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?
The Local Plan should resist rapid and unrestricted growth beyond the required level. This would be likely to impact both the historic and natural environment in unacceptable ways and would undermine commitments made in policy to environmental protection, reducing carbon emissions, combatting climate change, and conserving natural resources. Many existing services and facilities are operating at their limits (including visitor facilities at Trust properties) and the impact of additional population pressure on local community infrastructure is also likely to be harmful if capacity fails to match demand.
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Persimmon strongly agrees that Greater Cambridge should plan for a greater number of new homes than required by the councils’ respective minimum housing need figures calculated using the standard methodology. The councils correctly identify affordability as a key issue for this plan to address and this is a particularly urgent concern as the affordability of homes in Greater Cambridge acts as a significant constraint to economic growth of this strategically important area. The affordability problem in and around Cambridge also means that people cannot afford to live close where they work adding to private vehicle use and pressure on the road network. Solving the affordability problem is not just a question of planning for more homes that are specifically affordable as defined in the NPPF but also increasing the number and variety of market homes on offer. Positive and proactive planning now and providing increased flexibility in future housing land supply will ensure that developments in the future remain plan-led and obviate the need for the delivery of unallocated sites.
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• CambridgePPF strongly disagrees with this suggestion (we are curious as to why “strongly disagree” was not an option). We should not be planning to provide housing at a level above the requirement set by Government. • The Government’s minimum ‘standard method’ target of 41,000 by 2040 is realistic in terms of land availability and capacity to deliver, especially with the Cambridge Airport and the North East Cambridge sites coming forward during the Plan period. However, just to reach this minimum target will mean raising the annual target for home completions from 1,675 to some 1,800. At the moment, the Councils are failing to deliver even the current targets by a substantial margin so raising the targets will require a significant step-up in performance. • The 2018 Local Plan has proposed a significant amount of new development and a substantial increase in population. It will not start to become clear until 2025 and beyond what impacts this growth will have – for example, traffic congestion, overcrowding in Cambridge City Centre, or water shortages in our chalk streams. Therefore, it would seem unwise to continue to extrapolate growth to 2040 (or beyond) until the impacts of the ‘in-pipeline’ growth are better understood. This in turn would argue that a ‘precautionary approach’ should be adopted to the housing targets. If the continuous review process shows insufficient housing coming forward, then it is much easier to increase than to reduce targets during the course of the Plan – see our response to Q4 • The ‘Objectively Assessed Housing Needs (OAHN)’ will, as always, be the most contentious issue in this Plan’s preparation with the developers arguing for more and the residents’ organisations for less. In the absence of any clear Vision as to how the Councils envisage the Greater Cambridge area evolving over the next two decades, it is impossible to determine the ‘correct’ balance. • The question also raises the issue as to what are the resource restrictions that will eventually limit growth. Are these being assessed? Simply assuming that more and more housing can be loaded into Greater Cambridge is ludicrous without some examination of the capacity of the area to accommodate such growth. • To accommodate the doubling of the economic growth rate as set out in the CPIER, the Councils suggest that the OAHN target may need to be increased to around 66,700 by 2040, equivalent to a completion rate of some 2,900 each year. This represents an increase of some 75% over the current target which the Councils are failing to meet. It also represents an increase in the Greater Cambridge housing stock of more than 50% in just two decades. Is this realistic, deliverable or indeed desirable?: - are there sufficient sites that have the necessary transport and infrastructure in place without having to remove high quality agricultural land from food production or cause damage through new transport schemes? - is the water supply adequate for this scale of development? Electricity supply? How will the waste management be handled? - our large green spaces such as Wandlebury are already starting to reach capacity, where will the funds come from to provide additional large green spaces or expand the existing ones in order to have sufficient to accommodate such an increase in population? - what impact would such a massive and rapid increase in population have upon local services like education and healthcare? - how can the already overloaded infrastructure accommodate such an expansion? What effect will it have on traffic congestion, or crowds in Cambridge? - what impact would this growth have on the quality-of-life of current residents? • To absorb such a disruptive short-term increase would require a massive programme of capital investment – for example, a new reservoir in the East Anglia region to ensure adequate water supply, new waste incineration and sewage treatment works, additional capacity for the electricity supply, and the like. It would be folly to assume that the current infrastructure could accommodate such a massive surge in demand with just a little tweaking here and there. There is already a substantial infrastructure deficit just to accommodate the much smaller current growth projections, so where is this additional investment coming from? Central Government? Until and unless the investment funds are forthcoming, any increase over the Government’s figure of 41,000 should be resisted. • Even if the necessary infrastructure was forthcoming (which would seem improbable with the Government’s focus on the North), do we want to see Cambridge transformed from a compact, green city with its world-class historic core into a sprawling metropolis? The irony is that such a rapid rate of growth would do serious damage to the character and ambience of Cambridge such that its international competitiveness would be impacted, resulting in a drop in the demand that was driving the unsustainable growth in the first place. We cannot afford to trash a lovely historic city in an unsustainable dash for growth. • CambridgePPF is concerned that rapid housing growth together with a fast train service would simply attract more London commuters and that Cambridge could be providing London overspill. Does the Council have data that show the proportion of new build within and around Cambridge that is already housing London commuters? Cambridge South Station will increase the London commuter pressure and we won’t know the impacts of this until the late 2020s. • Some employment (and related housing) growth should be encouraged to disperse from greater Cambridge in order to reduce pressure on the over-heated local economy. Until pressures are relieved, we believe such growth would best be located in towns and cities that have good public transport connections to main centres (London, Cambridge) such as Ely, Peterborough, St Neots, Huntingdon, Bedford, Milton Keynes, etc.
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Neither agree nor disagree See comments above. [It is reasonable for the Greater Cambridge councils to plan for more homes than the standard methodology requires, as the standard methodology is a minimum figure. A higher need can be planned for such as taking into account economic circumstances. However, the Plan indicates potential for a substantial over provision of over a thousand more homes above that required by the standard methodology. The wider impact of this level of growth would need to be assessed, including the impact on local and strategic infrastructure such as the A14, park and rides, and platform capacity at Cambridge Station.]
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We cannot precisely predict what our housing needs will be in 20 years, but we need to build to what data we have. If that means building to the minimum, do it. This could mean that unexpected or unpredicted needs are not met but if the data is correct, this should be minimal. The numbers need to be achievable and publicised. If the data is accessible to all, businesses could be encouraged in knowing that housing stock in an area they are about to invest in is planned.
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• To provide a higher number of homes presupposes that the economy will grow as predicted, and is desirable. This is highly contentious and ignores the question of whether wider resource restrictions will eventually limit growth. It also ignores the question of whether such growth will result in a Greater Cambridge that maintains the present quality of life (let alone an improvement to it), and the quality of the the built and natural environment. Will we have shot the goose that laid the golden egg? • An increase in the Greater Cambridge housing stock of 50% in just 20 years is not remotely desirable, and may not even be deliverable.
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1.24 Our clients strongly agree that the Councils should plan for a higher number of homes than the minimum required by Government. Whilst Paragraph 60 of the National Planning Policy Framework (NPPF) identifies the use of the Government’s standard method for assessing local housing need it also acknowledges that an alternative approach can be justified in exceptional circumstances based on demographic trends and market signals. 1.25 The Greater Cambridge area has enjoyed years of strong economic growth alongside a persistent under-delivery of new homes. This has resulted in significant issues with affordability of housing in the city and surrounding villages. Therefore, it is essential that the Councils’ future housing targets seek to address both the future growth aspirations of the Greater Cambridge area and the acute affordability issues that it presently suffers from. 1.26 The Issues and Options document clearly identifies a level of economic growth that will further increase the historical imbalance between the delivery of new homes and jobs in the area. Therefore, our clients strongly believe that the predicted economic growth in the area justifies the Greater Cambridge Local Plan planning for a level of housing growth in excess of the figures identified by using the Government’s standard method. This approach would be entirely in accordance with paragraph 60 of the NPPF. 1.27 Should housing needs continue to be constrained by the Councils seeking a delivery target based on the standard method alone, without taking into account other material considerations that are unique to the Cambridge area, then the proposed big themes of the Local Plan will never be achieved. The economy of Cambridge is too important both nationally and globally to plan for the minimum number of homes and the Councils will need to be more flexible in the approach they adopt for calculating future housing needs. 1.28 It is evident that the Greater Cambridge area has been providing insufficient housing over successive plan periods and therefore a substantial uplift in the level of housing growth is necessary to redress the imbalance between new homes and jobs that has resulted in a housing market where affordability has worsened significantly over the last 10 years. 1.29 The implications of a failure to positively plan for the bespoke housing needs of the Greater Cambridge area will be that existing residents will continue to suffer the negative impacts of the widescale daily in-commuting of workers from outside the area. This in-commuting will continue to have wider environmental and health implications that impact negatively on the quality of life of residents of the villages of South Cambridgeshire in particular. 1.30 In accordance with the requirements of the NPPF any housing targets, whether they be for the Greater Cambridge area or individual allocations, should be clearly identified as minimum figures in order to stimulate positive growth. This would also accord with paragraph 59 of the NPPF that requires Councils to boost the supply of housing.
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The Councils correctly recognise that housing is one of the most important issues in planning and one that must extend beyond considerations of meeting the minimum needs as calculated using the standard method. Using the Governments approach results in a local housing needs assessment of circa 1,800 dwellings per annum (dpa). However, it is important to recognise that the Government state in PPG that this is the minimum number of homes that must be planned for and that it does not attempt to predict the impact of other factors. Therefore, in an area with strong economic growth, and aspirations to maintain this growth, as well as the affordability of its housing stock continuing to decline it will be important for the Greater Cambridge Plan to establish a housing requirement that seeks to address both these concerns. Economic growth What is evident from the evidence base supporting the local plan is that 1,800 dpa minimum established using the standard method will not be sufficient to support the economic growth expectations of Greater Cambridge. The work of the Cambridge and Peterborough Independent Economic Review (CPIER) sets out a compelling case for higher levels of housing growth within the Greater Cambridge area and warns of significant negative impacts on both the local and national economy should housing needs continue to be constrained. We note that the consultation document recognises this fact and it must play a significant factor in the decisions regarding this local plan. The economy of Cambridge is too important nationally for the Council to plan for the minimum number of homes required by the standard method. Affordability However, the increased demand for housing arising from the economic success of Cambridge also makes the area increasingly unaffordable. Whilst this is an undoubted concern for all residents of Cambridge looking to meet their housing needs it is also an issue for businesses looking to move to the area. It is interesting to note from the CPIER work that the Greater Cambridge area would seem to have been underestimating jobs growth and its impact on the demand for new housing. Whilst the insufficient supply of housing does not appear to have, at present, impacted on economic growth the ramifications of under provision can be seen in the housing market where affordability has worsened significantly over the last 10 years. Housing that is available at a reasonable price is key to attracting and retaining skilled employees. Without it there must a concern that Greater Cambridge may not be able to achieve its aspirations for continued economic growth and that it may actually suffer if this issue is not addressed. Infrastructure PPG outlines that Councils should consider the impact of strategic infrastructure improvements that are likely to drive an increase in the new homes locally. The Councils will therefore need to consider when establishing its housing requirement how improvements in infrastructure such as the East-West Rail link between Cambridge, Oxford and Milton Keynes will have significant economic benefits for the Greater Cambridge area and how the Councils can support this infrastructure both in terms of the scale and location of new development. London’s backlog These improvements in infrastructure and growth expectations must also be viewed in tandem with the continuing inability of London to meet its own needs for housing. The capitals shortfall in housing delivery has now expected to be over 140,000 units between 2018 and 2028 following the conclusion of the Inspectors examining the plan that the supply of small sites in outer London Borough’s had been significantly overestimated leading to the recognition at paragraph 175 of their report1 that London will fail to meet its housing needs “by some margin”. Whilst not a direct neighbour there are strong links between the Capital and Cambridge and an increasing backlog in delivery against housing needs in the capital and strong jobs growth in Greater Cambridge could potentially see an increasing amount of households migrating to Cambridge and fewer leaving to work in the capital. Indeed, the CPIER report acknowledges this position recognising the substantial knock-on effects on demand for housing across the wider south east as a result of the under supply of new homes in the capital. Recommendation All these factors will require the Councils to establish a housing requirement far in excess of the minimum number of homes that results from the application of the standard method. It is evident that the Greater Cambridge area has been providing too little housing in recent years and that the substantial uplifts being suggested are clearly necessary. We would therefore support the option of delivering at least 2,900 homes per annum within this local plan.
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1.24 Our client strongly agrees that the Councils should plan for a higher number of homes than the minimum required by Government. Whilst Paragraph 60 of the National Planning Policy Framework (NPPF) identifies the use of the Government’s standard method for assessing local housing need it also acknowledges that an alternative approach can be justified in exceptional circumstances based on demographic trends and market signals. 1.25 The Greater Cambridge area has enjoyed years of strong economic growth alongside a persistent under-delivery of new homes. This has resulted in significant issues with affordability of housing in the city and surrounding villages. Therefore, it is essential that the Councils’ future housing targets seek to address both the future growth aspirations of the Greater Cambridge area and the acute affordability issues that it presently suffers from. 1.26 The Issues and Options document clearly identifies a level of economic growth that will further increase the historical imbalance between the delivery of new homes and jobs in the area. Therefore, our client strongly believes that the predicted economic growth in the area justifies the Greater Cambridge Local Plan planning for a level of housing growth in excess of the figures identified by using the Government’s standard method. This approach would be entirely in accordance with paragraph 60 of the NPPF. 1.27 Should housing needs continue to be constrained by the Councils seeking a delivery target based on the standard method alone, without taking into account other material considerations that are unique to the Cambridge area, then the proposed big themes of the Local Plan will never be achieved. The economy of Cambridge is too important both nationally and globally to plan for the minimum number of homes and the Councils will need to be more flexible in the approach they adopt for calculating future housing needs. 1.28 It is evident that the Greater Cambridge area has been providing insufficient housing over successive plan periods and therefore a substantial uplift in the level of housing growth is necessary to redress the imbalance between new homes and jobs that has resulted in a housing market where affordability has worsened significantly over the last 10 years. 1.29 The implications of a failure to positively plan for the bespoke housing needs of the Greater Cambridge area will be that existing residents will continue to suffer the negative impacts of the widescale daily in-commuting of workers from outside the area. This in-commuting will continue to have wider environmental and health implications that impact negatively on the quality of life of residents of the villages of South Cambridgeshire in particular. 1.30 In accordance with the requirements of the NPPF any housing targets, whether they be for the Greater Cambridge area or individual allocations, should be clearly identified as minimum figures in order to stimulate positive growth. This would also accord with paragraph 59 of the NPPF that requires Councils to boost the supply of housing.
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Yes. Based on the Government’s standard method for calculating local housing need, there is a requirement to provide 1,800 dwellings per year in Greater Cambridge. This is the minimum number of homes that must be planned for and therefore, the local plan should provide for a higher number of dwellings to maintain growth. This will also help to ensure that affordable housing continues to be provided and existing stocks do not decline. The cost of new homes in the Greater Cambridge area is well above the national average. Therefore, the new local plan will need to address the issue of affordability and ensure that more affordable homes are provided, as well as plan for the right number of homes to maintain growth. The local housing need figure of 1,800 dwellings per year is the base line and the starting point for the new local plan. The evidence base that underpins the local plan demonstrates that higher levels of housing growth are required. It is considered that the new local plan should establish a housing requirement that is higher than the minimum number of houses provided by the standard method.
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Delivering significant numbers of new homes in the Local Plan is vital for the continuing prosperity of the area. The CPIER economic report identifies that without sufficient homes to accompany new employment, employers will look elsewhere, including potentially outside of the UK. The steadily increasing house prices in Cambridge and the surrounding region make it one of the most unaffordable locations to live in the country (ibid). A continuation of the trajectory of increasing house prices will see inequality increase as those on lower earnings are priced out of the area. MGH agrees with the issues raised by the Issues and Options report, that if insufficient housing is built to meet local need this will result in: - - worsening affordability; - damage to the local economy; - damage to equality and social inclusion; - adverse implications arising from climate change; and - adverse impacts on the ability of people to live healthy lives. The government has been clear that the Oxford Cambridge Arc should support economic growth. To do so will require housing to support the growing local work force. The Cambridgeshire and Peterborough Growth Deal* is predicated on the delivery of increased employment growth. The CPIER indicates that in order to realise the growth that could be delivered, a total of some 2,900 homes per year will be needed. If such levels cannot be reached, the Local Plan will fail in its ambitions to deliver other key objectives in terms of social and environmental improvements. MGH strongly agrees that the Local Plan should provide for higher levels of housing growth to support a strong economy, in accordance with government policy. * Cambridgeshire and Peterborough Devolution Deal
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Yes, strongly agree Thakeham note that the Councils’ current calculations using the Government’s ‘standard method’ indicate a need for 1,800 homes per year, or 40,900 homes for the suggested plan period of 2017-2040. However, Thakeham also note the Councils’ indicative calculation based on CPIER suggests that if the jobs growth is achieved, around 2,900 homes a year would need to be built in Greater Cambridge – an indicative total of 66,700 homes over 2017-2040. Thakeham is supportive of the Councils’ seeking to allocate additional provision beyond the local housing need derived from the standard method outlined above, in order to provide flexibility to support the Councils’ economic growth. Thakeham would like to highlight that Planning Practice Guidance (PPG) states that this is the minimum number of homes that must be planned for and therefore does not consider the impact of other factors (Housing Supply and Delivery - Paragraph: 001 Reference ID: 68-00120190722). This approach is also in accordance with PPG which identifies that the housing need number set out in household projections should be adjusted to reflect appropriate market signals including labour demand as well as other market indicators of the balance between the demand for and supply of dwellings (Housing and Economic Needs Assessment PPG Paragraph 027 Ref. 2a-027-20190220 Dated 20/02/2019). However, Thakeham would like to raise concern that there is no mention of a 5% buffer being applied to the Councils’ calculations. In accordance with PPG, to ensure that there is a realistic prospect of achieving the planned level of housing supply, the Local Planning Authority are required to provide a minimum buffer of 5% to ensure choice and competition in the market, applied to the requirement in the first 5 years (including any shortfall), bringing forward additional sites from later in the plan period which will result in a requirement over and above the level indicated by the local housing need figure. (Housing Supply and Delivery - Paragraph: 022 Reference ID: 68-022-20190722) Thakeham would like to raise concern that the Greater Cambridge Local Plan consultation document has not mentioned the wider housing market area and how this unmet need by neighbouring Authorities, impacts Greater Cambridgeshire’s housing need. Given the affordability issues in Cambridgeshire, it is highly likely the housing market area for Cambridge City and South Cambridgeshire is shared with neighbouring authorities. In accordance with the NPPF, the Councils’ have a duty to co-operate on housing issues crossing administrative boundaries. Local Plans are required to meet their “full objectively assessed need for market and affordable housing in the housing market area, as far as consistent with the policies set out in this Framework” (NPPF, paragraph 47). Whilst it is pleasing that the Councils’ appear to be looking to meet their housing needs in full it is important to consider whether any unmet needs from other authorities in the housing market area needs to be met within the Greater Cambridge Local Plan. Based on the above, this means the Councils’ should be identifying sites in in the next Local Plan period, to incorporate a 5% buffer and unmet need from neighbouring authorities.
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3.2 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. 3.3 In accordance with the National Planning Policy Framework (NPPF), the starting point for deciding how many homes need to be planned for in the emerging Greater Cambridge Local Plan is a local housing need assessment, conducted using the ‘standard method’ unless exceptional circumstances justify an alternative approach which also reflects current and future demographic trends and market signals (NPPF, paragraph 60). 3.4 The standard methodology is set out in Planning Practice Guidance (PPG)(Housing and economic needs assessment ) and uses a formula to identify a minimum annual housing need figure, calculated by setting the baseline household growth projection and then adjusting is to take account of affordability and finally capping the level of any increase. The standard method does not produce a housing requirement figure and neither does it reflect economic growth requirements. 3.5 Compared with the adopted 2018 Local Plans’ combined target of 1,675 homes per year, the standard method calculation for Greater Cambridge indicates a minimum need of around 1,800 homes per year. This in itself would require a further 17,950 homes to 2040. 3.6 Reflecting paragraph 60 of the NPPF, PPG (paragraph 10) explains that, "The standard method for assessing local housing need provides a minimum starting point in determining the number of homes needed in an area. It does not attempt to predict the impact that future government policies, changing economic circumstances or other factors might have on demographic behaviour. Therefore, there will be circumstances where it is appropriate to consider whether actual housing need is higher than the standard method indicates.” 3.7 PPG includes reference to circumstances under which housing need should be higher than derived using the standard method, including growth strategies, strategic infrastructure improvements and authorities agreeing to take on unmet need for neighbouring authorities. 3.8 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. The National Infrastructure Commission (NIC) published a report into the CAMKOX arc in 2017 (Partnering for Prosperity: A new deal for the Cambridge- Milton Keynes-Oxford Arc ). This recommended that the current housing delivery rates will need to double up to 2050 to realise the Arc’s economic potential, with a goal to deliver 1 million new dwellings in the arc by 2050. 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. This level of growth would also require significant investment in new transport infrastructure, including East-West Rail and an Expressway connecting Cambridge and Oxford. 3.9 At the sub-regional level, the Cambridgeshire and Peterborough Combined Authority has ambitious growth strategies for the area, with the Greater Cambridge Partnership (GCP) tasked to deliver infrastructure and a City Deal including £500m funding. The Combined Authority established the Cambridgeshire and Peterborough Independent Economic Commission to develop an evidence base and inform policy decisions. The Cambridgeshire and Peterborough Independent Economic Review (CPIER) was published in 2018 and it reported (page 9): “Growth in employment has not been matched by corresponding house-building, or developments in infrastructure. Consequently, house prices haves soared and journey times have increased as congestion has intensified. This has meant that many have been forced to endure unpleasant commutes or been priced away from the city altogether due to the unaffordability of rents. This is bad for both people and business, and we believe is an unsustainable approach to growth.” 3.10 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.’ 3.11 The CPIER indicates that housing supply across the whole area (the Combined Authority Area) should be in the range of 6,000-8,000 homes per year over the next 20 years. For the Greater Cambridge area this translates into a CPIER figure of around 2,900 homes per year, which results in an indicative total of 66,700 homes over the Local Plan period 2017-2040. 3.12 Following the recommendations of the NIC report (2017) and the CPIER (2018), Cross Key strongly agree with the approach of planning for a higher number of homes than the standard method minimum. In order to support the growing economy, and key national, strategic and sub-regional growth strategies, a step-change in housing delivery is needed in Greater Cambridge to ensure that growth is sustainable 3.13 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.
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Yes. Paragraph 60 of the National Planning Policy Framework (NPPF) outlines that strategic policies should be informed by local housing needs, using the Government’s standard method unless exceptional circumstances for an alternative approach can be justified which reflect current and future demographic trends and market signals. The evidence and explanation provided at page 61 and 62 of the Issues and Options document, regarding the scale of the future economic growth in area, justifies and indeed necessitates the need for the Greater Cambridge Local Plan (GCLP) to plan for housing growth in excess of the Government’s standard method figures. This would be entirely in accordance with paragraph 60 of the NPPF. Indicative calculations from the Cambridgeshire and Peterborough Independent Economic Review (CPIER), are that around 2,900 homes a year would need to be built in Greater Cambridge, creating an indicative total of 66,700 homes over 2017-2040. This compares with the adopted 2018 Local Plans target of 1,675 homes per year, and 1,800 homes per year to meet local needs using the Government’s standard method. Based on the CPIER 66,700 housing need figure the Issues and Options document states that the Local Plan will need to allocate housing sites capable of delivering an additional 30,000 dwellings over and above the sites already in the pipeline to be built out between 2017-2040. Given the early stage of the plan preparation and the need for further technical work and analysis regarding economic growth and housing need it is recommended that the additional 30,000 dwelling figure, based on the CPIER findings, is viewed as a minimum by the Councils. Indeed, the NPPF itself requires housing targets to be viewed as minimum figures in order to stimulate positive growth. The Councils will need to adopt a flexible approach to setting the increased housing target to ensure that available land is used efficiently to meet the economic and housing needs of the area. By planning proactively for increased rates of housing the GCLP will support and stimulate the anticipated economic growth and job creation in the area and in turn support the growth of the Cambridge area as it becomes a global leader in innovation. Preparing the GCLP on the basis of an enhanced figure to address economic growth is entirely justified given the context provided by the Cambridgeshire and Peterborough devolution deal, which aims to double economic output in the 25 years, and the continued high rate of job creation in Cambridge. Having established the principle and need to deliver a rate of housing growth above that set out by the Government’s figures, the Councils will now need to prepare and publish the evidence base to support the increased housing target for Greater Cambridge. This should be published as part of the next GCLP consultation; alongside a SHLAA review of the housing sites put forward by developers, land promoters and landowners. In our assessment, based on the information available and content of the Issues and Option document, it is strongly recommended that the GCLP plans for an increased housing need figure. This will support economic growth, reduce inequality, increase affordability levels and promote wellbeing through the delivery of additional market and affordable housing in sustainable locations. Even at this early stage of the plan preparation process it is evident that exceptional circumstances exist in this instance to justify increased housing delivery in accordance with paragraph 60 of the NPPF. It is inevitable that there will also be a need to undertake a Green Belt review as a result of these same exceptional circumstances.
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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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No answer given
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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 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 Within Greater Cambridge 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 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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Southern and Regional Developments (Swavesey) 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 consdiered 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 Comment: 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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4.88 In addition to supporting the growing economy, the Local Plan should provide sufficient scope and flexibility, including location to allow for changing circumstances and demand.
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Neither agree nor disagree. The number of homes to be provided should at least in part be influenced by the environmental capacity of the area to support new development. A study should be undertaken to consider the capacity of the area both in terms of considering the natural and historic environment, infrastructure capacity and planning constraints. This in turn will help to inform the appropriate level of growth. As the OxCam Arc agenda continues to emerge, this may also have a bearing on the required level of growth for the area. Without such evidence it is difficult to comment on an appropriate level of growth for the area.
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STRONGLY DISAGREE. Why no option for this?????? ENVIRONMENTAL CAPACITY is the key! Thorough review needed. Housing has not kept pace with existing growth in jobs. Yet further growth will not provide flexibility. As described by a Tech sector colleague, such a predict and provide approach will accelerate to catastrophe!
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This new Local Plan should seek identify a suitable housing requirement that balances with the economic growth ambitions of CCC/SCDC and the wider area. The new Local Plan should seek to identify and allocate sites that are sustainably located and provide the best opportunity to tackle and progress the four big themes identified in the Issues & Options. One of the Key Recommendations of the Cambridgeshire and Peterborough Independent Economic Report (CPIER)(2018) states that there should be a review of housing requirements based on the potential for higher growth in employment. It advises that dialogue with the ONS and the Centre for Business Research on employment numbers, as well as the impact on Cambridge-Milton Keynes-Oxford Arc, should be used to set new targets that are likely to be higher than those already set (Page 12). The report recognises that "no economy can achieve its potential without an adequate supply of housing" (Page 12). Therefore, it is our view that the standard method is used as a starting point for calculating OAN and that GCPS should seek to increase this target by positively responding to the evidence base, the findings in the CPIER and the Government's ambitions for the Ox-Cam corridor.
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European Property Ventures(Cambridgeshire) are of the position 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 consdiered 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 need to assure flexibility and to support the significant economic growth experienced in the Plan area.
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7.2 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. 7.3 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 5 Cambridgeshire and Peterborough Industrial Strategy 2019, p13
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See responses to Questions 5, 6, 16 and 31. Response Q5: No. The most important cross-boundary issues have been omitted completely. Firstly, the presumption of ‘growth’ and the growth corridors of Ox-Cam and London-Stansted-Cambridge have been accepted without question. Secondly, there has been no consideration as to how this major investment of national funds in the relatively well-off south-east will further reduce or limit investment in the North of the UK. Cambridgeshire hosts a significant proportion of this country’s best and most versatile farm land. By the end of this century it is probable that climate change will have caused significant loss of the Fens which currently grow 24% of UK food supply. Therefore it is imperative that the remaining farm land is not built on but preserved for food supply. This is a national issue. There are currently 1 million empty homes in the North and Midlands which could be brought back into use and space for a further 1 million homes on brownfield sites in the North and Midlands. Investment in these would preserve Cambridgeshire’s precious farm land for food supply. Furthermore, climate change and other environmental issues are caused by untrammeled economic growth. Therefore, this Plan should be addressing how to reduce growth whilst maintaining adequate standards of living in our Region. CPRE is very concerned by the complex structure of authorities across local government within Cambridgeshire. Including the GCP and the Combined Authority with County, District and Parish/Town councils there are now four levels of planning authority on some issues and five levels of local government on many others. This brings severe communication challenges and the practicalities associated with the duty to co-operate. Overlapping authorities and bodies cause confusion to the public and make decision making and accountability difficult to understand. For example on transport there has been intense public argument between the Combined Authority and other bodies. Response to Q6: Partially. Climate Change is the most pressing issue of our time. However, all the other themes are predicated upon ‘growth’ and growth has to be halted in a controlled manner if climate change is to be minimised without unacceptable effects on the poorer and more vulnerable people in our society. With that caveat, the other themes are appropriate. Society must recognise there is no such thing as “sustainable development”. The term is a non-sequiter. All development has varying degrees of unsustainability. Just look at building materials. Bricks leave holes in the ground where clay is dug. They create carbon dioxide when the clay is fired and more when they are transported from Belgium or Holland as most are. Cement burns more fuel, generating more carbon dioxide and so on… Therefore development must be minimised and better use made of existing facilities. Response to Q16: There is no such thing as ‘good growth’. It is becoming increasingly apparent that the growth economic model has to be substantially modified or even abandoned if the human race is to survive. However, there can be good developments in which effective planning and design can promote wellbeing and social cohesion. A good mix of housing, with sufficient truly affordable housing which includes housing for different age groups and housing suitable for the physically challenged will assist. Consideration needs to be given to ongoing care and maintenance, including security and the delivery of services, if wellbeing and social cohesion are to be maintained. More green and blue integrated infrastructure will assist mental health and well-being. Design standards should be maintained through provision of Design Guides and Landscape and Townscape Assessment. There must be a strong policy on building to meet the challenges of climate change minimisation and mitigation. Design Standards and build quality musty be firmly enforced once permission for development is granted to ensure the actual development is carried out in precise accordance with standards and policies. Building control must be strengthened and returned to be completely under the control of the local planning authority. Response to Q31: It should take a need-led approach and apply modern modelling techniques to forecast the resulting demand. The skills are available in the City and its two universities. The current conflation of ‘need’ with ‘demand’ is causing a situation where numbers matter more than type and tenure of housing. See CPRE’s study at: https://www.cpre.org.uk/wp-content/uploads/2019/11/HousingZForesightZPaperZ8.pdf There has to be a better approach than the ‘5-year housing supply’ currently imposed by the NPPF.
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The adopted Local Plans allocate land for 33,500 homes to 2031. However, current calculations using the Government’s standard method indicates a need for 1,800 homes per year, or 40,900 homes for the Plan period 2017 – 2040. This represents significant growth and associated development pressure across Greater Cambridge. In light of the Councils’ ambitious targets for zero net carbon, more efficient water use and ‘doubling nature’ our major concern is whether the proposed level of growth, and the additional infrastructure needed to support it, will be truly sustainable i.e. capable of having no adverse environmental impact and contributing towards the 100% BNG target. Also to ensure legal compliance it will be necessary to ensure assessment of the maximum number of houses through the SA and HRA, rather than a minima figure. As discussed above, the Local Plan will need to promote the delivery of a strategic green infrastructure network that is resilient to the scale of development proposed, capable of protecting designated sites and supporting habitat, and delivering the wider range of environmental services to meet the needs of development.
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- We somewhat disagree with this proposal within this LDP since there are several major new settlements and transport proposals under development at present and the details, impact or timescale of some of these is not yet certain. For example, although the preferred option for the East-West rail link has been announced, is there sufficient certainty to plan for new homes on this route? Will Cambridge South have a significant impact on car use? - We have suggested elsewhere that the 2021 census may provide a much firmer basis for planning. - We suggest that the LDP process should examine the relationship between the cost and types of housing to be provided, inward commuting from nearby areas of lower cost and the potential for the GC area to act as a magnet for people seeking to commute to London. Commuting out provides flexibility for many families and businesses in the GC area but there is a perceived risk that some development will act to serve London’s needs not Cambridge’s.
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2.7 Summary Answer: Yes, we think housing need should reflect the upper housing range recommended in the Cambridgeshire and Peterborough Independent Economic Review (CPIER, 2018) in order to support the forecast and needed economic growth over the next 20 years. This equates to around 2900 homes each year for Greater Cambridge and an uplift of 58% housing supply compared to the current objectively assessed need. Basing the CPIER’s estimates against the existing proportional representation of growth across the adopted development strategy shows the potential need for 6,294 additional homes in rural areas up until 2040 (see Barton Willmore Housing Delivery Study, 2020 – Appendix 1). 2.1 The Cambridgeshire and Peterborough Independent Economic Review (CPIER) 2018 highlighted concern that Cambridgeshire and Peterborough are running a very significant risk of not achieving their economic potential due to insufficient levels of planned housing. It calls for the recalibration of housing need assessments based on more accurate employment growth forecasts, which in turn should set new, higher housing targets – at the very least adding on accumulated backlog. This would require delivery of around 2900 homes per annum in Greater Cambridge until 2040. These indicative housing projections are substantially higher than the Government’s standard method and present exceptional circumstances to justify an alternative approach to the standard method. 2.2 To address this higher housing forecast up until 2040 the development strategy will need to balance the distribution of housing supply and ensure (as per para.59 of the NPPF) that sufficient amount and variety of land can come forward where it is needed. The current Local Plan trajectory places significant reliance on growth sites continuing the housing supply beyond 2031, but such sites are skewed to the north of the district and do not consider communities to the south. The collective proximity of these growth sites to one another also present future challenges in terms of market absorption rates. 2.3 Basing the CPIER’s estimates against the existing proportional representation of growth across the adopted development strategy shows the potential need for 6,294 additional homes in rural areas up until 2040 (see Barton Willmore Housing Delivery Study, 2020 – Appendix 1) beyond the current pipeline of homes that have permission or are allocated in the adopted Local Plans. This relies on the remaining housing need being delivered through densification of Cambridge, further urban fringe sites and new settlements. Whilst some of this need may be coordinated or shared with neighbouring authorities through the duty to cooperate it is highly likely that a great deal of this need will need to be delivered within Cambridge City and South Cambridgeshire taking into account the affordability crisis, sustainability objectives, as well as economic and market forces. Future pressure on Cambridge to densify and further expand its urban fringes will therefore need to be weighed against the harm to its compact and historic character. 2.4 The alternative scenario for the development strategy is to steer a greater proportion of homes towards sustainable rural settlements. As such, there is potential scope to consider the need for more than 6,294 additional homes to be delivered in rural areas up until 2040. In purely quantitative terms this would mean delivering around 60 homes in each of the 106 rural settlements as a minimum. 2.13 In responding to questions 31, 32, 37, 40, 41, 47 and 48, it is important to note that paragraph 78 of the NPPF states that to promote sustainable development in rural areas, housing should be located where it will enhance or maintain the vitality of rural communities. It goes on to promote planning policies that identify opportunities for villages to grow and thrive, especially where this will support local services. 2.14 Frameworks have been defined to take account of the present extent of the built-up area and planned development, but the level of planned development has been notably limited by the application of the settlement hierarchy (Policies S/7 - S/11 of the South Cambridgeshire Local Plan, 2018) and the principle that development can only occur within the settlement framework boundary. This is evident in the categorisation of South Cambridgeshire’s ‘Group’ or ‘Infill’ villages and the tightly drawn settlement boundaries, which have created little room for villages to grow. Examples of this are provided in the appended Barton Willmore Housing Delivery Study (2020). 2.15 Taking into account future requirements for housing land supply and housing affordability, it is clear that current settlement boundaries will need to flex in order to accommodate further growth in sustainable locations. As previously mentioned, the settlement hierarchy has defined the sustainability of each village as determinate rather than giving merit to its transformative potential through sustainable development. We are not arguing here for a removal of the settlement hierarchy, but a recalibration measured against levels of services and facilities in each settlement and potential sustainability enhancing measures such as: • Transport improvements that better connect villages to surrounding larger settlements, employment areas or service centres; • Local transport enhancements that provide more sustainable travel options to services and facilities and/or ease of access for satellite villages surrounding larger or better served settlements e.g. new footpaths/cycleways, real time bus stops; • Increasing capacity of local community facilities to better serve local needs; • Provision of new community services and facilities e.g. play areas, new business incubators; • New housing that provides different sizes, types and tenures to meet the needs of different groups in the community and supports a greater demographic mix; • Provision of much needed affordable housing; • Local employment generation; • New or enhanced access to public open space and recreation (i.e. health and wellbeing gains); and • Net gain in biodiversity and opportunities to ‘scale-up’ local green infrastructure networks. 2.16 The above factors present scope to expand village populations in a sustainable way; the degree of expansion will need to be scored against the level of existing and potential sustainability levels. Not all village settlements will be equal in this regard and therefore a scoping exercise will be required to assess each settlement and preferably define an extent of housing supply matched with new housing land allocations. 2.17 Local communities may have a particular view on the needs of their village or where growth opportunities are best located. Similar to the emerging Bedford Local Plan, housing policy could give the option to local communities to steer allocated growth through a Neighbourhood Development Plan or Neighbourhood Development Order (Regulation 16), or if one has not been submitted the Council can consider the need to allocate additional sites. 2.18 There are further benefits to consider through appropriate expansion of rural settlements. Housing sites in rural areas tend to be small to medium in size, which in turn have shorter delivery times than larger sites. Research by Nathaniel Lichfield & Partners ‘Driving housing delivery from large sites: What factors affect the build out rates of large scale housing sites’ (NLP, 2018) shows that the lead-in time for sites of less than 500 homes take 1.7-1.8 years to deliver the first dwelling after receiving detailed planning permission, whereas larger sites of 2000+ homes take much longer (2.9 years).
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6.3 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. 6.4 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.”5 5 Cambridgeshire and Peterborough Industrial Strategy 2019, p13
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Summary: Strongly agree that 'we should plan for a higher number of homes than the minimum required…, to provide flexibility…for the growing economy'. Full comment: 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'. The draft 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. CPIER recommends that 'rhere 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'. 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. 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 at least 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 both the local and national economy should housing in Greater Cambridge continue to be constrained.
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