Greater Cambridge Local Plan Preferred Options

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Comment

Greater Cambridge Local Plan Preferred Options

H/AH: Affordable housing

Representation ID: 60795

Received: 13/12/2021

Respondent: Cambridge and South Cambridgeshire Green Parties

Representation Summary:

Policy aim should be to demand for truly affordable housing that people want to live in.
Need a large increase in council owned and managed secure rented property backed up by community ownership cooperatives, housing associations and cohousing projects.
Previously engaged with the issue of Affordable Housing and key points remain salient.
It would be useful to have a definition of the term Affordable housing which encompasses both home-owning and rental.

Full text:

The aim of this policy should be to respond to the demand for truly affordable housing that people want to
live in. The Cambridge Green Party believes we need a large increase in council owned and managed secure rented property backed up by community ownership cooperatives, housing associations and cohousing projects.
We would like to see an assessment of the success or otherwise of previous policies to address the shortage
of truly affordable housing.
We have previously engaged with the issue of Affordable Housing - see for our example our response to the new housing policies consultation earlier this year [1]. Our key points from that consultation remain salient:
we believe that a discount of 20% relative to the market rate is insufficient to make ‘Affordable Private Rent’
homes truly affordable for local people. We are very concerned that the Setting of Affordable Rents Policy
seems to demonstrate that, by the Council’s own metrics, ‘affordable’ housing will in fact be no such thing.
The justification given is that providing greater discounts would not be “viable” in terms of Registered Housing Providers’ business plans. We also think that 40% ‘affordable’ housing in developments is insufficient and call for a minimum of 50%.
It would be useful to have a definition of the term Affordable housing which encompasses both home-owning and rental.
[1]
https://southcambs.greenparty.org.uk/assets/images/local parties/southcambridgeshire/Green%20response
%20housing%20consultation%20March%202021.pdf

Comment

Greater Cambridge Local Plan Preferred Options

H/ES: Exception sites for affordable housing

Representation ID: 60796

Received: 13/12/2021

Respondent: Cambridge and South Cambridgeshire Green Parties

Representation Summary:

Broadly support policy, as long as
a) exception sites only created in response to objectively assessed local need
b) “Rural exception sites will be allowed in the Green Belt only when it can be demonstrated that non Green-Belt alternative sites are not available” is rigorously enforced.
Concerned Exception Sites policy becomes a loophole for building on sites where development would not otherwise be permitted.
Pleased to see and would want greater policy emphasis on “community led housing initiatives such as community land trusts, co-housing and co-operatives”.
Agree that rural exception sites must not be ‘squeezed out’ by First Home sites.

Full text:

We broadly support this policy direction, as long as a) exception sites are only created in response to objectively assessed local need, and b) the clause “Rural exception sites will be allowed in the Green Belt only when it can be demonstrated that non Green-Belt alternative sites are not available” is rigorously enforced. We are concerned by the statement that “A small amount of market housing will be allowed on exception sites where it can be justified on viability or deliverability grounds”: there will need to be very clear and well-enforced rules about when this is allowable, with a quantified definition of “a small amount”, to avoid Exception Sites policy becoming a loophole for building on sites where development would not otherwise be permitted.
We are very pleased to see mention of “community led housing initiatives such as community land trusts,
co-housing and co-operatives” and would like to see these types of housing given greater policy emphasis.
We agree that rural exception sites must not be ‘squeezed out’ by First Home sites and support policies
intended to prevent this.

Comment

Greater Cambridge Local Plan Preferred Options

H/HD: Housing density

Representation ID: 60797

Received: 13/12/2021

Respondent: Cambridge and South Cambridgeshire Green Parties

Representation Summary:

Broadly support policy, ensuring standards for accessible green space provision met.
Note that building height is not mentioned in this section: drive for higher housing density must not override considerations such as landscape impacts from inappropriately tall buildings.

Full text:

We broadly support this policy, as long as standards for accessible green space provision are met (see also
BG/EO). Where people do not have private gardens, it is especially important that opportunities for local food growing - such as allotments, community farming schemes - are provided. We note that building height is not mentioned in this section (although it is covered elsewhere): a drive for higher housing density must not
override considerations such as landscape impacts from inappropriately tall buildings. The building heights initially proposed for NE Cambridge proved unacceptable to the public in the first round of consultation, and have been reduced in the next draft.

Comment

Greater Cambridge Local Plan Preferred Options

H/GL: Garden land and subdivision of existing plots

Representation ID: 60798

Received: 13/12/2021

Respondent: Cambridge and South Cambridgeshire Green Parties

Representation Summary:

Support policy direction.
Would support introduction of a condition that permeable surfaces must be used if gardens are converted to driveways.

Full text:

We support this policy direction. As mentioned in the First Proposals document, gardens can help mitigate surface water flooding. As such, we would support the introduction of a condition that permeable surfaces must be used if gardens are converted to driveways.

Comment

Greater Cambridge Local Plan Preferred Options

H/SS: Residential space standards and accessible homes

Representation ID: 60799

Received: 13/12/2021

Respondent: Cambridge and South Cambridgeshire Green Parties

Representation Summary:

Broadly support policy. UK minimum space standards are not generous and should be treated as a bare minimum.

Full text:

We broadly support this policy. UK minimum space standards are not generous and should be treated as a bare minimum.

Comment

Greater Cambridge Local Plan Preferred Options

H/SH: Specialist housing and homes for older people

Representation ID: 60800

Received: 13/12/2021

Respondent: Cambridge and South Cambridgeshire Green Parties

Representation Summary:

Support policy. Needs to be set alongside infrastructure and services policies ensuring access to specialist support.

Full text:

We support this policy. We would add that it needs to be set alongside infrastructure and services policies to ensure access to specialist support for the social groups identified. This has not always been the case to date, e.g. lack of pharmacy/medical provision on major development sites in Cambridge.

Comment

Greater Cambridge Local Plan Preferred Options

H/CB: Self and custom build homes

Representation ID: 60801

Received: 13/12/2021

Respondent: Cambridge and South Cambridgeshire Green Parties

Representation Summary:

Broadly support policy. Needs further clarification in two areas.

Full text:

We broadly support this policy. Two questions of clarification:
1) What are the selection criteria for inclusion on the register - e.g. can residents from outside Greater Cambridge can bid for sites?
2) Will policies CC/NZ (net zero buildings) and CC/WE (water efficiency) apply to self- and custom-build homes?

Comment

Greater Cambridge Local Plan Preferred Options

H/BR: Build to rent homes

Representation ID: 60802

Received: 13/12/2021

Respondent: Cambridge and South Cambridgeshire Green Parties

Representation Summary:

Accept private rented sector has a role in meeting housing need, sector is failing to provide secure, affordable and high standard homes.
Private rentals affordability cannot be guaranteed, but depends on the wider market conditions.
The Green Party has significant numbers of questions in regard to the detail, enforceability and extent of the policy.

Full text:

Although we accept that the private rented sector has a role in meeting housing need, the sector is failing to provide secure, affordable and high standard homes. Reform to housing policy is needed at national level to
address this, but in the meantime local policy should try to limit the damage. A fundamental drawback of private rentals is that affordability cannot be guaranteed, but depends on the wider market conditions.
We note that “Build to Rent developments should meet the requirements as set out in the Greater Cambridge Housing Strategy (Cambridge City Council and South Cambridgeshire District Council, June 2021)”. At the time the draft of this policy was consulted on we raised concerns which still apply to the published policy. It is not clear how much of the policy will actually be enforceable by the councils and how much will be negotiable with developers. The word ‘should’ is frequently used, as in “Tenancies of at least three years should be offered”, “No- one should be excluded on the basis of being in receipt of state benefits”– does ‘should’ mean ‘must’ in this context? An example we would particularly like to draw attention to is paragraph 12: “Quality of schemes is important; particularly environmental standards in line with the councils’ Sustainable Design and Construction Supplementary Planning Document.” Does this mean that
developers will be contractually required to meet all standards set out in this document? The Green Party
believes all new-build homes must meet the highest standards of sustainability and requests clarification on
this point.
“The policy will require at least 20% of homes on a Build to Rent development of 10 or more homes to be affordable private rented, and make clear that these homes will contribute towards the overall 40%
affordable homes to be provided on a mixed tenure development.”. We call for greater ambition in the
provision of affordable housing. We note that 20% is the standard benchmark given in national planning guidance. Given the crisis of affordable housing in Cambridge, we would like to see a much greater proportion of affordable rents provided in these developments.

Comment

Greater Cambridge Local Plan Preferred Options

H/MO: Houses in multiple occupation (HMOs)

Representation ID: 60803

Received: 13/12/2021

Respondent: Cambridge and South Cambridgeshire Green Parties

Representation Summary:

HMO's can be a more efficient use of a house than single occupancy but are often sub-standard housing, poorly adapted to multiple occupancy, with gardens removed. Rather than carrying forward existing policy, we call for a review of its successes and failures to inform a revised policy.

Full text:

At their best, house shares can be a more efficient use of a house than single occupancy (potentially
reducing carbon emissions per person), can lead to lower heating and food bills for individuals, can enable
people to live whether they otherwise could not afford to, and can provide a range of social benefits.
However, currently HMOs are often sub-standard housing, poorly adapted to multiple occupancy, with
gardens frequently removed to accommodate parking and bins. Rather than carrying forward existing policy,
we call for a review of its successes and failures to inform a revised policy.

Comment

Greater Cambridge Local Plan Preferred Options

H/SA: Student accommodation

Representation ID: 60804

Received: 13/12/2021

Respondent: Cambridge and South Cambridgeshire Green Parties

Representation Summary:

Agree policy is needed but awaiting 2022 findings from Universities on demand for student accommodation.

Full text:

We agree that this policy is needed but would suggest awaiting 2022 findings from Universities on how demand for student accommodation is changing (given the changes brought about by Covid and Brexit).
Anecdotally, demand from private 6th form colleges and from foreign students to Anglia Ruskin has fallen.

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