Context
Housing underpins every objective of sustainable development in the NPPF; economic (building a strong economy and ensuring sufficient land of the right types is available in the right place), social (supporting strong communities by ensuring a sufficient number and range of homes can be provided and by fostering well-designed, safe places) and environmental (making effective use of land, improving biodiversity and moving to a low carbon economy). The NPPF goes on to set out that (para 61): “To support the Government’s objective of significantly boosting the supply of homes, 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 and that land with permission is developed without unnecessary delay.”
Housing also underpins the themes of the emerging GCLP, for example:
1 Climate Change – it is a recurring theme in the GCLP that one of the biggest contributors to climate change is in commuting to Cambridge. This is exacerbated by the current lack of affordable housing relative to quantum of jobs in Cambridge. Building enough new homes just to keep pace with job growth may simply maintain the current situation but planning for more jobs without the corresponding homes would exacerbate the issue further.
2 Biodiversity – new housing development can provide access to new formal and informal open spaces, taking pressures of existing habitats, whilst also delivering biodiversity net gain.
3 Jobs – at its most simple level job growth must be supported by housing growth to ensure a sufficient labour force is available. It is also key that these homes are in the right places, because businesses rely upon (and gain a competitive advantage from) having a workforce which can move readily to new employment opportunities. Jobs also need to be supported by a range of housing types and tenures to ensure that workers on all incomes can access employment, and the provision of new housing allows for delivery of affordable housing as well as specific types, such as key worker accommodation.
4 Infrastructure – development of housing is key to ensuring existing infrastructure can be retained (for example, ensuring public transport networks remain viable) and is also key to unlocking new infrastructure.
The intersection of housing with other themes is also noted within the GCLP itself, stating that: “Delivering new net zero carbon homes, across a variety of tenures, with sufficient indoor and outdoor space, designed to be adaptable throughout the lifetime of their occupants, and located close to jobs will provide many varied benefits for people and the planet. This theme therefore connects with most of the other themes. For example: net zero carbon homes (Climate Change) will help control energy costs making living costs more affordable, the creation of healthy new high quality developments with green spaces and other appropriate infrastructure (Biodiversity and Green Spaces, Wellbeing and Social Inclusion, Great Places, and Infrastructure) will improve the health and wellbeing of residents, and providing new homes will help businesses to meet their staffing needs (Jobs).” (GCLP First Proposals p.259)
The GCLP proposes a number of policies including for affordable housing, housing mix, density, specialist housing, self-build homes, build-to-rent homes, student accommodation and community-led housing.
Housing in the GCLP
On the basis of Section 5.0 (which set out that the GCLP should be more ambitious in its planned level of employment growth) we consider that commensurate increases would also be needed in housing growth to support this. As with employment, we consider that the housing requirement in the GCLP should be expressed as a minimum to ensure that there is flexibility to allow for higher housing growth in order to ensure Greater Cambridge’s potential is maximised.
In addition, we also make some observations below about identified housing delivery in the GCLP.
Build-out rates
As per para 10.19 of the October 2021 Housing Delivery Study (HDS), Waterbeach is assumed to deliver at 250dpa, but Bourn Airfield and Cambourne West are set to only deliver at 150dpa with the odd year of delivery rising to 200dpa. The clear evidence to justify this disparity in sites of a similar scale is unclear.
Northstowe is consistently assumed to deliver 250 dpa but within the next 4 years is to deliver in excess of 300dpa. This approach would not appear to have been taken with regard to Table 18 of the HDS, which sets out that average build out rate of urban extensions delivering 2,000+ homes are 225-275. We would consider that setting out an expected delivery of over 300dpa for multiple years is highly optimistic and it is not clear from the evidence base how this is justified, to ensure no optimism bias this should be lowered to a more realistic average build out rate of 250dpa, which fits within the identified range above, with a peak of 300dpa in 1 or 2 years if it can be evidenced.
Windfalls
We further note the high windfall figure of 450 dwellings per annum that is expected to be delivered across Greater Cambridge, see HDS (October 2021). It is noted that the historic windfall allowance has traditionally been 350dpa, however a recent review of the data suggests that c.500dpa has been delivered across the area over the longer term. The 450dpa is made up of the top end of the range for 240-255 for South Cambridgeshire and 185-195 for Cambridge City.
However, the evidence appears to show that the windfall figures are elevated between the years of 2013 to 2018, i.e. the years in which the adopted Cambridge Local Plan was at Examination in Public. It is not surprising that windfalls would be higher in this period as non-allocated sites came forward without the benefit of an up to date adopted local plan, in effect the majority of housing supply would have been a windfall. Comparing this data with windfalls delivered in the period either side is less. Furthermore, the windfall ranges concluded on for Cambridge and South Cambridgeshire above seem to align very closely with the historic windfall figures for sites ‘including gardens’. This would run contrary to the NPPF paragraph 71 which states that plans should consider the case for setting out policies to resist inappropriate development of residential gardens, including these in a long-term windfall allowance could perpetuate this trend.
Housing requirement buffer
The HDS confirms that it is a recommendation that ‘at least a 10%’ buffer is applied to ensure an ‘over-allocation’ of land against the eventual housing requirement. However, as we have demonstrated above in the case of South East Cambridge and as we detail regarding Greater Cambridge as a whole in respect to Theme 5 – Jobs, the economy in this location is particularly robust and has seen strong levels of growth, despite the downward pressures placed on economic growth due to Covid 19. It is therefore a realistic expectation that job growth could be considerably higher than projected by the currently adopted scenario, which is demonstrated clearly by the spatial strategy suggested within the Cambridgeshire and Peterborough Independent Economic Review (CPIER) have referred to within their report that employment growth rates are far higher than have been indicated by official figures and that growth can be expected to keep increasing. Noting the overall thread of sustainability running through the Local Plan, it would seem appropriate to provide a higher buffer of dwelling to facilitate houses close to local sources of employment which have seen higher growth rates over the past few years, notably biomedical and technology industries which are prevalent in South East Cambridge.