Greater Cambridge Local Plan: Proposed Submission

In order to overcome the issues highlighted in this representation and progress a sound Local Plan, it will
be necessary to utilise more optimistic and realistic figures for job and housing numbers and include
explicit support for higher-growth scenarios. Without these changes, Policy S/JH risks being unsound
and inconsistent with national policy objectives to support sustainable economic growth and productivity

Jesus College object to Policy S/JH. The policy is unsound as it is not positively prepared, not justified,
not effective and inconsistent with national policy.

In terms of the policy context, paragraph 69 of the NPPF (2024) is clear that Authorities need to plan for
higher levels of growth than the Standard Method requirement to reflect growth ambitions linked to
economic development and infrastructure investment. Furthermore, paragraph 86(d) of the NPPF (2024)
confirms that planning policies should seek to address potential barriers to investment, such as
inadequate infrastructure, services or housing, or a poor environment. The draft Plan does not do this.
This need for growth is evidenced by national, regional and authority level investment in infrastructure
including the new Cambridge South Railway Station providing direct connectivity between Cambridge Biomedical Campus (CBC) and London, the granting of the Cambourne to Cambridge busway and
progression of Cambridge South East Transport (CSET) to inquiry later this year. In a national context,
the commitment to East West Rail establishes the area as one benefiting from continued investment in
major transport infrastructure. Growth envisioned by Government is set to be realised and delivered by
the Greater Cambridge Development Corporation set to deliver infrastructure first growth. We contend in
order to ensure the Plan is found sound the unique nature of Cambridge and its projected capacity for
growth must be realised within the emerging Local Plan.

The fact that the GCLP is not planning for the level of growth necessary to support the economic
ambitions of the Local Growth Plan, which align with the economic objectives of the government is
underlined by the fact that the Employment and Housing Needs Update (EHNU) (2026) does not even
consider the Oxford Cambridge Arc or the Local Growth Plan. Instead, it has been developed on the
basis of standard economic forecasts which are inevitably trend-based and so do not account for
economic potential of the area as is necessary to align with local and national economic ambitions. The
EHNU draws its conclusions and jobs and housing needs from the ‘central growth’ scenario with the
‘higher growth scenario’ dismissed. However, it is noted the EHNU notes that the higher scenario could
be achieved with step change in investment.

Rightly the EHNU draws a relationship between job growth and housing need, on the basis that greater
job growth in the region will generate a derived demand for housing, creating an interdependency
between the two. The ‘central growth scenario,’ as outlined within the EHNU, builds in assumptions of
slower periods of growth, contractions, and economic shocks. Inherently both the number of jobs and
homes proposed within the Proposed Submission Plan are conservative rather than reflective of the full
growth potential of the Greater Cambridge economy.

With the advent of the Greater Cambridge Development Corporation (backed by £400 million of central
government funding) and renewed commitment to delivery of growth in the Oxford – Cambridge Growth
Corridor there is clear rationale for the Authority to reasonably adopt the high growth scenario.
Furthermore whilst the Authority have met their identified needs for housing via the Standard Method it is
acknowledged the Standard Method does not take into account the specific growth agenda and focus on
Cambridge as an area of ‘supercharged growth’.

It is evident that committed and future infrastructure projects in Greater Cambridge continue to confirm
Cambridge’s position as an area capable of supporting and delivering high growth. Within this context
Cambridge remains a priority of the incumbent Labour government to deliver ‘supercharged growth’. The
Employment and Housing Needs Update acknowledges a ‘High’ and ‘High Sensitivity’ scenario, whereby
growth would meet or exceed the 2010–2020 trajectory. This high level of growth is feasible in
Cambridge and would support the Government’s direction of travel. It is therefore important to recognise
that higher-growth outcomes remain credible and should not be ruled out by policy. This requires revision
to the proposed policy wording.

We also note the Regulation 18 version of the emerging Local Plan required 2,463 dwellings per annum
to deliver employment growth of 66,000 jobs compared to the Regulation 19 version which required
delivery of 2,292 dwellings per annum to deliver 73,200 jobs across the plan period; representing a
decrease in housing delivery whilst reflecting an increase in job creation. The EHNU reasons this in
stating the fact that average household sizes are now larger, leading to an increase in people of working
age and more in-commuting which reduces the number of local people required to fill jobs created. We
raise concern this is an unsustainable approach to development strategy and reflects a local housing
market where many young people are unable to move out of their family homes and move closer to or
within Cambridge where jobs are located at key existing and development employment centres such as
CB1, Cambridge Biomedical Campus and Cambridge Science Park. We advocate the Plan needs to address the affordability of housing within Greater Cambridge by planning for increased growth and
supply to reflect growing demand rather than embed the issue of increasing household size.
In doing so and making provision for increased housing stock in Greater Cambridge in sustainable
locations would ensure the Local Plan promotes more suitable patterns of travel as required by
paragraph 111 of the NPPF (2024) using planning polices to minimise the length of and journeys
required for employment.