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

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 inclusion of key and essential local worker housing in the local plan is to be welcomed and encouraged. It will be a fundamental part of addressing the real affordability issue in Greater Cambridge and addressing climate change, because ‘local essential worker’ housing will be within a short distance to its employment centre to ensure that sustainable travel is the only real choice for those workers. The benefits of essential local worker housing is well-evidenced by reference to Granta Park. A significant employer and a key part of the research and development sector of the Cambridge area. A number of its employees struggle to find affordable accommodation within a reasonable commuting distance in a location which they can rely on sustainable modes of transport. Essential worker housing will become an increasingly vital aspect of meeting the needs of essential workers at Granta Park, to address affordability, climate change and the health and wellbeing of its employees.

Housing in the right place that our staff can afford The Local Plan will need to deliver a mix of housing sizes, styles and tenures at an affordable price. A key strategic priority for CUH is to support the delivery of more affordable housing for our staff, in the right place. We have submitted two documents in support of our representations: 1) “Assessing the Housing Need of Hospital Workers” report prepared by Savills in January 2020. This is research undertaken on our behalf which highlights the real affordability challenges facing our staff, and some of the less desirable outcomes arising as a result. 2) We have prepared a summary report entitled “Delivering Affordable Housing for our Hospital Workers: The Case for Change”. This is a simple, accessible document, which draws out the key findings of the Savills research, and sets out CUH’s corporate priorities in terms of housing, highlighting the critical importance of delivering of genuinely affordable housing in accessible locations, to ensure the growth and prosperity of the area can be supported by the NHS/ The research highlights housing as one of the key barriers to CUH in recruiting and retaining key staff and skills. To build on some of the recommendations of the report, CUH is seeking to work in partnership with a range of stakeholders to deliver housing at significant discounts on open market rents, and / or more affordable routes to home ownership, located within no more than 40-50 minutes of the Hospital by walking, cycling and public transport. The housing provided should be a mixture of sizes and tenures and where possible measures should be put in place to enable employees to live close to their place of work, in order to reduce commuting time, traffic congestion and impact on air quality and climate change, while improving physical and mental wellbeing.

3.35 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 with discretion for further development if a particular housing need arises. This would support the Government’s objective of significantly boosting the supply of homes where needed and ensure groups with specific housing requirements are properly considered/catered for (NPPF Paragraph 59).

CUHP considers housing to be a key priority and a barrier to the successful growth of the Cambridge Biomedical Campus (CBC), and our ability to continue to attract world-leading occupiers to further the vision for the campus. We are developing early thinking about the housing needs of current occupiers, and those issues raised by prospective tenants and partners at the CBC. We note and support the research in this arena commissioned by our partners and support expanding this research to include others.

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 increases 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. It is also important that the GCLP includes requirements for all type of new homes to meet the needs of first time buyers, those with expanding families and also those who are looking to downsize. GCLP should therefore prioritise the allocation of sites that can include a range of dwelling types and sizes to meet the diverse needs of Greater Cambridge’s residents. The Mill Lane Site, Sawston, offers great flexibility for such a mix of housing types.

6.1.1 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 (e.g. Care). 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 Local Plan should help to meet the needs for the amount and types of new homes required through adoption of a blend of the 6 identified options in the consultation.

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). 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.

Summary: Savills (UK) Ltd are instructed by xx to make representations to the Greater Cambridge Issues and Options Local Plan (January 2020) in respect of their land interests to the north of xx, Bassingbourn-cum-Kneesworth Full text: Savills (UK) Ltd are instructed by xx to make representations to the Greater Cambridge Issues and Options Local Plan (January 2020) in respect of their land interests to the north of xx, Bassingbourn-cum-Kneesworth. The Cambridgeshire and Peterborough Independent Economic Review (CPIER) (2018) suggests that an indicative total of 66,700 homes – subject to further modelling – could be required to meet the economic needs of the region. As noted on page 61 of the Issues and Options plan, the CPIER has found that recent jobs growth in the region has been faster than expected, and this growth is likely to continue. House prices in Greater Cambridge are well above the national average, and economic growth is going to continue to place pressures on the housing market. It is therefore crucial that the Local Plan looks to meet its housing targets across the plan period. It is considered this will be achieved by seeking to provide homes across a variety of different sites as advocated by paragraph 59 of the NPPF (2019). A stepped approach to housing delivery will not be appropriate in an area such as Greater Cambridge where there is already acute affordability issues and, in the past, housing supply has failed to keep up with demand. Three new settlements – Northstowe, Waterbeach and Bourn Airfield – are proposed in the adopted Local Plans. Whilst we recognise the important role new settlements and urban expansions can play in meeting the housing needs of an area, it is important sites which can be delivered in 1-5 years are identified in the Plan. It is therefore considered that the Councils should identify as part of its plan small and medium scale sites in existing villages to ensure a continuing supply of housing which is planned. Failure to do so could result in the Councils not meeting their housing targets and speculative planning applications coming forward.

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).

The Local Plan should plan for sustainable growth around the key settlements in the Greater Cambridge plan area. Key transport links and employment locations should guide growth, creating places that people want to live. The plan should allocate land appropriately and look to direct growth to existing settlements to enable these to grow. The houses provided on sites should help to meet the needs of local people and it is therefore essential to establish what the need is. Whilst many settlements around the city are within the Cambridge Green Belt, there are opportunities to expand those that do not require the removal of Green Belt land. This is particularly relevant for those settlements like Little Abington that are in close proximity to employment sites and have sustainable links into the centre of Cambridge.

2.37. It is acknowledged that the local housing need as informed by the Standard Method calculation identifies a need for a minimum of 1,800 homes per year within Cambridge and South Cambridgeshire. It is strongly recommended to the Councils that the emerging Local Plan should be planning for an increased supply of housing in order to support economic growth aspirations for the area and to ensure the full range of housing is provided to meet the needs of the area particularly with regard to student accommodation. 2.38. 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 aspects of the Local Plan, which necessarily need to be accompanied by housing growth. 2.39. It is also recommended that the emerging Local Plan is informed by a robust evidence base to establish the size, type, and tenure of housing needed in the area.

It is important that the Councils pursue a balanced approach to meeting housing needs through the identification of a range of small, medium and larger site allocations (NPPF para 68). Whilst large new housing allocations can offer attractive delivery rates over a sustained period, early and fast delivery can also be achieved through small and medium sized sites. The Local Plan should adopt a balanced approach to site identification, including a range of sizes and locations that allow the house-building industry to respond flexibly as the market fluctuates and develops. This will ensure a steady supply of new homes is provided throughout the Plan period such that the Councils are able to maintain a 5-year housing land supply. Over-reliance on large sites risks under-delivery in the early years, a dip in supply resulting in speculative applications and appeals. Inclusion of a healthy supply of small and medium sized sites will help to avoid this. It is also important to ensure planned housing growth is matched by public investment in necessary infrastructure so as not to burden development sites with additional costs that inevitably impact on the ability to achieve affordable housing policy targets.

5.1 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). 5.2 Harston is considered a suitable location for further residential development to support an existing rural community. The proposed residential development on Land to the south of Station Road is considered suitable and proportionate in relation to the size of the village. A number of services and facilities are within walking distance of the site including the Harston and Newton County Primary school located opposite the site, a doctor’s surgery, a post office, village hall, public houses and a convenience store. The primary school has capacity for additional pupils. By allocating residential development on the site, this would help to maximise opportunities for sustainable travel and residents would not be overly reliant on using cars to access services. Land to the south of Station Road is therefore considered an appropriate location for a residential site allocation in the Local Plan.

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 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. 6.3 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. 6.4 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 6.5 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. 6.6 Wates Developments are proposing a sustainable village extension along the western side of the village. The housing need across the district is well established and delivering new homes in the rural area is considered an important part of the Council response to meeting this need. Fowlmere is a sustainable location for residential development, development will help support local services and help provide employment opportunities. In assessing sustainability of a rural village, it is important to recognise the interconnection between villages and assess their suitability on this basis.

4.44 The evidence within the GCLP demonstrates the higher housing costs and the overall issues of affordability in the area. The Plan seeks to “… get the right homes in the right places so that everyone has the chance to live settled, healthy lives.” This however requires a broad and flexible approach to housing across the area. At present the councils’ focus has been on a number of significant expansions Darwin Green and North West Cambridge and new settlements like Northstowe and the new town north of Waterbeach. The larger strategic sites often have a long lead in time due to infrastructure provision and a community feeling takes time to establish. It is essential to ensure a variety of site sizes come forward to ensure delivery across the district. 4.45 This would ensure the opportunity for a mix of house types and tenures to come forward. The opportunity to downsize and free up family housing and provide lifetime homes is also an important point and potentially requires a difference approach to densities that will allow smaller units with flexible room sizes that support people in their existing local communities as their life- time requirements change.

4.43 The evidence within the GCLP demonstrates the higher housing costs and the overall issues of affordability in the area. The Plan seeks to “… get the right homes in the right places so that everyone has the chance to live settled, healthy lives.” This however requires a broad and flexible approach to housing across the area. At present the councils’ focus has been on a number of significant expansions Darwin Green and North West Cambridge and new settlements like Northstowe and the new town north of Waterbeach. The larger strategic sites often have a long lead in time due to infrastructure provision and a community feeling takes time to establish. It is essential to ensure a variety of site sizes come forward to ensure delivery across the district. 4.44 This would ensure the opportunity for a mix of house types and tenures to come forward. The opportunity to downsize and free up family housing and provide lifetime homes is also an important point and potentially requires a difference approach to densities that will allow smaller units with flexible room sizes that support people in their existing local communities as their life-time requirements change.

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.

According to the NPPF, the Planning Practice Guidance (PPG) 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 a range of housing sites. While the existing strategic allocations and new settlements are an important component of housing delivery, paragraph 68 of the NPPF advises that “Small and medium sized sites can make an important contribution to meeting the housing requirement of an area, and are often built-out relatively quickly.” The existing planning strategy places a significant reliance on the strategic allocations around the City and also the development of new settlements which the local plan inspectors raised concerns about. The new local plan should significantly increase the allocation of small to medium sized sites in the rural areas, helping to speed up the delivery of homes and allowing more flexibility. It is important that the rural areas are not left behind but allowed to prosper and thrive. It will be necessary for the new local plan to identify at least 10% of the housing allocations on sites no larger than one hectare (NPPF para 68 (a)). This coupled with medium sized allocations will provide greater potential to deliver a more diverse range of sites, better suited to local need, and better able to respond to market conditions. It will ensure that not all the growth is focused on the City but also supports the parallel growth of the rural economy. In terms of housing numbers the Cambridge & Peterborough Independent Economic Review identified that the recent growth in employment has not been matched by corresponding house-building and that ‘We are rapidly approaching the point where even high-value businesses may decide that being based in Cambridge is no longer attractive. If nothing is done, the damage to society from the continuing drift away of less well-paid workers may become irreparable’. To support the job growth, around 2,900 homes would need to be built each year to deliver a total of 66,700 homes between 2017 – 2040 rather than the 1,800 homes per year using the Government’s standard methodology. The PPG (paragraph 10) makes it clear that the standard method is only a minimum starting point. This higher level of growth is supported and necessary to help deliver the Cambridgeshire and Peterborough vision of doubling the total economic output of the area over 25 years. If the high target of 66,700 dwellings is used, then small sites of 1 hectare or less will need to deliver 6,670 dwellings. Given the rural nature of the plan area if 25 dwellings to the hectare were applied, this would equate to 266 sites. While it may be possible to identify some sites in and arround the City, it is likely the majority of the smaller sites will need to be found in and around the settlements covered in by polivies S/8, S/9, S/10 and S/11 of the existing South Cambridgeshire Local Plan which total 106 settlements. If these were to allocated proportionately it would equate to at least two sites per settlement. Obviously, if a larger proportion of sites are smaller than 1 hectare the total number of sites will be increased. Increased allocations on small and medium sized sites will increase delivery and help improve affordability through increased supply. A wider range of sites will also allow more flexibility in the mix, type and tenure of homes delivered. It will be important to take a flexible approach to development proposals designed to meet the needs of an aging population, a growing demographic group who’s needs will need to be accommodated over the plan period. The allocation of Scott properties site in Kneesworth would fulfil all the above objectives and while the sites individual contribution to the total housing need referred to above would be modest, it would make an effective and proportionate contribution to a specific need at the local level. Summary of Comments: The new Local Plan will need to allocate a significant number of new small and medium sized sites, to support prosperous rural economy.

The NPPF requires Local Authorities to plan positively, in a way that is aspirational but deliverable. The objectives stated in the Issues and Option document provide the right emphasis on the issues to be challenged the Plan period. The document is supported by the Greater Cambridge Housing Strategy 2019 - 2023, which identifies a need for more diverse provision of housing across the local authority areas. The population of Greater Cambridge is expected to increase by around 26% between 2011 and 2031. The current Government ‘Standard Method’ indicates a need for 1,800 homes a year, or 40,900 new homes over the proposed Plan period of 2017-2040. It should be noted that the ‘Standard Method’ provides a minimum starting point – there should be consideration during the plan-making process of whether other factors indicate that the target should be increased above the figure derived from the standard method. It is noted that South Cambridgeshire District Council has a track record of the under-delivery of housing generally. Whilst there is a 20% buffer applied as part of the Local Plan, it is considered that consistent under-delivery over the Plan period will affect the requirement for housing in the new Plan period. In terms of affordable housing more specifically, the 2019 Annual Monitoring Report shows that only 25% of housing delivered was affordable. The Greater Cambridge Housing Delivery Strategy acknowledges the unaffordability of housing within Cambridge, and states that a greater proportion of affordable housing is required in the greater Cambridge area. The Council will need to consider, as set out in paragraph 2a-024 of PPG, whether an increase in the total amount of housing is necessary to help deliver the required number of affordable homes. In terms of rural housing need, it is recognised in the Greater Cambridge Housing Strategy that, particularly for South Cambridgeshire, the Plan needs to ensure "its villages remain vibrant and sustainable, and working with local businesses to ensure homes are affordable and available to local workers are high priorities for the District". To meet the housing needs of the Local Plan area, it is considered a flexible approach to the allocation of sites across a number of locations across the boroughs will be required. This will require the allocation of larger sites in order to deliver large quantities of housing to meet significant need, but also in the allocation of smaller sites in rural towns and villages in order to ensure sustainable growth. When considering housing within rural areas, paragraph 77 of the NPPF requires planning polices to be relevant to local circumstances and that development which reflects these local needs should be supported. The NPPF requires 10% of housing need to be accommodated across the Plan area on ‘small sites’ of 1ha or under. It is acknowledged that a proportion of this requirement will be sought to be met through smaller scale allocations in towns or villages. Whilst this is a policy requirement it is considered that, particularly in villages, housing allocations should be flexible in this regard and should include sites over 1ha. Should only smaller scale sites be allocated in these locations this could stifle the sustainable growth of villages which would be contrary to paragraph 78 of the NPPF. Future policy in this area should take account of the potential opportunities that are available for housing, how these can be accommodated within the existing village forms, and above-all the benefits they will deliver. This approach is preferred rather than purely an arbitrary size threshold. Our client’s Site at Dubbs Knoll Road in Guilden Morden is a key example of a site which could offer a relatively small village a combination of much-needed affordable housing and upper market executive housing to assist in providing a balance of new development to help sustain the settlement. Sites which are over 1ha in rural locations can provide infrastructure and public benefits, such as affordable housing or public open space which cannot always be accommodated on smaller scale sites. Sites over 1ha can additionally assist in ensuring development delivers a range of housing and contributes to the vitality of rural areas and the creation of sustainable, balanced communities. Summary of Comments: The standard Method is a starting point and sets out a minimum target. To adhere to para 77 and 78 of the NPPF and maintain the vitality of rurla communities, a variety of sites should be allocated including sites such as the 1.2 hectare Land West of Dubbs Knoll Road in Guilden Morden which can have a key role to play in sustaining balanced communities.

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 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 Plan’s approach in proposing additional housing to provide flexibility and support the identified economic growth, at 2,900 homes a year. The trajectory of development must not be pushed backwards in the Plan. Meeting Cambridge’s housing need, particularly for affordable homes, is a pressing need and should be reflected in an accelerated rate of approvals from the start of the Plan period. In order to best address the affordability issues in Greater Cambridge and seek to ensure the needs to all community groups are addressed, the widest possible range of types, sizes and tenures of homes should be planned for in a wide variety of locations. This would also ensure that the Local Plan accords with Paragraphs 59, 61, 68 and 78.

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 the Travis Perkins site 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.

3.66 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. Response to Q32: 3.67 Altogether it has been estimated that more than 30,000 extra homes, above those already in the pipeline, could be built in the Greater Cambridge area by 2040. Grosvenor and USS support a plan for a higher number of homes to support the growing economy. However, it should be complimented with additional infrastructure and public services so that it does not compromise quality of life. Both Councils should carefully consider the priorities of their area to ensure local needs are being met. For example, a top priority for the South Cambridgeshire District Council is to reduce commuting travel and ensure the provision of homes specifically targets essential local workers. In addition, the demographic profile is also changing, with the proportion of those aged over 65 significantly increasing. Therefore, the Councils should promote a range of housing options across all tenures to accommodate for the growth of people and families. 3.68 The CPIER makes it clear that the area can plan for significant employment and housing growth successfully but acknowledges that each area needs to carry out their own detailed modelling work which will form part of a concrete evidence base. This in turn helps to inform the strategic planning requirements of the area. Higher levels of housing, where delivered in the most sustainable locations, such as at Trumpington, will have positive impacts on social, environmental and economic factors.

3.66 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.

SUMMARY OF COMMENTS: Links between housing availability/quality/design and health. Needs of Gypsies & Travellers. MAIN COMMENTS: We support the drive to build an appropriate number of homes, with appropriate housing mix, in order to support people to live settled, healthy lives. Affordable housing is particularly important in the GCP area given the stark socioeconomic inequalities in our area. We recognise there are stigmas attached to tenure types in the larger developments, consideration should be given to micro clustering affordable housing, rather than pepper potting. The experience suggests that this avoids an alienation of a different tenure type in an area that is predominately market housing. Consideration should be given to how affordable housing is allocated, whilst it is appreciated that this may be out of the scope of the local plan, how the housing is allocated could impact on the wellbeing of of the community. for example by allocating homes away from a persons social network may lead to isolation and poorer health outcomes. Specialist Housing is required to meet the needs of people with disabilities, vulnerable groups and our growing aging population. Priority should be given to providing sustainable older peoples accommodation that is based on the wider needs of the area. Consideration should be given to housing for priority groups such as care leavers, the ex-service personnel (under the Armed Forces Covenant) and key worker housing for Social Workers, Teachers and Healthcare staff. The local plan should reflect the impact of climate change on the type and design of housing being built, and therefore should include policies which require housing to be able to cope with colder winters and hotter summers - our most vulnerable people can suffer from both increased morbidity and mortality from houses that cannot cope well in either circumstance. The local plan should also contain policies on minimum room sizes, indoor light levels and outdoor space. The local plan should include policies which reflect the responsibility to ensure against household overcrowding. Whilst the role of HMO's is important in terms of providing lower cost accommodation, there should be measures to ensure the quality of housing is appropriate We also support the continued consideration of the needs of Gypsies and Travellers, carrying on from the adopted 2018 Local Plans. The Cambridgeshire Strategic Traveller Needs Assessment (2010) confirmed a pressing need for more sites of all kinds and that the preference was for small, self owned long stay sites for family groups, preferably on the edge of a village, near established Gypsy Traveller communities. Within South Cambs there are a range of sites including 2 local authority sites, 2 very large privately owned sites, several smaller privately owned sites and people living in housing both social and private. Being a Gypsy or Traveller is not about accommodation but about ethnicity. There is a lack of availability of good quality pitches be that private or local authority. As a result of this some pitches are overcrowded with several generations of families living on one ill-equipped pitch. The local plan should should reflect the fact that Gypsies & Travellers are Cambridgeshire’s largest ethnic minority and include polices requireing adequate provision of sites for Gypsies & Travellers and group housing schemes that enable Gypsies & Travellers to maintain the familial ties that sustain this community.

31. Cambridgeshire has significant housing affordability issue which will only increase as job growth continues, and the Greater Cambridge Plan must seek to significantly exceed minimum housing requirements in order to rebalance this issue. 32. Therefore, maximising the levels of growth and new housing in sustainable locations such as Cambourne must be support and encouraged by the Greater Cambridge Plan.

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 VJF is proposing a village extension along the western side of the village, on land enclosed by the existing bypass, for residential development of up to around 450 homes. The housing need across the district is well established and Papworth Everard is an increasingly sustainable location for residential development, with access to local services and employment opportunities as well as transport links. These transport links are explored in further detail within the accompanying Transport Appraisal. Papworth features a number of existing services which are explored in more detail within the accompanying Village Assessment. The expansion of Papworth is an appropriate location for further residential development as there will be opportunities to maximise opportunities for sustainable travel and residents would not be reliant on using cars for their whole journeys and be able to walk to access services.

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. Providing homes in well-connected areas to main centres of emoloyment can also help to ensure residents can access key services and facilities, as well as encouraging access to these by walking and cycling and train. These modes of travel are key to meeting climate change. 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. Many effects will depend on the location of new housing. In general, allocating higher levels of housing is more likely to have negative effects on environmental objectives, where this leads to increased travel and land take in areas that are not well connected by non-car modes of travel. For the reasons set out in this overall submission, Whittlesford is a sustainable location to meet future housing needs.