Question 32. Do you think we should plan for a higher number of homes than the minimum required by government, to provide flexibility to support the growing economy?
Yes, strongly agree. As recognised within the consultation document, planning for a higher number of homes provides greater flexibility and ensures that the Councils are able to maintain a five-year housing land supply. The National Planning Policy Framework (NPPF) sets out at paragraph 35 is that in order to be found sound at Examination, plans must be positively prepared. To be positively prepared plans must provide a “strategy which, as a minimum, seeks to meet the areas objectively assessed needs” [our emphasis]. The Planning Practice Guidance expands on this, stating at Paragraph 002 (Housing and Economic Development Needs Assessment section) that “the standard method uses a formula to identify the minimum number of homes expected to be planned for, in a way which addresses projected household growth and historic under-supply. The standard method set out below identifies a minimum annual housing need figure. It does not produce a housing requirement figure” [our emphasis]. Paragraph 010 explains that there are a number of scenarios where an increase from local housing need is likely to be appropriate, this includes ”growth strategies for the area that are likely to be deliverable, for example where funding is in place to promote and facilitate additional growth” (e.g. Housing Deals). Greater Cambridge is within the Oxford-Cambridge Arc. The Government describe the Arc as a “globally significant place”, where there is an anticipation to deliver over “one million high-quality new homes by 2050”. This is both to enable economic growth but also to assist in tackling severe housing affordability issues. All Councils within the Arc have agreed to the Joint Declaration of Ambition between Government and the Arc and as such should therefore act in a way which aligns with this declaration. This of course means seeking to increase the level of housing delivered in Greater Cambridgeshire. Greater Cambridge is part of the Cambridgeshire and Peterborough devolution deal, have committed to the vision of doubling the total economic output of the area over 25 years. As the document recognises, recent jobs growth has been shown to have been faster than expected, leading to the demand for new housing in the area exceeding supply. If not enough new homes are built, this could see employers struggle to recruit staff locally. This may force business to direct investment elsewhere, where there is a suitable and available working population, stunting local economic growth. Furthermore, in not providing suitable housing, the Council are likely to encourage unsustainable commuting patterns, as workers will need to travel longer distances from other locations to reach newly created jobs. On the above basis, there is compelling justification to deliver housing at a level significantly above the base Local Housing Need. Such growth is required to ensure the Council’s delivers housing at a rate commensurate with its commitments to the Cambridge and Peterborough Devolution Deal and Oxford Cambridge Arc. Increasing housing delivery above local housing need also contributes to the national objective of boosting significantly the supply of homes. Furthermore, whilst affordability is included within the standard methodology calculations, delivery at a rate above Local Housing Need is only going to benefit housing affordability in the locality. We consider the growth levels suggested within the Cambridgeshire and Peterborough Independent Economic Review document are likely to be needed to deliver the above aims.
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6.2 To support the Government’s objective of significantly boosting the supply of homes, a sufficient amount and variety of land needs to be identified to meeting housing needs within the Joint Local Plan area. The Cambridge and Peterborough Independent Economic Review (CPIER) (September 2018) identifies that higher housing target numbers are likely to be needed in Cambridgeshire if the potential for higher growth in employment is to be met and to address longstanding affordability issues. 6.3 Housing requirements are minimums, not maximums to stay under at all costs. There is a wellevidenced affordability problem in Greater Cambridge; a greater supply of homes will be part of the solution. “Too many of the people working in Cambridge have commutes that are difficult, long and growing: not out of choice, but necessity due to high housing costs.”1 6.4 A Housing Needs Report accompanies this assessment that undertakes an objective assessment for what the future housing needs of Greater Cambridge are. It finds that there is an underlying and systemic affordability issue that is making it increasingly difficult for those on lower incomes to afford to live in the Greater Cambridge area. Alongside, the Cambridge economy has seen a prolonged and steady increase, which has attracted a larger workforce and increased the pressure on the housing market; availability and affordability. Alongside this trend is a clear political aspiration to see the Cambridge economy grow further; mostly clearly expressed by the Combined Authority that has a growth target as set out in its Devolution Deal of doubling GVA over 25 years. All of this clearly points to the need to plan for an amount of housing well above the minimum housing requirement. 1 Cambridgeshire and Peterborough Industrial Strategy 2019, p13
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Q32: Do you think we should plan for a higher number of homes than the minimum required by Government, to provide flexibility to support the growing economy? Paragraph 16 of the NPPF requires plans to be prepared positively in a way that is aspirational but deliverable. Paragraph 59 reminds Local Planning Authorities that the Government’s objective is to significantly boost the supply of homes and it is therefore important that a sufficient amount and variety of land comes forward where it is needed. As such, planning policies are required to identify a supply of specific, deliverable sites for the first 5 years of the plan period and specific, developable sites (or locations for growth) for the next 5 – 10 years. Paragraph 68 recognises the important contribution that small and medium sized sites can make to meeting the housing requirement of an area as they can be built out relatively quickly. Neighbourhood Planning groups are encouraged to allocate small and medium sized sites suitable for housing in their area. The emerging Histon and Impington Neighbourhood Plan while unable to allocate sites because of the existing Green Belt constraints, is supporting development schemes of 50 units or less in recognition of the need for additional housing and in particular affordable homes to meet local needs. In order to ensure that Local Authorities have specific deliverable sites they are required to maintain a 5 Year Housing Land Supply with an appropriate buffer. In addition, to ensure supply is maintained, they are also required to monitor the progress in building out sites, to comply with the housing delivery test. Currently, the supply of housing in South Cambridgeshire is only marginally above the 5-year requirement (5.05 years – Appeal Reference APP/W0530/W/19/3220761) and the Government’s recently published housing delivery figures for 2019 indicate delivery to be at 95% which while is not significantly below the target is still falling short. The question asks whether or not the Greater Cambridge Shared Planning Service should plan for a higher number of homes than the minimum required by government to provide flexibility and support the growing economy. The standard methodology indicates a need for 1,800 homes per year, or 40,900 homes for the suggested plan period of 2017-2040. However, as the draft Local Plan acknwoledges, the Cambridgeshire & Peterborough Independent Economic Review (CPIER) ‘showed that our recent growth has been faster than expected, and that growth is likely to continue. As a result, demand for new housing in this area has been exceptionally high and housebuilding has not kept up'. CPIER recommends that 'There should be a review of housing requirements based on the potential for higher growth in employment than currently forecast in the EEFM'. It states that 'No economy can achieve its potential without an adequate supply of housing, which must offer a range of types and price points for all society' and adds that it 'is concerned that Cambridgeshire & Peterborough is already runnning a very significant risk in this regard' and that risk is most acute in the Greater Cambridge area'. CPIER continues, stating that 'There has been insufficient housing development to meet demand. Average house prices and commuting have risen, choking labour supply while reducing the well-being of those forced to commute longer and longer distances [from more affordabe areas]'. CPIER concludes that 'we believe the accumulated deficit in Cambridgeshire & Peterborough is so acute that the local authorities should re-examine their assessments of housing need, setting higher numbers, which at least reflect previous under-delivery'. 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. 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. For these reasons, we strongly agree that the Greater Cambridge Shared Planning Service 'should plan for a higher number of homes than the minimum required by government, to provide flexibility to support the growing economy'. Summary of Comments: Strongly agree that 'we should plan for a higher number of homes than the minimum required…, to provide flexibility…for the growing economy'.
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Yes. As set out in the response to Question 31, upward adjustments to the minimum figure derived from the standard method are required to take into account growth strategies, strategic infrastructure improvements and housing affordability in Greater Cambridgeshire. The National Infrastructure Commission, the Cambridge and Peterborough Combined Authority and the Greater Cambridge Greater Peterborough Enterprise Partnership acknowledge and support the economic growth potential of the Greater Cambridge area, and consider that there is a need to substantially increase housing delivery in order to support that economic growth and address the significant housing affordability issues that exist.
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6.1. Savills (UK) Ltd are instructed by Mr and Mrs Wilkinson to make representations to the Greater Cambridge Issues and Options Local Plan (January 2020) in respect of their land interests to the east of the A505 Royston. 6.2. It is considered essential that the authorities plan for a higher number of homes than the minimum required to support the region’s growing economy. 6.3. The Government advocates the use of the ‘standard method’ to determine the minimum number of homes needed. However, Paragraph 010 Reference ID: 2a-010-20190220 of the PPG notes ‘there will be circumstances where it is appropriate to consider whether actual housing need is higher than the standard method indicates.’ 6.4. It is considered the economic circumstances of the Cambridge, which has one of the fastest growing economies in the country , area justify the need to plan for a higher number of homes in Greater Cambridge than indicated by the standard method as discussed below. 6.5. The Cambridgeshire and Peterborough Combined Authority (CPCA) has set an ambitious target in its Devolution Deal of doubling GVA over 25 years. This is on top of the significant growth the region has seen in the last 15 years. In the circumstances where all of the relevant Councils have signed up to the devolution deal to create the Combined Authority, it is arguable they have also committed themselves to promoting policies which supports this level of economic growth. 6.6. Furthermore, the Cambridgeshire and Peterborough Economic Review (CPIER) Final Report (2018) concludes that “the success of Cambridgeshire and Peterborough is a project of national importance” and consequently all authorities within should endeavour the region continues to prosper and capitalises on the success afforded. 6.7. Paramount to this is ensuring an adequate supply of housing. The Review notes that the impact of business growth in the region has not always been entirely positive. Growth in employment has not been matched by corresponding housebuilding, or developments in infrastructure and as a result house prices have soared and journey times have increased as congestion has intensified. To address this particular issue, the report makes the following key recommendation: “There should be a review of housing requirements based on the potential for higher growth in employment than currently forecast by the EEFM. This review should take into account the continuing dialogue between ONS and the Centre for Business Research on employment numbers as well as the impact of the Cambridge–Milton Keynes–Oxford Arc. This should be used to set new targets which are likely to be higher than those already set – at the very least adding on accumulated backlog.” 6.8. Consequently we support higher growth figures on the basis for the need to supply a range of new housing to cope with not only future economic growth that is anticipated up to 2040 but also to address the issues which have arisen as a result of existing economic growth.
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60. Local Housing Need figures are a minima and the intention should be to exceed the number of homes required by the Government both to provide flexibility and meet affordability challenges. In order to be robust and sound, the number of sites and dwellings to be allocated by the Plan should exceed the objectively assessed need to reflect the reality that some allocated sites will not come forward in the plan period or deliver the number of homes they are allocated for. 61. Additionally, this is particularly the case when considering the aspirations for growth in jobs and economies across the district. Greater Cambridge’s current and future housing need is largely driven by the employment growth targeted as part of doubling the regional GVA by 2041. Research by Cambridgeshire & Peterborough Independent Economic Commission (CPIEC) clearly shows that the quantity of land/sites allocated for housing will need to be significantly more than that currently planned for in the Local Plans. 62. Evidence on job density and economic activity shows there is little capacity among existing Greater Cambridge residents to expand the workforce and economic growth will need to rely on workers migrating or commuting into the area to avoid to not be limited. This places continuing pressure and demand on the housing market and to date, demand has vastly surpassed supply, creating a severe affordability issue. Therefore, the volume of house building needs to significantly increase across the district and exceed minimum requirements in order to prevent economic growth in Greater Cambridge stalling and housing unaffordability increasing. 63. Allocating land for additional housing, above minimum targets, would also ensure there is sufficient flexibility within the Local Plan to respond to changing housing needs/trends over the Local Plan period.
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To support the Government’s objective of significantly boosting the supply of homes, a sufficient amount and variety of land needs to be identified to meeting housing needs within the Joint Local Plan area. The Cambridge and Peterborough Independent Economic Review (CPIER) (September 2018) suggests that higher housing target numbers are likely to be needed in Cambridgeshire if the potential for higher growth in employment is to be met. Housing requirements are minimums, not maximums to stay under at all costs. There is a well evidenced affordability problem in Greater Cambridge; a greater supply of homes will be part of the solution. “Too many of the people working in Cambridge have commutes that are difficult, long and growing: not out of choice, but necessity due to high housing costs.”1 A Housing Needs Report accompanies this representation that undertakes an objective review for what the future housing needs of Greater Cambridge are. It finds that there is an underlying and systemic affordability issue that is making it increasingly difficult for those on lower incomes to afford to live in the Greater Cambridge area. Alongside, the Cambridge economy has seen a prolonged and steady increase, which has attracted a larger workforce and increased the pressure on the housing market; availability and affordability. Alongside this trend is a clear political aspiration to see the Cambridge economy grow further; mostly clearly expressed by the Combined Authority that has a growth target as set out in its Devolution Deal of doubling GVA over 25 years. All of this clearly points to the need to plan for an amount of housing well above the minimum housing requirement. 1 Cambridgeshire and Peterborough Industrial Strategy 2019, p13
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Yes. As set out in the response to Question 31, upward adjustments to the minimum figure derived from the standard method are required to take into account growth strategies, strategic infrastructure improvements and housing affordability in Greater Cambridgeshire. The National Infrastructure Commission, the Cambridge and Peterborough Combined Authority and the Greater Cambridge Greater Peterborough Enterprise Partnership acknowledge and support the economic growth potential of the Greater Cambridge area, and consider that there is a need to substantially increase housing delivery in order to support that economic growth and address the significant housing affordability issues that exist.
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2.44 If you only provide for the minimum then there is no room for error if sites do not come forward within the plan period. As such by planning for a higher number of houses you build in an element of flexibility which allows for unpredictability. It makes the plan more robust and given that further housing will be needed beyond the plan period, provision over the minimum does not imply the development of unneeded dwellings. 2.45 Moreover, Greater Cambridge is by definition an area of economic growth and is attractive to inward migration driven in particular by the technology industries. It follows that many such inward migrants have a financial ability to outcompete local communities for the available housing. Failure to provide a budget above the government's minimum requirement is therefore either likely to does the shortly of the economy to support continued growth or, more likely, to increase housing stress in existing communities.
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6.1 Yes, strongly agree. 6.2 If the Greater Cambridge Authority seek to double the total economic output of the Combined Authority in 25 years, it will require residential development to keep up with anticipated employment growth. 6.3 Paragraph 4.6.3 of the Issues and Options document confirms that ‘Greater Cambridge is an expensive place to buy or rent a home. High prices are fueled by high demand which itself is fueled by the strength of the local economy which attracts highly skilled workers.’ The CPIER Report 2018 confirms that the employment sector growth has not been matched by proportionate levels of house building, resulting in increases in house prices. 6.4 The housing sector therefore needs to close the disparity between itself and employment growth in order to control affordability in the area. To achieve this, residential growth should eb set above the ‘minimum’ level and set ambitious but achievable levels of growth.
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6.2 To support the Government’s objective of significantly boosting the supply of homes, a sufficient amount and variety of land needs to be identified to meeting housing needs within the Joint Local Plan area. The Cambridge and Peterborough Independent Economic Review (CPIER) (September 2018) suggests that higher housing target numbers are likely to be needed in Cambridgeshire if the potential for higher growth in employment is to be met. 6.3 Housing requirements are minimums, not maximums to stay under at all costs. There is a wellevidenced affordability problem in Greater Cambridge; a greater supply of homes will be part of the solution. “Too many of the people working in Cambridge have commutes that are difficult, long and growing: not out of choice, but necessity due to high housing costs.”5 6.4 There is an underlying and systemic affordability issue that is making it increasingly difficult for those on lower incomes to afford to live in the Greater Cambridge area. Alongside, the Cambridge economy has seen a prolonged and steady increase, which has attracted a larger workforce and increased the pressure on the housing market; availability and affordability. Alongside this trend is a clear political aspiration to see the Cambridge economy grow further; mostly clearly expressed by the Combined Authority that has a growth target as set out in its Devolution Deal of doubling GVA over 25 years. All of this clearly points to the need to plan for an amount of housing well above the minimum housing requirement. 5 Cambridgeshire and Peterborough Industrial Strategy 2019, p13
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Yes, strongly agree. As stated within section 4.6.3 the Government’s ‘standard method’ calculation indicates a need for 1,800 homes per year or 40,900 within the plan period 2017-2040. However, CPIER (Cambridge and Peterborough Independent Economic Review) has highlighted that the recent job growth in Greater Cambridge is accelerating at a rate faster than expected. The popularity of the Cambridge sub-area to invest will be enhanced in no small part now that greater clarity has been provided on the nature and timescales of the infrastructure works proposed in response to the Government’s proposals for the Oxford Cambridge Arc. As a result, CPIER provide a rough expectation that 2,900 homes will be built per year, equating to 66,700 for the plan period. Therefore, it is clear that there will be a residual requirement to deliver 30,000 additional homes to meet job related needs over the plan period.
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Yes, Strongly agree. Delivering the Governments standard methodology will only deliver an additional 4,500 new homes to 2040. This does not generate sufficient flexibility to start to make significant changes to the overall sustainability of the area, particularly as the North East Cambridge site will come on stream and meet this growth target. Depending on whether the Cambridge Airport reserve site can be shown to be available and achievable, this could also absorb any surplus growth and stifle development elsewhere to 2040. The lower target does not reflect the transformational growth envisaged within the Oxford to Cambridge Arc. Building on the jobs growth and economic advantages that the Greater Cambridge area has experienced should be a priority. Uplifting the housing need to 66,700 over the plan period would create the necessary margins to create new communities away from the city edge. Delivering 30,300 additional homes above existing planned and committed supply will enable the Council to deliver on the identified objectives of climate change, greener environments and greater connectivity for its residents.
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Yes. As set out in the response to Question 31, upward adjustments to the minimum figure derived from the standard method are required to take into account growth strategies, strategic infrastructure improvements and housing affordability in Greater Cambridgeshire. The National Infrastructure Commission, the Cambridge and Peterborough Combined Authority and the Greater Cambridge Greater Peterborough Enterprise Partnership acknowledge and support the economic growth potential of the Greater Cambridge area, and consider that there is a need to substantially increase housing delivery in order to support that economic growth and address the significant housing affordability issues that exist.
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Yes. As set out in the response to Question 31, upward adjustments to the minimum figure derived from the standard method are required to take into account growth strategies, strategic infrastructure improvements and housing affordability in Greater Cambridgeshire. The National Infrastructure Commission, the Cambridge and Peterborough Combined Authority and the Greater Cambridge Greater Peterborough Enterprise Partnership acknowledge and support the economic growth potential of the Greater Cambridge area, and consider that there is a need to substantially increase housing delivery in order to support that economic growth and address the significant housing affordability issues that exist.
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6.5 Greater Cambridge is an area with strong economic growth and with an aspiration to maintain that growth. The affordability of housing is also a major issue. The new Local Plan must be able to address both of these concerns. 6.6 To support the Government’s objective of significantly boosting the supply of homes, a sufficient amount and variety of land needs to be identified to meeting housing needs within the Joint Local Plan area. The Cambridge and Peterborough Independent Economic Review (CPIER) (September 2018) suggests that higher housing target numbers are likely to be needed in Cambridgeshire if the potential for higher growth in employment is to be met. As is widely recognised, the economy of Cambridge is too important nationally for the Council to plan for the minimum number of homes required by the standard method. 6.7 The increased demand for housing arising from the economic success of Cambridge also makes the area increasingly unaffordable. In addition to being a concern to residents, affordability will impact upon the businesses looking to locate in the area. There is a danger that if there is an insufficient supply of housing, the economic growth plans will not be realised. The role of housing in attracting and retaining skilled employees is widely recognised and should be adequately addressed in the Plan.
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6.5 Greater Cambridge is an area with strong economic growth and with an aspiration to maintain that growth. The affordability of housing is also a major issue. The new Local Plan must be able to address both of these concerns. 6.6 To support the Government’s objective of significantly boosting the supply of homes, a sufficient amount and variety of land needs to be identified to meeting housing needs within the Joint Local Plan area. The Cambridge and Peterborough Independent Economic Review (CPIER) (September 2018) suggests that higher housing target numbers are likely to be needed in Cambridgeshire if the potential for higher growth in employment is to be met. As is widely recognised, the economy of Cambridge is too important nationally for the Council to plan for the minimum number of homes required by the standard method. 6.7 The increased demand for housing arising from the economic success of Cambridge also makes the area increasingly unaffordable. In addition to being a concern to residents, affordability will impact upon the businesses looking to locate in the area. There is a danger that if there is an insufficient supply of housing, the economic growth plans will not be realised. The role of housing in attracting and retaining skilled employees is widely recognised and should be adequately addressed in the Plan.
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Southern and Regional Developments (Cottenham) consider that the emerging Greater Cambridge Local Plan must plan for a higher quantum of housing. The Cambridgeshire and Peterborough Independent Economic Review has recognised that the Combined Authority Area (Cambridgeshire and Peterborough) has experienced a higher rate of economic growth than forecast. This is a significant indicator that the new Plan for Greater Cambridge must consider actively planning for through delivery of a significantly higher number of homes. Furthermore, if implemented into the spatial strategy, an increase in the number of homes to be delivered will allow a better degree of flexibility that will otherwise not be available if the Plan only provides for the minimum. Given the evidence that is available, it would not be an appropriate or sound approach if the Plan were to avoid strategising for a higher number of homes than the government figure suggests - instead the government figure should be considered the minimum level required. If the economic trend is to continue within the Plan area, which the CPIER report establishes, it would be a failure of the Plan's statutory requirement to "make sufficient provision" for housing numbers and boost delivery, as asserted in the NPPF. If the Plan is to support the economic growth of the area over the new Plan period, a higher housing quantum will need to be incorporated into strategic policy. If insufficient homes are delivered over the new period, this will supress any potential for economic growth within the Plan area and result in diminishing the expansion of the jobs market in Cambridge and South Cambridgeshire. Summary of Comments: Higher quantum of housing is needed to assure flexibility and to support the significant economic growth experienced in the Plan area.
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6.3 To meet the housing needs identified in the Local Plan, sufficient land has to be identified. The Local Plan supports the Government’s objective of significantly boosting the supply of homes. Indeed, higher housing target numbers are likely to prove necessary in Cambridgeshire if the potential for greater growth in employment is to be realised (as indicated in the Cambridge and Peterborough Independent Economic Review (CPIER) (September 2018)). 6.4 Against this background, the Local Plan’s housing requirements represent a minimum. Affordability is an important issue in Greater Cambridge. A greater supply of homes and the innovative use of different tenures will be part of the solution. “Too many of the people working in Cambridge have commutes that are difficult, long and growing: not out of choice, but necessity due to high housing costs.”1 1 Cambridgeshire and Peterborough Industrial Strategy 2019, p13
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20. The standard methodology indicates a need for 1,800 homes per year, or 40,900 homes for the suggested plan period of 2017-2040. However, as the draft Local Plan acknwoledges, the Cambridgeshire & Peterborough Independent Economic Review (CPIER) 'showed that our recent growth has been faster than expected, and that growth is likely to continue. As a result, demand for new housing in this area has been exceptionally high and housebuilding has not kept up'. 21. The draft Issues & Options Local Plan indicates that a rough indiactive calculation based on CPIER suggests that if the jobs growth is achieved, around 2,900 homes a year would need to be built in Greate Cambridge, which equates to an indicative total of 66,700 homes over the period 2017-2040. 22. CPIER recommends that ‘There should be a review of housing requirements based on the potential for higher growth in employment than currently forecast in the EEFM'. It states that ‘No economy can achieve its potential without an adequate supply of housing, which must offer a range of types and price points for all society' and add that it 'is concerned that Cambridgeshire & Peterborough is already runnning a very significant risk in this regard' and that risk is most acute in the Greater Cambridge area'. 23. CPIER continues, stating that 'There has been insufficient housing development to meet demand. Average house prices and commuting have risen, choking labour supply while reducing the well-being of those forced to commute longer and longer distances [from more affordabe areas]'. CPIER concludes that 'we believe the accumulated deficit in Cambridgeshire & Peterborough is so acute that the local authorities should re-examine their assessments of housing need, setting higher numbers, which at least reflect previous under-delivery'. It should also be noted that the CPIER indicates that job growth in recent years in Greater Cambridge has been under-estimated with a knock-on impact for the level of housing required, which is likely to be far higher than the numbers set out using the standard methodology method. 24. The supporting Housing Delivery Study prepared by Barton Willmore demonstrates that ‘current housing completions are on a par with the minimum houisng need identified using the Government’s standard method. However to keep up with the economic growth over the next 20 years, using the upper housing range recommended by CPIER will mean an uplift of 71% in housing supply compared to the current objectively assessed need (OAN) set out the the Cambridge and South Cambridgeshire Local Plan (2018)’. The NIC’s recommendations go even further than CPIER and recommend doubling the current OAN to reach a total of 3,350 homes per annum. The supporting Housing Delivery Strategy concludes that ‘Applying these indicative figures [set out in the CPIER and NIC] would result in a need to deliver 65,987-77,050 homes between 2017-2040. This would require a review of land available to support a further 29,587-40,650 homes during the Local Plan Period taking account the 36,400 homes that already have permission or are allocated in the adopted 2018 Local Plan’. 25. For these reasons, my client strongly agrees that the Greater Cambridge Shared Planning Service 'should plan for a higher number of homes than the minimum required by government, to provide flexibility to suppprt the growing economy'. While there is clearly more empirical evidence to be undertaken, the indicative CPIER calculation of 2,900 home a year (or 66,700 homes over the plan period) should be seen as an appropriate starting point. My client therefore supports the option of delivering a minum of 2,900 homes per year, as only by building at a higher level than has previously occurred will start to mitiage the significant negative effects on bothe the local and national economy should housing in Greater Cambridge continue to be constrained. 26. Housing should also reflect the upper housing range as recommended within the CPIER and the NIC to support the anticipated economic growth over the next 20 years. This equates to a minimum of 2,900 homes each year within Greater Cambridge and an uplift of a minimum of 71% of housing supply compared to the current OAN figures. This shows the potential need for 9,577 additional homes in rural areas up to 2040 based on the CPIER’s estimates against existing representation of growth across the existing adopted development strategy. 27. Summary: Strongly agree that ‘we should plan for a higher number of homes than the minimum required…, to provide flexibility..for the growing economy’. In order to meet the growth aspiration that has been set out by the Local Planning Authorities and CPCA, the plan must plan for the homes to support the anticipated growth.
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Yes- Strongly agree, please see supporting cover letter for justification.
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7.1.1 The consultation document outlines that the current calculations, using the Government’s standard method, indicate a need for 1,800 homes per year or 40,900 homes for the plan period 2017-2040. Through the process of preparing the Greater Cambridge Local Plan, the 1,800 figure should be considered as a minimum needed and the Councils should be open minded to the fact that this figure may increase due to other considerations. Once the minimum figure has been established further interrogation of this figure will be required to ensure that this is appropriate, for example it may be necessary to increase this figure to support economic growth or to meet affordable housing need as set out in the PPG. 7.1.2 Specifically, Gladman refer to Paragraph ID 2a-010-20190220 which states: “…Therefore, there will be circumstances where it is appropriate to consider whether actual housing need is higher than the standard method indicates. This will need to be assessed prior to, and separate from, considering how much of overall need can be accommodated (and then translated into a housing requirement figure for the strategic policies in the plan). Circumstances where this may be appropriate include, but are not limited to situations where increases in housing need are likely to exceed past trends because of: • Growth strategies for the area that are likely to be deliverable, for example where funding is in place to promote and facilitate additional growth (e.g. Housing Deals); • Strategic infrastructure improvements that are likely to drive an increase in the homes needed locally; or • An authority agreeing to take on unmet need from neighbouring authorities, as set out in the statement of common ground;…” 7.1.3 The consultation document acknowledges this when it outlines the scale of economic growth which the Council signed up to as part of the Cambridgeshire and Peterborough Devolution Deal. Whilst the consultation document outlines that further detailed work is required, it does also outline that a rough indicative calculation suggests that if this scale of jobs growth is achieved, around 2,900 homes a year would be needed across Greater Cambridge, which would require 66,700 homes between 2017-2040. 7.1.4 Gladman strongly believe that the new Local Plan should be planning for a significantly higher number of homes that the minimum identified by the standard method and that they should be seeking to deliver the homes necessary to align with the scale of economic growth. 7.1.5 In this regard Gladman also refer to the Cambridgeshire and Peterborough Independent Economic Review (CPIER) September 2018, which sets out a compelling case for higher levels of housing growth across the Greater Cambridge area. Specifically, Gladman note Key Recommendation 5 which points to the need to review the housing requirement based on the need for high economic growth and also how the report warns of significant negative impacts, both to the local and national economy should housing needs continue to be constrained. 7.1.6 In addition to the Cambridgeshire and Peterborough Devolution Deal and the economic growth associated with this, it is important for the new Local Plan to recognise the areas position within the Oxford to Cambridge Growth Arc and the implications that this will have for additional growth in the area. 7.1.7 The Government has designated the Oxford to Cambridge Growth Arc as a key economic priority and has stated the objective to deliver up to 1 million high quality new homes across the Arc up to 2050. Given that growth across the Arc is of national importance, Gladman believe it is imperative that the Local Plan seek do deliver a higher number of homes than the minimum requirement derived from the standard method. The economy of Cambridge is too important nationally for the Councils to be planning for the minimum number of homes required by the standard method. 7.1.8 The consultation document claims that there are 36,400 homes already in the pipeline to be built between 2017 and 2040, and that if this figure is correct then there may the case for making additional provision if the Local Plan does seek to deliver a higher housing figure then the standard method. 7.1.9 If the Council were to progress with the economic growth led scenario discussed in the consultation document this would suggest the need to identify sites for around an additional 30,000 homes in the next Local Plan. Gladman agree that the new Local Plan will need to be identifying significant amounts of land available to deliver the pro-growth strategy. The scale of this residual land to be identified will need to be clarified through further work on the housing need/requirement figure. 7.1.10 Given the factors identified above it is clear that the Councils will need to establish a housing requirement well in excess of the minimum number of homes required by the Standard Method. Gladman reserve the right to comment on the housing and jobs growth proposals when these are developed further and the preferred option is presented in the next stage of public consultation (Draft Plan).
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6.2 To support the Government’s objective of significantly boosting the supply of homes, a sufficient amount and variety of land needs to be identified to meeting housing needs within the Joint Local Plan area. The Cambridge and Peterborough Independent Economic Review (CPIER) (September 2018) suggests that higher housing target numbers are likely to be needed in Cambridgeshire if the potential for higher growth in employment is to be met. 6.3 Housing requirements are minimums, not maximums to stay under at all costs. There is a wellevidenced affordability problem in Greater Cambridge; a greater supply of homes will be part of the solution. “Too many of the people working in Cambridge have commutes that are difficult, long and growing: not out of choice, but necessity due to high housing costs.”1 6.4 A Housing Needs Report accompanies this representation that undertakes an objective review for what the future housing needs of Greater Cambridge are. It finds that there is an underlying and systemic affordability issue that is making it increasingly difficult for those on lower incomes to afford to live in the Greater Cambridge area. Alongside, the Cambridge economy has seen a prolonged and steady increase, which has attracted a larger workforce and increased the pressure on the housing market; availability and affordability. Alongside this trend is a clear political aspiration to see the Cambridge economy grow further; mostly clearly expressed by the Combined Authority that has a growth target as set out in its Devolution Deal of doubling GVA over 25 years. All of this clearly points to the need to plan for an amount of housing well above the minimum housing requirement. 1 Cambridgeshire and Peterborough Industrial Strategy 2019, p13
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2.22 Yes, to support the Government’s objective of significantly boosting the supply of homes, a sufficient amount and variety of land needs to be identified to meeting housing needs within the Greater Cambridge area. The Cambridge and Peterborough Independent Economic Review (CPIER) (September 2018) highlights the need for higher housing target numbers to ensure the higher growth in employment is met to achieve the economic growth potential for Greater Cambridge and the wider economy.
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Southern and Regional Developments (Willingham) consider that the emerging Greater Cambridge Local Plan must plan for a higher quantum of housing. The Cambridgeshire and Peterborough Independent Economic Review ('CPIER') has recognised that the Combined Authority Area (Cambridgeshire and Peterborough) has experienced a higher rate of economic growth than forecast. This is a significant indicator that the new Plan for Greater Cambridge must consider planning for a significantly higher number of homes. Furthermore, if implemented into the spatial strategy, an increase in the number of homes to be delivered will allow a degree of flexibility that will otherwise not be available if the Plan allows for a minimum number. Given the evidence that is available, it would not be an appropriate or sound approach if the Plan were to not plan for a higher number of homes than the government figure suggests. If the economic trend is to continue within the Plan area, which the CPIER report establishes, it would be a failure of the Plan's statutory requirement to "make sufficient provision" for housing number, as it asserted in the NPPF. If the Plan is to support this economic growth through the new Plan period, a higher housing quantum will be needed to be incorporated into strategic policy. If insufficient homes are delivered over the new period, this will supress any potential for economic growth within the Plan area and result in diminishing the expansion of the jobs market in Cambridge and South Cambridgeshire. Summary of Comments: Higher quantum of housing is need to assure flexibility and to support the significant economic growth experienced in the Plan area.
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5.1 Yes, strongly agree. 5.2 The current Cambridge and South Cambridgeshire Local Plans seek to provide a combined 33,500 dwellings to be built up to 2031. The area suffers a great disparity between housing provision and affordability. This is acknowledged within Figure 19 of the Issues and Options document itself and accompanying paragraph 4.6.3 confirms ‘Greater Cambridge is an expensive place to buy or rent a home. High prices are fueled by high demand, which itself is fueled by the strength of the local economy which attracts highly skilled workers’. The Cambridgeshire and Peterborough Independent Economic Review (CPIER) Report confirms that growth in the employment sector has not been matched by proportionate house-buildings. The result has been large increases in house prices. 5.3 Greater Cambridge is located within the key economic corridors of the Oxford – Cambridge arc, the London – Stansted - Cambridge corridor and the Cambridge – Norwich tech corridor. The Oxford – Cambridge arc seeks to create a strategic vision corridor between the University cities. Its goal is to deliver 1 million dwellings in the arc by 2050, to be complemented by the infrastructure projects of the East-West Expressway and East-West Rail. At the eastern end of the arc, the driver is the City of Cambridge and its need for residential development to complement its skilled workforce. 5.4 The CPIER report provides a number of Key Recommendations to assist with growth in the area. Key Recommendation #5 of the CPIER Final Report September 2018 states: ‘There should be a review of housing requirements based on the potential for higher growth in employment than currently forecast by the EEFM. This review should take into account the continuing dialogue between ONS and the Centre for Business Research on employment numbers as well as the impact of the Cambridge - Milton Keynes - Oxford Arc. This should be used to set new targets which are likely to be higher than those already set – at the very least adding on accumulated backlog.’ 5.5 A higher target of dwellings would assist in meeting the goals of the arc. A further positive resulting from increased housing numbers would be the subsequent proportion of affordable housing. At present, Cambridge City and South Cambridgeshire District Council seek affordable housing provision of 40% for schemes over 15 dwellings. Should the Plan seek 66,700 dwellings rather than the 40,900 dwellings from the standard method calculation, then this could provide over 10,000 much needed affordable houses. 5.6 Martin Grant Homes reserves the right to provide appropriate evidence to justify the objectively assessed need through the Local Plan process as considered necessary.
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While the Government’s National Planning Policy Framework (NPPF) makes clear that the minimum number of homes a plan-making authority should plan for should be calculated using the Local Housing Need Standard Method (LHNSM), the presumption in favour of sustainable development and the tests of soundness still require an objective assessment of need (OAN) to determine if a higher number of homes should be targeted. This OAN for housing should be based on demographic need and housing market signals. However, in a rapidly growing economy, such as Greater Cambridge, it is impossible to ignore the demand for housing generated by the incoming workforce. The alternatives would be to either stymie that economic growth or accept increased inflow of commuters; neither of which are compatible with the presumption in favour of sustainable development, or the Government’s aspirations for the Cambridge – Oxford Arc. To support the Government’s objective of significantly boosting the supply of homes, a sufficient amount and variety of land needs to be identified to meeting housing needs within the Joint Local Plan area. The Cambridge and Peterborough Independent Economic Review (CPIER) (September 2018) suggests that higher housing target numbers are likely to be needed in Cambridgeshire if the potential for higher growth in employment is to be met. As is widely recognised, the economy of Cambridge is too important nationally for the Council to plan for the minimum number of homes required by the standard method. The increased demand for housing arising from the economic success of Cambridge also makes the area increasingly unaffordable. In addition to being a concern to residents, affordability will impact upon the businesses looking to locate in the area. There is a danger that if there is an insufficient supply of housing, the economic growth plans will not be realised. The role of housing in attracting and retaining skilled employees is widely recognised and should be adequately address in the Plan. There is a well-evidenced affordability problem in Greater Cambridge; a greater supply of homes will be part of the solution. “Too many of the people working in Cambridge have commutes that are difficult, long and growing: not out of choice, but necessity due to high housing costs.”3 The Cambridge and Peterborough Independent Economic Review (CPIER) (September 2018) suggests that higher housing target numbers are likely to be needed in Cambridgeshire if the potential for higher growth in employment is to be met. It identifies a need for at least 2,900 per annum within this Local Plan. As is widely recognised, the economy of Cambridge is too important nationally for the Council to plan for the minimum number of homes required by the standard method. The increased demand for housing arising from the economic success of Cambridge also makes the area increasingly unaffordable. In addition to be a concern to residents, affordability will impact upon the businesses looking to locate in the area. There is a danger that, if there is an insufficient supply of housing, the economic growth plans will not be realised. The role of 3 Cambridgeshire and Peterborough Industrial Strategy 2019, p13 housing in attracting and retaining skilled employees is widely recognised and should be adequately addressed in the Plan. If the economic growth of the area is to be facilitated through increased commuting from beyond the sub-region, then the goal of zero carbon and balancing health and wellbeing will not be achieved. A Housing Needs Report accompanies this representation that undertakes an objective review for what the future housing needs of Greater Cambridge are. It finds that there is an underlying and systemic affordability issue that is making it increasingly difficult for those on lower incomes to afford to live in the Greater Cambridge area. Alongside, the Cambridge economy has seen a prolonged and steady increase, which has attracted a larger workforce and increased the pressure on the housing market; availability and affordability. Alongside this trend is a clear political aspiration to see the Cambridge economy grow further; mostly clearly expressed by the Combined Authority that has a growth target as set out in its Devolution Deal of doubling GVA over 25 years. All of this clearly points to the need to plan for an amount of housing well above the minimum housing requirement indicated by the Standard Method.
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2.30 Paragraph 35 of the NPPF sets out that Local Plan should seek to meet the identified housing need as a minimum, with sufficient flexibility to be able to respond to rapid change (NPPF paragraph 11). 2.31 Therefore, whilst it is not a requirement to exceed the minimum identified housing need, planning for a higher number of homes over the plan period will help to ensure the emerging Local Plan has sufficient flexibility to respond to rapid change and provide additional housing to accommodate any surplus housing need resulting from the growing economy. 2.32 This is reflected within the Greater Cambridgeshire Issues and Options consultation under section 4.6.3 (The need for new homes). The standard method is said to indicate a need for 1,800 homes per year, or 40,900 homes over the plan period for Greater Cambridgeshire however this number could be far exceeded. The Cambridgeshire and Peterborough Independent Economic Review (CPIER) suggests that if the projected job growth is achieved this would create an additional housing need of 1,100 homes a year (2,900 in total). This would equate to a new housing need of c. 66,700 homes over the plan period. 2.33 The need for additional housing to compensate for this surplus is clear: “Making the additional provision that would provide flexibility to support our potential economic growth suggests identifying sites for around an additional 30,000 homes in the next Local Plan.” (Greater Cambridgeshire Issues and Options 4.3.6 (6)) 2.34 Providing for additional housing growth can be easily captured through small to medium sites that can deliver modest levels of sustainable growth in the short term, and are therefore best placed to respond to rapid shifts at the macro level such as change in market signals and a rise in employment growth as a result of the planned infrastructure delivery over the plan period.
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Southern and Regional Developments (Waterbeach) consider that the emerging Greater Cambridge Local Plan must plan for a higher quantum of housing. The Cambridgeshire and Peterborough Independent Economic Review ('CPIER') has recognised that the Combined Authority Area (Cambridgeshire and Peterborough) has experienced a higher rate of economic growth than forecast. This is a significant indicator that the new Plan for Greater Cambridge must consider planning for a significantly higher number of homes. Furthermore, if implemented into the spatial strategy, an increase in the number of homes to be delivered will allow a degree of flexibility that will otherwise not be available if the Plan allows for a minimum number. Given the evidence that is available, it would not be an appropriate or sound approach if the Plan were to not plan for a higher number of homes than the government figure suggests. If the economic trend is to continue within the Plan area, which the CPIER report establishes, it would be a failure of the Plan's statutory requirement to "make sufficient provision" for housing number, as it asserted in the NPPF. If the Plan is to support this economic growth through the new Plan period, a higher housing quantum will be needed to be incorporated into strategic policy. If insufficient homes are delivered over the new period, this will supress any potential for economic growth within the Plan area and result in diminishing the expansion of the jobs market in Cambridge and South Cambridgeshire. Summary of Comments: Higher quantum of housing is need to assure flexibility and to support the significant economic growth experienced in the Plan area.
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Yes. As set out in the response to Question 31, upward adjustments to the minimum figure derived from the standard method are required to take into account growth strategies, strategic infrastructure improvements and housing affordability in Greater Cambridgeshire. The National Infrastructure Commission, the Cambridge and Peterborough Combined Authority and the Greater Cambridge Greater Peterborough Enterprise Partnership acknowledge and support the economic growth potential of the Greater Cambridge area, and consider that there is a need to substantially increase housing delivery in order to support that economic growth and address the significant housing affordability issues that exist.
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