Greater Cambridge Local Plan Preferred Options

The expected Future Homes Standard will set out the requirements with a clear timetable for implementation to lower standards in achieving Net Zero by 2050. The transition to the standard within Part L will set out a 31% reduction on CO2 emissions comparative to the current Building Regulations up to 2025, then a requirement of 75% lower emissions than the current energy efficiency requirements.
Whilst Persimmon Homes are in support of the need to move to better energy efficiency, it is not appropriate for this to be achieved through Local Planning Policy. A standardised approach through nationally set Building Regulations would be the most effective way of achieving net zero by 2050 to avoid additional policies and assessment which could impede the planning process, causing confusion and more cost. Furthermore, Persimmon Homes would question how developments would be assessed against this policy through a planning application process and what consultee would be involved in ensuring that plans meet the policy. Considering this, it is again more evidence that the nationally set Building Regulations that are assessed by Building Control is the most appropriate mechanism to avoid delays, cost and confusion through the process.
In addition to this, it is noted that the proposed policy states local authorities can set policy requirements for carbon reduction. However paragraph 6-012 of the PPG states in new housing this is only up to level 4 of the Code for Sustainable Homes (equivalent to a 20% improvement on the 2013 Building Regulations), so the policy is therefore not consistent with national policy.
With regards to Part C, the policy should have regards to the site specific deliverability with acknowledgements that this may not be achievable. There is no acknowledgement to decarbonisation of the national grid within the policy also.
With regards to Part D, it should be ensured that it is achievable to obtain the requirements of Part C on all sites prior to offsetting.
Further clarification is needed on the requirements of the Whole Life Carbon Assessment and it should be ensured any resulting recommendations are included in viability.
In conclusion, the most appropriate method of achieving net zero carbon in new buildings would be through nationally set building regulations.

The policy requirements of 80 litres per person per day are significantly lower than the current requirements. It would be appropriate to wait until publication of the Water Resource Management Plan in 2022 to assess whether such extreme measures on water consumption reduction is necessary. A goal of 100-110 litres per day would be more appropriate and achievable.

Persimmon Homes state that it is not appropriate to refer to guidance within policy as this can be ever-changing and is guidance not set policy.

The requirements for hard surfacing to be permeable should ensure that they meet the requirements of the Local Highways Authority for adoptable road standards.

There is no evidence justifying the need for 20% BNG onsite and why there should be a higher requirement than what is set out in the Environment Act. The viability assessment does not consider the great impact on the deliverability of some sites and could prevent many sites coming forward for development. The policy should be in line with the national legislation with 10% net gain.

Going forward the policy should acknowledge the requirements for providing BNG when calculating the typologies of open space provision.

The proposed policy direction of Policy WS/MU is that it will seek meanwhile uses on vacant sites where a longer term use is still being resolved. Persimmon Homes understand the rationale for the policy and are of the view that such a requirement should be encouraged in the wording of the policy wording and not be a mandatory requirement. There are so many factors which could impact on the capability of a site to accommodate meanwhile uses which could not be factored into such a policy, for example, sites not being served by the necessary infrastructure.

Persimmon Homes are of the view that this policy is neither necessary nor justified for residential developments.
The NPPF sets out at paragraph 57 and in Regulation 122(2) of the CIL Regulations 2020 that planning obligations must only be sought where they are necessary to make the development acceptable; directly relate to the development and fairly and reasonably related in scale and kind to the development. Persimmon Homes are of the view that such a policy does not meet any of these tests.
Furthermore, it is important to emphasise that residential development sites during the construction stage already significantly contribute to the local economy and provide significant opportunities for local jobs at various skill levels, including apprenticeships which give opportunities for the local community to learn new trades.

Persimmon Homes note that this policy requires 40% affordable housing provision which is equivalent to the percentages sought under the current Cambridge City Local Plan and the South Cambridgeshire Local Plan. As identified within the wording of the policy the Viability Assessment as it progresses through the process will be key in determining whether such percentages are affordable when considered alongside other policy requirements and the different land values in place within different parts of the Greater Cambridge District.

This policy sets out specific percentages, based on bedroom number for different tenures of houses to create mixed and balanced communities to meet housing needs.
The percentages set out at paragraph 7 are largely based on those set out in the ‘Cambridgeshire and West Suffolk Housing Needs Study 2021’ prepared by GL Hearn.
Whilst Persimmon Homes recognise the need to create balanced communities and bring forward a mix of homes, it is considered that the wording of the policy needs to be more flexible and not stipulate set percentages. Instead, Persimmon Homes are of the view that the policy should be worded along the lines that schemes should demonstrate how the needs set out in the Cambridgeshire and West Suffolk Housing Market Needs of Specific Groups Study 2021 or similar needs assessment.
The advantage of this approach is that:-
- Housing Needs will continue to be met over the plan period;
- The policy will not be become out of date. Percentage range requirements will inevitably change over time;
- Schemes can be designed to meet the specific needs of an area which will ultimately vary both within different areas of both Cambridge and South Cambridgeshire; and
- Schemes have flexibility to be designed to reflect the character of the area.
The Cambridgeshire and West Suffolk Housing Needs Study 2021 recognises that needs will change as the document states:-
‘The strategic mix identified above shall inform policies. But in applying the mix the individual development sites regard should also be had to the nature of the site and character of the area, up-to-date evidence of need (such as the housing register) as well as the existing mix of turnover of properties at the local level and the need to create and maintain mixed and balanced communities. The Council’s should also monitor the mix of housing delivered and respond accordingly so that the strategic mix requirements are clearly met.’
Notwithstanding the above, if percentage range points for market dwellings are to be remain within the policy to allow for more flexibility, whilst still meeting needs consideration needs to be given providing more flexibility within the ranges, thus allowing developments to adjust to the housing needs at the time of submitting the application. To this end, Persimmon Homes suggested the range for 3 bed dwellings be amended to 40 -60% and 4 bed dwellings be extended to 20 – 35% for both Cambridge and South Cambridgeshire. Such a change would be in line with the objective identified within the Cambridgeshire and West Suffolk Housing Needs Survey which recognises the need for family houses for which both 3 and 4 bedroom dwellings equally perform this function. Increasing the percentage of 3 bed dwellings will also support the emphasis on downsizing which is identified in the Cambridgeshire and West Suffolk Housing Needs Survey and will increase the supply of housing that is affordable to those on median incomes which is an objective site out in the document referred to in the associated text ‘Homes for our Future’ Greater Cambs Housing Strategy 2019 – 2023.’