Greater Cambridge Local Plan Preferred Options

Search representations

Results for Home Builders Federation search

New search New search

Comment

Greater Cambridge Local Plan Preferred Options

I/DI: Digital infrastructure

Representation ID: 60142

Received: 10/12/2021

Respondent: Home Builders Federation

Representation Summary:

The Council should not impose new electronic communications requirements beyond the provision of infrastructure as set out in statutory Building Regulations. In 2020, the Government confirmed future legislation to ensure that new build homes are built with gigabit-capable broadband. Any type of technology may be used, which is able to provide speeds of over 1000 Mbps. All new build developments will be equipped with the physical infrastructure to support gigabit-capable connections from more than one network operator.

The Council’s approach is therefore unnecessary and repetitive of Building Regulations and should not be taken forward into the local plan.

Comment

Greater Cambridge Local Plan Preferred Options

I/EV: Parking and electric vehicles

Representation ID: 60143

Received: 10/12/2021

Respondent: Home Builders Federation

Representation Summary:

When considering this policy, it will be necessary for the Council to take into account the Government’s policy on the delivery of electric vehicle charging points. The Government have indicated that this will become a requirement for all new homes with a dedicated parking space and is likely to set out the type of charging facility to be provided. As we set out in our comments on policy CC/NZ it will be important for the Council not to apply its own standards where these are set out in Building Regulations to avoid confusion and conflict between local and national requirements.

Comment

Greater Cambridge Local Plan Preferred Options

H/CB: Self and custom build homes

Representation ID: 60144

Received: 10/12/2021

Respondent: Home Builders Federation

Representation Summary:

It would appear from the evidence that there are relatively high levels of demand. However, it is not clear whether the register has been revisited to confirm this demand. When registers have been reviewed in other areas Councils have seen numbers fall dramatically e.g. Runnymede, Fareham.

It is necessary for the Council to establish how many plots would be delivered through this policy. We could not find this evidence. To be considered sound the policy must be reasonably related to the demand.

The timescale for the reversion of self-build plots to the developer if they remain unsold should be as short as possible. We would recommend a 6-month timescale.

The provision of self & custom build plots on sites of more than 20 dwellings adds to the complexity and logistics of developing these sites. Unsold plots should not be left empty to the detriment of neighbouring dwellings or the whole development.

Comment

Greater Cambridge Local Plan Preferred Options

H/SH: Specialist housing and homes for older people

Representation ID: 60145

Received: 10/12/2021

Respondent: Home Builders Federation

Representation Summary:

The HBF consider it important that local plans look to allocate specific sites to meet the needs of older people, and these allocations should be in the most sustainable locations close to key services. Should not be concentrated solely in new settlements.
We would suggest that the local plan sets a target for the delivery of homes for older people and maintains a supply of land to meet that target. We recognise that this is not a national requirement but consider it to be necessary to ensure the effectiveness of this policy.
Support and encourage use of brownfield and other land in established urban and suburban environments given the increasing level of need and that older people are most likely to prefer to continue to reside in established areas with which they are familiar.

Comment

Greater Cambridge Local Plan Preferred Options

H/SS: Residential space standards and accessible homes

Representation ID: 60146

Received: 10/12/2021

Respondent: Home Builders Federation

Representation Summary:

It is important that the Council has sufficient evidence to support the continued inclusion in the Greater Cambridge Local Plan. It is necessary to examine the impact the implementation of these standards has had on development, in particular whether it has limited opportunities in Cambridge. It is important that this policy is sufficiently flexible to ensure schemes where it is either unfeasible or unviable to deliver these standards can still come forward.
Part M4(2) - we would suggest that some consideration be given to the accessibility of the existing stock and degree to which those with mobility difficulties will be able to adapt their own home to meet their needs.

Comment

Greater Cambridge Local Plan Preferred Options

H/HM: Housing mix

Representation ID: 60149

Received: 10/12/2021

Respondent: Home Builders Federation

Representation Summary:

The HBF consider the threshold of 10 or more dwelling proposed in this policy is appropriate. This is a very small level of development on which to achieve the proposed mix set out on page 268. The type of development on smaller sites will be dictated by its size, location, and topography and in many cases, it will not be possible to deliver mix proposed. We would therefore suggest a higher threshold is applied of greater than one hectare. It is also important to recognise that the mix being suggested in the proposed policy is a snap shot in time across each local authority area. Therefore, in considering the mix of homes on any site the policy should ensure that decision makers and application should not only have regard to the relevant and up to date housing study but should also have regard to other relevant evidence on housing needs and supply.

Comment

Greater Cambridge Local Plan Preferred Options

H/AH: Affordable housing

Representation ID: 60151

Received: 10/12/2021

Respondent: Home Builders Federation

Representation Summary:

The HBF has concerns that the viability assessment has underestimated some of the costs in relation to polices and land values. Given that affordable housing is the principal cost placed on development through local plans it will therefore be necessary to reconsider this policy through an updated viability assessment. It may be necessary to reduce the affordable housing requirement on some development typologies in order to ensure the local plan is consistent with paragraph 58 of the NPPF which states that decision makers should be able to assume that applications that comply with all policies are viable.

Comment

Greater Cambridge Local Plan Preferred Options

WS/IO: Creating inclusive employment and business opportunities through new developments

Representation ID: 60155

Received: 10/12/2021

Respondent: Home Builders Federation

Representation Summary:

Whilst the HBF understands that the Council wishes to improve opportunities for those living in the Greater Cambridge area to enter the construction industry it is not clear how this is considered to be justified against the tests set out in paragraph 57 of the NPPF and regulation 122 of the CIL Regulations. Planning obligations must be necessary to make the development acceptable in planning terms and the necessary evidence must be provided to support this policy.

The construction industry already contribute to improving skills and opportunities through CITB, who are leading a variety of programmes to develop skills. Whilst we recognise that the Council want to support local businesses get access to opportunities it is important to recognise that commercial interests in ensuring the most appropriate supplier in terms of skills and costs will be the priority for businesses and should not be compromised. It should be left to the developer to decide the most effective approach to delivering their scheme.

Comment

Greater Cambridge Local Plan Preferred Options

BG/BG: Biodiversity and geodiversity

Representation ID: 60159

Received: 10/12/2021

Respondent: Home Builders Federation

Representation Summary:

The requirement for a 20% net gain in biodiversity is not sound. No robust justification has been provided as to why the Greater Cambridge area is any different to the rest of the country and should set a higher requirement for net biodiversity gains from new development. If Government considers 10% sufficient to mitigate the impact of new development in future, then this should also be an appropriate level of net gain for the Greater Cambridge area. It is important to recognise that the Environment Act does not set this as a minimum and at present there is no suggestion that in future policy will allow for a higher requirement to be set in local plans.

The HBF also has concerns that the impact of a 20% requirement has not been fully considered. A 20% requirement will have a more considerable cost impact than as is suggested in the viability assessment and one that could impact on the deliverability of some sites. Therefore, we recommend that the policy is amended to ensure that it reflects the approach established in the Environment Act that requires a 10% net gain in biodiversity.

Comment

Greater Cambridge Local Plan Preferred Options

CC/CE: Reducing waste and supporting the circular economy

Representation ID: 60164

Received: 10/12/2021

Respondent: Home Builders Federation

Representation Summary:

Whilst we understand the need to reduce waste and promote recycling within development we are concerned that such issues need to be set out in a separate statement to support the application. Councils are placing more and more requirements on applicants without having the resources and knowledge to assess these reports or provide the necessary advice and guidance to applicants on such matters. The housebuilding industry recognises the need for a more circular economy but any such requirements on such matters must be done through national regulation not through local plans to ensure they are applied consistently across the Country and can be delivered effectively.

For instructions on how to use the system and make comments, please see our help guide.