On behalf of our client, Universities Superannuation Scheme Investment Management (USSIM), please find below representations on the draft Affordable Housing SPD.

Viability (pages 12-15)

Whilst it is recognised that contributing towards affordable housing provision should be reflected in the price paid for the land, this is not always the case. Historic purchases based on previous market values can continue to be a burden even in the improving economic climate. It is important that Cambridge City Council applies the affordable housing target sensitively, taking full account of individual site circumstances, including financial viability. Until land values adjust to reflect policy requirements, which is still a long way off, application of policy needs to be undertaken carefully to encourage development to come forward. The SPD should also reflect that some sites may be carrying exceptional costs such as infrastructure or contamination costs.

Monitoring and implementation (Section 8)

The standard clauses for any s106 Agreement which prevent development commencing until completion of a transfer of an affordable housing site or lease or that affordable housing must be completed prior to 50% of market housing being occupied, are potentially onerous.
Flexibility needs to be built in to the standard clauses to reflect the different way affordable housing can be negotiated and delivered. For example, there may be instances where delivery of affordable housing may be dependent on forward selling a proportion of market housing and this may be above 50%. Again this may be related to exceptional costs being borne by the development or uncertainty from developers as to values they might receive from registered providers for affordable units Individual site characteristics mean that blanket policy requirements should be tempered by a level of flexibility in the application of policy requirements.