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?
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 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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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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Summary: 4.17 In summary, the Trust seek to ensure that any policy relating to student housing should remove the criteria restricting the provision of new student accommodation to those attending a full time course of one year or more. This would enable the provision of student accommodation, outside of the two universities, to be provided and hence enable the expansion of and continued contribution of the establishments to the local economy while being more inclusive. Full Text: 4.2 The Issues and Options document sets out that the next Local Plan period will be 2017-2040. The currently allocated sites and planning permissions are likely to provide 36,400 homes, and a further 9,660 may be built after 2040. A number of sites are already planned which will contribute to future housing need for the next Local Plan. However, the current calculations using Standard Method indicate a need for 1,800 homes per year or 40,900 for plan period 2017-2040. 4.3 It is important to take into account that the Standard Method does not work when applied to ‘niche’ housing and therefore when considered alongside job growth, which has been faster than expected and is likely to continue to grow, undoubtedly results in the demand for housing being exceptionally high. In the Issues and Options document it is set out that if full jobs growth is achieved then 2,900 homes a year would need to be built, equating to 66,700 homes between 2017-2040. 4.4 There is therefore likely to be an additional need beyond the local housing need derived from the standard method of an additional 30,000 homes, particularly if the requirements of specialist housing are not met through the proposed method. 4.5 As has been set out earlier in these representations, continued economic growth within the Greater Cambridge area is a key priority, and therefore there will be a greater demand for more housing to meet the needs of those employed in the area. The Councils’ clearly acknowledge this in their Issues and Options by providing the above higher end growth figures. 4.6 This factor along with the different type of housing required, including student accommodation, will only serve to increase the demand for residential accommodation within the Greater Cambridge area for the foreseeable future, therefore additional housing will need to be provided at the upper level. 4.7 Question 33 of the consultation document asks; “What kind of housing do you think we should provide?” 4.8 The Issues and Option document acknowledges that there is a need to provide market and affordable housing that meets the needs of communities including amongst others, students. 4.9 In January 2017 the Assessment of Student Housing Demand and Supply for Cambridge City Council (ASHDS) was published to help inform the emerging planning policy relating to student accommodation. 4.10 The ASHDS provides a comprehensive assessment of student supply and demand in Cambridge and valuable background evidence. At the time Bell Educational Services participated in the survey undertaken as part of the ASHDS. 4.11 The school falls within the category of ‘non-University institutions’ as defined in the ASHDS. The ASHDS identifies the diverse accommodation arrangements and needs of non-education institutions and confirms that a large proportion of their students make no impact on the housing stock in the City. (Appendix 2 Paragraphs 1.16 part g and 1.34 of ASHDS). 4.12 In paragraph 1.16 of the ASHDS, of the 15,000 non-institutional students in Cambridge, 5,000 (33%) live locally in the parental home. Nearly 30% of students are housed in home stay. This being a fundamental part of their learning experience whilst attending the school. Just under 30% of students are housed in Purpose Built Student Accommodation (private halls or their own accommodation) with extensive use made of this accommodation out of term time making a very efficient use of existing available accommodation. Only 2% of the non-educational institution students (according to the ASHDS) are accommodated in shared housing. 4.13 The ASHDS identifies that all educational institutions in Cambridge have part time students. Both Universities have a proportion of part time students but the majority of part time students (75% of the total population) attend non-university institutions. The non-university educational institutions, such as Bell, offer a range of accommodation for their students who have different accommodation needs. For example, those students under 16 need a place with suitable element of care and supervision. 4.14 The study concludes that due to education being one of the fundamental drivers of Cambridge’s economy, ‘the provision of student accommodation is a necessary feature of the city’s development’. The assessment also advises that ‘a policy that requires new student housing to be located near the education institutions, assuming a walk, cycle or perhaps bus ride’ would be suitable. Reference is also made to the benefits of having a concentration of students residing close to their institution, as this would ‘enable some degree of management and coherent service provision’. 4.15 The current Local Plan 2018 currently differentiates between those institutions providing housing for students on full time courses of a year or more and those that are on shorter courses, many of whom attend the Bell School. 4.16 The Trust considers that there is a clear need for future policy to remove this differentiation and to consider all institutions in a comparable way. Currently policy 46 of the Local Plan 2018, criterion a) requires there to be a proven need for the accommodation to serve that institution. The submission of evidence to prove need as part of a planning application would enable the non-University educational institutions to demonstrate this in the same way as the universities and allow the local planning authority to interrogate the information. A distinction between the Universities and non-university institutions is not necessary and should be removed in future policy.
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It is imperative that the Plan allows for more than the minimum housing requirement in order to safeguard delivery, help meet demand and keep prices more affordable. We note that the Cambridgeshire & Peterborough Independent Economic Review advocates a step change in housing delivery and that the Local Authorities have all signed up to the recommendations of the CPIER report, including its recommendations in respect of housing. We note the ranges of housing numbers quoted in the consultation document. The range of housing to be delivered by the plan could range between: • Government’s Objectively Assessed Need (OAN) figure of 40,900; and • a CPIER compliant figure (aligning housing with economic growth) or circa 66,700 homes. With a committed supply from the existing allocated sites in the Local Plan estimated at 36,400, we note that it would be ‘easier’ to select a housing target at the lower end of the range. However, this would not align with the recommendations of CPIER and risks perpetuating the current issues of housing affordability. CUH would encourage a figure towards the upper end of the range, to ensure housing choice, to boost supply, and to deliver more affordable housing forms of housing tenure. With a larger pipeline, it also provides scope for the Council to meet those in highest need (e.g. homeless or unemployed) whilst also providing forms of tenure which give priority to working people, for both discount rental and discounted forms of purchase. In the spirt of this, we have submitted two documents in support of our representations: 1) “Assessing the Housing Need of Hospital Workers” report prepared by Savills in January 2020. This is research undertaken on our behalf which highlights the real affordability challenges facing our staff, and some of the less desirable outcomes arising as a result. 2) We have prepared a summary report entitled “Delivering Affordable Housing for our Hospital Workers: The Case for Change”. This is a simple, accessible document, which draws out the key findings of the Savills research, and sets out CUH’s corporate priorities in terms of housing, highlighting the critical importance of delivering of genuinely affordable housing in accessible locations, to ensure the growth and prosperity of the area can be supported by the NHS. The research highlights housing as one of the key barriers to CUH in recruiting and retaining key staff and skills. There are commonly delays with the delivery of larger proposals and/or new settlements and therefore to ensure supply is maintained the Plan should allocate more than the minimum requirement, and significantly boosting supply will create more opportunities to deliver more affordable forms of tenure. Our work concludes that more affordable forms of housing, for working people, are required in locations 40 to 50 minutes walking, cycling and public transport journey time from the Hospital. Allocating a greater number of homes will help to bring forward a greater number of affordable houses, identified as urgently needed in the Savills (2020) study “Assessing the Housing Need of Hospital Workers”, which identified that 40% of the Addenbrooke’s workforce or approximately 4,800 employees were either stretched or very stretched in meeting their housing costs and that 2,466 additional affordable houses are needed by the workforce now.
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We note that the 2018 Cambridgeshire & Peterborough Independent Economic Review (CPIER) recommended a review of housing requirements based on the potential for higher growth in employment than currently forecast (by the East of England Forecasting Model).
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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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6.2.1 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. 6.2.2 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.”3 3 Cambridgeshire and Peterborough Industrial Strategy 2019, p13
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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 4 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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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 can 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, of which the Land east of Long Road, Comberton could contribute towards. Please refer to the appended Vision Document titled 'Land east of Long Road, Comberton' produced by Thakeham
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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 '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'. 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 knockon 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 bothe the local and national economy should housing in Greater Cambridge continue to be constrained.
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7.1 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. 7.2 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 in our client’s view 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. 7.3 The Issues and Options document indicates that based on indicative calculations from the Cambridgeshire and Peterborough Independent Economic Review (CPIER), 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. 7.4 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 also 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. 7.5 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. In addition, as set out early in our client’s representations, the continued investment in strategic infrastructure in and around Cambridge will only seek to enhance the area’s credentials as a focus for employment and housing growth. 7.6 Having established the principle and need to deliver a rate of housing growth above that set out by the Government’s figures, the Council’s 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 review of the housing sites put forward by developers, land promoters and landowners. 7.7 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.
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There must be flexibility and not simply in relation to the number of homes but also, flexibility to the wider housing strategy. This should include inter alia, flexibility with village frameworks and how these are defined / could be amended in the future. Not only would this provide flexibility with the spatial strategy and allow policies to ‘identify opportunities for villages to grow and thrive’ (NPPF, paragraph 78) but it would also ensure a mix of sites are brought forward and help to speed up housebuilding. Development should be considered and consistent with a Local Plan and providing flexibility for important infrastructure such as housing will allow the Greater Cambridge area to build on the success of the region as an economic powerhouse and avoid the situation created through the success of the Cambridge / Peterborough devolution deal when demand outstripped supply – ie, a range of size and location of sites are required.
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Summary: Savills (UK) Ltd are instructed by xx to make representations to the Greater Cambridge Issues and Options Local Plan (January 2020) in respect of their land interests to the north of xx, Bassingbourn-cum-Kneesworth Full text: Yes strongly agree Savills (UK) Ltd are instructed by xx to make representations to the Greater Cambridge Issues and Options Local Plan (January 2020) in respect of their land interests to the north of xx, Bassingbourn-cum-Kneesworth. 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. 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.’ It is considered the economic circumstances of the Cambridge area, which has one of the fastest growing economies in the country (https://www.cambridgenetwork.co.uk/news/new-economic-report-highlights-strong-year-cambridge), justifies the need to plan for a higher number of homes in Greater Cambridge than indicated by the standard method, as discussed below. 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. 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. 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.” 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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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 5 Cambridgeshire and Peterborough Industrial Strategy 2019, p13
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The Local Plan should plan for sustainable growth around the key settlements in the Greater Cambridge plan area. Key transport links and employment locations should guide growth, creating places that people want to live. The plan should allocate land appropriately and look to direct growth to existing settlements to enable these to grow. The houses provided on sites should help to meet the needs of local people and it is therefore essential to establish what the need is. Whilst many settlements around the city are within the Cambridge Green Belt, there are opportunities to expand those that do not require the removal of Green Belt land. This is particularly relevant for those settlements like Little Abington that are in close proximity to employment sites and have sustainable links into the centre of Cambridge.
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2.37. It is acknowledged that the local housing need as informed by the Standard Method calculation identifies a need for a minimum of 1,800 homes per year within Cambridge and South Cambridgeshire. It is strongly recommended to the Councils that the emerging Local Plan should be planning for an increased supply of housing in order to support economic growth aspirations for the area and to ensure the full range of housing is provided to meet the needs of the area particularly with regard to student accommodation. 2.38. The CPIER indicates that in order to realise the growth that could be delivered, a total of some 2,900 homes per year will be needed. If such levels cannot be reached, the Local Plan will fail in its ambitions to deliver other key aspects of the Local Plan, which necessarily need to be accompanied by housing growth. 2.39. It is also recommended that the emerging Local Plan is informed by a robust evidence base to establish the size, type, and tenure of housing needed in the area.
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Pigeon strongly agree that the Local Plan should aim to deliver more than the minimum number of new homes defined through the Standard Method. The PPG is clear that the Standard Method provides only the minimum local housing need. It takes no account of economic needs or specialist housing needs including those in need of affordable housing1. It is therefore appropriate to ensure that the housing requirement appropriately reflects these factors to ensure that the needs of different groups are addressed as required by paragraph 61 of the NPPF and that conditions are created to support economic growth as required by paragraph 80 of the NPPF. The PPG (2a-010) confirms that it is necessary to take account of other factors and identifies that the need will be greater than the figure identified by the standard method in circumstances including where previous assessments of need have identified that the need is significantly greater as is the case with Greater Cambridge. The Greater Cambridge economy, driven by the world leading hi-tech and life sciences cluster is of significant importance to the UK economy and with Cambridge lying at the centre of three economic growth corridors. It is therefore vital that the National significance of the Greater Cambridge economy is fully recognized by the two Councils and that its growth continues to be supported. In this regard, the CPIER Report noted that “the levels of planned housing are insufficiently high to accommodate the existing, let alone anticipated growth of the economy.” Additional flexibility (and allocations to achieve it) is therefore needed to allow the market to respond to the rapid growth in the jobs market, to improve choice, access and affordability. There also needs to be a sensible buffer to enable additional demand to be taken up and supply on a wide range of sites to be delivered. Whilst we accept that monitoring can be the basis for reviewing the Plan in future the Councils should be ambitious at the outset in addressing the known national recognition of the value of the area to the economy and setting a target which gives confidence and certainty to the community and the development industry. On this basis, Pigeon considers that the Plan should plan for the provision of around 2,900 new homes per annum to ensure sufficient flexibility to support the growing economy. 1 Although it does take account of the affordability of market housing.
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5.3 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. 5.4 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 1 Cambridgeshire and Peterborough Industrial Strategy 2019, p13
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6.7 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. 6.8 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. 6.9 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. 6.10 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 1 Cambridgeshire and Peterborough Industrial Strategy 2019, p13
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4.46 We strongly agree that the councils should be planning for a higher number of homes than the minimum required. On page 62 of the GCLP, they have already acknowledged that the demand for new housing in the area has been exceptionally high and housing building has not kept up with demand. The previous focus has been on the Cambridge Southern Fringe developments and new towns such as Northstowe. The key word is reference to “minimum” and the NPPF requires all councils to significantly boost the supply of housing. Only planning for the minimum would appear to be contrary to this guidance. In addition, if the approach continues with large scale developments, these are often delayed in coming forward due to infrastructure provision and funding issues. With the level of growth anticipated it is essential that sufficient homes are available to create safe and inclusive communities to avoid increases in commuting and the use of the private car.
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4.45 We strongly agree that the councils should be planning for a higher number of homes than the minimum required. On page 62 of the GCLP, they have already acknowledged that the demand for new housing in the area has been exceptionally high and housing building has not kept up with demand. The previous focus has been on the Cambridge Southern Fringe developments and new towns such as Northstowe. The key word is reference to “minimum” and the NPPF requires all councils to significantly boost the supply of housing. Only planning for the minimum would appear to be contrary to this guidance. In addition, if the approach continues with large scale developments, these are often delayed in coming forward due to infrastructure provision and funding issues. With the level of growth anticipated it is essential that sufficient homes are available to create safe and inclusive communities to avoid increases in commuting and the use of the private car.
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Yes The new Local Plan will need to plan for a significantly higher number of new homes to support the economic growth potential of the Greater Cambridge area. The standard method only sets out a minimum requirement and as outlined in the National Planning Policy Guidance, other considerations such growth strategies need to be taken into account when determining the Councils objectively assessed housing need. As highlighted in the Cambridgeshire and Peterborough Independent Economic Review report a higher number of local homes is needed to support job growth.
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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. The identified site off Royston Road would bring considerable benefits to the local economy during the construction phase of the project and in the longer term new residents would help to support shops and services in the village through an increase in local household spending. It is considered that the additional residents resulting from the proposed development would help the viability of existing services within the village and their future retention.
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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 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 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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Strongly agree. Our client’s site West of Dubbs Knoll Road in Guilden Morden is submitted for consideration. It is wellconnected village which can support an appropriate amount of development to fulfil the aims of the National Planning Policy Framework around promoting and maintaining the vitality of rural communities. As has been identified in the Issues and Options document, South Cambridgeshire and Cambridge Councils are currently planning for the delivery of 1,600 homes per year. The Issues and Options document identified that over the plan period of 2017-2040 there is a need for 1,800 homes per year using the government's calculations. In order to provide flexibility for a growing economy 2,900 homes per year will be required. As set out in Paragraph 010 (Id. 2a) of the Planning Practice Guidance, it should be noted that the ‘Standard Method’ provides a minimum starting point – there should be consideration during the planmaking process of whether other factors indicate that the target should be increased above the figure derived from the standard method. Furthermore, paragraph 60 of the NPPF states that the housing need figure should take into account any needs that cannot be met within a neighbouring area – past trends should be considered, and joint working guaranteed in forming housing targets. To achieve sustainable development the NPPF sets out 3 objectives: social, economic and environmental. In relation to the economic objective, this is focused on " ensuring that sufficient land of the right types is available in the right places and at the right time to support growth, innovation and improved productivity; and by identifying and coordinating the provision of infrastructure", which includes the delivery of homes. South Cambridgeshire Council has a track record of the under-delivery of housing, particularly affordable housing. The 2019 Annual Monitoring Report shows that only 25% of housing delivered was affordable. The Greater Cambridge Housing Delivery Strategy acknowledges the unaffordability of housing within Cambridge, and states that a greater proportion of affordable housing is required in the greater Cambridge area. Whilst there is an existing 20% buffer applied as part of the Local Plan, in accordance with the NPPF, it is considered that consistent under-delivery over the Plan period will affect the requirement for housing in the new Plan period. The forthcoming Plan will be required to ensure that an appropriate amount of housing, particularly affordable housing is delivered which also considers any historic under-delivery from the previous Plan period. The Greater Cambridge Issues and Options Document has identified that the economy of the area is growing. Paragraph 80 of the NPPF requires local authorities to allow the expansion and growth of business. Cambridge therefore requires relevant infrastructure, including the delivery of homes, to meet and deliver this growth. Providing the flexibility for growth will give confidence to investors that Cambridge continues to provide and invest in opportunities for business. Paragraph 73 of the NPPF makes it clear that a 5-year housing land supply is a minimum requirement to be delivered by the local authority and not a maximum number. The flexibility in the NPPF therefore allows local authorities to deliver more housing where it is required, such as in Cambridge where the growth of the economy is ongoing. Additionally, providing the flexibility for growth will also ensure that a diverse range of workers have employment opportunities and a choice of home across Greater Cambridge. If housing does not meet the needs of a variety of workers and families, there will be outward migration to areas which satisfy this need. This is of particular importance when considering the diverse nature of Greater Cambridge's towns and villages and the retention of the existing population. The NPPF aims to deliver balanced, mixed communities and the siting of sustainable housing development in these areas is essential in meeting the requirements of paragraph 78 of the NPPF in retaining the vitality of rural communities. Additional housing in villages would support other wider aims in Greater Cambridge, including the strengthening of rural businesses by providing housing for existing and potential employees. Summary of Comments: Paragraph 73 of the NPPF makes it clear that a 5-year housing land supply is a minimum requirement to be delivered by the local authority and not a maximum number. The flexibility in the NPPF therefore allows local authorities to deliver more housing where it is required, such as in Cambridge where the growth of the economy is ongoing. Additionally, providing the flexibility for growth will also ensure that a diverse range of workers have employment opportunities and a choice of home across Greater Cambridge. If housing does not meet the needs of a variety of workers and families, there will be outward migration to areas which satisfy this need. This is of particular importance when considering the diverse nature of Greater Cambridge's towns and villages and the retention of the existing population. The NPPF aims to deliver balanced, mixed communities and the siting of sustainable housing development in these areas is essential in meeting the requirements of paragraph 78 of the NPPF in retaining the vitality of rural communities. Additional housing in villages would support other wider aims in Greater Cambridge, including the strengthening of rural businesses by providing housing for existing and potential employees.
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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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We support the Plan’s approach in proposing additional housing to provide flexibility and support the identified economic growth, at 2,900 homes a year. The trajectory of development must not be pushed backwards in the Plan. Meeting Cambridge’s housing need, particularly for affordable homes, is a pressing need and should be reflected in an accelerated rate of approvals from the start of the Plan period. In order to best address the affordability issues in Greater Cambridge and seek to ensure the needs to all community groups are addressed, the widest possible range of types, sizes and tenures of homes should be planned for in a wide variety of locations. This would also ensure that the Local Plan accords with Paragraphs 59, 61, 68 and 78.
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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 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.”* *Cambridgeshire and Peterborough Industrial Strategy 2019, p13
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3.67 Altogether it has been estimated that more than 30,000 extra homes, above those already in the pipeline, could be built in the Greater Cambridge area by 2040. Grosvenor and USS support a plan for a higher number of homes to support the growing economy. However, it should be complimented with additional infrastructure and public services so that it does not compromise quality of life. Both Councils should carefully consider the priorities of their area to ensure local needs are being met. For example, a top priority for the South Cambridgeshire District Council is to reduce commuting travel and ensure the provision of homes specifically targets essential local workers. In addition, the demographic profile is also changing, with the proportion of those aged over 65 significantly increasing. Therefore, the Councils should promote a range of housing options across all tenures to accommodate for the growth of people and families. 3.68 The CPIER makes it clear that the area can plan for significant employment and housing growth successfully but acknowledges that each area needs to carry out their own detailed modelling work which will form part of a concrete evidence base. This in turn helps to inform the strategic planning requirements of the area. Higher levels of housing, where delivered in the most sustainable locations, such as at Trumpington, will have positive impacts on social, environmental and economic factors.
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