Greater Cambridge Local Plan Preferred Options

Housing Supply
With regard to housing supply the consultation document outlines the Councils’ intention to ensure a buffer of at least 10% between housing needs and supply. The inclusion of a buffer in supply is welcomed, however the HBF recommends that such buffers should be at least 20% in order to offset the potential risks that development will not come forward as planned. Whilst the Council have examined the issue of delivery in relation to its sites and delivery trajectory in its Housing Delivery Study there is always uncertainty when bringing forward strategic sites of the size allocated in this local plan, and it will be important to ensure that these risks are mitigated through a higher buffer and the inclusion of additional development sites.

In addition, the level of windfall that is being proposed by the Council is significantly higher than in the past. Whilst the evidence suggests that windfall development has been higher than previous estimates indicate, it is important to remember there is a finite supply of previously developed land in the Borough and as such fewer homes will come from such sites in future. However, it is difficult to say how steeply this decline will be and as such the HBF advocate caution in the level of supply expected to come forward from windfall sites, especially where these include larger windfall sites which come forward with less regularity and certainty. Given the relatively high level of windfall that is expected across Greater Cambridge we would suggest that the Council either increases supply as outlined above or applies a discount to offset any potential future decline in delivery from windfall.

The Housing Delivery Study sets out the trajectory for each site that contributes to the overall supply across the plan period and makes an assessment as to the likely five-year land supply on adoption. The HBF does not comment on the deliverability or developability of individual sites, but we note that the expectation is that the five-year housing land supply on adoption in 2025 will be 5.15 years. This is a marginal five-year housing land supply and one that could easily fall below five years between now and the point at which the plan is examined and adopted should sites not come forward as expected. As such we would recommend that the Council give more consideration to allocating small sites of less than one hectare in the local plan that would bolster the Councils’ housing land supply in the first five years following adoption.

In particular it will be important for the Council to show that they are meeting the requirements of paragraph 69 of the NPPF and have identified through the local plan, or the brownfield register sufficient sites of one hectare of less to accommodate at least 10% of the housing requirements. The Council state that they will exceed this requirement by some margin but include windfall sites in this assessment. As these sites are unknown to the Council, they cannot be considered to have been identified through the plan making process. Whilst they may come forward the intention of paragraph 69 is to provide the certainty to small and medium sized house builder that comes from having their sites allocated for development in the local plan. Therefore, the Council must be able to demonstrate it can meet the requirements of paragraph 69 either through allocations in the local plan or on sites identified on the Brownfield register. If they cannot meet this requirement of national policy the Councils must allocate such sites for development in the local plan.

Finally, the Councils propose to use the dwelling equivalent set out in the Housing Delivery Test in relation to the delivery of communal housing. Whilst the HBF acknowledges that some allowance can be made for communal housing in the housing supply estimates we consider it important that local evidence is provided with regard to equivalency rate for student housing. The equivalency rate in some areas will be significantly higher than the national average 2.5 students to each student house. In some areas this will be much higher and in order to ensure that supply of homes returning to the open market as a result of student accommodation being provided is not overestimated and it will be necessary for some local justification to be provided on this matter.

Housing Supply
With regard to housing supply the consultation document outlines the Councils’ intention to ensure a buffer of at least 10% between housing needs and supply. The inclusion of a buffer in supply is welcomed, however the HBF recommends that such buffers should be at least 20% in order to offset the potential risks that development will not come forward as planned. Whilst the Council have examined the issue of delivery in relation to its sites and delivery trajectory in its Housing Delivery Study there is always uncertainty when bringing forward strategic sites of the size allocated in this local plan, and it will be important to ensure that these risks are mitigated through a higher buffer and the inclusion of additional development sites.

In addition, the level of windfall that is being proposed by the Council is significantly higher than in the past. Whilst the evidence suggests that windfall development has been higher than previous estimates indicate, it is important to remember there is a finite supply of previously developed land in the Borough and as such fewer homes will come from such sites in future. However, it is difficult to say how steeply this decline will be and as such the HBF advocate caution in the level of supply expected to come forward from windfall sites, especially where these include larger windfall sites which come forward with less regularity and certainty. Given the relatively high level of windfall that is expected across Greater Cambridge we would suggest that the Council either increases supply as outlined above or applies a discount to offset any potential future decline in delivery from windfall.

The Housing Delivery Study sets out the trajectory for each site that contributes to the overall supply across the plan period and makes an assessment as to the likely five-year land supply on adoption. The HBF does not comment on the deliverability or developability of individual sites, but we note that the expectation is that the five-year housing land supply on adoption in 2025 will be 5.15 years. This is a marginal five-year housing land supply and one that could easily fall below five years between now and the point at which the plan is examined and adopted should sites not come forward as expected. As such we would recommend that the Council give more consideration to allocating small sites of less than one hectare in the local plan that would bolster the Councils’ housing land supply in the first five years following adoption.

In particular it will be important for the Council to show that they are meeting the requirements of paragraph 69 of the NPPF and have identified through the local plan, or the brownfield register sufficient sites of one hectare of less to accommodate at least 10% of the housing requirements. The Council state that they will exceed this requirement by some margin but include windfall sites in this assessment. As these sites are unknown to the Council, they cannot be considered to have been identified through the plan making process. Whilst they may come forward the intention of paragraph 69 is to provide the certainty to small and medium sized house builder that comes from having their sites allocated for development in the local plan. Therefore, the Council must be able to demonstrate it can meet the requirements of paragraph 69 either through allocations in the local plan or on sites identified on the Brownfield register. If they cannot meet this requirement of national policy the Councils must allocate such sites for development in the local plan.

Finally, the Councils propose to use the dwelling equivalent set out in the Housing Delivery Test in relation to the delivery of communal housing. Whilst the HBF acknowledges that some allowance can be made for communal housing in the housing supply estimates we consider it important that local evidence is provided with regard to equivalency rate for student housing. The equivalency rate in some areas will be significantly higher than the national average 2.5 students to each student house. In some areas this will be much higher and in order to ensure that supply of homes returning to the open market as a result of student accommodation being provided is not overestimated and it will be necessary for some local justification to be provided on this matter.

It is being proposed that the local plan include a housing requirement of 44,400 homes over the plan period 2020 to 2041, the equivalent of 2,111 dwellings per annum (dpa). This level of need is higher than the minimum housing need established using the standard method by some 40%. The HBF supports the Councils’ ambitions to go beyond minimum needs and considers its approach to be consistent with national policy and guidance. As the Council note in the consultation document and supporting evidence, paragraph 61 of the National Planning Policy Framework (NPPF) is clear that the local housing needs assessment is the minimum number of homes the Council should be planning to meet with Planning Practice Guidance (PPG) outlining that there will be circumstances where housing needs will be greater than that arrived at using the standard method. In this case it is clear that the level of jobs growth in the Greater Cambridge area and the need to reduce the level of in-commuting to the area (in line with paragraph 104 and 105 of the NPPF) is sufficient justification to support a housing requirement in excess of the standard method.