In terms of residential and employment commitments, the new Local Plan should seek to meet the full, unconstrained objectively assessed needs for market and affordable housing, as well as the assessed needs for jobs.
Paragraph’s 60 – 62 of the National Planning Policy Framework (NPPF) outline that Local Plans should support the Government’s objective to significantly boost the supply of homes and at a minimum should be informed by a local housing need assessment using the standard method included in National Policy Guidance. The NPPF also notes that it is important that a sufficient amount and variety of land can come forward where it is needed, that the needs of groups with specific housing requirements are addressed.
The Plan has identified an objectively assessed need for 58,500 jobs and 44,400 homes across the Plan period from 2020-2041.
The total number of homes to be provided through the plan is 48,840 which includes a 10% buffer for flexibility and results in a requirement of 11,640 homes to be identified in this Plan.
Whilst an uplift has been applied to the Standard Method, in response to the Council’s evidence which considers the preferred forecasted employment levels, it is noted that planning for the standard method housing figure set by government would not support the number of jobs expected to arise between 2020 and 2041.
The Councils have instead opted to pursue a ‘Medium’ growth option (2,111 dwellings per annum), but this falls short of maximising the economic potential of the ‘Plan Area’ and the provision of housing in accordance with higher forecasts for jobs growth (2,549 to 2,690 dwellings per annum). This is projected to continue existing trends, where levels of housing delivery have been out-paced by jobs growth, resulting in sustained affordability pressure, and increased in-commuting. This has addressed in more detail by the representations submitted by Barton Willmore in respect of our client’s wider interests in Greater Cambridgeshire.
The Council’s Housing Needs for Specific Groups Addendum (2021) models the demographic implications of various growth scenarios. This recognises that whilst needs increase as the housing numbers go up, the proportionate increases are fairly small due to uplifts primarily affecting younger working populations (Paragraphs 6.7-6.8). The material point, however, is that the higher growth scenarios provide a true reflection of the actual demand for housing. Even using the Council’s ‘medium’ scenario, without prejudice to the reservations in these representations, the Council’s Preferred Approach represents a significant increase in the requirements for development.
To address this, the Council is only proposing a limited number of new allocations at urban extensions and new settlements and is seeking to realise additional capacity from existing allocated and committed sites as provided for in the existing strategy. In practice, the risks to delivery mean that the Council’s stated provision for the ‘medium’ scenario plus a 10% buffer is unlikely to be achieved within the plan period utilising very limited additional sources of flexibility.
Whilst this policy recognises the overall number of homes to be provided for within the plan period, the First Proposals as a whole fail to set a figure or a range for the number of specialist housing for older people needed across the plan area. The issues identified mean that, together with considering full housing needs, and the requirement for an increased supply buffer, consideration must therefore be given to specifying the amount of homes to be provided for to meet the demand for Extra Care and other types of specialist accommodation, and then how these will be delivered.
While an increase to the overall buffer may be appropriate (to say 20%) the practical implications are that any risks to delivery of the strategy mean operators within the specialist older persons housing sector will face the most extreme pressures of competition in securing development opportunities.
This is an issue exacerbated in circumstances where the limited provision that exists (in some cases) as part of committed developments fails to meet the operational requirements of the sector in terms of scale and scope to deliver a full and comprehensive range of services to residents as part of the Extra Care model.
In these circumstances, greater certainty and flexibility would be achieved through the allocation of specific sites to meet the needs for specialist housing for older people alongside provisions for the overall buffer, including that relating to general housing needs. Addressing this issue is central to satisfying NPPF Paragraph 60 in terms of providing an appropriate strategy that will enable the needs of specific groups to be addressed without being entirely dependent on the wider identified risks.