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

It is recognised that the Greater Cambridge Local Plan will seek housing growth to be directed to urban areas, such as Cambridge City and South Cambridgeshire’s larger rural centres. The urban locations can, however, have their own constraints on land availability and limit the potential nature and type of housing. The opportunity exists within the villages, such as Fowlmere, to assist with providing a range of housing types, including starter homes, affordable housing and family housing. There is also the promotion and need for self-build developments, which development on the edge of villages could assist with providing. Through directing this form of development to the villages within the authority this would promoted inward investment into the villages, support the existing community through providing options for people to remain in the village. The approach therefore needs to be balanced, so that villages are not forgotten about and where there is investment into villages, a mix of tenure of housing needs should be provided within the villages to support and enhance the sustainable credentials of the village. The larger rural settlements are already subject to significant housing growth and therefore there is scope to consider allocating residential development across the smaller settlements, such as Fowlmere. Medium scale development in the villages will ensure that a range of housing types in a range of different settlement across the area are delivered, catering for various different demands in the area and maintaining communities in a sustainable way.

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).

2.18 The National Planning Policy Framework 2019 Glossary highlights the diverse range of needs that exist. For example, the health and lifestyles of older people will differ greatly, as will their housing needs, which can range from accessible and adaptable general needs housing to specialist housing with high levels of care and support. 2.19 The new Local Plan will need to be underpinned by robust evidence on the need for older people housing. This is reiterated in the Government’s National Planning Practice Guidance, which states: “For plan-making purposes, strategic policy-making authorities will need to determine the needs of people who will be approaching or reaching retirement over the plan period, as well as the existing population of older people” (Paragraph: 003 Reference ID: 63-003-20190626; and “an understanding of how the ageing population affects housing needs is something to be considered from the early stages of plan-making through to decision-taking.” (Paragraph: 001 Reference ID: 63-001-20190626). 2.20 The NPPG also recognises that new innovative and diverse housing models will need to be considered where appropriate (Paragraph: 012 Reference ID: 63-012-20190626). 2.21 There is a significant undersupply of older people accommodation across Greater Cambridge. Bidwells Socio-Economic team undertook a review of care home need alone in Greater Cambridge and found that the demand for bed spaces is projected to exceed supply from 2027 onwards; this does not account for all other types of older people housing. The new Local Plan should, therefore, allocate land for C2 housing to meet the unmet need. This will provide greater certainty for developers and encourage the provision of sites in suitable locations.

Southern & Regional Developments (Willingham) recognsies that it is a statutory requirement for Local Plans to address the housing requirements for their local plan areas and tht this needs to influence the emerging plan. 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. 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 also needs to engage with a deliverable spatial strategy which can provide the basis for the growth that is required to meet this 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 however will need to consider all options in terms of locations for new development. Given that the Greater Cambridge area includes vastly different spatial characteristics, including dense urban landscapes to rural village locations, the spatial strategy will need to take this into account when it reviews the spatial options for development. It is considered that no single spatial option represents the most appropriate approach and therefore, the Plan should adopt a flexible approach to its emerging spatial strategy, by not precluding any possible avenues at this early stage. Claremont Planning recognises that large quantums of development for housing and employment purposes are best focused upon the larger settlements and sustainable expansion of Cambridge, but the importance of sustaining existing communities in smaller sustainable developments is advanced as a key consideration on behalf of Southern & Regional Developments (Willingham). As such the strategy should seek to provide development opportunities at smaller settlements where growth can be accommodated through amendment to settlement boundaries and 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 articfically 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.

4.1 Figure 19 of the Issues and Options document shows a serious concern regarding growth in Cambridge. As noted, average house prices in Cambridge are more than double the national average, with South Cambridgeshire significantly above the national figure. It is an expensive place to live and is especially difficult for young professional to get on the property ladder given the price of housing in comparison to other areas of the country. The rental market also suffers from inflated prices. 4.2 The Local Plan provides an opportunity to address this balance. In order to ensure affordability in the future, the Local Plan must include a range of land types for housing provision, and this must include small and medium sites in line with paragraph 68 of the National Planning Policy Framework (NPPF). Such sites help ensure early delivery of housing and do not suffer from longer lead-in times given the limited infrastructure requirements. 4.3 The Local Plan must ensure that appropriate housing numbers within the area are planned for in order to lower the house price to income ratio and ensure that house purchase remains an option for residents.

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 Para. 59). 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

2.26 As per the NPPF, the Planning Practice Guidance and the Planning Inspector’s Report on the South Cambridgeshire Local Plan (2018), the Greater Cambridge Local Plan should meet housing needs through the development of small scale sites, such as those land south of Barley Road, as well as large strategic sites. 2.27 The NPPF concludes at paragraph 68 that “Small and medium sized sites can make an important contribution to meeting the housing requirement of an area, and are often builtout relatively quickly.” This can be achieved by ensuring allocation of a higher number of small to medium sized sites, and avoiding focusing solely on large strategic allocations, helping to speed up the delivery of homes. 2.28 Additionally, the Planning Practice Guidance identifies the need to consider a range of sites for development, including small scale sites in villages and towns. Indeed, the Planning Practice Guidance expressly calls for strategic planning policies to recognise the particular challenges faced by rural communities, including in respect of housing supply and housing affordability. It confirms that a wide range of settlements can play a role in delivering sustainable development, and cautions against blanket policies which restrict development in certain types of settlement. 2.29 As set out elsewhere in this representation, but to reiterate, it is important to ensure that new homes are provided to support all of the area’s communities, and that development is not solely focused on larger settlements.

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 positvely 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. Claremont Planning recognises that large quantums of development for housing and employment purposes are best focused upon the larger settlements and sustainable expansion of Cambridge, but the importance of sustaining existing communities in smaller sustainable developments is advanced as a key consideration on behalf of Southern & Regional Developments (Waterbeach). As such 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 articfically 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.

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.

• The policy of 40% affordable housing must be continued and rigorously enforced by the Councils. The use by developers of Viability Assessments as a justification to reduce the proportion of affordable must be resisted, and all viability appraisals must be transparent, publicly available, and subject to independent scrutiny. We don’t feel that the current system works and would suggest that this is an issue that needs to be addressed through an independent expert body that could act on behalf of the local authorities. • Developers have now had long enough notice that they are required to provide 40% affordable that this should have been factored into the land-value and therefore, going forward, viability assessments should not be used to avoid 40% affordable. If developers overpaid for the land then why should that impact those who can least afford housing? • Large developments should include housing provision for key workers. As well as those people who work in the public sector in roles that are vital to the infrastructure of the community, such as teachers, police officers, armed forces personnel and National Health Service, we believe that key workers for Cambridge should also include care workers, laboratory technicians, low paid public service workers and support workers (cleaners, porters, etc). • Large developments should provide a variety of housing options for different markets in order to achieve faster rates of completion - for example, the inclusion of private rented, social rented, retirement, self-build, etc, as recommended in the Letwin Report. • ‘Affordable housing’ is still unaffordable to those on the Councils’ housing list, so both Councils should explore with central government mechanisms to maximise the proportion of Councilowned new housing for affordable rental and other types of tenure. • The Local Plan should adopt the recommendations of the Building Better, Building Beautiful Commission when it reports in 2020.

It is reasonable for the Greater Cambridge councils to plan for more homes than the standard methodology requires, as the standard methodology is a minimum figure. A higher need can be planned for such as taking into account economic circumstances. However, the Plan indicates potential for a substantial over provision of over a thousand more homes above that required by the standard methodology. The wider impact of this level of growth would need to be assessed, including the impact on local and strategic infrastructure such as the A14, park and rides, and platform capacity at Cambridge Station.

East West Rail (EWR) represents a unique opportunity for the combined authority to set and deliver an aspirational target for housing growth in the local plan area. The railway has the potential to unlock land for housing delivery, providing a significant opportunity to allocate high numbers of residential allocations, in line with national aspirations for the Arc. Recommendation The combined authority should seek to allocate significant land for housing (as well as employment) on land unlocked by the EWR project in order to meet the aspirations of the UK government for the Arc. This is consistent with the aims as set out in 4.6 of the Issues and Options Paper, which states that “If we do not plan for enough homes, this could worsen affordability, limit our local economy, damage social inclusion, and have implications for climate change as people travel further to access jobs.”

To meet our needs, we need to know our needs. A record of those needs to be made available to all and particularly to developers so they can design towards those needs meaning that developers work towards meeting those needs, and not towards making the greatest profit. New homes are expected to be highly efficient with regards to energy and water conservation. Housing mix is also an essential point here as communities should be mixed and not one demographic. New housing should be built for a range of family sizes, income bracket and a range of ages.

• The Local Plan must prioritise the construction of high quality ‘affordable’ homes (the current policy of 40% should be continued), and the percentage agreed at any planning approval must not be amended downwards as a result of spurious ‘economic viability’ assessments by developers. The ‘affordable’ homes (whether shared-equity or for rent) must be integrated into the wider development to help social unity. Green spaces and adequate gardens are essential to provide an environment that is healthy, promotes community and a place to be proud of. • The variety of housing options should be expanded to include both cohousing and self-build.

1.19 If the Councils do not plan for enough homes for the Greater Cambridge area this will worsen the existing affordability issues, limit the benefit that the area has for the local and national economy, damage social inclusion, and have implications for climate change as people travel further to access jobs. 1.20 The adopted strategy of large new settlements and urban extensions takes years to deliver and whilst they deliver new housing they have consistently under-delivered on affordable housing due to the significant infrastructure needed to develop the sites. This isn’t just the case with brownfield sites like Northstowe and Wing. Large greenfield sites like Cambourne West also under-delivered on affordable housing with only 30% and a tenure split that did not accord with the District Council’s affordable housing SPD. 1.21 The Councils should look to maximise the use of land in existing sustainable locations, rather than new locations that need significant infrastructure to make them sustainable. The expansion of existing development sites, or the development of land on the edges of the more sustainable rural settlements, will maximise the use of existing social and transport infrastructure and minimise disruption to existing communities. 1.22 Development frameworks are a negative planning tool that are too rigidly enforced without officers being given the ability to use their sound planning judgement. A relaxation of development frameworks would allow for a large number of new homes to come through as windfall sites. If priority were given to self-build plots on the edge of villages, where all other material planning considerations could be satisfied, then this would also help the Councils to address their statutory obligation to deliver self-build plots in the Greater Cambridge area. 1.23 There should be a greater focus on small and medium size developments on the edges of the District’s more sustainable rural settlements that can be build out quickly and where residents are more easily integrated into existing communities. Our clients site offers the flexibility of being either a stand-alone site or an early phase of a larger allocation for the village. Either way, the site is capable of delivering new homes in this sustainable location that is likely to include a policy compliant level of affordable housing. The proposals for a larger scheme would also include a retirement village to cater for the changing needs of the Greater Cambridge area.

1.19 If the Councils do not plan for enough homes for the Greater Cambridge area this will worsen the existing affordability issues, limit the benefit that the area has for the local and national economy, damage social inclusion, and have implications for climate change as people travel further to access jobs. 1.20 The adopted strategy of large new settlements and urban extensions takes years to deliver and whilst they deliver new housing they have consistently under-delivered on affordable housing due to the significant infrastructure needed to develop the sites. This isn’t just the case with brownfield sites like Northstowe and Wing. Large greenfield sites like Cambourne West also under-delivered on affordable housing with only 30% and a tenure split that did not accord with the District Council’s affordable housing SPD. 1.21 The Councils should look to maximise the use of land in existing sustainable locations, rather than new locations that need significant infrastructure to make them sustainable. The expansion of existing development sites, or the development of land on the edges of the more sustainable rural settlements, will maximise the use of existing social and transport infrastructure and minimise disruption to existing communities. 1.22 Development frameworks are a negative planning tool that are too rigidly enforced without officers being given the ability to use their sound planning judgement. A relaxation of development frameworks would allow for a large number of new homes to come through as windfall sites. If priority were given to self-build plots on the edge of villages, where all other material planning considerations could be satisfied, then this would also help the Councils to address their statutory obligation to deliver self-build plots in the Greater Cambridge area. 1.23 There should be a greater focus on small and medium size developments on the edges of the District’s more sustainable rural settlements that can be build out quickly and where residents are more easily integrated into existing communities. Our client’s sites at Bennell Farm offer one such opportunity to deliver new homes in this sustainable location with a policy compliant level of affordable housing.

Housing schemes should, where appropriate, make provision for housing to meet a range of needs from homes for first time buyers through to later living provisions. It should also include a proportion of affordable housing. The development proposals for Meldreth will provide a range of house types and sizes to provide for the needs of different groups in the community. The indicative master plan would also make provision for a policy compliant level of affordable housing.

Delivering significant numbers of new homes in the Local Plan is vital for the continuing prosperity of the area. The CPIER economic report identifies that without sufficient homes to accompany new employment, employers will look elsewhere, including potentially outside of the UK. The steadily increasing house prices in Cambridge and the surrounding region make it one of the most unaffordable locations to live in the country (ibid). A continuation of the trajectory of increasing house prices will see inequality increase as those on lower earnings are priced out of the area. MGH agrees with the issues raised by the Issues and Options report, that if insufficient housing is built to meet local need this will result in: - - worsening affordability; - damage to the local economy; - damage to equality and social inclusion; - adverse implications arising from climate change; and - adverse impacts on the ability of people to live healthy lives. The government has been clear that the Oxford Cambridge Arc should support economic growth. To do so will require housing to support the growing local work force. The Cambridgeshire and Peterborough Growth Deal* is predicated on the delivery of increased employment growth. The CPIER indicates that in order to realise the growth that could be delivered, a total of some 2,900 homes per year will be needed. If such levels cannot be reached, the Local Plan will fail in its ambitions to deliver other key objectives in terms of social and environmental improvements. MGH strongly agrees that the Local Plan should provide for higher levels of housing growth to support a strong economy, in accordance with government policy. * Cambridgeshire and Peterborough Devolution Deal

2.1 Figure 19 of the Issues and Options document shows a serious concern regarding growth in Cambridge. As noted, average house prices in Cambridge are more than double the national average, with South Cambridgeshire significantly above the national figure. It is an expensive place to live and is especially difficult for young professionals to get on the property ladder given the price of housing in comparison to other areas of the country. The rental market also suffers from inflated prices, whereby monthly renting costs are well above the national average. 2.2 In addition to causing stress for individual households, a lack of housing and worsening affordability has the potential to cause significant negative impacts on the local economy, communities and the environment. 2.3 The Local Plan provides an opportunity to address this balance, but in a sustainable manner that minimises impact upon the environment, and makes de-carbonisation a priority. In order to ensure affordability in the future, the Local Plan must include a range of land types for housing provision, and this must include small and medium sites in line with paragraph 68 of the National Planning Policy Framework (NPPF). Such sites help ensure early delivery of housing and do not suffer from longer lead-in times given the limited infrastructure requirements. However, The Local Authority must set clear objectives for provision of affordable housing and carbon reduction to ensure that these are enshrined in policy in a manner that is clear to landowners when factoring in sale and purchase of land. 2.4 The Local Plan must ensure that appropriate housing numbers within the area are planned for in order to lower the house price to income ratio and ensure that house purchase remains an option for residents.

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.

Affordable social rent properties are needed most. To build inclusive, sustainable communities ‘Life-Time’ homes should be the norm. Numbers and mix should be prescribed.

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 positvely 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. Claremont Planning recognises that large quantums of development for housing and employment purposes are best focused upon the larger settlements and sustainable expansion of Cambridge, but the importance of sustaining existing communities in smaller sustainable developments is advanced as a key consideration on behalf of Southern & Regional Developments (Swavesey). As such 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 artifically 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.

This new Local Plan should seek identify a suitable housing requirement that balances with the economic growth ambitions of CCC/SCDC and the wider area. The new Local Plan should seek to identify and allocate sites that are sustainably located and provide the best opportunity to tackle and progress the four big themes identified in the Issues & Options. One of the Key Recommendations of the Cambridgeshire and Peterborough Independent Economic Report (CPIER)(2018) states that there should be a review of housing requirements based on the potential for higher growth in employment. It advises that dialogue with the ONS and the Centre for Business Research on employment numbers, as well as the impact on Cambridge-Milton Keynes-Oxford Arc, should be used to set new targets that are likely to be higher than those already set (Page 12). The report recognises that "no economy can achieve its potential without an adequate supply of housing" (Page 12). Therefore, it is our view that the standard method is used as a starting point for calculating OAN and that GCPS should seek to increase this target by positively responding to the evidence base, the findings in the CPIER and the Government's ambitions for the Ox-Cam corridor.

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 positvely 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. European Property Ventures (Cambridgshire) recognises that large quantums of development for housing and impeloyment 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.

7.1 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 Para. 59).

It should take a need-led approach and apply modern modelling techniques to forecast the resulting demand. The skills are available in the City and its two universities. The current conflation of ‘need’ with ‘demand’ is causing a situation where numbers matter more than type and tenure of housing. See CPRE’s study at: https://www.cpre.org.uk/wp-content/uploads/2019/11/HousingZForesightZPaperZ8.pdf There has to be a better approach than the ‘5-year housing supply’ currently imposed by the NPPF.

2.6 Summary Answer: The Local Plan should allocate the widest possible range of sites in order to provide choice, affordability and diversity in the market. The Letwin Review, published in October 2018, placed a clear emphasis on the need to tackle the homogeneity of homes on offer and diversify the types and tenures on offer on large sites. Smallmedium sized sites play an important role in providing a wide variety of house types, tenures, sizes and mix and also deliver quickly compared to larger sites. In accordance with paragraphs 67 and 68 of the NPPF, strategic policy-making authorities should identify a sufficient supply and mix of sites over the local plan, including at least 10% of their requirement on sites no larger than one hectare. 2.13 In responding to questions 31, 32, 37, 40, 41, 47 and 48, it is important to note that paragraph 78 of the NPPF states that to promote sustainable development in rural areas, housing should be located where it will enhance or maintain the vitality of rural communities. It goes on to promote planning policies that identify opportunities for villages to grow and thrive, especially where this will support local services. 2.14 Frameworks have been defined to take account of the present extent of the built-up area and planned development, but the level of planned development has been notably limited by the application of the settlement hierarchy (Policies S/7 - S/11 of the South Cambridgeshire Local Plan, 2018) and the principle that development can only occur within the settlement framework boundary. This is evident in the categorisation of South Cambridgeshire’s ‘Group’ or ‘Infill’ villages and the tightly drawn settlement boundaries, which have created little room for villages to grow. Examples of this are provided in the appended Barton Willmore Housing Delivery Study (2020). 2.15 Taking into account future requirements for housing land supply and housing affordability, it is clear that current settlement boundaries will need to flex in order to accommodate further growth in sustainable locations. As previously mentioned, the settlement hierarchy has defined the sustainability of each village as determinate rather than giving merit to its transformative potential through sustainable development. We are not arguing here for a removal of the settlement hierarchy, but a recalibration measured against levels of services and facilities in each settlement and potential sustainability enhancing measures such as: • Transport improvements that better connect villages to surrounding larger settlements, employment areas or service centres; • Local transport enhancements that provide more sustainable travel options to services and facilities and/or ease of access for satellite villages surrounding larger or better served settlements e.g. new footpaths/cycleways, real time bus stops; • Increasing capacity of local community facilities to better serve local needs; • Provision of new community services and facilities e.g. play areas, new business incubators; • New housing that provides different sizes, types and tenures to meet the needs of different groups in the community and supports a greater demographic mix; • Provision of much needed affordable housing; • Local employment generation; • New or enhanced access to public open space and recreation (i.e. health and wellbeing gains); and • Net gain in biodiversity and opportunities to ‘scale-up’ local green infrastructure networks. 2.16 The above factors present scope to expand village populations in a sustainable way; the degree of expansion will need to be scored against the level of existing and potential sustainability levels. Not all village settlements will be equal in this regard and therefore a scoping exercise will be required to assess each settlement and preferably define an extent of housing supply matched with new housing land allocations. 2.17 Local communities may have a particular view on the needs of their village or where growth opportunities are best located. Similar to the emerging Bedford Local Plan, housing policy could give the option to local communities to steer allocated growth through a Neighbourhood Development Plan or Neighbourhood Development Order (Regulation 16), or if one has not been submitted the Council can consider the need to allocate additional sites. 2.18 There are further benefits to consider through appropriate expansion of rural settlements. Housing sites in rural areas tend to be small to medium in size, which in turn have shorter delivery times than larger sites. Research by Nathaniel Lichfield & Partners ‘Driving housing delivery from large sites: What factors affect the build out rates of large scale housing sites’ (NLP, 2018) shows that the lead-in time for sites of less than 500 homes take 1.7-1.8 years to deliver the first dwelling after receiving detailed planning permission, whereas larger sites of 2000+ homes take much longer (2.9 years).

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 Para. 59). 6.2 There is an identified need for Build to Rent housing in Cambridge. The redevelopment of Land at Cambridge North offers an opportunity to provide a significant amount of rented accommodation in a highly sustainable location, making the best possible use of a brownfield site that is already allocated for residential development.

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 Para. 59). 6.2 Land at Capital Park is considered a suitable location for further residential or commercial development.

At this stage, the average annual requirement for Greater Cambridge is to ensure sufficient land is identified to deliver a minimum 1,800 dwellings per annum (using the Governments standard methodology) or 2,900 dwellings per annum to deliver jobs related growth by 2040. To achieve this, it will need a selection of options and choice of sites to sustain the pace of delivery. There should be a spread of delivery over the period to 2040 to ensure the market can support the step change in the level of growth envisaged through the economic growth model. Introducing further land supply through alternative locations where they are not affected by largescale upfront infrastructure requirements with long lead in periods can enable new communities to be established quicker. For example, utilising planned infrastructure projects to direct growth to areas that have the necessary infrastructure capacity and options to influence delivery rates is key. Taking advantage of this immediate opportunity that new transport connections will offer during the plan period will help create new markets to offer market choice and avoid market saturation. The committed road funding for the A428 should be a key focus for locating new housing where the route unlocks new housing locations through better connectivity and accessibility i.e. facilitating the CAM along the original route; opportunities to increase provision of schools and other services in the rural area. The rationale for creating new communities is to balance development across the districts and improve the relative sustainability of the rural area.