Draft Greater Cambridge Local Plan for consultation

Search representations

Results for SmithsonHill search

New search New search

Object

Draft Greater Cambridge Local Plan for consultation

Policy S/JH: New jobs and homes

Representation ID: 211664

Received: 30/01/2026

Respondent: SmithsonHill

Agent: Lichfields

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

Within the supporting text (para 2.10) the draft GCLP states “for jobs, the [EHNU] central forecast assumes strong growth of around 4,000 additional jobs per annum ... We consider that we should plan for this forecast of the most likely level of new jobs”.

This statement is not reflective of the EHNU, which clearly shows (Table 3.7) the ‘central’ scenario being associated with 3,490 jobs per year. In fact, a figure of 4,000 jobs per year is actually closer to the ‘high’ scenario, which Table 3.7 of the EHNU shows is 4,330 jobs per year. The assertion that the policy is planning on the basis of around 4,000 jobs per year is therefore not in accordance with the GCLP’s own evidence (were it to be accepted on its own terms) and is misleading. Over a 21-year plan period the
difference between the number of jobs indicated by the ‘central’ scenario (3,490 per year) and those asserted in the GCLP (4,000 per year) is nearly 11,000 jobs.

The draft GCLP is therefore not currently sound because it does not reflect its own evidence, as required by NPPF para 36(b).

Object

Draft Greater Cambridge Local Plan for consultation

SA

Representation ID: 211665

Received: 30/01/2026

Respondent: SmithsonHill

Agent: Lichfields

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

The Sustainability Appraisal of the draft GCLP (October 2025) sets out the background to the reasonable alternatives that have been considered for the overall quantum of housing and job growth underpinning Policy S/JH, including the rationale (this is separate to the reasonable alternatives that are tested for the spatial distribution of growth, which are set out earlier in the SA in Chapter 4). Within the SA (p.178) GCSP set out that draft Policy S/JH is the preferred option in terms of overall growth quantum because it meets the minimum standard method and the ‘most likely’ job growth scenario.

The assertion that the higher jobs forecast is not ‘reasonable’ is not consistent with the EHNU and other evidence of economic growth potential set out previously. Furthermore, excluding it on the basis that it is ‘not the most likely scenario’ does not withstand basic scrutiny; applying this logic, any SA would only test one scenario - the most likely - which is clearly not the purpose of SA.

Given the ‘high’ job growth is only c.25% above the ‘central’ (which can be considered a baseline level of job
growth, since it would arise based on the minimum amount of housing that must be provided in any event), it is clear that the ‘high’ job growth scenario represents a reasonable alternative that should have been tested through the SA.

Object

Draft Greater Cambridge Local Plan for consultation

SA

Representation ID: 211666

Received: 30/01/2026

Respondent: SmithsonHill

Agent: Lichfields

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

The [2011] Census shows that for people commuting into Greater Cambridge from elsewhere, the vast majority – nearly 80% - travel by car (this actually rises to 84%
when people who travel as passengers are included). Although the completion of East-West Rail might be expected to achieve some shift in commuting patterns, this will only occur insofar as (1) housing development outside Greater Cambridge is focused on areas where
EWR stations are proposed, and (2) those people travel to employment opportunities in Greater Cambridge that are accessible via EWR stations.

It should be noted that East-West Rail would be unlikely to impact the Rural Southern Cluster, where the Site is located, due to the areas it serves. The same two points are true for other transport initiatives, such as the Cambridge South East Trasport (CSET) programme.

On this basis EWR (and other initiatives) are still fundamentally unlikely to shift the balance of in-commuting into Greater Cambridge away from the private car being the predominant mode of transport. This is especially true for employment centres (such as research campuses) that are spread across the rural part of South Cambridgeshire. A strategy in which employment growth in Greater Cambridge is not matched by commensurate housing growth within the area will therefore almost certainly result in an increase in in-commuting to Greater Cambridge, the majority of which will be by private
car, with knock-on impacts on traffic/congestion, air quality, climate change and overall quality of life.

For these reasons, we also dispute the finding of the SA regarding the overall development strategy in Policy S/JH, which states “the housing target is supported by a substantial level of job growth in the area, which is likely to help support self-containment and minimising long distance commuting, as Greater Cambridge residents will be able to benefit from nearby employment opportunities” (SA para 5.30). The substantially higher levels of job growth likely to be generated by the draft GCLP will clearly not result in self-containment given they are not matched by an equivalent level of housing, as set out above.

Object

Draft Greater Cambridge Local Plan for consultation

Policy S/JH: New jobs and homes

Representation ID: 211667

Received: 30/01/2026

Respondent: SmithsonHill

Agent: Lichfields

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

A lack of housing relative to demand (driven by employment growth) is likely to contribute to a further worsening of housing affordability (both for housing to buy and to rent), making it difficult for lower wage workers in particular to access housing close to near where they work. Further worsening of affordability could result in business and public services that rely on lower paid workers struggling to recruit and retain workers. This would also result in a knock-on impact on the demand for affordable housing, which would increase as fewer people are able to meet their needs in the private market.

A shortage of labour supply generally could in turn undermine local businesses and services and their ability to recruit and retain workers. Across all income levels, the immobility of workers undermines agglomeration benefits and could lead to reduced competition between businesses, stifling economic growth. Businesses may choose to locate elsewhere, either within the UK or internationally which would undermine Greater Cambridge’s (and the wider Arc’s) position as the potential global leader in education, life sciences, technology and other sectors. Stifling economic growth in Cambridgeshire in this way would also certainly undermine wider regional and national economic growth prospects.

Object

Draft Greater Cambridge Local Plan for consultation

Policy S/JH: New jobs and homes

Representation ID: 211668

Received: 30/01/2026

Respondent: SmithsonHill

Agent: Lichfields

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

We disagree with the ENHU that the ‘high’ growth scenario (which sees job growth around 25% above the ‘central’ job growth scenario [which aligns with the standard method]) represents a ‘step change’ in economic circumstances. To the contrary, it represents a relatively modest increase on the level of job growth that is likely to occur by planning for the minimum amount of housing. The Mayor’s plan discusses scenarios which could see the local economy double or even triple in size, far exceeding past trends or any scenario tested in the EHNU, and such scenarios should be explored within the evidence base (EHNU and SA).

Comment

Draft Greater Cambridge Local Plan for consultation

Appendix E: Housing trajectory and five year housing land supply calculation

Representation ID: 211669

Received: 30/01/2026

Respondent: SmithsonHill

Agent: Lichfields

Representation Summary:

The trajectory presents only a modest 6.5% buffer (excluding North East Cambridge) against the minimum requirement of 48,195 dwellings aligned with the standard method.

In general, we wish to highlight the overreliance that the trajectory places on recent policy changes (rather than evidence) when asserting that there is no need to revise delivery assumptions made in the Council’s initial 2021 Housing Delivery Study (‘the 2021 study’).

Object

Draft Greater Cambridge Local Plan for consultation

Appendix E: Housing trajectory and five year housing land supply calculation

Representation ID: 211670

Received: 30/01/2026

Respondent: SmithsonHill

Agent: Lichfields

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

The trajectory highlights the widespread issue around stalled sites and delayed phases nationally which leads to the under delivery of housing. It also highlights the current
difficulties associated with affordable housing delivery in England, related in a large part to uncontracted units causing developer uncertainty and financial exposure. In spite of this, the trajectory asserts at para 2.40 that there is no need to revise delivery assumptions in the 2021 study, despite noting the increasingly unreliable levels of affordable housing delivery, and the effect that this has on the sites coming forward. We disagree with this conclusion.

Crucially, the trajectory fails to acknowledge the role of viability in the ability of sites to come forward, whether that is once planning permission is granted or before (in S106
discussions). It appears to follow a truism that meeting high housing demand in Cambridge will be supported by the delivery of a high proportion of affordable housing versus market housing. However, sites which do not yet have planning permission are now required to meet a range of policy requirements introduced since the original 2021 trajectory was released (such as BNG). They may also be subject to high infrastructure costs associated
with certain schemes.

Object

Draft Greater Cambridge Local Plan for consultation

Appendix E: Housing trajectory and five year housing land supply calculation

Representation ID: 211671

Received: 30/01/2026

Respondent: SmithsonHill

Agent: Lichfields

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

The trajectory fails to take account of the slowdown in market absorption due to the affordability challenges which, since 2022 and the abolition of Help to Buy, have had no Government solution in terms of first-time buyer support. This is widely recognised across the sector as slowing the pace of build out of market homes on sites compared to what might have been expected in the period that is captured in the evidence base. This is particularly acute in the areas with the highest values (i.e. least affordable). Therefore, perhaps counter intuitively, the areas with the highest levels of value and past experience of strong demand (such as London, but which would include Cambridge), are now seeing reduced rates of build out. The issue explains why there have been reduced real-world demand for particular property types in Cambridge over recent years – notably apartments on some sites. This is something Hill has observed in its other projects in Cambridge (and elsewhere).

Comment

Draft Greater Cambridge Local Plan for consultation

Policy S/JH: New jobs and homes

Representation ID: 211672

Received: 30/01/2026

Respondent: SmithsonHill

Agent: Lichfields

Representation Summary:

The draft GCLP relies on larger schemes for development, but delivery of such sites is inherently more complicated to bring forward, especially where there are significant infrastructure requirements and multiple landowners.

If any existing commitments become stalled or lapse (for example if there are changes to site capacity, changes in deliverability of sites, competition in the market, changing demand for other uses, etc), this situation will only worsen.

In this context, we recommend:
1) 15% should be the minimum buffer if North East Cambridge is not included, and the current growth assumptions are taken forward. This would require an uplift of at least 4,096 homes within the proposed plan period which are not currently allocated;

2) 20% should be the minimum buffer if North East Cambridge is included, to allow for potential manifestation of recognised difficulties associated with the delivery of this Site. This would require an uplift of at least 2,445 currently unallocated homes within the proposed plan period.

Object

Draft Greater Cambridge Local Plan for consultation

Appendix E: Housing trajectory and five year housing land supply calculation

Representation ID: 211673

Received: 30/01/2026

Respondent: SmithsonHill

Agent: Lichfields

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

The trajectory asserts at para 2.103 to 2.106 that in spite of recent downward delivery trends on windfall sites, it has not been necessary to revise the assumptions in the 2021
study. In so doing, it states that recent changes to policy are likely to lead to a restored level of windfall delivery. However, this is not justified by compelling evidence and therefore falls short of Paragraph 75 of the NPPF.

For instructions on how to use the system and make comments, please see our help guide.