Greater Cambridge Local Plan Preferred Options

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
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
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
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.

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.

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.

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.

Inclusive & affordable employment
Policy WS/IO sets out how new developments should support the skills and training needs of local residents and provide opportunities for local businesses. The policy demonstrates that importance will be given to appropriately scaled developments that support local employment contributions to help to ensure that the local community benefits from the development.
CEG fully support this policy direction and the site presents a significant opportunity to make an important contribution to the Councils’ aims of creating inclusive employment in the area. Dependent on the scale of development at the site, this would be a notable local benefit of Green Belt release, which should be considered in the context of existing employment facilities at PTP. There is an established employment market in this location and expansion of this market could readily generate opportunities for local people to train in the higher-skilled sectors, through on-site apprenticeships for example, providing significant community benefit. This would further support the provision of a skilled labour force and mitigate the need for greater in commuting to Greater Cambridge, linking to the climate change theme throughout the Reg 18 consultation.
On a similar note, Policy J/AW proposes the means by which affordable workspace, including for creative businesses, should be provided across Greater Cambridge. The policy requires affordable workspace – that is, workspace that has a rental value below the market rate (generally, 80% of the market rate or less) – to be delivered as a proportion of larger commercial developments. We support this proposed policy, in particular the inherent flexibility that is provided by including the potential for financial contributions to be made for equivalent off-site provision should on-site provision not be possible.
Delivery of employment development at the site, and the associated contribution it would make, would increase access to affordable flexible spaces for start-up businesses and small and medium-sized enterprises (SMEs) across Greater Cambridge. As noted in the GCLP, this plays an important role in helping to address social inclusion and it would therefore provide an additional benefit to Green Belt release in this location.

Inclusive & affordable employment
Policy WS/IO sets out how new developments should support the skills and training needs of local residents and provide opportunities for local businesses. The policy demonstrates that importance will be given to appropriately scaled developments that support local employment contributions to help to ensure that the local community benefits from the development.
CEG fully support this policy direction and the site presents a significant opportunity to make an important contribution to the Councils’ aims of creating inclusive employment in the area. Dependent on the scale of development at the site, this would be a notable local benefit of Green Belt release, which should be considered in the context of existing employment facilities at PTP. There is an established employment market in this location and expansion of this market could readily generate opportunities for local people to train in the higher-skilled sectors, through on-site apprenticeships for example, providing significant community benefit. This would further support the provision of a skilled labour force and mitigate the need for greater in commuting to Greater Cambridge, linking to the climate change theme throughout the Reg 18 consultation.
On a similar note, Policy J/AW proposes the means by which affordable workspace, including for creative businesses, should be provided across Greater Cambridge. The policy requires affordable workspace – that is, workspace that has a rental value below the market rate (generally, 80% of the market rate or less) – to be delivered as a proportion of larger commercial developments. We support this proposed policy, in particular the inherent flexibility that is provided by including the potential for financial contributions to be made for equivalent off-site provision should on-site provision not be possible.
Delivery of employment development at the site, and the associated contribution it would make, would increase access to affordable flexible spaces for start-up businesses and small and medium-sized enterprises (SMEs) across Greater Cambridge. As noted in the GCLP, this plays an important role in helping to address social inclusion and it would therefore provide an additional benefit to Green Belt release in this location.