Greater Cambridge Local Plan Preferred Options

Under this policy residential developments will be expected to demonstrate that they have engaged with a range of providers to upgrade infrastructure to deliver gigabit-capable broadband infrastructure. The policy also requires residential developments will also deliver dedicated telecommunications ducting to facilitate the delivery of competitive fibre broadband services.

The Council should not impose new electronic communications requirements beyond the provision of infrastructure as set out in statutory Building Regulations. In the Budget of March 2020, the Government confirmed future legislation to ensure that new build homes are built with gigabit-capable broadband. The Government will amend Part R “Physical Infrastructure for High Speed Electronic Communications Networks” of the Building Regulations 2010 to place obligations on housing developers to work with network operators to install gigabit broadband, where this can be done within a commercial cost cap. The Department for Culture, Media and Sport (DCMS) has outlined its intentions on the practical workings of this policy, which will apply to all to new builds. 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.

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.

The proposed policy would require all development of 20 units or more to provide at least 5% of homes as plots for self-build or custom housebuilding. This policy is considered to be justified on the basis that since 2016 there have been 639 entries added to the self-build register for Greater Cambridge, an average of 140 per annum. It would therefore appear from the evidence presented by the Councils that there are relatively high levels of demand for self-build and custom house building plots. However, what is not clear is whether the Council have revisited this register to ascertain whether individuals on it are still looking to self-build or whether they have acquired a plot since asking to be placed on the register.

When registers have been reviewed in other areas Councils have seen numbers fall dramatically. For example, when Runnymede Borough Council reviewed their register and introduced an entry fee of £65 for the register, and a £60 annual fee for each year after has led to the numbers of interested parties on the register fall from 155 to just 3. Similarly, when Fareham Borough Council introduced an annual registration fee from 1st August 2017 and as a result (as set out at paragraph 4.25 of their 2017-18 AMR), the Council’s Self Build Register recorded those 35 individuals initially signed up in the first base period, which ran from 21st March 2016 (the date the register was created) to 30th October 2016. Following the introduction of the fee, the number who wished to remain on the register dropped to 12, a reduction of 65%. Whilst we recognise that requiring a fee will have an impact, however, it also suggests that many on registers may no longer be interested in self-build, and it is important to review the register regularly.

It will also be necessary for the Council to establish home many plots would be delivered through this policy. We could not find this evidence in the relevant topic paper and in order for the policy to be considered sound it must be reasonably related to the demand for self-build plots in Greater Cambridge.

With regard to the timescale for the reversion of self-build plots to the developer if they remain unsold this should be as short as possible. The provision of self & custom build plots on sites of more than 20 dwellings adds to the complexity and logistics of developing these sites. It is difficult to co-ordinate the provision of self & custom build plots with the development of the wider site. Often there are multiple contractors and large machinery operating on-site, the development of single plots by individuals operating alongside this construction activity raises both practical and health & safety concerns. Unsold plots should not be left empty to the detriment of neighbouring dwellings or the whole development. Any differential between the lead-in times / build out rates of self & custom build plots and the wider site may lead to construction work outside of specified working hours, building materials stored outside of designated compound areas and unfinished plots next to completed / occupied dwellings resulting in customer dissatisfaction. As such we would recommend a 6-month timescale after which unsold plots revert to the developer. This time period should be sufficient if the demand for self-build plots is in line with the Council’s expectations.

The HBF consider it important that local plans look to allocate specific sites to meet the needs of older people. In particular the Council must look, in the first instance, to allocate those sites submitted for older people’s accommodation that are in the most sustainable locations close to key services. Whilst some provision will be necessary in the new settlements provision should not be concentrated solely in such locations in order to provide a range of specialist housing and accommodation for older people across Greater Cambridge. In addition, we would suggest that the local plan goes further and looks to set out in policy:
• a target for the delivery of homes for older people and maintains a supply of land to meet that target. Whilst we recognise that there is not a requirement in national policy for the Council to maintain a specific supply of accommodation for older people identifying the level of need and monitoring supply the HBF consider it to be necessary to ensure the effectiveness of this policy and its application. Such an approach would also ensure effective monitoring in relation meeting the needs of older people and encourage positive decision making if there is a deficiency in supply; and
• support and encouragement for older persons accommodation on brownfield and other land in established urban and suburban environments and which is not allocated (for example, windfall sites) 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.

This policy reflects existing policies in both the Cambridge City Local Plan and South Cambridgeshire Local Plan, and it will important that the Council has sufficient evidence to support their continued inclusion in the Greater Cambridge Local Plan. With regard to 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. With regard to both space standards and accessibility standards it will be necessary to examine the impact the implementation of these standards has had on development, in particular on windfall sites and whether it has limited opportunities in Cambridge. We note that the Homes Topic paper mentions that the application of part M4(2) has been challenging in some instances and it will be 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.

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.

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.

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.

As the Council note the construction industry already contribute to improving skills and opportunities through CITB, who are leading a variety of programmes to develop skills through the levy’s paid by the construction industry and provide significant benefits in terms of local funding and employment opportunities. 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. Therefore, whilst we recognise that the Council may want to encourage such activities this should be left to the developer to decide the most effective approach to delivering their scheme.

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.

Whilst the HBF and our members understand the need to reduce waste and promote recycling within development we are concerned that such issue 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 and but any such requirements on such matter must be done through national regulation not through local plans to ensure they are applied consistently across the Country and can be delivered effectively.