The First Proposals plan sets a challenging target for affordable housing to reflect the acute and substantial need for affordable housing across Greater Cambridge. This places a great responsibility on all major developments to provide an element of affordable housing.
Policy H/AH will have a significant bearing on the viability of individual residential developments, so it is vital that the affordable housing requirement is achievable in practice.
The draft policy states that "current evidence" indicates that securing 40% affordable homes is deliverable across Greater Cambridge. Does this refer to The Greater Cambridge Local Plan Strategic Spatial Options Viability Assessment (November 2020) and/or The Greater Cambridge Local Plan Viability Study and Assessment Interim Report 2021? If so, this should be more clearly stated.
The latest build cost figures may not factor in fluctuating material costs caused by the pandemic, the haulage driver shortages, and Brexit. Building material costs increased around 23% year-on-year in August 2021, with timber and steel in particularly short supply. It is unclear whether shortages in building materials will continue long-term. It is also noted that the First Proposals plan sets ambitious requirements in relation to sustainability and design. These more stringent requirements are likely to further increase the costs of development.
Although the First Proposals plan indicates that viability evidence will be reviewed as appropriate as part of the plan-making process, this is not sufficient. Planning Practice Guidance indicates that plans should set out circumstances where review mechanisms may be appropriate, as well as a clear process and terms of engagement regarding how and when viability will be reassessed over the lifetime of a development to ensure policy compliance and optimal public benefits through economic cycles. Draft Policy H/AH does not do this - changes in affordable housing tenure models or continued increases in build costs may render the viability evidence which underpins the affordable housing requirement out-of-date relatively quickly.
Recent analyses of local property market dynamics indicate that affordable housing demands are still a focal concern for local authorities across the Greater Cambridge area. According to recent housing needs projections, an annual net need of 435 affordable rental units and 105 affordable units for homeownership will be needed across South Cambridgeshire to satisfy housing demands. Indeed, these projections do not account for local variegation in housing needs, which may be higher for conurbations closer to epicentres of business growth (e.g. Longstanton). Dependence on the allocation of strategic sites with already high infrastructure burdens is unlikely to offer sustainable, long-term solutions to the chronic and worsening affordability issues being experienced across the Greater Cambridge area. Strategic sites alone do not deliver policy-compliant levels of affordable housing, so, if this is the target, more smaller sites that are far more likely to deliver affordable homes at a faster rate need to be allocated.