Question 33. What kind of housing do you think we should provide?

Southern & Regional Developments (Willingham) identify that it is crucial for the delivery of housing, particularly bedroom size and tenure mix, to reflect the findings of the Strategic Housing Market Assessment. However, to ensure that development can truly address local needs and respond to locational characteristics, such development requirements for residential proposals should not be overly or inappropriately prescriptive. Schemes for residential development should be required to deliver a housing mix that most appropriately caters for the needs of the community it will serve and should not be controlled by a restrictive development management policy which applies particular obligations for development to deliver at the strategic level. It is recognised that affordability is a major issue within Greater Cambridge, particularly within the rural areas and villages. Southern & Regional Developments (Willingham) consider there is a need for the emerging Local Plan policy to address this issue and ensure that a mix of types and tenures is catered for across the whole of the plan area. Similarly, where settlements are dominated by a particular housing type or scale, there should be the opportunity through emerging plan policy for Development Frameworks to be suitably amended. Southern & Regional Developments (Willingham) maintain that although the new Plan should include policy guidance on housing types, including size and tenure mix, such guidance should be supported by the most up to date evidence and have the ability to respond directly to specific local requirements. The wording of any policy should reflect this and provide suitable provisions for housing mix to be informed by local circumstances and market influences. Taking into account the size of the plan area and the varied characteristics of the area, it is important that any policy guidance includes an appropriate degree of flexibility in its requirements for housing development. For example, housing mix requirements will differ between settlements across the entire Plan area, given that the needs of rural South Cambridgeshire will be different from those within Cambridge City. It is therefore important that any attempt to include specific housing mix and type requirements within development management policies should ensure a degree of flexibility and acknowledge locational considerations. Summary of Comments: Policies for housing mix/type should not be prescriptive and should reflect the requirements as identifed in the latest SHMA.

There should be flexibility within the Local Plan to respond to changing housing needs over the Local Plan period. Consideration of individual site circumstances and the circumstances of a local area should be taken into account to determine the appropriate type of housing for development sites. Separate housing needs assessments should be used to inform the appropriate size, type and tenure of housing needed for different sections of the community, as set out within the Greater Cambridge Housing Strategy 2019-2023. Flexibility will be key to a successful Local Plan; through market housing, low-cost and affordable housing. The Government is committed to building a housing market and recognise that for too many people homeownership is unaffordable. The Local Plan should seek to facilitate home ownership and support established, new and innovation routes into home ownership. Appropriately worded design policies should require a high-quality design for new developments. Policy should not be prescriptive for precisely how it will be accomplished, it can set a policy level, but developers should be able to use a host of options to achieve the target.

Southern & Regional Developments (Waterbeach) consider that it is important for the Plan to deliver a varied range of housing, particularly with respect to bedroom size and tenure mix that reflects the findings of the Strategic Housing Market Assessment. However, to ensure that development can truly address local needs and respond to locational characteristics, such development requirements for residential proposals should not be overly or inappropriately prescriptive. Schemes for residential development should be required to deliver a housing mix that most appropriately caters for the needs of the community it will serve and should not be controlled by a restrictive development management policy which applies particular obligations for development to deliver at the strategic level. It is recognised that affordability is a major issue within Greater Cambridge, particularly within the rural areas and villages. Southern & Regional Developments (Swavesey) consider there is a need for the emerging Local Plan policy to address this issue and ensure that a mix of types and tenures is catered for across the whole of the plan area. Similarly, where settlements are dominated by a particular housing type or scale, there should be the opportunity through emerging plan policy for Development Frameworks to be suitably amended. Claremont Planning maintain that although the new Plan should include policy guidance on housing types, including size and tenure mix, such guidance should be supported by the most up to date evidence and have the ability to respond directly to specific local requirements. The wording of any policy should reflect this and provide suitable provisions for housing mix to be informed by local circumstances and market influences. Taking into account the size of the plan area and the varied characteristics of the area, it is important that any policy guidance includes an appropriate degree of flexibility in its requirements for housing development. For example, housing mix requirements will differ between settlements across the entire Plan area, given that the needs of rural South Cambridgeshire will be different from those within Cambridge City. It is therefore important that any attempt to include specific housing mix and type requirements within development management policies should ensure a degree of flexibility and acknowledge locational considerations. Summary of Comments: Policies for housing mix/type should not be prescriptive and should reflect the requirements as identifed in the latest SHMA.

Paragraph 61 of NPPF expects the size, type and tenure of housing needs of the community to be assessed and reflected in planning policies, including for example those with an affordable housing need, students, renters and self-builders. It is noted that the existing and planned new settlements in South Cambridgeshire and some of the strategic sites are not delivering policy compliant levels of affordable housing. As such, it is considered that emerging GCLP should seek to allocate sites which are capable of delivering policy compliant levels of affordable housing. The promoted development at land off Station Road in Willingham includes housing, affordable housing and self-build plots.

Whilst Persimmon recognises the need for appropriate diversity in the delivery of housing types and tenures, the quantitative need for and the potential uptake of these must be properly understood if they are to be planned for effectively. The application of any detailed policies must specifically respond to the scale of need and demand and this must be demonstrated through an appropriately robust evidence base. In addition, where a quantitative need and demand is identified for a specific housing type/tenure, we would encourage the councils to proactively plan for these through specific site allocations and appropriately flexible development management policies rather than imposing blanket policy requirements on all sites above a certain threshold. A broad policy allowing for self-build or other specialist housing “exception sites” on land well-related to existing settlement boundaries would be an example of how the councils could meet future specialist housing demand proactively.

• The types of housing set out in the Plan should be influenced by the allocations proposed in the SHLAA • The Letwin Review identified the low rates of house building on some large sites as being partially attributable to the lack of diversity of housing type in the housing offer. This must be addressed with a determination by the Council to ensure much greater diversity in the housing mix. • Cambridge needs more affordable housing but the ‘affordability crisis’ dictates that a wide range of affordable options must be pursued – affordable rents of Council owned properties, community-led housing (especially in villages where priority should be given to first-time buyers with a proven affinity to the neighbourhood), HMOs and shared-ownership models. Greater provision should be made for self-build which is an attractive method for young people to gain their independence. • Unfortunately, within the current development and planning framework the housing mix will largely be determined by the developers in response to market forces. The Councils will need to take a stronger stance if models like Eddington are to become the standard. • Greater provision should be given to accommodating an ageing population. New builds should have the structural flexibility for easy conversion to enable the elderly to remain in their own homes. Retired people whose children have left the family home may in principle want to down-size but in reality, baulk at the practical implications of leaving their home. Greater opportunity should be made to allow family homes to be subdivided with part of the property rented. • Greater Cambridge should also give consideration to expanding its definition of key workers. Essential local employment to support the high-tech sector includes relatively low-paid laboratory technicians, research assistants, ancillary support staff, cleaners, porters, and the like, and these categories should be included in ‘affordable’ housing schemes. • The register of empty properties needs up-dating and maintaining by both Councils. Bringing empty properties back into use would help alleviate some of the pressures on residential development.

More affordable housing is required, not 4-5 bedroom houses

A mix is essential. We need to provide for individuals and large families with mixed abilities. It is essential that all apartments are built for those with limited mobility. The mix should also allow for individuals and families in different income brackets so clusters of individuals and families falling in a single demographic are discouraged, hence promoting mixed communities. The mix should also be data based.

1.31 Whilst there is a statutory requirement to provide self-build plots there should be more of a criteria based approach for when they are required with development viability being a material consideration. This is especially the case for larger sites where the costs of delivering infrastructure often impact negatively on the percentage of affordable housing that is delivered. A requirement for self-build plots, which generate less revenue for developers than finished homes, has the potential to further reduce the level of affordable housing on these large sites. It seems perverse that the needs of people with the financial means to build their own homes could be prioritised over low earning residents who cannot afford to buy or rent homes in the Greater Cambridge area. 1.32 As our clients’ site has the potential to form an early phase of a larger extension of Comberton the impact of providing self-build plots, alongside the any necessary enhancements to infrastructure to accommodate the larger site, could impact negatively on the viability of the development. Our clients are committed to the delivery of affordable housing on their site but recognise that for any scheme to come forward it has to be commercially viable for a developer to purchase the site. 1.33 Our clients are concerned that the need for self-build plots can be often be overstated by self-build registers. In particular, many registers are rarely updated to remove those no longer in need of a self-build plot or to assess whether there is double counting across registers. Given the attractiveness of the Greater Cambridge area there is also the concern that the self-build register has been inflated by people with aspirations to live in the area, meaning that there is an artificially high number of people on the registers compared to neighbouring authorities. 1.34 With the above in mind, it will be important for the Councils to ensure that their evidence on the need for self-build homes has been effectively reviewed if it is to offer a robust position on the demand for this type of development. Whilst South Cambridgeshire is a vanguard for self-build housing Cambridge City has not been as proactive towards promoting its self-build register. This may also have artificially inflated the number of people on South Cambridgeshire’s register. 1.35 Rather than targeting major developments it is suggested that the Councils look at what opportunities exist to promote self-build plots on the edges of development frameworks. Especially where the development of small sites and residential gardens would not result in wider harm. By including self-build plots in the criteria for a bespoke policy that permits the development of sites on the edges of development frameworks it would help to boost the supply of housing, address the Councils’ self-build registers and provide a continued source of employment for small builders and tradespeople. 1.36 The Councils should not adopt overly restrictive policies that require a precise mix of housing to be provided on all sites. The reliance on the Strategic Housing Market Assessment (SHMA) for a plan period of several decades does not give officers the flexibility to take into account other material planning considerations that may make alternative housing mixes more appropriate for specific sites. Therefore, the SHMA figures should be used as a guide only for the mix of housing on sites rather than a requirement. Any new policy should allow officers the flexibility to take into account other material considerations when considering planning applications, especially as they would be used the assess the needs of developments in both urban and rural settings.

The kind of housing that is required in Cambridge will need to be based on the evidence of needs as set out in their Strategic Housing Market Assessment. However, we would suggest that with regard to the type of market housing that is provided the Council should not seek to place overly restrictive policies that seek to set the precise mix of housing provided on all sites. Strategic Housing Market Assessment can only provide a snapshot in time and can only be considered as providing a guide as to the type of housing that should be delivered in future rather than a requirement. Delivering a mix of homes requires the provision of a range of site typologies and locations that will allow for a diversity of market provision. In relation to specific types of need we would make the following comments: • Affordable housing: It will be important for the Councils to ensure that their viability assessment reflects the latest policy and guidance published by the Government. The focus on viability assessment and how it relates to affordable housing places a far greater emphasis on viability being assessed as part of the local plan and that compliance with policy requirements should be set so that most sites are deliverable without further viability assessment negotiations. This may require the Councils to include greater variation in affordable housing requirements based on site type and location to reduce the need for negotiation in relation to onsite affordable housing provision. To aid Councils in the preparation of their viability evidence the HBF has worked with its members to provide a briefing note (attached) to aid understanding of the housebuilding industries approach to viability. Student housing: The Councils should not overestimate the potential contribution of student accommodation to improving the availability of housing within Cambridge. The Government’s general assessment is that for every 2.5 students living in student accommodation there will be one house released for general housing needs. However, it must be remembered that this is a national figure and will vary significantly between cities depending on the housing stock in that area. Local evidence will be needed as to the appropriate ratio of homes freed to the market through the provision of student housing. • Older people’s housing: It will be important for the Council to identify and allocate sites to meet the specific needs of older people. Too often such development is expected to come through windfall or on strategic allocations with no specific target set in the local plan as to how many specialist homes for older people should be provided. This approach does not offer the necessary certainty that needs will be met. As such we would suggest the local plan undertakes to, firstly, establish a housing requirement specifically for the needs of older people. This will ensure that the supply of such homes can be effectively monitored and any under supply be taken into account when making decision on applications for older peoples’ accommodation. Secondly, we would suggest that the Council’s work with specialist providers to identify suitable sites that will meet the specific needs of older people. Such accommodation needs to be in sustainable locations close to services and as such it is important to work closely with this sector of the housebuilding industry to understand the needs of their customers. • Self-build: We are supportive of self-build and custom house building and the important contribution such development can make to housing supply. However, we are concerned that the need for such homes can be often be overstated by self-build registers. In particular we find that many registers are rarely updated to remove those no longer in need of a self-build plot or to assess whether there is double counting across registers. It will be important for the Council to ensure that its evidence on the need for self-build homes has been effectively reviewed if it is to offer a robust position on the demand for this type of development. It will also be necessary for the Councils to consider how they support the selfbuild market in Greater Cambridge. Paragraph 57-025 of PPG sets out a range of different approaches all of which need to be thoroughly considered by the Council. Too often local plans seek to require demand for self-build plots to be met through their provision on allocated sites without proper consideration of the other approaches set out in PPG. Rather than set requirements for the provision of such plots on allocated sites we would suggest the Council seek to find suitable sites where the landowner is willing to provide self-build plots. Such an approach would also be consistent with PPG which states that Councils should work with landowners and encourage them to consider self-build plots but does not state that it should compel them do to so.

1.31 Whilst there is a statutory requirement to provide self-build plots there should be more of a criteria based approach for when they are required with development viability being a material consideration. This is especially the case for larger sites where the costs of delivering infrastructure often impact negatively on the percentage of affordable housing that is delivered. A requirement for self-build plots, which generate less revenue for developers than finished homes, has the potential to further reduce the level of affordable housing on these large sites. It seems perverse that the needs of people with the financial means to build their own homes could be prioritised over low earning residents who cannot afford to buy or rent homes in the Greater Cambridge area. 1.32 Our client is concerned that the need for self-build plots can be often be overstated by self-build registers. In particular, many registers are rarely updated to remove those no longer in need of a self-build plot or to assess whether there is double counting across registers. Given the attractiveness of the Greater Cambridge area there is also the concern that the self-build register has been inflated by people with aspirations to live in the area, meaning that there is an artificially high number of people on the registers compared to neighbouring authorities. 1.33 With the above in mind, it will be important for the Councils to ensure that their evidence on the need for self-build homes has been effectively reviewed if it is to offer a robust position on the demand for this type of development. Whilst South Cambridgeshire is a vanguard for self-build housing Cambridge City has not been as proactive towards promoting its self-build register. This may also have artificially inflated the number of people on South Cambridgeshire’s register. 1.34 Rather than targeting major developments it is suggested that the Councils look at what opportunities exist to promote self-build plots on the edges of development frameworks. Especially where the development of small sites and residential gardens would not result in wider harm. By including self-build plots in the criteria for a bespoke policy that permits the development of sites on the edges of development frameworks it would help to boost the supply of housing, address the Councils’ self-build registers and provide a continued source of employment for small builders and tradespeople. 1.35 The Councils should not adopt overly restrictive policies that require a precise mix of housing to be provided on all sites. The reliance on the Strategic Housing Market Assessment (SHMA) for a plan period of several decades does not give officers the flexibility to take into account other material planning considerations that may make alternative housing mixes more appropriate for specific sites. Therefore, the SHMA figures should be used as a guide only for the mix of housing on sites rather than a requirement. Any new policy should allow officers the flexibility to take into account other material considerations when considering planning applications, especially as they would be used the assess the needs of developments in both urban and rural settings.

The new local plan should seek to provide a mix of housing in suitable locations. The local plan policies should not be too prescriptive in this regard or specify the precise mix of housing to be provided on sites, but rather should be flexible to allow developments to respond to market demands. The comments made in response to question 31 are also applicable here and the Meldreth proposals would provide a range of house types and sizes to provide for the needs of different groups in the community. Planning policies should support small to medium scale builders to bring forward sites of small to medium scale, which can be delivered quickly and make an immediate impact on the delivery and supply of new housing.

There is a need to provide for a wide range of housing in the Local Plan, including a diverse range of tenures, with rented accommodation, retirement living, market housing, and affordable housing together with some custom and self-build homes. A diversity of typologies will improve the ability of the market to deliver enhanced levels of delivery through provide a range of options to access housing whether rent or buy or a combination of these types. Such diversity is best achieved on larger sites which can adapt to market trends as demand changes in order to create robust communities with a range of socio-economic groups.

Thakeham is of the view that housing mix policies should be determined by a Local Housing Need Assessment in accordance with Paragraphs 60 and 61 of the NPPF, but also with the flexibility of the policies to be reviewed on a site-by-site basis based on their location.

As required by the NPPF paragraph 61, market, affordable, and specialist (student, older persons') housing is required to be provided to create a mixed and balanced community. In terms of market housing and starter homes, the Council's Housing Statistical Information Leaflet (December 2018) only notes a need for traditional types of affordable housing, based on information from its housing register. For Dry Drayton, where our client is promoting a site for up to 30 dwellings, it is notable that the affordable stock in the Parish includes no 1-bed houses and only one 2-bed house for those under 60. There are 17 3-bed houses and 1 4-bed, plus 12 bungalows for people over 60. Housing association stock comprises 2 houses (one 2-bed and one 3-bed). There is no shared equity housing and no sheltered accommodation. The stated need for Council and RP rented accommodation was two 1-bed and two 3-bed houses. The Council has not measured the need for starter homes: rent to buy or low cost home ownership, and there is likely to be a hidden need for both market and affordable housing relating to newly formed households. Over time, we anticipate that housing needs surveys will widen to include assessment of needs for the types and wider tenures and housing referred to in the NPPF. Even then, that snapshot of need will be only part of the evidence to be weighed in consideration of the design of a housing scheme on a particular site. In Parishes across Greater Cambridge, the type of market housing that should be provided should address market demand as well as need, and in different locations, the type of housing that will ensure a development site will be viable and attractive to developers will differ by site. It is therefore counterproductive to dictate a market housing mix . Therefore the type of market housing that should be provided should be subject to flexibility, rather than dictating arbitrary mixes for all development schemes.

Paragraph 61 of NPPF expects the size, type and tenure of housing needs of the community to be assessed and reflected in planning policies, including for example those with an affordable housing need, students, renters and self-builders. It is noted that the existing and planned new settlements in South Cambridgeshire and some of the strategic sites are not delivering policy compliant levels of affordable housing. As such, it is considered that emerging GCLP should seek to allocate sites which are capable of delivering policy compliant levels of affordable housing. The promoted development at land at Beach Road in Cottenham would include housing and affordable housing. A mix of house types and sizes would be provided within the promoted development.

‘Life-Time’ homes standards, social rent properties, bungalows for elderly and disabled people.

Southern & Regional Developments (Swavesey) consider that it is important for the Plan to deliver a varied range of housing, particularly with respect to bedroom size and tenure mix that reflects the findings of the Strategic Housing Market Assessment. However, to ensure that development can truly address local needs and respond to lcoational characteristics, such development requirements for residential proposals should not be overly or inappropriately prescriptive. Schemes for residential development should be required to deliver a housing mix that most appropriately caters for the needs of the community it will serve and should not be controlled by a restrictive development management policy which applies particular obligations for development to deliver at the strategic level. It is recognised that affordability is a major issue within Greater Cambridge, particularly within the rural areas and villages. Southern & Regional Developments (Swavesey) consider there is a need for the emerging Local Plan policy to address this issue and ensure that a mix of types and tenures is catered for across the whole of the plan area. Similarly, where settlements are dominated by a particular housing type or scale, there should be the opportunity through emerging plan policy for Development Frameworks to be sutiably amended. Claremont Planning maintain that although the new Plan should include policy guidance on housing types, including size and tenure mix, such guidance should be supported by the most up to date evidence and have the ability to respond directly to specific local requirements. The wording of any policy should reflect this and provide suitable provisions for housing mix to be informed by local circumstances and market influences. Taking into account the size of the plan area and the varied characteristics of the area, it is important that any policy guidance includes an appropriate degree of flexibility in its requirements for housing development. For example, housing mix requirements will differ between settlements across the entire Plan area, given that the needs of rural South Cambridgeshire will be different from those within Cambridge City. It is therefore important that any attempt to include specific housing mix and type requirements within development management policies should ensure a degree of flexibility and acknowledge locational considerations. Summary of Comments: Policies for housing mix/type should not be prescriptive and should reflect the requirements as identifed in the latest SHMA.

The Greater Cambridge City Deal recognises that an appropriate mix of housing is vital to economic growth. It acknowledges that a shortage of available and affordable housing within a reasonable distance of key employment centres has driven an unsustainable increase in house prices, which has in turn affected the recruitment, retention and quality of life of employees (Page 6). The scale of the opportunity at Cambridge East would allow for a delivery of a wide mix of housing types in response to the housing needs of Greater Cambridge. The final mix of housing should be determined based on the latest available housing needs data, in conjunction with engagement with the Councils, and should seek to accommodate these needs as far as possible. If Cambridge East is allocated for development, it is anticipated that the 12,000 new homes it is capable of delivering would comprise a mix of sizes and tenures, including Private Rented Sector, later living, student housing, discounted rental, discounted purchase and First Homes opportunities.

European Property Ventures (Cambridgshire) consider that it is important for the Plan to deliver a varied range of housing, particularly with respect to bedroom size and tenure mix that reflects the findings of the Strategic Housing Market Assessment. However, to ensure that development can truly address local needs and respond to lcoational characteristics, such development requirements for residential proposals should not be overly or inappropriately prescriptive. Schemes for residential development should be required to deliver a housing mix that most appropriately caters for the needs of the community it will serve and should not be controlled by a restrictive development management policy which applies particular obligations for development to deliver at the strategic level. It is recognised that affordability is a major issue within Greater Cambridge, particularly within the rural areas and villages. European Property Ventures (Cambridgshire) considers there is a need for the emerging Local Plan policy to address this issue and ensure that a mix of types and tenures is catered for across the whole of the plan area. Similarly, where settlements are dominated by a particular housing type or scale, there should be the opportunity through emerging plan policy for Development Frameworks to be sutiably amended. European Property Ventures (Cambridgshire) maintain that although the new Plan should include policy guidance on housing types, including size and tenure mix, such guidance should be supported by the most up to date evidence and have the ability to respond directly to specific local requirements. The wording of any policy should reflect this and provide suitable provisions for housing mix to be informed by local circumstances and market influences. Taking into account the size of the plan area and the varied characteristics of the area, it is important that any policy guidance includes an appropriate degree of flexibility in its requirements for housing development. For example, housing mix requirements will differ between settlements across the entire Plan area, given that the needs of rural South Cambridgeshire will be different from those within Cambridge City. It is therefore important that any attempt to include specific housing mix and type requirements within development management policies should ensure a degree of flexibility and acknowledge locational considerations. Summary of Comments: Policies for housing mix/type should not be prescriptive, allow for local requirements alongside those identifed in the latest SHMA.

7.4 There should be flexibility within the Local Plan to respond to changing housing needs over the Local Plan period. Consideration of individual site circumstances and the circumstances of a local area should be taken into account to determine the appropriate type of housing for development sites. Separate housing needs assessments should be used to inform the appropriate size, type and tenure of housing needed for different sections of the community, as set out within the Greater Cambridge Housing Strategy 2019-2023. 7.5 Flexibility will be key to a successful Local Plan; through market housing, low-cost and affordable housing. 7.6 Land at the Gas Field has the potential to deliver residential development, comprising both market and affordable housing of a range of size, types and tenures to meet the needs of the Greater Cambridge area. The proposals would therefore contribute to increasing accessibility to housing for different sections of the community in a sustainable location.

A mix of well-designed housing with sufficient genuinely affordable housing following the successful model of South Cambridgeshire. All new housing should be climate change proofed dwellings. The East Cambridgeshire model of ordinary commercial developments branded as ‘Community Land Trusts’ must be resisted strongly. The ethics and distribution of the current housing loans policy of the Combined Authority should be closely examined. For example, the conversion of commercial premises to housing under the ‘permitted development’ rules which has caused such havoc and suffering in Harlow and other communities should be firmly resisted.

6.5 There should be flexibility within the Local Plan to respond to changing housing needs over the Local Plan period. Consideration of individual site circumstances and the circumstances of a local area should be taken into account to determine the appropriate type of housing for development sites. Separate housing needs assessments should be used to inform the appropriate size, type and tenure of housing needed for different sections of the community, as set out within the Greater Cambridge Housing Strategy 2019-2023. 6.6 Flexibility will be key to a successful Local Plan; through market housing, low-cost and affordable housing.

Question 33 –Housing Provision 2.16 In 4.6.3, the consultation document asks whether more student housing is required. The College feel that this rather over-simplifies the issue and therefore make these observation in response to Q33 about what kind of housing is needed. This blanket definition is surprising, as the Council commissioned ‘An Assessment of Student Housing Demand and Supply…’ in 2017 which gave some clear guidance on the needs within the City. Clearly further analysis is needed to ensure that the full diversity of housing for the Colleges, the University of Cambridge and Anglia Ruskin University and the various language schools is properly understood. 2.17 Magdalene College currently has 380 undergraduate students – all of them housed by the College on its principal sites. There are also 152 postgraduates, of which 2/3 are housed by the College. The College’s aspiration is to house 85% of these. Whilst it recognises that some students want the independence of finding their own accommodation, the majority benefit from being closer to College life – the student’s benefit from interaction with their peers which in turn sustains the ‘beating heart’ of the College. 2.18 However, the student body also today includes graduates with families. Their housing needs are different from single under-and post-graduates and generally the minimum they require is a self-contained flat. Currently the College struggles to provide such accommodation. 2.19 The College also has 8 research fellows. These are early stage career academics who are generally housed within College rooms or flats in the houses which the College owns. The same would apply to visiting academics carrying out research for say a term. 2.20 Magdalene College has 8 houses and 10 self-contained flats on Northampton St, Chesterton Rd, Hertford St and Thompson’s Lane. This is used to house teaching fellows, some college officers and the chaplain. 2.21 This part of the Fellowship has a particular housing need. Often young teaching fellows may be new to Cambridge and the high house prices mean that the College needs to house them in the short to medium term. 2.22 ‘Student housing’ is therefore relatively diverse in terms of the needs and the resultant accommodation and this needs to be recognised within the local plan. This is very important if the University and its Colleges are to maintain their role on the world stage. It needs to be able to offer high quality accommodation to attract the best staff and students who add so much to the vitality of the City. The local plan needs to recognise this specific need and allow scope for new buildings or sensitive conversions to provide for this need – which is currently a considerable challenge due to the heritage sensitivities of the Colleges and the city centre as a whole. 2.23 Even when Colleges such as Magdalene are not planning for increased undergraduate or postgraduate numbers, it still has a need for new housing to meet specific needs (as set out above), as dated stock is modernised or to free up private housing by bringing more of the student body / fellowship into or closer to the College campus.

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.

2.11 At Section 4.6.3 of the Consultation document, the Councils ask respondents to consider the broad range of housing that the emerging Local Plan will need to consider. It outlines a range of different types of housing, including student housing, which is in line with paragraph 61 of the National Planning Policy Framework (“NPPF”). 2.12 The College suggests that the Councils go further than simply considering whether Cambridge needs more student accommodation so that students do not increase the demand for local housing as set out in point 3 on page 64 of the consultation document. In Cambridge the student population is diverse and has different needs across a variety of educational institutions. National Planning Practice Guidance (“NPPG”) sets out that at the strategic policy–making stage, ‘Local Planning Authorities will need to engage with universities and other higher educational establishments to ensure they understand their student accommodation requirements in their area’ (Ref: 67-004/20190722). 2.13 This requirement is not new for the Councils, which as part of the adopted Local Plan (2018) undertook an Assessment of Student Housing Demand and Supply for Cambridge City Council (ASHSD, 2017). One of its important themes was that Cambridge had a diversity of students across different educational institutions. The City Council, therefore, proposed to consider this theme within their next Strategic Housing Market Assessment for the next Local Plan. 2.14 A further important theme recognised in the ASHSD was that ‘whilst undergraduates are likely to want some form of institutionally provided accommodation, there is a large postgraduate population, some of whom will desire a more ‘home-like’ form of accommodation’. 2.15 This situation continues to be the case: the University of Cambridge, together with the Colleges, is seeking student population growth at a rate of 0.5% for undergraduates and around 2% for graduate students. It is this latter group who are likely to have different accommodation needs together with other sectors of the academic population such as post-doctoral researchers and contract researchers. Downing College Context 2.16 For the last full academic year (2018-2019), the College had 812 students (470 undergraduates and 342 postgraduates), 49 Fellows, and 177 staff. Over recent years, the Council will be aware that Downing has been working hard to achieve their objective of accommodating all their undergraduate and postgraduate students for the first four years of study in accommodation within the bounds of Regent Street, Lensfield Road, Tennis Court Road, and the Downing Site. At present the College accommodate 543 of these undergraduates and postgraduates within this area. 2.17 However, as the table below shows, over the last 10 years, Downing has seen the most growth in the postgraduate population. (Table - see attachment) 2.18 The postgraduate community comes from diverse backgrounds, e.g. overseas, and in many cases require accommodation as a couple or a family, given where they are in their academic careers. As such, their needs are very different from those of undergraduate students. 2.19 Furthermore, the College is finding that in order to attract the talent of potential postgraduates, it must be able to offer not only a high standard of living accommodation that works for individuals, couples, and families but also up-to-date welfare and social facilities. 2.20 As this early stage of the Plan makes process, the College urges the Councils to undertake the relevant research to ascertain what type of student accommodation the emerging Local Plan needs to account for in line with the requirements of the NPPF and NPPG. In order to broaden the Councils’ understanding of the student population and in line with national planning guidance, this research should be undertaken in collaboration with Colleges, the University of Cambridge, and Anglia Ruskin University, together with other educational establishments such as language schools. It is a complex subject and, as set out in the ASHDS, there are few other Local Planning Authorities which have had to grapple with the same demands for student accommodation. The Councils need to be forward-thinking and collaborative in order to address the requirements of the academic community.

Our Housing research set out in the report “Assessing the Housing Need of Hospital Workers” (Savills, January 2020) identifies a latent need for 2466 affordable homes to serve the existing 12,000 staff at Addenbrooke’s. The study identifies discounted rental as a realistic option for many NHS staff; however, there remained a high proportion of those in housing need who wished to buy their own home. The research highlights a mix of housing types being required, focussing predominantly on 1, 2 and 3 bedroom properties. CUH is keen to work with a range of partners to identify housing typologies and tenures to meet the identified need for our staff. CUH is aware of emerging proposals, including the Government’s consultation on First Homes (30% discount on Open Market Value for first time buyers) and also the Cambridgeshire and Peterborough Combined Authorities proposed £100k homes initiative. We are interested in these as just two examples of discounted home purchase models, whilst we are also interested in exploring innovative routes to discounted rents for high quality housing, offering long term security of tenure. We also wish to highlight the significant interest from our staff in Rent to Buy type products (rent at a subsidised rate with a view to buying at a later stage).

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

Paragraph 61 of NPPF expects the size, type and tenure of housing needs of the community to be assessed and reflected in planning policies, including for example those with an affordable housing need, students, renters and self-builders. It is noted that the existing and planned new settlements in South Cambridgeshire and some of the strategic sites are not delivering policy compliant levels of affordable housing. As such, it is considered that emerging GCLP should seek to allocate sites which are capable of delivering policy compliant levels of affordable housing, as well as a mix of housing types for diverse residents with a arrange of ages, family or household sizes. The Mill Lane Site, Sawston would deliver up to 225 new homes and is capable of delivering a variety of house types including apartments, terraces, semi-detached and detached dwellings in order to meet the broadest need.

6.3.1 There should be flexibility within the Local Plan to respond to changing housing needs over the Local Plan period. Consideration of individual site circumstances and the circumstances of a local area should be taken into account to determine the appropriate type of housing for development sites. Separate housing needs assessments should be used to inform the appropriate size, type and tenure of housing needed for different sections of the community, as set out within the Greater Cambridge Housing Strategy 2019-2023. 6.3.2 It will be important for the Local Plan to identify and allocate sites to meet the specific needs of older people, as such development is often expected to come through windfall or on strategic allocations with no specific target set in the local plan as to how many specialist homes for older people should be provided. Such an approach does not offer the necessary certainty that needs will be met. 6.3.3 We would therefore recommend that the local plan undertakes to, firstly, establish a housing requirement specifically for the needs of older people, to ensure that the supply of such homes can be effectively monitored and any under supply be taken into account when making decisions on applications for older people’s accommodation. Secondly, we would recommend that the Council’s work with specialist providers to identify suitable sites that will meet the specific needs of older people, thus freeing up existing accommodation. 6.3.4 Flexibility will be key to a successful Local Plan; through market housing, low-cost and affordable housing, and older people’s housing.