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

28. Cambridgeshire has a 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. 29. Therefore, maximising the levels of growth and new housing in sustainable locations such as Cambourne must be supported and encouraged by the Greater Cambridge Plan.

4.56 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). 4.57 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. 4.58 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 4.59 The new Local Plan should recognise the role that larger scale development can have in providing greater scope to provide a greater range of housing types.

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). Land at Granta Park Page 4 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. Summary The above representation sets out why there is a compelling case to provide essential worker housing at Granta Park and why the concept of such housing is supported by both local and national policy; not least the current Greater Cambridge Housing Strategy that quite rightly recognises the benefits that can be delivered by essential local worker housing. An allocation for essential worker housing will be of significant help to address the affordability issue for a number of employees at Granta Park to be able to afford a suitable home close to where they work; and in turn support the ongoing success and increasing contribution to the economy made by Granta Park. I trust that the above and the enclosed documentation is self-explanatory, but should you require any further information, then please contact me at your earliest opportunity. I look forward to receiving your response to the above information in relation to the Issues and Options Consultation 2020.

A. Flexibility and variety are required within the Local Plan in order to respond to changing housing needs over the Local Plan period. It is important to identify and plan to exceed the baseline housing need and allow 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 (NPPF Para. 59). B. Additionally, Cambridgeshire has significant housing affordability issues. By seeking to exceed minimum housing requirements this can only help to limit house price growth and help provide more affordable dwellings across the district.

According to the NPPF, the Planning Practice Guidance, and Planning Inspector’s Report on the South Cambridgeshire Local Plan (2018), the Greater Cambridge Local Plan should meet housing needs through development of a small scale sites, as well a large strategic sites. Small sites present an under-utilised opportunity for both residential and commercial development, overlooked and undercapitalised in the South Cambridgeshire Local Plan (2018). In the Planning Inspector’s Report of the South Cambridgeshire Local Plan (2018), it was recognised that “a significant proportion of the overall housing requirement will be provided in major allocations”. Considering this, the potential of smaller sites has in helping to “diversify the house building sector by providing a boost to small and medium sized developers” was recognised, with a recommendation to allocate housing in individual villages. This is reflected in national policy, with the NPPF states in paragraph 68 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”. This can be achieved by allocating a higher amount of small to medium sized sites, rather than less large strategic allocations, or working with developers to encourage the sub-division of large sites, helping to speed up the delivery of homes. Additionally, the Planning Practice Guidance identifies the need to consider a range of sites for development, including small scale sites in villages and towns. At 1 hectare, the site is a prime example of the land described by the Planning Inspector, as well as by national policy; small sites in existing villages, able to make an important contribution to local housing requirements in a relatively quick time frame. The site size and location, shown in Appendix 2, means that the site is small enough to be in keeping with the village, with the services shown in Appendix 1 having capacity for an increased population, whilst being large enough to positively contribute to the local housing supply.

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. Summary of Comments: 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.

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 componant 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 alloactions around the City and also the development of new settlements which the local plan inspectors raised concerns about. The new local plan should signifcantly 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. 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 flexibile 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 Fen Ditton 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.

Question 31. How should the Local Plan help to meet our needs for the amount and types of new homes? In accordance with 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 be seeking to 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 Joint Local Plan should signifcantly increase the allocation of small to medium sized sites in a variety of locations, including rural areas, to help speed up the delivery of homes and allow more flexibility in the type of properties that come forward. It is important that the rural areas are not left behind but allowed to prosper and thrive, in accordance with paragraph 78 of the NPPF. It will be necessary for the new Joint 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, such as the land to the east of Ditton Lane, Fen Ditton, will provide greater potential to deliver a more diverse range of housing, better suited to local needs and capable of delivery within the short term, unlike the larger, strategic allocations. It will ensure that not all the growth is focused on the City but also supports the parallel growth of the rural economy. 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 ageing population, a growing demographic group whose needs will need to be accommodated over the plan period. Paragraph 61 of the NPPF requires the size, type and tenure of housing needed for different groups in the community to be assessed and reflected in planning policies, which includes older people and people with disabilities. In addition, the Housing for older and disabled people PPG, which was published after the adoption of the existing local plans, stresses the importance of the need to provide housing for older people. It also recognises that housing needs amongst older people differ greatly, requiring strategic policy-making authorities 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. According to ONS data, by 2035, almost 22% of the population within Greater Cambridge will be aged 65 or over, therefore it is imperative that the plan makes adequate provision for older people within the Joint Local Plan. The allocation of Scott Properties' Site to the east of Ditton Lane, Fen Ditton for c.30 single storey properties specifically designed for those aged 55 and over as well as those with or supporting someone with a disability would help towards meeting a locally defined need for specialist accommodation. The Site would fulfil all of the above objectives and while the Site's 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. Attached to these representations is a Specialist Accommodation Needs Assessment, which seeks to assess the provision of specialist housing that may be required within Fen Ditton Parish, and, within a 5 minute drive-time of Fen Ditton. The latter generates a potential requirement for 125 specialist properties by 2023. The Site represents an opportunity to provide this type of accommodation in a highly sustainable location, close to key transport links and a number of facilities, both within Fen Ditton, adjacent Cambridge and proposed as part of the consented c.1300 dwelling scheme on land to the north of Newmarket Road. The provision of c.30 single storey properties would also represent a modest 10% increase to the existing property numbers in Fen Ditton. Summary of Comments: The new Joint Local Plan will need to allocate sufficient small to medium sized sites specifically to meet the needs of its ageing population.

3.1 The Local Plan will need to provide sufficient amount and variety of land to ensure that housing needs in Greater Cambridge are fully met. Alongside economic evidence, it is equally important to understand the environmental implications of future growth and how low carbon developments and lifestyles can be facilitated through the development strategy. 3.2 Large, strategic sites located within transport corridors have huge potential to promote a transition towards low/zero carbon lifestyles through the scale of improvements that such settlements can deliver in terms of: • District/Community-scale heating systems, renewable energies, water efficiency/greywater recycling systems etc. • sustainable transport infrastructure • location of higher housing densities around services and transport nodes • high degrees of internalization and reduced travel needs • provision of mixed uses and co-located uses • access to open space and sports • integration of smarter infrastructure and technologies 3.3 As stated in paragraph 72 of the NPPF, the supply of large numbers of new homes can often be best achieved through large scale developments, such as new settlements, provided they are well located and designed and supported by the necessary infrastructure and facilities. The Site put forward by Gallagher Development Groups Limited is of sufficient scale and location to meet this objective and to support the delivery of a highly sustainable new settlement.

2.51 The emerging GCLP will need to be consistent with national guidance on meeting housing needs. 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.

Please see section 6.0 and 7.0 of the accompanying representations document. Forecasts suggest that long-term Greater Cambridge could see job growth of up to around 3,500 per year under a transformational job scenario, with associated housing need for around 2,200-2,300 homes per year across Greater Cambridge. There is good reason for Greater Cambridge to consider delivery in excess of its standard method figure (of c.1,800 homes per year). This would be consistent with the NIC’s findings that housebuilding across the CaMKOx arc would need to roughly double compared with recent delivery levels to meet needs in full, including those from land constrained markets. It would also assist the area in meeting more of its affordable housing needs and deal with some of the pressure from unmet housing needs in London leading to in commuters from the capital, often with greater purchasing power than local residents. The edge of the city is likely to need to be the focus for future employment growth. To achieve the most sustainable commuting patterns, housing similarly needs to be located on the edge of the city. We know that the most common method of transport for those living in the city and fringe who also work there is by cycling or walking. These high levels of sustainable travel can be maintained with the co-location of housing and employment at the site, and potentially the number using cars to travel locally could be reduced if accessibility around the local area is improved as a result of the development.

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

In order to adequately respond to changing housing needs over the Local Plan period, flexibility and variety in the amount and type of new homes is required. As stated in response to Question 5, this can be achieved by avoiding reliance on a single growth strategy, and instead adopting a mixed and flexible approach to identifying and allocating new housing sites of different sizes and in different locations across the entire plan area. This will ensure a range of different housing types and products will come forward which are appropriate to the site context and development size and will help meet demand for housing in all locations including established settlements and villages. Additionally, 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 to begin to rebalance this issue, and ensure a range of different affordable housing types can be delivered.

3.1 The Local Plan will need to provide sufficient amount and variety of land to ensure that housing needs in Greater Cambridge are fully met. Alongside economic evidence, it is equally important to understand the environmental implications of future growth and how low carbon developments and lifestyles can be facilitated through the development strategy. 3.2 Large, strategic sites located within transport corridors have huge potential to promote a transition towards low/zero carbon lifestyles through the scale of improvements that such settlements can deliver in terms of: • District/Community-scale heating systems, renewable energies, water efficiency/greywater recycling systems etc. • sustainable transport infrastructure • location of higher housing densities around services and transport nodes • high degrees of internalization and reduced travel needs • provision of mixed uses and co-located uses • access to open space and sports • integration of smarter infrastructure and technologies 3.3 As stated in paragraph 72 of the NPPF, the supply of large numbers of new homes can often be best achieved through large scale developments, such as new settlements, provided they are well located and designed and supported by the necessary infrastructure and facilities. The Site put forward by Gallagher Development Groups Limited is of sufficient scale and location to meet this objective and to support the delivery of a highly sustainable new settlement.

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.

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.

6.1.1 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 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

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).

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.