Greater Cambridge Local Plan Preferred Options

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Comment

Greater Cambridge Local Plan Preferred Options

S/JH: New jobs and homes

Representation ID: 60270

Received: 13/12/2021

Respondent: Commercial Estates Group

Agent: Lichfields

Representation Summary:

Summary: Land south of Fulbourn Road and north of Worts Causeway, known as Cambridge South East (HELAA site 40058)

Housing underpins every objective of sustainable development in the NPPF and also underpins the themes of the emerging GCLP. On the basis 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. 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.

Comment

Greater Cambridge Local Plan Preferred Options

S/DS: Development strategy

Representation ID: 60271

Received: 13/12/2021

Respondent: Commercial Estates Group

Agent: Lichfields

Representation Summary:

Land south of Fulbourn Road and north of Worts Causeway, aka Cambridge South East (HELAA site 40058)

Build-out rates
As per 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.

Comment

Greater Cambridge Local Plan Preferred Options

S/DS: Development strategy

Representation ID: 60272

Received: 13/12/2021

Respondent: Commercial Estates Group

Agent: Lichfields

Representation Summary:

Land south of Fulbourn Road and north of Worts Causeway, known as Cambridge South East (HELAA site 40058)

Windfalls
We further note the high windfall figure of 450 dwellings per annum that is expected to be delivered across Greater Cambridge. 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 South Cambridgeshire and Cambridge City.
However, the evidence appears to show that the windfall figures are elevated between the years of 2013 to 2018. Comparing this data with windfalls delivered in the period either side is less. Furthermore, the windfall ranges concluded on 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 resist inappropriate development of residential gardens, including these in a long-term windfall allowance could perpetuate this trend.

Comment

Greater Cambridge Local Plan Preferred Options

S/DS: Development strategy

Representation ID: 60273

Received: 13/12/2021

Respondent: Commercial Estates Group

Agent: Lichfields

Representation Summary:

Land south of Fulbourn Road and north of Worts Causeway, known as Cambridge South East (HELAA site 40058)

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, 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, which is demonstrated clearly by the spatial strategy suggested within the CPIER. Noting the overall thread of sustainability, it would seem appropriate to provide a higher buffer of dwellings to facilitate houses close to local sources of employment which have seen higher growth rates over the past few years.

Comment

Greater Cambridge Local Plan Preferred Options

S/JH: New jobs and homes

Representation ID: 60274

Received: 13/12/2021

Respondent: Commercial Estates Group

Agent: Lichfields

Representation Summary:

Summary: Land south of Fulbourn Road and north of Worts Causeway, known as Cambridge South East (HELAA site 40058)

The NPPF places great importance on building a strong, competitive economy. The significance of the Cambridge economy and its high technology clusters is recognised throughout the GCLP. The retention and ongoing growth of these sectors needs to be fully supported by the GCLP.
The emerging GCLP only provides for the lowest identified need. Whilst there is a possibility of individual sectors slowing in growth as they expand, those particular sectors which have primarily driven growth in Greater Cambridge have not seen such a slowdown in growth.
It is therefore considered that the evidence to support the Central Scenario is lacking, and that the prevalence of unfettered growth in challenging economic conditions would point to continued long term higher job growth for Greater Cambridge.
It is vital that the GCLP 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.

Comment

Greater Cambridge Local Plan Preferred Options

S/DS: Development strategy

Representation ID: 60275

Received: 13/12/2021

Respondent: Commercial Estates Group

Agent: Lichfields

Representation Summary:

Land south of Fulbourn Road and north of Worts Causeway, known as Cambridge South East (HELAA site 40058)

It is notable that there is a lack of new housing or employment allocations located on the south eastern 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.
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. It would therefore seem unnecessarily restrictive of Greater Cambridge to limit the allocations for employment growth in this area solely to the Biomedical Campus.
The Councils should not arbitrarily limit themselves at this stage 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.

Comment

Greater Cambridge Local Plan Preferred Options

S/DS: Development strategy

Representation ID: 60276

Received: 13/12/2021

Respondent: Commercial Estates Group

Agent: Lichfields

Representation Summary:

Land south of Fulbourn Road and north of Worts Causeway, aka Cambridge South East (HELAA site 40058)

The development strategy is not overtly clear on which sites will specifically include employment uses to accommodate the need for new jobs. 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).
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.

Comment

Greater Cambridge Local Plan Preferred Options

J/NE: New employment and development proposals

Representation ID: 60277

Received: 13/12/2021

Respondent: Commercial Estates Group

Agent: Lichfields

Representation Summary:

While the policy recognises that cluster related employment is not restricted to the areas listed, the GCLP is not currently proposing to direct growth towards South East Cambridge. 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.

Comment

Greater Cambridge Local Plan Preferred Options

J/AW: Affordable workspace and creative industries

Representation ID: 60278

Received: 13/12/2021

Respondent: Commercial Estates Group

Agent: Lichfields

Representation Summary:

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.
Would increase access to affordable flexible spaces for start-up businesses and small and medium-sized enterprises (SMEs) across Greater Cambridge. This plays an important role in helping to address social inclusion.

Comment

Greater Cambridge Local Plan Preferred Options

WS/IO: Creating inclusive employment and business opportunities through new developments

Representation ID: 60279

Received: 13/12/2021

Respondent: Commercial Estates Group

Agent: Lichfields

Representation Summary:

CEG fully support this policy direction. There is an established employment market in South East Cambridge 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.

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