Greater Cambridge Local Plan: Proposed Submission

The Chamber requests that:
1. the cumulative effect of Local Plan requirements is explicitly assessed;
2. cumulative viability is monitored following adoption;
3. proportionate flexibility is available where robust evidence demonstrates that combined requirements would prevent otherwise sustainable development;
4. housing and employment delivery rates are monitored for evidence of systemic viability impacts; and
5. persistent evidence of impaired delivery triggers policy review.
This is not a request for automatic exemption from planning requirements.
It is intended to prevent the Plan's objectives collectively frustrating the growth strategy on which they depend.

Chamber position: MODIFICATION REQUIRED ACROSS RELEVANT POLICIES

The Local Plan contains significant requirements concerning:
• affordable housing;
• affordable workspace;
• biodiversity;
• carbon and energy;
• water;
• transport;
• infrastructure;
• design; and
• other development obligations.

Many of these objectives are individually supported by the Chamber.

The key question is whether their combined effect remains deliverable. Soundness concern
Justified and effective. Modification sought

The monitoring framework should consider housing delivery as part of the economic-growth strategy, including:
• total completions;
• affordable housing delivery;
• employment growth;
• relevant labour-market indicators; and
• sustained imbalance between jobs, homes and supporting infrastructure.

The Plan's implementation and monitoring framework should clearly identify cross-
boundary economic and infrastructure dependencies, responsibility for addressing them and mechanisms for escalation where delivery is being delayed.

Chamber position: SUPPORT
For the Chamber, housing is an essential component of economic infrastructure. The Chamber supports substantial delivery of both market and affordable housing.
The Plan anticipates approximately 73,300 additional jobs. A labour market capable of
supporting this growth requires an adequate supply of homes accessible to people working across a wide range of occupations.
Our employer evidence demonstrates that recruitment is already challenging for many businesses.
Housing is not the only cause, but inadequate housing supply or affordability can compound labour-market pressure and increase dependence on longer-distance commuting.

Chamber position: SUPPORT STRONGER INTEGRATION
Greater Cambridge's economy does not stop at local-authority boundaries.
Labour markets, commuting patterns, utility networks, housing, supply chains and strategic transport infrastructure operate across the wider Cambridgeshire and Peterborough
economy.
The Chamber therefore supports strong coordination between:
• Cambridge City Council;
• South Cambridgeshire District Council;
• Cambridgeshire County Council;
• Cambridgeshire and Peterborough Combined Authority;
• neighbouring authorities;
• utility providers;
• central government;
• infrastructure bodies; and
• representative business organisations including the Chamber.

Policy I/ST or its supporting text should ensure that:
• freight and servicing remain practical;
• shift patterns are considered;
• urban and rural circumstances are differentiated;
• viable alternatives are available before existing access is materially restricted; and
• strategically important employment sites remain accessible.

Sustainable transport and business growth should be mutually reinforcing objectives.

Chamber position: SUPPORT, SUBJECT TO MODIFICATION
The Chamber supports measures which improve public transport and active travel and reduce unnecessary congestion.
Improved connectivity can widen the effective labour market and improve journey reliability.
However, not every business journey can reasonably be transferred to active travel or public transport.
Businesses need appropriate provision for:
• freight;
• servicing;
• tradespeople;
• customer access;
• shift workers;
• early and late working;
• rural employment locations; and
• journeys where credible alternatives do not exist.

Soundness concern Effectiveness.

Environmental policies should:
• focus on measurable outcomes;
• avoid unnecessary duplication;
• allow appropriate technological innovation;
• remain proportionate to development scale and circumstances; and
• operate within wider cumulative-viability safeguards.

Chamber position: SUPPORT THE OBJECTIVES, SUBJECT TO DELIVERABILITY
The Chamber supports Greater Cambridge's transition towards a low-carbon and environmentally sustainable economy.
Businesses benefit from:
• resilient infrastructure;
• efficient buildings;
• energy security;
• climate resilience; and
• high-quality places.
The Chamber does not oppose ambitious environmental outcomes merely because they exceed minimum requirements.
We support an approach focused on clear, measurable environmental outcomes combined with reasonable flexibility and innovation in how those outcomes are achieved.

This could include, where technically and commercially appropriate:
• onsite renewable energy generation;
• solar technologies;
• battery storage;
• rainwater harvesting and reuse;
• integrated water management;
• energy-efficiency technologies; and
• other emerging sustainable infrastructure solutions.
Planning requirements should encourage innovation rather than unnecessarily prescribe a single technical solution.

Environmental policies should:
• focus on measurable outcomes;
• avoid unnecessary duplication;
• allow appropriate technological innovation;
• remain proportionate to development scale and circumstances; and
• operate within wider cumulative-viability safeguards.

Chamber position: SUPPORT THE OBJECTIVES, SUBJECT TO DELIVERABILITY
The Chamber supports Greater Cambridge's transition towards a low-carbon and environmentally sustainable economy.
Businesses benefit from:
• resilient infrastructure;
• efficient buildings;
• energy security;
• climate resilience; and
• high-quality places.
The Chamber does not oppose ambitious environmental outcomes merely because they exceed minimum requirements.
We support an approach focused on clear, measurable environmental outcomes combined with reasonable flexibility and innovation in how those outcomes are achieved.

This could include, where technically and commercially appropriate:
• onsite renewable energy generation;
• solar technologies;
• battery storage;
• rainwater harvesting and reuse;
• integrated water management;
• energy-efficiency technologies; and
• other emerging sustainable infrastructure solutions.
Planning requirements should encourage innovation rather than unnecessarily prescribe a single technical solution.

Chamber position: STRONG SUPPORT
The Chamber strongly supports the Plan's recognition of Greater Cambridge's major employment, research and innovation clusters.
Strategic locations must accommodate not only research activity but the full ecosystem necessary to commercialise innovation and generate economic value.
This includes:
• start-ups;
• scale-ups;
• laboratories;

• biotechnology;
• high-tech and advanced manufacturing;
• supply-chain companies;
• technical services;
• professional services;
• appropriate logistics; and
• supporting facilities.
Planning policy should avoid an unnecessarily narrow interpretation of appropriate economic uses where complementary activity is required for successful clusters.

The Chamber recommends establishment of an ongoing Greater Cambridge Business and Growth Forum.

Chamber position: MODIFICATION REQUESTED
Successful adoption of the Local Plan is only the beginning of implementation.
The Chamber recommends establishment of an ongoing Greater Cambridge Business and Growth Forum.
Membership should include, as appropriate:
• Cambridgeshire Chamber of Commerce and other representative business bodies;
• SMEs;
• major employers;
• developers delivering business parks, enterprise and investment locations;
• strategic-site representatives;
• water and wastewater companies;
• electricity network and energy providers;
• transport and highways bodies;
• planning authorities;
• statutory consultees; and
• the Combined Authority.
The forum should meet alongside publication of the annual Growth and Infrastructure Dashboard and provide structured evidence on emerging barriers to investment and delivery.
Particular attention should be given to resolving cross-organisational issues where a development is being delayed because responsibility sits across several planning, utility or infrastructure bodies.
The Chamber would be willing to play a constructive role in this process.


Chamber position: IMPLEMENTATION PRIORITY
A pro-growth Local Plan will achieve little if the development-management system cannot translate policy into timely decisions.

The Chamber supports a positive planning culture in which planning officers, applicants, statutory consultees and infrastructure providers work collaboratively to identify and resolve issues at the earliest practical stage.

Businesses require:
• accessible and constructive pre-application engagement;
• consistent advice;
• clear responsibility for outstanding issues;
• predictable timescales;
• efficient discharge of conditions; and
• timely decisions.

The Chamber recognises the national pressures on planning-authority and statutory-consultee resources identified by BCC.

However, an ambitious growth strategy must be matched by sufficient capacity and effective processes.

Implementation measures sought
The Chamber encourages the Councils to:
1. publish service standards for strategically important and major employment proposals;
2. monitor performance against agreed and statutory decision times;
3. provide applicants with clear reasons and revised milestones where decisions are delayed;
4. establish escalation arrangements for strategically significant stalled developments;
5. improve coordination between planning teams, statutory consultees and infrastructure providers;
6. use high-quality pre-application engagement to identify evidence requirements early; and
7. report relevant planning-delivery performance through the proposed Growth and Infrastructure Dashboard.

The Chamber is not proposing a Local Plan penalty regime for missed deadlines.

The objective should instead be greater accountability, transparency and delivery discipline.