The general approach to affordable housing contributions is welcomed; however, following the publication of the Cambridge Biomedical Campus Housing Study – Establishing the housing needs of the CBC workforce (2024), CUH is committed to working with Local Planning Authorities to develop a mechanism by which the housing needs of the campus workforce can be delivered through the growth agenda and at the same time delivering the healthcare provision to support the growth agenda.

In relation to smaller scale major developments there is a significant issue presently around the delivery of Section 106 housing through registered providers (RP) with many sites unable to contract with an RP. Review mechanisms need to be considered and built in to S106 Agreements. I have attached the BHF Bid Farwell publication which sets the scene and suggests solutions. In order to deliver small and medium scale housing schemes flexibility is required.

Please see attached document for representations.

This section of the SPD explains the Council’s approach to the delivery of affordable housing and expands on the policies in the Cambridge City Local Plan (Policy 45) and the South Cambridgeshire Local plan (Policy H10 and H11). The HBF notes that the SPD states that the affordable housing policies will apply to schemes for specialist housing (such as extra care, retirement homes, residential and / or nursing care, care suites, or smaller group homes. It also states that the affordable housing policies apply to Build to Rent schemes. The HBF considers that the viability of these requirements should be evidenced and ensured.

The SPD notes that the Local Plan policies do not set out an expected tenure split, however, the SPD will seek a tenure split that sees 75% of the 40% affordable housing requirement to be Affordable / Social Rent. And on sites above 15 homes at least 10% of that 75% is expected to be allocated for Social Rent. The HBF considers that it will be important to ensure that this proposed tenure split is viable and developable. It will also be important for the Councils to work closely with local registered providers to ensure that these requirements are in line with their plans in the area.

With regard to phased development paragraph 4.30 states “The Councils may require phased developments to submit a viability assessment if during any phase of the development, the amount of affordable housing being delivered during that phase decreases…” HBF do not disagree, but additional guidance should be added for completeness to address phased developments which provide increased affordable housing in an earlier phase to allow for a reduction in another.

The SPD suggests that the Council’s expectations on the affordable housing mix by bedrooms as a starting point, is set out in Tables 2 & 3 of Annex 2 of the Greater Cambridge Housing Strategy 2024-2029. The suggested mix is not included in the SPD, and it is not apparent how it will be kept up to date should new evidence from monitoring or a housing needs assessment indicates that these are no longer correct. HBF suggest a new paragraph is introduced stating that the suggested mix in Annex 2 of the Cambridge Housing Strategy will apply unless sufficient evidence demonstrates a different appropriate mix should be provided and that the mix will be agreed in consultation with the Local Planning Authority (LPA).

On behalf of our client, U+I (Cambridge) Limited and Cambridge 4 LLP, please find attached our formal Representations to the Draft Greater Cambridge Planning Obligations Supplementary Planning Document.

Please find attached a letter from CBC Ltd setting out our support for proposals raised by CUH in relation to S106.

This section of the SPD explains the Council’s approach to the delivery of affordable housing and expands on the policies in the Cambridge City Local Plan (Policy 45) and the South Cambridgeshire Local plan (Policy H10 and H11). The HBF notes that the SPD states that the affordable housing policies will apply to schemes for specialist housing (such as extra care, retirement homes, residential and / or nursing care, care suites, or smaller group homes. It also states that the affordable housing policies apply to Build to Rent schemes. The HBF considers that the viability of these requirements should be evidenced and ensured.

The SPD notes that the Local Plan policies do not set out an expected tenure split, however, the SPD will seek a tenure split that sees 75% of the 40% affordable housing requirement to be Affordable / Social Rent. And on sites above 15 homes at least 10% of that 75% is expected to be allocated for Social Rent. The HBF considers that it will be important to ensure that this proposed tenure split is viable and developable. It will also be important for the Councils to work closely with local registered providers to ensure that these requirements are in line with their plans in the area.

With regard to phased development paragraph 4.30 states “The Councils may require phased developments to submit a viability assessment if during any phase of the development, the amount of affordable housing being delivered during that phase decreases…” HBF do not disagree, but additional guidance should be added for completeness to address phased developments which provide increased affordable housing in an earlier phase to allow for a reduction in another.

The SPD suggests that the Council’s expectations on the affordable housing mix by bedrooms as a starting point, is set out in Tables 2 & 3 of Annex 2 of the Greater Cambridge Housing Strategy 2024-2029. The suggested mix is not included in the SPD, and it is not apparent how it will be kept up to date should new evidence from monitoring or a housing needs assessment indicates that these are no longer correct. HBF suggest a new paragraph is introduced stating that the suggested mix in Annex 2 of the Cambridge Housing Strategy will apply unless sufficient evidence demonstrates a different appropriate mix should be provided and that the mix will be agreed in consultation with the Local Planning Authority (LPA).

Dear Sir / Madam,

Here are some representations in respect of the above reference consultation draft SPD’s submitted on behalf of the following named clients:
• TLC Group
• Rockley Dene Homes Ltd
• The Fellows House Ltd
• SPK Residential Cambridge Ltd
• London Inn Hotels (Cambridge) Ltd

Yours faithfully

Colin Brown

Colin Brown MRTPI
Partner, Head of Planning & Development