H/AH: Affordable housing

As much as legally allowed of "affordable" housing should be truly affordable, not just use that name.
That clearly means that all "affordable" housing should be at social rents, and not "affordable" rents or discounted purchase.

A policy is also needed to ensure that the number of "affordable" flats/houses is proportionate to the commercial part of the site - not like the "Wing" site, where the ratio of commercial flats to houses is almost the inverse correlation to the "affordable" dwellings.

All "affordable" housing should be council housing, to provide security of tenure, accountability, and efficiency.

Support the policy which provides 40% affordable housing. This should be on ALL developments, not just developments of more than 10 dwellings.

It is essential that affordable housing is just that - affordable.

If affordable housing is really the goal, then tighter proposals are required to ensure that developments actually deliver this. The opportunity for developers to, in practice, deliver far lower than the 40% threshold for affordable housing on new developments of over 10 houses is far too high. Securing a site for development based on one promise and then whinging about “lack of commercial viability” until the requirement is watered down is appalling, yet very frequent behaviour. At the point a developer tries to renege on meeting this threshold, which is clearly known from the outset, the land should simply be removed from them at the price they paid for it (minus administrative costs of the process, which may be substantial) and passed to someone who can stick to the rules.

The Trumpington Residents' Association strongly supports the policy and the need for affordable housing, including the reference to 40% affordable housing on sites with 10 or more homes. However, we are very aware that so-called 'affordable housing' is not affordable to many people who may be driven out of the housing market by escalating house prices. There is the continued need for social housing at reasonable rents.

We question the service that is provided by the affordable housing organisations such as BPHA and Flagship and their failure to enforce rental agreements and take responsibility for fighting anti-social behaviour.

We are also concerned that the housing organisations are allowed to sell on their housing stock to other providers and the effect this can have on fragmenting the housing system in areas such as the Southern Fringe.

I am told that 70% of house prices are from land value. The plan includes development of green field sites. This land should be acquired at current use value and either (a) kept as social housing as a price related to the cost of land and construction cost or (b) if sold at market rate then the windfall land value increase should all go to government for use on infrastructure and not to developers/ landowners who did nothing socically valuable to earn it.

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. Ickleton). This is concerning as there are no allocations for residential development in the adopted Local Plan and no proposed allocations in Ickleton as part of the emerging GCLP. 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.

Draft Policy H/AH of the First Proposals plan requires 40% affordable housing on sites of 10 or more dwellings. With a total of 20 dwellings proposed on site 40536, 8 would be sought for affordable housing under this policy (of which at least 2 will be allocated as ‘First Homes’ under the national First Homes scheme). As well as helping to address the current shortage of affordable housing over the Greater Cambridge area, the delivery of up to 8 affordable dwellings would represent a positive contribution for the social sustainability of the local area.

It is considered that the threshold of 40% of new homes to be affordable on sites of 10 or more dwellings does accord with advice contained within NPPF. There will be circumstances however where not all sites will be able to meet these requirements for example some brownfield sites that have complex contamination issues may make affordable housing at this level unviable. It is considered that the strategy of the plan is focussed towards development within Cambridge city and on the edge of Cambridge where affordable housing provision may be less viable. The plan should recognise this and look to release more greenfield sites that have a good prospect of meeting the proposed affordable housing requirements.

It is considered that the threshold of 40% of new homes to be affordable on sites of 10 or more dwellings does accord with advice contained within NPPF. There will be circumstances however where not all sites will be able to meet these requirements for example some brownfield sites that have complex contamination issues may make affordable housing at this level unviable. It is considered that the strategy of the plan is focussed towards development within Cambridge city and on the edge of Cambridge where affordable housing provision may be less viable. The plan should recognise this and look to release more greenfield sites that have a good prospect of meeting the proposed affordable housing requirements.

USS notes that proposed policy H/AH proposes that affordable homes should be provided on-site except for in the circumstances set out in paragraph 63 of the National Planning Policy Framework 2021. USS supports this approach which is in line with national policy.

USS notes that it is proposed that where the development is solely for Build to Rent, there could be a proportionate reduction in affordable housing. USS recommends that this also applies for developments where part of the residential uses are Build to Rent. This will ensure that it is viable for the most suitable residential mix to come forward on sites.

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. 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.

In relation to the development of Land North of Pampisford Road in Great Abington, “a demonstrable need for affordable housing in Great Abington and Little Abbington” was outlined by the Planning Committee when reviewing The Orchards development directly north of site 40539 (see S/3543/16/FL Great Abington Report). 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. Great Abington). This is concerning as there are no allocations for residential development in the adopted Local Plan and no proposed allocations in Great Abington as part of the emerging GCLP. 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 manifesting 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 a policy-compliant level of affordable homes at a faster rate need to be allocated.

Draft Policy H/AH of the First Proposals plan requires 40% affordable housing on sites of 10 or more dwellings. With a total of 135 dwellings proposed on Site 40539, 54 would be sought for affordable housing under this policy (of which at least 14 will be allocated as ‘First Homes’ under the national First Homes initiative). As well as helping to address the current shortage of affordable housing over the Greater Cambridge area, the delivery of up to 54 affordable dwellings would represent a significant positive for the social sustainability of the local area.

Persimmon Homes note that this policy requires 40% affordable housing provision which is equivalent to the percentages sought under the current Cambridge City Local Plan and the South Cambridgeshire Local Plan. As identified within the wording of the policy the Viability Assessment as it progresses through the process will be key in determining whether such percentages are affordable when considered alongside other policy requirements and the different land values in place within different parts of the Greater Cambridge District.

Huntingdonshire District Council supports the proposed policy direction.

We have a genuine need for more affordable housing, but as we are one of the most expensive parts of South Cambs, we recognise that the 80% price cap does not make new houses affordable! 100 houses built on a 10 hectare site will not produce the truly affordable houses we need and no developer will find it financially acceptable to build them. We are a very green open village and the proposal to cluster 100 houses on one side of the site changes the design and feel of the village completely. It is also proposed to make the rest of the site open space, but this is not a use for the Green Belt! We don’t want ‘cluster building’. We want the village community we all desire to be enhanced by expansion and future needs. As regards the final 7 statements in this section, we would ask that the Plan considers these important areas but they are not applicable to our Parish.

We support the policy that 40% of housing on new developments of 10 or more houses shall be affordable.

Affordable Housing

4.58. The housing strategy in emerging Policy H/AH identifies the requirement for 40% of homes on sites of 10 or more dwellings to be affordable. It also sets out that the Councils will seek the following proportions of different tenures of affordable homes in South Cambridgeshire: 70% affordable housing for rent (social rent homes and / or affordable rent homes) and 30% intermediate tenures. The expectation is also to deliver 25% First Homes in line with the NPPF and transitional guidance.
4.59. Overall MGH is supportive of the proposed policy direction, but that the need for viability testing may arise in some areas. Housing affordability is a key issue for equality both nationally and more significantly, within Greater Cambridge. It is also an international issue. International companies able to offer better living standards with a smaller portion of wages needed to pay for living accommodation can tempt workers from the UK to other destinations across the globe. The government and local authorities recognise in the Oxford-Cambridge Arc document that median house price to median income ratio has been increasing across the UK, and is increasing more significantly across the Arc.
4.60. Savills estimates that for its economic potential to be reached, 9.6 million sq ft of business floor spaces is needed across the Arc, with 680,000 homes beyond the existing pipeline. If the Arc is to deliver its employment potential, housing affordability must be addressed through the building of significant numbers of homes.

"40% of new homes will be required to be affordable" is a laudable aim.
However, I see too many instances where developers get away with less, because the Council doesn't enforce policies.

I agree with the broad policy on affordability. However, we need a much more refined approach to affordability that recognises the total cost of living in each location. An affordable home for a couple that requires one or two cars is a significantly less affordable home that one in which the occupants can function with public transportation and active travel options. The same concepts applies to standards of energy efficiency and the renewable energy. The simple percentage of affordable housing on a development does not tell the complete story.

Countryside supports policy H/AH in seeking to secure affordable housing provision as part of residential developments and that the 40% requirement will contribute to meeting the affordable housing needs of Cambridge. It is agreed that affordable housing should be distributed throughout new developments, however the policy should also acknowledge that appropriately sized clustering can also assist with the delivery and on-going management of affordable homes.

There is a substantial need for affordable housing across Greater Cambridge due to past under delivery and worsening affordability ratios and new development is needed to help address this unmet need. In relation to Melbourn, there are a significant number of households on the SCDC Housing Register. It is likely that some of this demand will be met through development which has already been granted permission, however there will be existing households that remain on the register, alongside new households that aren’t yet identified. Greenfield development where there is a less infrastructure burdens mean that policy aspirations for affordable housing provisions are normally more easily met.

Land to the west of Cambridge Road, Melbourn presents an excellent opportunity to deliver a substantial number of affordable homes in a highly sustainable location. Affordable housing would comprise a range of sizes, types and tenures, in a genuinely tenure blind manners, increasing the supply of high quality affordable housing to meet local needs. The proposals could also deliver an element of build to rent, helping to increase accessibility to housing for different sections of the community.

The existing affordable housing policy is regularly not met by developers. This policy MUST be enforced. Strongly support intermingling of affordable homes throughout developments to increase social inclusion.

Need to provide truly affordable housing for lower paid and starters.

Will this include building the modular pod type homes that could be made available for those who find themselves homeless?

This policy sets out that a 40% affordable housing requirement will be required from new developments coming forward. Further work is underway, including consideration of the implications of the introduction of First Homes on the provision of other affordable tenures. New housing developments of 10 or more dwellings will be required to provide an appropriate mix of housing sizes (number of bedrooms), with the proportions of dwellings of each size to be guided by the housing mix for each tenure. Marshall supports this policy direction and intends to deliver a policy compliant development at Cambridge East that offers wide ranging housing benefits, including to those in greatest housing need.

The Commissioners support the need for an affordable housing policy within the Local Plan which will deliver the level of provision required within Greater Cambridge. At this early stage in the plan-making process, the Council acknowledges further work regarding the Plan’s viability is required in order to justify this proposal. The Commissioners wish to reiterate the importance of ensuring that a whole Plan viability assessment, which takes into account infrastructure and emerging policy requirements. is undertaken at the appropriate time to ensure the policy is robust.

It is acknowledged that the First Proposals include a requirement for 40% affordable housing on sites of 10 or more dwellings.
This is higher than the adopted Cambridge Local Plan approach of seeking 25% affordable homes on sites of 10-14 dwellings and 40% affordable homes on sites of 15 dwellings or more, however, we acknowledge there is an affordability issue within the Greater Cambridgeshire area which justifies the amended policy approach.
By proposing additional small to medium sized allocations within the Greater Cambridge area, including within the more rural Villages, this will ensure the delivery of affordable is housing dispersed across the wider area, providing a choice of affordable homes for future occupiers.

TMLC supports the provision of Affordable Housing which is particularly needed within Cambridgeshire.

It is acknowledged that the First Proposals include a requirement for 40% affordable housing on sites of 10 or more dwellings.
This is higher than the adopted Cambridge Local Plan approach of seeking 25% affordable homes on sites of 10-14 dwellings and 40% affordable homes on sites of 15 dwellings or more, however, we acknowledge there is an affordability issue within the Greater Cambridgeshire area which justifies the amended policy approach.
By proposing additional small to medium sized allocations within the Greater Cambridge area, including within the more rural Villages, this will ensure the delivery of affordable is housing dispersed across the wider area, providing a choice of affordable homes for future occupiers.

It is acknowledged that the First Proposals include a requirement for 40% affordable housing on sites of 10 or more dwellings.

This is higher than the adopted Cambridge Local Plan approach of seeking 25% affordable homes on sites of 10-14 dwellings and 40% affordable homes on sites of 15 dwellings or more, however, we acknowledge there is an affordability issue within the Greater Cambridgeshire area which justifies the amended policy approach.

By proposing additional small to medium sized allocations within the Greater Cambridge area, including within the more rural Villages, this will ensure the delivery of affordable is housing dispersed across the wider area, providing a choice of affordable homes for future occupiers.

CBC Limited and the landowners support the intention to secure the delivery of affordable housing in Cambridge, particularly given the high house prices seen in the city. The CBC Vision 2050 seeks to deliver affordable housing to address the needs of Campus staff, the nature and securing mechanisms for which can be agreed through the local plan policies and joint working with GCSP.