Greater Cambridge Local Plan Preferred Options

OBJECT

These representations are submitted on behalf of Endurance Estates, who has promoted land at Crow Green to the north-east of Caxton Gibbet for employment uses. The promoted development comprises mid-tech and advanced manufacturing employment uses and strategic logistics development. The site is located to the north of Cambourne, and the promoted development would increase employment opportunities at Cambourne. The site is located at a junction that is due to be upgraded as part of the proposed A428 Black Cat to Caxton Gibbet Improvements project being brought forward by National Highways. The site would also be well-related to the the Cambourne to Cambridge Better Public Transport project being delivered by the Greater Cambridge Partnership and the preferred routes for the East West Rail project including the proposed station at Cambourne.

These representations are supported by a Vision Document (Stephen George & Partners), Employment Need Report (Savills), Market Demand Report (Carter Jonas).

The Cambridgeshire and Peterborough Devolution Deal included a commitment to deliver substantial economic growth and to double economic output during the next 25 years. The 2018 Cambridgeshire and Peterborough Independent Economic Review (CPIER) identified that recent employment growth has been faster than anticipated, and the aim of doubling economic output in the area by 2040 was realistic. It was suggested in CPIER that economic growth could be achieved by attracting knowledge-intensive businesses that would not locate elsewhere in the UK, by delivering new housing, and by prioritising infrastructure projects. The National Infrastructure Commission, the Cambridge and Peterborough Combined Authority and the Greater Cambridge Greater Peterborough Enterprise Partnership acknowledge and support the economic growth potential of the Greater Cambridge area. The preferred growth option also does not reflect the anticipated growth aspirations of the Oxford to Cambridge Arc Spatial Framework, or that the economic success of Greater Cambridge is of national significance. As set out below, the employment land evidence and emerging GCLP does not plan for sufficient economic growth.

Barton Willmore, on behalf of Endurance Estates, have assessed the preferred jobs and housing targets in Policy S/JH. Policy S/JH takes forward the ‘Central’ growth scenario, based on employment growth of 58,500 jobs 2020-2041, at an average annual growth rate of 1.1%. However, the CPIER report identified that Cambridge and South Cambridgeshire Districts experienced average annual employment growth of 2.4% and 2.3% respectively according to Office for National Statistics data, between 2010 and 2016. This approach by CPIER results in an annual employment growth rate for Cambridge which is the same as the ONS rate (2.4%), but a significantly higher rate (4.2%) is calculated for South Cambridgeshire. Barton Willmore conclude that the Councils current objectively assessed need is far below the potential growth scenarios for the area and, therefore, will need to be revised up and supported by further site allocations in the development strategy.

Therefore, the emerging GCLP should have selected a higher growth level option to support economic growth, and made additional employment allocations to meet that growth..

Requested Change

It is requested that the housing and jobs requirements in Policy S/JH are reviewed to ensure they meet the growth potential of Greater Cambridge, and based on delivering a higher growth level option.

OBJECT

These representations are submitted on behalf of Endurance Estates, who has promoted land at Crow Green to the north-east of Caxton Gibbet for employment uses. The promoted development comprises mid-tech and advanced manufacturing employment uses and strategic logistics development. The site is located to the north of Cambourne, and the promoted development would increase employment opportunities at Cambourne. The site located at a junction that is due to be upgraded as part of the proposed A428 Black Cat to Caxton Gibbet Improvements project being brought forward by National Highways. The site would also be well-related to the Cambourne to Cambridge Better Public Transport project being delivered by the Greater Cambridge Partnership and the preferred routes for the East West Rail project including the proposed station at Cambourne.

These representations to Policy S/DS are focussed on the part of the development strategy that relate to Cambourne because of the location of the site promoted by Endurance Estates; separate representations are submitted to Policy S/CB: Cambourne. The development strategy for Cambourne states “For our new settlements, we propose: Evolving and expanding Cambourne into a vibrant town alongside the development of the new East West Rail station, which will make it one of the best connected and most accessible places in the area”. The principle of expanding Cambourne to make it a vibrant town is supported. However, the delivery of additional employment land at Cambourne must be part of any strategy to make it more vibrant.

In summary, there is a need for additional industrial (Class B2) and storage and distribution (Class B8) land in Greater Cambridge, but a limited supply and strong market demand. The promoted development by Endurance Estates at Caxton Gibbet would meet the demand for mid-tech and advanced manufacturing units and strategic logistics units, and would provide a range of unit sizes to meet the needs of different occupiers. The promoted development is well-related to Cambourne and to the strategic road network, and would provide employment opportunities for current and future residents closer to where they live. It is requested in these representations that the development strategy for Cambourne makes specific reference to increasing the supply of employment land at Cambourne. The representations to Policy S/CB: Cambourne seek an allocation of the land at Caxton Gibbet for industrial and storage and distribution uses. The representations to Policy J/NE: New Employment Development comment on the employment land evidence prepared for emerging GCLP and specifically the decision to not allocate land for warehouse and distribution centres in Greater Cambridge despite the identified need and demand.

Paragraph 8 of the NPPF identifies the three objectives of sustainable development. The economic objective specifically identifies the need to 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. Paragraph 20 notes that strategic policies should set out an overall strategy for the pattern, scale and quality of development, and make sufficient provision for employment and other commercial development amongst other matters. Paragraph 81 expects planning policies to create the conditions in which businesses can invest, expand and adapt, and to support economic growth and productivity and to meet the needs of business. Paragraph 82 expects planning policies to have regard to local industrial strategies and other local policies for economic development and regeneration, and to identify strategic sites to meet economic strategies and anticipated employment needs. Paragraph 83 expects planning policies to recognise and address the specific locational requirements of different sectors including high technology industries and storage and distribution operations. Paragraph 031 (ID: 2a) of the Planning Practice Guidance explains how local planning authorities should identify the need for logistics and allocate land to meet that need. The Greater Cambridge Employment Land and Economic Development Evidence Study (November 2020 GL Hearn) was prepared to inform the economic development and employment land needs for emerging GCLP, including the approach to the provision of land for Class B2 and B8 uses. As explained below, it is considered that the evidence base for the emerging GCLP underestimates the need for Class B2 and B8 uses, and does not reflect the market demand for these uses in Greater Cambridge.

The Need for Employment Land Report (prepared by Savills on behalf of Endurance Estates) assessed the employment land evidence for emerging GCLP; the Report is attached to the representations to Policy S/CB: Cambourne that includes a request for land at Caxton Gibbet to be allocated for industrial (mid-tech/ advanced manufacturing) and storage and distribution (logistics) uses. In summary, Savills conclude that the employment land evidence base underestimates the actual need for Class B2 and B8 uses, does not properly take into account existing supply or market signals, and ignores the wider region/functional property market area relevant to Greater Cambridge. The current and emerging policies for industrial development are restrictive, and suppress demand. Savills estimate that between 270,000 sqm and 461,000 sqm of industrial floorspace is required over the plan period.

The Market Demand Report (prepared by Carter Jonas on behalf of Endurance Estates) assessed the supply, demand and need for high technology manufacturing and logistics floorspace; the Report is attached to the representations to Policy S/CB: Cambourne. In summary, Carter Jonas conclude that there is limited supply of floorspace suitable for high technology manufacturing and logistics uses, and the supply is not being provided in Cambridgeshire. There is strong demand for floorspace in Greater Cambridge and along the A428 corridor, but that demand is not being met.

The Savills and Carter Jonas reports identify the benefits of the logistics sector and of the promoted employment development at land at Caxton Gibbet, which are explained in more detail in the representations to Policy S/CB: Cambourne.

Paragraph 104 of the NPPF expects transport issues to be considered at an early stage of plan-making, so that impacts and opportunities can be assessed. Paragraph 105 seeks to ensure that development is located where the need to travel will be minimised and the use of sustainable transport modes can be maximised. Paragraph 106 expects planning policies to support an appropriate mix of uses across an area, and within larger scale sites, to minimise the number and length of journeys needed for employment, amongst other matters.

There are a number of transport infrastructure projects already planned at an in the vicinity of Cambourne that will improve accessibility along the A428 corridor in South Cambridgeshire. Those transport projects are the proposed A428 Black Cat to Caxton Gibbet Improvements project, the preferred routes for the East West Rail project including the proposed station at Cambourne, and the Cambourne to Cambridge Better Public Transport project. Therefore, in due course Cambourne and the promoted development at Caxton Gibbet will be very well connected by road, rail and bus. The improvements to the A428 include the delivery of pedestrian routes and connections across the Caxton Gibbet junction, south to Cambourne West, as well as improvements further east at the ‘Cambourne Junction’. In all respects, additional employment development at Cambourne/Caxton Gibbet would deliver on the sustainable transport objectives of national policy.

Cambourne has a good range of services and facilities, but it lacks land for employment which means that residents need to travel elsewhere to access job opportunities. Cambourne with approved expansion will have 6,600 dwellings and a further potential 1,950 dwellings in the future proposed through the emerging Greater Cambridge Local Plan, and Bourn Airfield will have 3,500 dwellings. . Cambourne is currently the largest settlement in South Cambridgeshire. A more sustainable outcome would be delivered if a higher proportion of Cambourne’s existing and future residents could access employment opportunities locally, commuting via sustainable modes and reducing commuting into Cambridge. Irrespective of potential future housing growth at Cambourne there is already a significant case to be made for providing more jobs close to existing houses in this location. The promoted development by Endurance Estates at Caxton Gibbet would provide some of those employment opportunities.

In conclusion, the development strategy ignores the opportunity for additional employment to be provided at and in the vicinity of Cambourne, and does not properly reflect the need and demand for Class B2 and B8 uses.

Requested Change

It is requested that the development strategy for Cambourne makes specific reference to increasing the supply of employment land at and in the vicinity of Cambourne, including at land at Caxton Gibbet as promoted by Endurance Estates.

OBJECT

As set out in Endurance Estates’ representations to Policy S/DS, it is considered that the evidence base for the emerging GCLP underestimates the need for Class B2 and B8 uses, and does not reflect the market demand for these uses in Greater Cambridge. Two reports, prepared on behalf of Endurance Estates, have assessed supply and demand matters for Class B2 and B8 uses: The Need for Employment Land Report (prepared by Savills) assessed the employment land evidence for emerging GCLP; and, Market Demand Report (prepared by Carter Jonas) assessed the supply, demand and need for high and mid-technology manufacturing and logistics floorspace in Greater Cambridge. The reports are submitted with these representations.

The representations to Policy S/DS also highlighted the transport infrastructure projects already planned at and in the vicinity of Cambourne that will improve accessibility along the A428 corridor in South Cambridgeshire, and the transport related sustainability benefits of locating more employment development close to Cambourne to provide employment opportunities for existing and future residents.

It is considered that additional employment land should be allocated at land at Caxton Gibbet, to meet the needs for high and mid-technology manufacturing and logistics floorspace on the strategic road network, and to make Cambourne more sustainable by increasing the mix of uses at the town including additional employment uses.

The Savills Report highlights some of the benefits of industrial and logistics employment (see Section 4) including the following:

• A major contributor to the national economy.
• Higher wages than the national average.
• Higher rates of productivity than the overall economy.
• Increasingly diverse employment opportunities including professional and technical roles, and in high skilled engineering and technological professions.
• Innovative workplaces that are modern and technologically advanced.
• Replace jobs lost from other part of the economy.
• Increasing demand for online shopping.

As highlighted in the Savills Report, Greater Cambridge should not rely on other parts of the region to provide industrial and logistics premises.

The Carter Jonas Report highlighted some of the benefits of locating high technology manufacturing and logistics floorspace at land at Caxton Gibbet, as follows:

• Good transport links, including planned highway improvements to A428 and planned new East West Rail route including a proposed station at Cambourne.
• Provide a range of unit sizes to meet the needs of a variety of occupiers including small scale, mid-box and big-box units.
• Provide units to meet demand for floorspace required by high-tech manufacturing, life science and general manufacturing companies.
• Providing affordable units to address the increasing rents for industrial and logistics floorspace within Greater Cambridge.
• Close to large supply of potential employees at Cambourne, reducing commuting levels and providing opportunities to access employment locally and by sustainable modes of transport

A Vision Document (by Stephen George & Partners) has been prepared for the promoted development to provide key design principles and explain how potential impacts would be addressed including landscape impacts.

The site is beyond the Cambridge Green Belt. The baseline technical studies have demonstrated that the site may be sustainably accessed and drained. There are no adverse impacts on heritage assets. A suitable strategic scale landscape strategy can be provided to mitigate visual impacts. A biodiversity net gain can be delivered. The promoted development would be zero net carbon, and could deliver between 3,500 and 4,500 new FTE jobs. The site is in close proximity to planned new transport infrastructure.

A Vision Document is submitted with these representations.

For all these reasons it is requested that land at Caxton Gibbet, as promoted by Endurance Estates, is identified as an addition employment allocation at Cambourne.

Requested Change

It is requested that land at Caxton Gibbet, as promoted by Endurance Estates, is identified as an addition employment allocation at Cambourne with the following policy requirements:

• Site Area of 164.40 Ha
• Employment for industrial (Class B2) and storage and distribution (Class B8) for mid-tech and advanced manufacturing units and strategic logistics units
• Main vehicular access via new roundabout on the A1198 provided as part of A428 Black Cat to Caxton Gibbet Improvements project.
• Pedestrian and cycle access via the new bridge over the A428 (provided as part of A428 Black Cat to Caxton Gibbet Improvements project) and via the existing bridge over the A428 at Cambourne Road/St Neots Road.
• New footways and cycleways would need to be provided to Cambourne and Papworth Everard from the promoted development. from The Causeway
• Development should address the following constraints:
o Woodland planting at the northern part of the site
o Strategic landscape planting on northern, eastern and western boundaries

Section 3.1: Climate Change

COMMENT

Section 3.1 set out the approach to tackling climate change and includes the following policies:

Policy CC/NZ: Net Zero Carbon New Buildings: The promoted development will be net zero carbon in operation, taking a holistic approach that implements energy efficient buildings alongside a dedicated solar farm and solar PV on roofs. Given the fast pace of technological advancement and evolution, the development will assess the available options at the time of construction so as to be able to deliver a sustainable, viable, project.

Policy CC/FM: Flooding and Integrated Water Management: The prevailing surface water strategy to be adopted is a network of positive drainage consisting of, and not limited to, the following SuDS features:
• Open swales / rills;
• Living Roofs
• Blue Roofs (these can also be used in areas of Living Roof)
• Attenuation Basins (with some localised pond/wetland features);
• Porous Paving (where feasible);
• Bio-retention areas; and
• Rainwater Harvesting.

Section 3.2 – Biodiversity and Green Spaces

OBJECT

As highlighted in the submitted Vision Document, the promoted development at land at Caxton Gibbet includes substantial areas of green infrastructure and ecological enhancements. It is considered that this approach would be consistent with the aims of the following policies in Section 3.2: Policy BG/BG: Biodiversity and Geodiversity; and Policy BG/GI: Green Infrastructure. It is the large-scale development with sufficient land available that can deliver significant benefits for all these policy areas.

Figure 54 in the GCLP Preferred Options document identifies green infrastructure initiatives, including one at Western Gateway Multifunctional GI Corridors, which is located around Cambourne and Bourn and along the A428 corridor. One of the objectives for this green infrastructure initiative is to “Provide opportunities to improve biodiversity by expanding and joining up the existing woodland, hedgerow and grassland habitat network. This will be delivered through new woodland planting, natural regeneration, hedgerow extension and management, and habitat restoration. Ensure opportunities for biodiversity offsets from East West rail are sought”. – see pg.8 of Greater Cambridge Green Infrastructure Opportunity Mapping Part 2 Recommendations Report (LUC September 2021). The green infrastructure proposed for the promoted development at land at Caxton Gibbet would be consistent with this initiative, in terms of providing additional woodland and retaining and enhancing hedgerows.

There is a real opportunity to deliver green infrastructure improvements to the north of Cambourne in conjunction with employment development at land at Caxton Gibbet, and complement the Western Gateway green infrastructure initiative.

Requested Change

It is requested that the promoted development at land at Caxton Gibbet is allocated in emerging GCLP for employment development to deliver substantial green infrastructure benefits and complement the Western Gateway Multifunctional GI Corridors initiative.

Policy J/NE: New Employment Development

OBJECT

Endurance Estates is promoting land at Caxton Gibbet for employment development, comprising high-tech and advanced manufacturing employment uses and strategic logistics development. It is stated in Policy J/NE that large scale national and regional warehousing and distribution centres will not be supported in Greater Cambridge, that is despite an need for additional land for these uses being identified in the evidence for emerging GCLP.

Paragraph 8 of the NPPF identifies the three objectives of sustainable development. The economic objective specifically identifies the need to 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. Paragraph 20 notes that strategic policies should set out an overall strategy for the pattern, scale and quality of development, and make sufficient provision for employment and other commercial development amongst other matters. Paragraph 81 expects planning policies to create the conditions in which businesses can invest, expand and adapt, and to support economic growth and productivity and to meet the needs of business. Paragraph 82 expects planning policies to have regard to local industrial strategies and other local policies for economic development and regeneration, and to identify strategic sites to meet economic strategies and anticipated employment needs. Paragraph 83 expects planning policies to recognise and address the specific locational requirements of different sectors including high technology industries and storage and distribution operations. Paragraph 031 (ID: 2a) of the Planning Practice Guidance explains how local planning authorities should identify the need for logistics and allocate land to meet that need.

The Greater Cambridge Employment Land and Economic Development Evidence Study (November 2020 GL Hearn) was prepared to inform the economic development and employment land needs for emerging GCLP, including the approach to the provision of land for Class B2 and B8 uses.

The Need for Employment Land Report (prepared by Savills on behalf of Endurance Estates) assessed the employment land evidence for emerging GCLP; the Report is attached to the representations to Policy S/CB: Cambourne that includes a request for land at Caxton Gibbet to be allocated for industrial and storage and distribution uses. In summary, Savills conclude that the employment land evidence base underestimates the actual need for Class B2 and B8 uses, does not properly take into account existing supply or market signals, and ignores the wider region/functional property market area relevant to Greater Cambridge. The current and emerging policies for industrial development are restrictive, and suppress demand. Savills estimate that more than 270,000 sqm of industrial floorspace is required over the plan period.

The Market Demand Report (prepared by Carter Jonas on behalf of Endurance Estates) assessed the supply, demand and need for high technology manufacturing and logistics floorspace; the Report is attached to the representations to Policy S/CB: Cambourne. In summary, Carter Jonas conclude that there is limited supply of floorspace suitable for high technology manufacturing and logistics uses, and the supply is not being provided in Cambridgeshire. There is strong demand for floorspace in Greater Cambridge and along the A428 corridor, but that demand is not being met.

Greater Cambridge is relying on other parts of the region to provide industrial and logistics premises. The benefits of providing industrial and logistics development within Greater Cambridge have been ignored e.g. for the economy, variety of job opportunities, employment close to Cambourne etc. it should be noted that the promoted development at land at Caxton Gibbet is well-related to the strategic highway network, is accessible for employees and is not located in the Green Belt.

It is considered that not meeting the needs for industrial and strategic logistics within Greater Cambridge is contrary to national guidance.

Requested Change

It is requested that the employment land evidences is updated and amended as set out in findings of the Need for Employment Land Report (prepared by Savills) and the Market Demand Report (prepared by Carter Jonas).

It is requested that land at Caxton Gibbet, as promoted by Endurance Estates, is identified as an addition employment allocation at Cambourne for Class B2 and Class B8 uses.

COMMENT

Policy I/ST: Sustainable Transport and Connectivity set out how the transport impacts of development should be managed, and how new development should be connected to the transport network. An aim of the policy is to reduce transport emissions. The preferred development strategy seeks to co-locate housing close to jobs, services and facilities in order to reduce the need to travel and support travel by walking, cycling and public transport. This approach is consistent with Paragraphs 104 and 105 of the NPPF and is supported. However, it is considered of the aim of Policy I/ST will only be fully implemented if all available opportunities to direct development to sustainable locations are taken, including additional employment development being directed to the A428 corridor close to Cambourne edge of Cambridge.

There are a number of transport infrastructure projects already planned at an in the vicinity of Cambourne that will improve accessibility along the A428 corridor in South Cambridgeshire. Those transport projects are the proposed A428 Black Cat to Caxton Gibbet Improvements project, the preferred routes for the East West Rail project including the proposed station at Cambourne, and the Cambourne to Cambridge Better Public Transport project. Therefore, in due course Cambourne and the promoted development at Caxton Gibbet will be very well connected by road, rail and bus.

The pedestrian and cycle access to the promoted development would be provided by the new bridge over the A428 (connection to proposed Cambourne West development) and via the existing bridge over the A428 at Cambourne Road/St Neots Road (connection to existing Cambourne). All of this infrastructure will be delivered through the A428 improvement works. Connections into and any required improvements to these footways and cycleways would be provided both to Cambourne and Papworth Everard from the promoted development.

Therefore, walking, cycling and public transport options would be available once the proposed and planned projects in the A428 corridor are delivered, providing realistic options for sustainable travel to and from the promoted development. The promoted development provides an excellent opportunity to provide employment generating development that capitalises on infrastructure investment and that has a significantly enhance opportunity to drive a shift to commuting by sustainable modes, reducing the reliance on the private car and reducing commuting into Cambridge.

An additional allocations on the edge of Cambourne, including at the promoted development at land at Caxton Gibbet, would be consistent with the aims of Policy I/ST.

Requested Change

It is requested that the promoted development by Endurance Estates at land at Caxton Gibbet is allocated for employment development, in order to support the aims of Policy I/ST e.g. reduce transport emissions, reduce the need to travel, and encourage the use of sustainable modes of transport.

COMMENT

Policy I/FD seeks to support the development of local delivery hubs. However, as set out in the representations to Policy J/NE: New Employment Development, the identified need for strategic logistics floorspace of Greater Cambridge will not actually be met. As such, while local delivery hubs may help to divert delivery related traffic from Central Cambridge, it does not seek to address longer journeys by delivery vehicles from logistics hubs located elsewhere because units are not provided in Greater Cambridge through emerging GCLP. In effect Greater Cambridge is relying on other parts of the region to provide industrial and logistics premises, and Policy I/FD is only addressing the ‘last mile’ part of the delivery chain. It is for this reason that Endurance Estates has requested a specific strategic employment allocation at land at Caxton Gibbet for Class B2 and Class B8 uses.

No changes are requested.

COMMENT

Policy I/ID explains that development needs to be supported by infrastructure, which is agreed. It should be noted that infrastructure is proposed and planned to support the growth in the A428 corridor including for Cambourne. For example there are numerous transport infrastructure projects in the A428 corridor. National Highways are bringing forward the proposed A428 Black Cat to Caxton Gibbet Improvements project, which involves the dualling of this section of the road and includes new junctions one of which is at Caxton Gibbet (and includes pedestrian and cycle links to Cambourne). The Cambourne to Cambridge Better Public Transport project being delivered by the Greater Cambridge Partnership is a proposed as a high quality public transport corridor on the A428 corridor, with initial route stops at Cambourne but in the future it is likely to be extended to connect to the proposed West Cambourne Development and onto St Neots. Greater Cambridge Partnership has also proposed a Making Connections project that identifies St Neots/St Neots East and Cambourne/Cambourne West as transport hubs for improved bus routes along the A428 corridor, which would provide improvements to the bus services in this area. The East West Rail project identifies preferred routes options via Cambourne and includes a proposed station at Cambourne. The promoted employment development by Endurance Estates at land at Caxton Gibbet would be well related to all these proposed and planned transport infrastructure projects. It would be consistent with the economic objectives and principles of sustainable development to co-ordinate infrastructure and growth with one another, and directing economic development with proposed and planned transport infrastructure improvements in the A428 corridor would meet these objectives and principles.

The promoted development at land at Caxton Gibbet would need to address local impacts on infrastructure, and these would be assessed at planning application stage.

No changes are requested.

Sustainability Appraisal

A key aim of the Sustainability Appraisal process is to make a plan more sustainable. It tests the social, economic and environmental impacts of various plan options, to help choose the most sustainable options. It also seeks to determine the extent to which the principles of sustainable development are integrated into the plan and its policies.

It is considered by Endurance Estates that the Sustainability Appraisal has not sought to make emerging GCLP more sustainable. It appears that the assessment against sustainability objectives is not robust because it does not critically review or challenge the evidence provided by the Councils.

Endurance Estates representations and requested amendment to the assessment of policy options in the Sustainability Appraisal, which are relevant to the promoted development for employment uses at land at Caxton Gibbet are as follows:

• Table 5.4: Policy S/DS: Development Strategy - Assesses the development strategy against sustainability objectives. The economy objective (SA14) relates to employment land supply and business needs matters, and the and employment objective (SA15) relates to the availability of and access to employment opportunities. The score of the economy and employment objectives are ‘mixed minor effects likely’. These scores highlight how unambitious the development strategy is towards supporting the economy of Greater Cambridge, supporting businesses and meeting their needs, and providing job opportunities for residents. As set out in Endurance Estates’ representations to Policy S/DS, the need for additional land for industrial and strategic logistics will not be met through the preferred development strategy, and there is no clear strategy to make Cambourne more sustainable by directing strategic employment development to this location. It is considered that the SA should recommend amendments to Policy S/DS to improve the score for economy and employment related sustainability objectives. As requested in the representations to Policy S/DS and S/CB: Cambourne, a specific strategic employment allocation should be made at land at Caxton Gibbet for Class B2 and Class B8 uses, in order to meet the needs for industrial and strategic logistics floorspace in Greater Cambridge and to provide job opportunities close to Cambourne for existing and future residents.

• Table 5.16: Policy S/CB: Cambourne – Identifies ‘significant positive effects likely’ for the economy objective (SA14) and the employment objective (SA15). The commentary for these matters refers to the transport connections as providing an opportunity to attract a new workforce. The assessment and commentary for economy and employment matters is inadequate and not robust. There is already an existing highly skilled workforce available in Cambourne, the problem is that not enough jobs are provided in this location to enable residents to work locally and so they travel elsewhere for employment purposes. It is not a sustainable outcome for most residents of Cambourne, the largest settlement in South Cambridgeshire, to travel to other centres for work, and it is necessary for emerging GCLP to set out a deliverable strategy to increase significantly the amount of job opportunities available in Cambourne during the plan period. As set out in Endurance Estates’ representations to S/CB: Cambourne, it is requested that a specific strategic employment allocation should be made at land at Caxton Gibbet for Class B2 and Class B8 uses, in order to meet the needs for industrial and strategic logistics floorspace in Greater Cambridge and to provide job opportunities close to Cambourne for existing and future residents. This approach would more accurately reflect the ‘significant positive effects likely’ scores currently given for the economy and employment related sustainability objectives.

• Table 5.50: Policy J/NE: New Employment Development Proposals – Identifies ‘significant positive effects likely’ for the economy objective (SA14) and a ‘negligible effect’ for the employment objective (SA15). The ‘negligible effect’ score for the employment objective again highlights the lack of ambition in emerging GCLP to meet the employment needs of all residents. The ‘significant positive effects likely’ score for the economy objective does not take into account the decision to not meet the business needs for additional Class B2 and B8 floorspace – see findings in the Need for Employment Land Report (prepared by Savills) and the Market Demand Report (prepared by Carter Jonas) referred to in representations to Policy S/CB: Cambourne, Policy S/DS: Development Strategy and Policy J/NE. It is clear that emerging GCLP does not intend to accommodate the needs for high and mid-technology manufacturing and strategic logistics floorspace. The SA does not assess the consequences of industrial and logistics floorspace being provided elsewhere and not in Greater Cambridge, or the associated consequences on the economy, businesses, employees and transport. It is considered that there would be negative sustainability outcomes for all these matters. Policy J/NE should seek to deliver an actual ‘significant positive effects likely’ score for the economy and employment related sustainability objectives by meeting the needs for industrial and strategic logistics floorspace in Greater Cambridge and by providing job opportunities close to Cambourne for existing and future residents. This could be delivered by a specific strategic employment allocation at land at Caxton Gibbet for Class B2 and Class B8 uses, as requested by Endurance Estates.

It is requested that the above comments are taken into account when the SA is updated.