Comment

Greater Cambridge Local Plan Preferred Options

Representation ID: 59533

Received: 13/12/2021

Respondent: Countryside Properties - Bourn Airfield

Agent: Turley

Representation Summary:

BTR Homes are an important housing model for diversifying the housing market and there is a requirement to plan positively for rented homes in Local Plans. The inclusion of a policy specifically addressing this form of development is therefore supported. BTR expands residents’ access to, and choice of, good quality housing, helping affordability in the widest sense.
BTR can also increase the overall supply and accelerate the construction of new homes due to the different market it serves.
The PPG is clear that the onus is on LPAs to consider how BTR can meet housing needs and create mixed and balanced communities. Concern is therefore raised that the proposed policy direction seemingly seeks to direct this requirement on to the applicant. It is considered there is a clear and evidenced need for BTR provision in the Greater Cambridge area.
The proposed policy direction also seeks to seemingly restrict how much BTR could be brought forwards. Concern is raised regarding this proposed approach.
A variety of business models will exist for the provision of BTR and therefore flexibility should be allowed within the final policy wording to reflect this.

Full text:

Build to Rent (BTR) Homes are an important housing model for diversifying the housing market as has been recognised by the Government through the NPPF and PPG and there is a requirement to plan positively for rented homes in Local Plans. The inclusion of a policy specifically addressing this form of development is therefore supported. BTR expands residents’ access to, and choice of, good quality housing, helping affordability in the widest sense.
BTR is different from the existing private rented sector offer through the professional management and longer tenancies for those who want them of high-quality, purpose-built homes. It is important to recognise that whilst the BTR sector may have initially been focused on town/city centre developments of apartments the model has diversified to include all types of homes including family homes. BTR can also increase the overall supply and accelerate the construction of new homes due to the different market it serves.
Countryside recognise the important role that the BTR sector can play as part of the overall mix of housing to be provided at Bourn Airfield which will include a policy compliant 40% affordable housing. It is considered that the provision of BTR will further broaden the appeal of living as part of a new community by widening the choices available and will assist in bringing forward the proposed development more swiftly than originally envisaged by the Council.
The PPG provides the following guidance to LPAs in preparing Local Plans which consider BTR: “As part of their plan making process, local planning authorities should use a local housing need assessment to take into account the need for a range of housing types and tenures in their area including provisions for those who wish to rent. Specific demographic data is available on open data communities which can be used to inform this process. The assessment will enable an evidence-based planning judgement to be made about the need for build to rent homes in the area, and how it can meet the housing needs of different demographic and social groups. If a need is identified, authorities should include a plan policy setting out their approach to promoting and accommodating build to rent. This should recognise the circumstances and locations where build to rent developments will be encouraged – for example as part of large sites and/or a town-centre regeneration area.” Paragraph: 001 Reference ID: 60-001-20180913
The PPG is therefore clear that the onus is on LPAs to consider how BTR can meet housing needs and create mixed and balanced communities. Concern is therefore raised that the proposed policy direction seemingly seeks to direct this requirement on to the applicant rather than being considered in a Plan led manner. It is considered there is a clear and evidenced need for BTR provision in the Greater Cambridge area and therefore the Local Plan should be positively planning to support this as part of a diversified housing market.
The proposed policy direction also seeks to seemingly restrict how much BTR could be brought forwards, although a decision on the exact quantum is deferred for later stages of plan-making. Concern is raised regarding this proposed approach. Whilst we understand from the supporting text that the Council are concerned that the provision of a significant quantum of BTR would result in a reduction in the level of the overall affordable housing delivery (as BTR would likely be subject to a 20% affordable housing requirement rather than the 40% of general market housing locally) it is necessary to consider the needs for all forms of housing. Although no quantum is proposed at this stage, it is noted that the draft North East Cambridge Area Action Plan (AAP) proposes a restriction of no more than 10% of the total housing across the AAP being BTR. Importantly the AAP is only in draft and we are unaware of any similar restrictions being successfully introduced elsewhere in the country. Clearly no such restriction could be applied to other forms of private rented accommodation by private landlords. It is therefore considered such an approach is unjustified.
A variety of business models will exist for the provision of BTR and therefore flexibility should be allowed within the final policy wording to reflect this. It should be noted that Countryside will deliver BTR on Bourn Airfield whilst also delivering a 40% policy compliant level of affordable housing.