Question 31. How should the Local Plan help to meet our needs for the amount and types of new homes?

The importance of the Local Plan shaping the strategy for the number and location of new homes cannot be underestimated. The economic performance of Greater Cambridge is of national importance and it is imperative that a strategy is in place which delivers the number, range and type of housing required to avoid the position where supply wasn’t able to meet demand following the Cambridgeshire and Peterborough devolution deal (Issues and Options document, p. 62).

be underestimated. The economic performance of Greater Cambridge is of national importance and it is imperative that a strategy is in place which delivers the number, range and type of housing required to avoid the position where supply wasn’t able to meet demand following the Cambridgeshire and Peterborough devolution deal (Issues and Options document, p. 62). Paragraph 78 of the National Planning Policy Framework (‘NPPF’) acknowledges the role of villages and states “planning policies should identify opportunities for villages to grow and thrive, especially where this will support local services”. We therefore contend ‘Dispersal - Villages’ must be incorporated into the housing strategy of the Local Plan. Furthermore, page 59 of the Issues and Options document states, the “Local Plan has an important role to play in ensuring we get the right homes in the right places so that everyone has the chance to live settled, healthy lives” and in consideration of the long lead in times for large urban extensions and/or new settlements, ‘Dispersal - Villages’ which can be delivered quickly, can take advantage of existing infrastructure, be attractive to smaller housebuilders and ensure a good mix of sites come forward (as part of the Plan) must be supported.

Connected to Q32, delivering the right numbers of homes and in the right locations can support the economy both by housing the workforce and by boosting spending in the local area, as well as supporting the vibrancy and vitality of centres and neighbourhoods. As recommended by the CPIER report, a blended spatial strategy is required. Providing homes in central, well-connected areas can also help to ensure residents can access key services and facilities, as well as encouraging access to these by waking and cycling. Co-ordinating economic and housing growth, including considering the needs of people who work from home, could result in people working more locally and reducing in- and out-commuting, leading to reductions in emissions of greenhouse gases and air pollutants. Furthermore, provision of diverse, specialist housing and self-build plots could help to reduce inequalities by ensuring everyone has access to suitable housing.

The Local Plan needs to urgently focus on increasing the affordability of homes in the Greater Cambridge region and ensure that more people can live closer to their workplace and travel to work by walking, cycling and public transport.

Please refer to the Barton Wilmore Greater Cambridge Housing Delivery Study for supporting evidence. In order to accord with Paragraphs 59, 60 and 61 of the NPPF as well as the guidance set out in the PPG covering economic growth and affordability, the GCLP will need to allocate a sufficiently broad range of sites, in size and location, to meet the needs of the Greater Cambridge area. Furthermore, given the conclusions of the Letwin Review (2018), particular attention should be paid to how best to ensure housing need is met at all points throughout the local plan period, with sufficient variety to aid choice for the whole community and therefore increase market absorption.

The local Plan needs to allocate sufficient housing land across Cambridge City and South Cambridgeshire to help settlements at all levels of the hierarchy to become more sustainable while safeguarding the Plan against inevitable delays and uncertainty in the delivery of large projects such as Cambridge East. Allocations on the edge of villages with some service provision, close to sustainable modes of transport, such as the land at 13 Newton Road, Little Shelford should be considered favourably.

The new housing stock should all be accessible to wheel chair users (as visitors – this includes having access to the property, and to toilets within it). Sufficient properties, large and small, should also be available for families with wheelchair users (including adequate bathing facilities)

The median cost you have quoted for renting a two-bed house in Cambridge seems very low to me. I can't think of a single friend who is renting a 2-bed for that low a price. That is closer to the price for a one-bed apartment (if not still too low). Most people are paying over £600 for one bedroom in a HMO with 3+ bedrooms and no proper living areas. This may be beyond the remit of the local plan, but I'll mention it just in case. Please have some policies to make landlords provide and maintain a higher quality of rental property. It is one thing to have to pay so much money, but to be paying it for low quality, inefficient, unsustainable, cold, mouldy and expensive to run properties with landlords who do not care about fixing them is soul destroying and directly leads to unhealthy lives through health conditions and stress. Multiple occupancy housing with no living space (people have to eat dinner in their bedrooms) and no choice of housemates is also soul destroying. Our local planning policies should not allow such buildings. Tighter rules to stop landlords exploiting the system may dissuade them from 'investing' in Cambridge and help to make a more reasonable rental market. In the rush to provide more accommodation in Cambridge a lot of poorly designed rubbish has been allowed. We must ensure quality of design to ensure people's wellbeing and the longevity and sustainability of these properties and prevent future slum-like housing. The K1 cohousing development is a great example and this should be encouraged. The process the K1 community had to go through should not have been so onerous and the design of the community and buildings was actually compromised by inappropriate planning rules. How can an aspirational development like that be compromised by planning rules while so many developers get away with building rubbish in other parts of of the same authority?

It is paramount to ensure sufficient homes are planned and agree that a lack of supply since the 1970's has been the major contributing factor to the affordability issue identified in this Section and the effect on social inclusion. (As referred to in the Greater Cambridge Housing Strategy (GCHS) for South Cambridgeshire, ensuring its villages remain vibrant and sustainable, and working with local businesses to ensure homes are affordable and available to local workers) The impact of house prices being disproportionate to earnings is also a major contributing factor on the size and tenures being delivered. Again, providing the negative effect for those in housing need having the ability to access a decent home. The land resource as demand outstrips supply not only requires developers to pay more but as there is an over reliance on major schemes in the two adopted plans very few smaller builders can raise the required finance to enter into the market. The new Plan therefore needs not only to focus on quantum but also both the location and size of the proposed sites. Development in rural communites can be sustainable and suggest that in the villages with local services accessible to the local population more sites should be made available for: 1. Small Medium Enterprises - Whilst South Cambs Local Plan has a maximum of 8 dwellings that would be considered for an infill site this process should identify edge of settlement opportuntiies that are sustainably located as allocations to boost the availability for these housebuilders. Such site could be comparable to windfall sites but to boost the supply in addition to windfalls sites of between 1 to 30 dwellings should form part of the Plan.This view is supported in the GCHS where within priority 02 (p21) it states: "Both councils want to promote diversity in the market, to help speed up delivery and provide a wider range of housing options. We are keen to work with SME builders to bring forward smaller sites that provide variety in the market to meet local needs. The councils will seek to identify land to accommodate at least 10% of our housing requirement on sites no larger than one hectare, in accordance with the National Planning Policy. This will help to ensure that land is available for small to medium sized housebuilders to develop." 2. The current custom build local plan policies are deficient. This sector of housing is properly identified as Priority 02 in GCHS Study (p20) but does not go far enought in identifying where the plot supply should be located. Those individuals that want to build a more affordable home that is purpose built for their own needs are unlikley to consider a serviced parcel within a major development and at the housebuilders choice. The custom builder's aspiration is for a unique and independent build strategy where in contrast both the street venacular and the elevational concept would have already been pre-decided as part of the development outline permission for the 5% service plot policy requirement. As part of the Local Plan evidence base there needs to be a specific focused research paper into the take up of custom build housing within the residential schemes this policy has been applied. It is likley that the supply from this source is not adequate to meet the demand and take up. An opportunity lost to boost the housing supply. It could be increased by ensuring a more appropriate supply on the edge of settlements in rural locations; more particulalry service villages such as Bourn. Policy should specify permission would only be granted for good design. Custom build plot clusters could be identified for up to 4-6 dwellings 3. Opportunities could also be provided in the rural settlements for schemes that could deliver more diverse tenures to meet local housing need and social inclusion. Scheme sizes of up to 50 dwellings that have no single tenure greater than 25%-50% of the total would give a platform for all the different tenures. The dwelling types could be related to the specific rural settlement housing assessment. The above points would increase the ability for the Plan to deliver more homes, in the right location to meet the local housing needs. At the same time SME's and custom home builders would be given greater opportunities which defacto would boost the local economy in accordance with the NPPF.

See 2 above.

The Local Plan should focus on provision of 1 and 2 bed homes as discussed until the homeless and affordability issues have been resolved with sensitive single bedroom extensions allowed to accommodate proven family needs.

I emphasise my support for the TRAs response concerning over 50s provision and refer back to my response to Q18

No opinion other than need to be built sustainably with protection of and emphasis on environment.

The NPPF requires the Local Plan to plan for at least 10% of new homes to be built on smaller sites of no more than 1 hectare. The local plan therefore needs to allocate a sufficent amount of smaller sites within sustainable village/edge of village locations across the Greater Cambridgeshire Local Plan area. It is important that these are allocated as well as the large, strategic sites in order to meet the requirements of the NPPF and to ensure that the plan is sound, ensuring delivery across all time periods of the plan, recognising that smaller sites have fewers issues to unlock and can be brought forward often within the first five years of the plan. Sustainable sites such as land north east of Woodside, Longstanton should be looked upon favourably for allocation.

Greater Cambridge faces huge pressures to deliver significant numbers of new homes and employment opportunities. To ensure that all potential sites are available to deliver the agreed housing targets, it will be important to ensure that the Local Plan allocates above what is necessarily required to have the best possible chance of meeting those targets. Previous experience of allocated sites not coming forward for development within anticipated timeframes is expected to continue and will therefore mean targets are not met unless sufficient land is allocated through the plan process. In addition to the availability of land, policies in the Plan should be flexible enough to recognise specific site issues and enable development to come forward without a straight jacket of inflexible requirements which at best may delay delivery and at worst prevent delivery.

The emerging GCLP will need to be consistent with national guidance on meeting housing needs. Paragraph 59 of the NPPF confirms the Government’s objective to significantly boost the supply of housing, and to achieve this by ensuring that a sufficient amount and variety of land for housing is identified. Paragraph 60 expects the standard method to be used to determine the minimum number of houses needed. Paragraph 61 expects the size, type and tenure of housing needs of the community to be assessed and reflected in planning policies, including for example those with an affordable housing need, students, renters and self-builders. Section Id.2a of the Planning Practice Guidance explains how housing and economic needs assessments should be undertaken, including how to calculate local housing needs using the standard method. Paragraph 010 of Id.2a makes it clear that the standard method is the minimum starting point for determining local housing needs, and acknowledges that there may be circumstances where actual housing need is higher than the standard method indicates. As set out in Paragraph 010 the circumstances where increases to housing need that exceed past trends are as follows: there is a growth strategy in place to promote and facilitate additional growth; strategic infrastructure improvements are likely to lead to an increase in the number of homes needed locally; and, an authority has agreed to accommodate unmet housing needs from a neighbouring area. The first two circumstances are relevant to Greater Cambridge. Paragraph 024 of Id.2a explains how the need for affordable housing is calculated, and it is suggested that the overall housing target should be increased where it could help deliver the required number of affordable homes. There is an urgent need to improve the affordability of housing and to boost affordable housing delivery in Greater Cambridge. Therefore, the emerging GCLP should use the standard method to calculate the minimum local housing need, and then make appropriate adjustments taking into account the growth strategies and strategic infrastructure improvements identified for Greater Cambridge, and a further adjustment to ensure affordable housing needs are met.

We support the requirement that the Local Plan should plan for at least 10% of the new homes required to be on small sites no larger than one hectare. We support this objective to ensure that a mix of sites come forward. When public sector agencies are seeking to dispose of such sites themselves they should consider fully what they want to achieve on the site and not just focus on cash receipt maximisation. They should consider whether the site would benefit from higher than policy requirements for affordable housing.

Paragraph 91 of the NPPF seeks to deliver healthy, inclusive and safe places, and identifies a number of approaches to support healthy lifestyles. It promotes social interaction through mixed-use developments, strong neighbourhood centres, street layouts that include pedestrian and cycle connections, and active street frontages for example. It enables and supports healthy lifestyles, by providing green infrastructure, sports facilities, local shops, access to healthier food, allotments, and layouts that encourage walking and cycling for example. NHS England Healthy Towns Initiatives identified ten principles to deliver healthy places, which relate to the provision of health services, meeting local and community health needs, and development design matters. In terms of design matters it is suggested that compact neighbourhoods, active travel, healthy eating opportunities, play and leisure facilities would contribute towards the delivery of healthy places. It is considered that the promoted development at land off Leaden Hill in Orwell would be consistent with guidance and initiatives to support healthy lifestyles. The promoted development is accessible to the services and facilities within Orwell by walking and cycling. There are outdoor play and recreation facilities at Town Green Road, which is within walking distance of the site.

It is a matter of basic soundness that the new Local Plan should meet housing needs over the Plan period by providing the necessary supply of housing. In doing so, the two Councils must allocate a sufficient number and scale of sites to provide realistically deliverable developments, which can come forward as and when they are required and thereby provide a consistent supply of housing. Paragraph 59 of the National Planning Policy Framework (NPPF) sets out the objective of ‘significantly boosting the supply of homes’ and stresses the importance of providing ‘a sufficient amount and variety of land … where it is needed’. The Councils should therefore look to identify a wide range of sites across the full spectrum of development scales to ensure consistent delivery throughout the new Plan period.

By providing for the full quota of intended housing across the plan period in order to significantly boost the supply of housing (as required by NPPF paragraph 59).

Build close to Cambridge, build on the green belt, if you are going to expand communities make sure the community wants to be expanded and if not build stand alone communities. Work out how people are going to move around in the community. Don’t build anywhere that can only be accessed by car. The Cam is running dry this is a tragedy we need to resolve this as a matter of urgency. So there should be a moratorium on all building until the water issue is resolved.

It is vital that the right number of homes are delivered in the right locations. Housing in Cambridge has an important role to play in supporting both the local and national economy, as well as being critical in promoting well-being and achieving positive health outcomes. Cambridge is at the centre of significant housing growth however there is shortage of all types of tenure and in particular a lack of affordable housing. This growth is needed to support the strong and growing economy at the eastern end of the Oxford Cambridge Arc. The provision of a mix housing tenures in a central, wellconnected location can help to ensure residents access services, as well as encourage people to travel by more sustainable means, i.e. walking and cycling. The currently challenges facing the housing market in Cambridge can lead to employers facing issues with the recruitment and retention on staff due to the city’s high house prices and high levels of housing need. Therefore, the co-ordination and the provision of residential and employment use within a site can alleviate some of these concerns by resulting in people living more locally. This reduces commuting which leads to a reduction in the impact on the environment from the air pollution associated with daily commuting.

The emerging GCLP will need to be consistent with national guidance on meeting housing needs. Paragraph 61 of the NPPF expects the size, type and tenure of housing needs of the community to be assessed and reflected in planning policies, including for example those with an affordable housing need and renters. Section Id.61 of the Planning Practice Guidance provides advice on assessing the housing needs of different groups, including those seeking housing in the private rented sector. Section Id.60 provides specific advice on build to rent developments. As set out in Paragraph 001 (of Id.60) it is advised that development plans should include a policy setting out the approach to promoting and accommodating build to rent, including the circumstances and locations where build to rent developments will be encouraged. It is requested that the emerging GCLP will need to assess the demand for private rented accommodation in Greater Cambridge and seek to meet that need during the plan period through a build to rent policy and site specific allocations. Marchingdale Developments Ltd is promoting the land at NIAB Headquarters on Huntingdon Road for a high quality Build to Rent scheme. Marchingdale Developments Ltd commissioned a report to assess the demand for this type of housing in Cambridge. The Build to Rent in Cambridge: Market Research Report (Iceni Projects Limited – March 2019) is submitted with these representations. Please note that both reports are commercially sensitive and should not be made publicly available. In summary, there is recent evidence of a significant increase in the private rented sector, which is driven by strong house price growth exceeding incomes resulting in increasing numbers of younger households unable to buy and therefore renting for longer. The delivery of high quality purpose-built Build to Rent accommodation, as proposed at the NIAB Headquarters site, would increase tenant choice, provide more secure tenancy arrangements, and deliver a proportion of affordable rented accommodation.

Please refer to M&M’s response to question 32.

ARU's mission has always been to transform lives through innovative, inclusive and entrepreneurial education and research. It continues to play a critical role in the educational, research and economic success of the Greater Cambridge area, and has ambitious but realistic plans to ensure that it can continue to make this vital contribution. There are currently just over 11,000 students studying on campus in Cambridge, up around 120 students on the previous year, with further intakes due in May. The year on year increase in numbers is driven by doubledigit growth in both EU and International students: - The EU student population has grown to 1539, a 12% increase on 2018/9 - The International student population has grown to 1962, a 27% increase on 2018/9. Undergraduates make up two-thirds of the population in 2019/20 but Postgraduate Taught student numbers are growing (up 14% on last year). The University has aspirations for further growth, in particular, relating to International, Degree Apprenticeship and Foundation Year courses, of between 5 to 10% over the next 3 years. Higher Education continues to change, making detailed planning for the life of the new Local Plan very difficult. The University would very much welcome the opportunity to discuss its plans in more detail as the Local Plan process continues. Support for University development To ensure that the University of Cambridge and ARU can continue to modernise and maximise their contributions to the educational, research and economic success of the Greater Cambridge area, it is important that the new Local Plan recognises and makes provision for the planned growth. To do this, policies in the new Local Plan need to positively support University development. Policy 43 in the Cambridge Local Plan 2018 states that University Development in the City Centre will be permitted subject to criteria whereas University Development outside the City Centre will be treated on their merits. East Road marks the city centre boundary in that Plan with land to the northwest of the road being inside and land to the southeast of the road being outside the city centre. The Local Plan 2018 acknowledges that the East Road site and area remain the most sustainable location for ARU and the University is keen to continue to concentrate its provision in this area, but the consequence of the spatial differentiation in policy 43 means that development on the University’s East Road campus, which is adjacent to but outside the city centre, and its site at Young Street site will be judged on their merits rather than being permitted (subject to criteria). The new Local Plan needs to include explicit support for modernised and enhanced provision on ARU’s East Road site and area. Student Accommodation It is important that the new Local Plan recognises, is consistent and makes provision for the expected growth in student numbers and need for accommodation. Paragraph 5.28 of the Cambridge Local Plan 2018 refers to catering for growth in student numbers (at ARU) whilst paragraph 6.14 contradicts this by stating that ARU has confirmed that it has no growth aspirations to 2026. It is acknowledged that the increasing demand for accommodation from students can put pressure on the general housing market. The National Planning Policy Framework 2019 requires sufficient land to come forward to meet the housing needs of different groups, and makes specific reference to students in this regard (paragraph 61). The implications of the wording of Policy 46 of the Cambridge Local Plan 2018 will unduly limit the opportunities to make the required provision for additional student accommodation. The policy states that “Permanent purpose built student accommodation will not be supported on sites allocated for housing, or with an extant planning permission for residential development, or sites identified as potential housing sites within the Council’s Strategic Housing Land Availability Assessment”. Such a wide ranging exclusion together with policies that seek to protect other land uses, unduly limits the opportunities to provide student accommodation. Rather than unduly limit opportunities to provide the required provision for additional student accommodation, the new Local Plan needs to ensure that it provides for sufficient land to meet all the housing needs, including Student accommodation. Masterplan The University is preparing a masterplan for its East Road campus and is keen to ensure that it has a clear, recognised standing as a material planning consideration in the determination of subsequent planning applications. We are keen to continue discussions on how this might be achieved, which could include being a supplementary planning document to a policy hook in the new Local Plan.

There should be flexibility within the Local Plan to respond to changing housing needs over the Local Plan period. It is important to identify a baseline housing need but there should be scope for further development to come forward if it meets a particular housing need. This would support the Government’s objective of significantly boosting the supply of homes to ensure that a sufficient amount and variety of land can come forward where it is needed and that the needs of groups with specific housing requirements are addressed (NPPF paragraph 59). 7.2 The Local Plan should also allow for a range of tenure types to come forward. In accordance with the NPPF, this includes affordable rent, starter homes, discounted market housing and other options such as build to rent/private rented sector. The Local Plan should be flexible in relation to the mix of housing tenures, to ensure that the Plan can respond to changing needs throughout the Plan period.

See response to question 32.

6.1 There should be flexibility within the Local Plan to respond to changing housing needs over the Local Plan period. It is important to identify a baseline housing need but there should be scope for further development to come forward if it meets a particular housing need. This would support the Government’s objective of significantly boosting the supply of homes to ensure that a sufficient amount and variety of land can come forward where it is needed and that the needs of groups with specific housing requirements are addressed (NPPF paragraph 59). 6.2 The Local Plan should also allow for a range of tenure types to come forward. In accordance with the NPPF, this includes affordable rent, starter homes, discounted market housing and other options such as build to rent/private rented sector. The Local Plan should be flexible in relation to the mix of housing tenures, to ensure that the Plan can respond to changing needs throughout the Plan period.

6.1 There should be flexibility within the Local Plan to respond to changing housing needs over the Local Plan period. It is important to identify a baseline housing need but there should be scope for further development to come forward if it meets a particular housing need. This would support the Government’s objective of significantly boosting the supply of homes to ensure that a sufficient amount and variety of land can come forward where it is needed and that the needs of groups with specific housing requirements are addressed (NPPF paragraph 59).

It is a statutory requirement for Local Plans to address the housing requirements of their local plan area. This includes providing strategic policies to identify the requisite scale of development as well as the quantum of development, particularly housing numbers to meet the identified need of the Plan area over the established Plan period and reflect economic growth requirements. Paragraph 20a of the National Planning Policy Framework asserts that Plans should make sufficient provision for multiple elements of development, including housing, retail and other commercial development. As such, it is a fundamental priority for the emerging Local Plan to ensure that an appropriate objectively assessed need, underpinned by the relevant evidence, is identified and that this need can be realistically delivered over the Plan period. The Plan should also engage a deliverable spatial strategy that has the ability to provide a basis for growth that can accommodate the necessary housing requirement. The adoption of a realistic spatial strategy will contribute towards the Plan's ability to satisfactorily deliver the requisite housing numbers over the Plan period. An effective spatial strategy should consider all options in terms of locations and the distribution of development. Given that the Greater Cambridge area includes vastly different spatial characteristics, ranging from dense urban landscapes to rural village locations; the spatial strategy should positively respond by allowing for a distribution of development and varying spatial options to accommodate development. It is considered that no single spatial option represents the most appropriate approach and instead the Plan should adopt a flexible approach to its emerging spatial strategy, by not precluding any possible avenues at this early stage. Southern & Regional Developments (Joscelyn) recognise that large quantums of development for housing and employment purposes are best focused upon the larger settlements and sustainable expansion of Cambridge. Alongside this the strategy should seek to provide development opportunities at smaller settlements where growth can be accommodate through amendment to Development Frameworks. Achieving development at sustainable settlements across the hierarchy would be able to deliver affordable homes and also provide new houses to address high house prices within rural locations where the lack of new housing stock has artificially inflated values. Summary of Comments: Adoption of a flexible and considered spatial strategy will contribute towards delivering the housing numbers the Plan needs to meet demand.