Object

Representation ID: 56020

Received: 05/10/2020

Respondent: Endurance Estates

Agent: Barton Willmore

Draft Policy 13b requires 40% of new homes to be delivered as affordable housing, comprising a minimum of 60% social/affordable rent and 40% intermediate housing products. This reduces the level of social/affordable rent from the existing 75/25 split required in Cambridge City Council and 70/30 split in South Cambridgeshire Council. This is reasoned on the basis that this could help to provide a wider range of housing options beyond the more traditional shared ownership model, and also support local businesses by improving provision of housing which is accessible to a wider range of local workers.

The National Planning Policy Framework says that plans should set out the contributions expected from development. This should include setting out the levels and types of affordable housing provision required, along with other infrastructure (such as that needed for education, health, transport, flood and water management, green and digital infrastructure). Such policies should not undermine the deliverability of the plan. Policy requirements for developer contributions should be informed by proportionate evidence of infrastructure and affordable housing need and be assessed for viability at the plan-making stage in accordance with guidance.

We note that there is a lack of any viability evidence in the NECAAP supporting documents and evidence base. This is a concern for several reasons.

The majority of the housing allocation is proposed to the northern half of the NEC site where the current WwTW lies and where there will be significant costs in terms of remediating the land. In addition, there will be costs associated with land assembly and the use of Compulsory Purchase Order or compensatory agreements for existing businesses that will be relocated off the site. It is unclear to what extent these issues have been accounted for in setting out the viability of the plan and the level of affordable housing requirement.

This is a critical issue not only for meeting local affordable housing needs but also ensuring policy compliant affordable housing levels can be delivered on site rather than being displaced elsewhere. The total quantity of affordable housing would amount to 3,200 homes, which represents a significant proportion of the area’s affordable housing need. It would not be possible to absorb such a high level of affordable housing through windfall or rural exception sites once the AAP is adopted and therefore understanding the viability of implementing the plan is critical at this stage of policy drafting.

Our concerns regarding the lack of financial viability evidence extend to Policy 13c and the proposal for a maximum of 10% Build to Rent (800 units) across all housing within the AAP, comprising a minimum of 20% affordable private rent units. Built to Rent is a relatively untested product within Cambridge and would likely achieve lower land sale values compared to normal market products in this area. We would question whether this has been considered in the financial viability review work that supports the AAP. Also, how applicable is the research on Built to Rent to the Cambridge market? The AAP’s Housing Topic paper references evidence to Build to Rent demand within a document titled ‘Private Rented Sector (Build to Rent) research – national and emerging local’ but this does not appear to be published on the NECAAP consultation page. We therefore do not know the assumptions on likely take-up of Build to Rent at NEC and the impacts on the financial viability of implementing the plan, along with delivery of affordable housing delivery.