average house price in Greater Cambridge in September 2015 was £345,248 and in the most recently available figures, for September 2020, it stood at £402,500; an increase of 16.7%.
Across the Plan area, the City of Cambridge has significantly worse affordability issues than South Cambridgeshire, but the affordability ratios (and thus pressure in terms of access to market housing) are rising more quickly in South Cambridgeshire.
Both of the constituent Local Planning Authorities have seen a worsening trend in workplace-based affordability ratios over the past 5-years as demonstrated above in Table 3 notwithstanding levels of housing delivery.
Given the very strong jobs growth in recent years it would normally be expected that workplace-based affordability would demonstrate the greatest improvement or stabilisation (in keeping with the Government’s aims in introducing the Standard Method).
Assumptions regarding commuting are important in determining the population and future housing needs and ensuring a sustainable relationship between the supply of jobs and homes. In recent years in-commuting into Greater Cambridge has increased significantly. Housing delivery above that required to sustain the associated level of employment growth will likely result in a reduction of net commuting and an improvement in housing affordability within Greater Cambridge.
This is only likely to be achieved in circumstances where housing growth reflects the outputs of the Councils’ ‘higher’ employment growth forecast. Housing delivery below that required to sustain the associated level of employment growth will likely result in an increase in net commuting and a deterioration in housing affordability. This cannot be regarded as sustainable.
The Councils’ HEGER shows net in-commuting to Greater Cambridge in 2011 of 30,173 persons (Table 12). Table 19 anticipates that using the Council’s central scenario and a 1:1 commuting ratio forecast jobs growth would result in further net commuting inflows of 6,147 persons. This is because the 1:1 ratio is only applied to jobs growth that is supported through planned housing delivery in excess of that already provided for under the standard method (Paragraph 4.12). A total net flow of in-commuters of 36,347 cannot be regarded as sustainable. Furthermore, Paragraphs 4.31 to 4.33 of the HEGER look at the locational impact of housing additional workers outside Greater Cambridge, as generated under 2011 commuting ratios to support jobs growth under the central and higher scenarios compared to the balance achieved when a 1:1 ratio is applied to jobs growth above that supported by the standard method. The problem for the Council is that while it claims to avoid the impact of a 114dpa locational impact on surrounding authorities of the central scenario through use of the 1:1 ratio any jobs growth above this total will substantially increase in-commuting in order to provide for the number of workers required. Additional sensitivity testing is required to illustrate this, given that jobs growth continues to outpace housing delivery under existing trends.
In terms of the relationship with the affordability ratios set out in Table 3 it should be noted that the residence-based ratio for South Cambridgeshire is lower than the workplace-based figure (2020: 9.68). This ratio has remained relatively stable, albeit substantially in excess of national averages, and has not been significantly reduced by recent levels of housebuilding.
In South Cambridgeshire, the residence-based affordability ratio may be explained by an ageing population, who generally benefit from higher earning, could arguably account for this trend, with residents in the rural district taking the highest paying jobs across Greater Cambridge, with younger and generally lower paid workers being forced to commute further.
It is recognised that a significant proportion of new employees following recent jobs growth are in-commuters so if they are commuting into Greater Cambridge (and can’t afford housing) their earnings won’t affect the residence-based ratio (which is made up of the ageing population referred to above). It should also be recognised that not all jobs growth across the county will be high-earning, particularly growth in the service sector, which places upward pressure on workplace-based affordability ratios.
This is a significant negative side-effect of failing to sustain the required balance between the growth in homes and jobs. This scenario is effectively acknowledged at Paragraph 3.77 of the HEGER Report regarding recent increased in-commuting to South Cambridgeshire.
In these circumstances it is correct that use of the 2011-based commuting ratio in these circumstances would not suppress levels of housing need (i.e., it would not seek to lock-in even more unsustainable commuting patterns and sources of net additional labour supply from outside of Greater Cambridge). However, the practical issue is that continued impacts are only likely to be avoided where planned housing growth genuinely reflects a reasonable assessment of potential employment growth.
In these circumstances the ‘First Options’ proposals to suppress opportunities for growth in the rural area at sustainable settlements including Steeple Morden, in circumstances where this would encourage even greater long-distance commuting, are misconceived and unsound (not justified and not effective).
The present levels of economic growth have resulted in a supply-demand imbalance for housing, contributing to both house price growth and growth in net in-commuting into Greater Cambridge. As such, Greater Cambridge’s strong economic performance has led to a supply/demand imbalance which has created a further deterioration in housing affordability.
Greater Cambridge is clearly an expensive place to live and work, but there are clear indications of strong market demand. In the pre-pandemic years of 2018-2019 and 2019-2020, delivery across the Plan area exceeded 2,000 dwellings per annum.
The level growth witnessed in the years 2018-2020 has resulted only in a marginal improvement in the affordability recorded in Cambridge, but not in South Cambridgeshire, and therefore this height of growth at some 2,000 dwellings per annum is clearly insufficient to address worsening affordability trends. This is in-line with the Government’s position on minimum annual local housing need providing the relevant starting point but not confirmation of an appropriate level of supply to address housing market pressure.
The economy in Cambridgeshire remains amongst the most buoyant nationally and, with the Government prioritising the area for growth, it is forecast that economic activity rates, investment and the development of industries within key sectors will continue and grow in the years ahead. Accordingly, once again, there is a clear rationale for adopting a higher approach to housing need that would support the level of job growth that the Plan area has the potential to accommodate and, indeed, is accommodating.
There is sufficient evidence to support at least 2,549 dwellings per annum being planned for in accordance with the Plan area’s objectively assessed housing need. This is entirely in line with the Council’s own evidence base in respect of economic growth and would ensure that jobs growth does not continue to outstrip housing growth.

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.

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.

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.

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.

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.
The landowner is supportive of the Councils' decision to plan for higher levels of growth than the standard method, though it is disappointing that the Council have decided to base their strategy on the medium rather that the higher growth scenario. The Greater Cambridge economy is dynamic and does not readily align with national or regional forecasts for jobs growth. It has a world-renowned life sciences cluster which has the potential to drive growth beyond typical regional or national rates.
We would strongly advise the Greater Cambridge Partnership to ensure that their objectively assessed housing targets are more aligned with the higher jobs growth aspirations. An indicative calculation based on Cambridgeshire and Peterborough Independent Economic Review suggests that, if the jobs growth targets are to be achieved, around 2,900 homes a year would need to be built in Greater Cambridge - an indicative total of 66,900 homes over 2020-2041.
As set out in the Government's most recent consultation document, the OxCam Arc has the potential to be one of 'the most prosperous, innovative and sustainable economic areas in the world'. However, this transformational growth will only be achieved if local authorities make asserted efforts to provide the residential capacity needed to support sustainable growth across the region. On this basis, we would strongly urge the Council to plan for the higher growth scenario, which is more closely aligned with past growth rates in the Greater Cambridge area.

We have witnessed a remarkable acceleration in the use of on-line retailing and a significant increase storage and distribution from manufacturing business which have been part of the massive demand for logistics and warehouse buildings. This demand has been fuelled by the twin drivers of Covid 19 movement restrictions and uncertainty in the global supply chain of goods and components, a factor of Brexit and Covid. Nationally this has led to a supply of less than 12 months in logistics floorspace. Lack of floorspace to meet the needs for storage and distribution will lead to strain on all sectors of the economy and public life. As a part of social infrastructure, logistics floorspace like retail floorspace, needs to respond to growth in population and real growth in demand. National Policy Statement for National Networks confirms that the logistics industry provides warehousing and distribution networks for UK manufacturers, importers and retailers.

In respect of need for employment land the SoS found “an evident and compelling planning policy imperative for high-quality logistics floorspace regionally, sub-regionally and locally”. The lack of employment land was likely to result in valuable investment flowing into adjacent authorities to the detriment of local residents and existing businesses wishing to expand would continue to leave to find more suitable premises.

It was material the site is available now and can be delivered relatively quickly to address known commercial and policy needs.

The development would deliver a range of socio-economic benefits which carry significant weight in the Borough. Those benefits included;

• A construction expenditure of £72.7m, creating over a thousand construction jobs;
• The creation of 1,200-1,410 operational jobs with mechanisms in place to ensure these are available to local people.
• Business rates of circa £3m per annum;
• £50-60m GVA, and
• Support for local businesses.

In a number of recent Inquiries the SoS gave very substantial weight to the delivery of high-quality logistics floorspace. Commenting that the proposal would address “the very specific locational requirements of the logistics sector and make provision for storage and distribution operations at an appropriate scale.”

The SoS agreed the proposal would “deliver a substantial range of tangible economic benefits including well paid jobs for local people” and would boost the local economy.

The Secretary of State found;
• there is persuasive evidence that a substantial planning need exists for major logistics and associated industrial development of the kind proposed in this application.
• the broad evidence of need for the type of employment land represented by the application site is material to the consideration of this application.
• while approval of the present application would produce a numerical exceedance of the quantum of employment development allocated; such development plan provisions are not to be regarded as ceilings to development
• there is evidence of unfulfilled enquiries for development of the kind proposed
• the evident need for development of the type proposed carries substantial weight in the planning balance.
• the proposed development would contribute substantially to the national policy imperative, to promote and support a strong competitive economy, as particularly with regard to the need for storage and distribution facilities, at a variety of scales, in accessible locations. the development would contribute substantially to the supply of employment land evidently necessary to the economic recovery and well-being of the area.
• the development would directly and indirectly generate several thousand jobs and other economic benefits in the area, encouraging business commitment and creating opportunities for enhancement of skills among the workforce.
• agrees that that the economic benefits carry very substantial weight in the planning balance.
• the evident need for development of the type proposed carries substantial weight, and the economic benefits of the proposal carry very substantial weight in favour of the scheme.

The Inspectors found
• Information from the British Property Foundation (BPF) confirms a widely held view that rapid growth being experienced in the logistics sector of the UK has been due to structural changes to high street retailing and a commensurate growth in e-commerce. This shift has been accelerated by the ongoing Covid19 pandemic restrictions on personal movement.
• The warehousing and logistics sector has proved resilient in the current pandemic. It is therefore to be expected that this sector will be instrumental in the post-pandemic recovery of the wider UK economy.

Significantly, National Policy Statement for National Networks states;

The logistics industry, which directly employs over two million people across more than 190,000 companies generating over £90 billion annually, underpins the efficient operation of most sectors of the wider national economy.4

With respect to warehouse and distribution space, the Employment Land Review reports an under supply of around 20,000 m2 and suggests suitable locations should be identified for small and mid-sized light industrial and distribution units. The analysis also identified an undersupply in industrial floorspace requirements, and the consultants suggest that some provision should be made for allocations that support this use class, both in order to facilitate traditional industries as well as supporting advanced industries that require operational activities not suited to residential areas. It states that future re-provision should be of at least 25,000 m2, however, planning for a greater recommended rate of up to 50,000 m2 would align with the recent completions trends and better offset losses in both the Cambridge and South Cambridgeshire

The ELR says that for Industrial (B2) and Warehousing and distribution (B8); suitable locations should be identified for small and mid-sized light industrial, general industrial and distribution units. Light industrial premises are required with anticipated losses in the city requiring re-provision in South Cambridgeshire. Some provision should be made for allocations that support general industrial floorspace in order to facilitate traditional industries as well as supporting advanced industries that require operational activities not suited to residential areas.

While the plan is seeking to provide a range of new employment space this will not, together with the existing allocations, provide a good range in the type, size and location of sites that respond to the needs of businesses. A range of employment sites must be able to cater for the needs of the logistics sector and provide sites of at least 10ha close to the SRN. A single warehouse of 25,000 sqm (which is below the current market average) requires a site of around 10ha. Greater Cambridge will need to consider whether regional distribution centres are being provided in sustainable locations in adjoining authority areas to meet any regional need before unilaterally abdicating responsibility to meet regional needs.

Failure to address the logistics floorspace needs of Greater Cambridge will lead to increased vehicle miles as businesses and households are supplied from facilities further away. There will also be greater stress on businesses seeking to fulfil orders from greater distances. Logistics buildings are part of the local manufacturing supply chain and form important synergies with local businesses or customers.

The Plan needs to reflect the current and future needs of the logistic industry as that need is now manifesting itself, post Covid and post Brexit. Large sustainable sites close to the SRN need to be identified in a planned way.

LATE REPRESENTATION
On behalf of Westley Waterless Parish, I would like to put on record the following comments about the SCLP.

Strategy
Figure 4 - support the locations of proposed new housing development 2020-2041
Policy S/JH - agree that the Plan should formulate proposals based upon the forecast of the most likely level of new jobs
Policy S/DS agree with the proposed policy direction and consider that Figure 6 showing proposed sites to be included in the Plan represents a sustainable spatial response to the proposed development strategy. Support the fact that no new settlement is proposed around Six Mile Bottom and agree with the comment at page 39 that further new settlements should not be allocated
Policy S/RRA - endorse Figure 43 showing site allocations in the rest of the rural area which does not include SMB

Greater Cambridge HELAA Appendix 4 (Part C)
Refer to Site 40078 at pages 1419-1425
Agree with the red assessment of impact upon the local landscape. But it must be noted that the overall evaluation has been based upon a development of 2,000 dwellings whilst the Concept Vision produced by L&Q Estates / Hill Residential Ltd. in February 2020 describes Westley Green as having the potential to deliver up to 8,500 dwellings. The Westley Green Concept Framework shows a very large site extending into East Cambridgeshire and the impact of such a development form will have a significant deleterious impact upon a much wider landscape and existing communities. That scale of development will have a much greater impact upon local infrastructure such as water supply than the more limited assessment contained in the HELAA.

Have ECDC formally requested that the Plan should accommodate some of its future housing provision around SMB?

Kind regards
Jim Paltridge
Chair
Westley Waterless Parish

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.
The landowner is supportive of the Partnership's decision to plan for higher levels of growth than the standard method, though it is disappointing that the Council have decided to base their strategy on the medium rather that the higher growth scenario. The Greater Cambridge economy is dynamic and does not readily align with national or regional forecasts for jobs growth. It has a world-renowned life sciences cluster which has the potential to drive growth beyond typical regional or national rates.
We would strongly advise the Greater Cambridge Partnership to ensure that their objectively assessed housing proposals are more closely aligned with the higher jobs growth aspirations. An indicative calculation based on Cambridgeshire and Peterborough Independent Economic Review suggests that, if the jobs growth targets are to be achieved, around 2,900 homes a year would need to be built in Greater Cambridge - an indicative total of 66,900 homes over 2020-2041.
As set out in the Government's most recent consultation document, the OxCam Arc has the potential to be one of 'the most prosperous, innovative and sustainable economic areas in the world'. However, this transformational growth will only be achieved if local authorities make asserted efforts to provide the residential capacity needed to support sustainable growth across the region. On this basis, we would strongly urge the Council to plan for the higher growth scenario, which is more closely aligned with past growth rates in the Greater Cambridge area

We have attempted, unsuccessfully, to complete a survey on line and am now writing to you re the grand plan for 44,000 homes and 58,500 jobs before 2041.

We are unclear whether the houses are being built for jobs or are the jobs being created for the housing.

There is no more room for more houses in Cambridge without building on flood plains/green belt. There are not enough doctors, dentists or water at present. There is a transport system that already cannot cope.

For any new houses that are planned it is hoped that they will all be eco-friendly. With heat pumps, solar panels and electric car charging points as directed by COP26.

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
• 44,400 homes, reflecting an annual objectively assessed need of 2,111 homes per year, which is rounded for the plan.
This 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 following two studies, with the higher need predicated on supporting anticipated economic growth within Greater Cambridge:
• 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 both 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 proposed housing requirement evidently aligns with the Central scenario (58,400 jobs), with the First Proposals therefore not looking to provide the housing infrastructure that would appear to be needed to accommodate a more ambitious level of employment growth.
Whilst Taylor Wimpey 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 and the clear aspirations for economic growth within the Arc. Clearly the Greater Cambridge Local Plan will also need to conform with the Spatial Framework for the Arc when prepared which will have the same status of National Policy.

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

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

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

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

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

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

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

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

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

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

Greater Cambridge Local Plan – The First Proposals Consultation
Land east of Long Road, Comberton

Thakeham Homes Ltd (Thakeham) is writing in respect of the Greater Cambridge Local Plan – The First Proposals Consultation (1st November to 13th December 2021), specifically in relation to Land east of Long Road, Comberton located to the east of Comberton (‘The Site’)

Introduction Thakeham is pleased to be participating in this consultation and has outlined its position below in response to the Greater Cambridge Local Plan (GCLP) – The First Proposals Consultation.

Thakeham is promoting a site: Land east of Long Road, Comberton which is located on the eastern edge of Comberton. This site is available, within single ownership and is achievable and deliverable to contribute towards the development needs of Greater Cambridge in the first five years of the plan period.

An Evolution Document accompanies these representations, which further sets out Thakeham’s vision for the site, incorporating 400 new homes (inclusive of policy compliant affordable housing provision) alongside key community benefits including a new flexible co-working space, a new Multi Use Games Area and community allotments alongside play space and open space provision.

About Thakeham
Thakeham prides itself in being an infrastructure-led sustainable placemaker and is committed to creating new, extraordinary places, where the highest attention to detail makes a positive difference.

Thakeham build for the future, for communities and individuals. Our approach sets us apart from our competitors. We deliver our schemes with a focus on sustainable development, looking ahead of current housing standards. From 2025, all Thakeham Homes will be carbon neutral in production and zero carbon in lifetime use.

Each development is different and tailored to its locality with careful consideration of the area’s character, as well as the environment. As a sustainable placemaker first and foremost, Thakeham’s commitment to improving existing communities means its schemes are design and infrastructure-led; engaging with education, highways, healthcare, utilities and other local community, cultural and environmental stakeholders from the start of each project. The delivery of homes facilitates the delivery of physical, social and green/blue infrastructure which benefits the wider surrounding area, as well as the new residents, and ensures that Thakeham create sustainable places to live and work.

As one of 12 members of the NHS Healthy New Towns network, Thakeham is a committed advocate of developing healthy places in line with the Healthy New Town principles. But over time, we have realised that these principles are just the starting blocks, and at Thakeham, as a founder member of the HBF Future Homes Task Force, we are committed to delivering sustainable, zero carbon communities. Out approach sets us apart from our competitors. We deliver our schemes with a focus on infrastructure-led sustainable development.

Sustainability
There is an evident theme in Greater Cambridge in respect of environmental impact and the importance of ensuring any development, whether that be residential or infrastructure, seeks to minimise its impact. Thakeham would like to take this opportunity to outline the measures implemented on its developments to minimise environmental impacts as a direct and indirect result of development: • From 2025, all Thakeham homes will be net-zero carbon in lifetime use. • From 2025, all Thakeham homes will be carbon neutral in production. Our off-site panellised system will make construction more efficient, faster, enhancing quality and reducing construction traffic. • Thakeham is committed to offsetting the embodied impact from the production of new houses, as well as development houses that are zero carbon in lifetime operation. • Thakeham support the Wildlife Trust’s guidance on Homes for People and Wildlife. Our commitment is to at least 20% biodiversity net gain (double the government’s target within the recent Environment Act 2021) on all our developments post-2025 with attractive and functional green and blue infrastructure. • Through placemaking and the implementation of sustainable travel plans, Thakeham prioritises walking and cycling over car travel, helping people make more sustainable choices around walking, cycling and taking public transport, as well as highlighting innovative car-sharing online platforms such as LiftShare to reduce single-occupancy car use and facilitating use of autonomous vehicle/pods. • Thakeham provides electric car charging points at all of their homes both market and affordable alike, reducing barriers to customers purchasing emission-free vehicles. • Thakeham is keen to champion low carbon transport in the local area, encouraging local transport services such as buses to electrify their fleet. • Mechanical Ventilation with Heat Recovery (MVHR) is installed in our homes, which has a filter built-in to capture incoming pollution to provide fresh filtered air. • Thakeham works with its supply chain with an aim that all mechanical plant on site is less than 18 months old, which means it is less polluting and more fuel efficient.

Response to Options
Thakeham has reviewed the consultation documents and has chosen to comment on key questions and themes where relevant to our business to comment on.

Vision and development strategy
Vision and aims Thakeham supports the Council’s vision for new development to come forward with sustainability and healthy place shaping at the forefront. As we’ve touched on above, Thakeham supports the focus on healthy place shaping, with a need to ensure that future development maximises opportunities for journeys to be made on foot or bicycle. This will necessitate ensuring new developments prioritise non-motorised transport and easy access to full range of day-to-day services and facilities. Thakeham has made a number of commitments in respect of its own carbon impact, ensuring that all its development will be net zero carbon in lifetime use and carbon neutral in production by 2025. Additionally, Thakeham has made a commitment to achieve 20% biodiversity net gain on all projects post-2025 which is double that set out in the Environment Act 2021.

How much development, and where – general comments

Whilst Thakeham supports a weighted distribution of development towards the most sustainable locations and key employment hubs, we would emphasise the importance of a variety of growth locations and sizes to support housing growth. New settlements, strategic extensions and development in rural locations all form a key part in meeting varying housing needs and ensuring a consistent supply of housing delivery.

S/JH: New jobs and homes
Thakeham is supportive of the Councils’ conclusions that adopting the suggested ‘standard method minimum homes and related jobs’ approach would not be appropriate for Greater Cambridge and would not support its economic growth aspirations.

It is acknowledged that the Councils’ have sought to accommodate an uplift to accommodate their economic growth aspirations, suggesting that the ‘medium level of homes’ approach is justified, resulting in a need for 44,400 homes over the plan period 2020-2041 amounting the 2,111 homes per annum, alongside provision of 58,500 new jobs over the plan period.

Whilst the ‘maximum level of homes’ does not represent the Councils’ preferred approach; it is worth noting that this approach does acknowledge housing need arising out of fast job growth and therefore the Employment Land Review makes recommendations to provide more that the ‘medium’ scenario level of jobs to provide flexibility.

Thakeham is supportive of the Councils’ intention to accommodate their full objectively assessed needs for housing and jobs within the plan area. It is also acknowledged that a 10% buffer has also been added into their housing requirement to provide flexibility, amounting to a housing requirement of 48,840 over the plan period.

The Greater Cambridge Local Plan will need to ensure that it is planning for a sufficient number of new homes to support its economic growth aspirations. Whilst it is acknowledged that the medium option for new homes does incorporate an uplift for economic growth in the area, in addition to the application of a 10% buffer to reach the suggested housing requirement. Thakeham would suggest that the Councils undertake further work to ensure that the correct uplift has been applied to ensure that the Councils can meet their relevant aspirations in terms of job creation and growth, and as a result provide the right level of housing to support this. This is important to ensure that existing employers in the area can continue to thrive and expand retaining and attracting staff including graduates, in what is a global recruitment marketplace for many of the industries already located in Greater Cambridge. Further, in order to ensure Greater Cambridge continues to be a focus for inward investment into the UK, following on from the successes of the past, continued focus on supporting employment growth will be key and part of that will be providing housing to attract not just highly skilled staff but also for the variety of lower paid workers such as cleaners, delivery drivers and shop workers. These lower paid workers are necessary to support the wider community and economy such as in Greater Cambridge where land and house prices are high. These people are either driven out, much has been the case in London and has been seen in parts of Greater Cambridge to more affordable locations, but with the consequence of a longer commute, or greater affordable housing provision is required to accommodate them

S/DS: Development strategy

The first proposals consultation is suggesting a focus on existing commitments and expansion of existing sites to meet the suggested housing need. Where new sites are proposed these are focussed predominantly within and around the edge of Cambridge.

The background text to S/DS suggests that very limited development is proposed in rural areas due the Councils’ desire to focus growth to more readily sustainable locations. Whilst, as we have touched on above, Thakeham supports a weighted distribution of development towards the most sustainable locations and key employment hubs, we would emphasise the importance of a variety of growth locations and sizes to support housing growth. New settlements, strategic extensions and development in rural locations all form a key part in meeting varying housing needs and ensuring a consistent supply of housing delivery. In particular, growth in rural areas can contribute to improving and maintaining the vibrancy of these areas and is of great importance to ensuring these communities thrive. The important role that development in these rural areas can play should not be overlooked in the GCLP development strategy.

S/SH: Settlement hierarchy
The settlement hierarchy seeks to group together similar settlements into categories that reflect their scale, characteristics and sustainability. It then seeks to limit development in any settlements which fall within the ‘Minor Rural Centre’ category and below.

Thakeham considers this view is overly prescriptive. The Settlement hierarchy identifies just 8 settlements which would have no limit on individual scheme size:
City: Cambridge
Town: Cambourne, Northstowe and Waterbeach New Town
Rural Centres: Bourn Airfield New Village, Histon & Impington, Great Shelford and Stapleford and Sawston

The Greater Cambridge Area covers a significant geographical area and this suggested policy approach limits development opportunities across the plan area. It is suggested that development at Minor Rural Centre’s should incorporate schemes of a maximum scheme size of 30 dwellings with lower tiers suggesting significantly less.

Policies should retain a flexible approach to ensure that promotion sites and applications can be assessed on a site-by site basis on the merits and positive contribution they could make to an existing and future community. Development opportunities in these communities could have significant longer term sustainability benefits by helping existing services remain, and where appropriate levels of growth are accommodated, new services could be provided as a result of development.

Rest of the rural area
Rest of the rural area - general comments

As we have discussed above, Thakeham do not consider that the Greater Cambridge Local Plan goes far enough to support rural villages to allow them to thrive and grow in a sustainable way.

The supporting text and preferred options throughout this consultation suggest that growth has been directed away from rural areas to meet the plans climate objectives and encourage a modal transport shift from private car use. The importance of rural communities and ensuring they have the ability to grow appropriately to accommodate their needs and improve their services is paramount to ensuring these communities thrive alongside larger towns and cities. Importantly, appropriate growth at smaller settlements can help contribute to local services and facilities, including public transport provision and internalisation.

As discussed in these representations, Thakeham is promoting Land east of Long Road, Comberton as a sustainable extension to the village. Thakeham prides itself on being and infrastructure-led placemaker who seeks to ensure that social, physical, green and technological infrastructure is delivered as a result of its developments, in appropriate manner in relation to scale and siting of such sites. As part of its promotion at Land east of Long Road. Comberton Thakeham has sought to adopt a landscape a social infrastructure-led approach to its proposals. Alongside open space and play provision the proposals also include a co-working hub, community allotments and a Multi Use Games Area. Thakeham has proven track record for early infrastructure delivery, ensuring that existing and new communities’ benefit from the outset.

In addition, Thakeham has its own approach to sustainable movement starting with the principle of reducing the need for travel, which in part can be achieved by offering bespoke home offices for all of our houses. The focus is then on shifting the mode of travel by ensuring pedestrian and cycle movement is prioritised and links into the existing network where possible, encouraging private vehicles to be a tertiary mode of transport. Thakeham has also made a commitment to provide easily accessible cycle storage with charging for electric bikes and scooters and the provision of fast electric vehicle charging points for all houses.

Climate change
Climate change - general comments
Thakeham is supportive of the Councils’ objectives to enhance climate change resilience and transition Greater Cambridge to net zero carbon by 2050.

As a developer, Thakeham prides itself in the objectives it has set in respect of climate change and the impact development can have. Thakeham has a key focus on sustainable practices both in construction and placemaking. Our approach sets us apart from our competitors. Thakeham’s schemes are delivered with a focus on sustainable development, looking ahead of current housing standards. From 2025, all Thakeham homes will be carbon neutral in production and zero carbon in lifetime use. Thakeham are a founding member of the HBF Future Homes Task Force, which examines how the house building industry can work toward delivering net zero carbon homes in order to support the Government’s target of the country delivering ne zero carbon emissions by 2050. Thakeham has a particular focus on first improving the fabric of buildings, constructed from sustainable timber sources, consideration of sustainable energy features and a sustainable procurement strategy which encourages the use of recycled materials. Thakeham intends to open a new MMC factory in the future, which will provide locally sourced MMC constructed homes further helping to reduce the environmental impact of construction.

CC/NZ: Net zero carbon new buildings
Thakeham considers that the proposed policy direction is too prescriptive and does not provide sufficient flexibility for advances in technologies and Building Regulations. Policy wording should be less prescriptive on the measures used to achieve net zero carbon buildings, rather there should be sufficient flexibility to allow the methods for achieving such targets to be assessed on a site-by-site basis. This is critical as technology is advancing quickly and will continue to do so during the lifetime of the emerging local plan and consequently to set prescriptive policies will have the effect of the local plan being out of date before or at adoption.
As above, Thakeham prides itself in its own objectives for all its new homes to the zero-carbon in lifetime use and carbon neutral in production by 2025.

Biodiversity and green spaces
BG/BG: Biodiversity and geodiversity
Thakeham is supportive of the policy direction of BG/BG and the Councils’ aspiration to require a minimum of 20% biodiversity net gain, whilst also acknowledging the difficulties this may bring for smaller sites with a suggested contribution mechanism to allow these sites to meet the requirements of the proposed policy. However, the current policy direction seeks to limit off-site habitat measures to align with the Greater Cambridge green infrastructure network strategic initiatives. Whilst it is acknowledged that this may represent a preferred approach, this may cause issues in deliverability due to availability of such land.

Policy BG/BG should incorporate sufficient flexibility to allow sites to achieve the required biodiversity net gain requirements by measures which are most appropriate to that site, if this requires off-site habitat creation there should be sufficient flexibility to allow consideration of all suitable options to ensure such requirements do not stifle development. Thakeham itself has already made a commitment to achieve at least 20% biodiversity net gain as a result of our projects post 2025.

Wellbeing and Inclusion
Policy WS/HD: Creating healthy new developments
Thakeham supports the objective and policy direction of Policy WS/HD, requiring health principles to be applied to new development, drawing on the ten principles developed from the Healthy New Towns Initiative.

In our view, relevant policies in respect of wellbeing and inclusion could go further to set out requirements on not only creating healthy new developments, but other measures which maximise wellbeing benefits that developments can offer those who build them, those who live in them and the communities around them now and into the future.

As one of 12 members of the NHS Healthy New Towns, Thakeham supports such policy initiatives and itself is a committed advocate of developing healthy places in line with the Healthy New Town principles. But over time, we have realised that these principles are just starting blocks, and at Thakeham, as a founder member of the HBF Future Homes Task Force, we are committed to delivering sustainable zero carbon communities. Our approach sets us apart from our competitors, Thakeham is passionate about having a positive impact on people’s wellbeing, constantly striving to deliver against our four key focus areas:
-Building local communities via excellent placemaking that creates interconnected communities that challenge issues of loneliness and promoting healthy living, and via our long-term charity partnerships.
-Building future generations via our school engagement programmes, including our industry leading holistic ecology programme ‘Eddie and Ellie’s Wild Adventures’ for primary age pupils, and providing inspiring careers support to secondary age pupils through our Cornerstone Employer status with The Careers Enterprise Company.
-Building a stronger Industry with our support of small and medium size enterprises and upskilling for local workers, supporting apprenticeships, and actively contributing to the diversification and upskilling of the construction sector.
-Building Sustainable places by tackling issues of climate change, biodiversity loss and societal disconnects via our ambitious Sustainability Strategy.

WS/IO: Creating inclusive employment and business opportunities through new developments
Thakeham is supportive of the policy direction of Policy WS/IO and as touched on above, adopts its own approach to creating inclusive employment and business opportunities through our support of small and medium size enterprises and upskilling for local workers, supporting apprenticeships, and actively contributing to the diversification and upskilling of the construction sector.

Homes policies Policy
H/AH: Affordable housing
Thakeham support the Councils’ policy direction in respect of Affordable Housing and the importance that such homes are built with inclusion, health and wellbeing at the forefront. Thakeham continues to provide policy compliant affordable housing across all of our developments whilst adopting a truly tenure blind approach to affordable housing which creates cohesive communities.

H/SS: Residential space standards and accessible homes
Whilst Thakeham supports the Councils’ aspiration to see good quality homes delivered across their districts, such policy requirement which seeks all dwellings to meet NDSS needs to be supported by robust evidence that there is a specific need to introduce such standards. Any policy requirements in respect of housing accessibility requirements should be based on identified need, with sufficient flexibility incorporated to ensure that provision is directed to the right places. In particular, blanket policy requirements for M4(2) in all new developments should not be adopted as these requirements should be based on identified need, whilst requirements in relation to M4(3) can be particularly onerous and should only be directed to developments where there is an identified end user.

H/CB: Self- and custom build homes
Whilst Thakeham is supportive of self and custom build home provision in Greater Cambridge, it is not considered that a blanket policy as suggested by H/CB on developments of 20 or more is appropriate or feasible. Self and custom-build products should be directed towards key strategic allocations to ensure such homes are deliverable. Self and custom build home provision should also be based on an identified need.

Land east of Long Road, Comberton

The accompanying Evolution Document outlines the constraints and opportunities associated with Land east of Long Road, Comberton and provides a high-level illustrative masterplan and delivery strategy. The site can accommodate circa 400 dwellings alongside significant community benefits on an edge of settlement location, with close proximity to existing facilities and services, with main vehicular access from Long Road.

The landscape and social infrastructure-led scheme is planned around the provision of open space incorporating a number of community benefits including: play space, a Multi Use Games Area, community allotments and a new flexible co-working space.

On the edge of Comberton, the site is situated in a sustainable location with opportunities to access existing local services and amenities within the village. There is also access to public transport provision within close proximity of the site.

The site is within single ownership, within the control of Thakeham and on that basis Thakeham confirms that the site is available and deliverable within the first five years of the plan period.

We trust that these representations are useful and clear, and we would be grateful for confirmation of receipt of our submission. In the meantime, please do not hesitate to contact me if you have any further queries or require any further information.

1. INTRODUCTION

1.1 This representation has been prepared by Strutt & Parker on behalf of Countryside Properties (UK) Ltd to support the promotion of land to the north-west of Balsham Road, Linton as part of the Greater Cambridge First Proposals Consultation 2021.

1.2 In September 2021 Greater Cambridge Shared Planning Service published the Greater Cambridge Housing and Economic Land Availability Assessment (HELAA), which provided an initial assessment of the sites put forward for consideration for allocation as part of the Call for Sites consultations within Greater Cambridge.

1.3 This representation provides a response to the ‘First Proposals’ Preferred Options Consultation and has been structured to respond to relevant questions as set out within the First Proposals Consultation. In addition, a detailed assessment is provided in respect of the HELAA Proforma for the site.

1.4 The HELAA excludes the Balsham Road site from allocation primarily on the basis of landscape issues, notably that the proposed development “would have substantial and unacceptable landscape and visual impacts that would not be sufficiently mitigated by the proposed landscape treatments”.

1.5 The site was submitted as part of the Call for Sites for circa 300 dwellings and a rural business park. In response to the HELAA consultation, an updated Landscape Technical Note and Opportunities and Constraints Plan has been prepared by Barton Willmore to respond to the landscape and townscape comments regarding the sensitivity of the site. As a result, it is proposed to set development back from the northern boundary and provide key landscape corridors through the site. The site is considered to have capacity for the provision for up to 300 dwellings and up to 1 hectare of employment land. The Technical Note by Barton Wilmore on the landscape and visual impact has been provided within appendix A of this response.

1.6 The Opportunities and Constraints Plan demonstrates where the most and least sensitive areas within the site are. This has been produced in conjunction with the Technical Note on landscape and visual impact and the Council’s Landscape Character Assessment (2021). This has informed a reduced developable area. The revised scheme has been set back from the north, with clear landscape corridors, to allow clear landscape views to the Grade II Listed Water Tower to be fully maintained. The proposed development area represents a logical rounding off and extension to the large Minor Rural Centre of Linton which is a well-served village with a number of existing services and facilities.

1.7 Therefore, in view of the above, it is considered that several of the assessments criteria, particularly regarding the landscape impact should be re-categorised. It has been demonstrated in the supporting information provided that the allocation of this site would not have a significant adverse impact the landscape and townscape such that the site should be considered as a suitable, achievable and deliverable site for housing and should therefore be put forward for allocation in the emerging Local Plan. Further analysis of this is set out within section 7 of this report.

1.8 In support of this report, the following documents have been prepared; • Landscape and Visual Technical Advice Note – Barton Willmore; and • Opportunities and Constraints Plan – Barton Willmore.

1.9 In addition to the above documents, where relevant reference is also made to documents prepared and submitted previously as part of earlier rounds of consultation on the Local Plan.

2. QUESTION: Do you agree that we should plan for an extra 550 homes per year, so that housing keeps up pressure with increased jobs in our area?

2.1 We agree that it is very important that housing delivery keeps up for demand for increased jobs within the area.

2.2 As part of the preparation of the emerging Greater Cambridge Local Plan, the Shared Planning Service has identified a need for 2,321 dwellings to be built per year. A significant proportion of this growth is made up of existing allocations within the Local Plan.

2.3 The initial evidence base and spatial options assessment for the emerging Local Plan, set three growth options; ‘minimum’ (40,300 dwellings - based upon standard methodology); ‘medium’ (46,200 dwellings- based upon economic forecast based upon long term historic employment) and ‘maximum’ (67,700 dwellings – based upon fast economic growth in the recent past). In view of this, the housing delivery target of 44,400 new homes over the plan period alongside 58,500 new jobs would fall between the ‘minimum ‘and ‘medium’ growth scenarios previously suggested.

2.4 The Development Strategy Topic Paper, that accompanies this consultation acknowledges that the Greater Cambridge economy is dynamic and does not readily align with national or regional forecasts for job growth. In particular, it has a world-renowned life sciences cluster which has the potential to drive growth beyond typical regional or national rates. It is also acknowledged that in the recent past employment growth within the region has been significantly higher than predicted.

2.5 Accounting for the evidence set out within the Development Strategy Topic Paper, it is not clearly justified why only 44,400 new homes and 58,500 new jobs are proposed over the plan period. It is considered that this approach should be re-visited to increase both housing and employment allocations within the Local Plan. It is considered that the delivery of housing should be significantly increased, in line with the ‘maximum’ growth forecast, to align with economic growth within the recent past. The case for maximum growth forecast is further supported by significant transport investment within the area over the plan period. This includes schemes such as East-West Rail, Cambridge South Station and the delivery of a number of Rapid Transit Routes proposed by the Greater Cambridge Partnership.

2.6 The provision for lower growth scenarios does also not appear to be consistent with the Government’s objectives for the Ox-Cam Arc as a focus for housing and employment growth with associated infrastructure

3. QUESTION: Do you agree that new development should mainly focus on sites where car travel, and therefore emissions, can be minimised?

3.1 Yes, in principle the proposal to focus development on sites where car travel can be minimised is supported. Consistent with this strategy, it is considered to be very important that some growth is delivered in the larger more sustainable villages that are located outside of the Green Belt, such as Linton. National policy is clear within paragraph 79 of the National Planning Policy Framework (NPPF) that planning policies should identify opportunities for villages to grow and thrive, especially where they will support local services. The updated NPPF (2021), also provides additional emphases on the suitability of providing significant extensions to villages, provided that they are well located and designed.

3.2 The CPIER report, which is referenced as a key document within the evidence base provides a detailed analysis regarding the potential benefits of focusing growth along key transport corridors. The proposed Cambridge South-East Transport Project (CSET), proposes significant sustainable transport improvements between Cambridge and Haverhill. This includes significantly improved public transport, including an off-road rapid transit bus route, along with significant cycleway improvements along the A1307, some of which have already been implemented. For ease of reference appendix D of this representation provides accessibility plans, prepared by Richard Jackson Partnership, which were previously submitted as part of the Issues and Options Consultation. The Accessibility Plans demonstrate the significant transport improvement measures within Linton and in between Linton and Cambridge.

3.3 In addition, Linton, benefits from being a sustainable settlement in its own right. As referred to within our previous representation at Issues and Options Stage (refer to Appendix C), Linton is the largest Minor Rural Service Centre (As defined within the adopted and emerging Local Plan) that is not situated within the Green Belt. It is also benefits from both primary and secondary education facilities and a large range of services, including shops, pubs, restaurants and community facilities.

3.4 Linton did also not receive any allocations within the 2018 Local Plan and therefore provision for additional growth as part of the Local Plan 2041 would be appropriate and assist with maintaining viability and vibrancy of the village by sustaining and enhancing rural services.

3.5 For the above reasons, it is considered that additional growth within Linton would be consistent with the objective of the Local Plan, which seeks to minimise car travel. Of the 6 sites submitted within Linton as part of the Call for Sites process, land to the north-west of Balsham Road, is considered to be a particularly sustainable and suitable site for residential development.

3.6 It is suggested that the provision for increasing the range of sites modestly to include smaller and medium sites in the rural area would provide significant benefits. For example, they could be delivered more quickly without requiring additional infrastructure, provide choice and flexibility in the housing market and secure affordable housing more immediately. This is a point recognised by the Inspector that examined the 2018 Local Plan for South Cambridgeshire as referenced within paragraph 31 of the report: “In order to arrive at a sound strategy, we consider that as a primary consideration, the Council would need to allocate more small and medium sized sites that could deliver homes in the short to medium term and help to bolster the 5-year HLS, until the Garden Communities begin to deliver housing. This would have the benefit of providing flexibility and choice in the market and the earlier provision of more affordable housing” (paragraph 114).

4. QUESTION: We feel that we should support the development of the Cambridge Biomedical Campus, with space for more healthcare facilities, research and housing. What housing, facilities or open spaces should be created around the campus?

4.1 We strongly agree that supporting the development and further expansion of Cambridge Biomedical Campus should be one of the key principles of the new Local Plan. To support this objective, it is imperative therefore that a proportion of new housing growth is located along sustainable transport corridors from the Biomedical Campus, to support the objective of the Local Plan outlined above (in section 3 of this statement), which seeks to minimise car travel.

4.2 It is also very important that the emerging Local Plan 2041 aligns housing and employment growth, with major transport schemes that are being promoted in and around Cambridge. The First Proposals provide a number of references to East-West Rail and the provision for Cambridge South Station, both of which are important new transport infrastructure projects. However, additional focus needs to be given the major infrastructure projects being promoted by the Greater Cambridge Partnership. Of particularly relevance to the Biomedical Campus expansion, is the Cambridge South East Rapid Transit Route (CSET), which is proposed to provide a rapid transit route from the Biomedical Campus to the market town of Haverhill, the majority of which will be provided as an off-road bus way route. It is considered important that substantial housing growth is provided to the south east of Cambridge along this rapid transit route, to ensure ease of access to the Biomedical Campus by sustainable transport means.

4.3 It is understood that the CSET Project has progressed significantly since the Issues and Options Consultation in 2020. It is understood that the Greater Cambridge Partnership are intending to submit a Transport for Works Order in early 2022. It is also an identified route within the current Local Transport Plan.

4.4 Linton is one of the largest settlements with South Cambridgeshire that will be served by the CSET route. Therefore, growth in this settlement would be consistent with one of the key objectives of the Local Plan, which seeks to minimise car travel by focusing growth on locations with good transport infrastructure. Linton is situated outside of the Green Belt and therefore it is considered that Linton should be the focus for growth ahead of settlements that lie within this designation such as Sawston.

5. QUESTION: What housing, jobs, facilities or open spaces do you think should be provided in and around these villages?

5.1 It is important that a range of housing, jobs and facilities are provided within larger villages as part of new allocations to allow them to thrive and remain vibrant. Countryside Properties are responsible for the promotion of land to the north-west of Balsham Road, Linton and have a track record of delivering high quality housing developments, which provide a mix of dwellings and tenures to meet objectively assessed housing needs. Countryside Properties are fully committed, to engagement with the Greater Cambridge Shared Planning Service and Linton Parish Council regarding the mix and type of housing to be delivered on land to the north-west of Balsham Road. The proposals also include the provision for the delivery of a substantial area of public open space with associated landscaping and Countryside Properties are flexible on the proposed use of this open space.

5.2 The submission of the site, also includes the provision for a Rural Business Centre of up to 1 hectare in size. This Rural Business Centre has the ability to ensure that jobs are provided within the application site and to support smaller start-up businesses within the local area. This further strengthens the sustainability case for development of this site.

5.3 It should however be noted that Linton is strategically well located to provide housing growth in close proximity to large employment generators and jobs such as the Genome Campus, Granta Park, Haverhill, the Biomedical Campus as demonstrated by the attached accessibility plan, prepared by Richard Jackson Partnership, that is provided within Appendix D.

6. QUESTION: Are there any sites which you think should be developed for housing or business use, which we haven’t got on our map so far?

6.1 Yes, land to the north-west of Balsham Road, Linton should be allocated for development and would be a sound allocation as part of the emerging Local Plan being brought forward by a housebuilder that has a good track record for delivery. Countryside is a leading national housebuilder and has established a strong reputation for delivering high-quality mixed-tenure housing developments and award-winning places to live and are committed to delivering a landscape led development at Balsham Road, Linton.

6.2 The land to the north-west of Balsham Road, Linton is being promoted for a residential-led mixed use development which comprises an employment area. The proposals consist of up to 300 dwellings and a rural business centre of up to 1 hectare in size.

6.3 Having reviewed the settlement morphology, the area of proposed built form is now concentrated away from the northern boundary, thereby extending the village in such a way that respects the more sensitive landscape views in the northern part of the site.

6.4 The proposed development is focussed towards the south of the site which is the least visible from the surrounding landscape, and will comprise of up to 300 dwellings. To the east the site is well screened by the existing scrap yard and structural vegetation.

6.5 Medium to long distant views are available of only the northern parts of the site and as such these areas are proposed as open green space, in order to protect the character of the rolling Chalkland, as well as views of the listed Rivey Hill Water Tower, as a prominent feature on the horizon above Linton, as seen from the landscape to the south, which is identified in the Greater Cambridge Landscape Character Assessment.

6.6 The opportunity and constraints plan also allows provision for clear views to the water tower, along green corridors within the site. This will also help protect views of the water tower to the north. The aim of integrating the settlement with the rural landscape is also furthered by the inclusion of lower density housing towards the northern parts of the area proposed for development, forming an outward-facing, transitional porous settlement edge.

6.7 Structural vegetation is proposed along the western extents of the southern boundary, in order to provide a buffer between the proposed development and the existing housing to the south, as well as the western boundary in order to reinforce and strengthen the existing vegetated buffer to the bridleway. Further structural vegetation is proposed along the northern boundary, following the natural contours of the land form in order to soften the artificially straight line of the hedgerow that cuts across the landscape. Belts of structural 10 vegetation running broadly east/west more centrally within the site similarly follow the existing contours in order to soften the proposed development and integrate it within the surrounding rural landscape - see The Landscape and Visual Opportunities and Constraints plan (LN-LP-04 Rev A).

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 (that is needed to meet the objective of doubling GVA by 2040) and address the significant housing affordability issues that exist (Cambridgeshire and Peterborough Independent Economic Review). At present there is an imbalance between rates of economic growth and housing delivery in Greater Cambridge.
Countryside are disappointed that the authorities have not taken the opportunity to plan more positively to meet the full need for housing. The evidence base clearly confirms that Greater Cambridge will continue to experience a significant demand and need for new housing, reflecting the strength of the local economy and the scale of investment being made by the Government to support and facilitate even more ambitious levels of growth in recognition of this area’s national importance as an engine for economic growth.
In proposing to plan for 48,840 homes over the period from 2020 to 2041, the authorities are currently assuming a need for only 44,800 homes, or 2,114 homes per annum. Whilst such a level of need exceeds that calculated using the standard method, it is clear from the supporting evidence base that it directly relates to an economic forecast – under which circa 58,500 new jobs could be created over the plan period – that is described as ‘business as usual’, ‘taking into account long term patterns of employment’. As we explain in our response, such an approach sits fundamentally at odds with the Government’s ambitions and expectations of this area. It also implies a retraction from more recent evidence of stronger job growth that has been sustained, reflecting in no small part the success of significant investment in infrastructure which is set to continue and indeed increase over the plan period.
In this context, it is of note that the evidence base itself acknowledges the potential for Greater Cambridge to see a ‘higher-growth scenario’ in which more jobs are created, and actually concludes that this should be used to ensure a positive plan-led approach to providing employment floorspace. This scenario is predicated on more positive expectations around the continued growth of identified priority sectors, and assumes that this could lead to the creation of some 78,700 jobs over the plan period. The evidence base concludes that approximately 56,500 homes, or 2,690 homes per annum, could be needed to sustainably support such growth.
Countryside consider that this should be recognised in the GCLP as a minimum level of housing provision, with the reasoning for this conclusion set out in more detail below. In providing for the appropriate housing land response, Countryside would also strongly encourage the authorities to reconsider the length of the proposed plan period, particularly given that the Oxfordshire Growth Plan – also recently subject to a process of consultation – looks to 2050 and Milton Keynes similarly has a “Strategy for 2050”, which indicates (in high-level terms) the ambitions for growth to that point and is set to be supported by an emerging review of the Local Plan. Given the benefit of consistent timeframes in these key parts of the Oxford Cambridge Arc (‘the Arc’) Countryside believe the GCLP should similarly look to 2050, which would necessitate a larger supply of land assuming a sustained need for 2,690 homes per annum, with this equating to a total need for 80,700 homes over a thirty year plan period.
In addition, in light of the requirements of paragraph 22 of the NPPF and the Council’s inclusion of significant extensions to existing villages and towns as part of its current proposed spatial strategy, the plan period should again be extended to a period of 30 years (2020-2050). Additional allocations will therefore be necessary in order to accommodate the additional needs over this extended plan period.
Justifying a higher level of housing need
We commend the authorities on the assembly of a detailed evidence base, which appears to demonstrate compliance with Planning Practice Guidance (PPG) and importantly looks in detail at the crucial relationship between job creation and housing need. It is right to identify that whilst the standard method provides an important starting point, there are still circumstances – established within the PPG – when a higher level of housing need may exist. This confirmation of a potentially higher need, beyond the level implied by the standard method, is therefore fully supported. Indeed, to do otherwise – by aligning with the outcome of the method and planning for a level of need that is inextricably linked to trend-based demographic projections – would fundamentally fail to recognise, as the evidence base acknowledges, the Government’s commitment to continuing sustainable economic growth in Greater Cambridge. This follows the Government’s award of the Cambridgeshire and Peterborough Devolution Deal 2017 and its commitment to the Arc, the spatial framework for which – once prepared – must be adhered to by the CGLP given it will have the same status as national policy.
An area of national economic significance – a Plan for Growth
The National Infrastructure Commission (NIC) presented to the Government a compelling rationale for recognising the Arc as a national priority in its influential report of 2017, titled ‘Partnering for Prosperity’, which advocated a ‘New Deal for the Cambridge-Milton Keynes-Oxford Arc’.
The Government reaffirmed its commitment to the Arc through last year’s Spending Review, identifying additional funding to support its promise to develop a spatial framework that plans for long-term economic and housing growth throughout the area. Reference to this commitment was equally made within the National Infrastructure Strategy, which also generally emphasised – in the context of cities, like Cambridge – a view that they are:
“…the anchors of successful regions across the world; they are engines of growth. To drive economic growth across all regions of the UK, the government is investing in growth in cities”
The spatial significance of Cambridge – and indeed the Greater Cambridge area to be covered by the GCLP – is clear in the spatial context plan included in the First Proposals Consultation Document, which shows it located not only within the Arc but also the UK Innovation Corridor and the Cambridge-Norwich Tech Corridor.
It is evident that Cambridge plays a significant part of the Government’s national economic ambition. The unique economic proposition of the Arc is reflected in its Economic Prospectus, published in Autumn 2020, which set an ambition that:
“By 2050, the Arc will be the world leading place for high-value growth, innovation and productivity. A global hub where ideas and companies are generated and thrive, home to exemplary models of 21st century development, with a high-quality environment and outstanding quality of live, and with a strong economic focus that drives inclusive clean growth” (emphasis added)
In the context of its acknowledged national significance, the Government is playing a leading role in directing its ambition for the growth of the Arc, with the intention of publishing a spatial framework that covers the entire area. To this end, the Government published an ‘Introduction to the Spatial Framework’ in February 2021.
This document, in justifying both the Government’s involvement in planning for the future of the Arc and its designation as a national economic priority, acknowledged that:
“Forecasts vary, but successive studies have found that there is a clear transformational opportunity”
It proceeds to suggest that, ‘with the right interventions and investment’, the Arc could create as many as 1.1 million extra jobs by 2050. It continues in this context to state that:
“The Arc’s success is key to the UK’s national prosperity, international competitiveness, and ability to meet the challenges and opportunities we will face as a country over the next century”
The Government identifies housing provision as one of three areas of particular concern. It observes, in the context of housing affordability being poor, that:
“The wider economic effect of this is to make it harder for businesses to attract the skilled workers they need, to locate in the most productive locations, and is forcing longer and more polluting journeys as people travel longer distances to get to work”
In this context, the report confirms the Government’s commitment to planning for the right level of growth in the Arc through the accelerated delivery of a robust, evidence based spatial framework over a period of only 30 months.
The implicit recognition of a need for progress by the Government was reflected in its publication of a consultation document in July 2021 titled ‘Creating a Vision for the Oxford-Cambridge Arc’. This evidently predated the current consultation on the GCLP.
It is clear from this latest document that, in establishing a ‘vision’, the Government expects the Arc to be ‘ambitious and aspirational’, with it emphasising the importance of looking at ‘potential opportunities for transformation’. With reference to both the planned level of job growth and the aligned proposed housing provision, Countryside consider that the Greater Cambridge authorities have so far failed to align with and take adequate account of this national ambition. This creates an unjustified inconsistency with the emerging strategic vision for the Arc, thereby undermining its potential to be realised and failing to represent a positive planning approach.
Investment in strategic infrastructure
The PPG is clear that investment in strategic infrastructure improvements, which are likely to drive an increase in the homes needed in an area, can justify a higher level of housing need than implied by the standard method.
The Government’s support of the Arc and its component authorities has gone beyond a commitment to assisting in creating policy and strategy. As far back as 2014 the Government signed a City Deal with the Greater Cambridge authorities, with this bringing up to £500m of funding over a fifteen year period towards transport and infrastructure projects managed by the Greater Cambridge Partnership. It is understood that much of this investment is underway and delivering strategic improvements to the area’s infrastructure.
The First Proposals Consultation Document includes a map of the existing and proposed major transport projects which are supporting the growth of Greater Cambridge, and are intended to keep doing so.
The Consultation Document itself recognises the role of investment in facilitating growth, noting for example the importance of the committed funding for the new Cambridge South Railway Station in facilitating the further growth of the Cambridge Biomedical Campus and the importance of investment to date in the development of the Babraham Research Campus.
This investment also reflects the Government’s awarding of circa £150m of Local Growth Funds in 2015 to the Cambridgeshire and Peterborough Combined Authority, all of which is understood to have been assigned to specific projects that have to date leveraged further funding of in the order of £328m. These projects are estimated to have already collectively generated some 6,500 jobs, with over 40,000 jobs forecast to be created in total. Projects in receipt of monies in Greater Cambridge include:
• West Cambs Innovation Park
• NIAB – AgriTech Start Up Incubator
• Hauxton House Incubation Centre
• TTP Life Sciences Incubator
• Illumnia Genomics Accelerator
• Medtech Accelerator
The 2016 designation of the Cambridge Compass Enterprise Zone, which comprises of five employment sites, also represents another commitment by the Government to the area and will continue to create further employment-generating opportunities. As set out above, the Government’s continued commitment to the Arc suggests that further monies will be directed at the area to build on these existing significant investments, such that it is reasonable to expect continued above-trend job creation and contributions to the national economy.
A history of economic success and forecasting growth
The investment noted above, both by the public sector and also by private companies – including internationally renowned businesses like AstraZeneca for example – has been matched by the generation of economic opportunities. Indeed, Cambridge’s economic prominence and success is acknowledged in the First Proposals Consultation Document, which cites recent research by the Centre for Cities in describing Cambridge as ‘one of the most important research and innovation-led hubs in the UK’.
The recent success of Greater Cambridge in creating new jobs is therefore undeniable, as is the pace of this growth. The Employment Land and Economic Needs Study (ELENS) uses data from Cambridge Econometrics to estimate that some 35,800 jobs were created throughout Greater Cambridge between 2011 and 2017, equivalent to almost 6,000 jobs per annum. Even when acknowledging uncertainties associated with the accuracy of historic job figures – which lead different datasets to suggest that job growth in this period may have ranged from 25,588 to 40,160 jobs – it is clear that the area has seen substantial and rapid job growth over this period.
The Business Register and Employment Survey (BRES) now provides an indication of job growth in three more recent years, which can be used to build on the analysis in the ELENS. Figure 2.3 shows how, according to this dataset, Greater Cambridge has sustained and indeed increased the rate at which new jobs have been generated across the area. It suggests that some 20,700 jobs were created between 2017 and 2020, its use of a mid-September reference point meaning that it technically captures the first six months of the COVID-19 pandemic. Taking an average over this period would suggest growth of almost 6,900 jobs per annum, indicating that job growth has been broadly sustained since 2017 rather than having peaked at that point, as the ELENS prematurely suggested.
Historic performance in the creation of new jobs an important context in the forecasting of future trends, albeit in Cambridgeshire there is notably a history of so-called “off the shelf” baseline forecasts underestimating the job growth that actually occurs, acknowledged first in the Cambridgeshire and Peterborough Independent Economic Review (CPIER) but also more recently in the ELENS.
It is acknowledged that the Councils’ evidence base at least attempts to account for this issue, with the ELENS confirming in its consideration of historic job growth data and forecasts that there are ‘questions about relying too heavily on an econometric model which constrains local potential within parameters which are defined regionally’.
The ELENS proceeds to develop alternative scenarios which build from the baseline forecasts and apply judgements to better reflect historic growth rates in a number of key industrial sectors, which are understood to include:
• Health and care;
• Computer related;
• Research and development (R&D); and
• Professional services.
The approach taken in the analysis of variant forecasts is not directly challenged by Countryside, given that these sectors are generally those which are both anticipated to remain the focus of investment and have locally experienced growth in recent years. It is separately noted also that the subsequent impact of the pandemic would appear to lend further support to the potential growth of health and care in the region, given the specific link to life sciences in Greater Cambridge, as well as related professional services and R&D.
This is borne out when looking at the ten sectors that have created the most jobs since 2017, illustrated at Figure 2.4.
The education sector has evidently played a significant role in creating new jobs, with further analysis revealing that this is largely attributable to “First-degree level higher education” and therefore suggesting that this reflects an increase in jobs related to the area’s universities. Separate to this, it is noted that strong growth has also been recorded in the professional, scientific and technical sector, information and communication and health over this period. This affirms the sustained ability of these key sectors to contribute significant growth, with no evidence that their capacity to grow has been curtailed. Indeed, it suggests in contrast that their growth is on course to remain at the higher rates seen over more recent years.
The evidence of sustained growth – most notably in these sectors but also across the economy as a whole – does, however, challenge the notion of a regression to longer term and lower growth trends, which is implicit in the central scenario presented in the Councils’ evidence base and seemingly favoured as a job target in the First Proposals Consultation Document. In contrast, it is observed in the ELENS itself that the ‘higher growth’ scenario ‘sits broadly in the middle of the longer term historic (1991 or 2001 – 2017) and recent historic (2011 – 17) absolute change’. In the context of the evidence of growth noted above, even this scenario could be viewed as being unjustifiably modest, but it does at least have the advantage of more closely reflecting the proven strength of the local economy.
The analysis of forecasts did also identify a scenario which suggested a still higher level of job growth, by allowing for the continuation of job growth rates recorded between 2011 and 2017. This identified the potential for more than 120,000 new jobs throughout Greater Cambridge over the plan period. Such a level of job growth is dismissed as unreasonable, but it nonetheless serves to highlight that even the so called “higher growth” forecast scenario could be exceeded.
It is pertinent to note, in the context of the above, that the First Proposals Consultation Document confirms – with reference to the ELENS – that the Councils are ‘mindful that the Study also identified a higher job growth forecast’, noting specifically in this regard the conclusion that the GCLP provide ‘flexibility in employment land in case the market delivers more jobs than anticipated’. This responds to a clear conclusion of the ELENS itself, which recommends 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’. In justifying this conclusion, it confirms that this takes account of the fact that it ‘broadly aligns with completions trends and market feedback’.
This conclusion was presumably taken into account by the Councils in proposing their more flexible approach to providing for employment floorspace. Where the evidence suggests the target of 58,500 new jobs would translate into a need for circa 416,400sqm, the First Proposals Consultation Document identifies an existing pipeline supply of 624,310 sqm of employment floorspace, as of 2019, which aligns more closely with the level of floorspace calculated as being required to support the higher growth scenario (541,655sqm). The Consultation Document suggests that a proportion of this space is expected to build out beyond the plan period but even allowing for that it is the case that the Councils currently intend to be supportive of further increases to this pipeline, with Policy J/NE confirming that ‘proposals for new employment development will be considered on their merits’. Where the provision of new employment floorspace and investment in new facilities has evidently played an important role in supporting the high levels of employment growth achieved over recent years, there is every reason to believe on this basis that the circumstances will be in place and supported to allow this to continue over the plan period.
A reasonable forecast of economic growth and balancing housing needs
The Councils’ Strategy Topic Paper appears to recognise the strength of the Greater Cambridge economy, reflecting on the findings of the CPIER and in turn acknowledging that this ‘supports the argument for exploring the relationship between economic growth, future employment and the number of new homes to plan for’.
Critically, however, in arriving at its proposed approach to planning for new jobs and homes, the Councils observe with reference to the higher growth scenario that it is ‘considered possible but not the most likely’. Countryside strongly believe, in the context of the above – which draws on the Councils’ own evidence and reflects the Government’s national position – that this position is wholly unsubstantiated.
A more reasonable and positive interpretation of the evidence available, accounting for the Government’s clearly stated ambitions for the Arc of which Greater Cambridge is part, is that the GCLP must provide for and support a higher level of future job growth. As a minimum, the level of job growth associated with the so-called “higher” scenario would be more representative of the assessed economic potential of this area, where it:
• More closely reflects continuing evidence of stronger historic job growth, including in the key sectors that have been consistently identified as local drivers of growth in the published evidence base;
• Shows a greater alignment with the ambition which continues to be articulated by Government, which expects above-trend growth within its designated nationally significant growth corridors; and
• More closely aligns with the emerging approach of providing the employment land that will accommodate new business investment and growth, noting specifically the indication in the evidence base that the stronger associated growth aligns more closely with the market.
Based on the Councils’ published evidence, where alignment is sought with the higher of the job growth scenarios, the GCLP must make provision for 2,690 homes per annum or approximately 56,500 homes if the plan period to 2041 is retained. As referenced at the start of our response to this policy, however, Countryside are of the view that in order to demonstrate consistency with the emerging plans for Oxfordshire and Milton Keynes a plan period of 30 years out to 2050 should be used. This would necessitate a larger supply of land, assuming a sustained need for 2,690 homes per annum, with this equating to a total need for 80,700 homes over a thirty year plan period.
As we consider below, a failure to plan positively for housing provision in the context of sustained job growth over this period would continue to have adverse consequences for the population of Greater Cambridge.
The consequences of failing to positively plan for growth
The First Proposals Consultation Document is clear to acknowledge that to date the plan-led system in Greater Cambridge has not managed to enable a sustainable balance between jobs and homes, observing that:
“Over recent years, jobs have been created faster than new homes have been built, and this has contributed to higher house prices and increased commuting into the area”
It also notably concedes that there would be adverse consequences if the GCLP fails to provide the homes that are needed in future, stating with reference to the lower level of need implied as a minimum by the standard method that such a level of housing provision ‘would risk increasing the amount of longer distance commuting into Greater Cambridge, with the resulting impacts on climate change and congestion’.
Such a position was also articulated by the CPIER in its diagnosis of the consequences of failing to plan positively for growth in Cambridge, stating that:
“If nothing is done, the damage to society from the continuing drift away of less well paid workers may become irreparable, the ageing of the city (whose housing ladder’s bottom rung is out of reach of the vast majority of the young) will threaten its dynamism, and the cost to people’s mental health of commuting-induced stress and housing insecurity will soar”
Positively, the vision expressed in the First Proposals Consultation Document indicates that the Councils aspire to improve the sustainability of Greater Cambridge, which they ‘want…to be a place where a big decrease in our climate impacts comes with a big increase in the quality of everyday life for all our communities’.
In this context, and putting aside the scale of job growth planned for, the Councils’ apparent aim of ensuring that Greater Cambridge better balances job growth and housing provision by “consuming its own smoke” is supported. The assumption of a commuting rate to this effect is, as the Councils confirm, ‘consistent with the local plan theme of net zero carbon’ and also overcomes the lack of ‘certainty that neighbouring authorities would plan for the additional homes in their local plans in order to support the economy in Greater Cambridge’.
This is further reinforced, the Councils confirm, in the transport evidence and with reference to the developed transport model which notably suggests that
“…the approach of providing more homes could help reduce longer distance commuting, which could help limit carbon emissions, and explicitly highlight that if the number of jobs in an area increases faster than the development of homes for the population to service those jobs, then travel distances to access these jobs will increase, and the longer trips that this entails will most often by undertaken by car, leading to large increases in travel distance by car compared to more balanced strategies”
Even this ostensibly ‘balanced approach’ to commuting could, however, lead to adverse and unsustainable outcomes if the Councils do not accept and plan for the likelihood of a stronger level of job growth.
Similarly, underestimating potential job growth and therefore housing need will continue to exacerbate what are already acute affordability challenges facing many households. The CPIER highlighted even in 2018 that:
“Housing affordability pressures are one of the main threats to growth in Cambridgeshire and Peterborough, and one of the main burdens on people’s lives. Demand for housing has risen strongly, while supply, though increasing, has not been able to keep pace”
The serious consequences of acute affordability issues are explained in the Councils’ evidence base. The addendum to the study of housing need, for example, confirms that under each of the previously introduced jobs-led scenarios there is expected to be a net need for between 1,093 and 1,246 affordable homes for rent per annum across Greater Cambridge. This evidently represents a significant need when set against the overall need for housing across all tenures, and there is again clearly an imperative on ensuring that the supply of homes will positively address rather than worsen affordability for those households on lower incomes.
The acknowledged serious consequences associated with failing to better align jobs and homes provides a further compelling justification for the GCLP to more positively anticipate a stronger level of job growth and ensure the provision of the homes required to support it.