H/AH: Affordable housing

The proposed policy direction wording should be amended to make it clear that on sites of 10 or more private residential dwellings 40% of new homes will be required to be affordable…

In addition, and in line with paragraph 65 (b) of the National Planning Policy Framework, it should be made clear that purpose built accommodation for students is exempt from the requirement to provide a percentage of the total number of units as affordable.

A mix of housing types should be provided across Greater Cambridge. Alongside open market sale housing this should include affordable rent, social rent, starter homes and rent to buy. We have significant reservations regarding the affordability of the First Homes product and how under the current policy proposals they will replace “traditional” affordable tenures in particular Shared Ownership.

As per submission under Housing: General Comments, we need truly affordable housing for young families

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. For example, 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continued increases in build costs may render the viability evidence which underpins the affordable housing requirement out-of-date relatively quickly.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 south of Horseheath Road in Linton, a Housing Needs Survey carried out in June 2019 indicated a need for 81 affordable dwellings in the village. According to a recent appeal decision there was still an unfulfilled need for 64 affordable dwellings as of 16 February 2021. There are no allocations for residential development in the adopted Local Plan and no proposed allocations in the village as part of the emerging GCLP. It is understood that two permitted developments will deliver 39 affordable homes, leaving a presumed requirement for 25-42 affordable dwellings – a requirement which will likely increase across the life of the Greater Cambridge Local Plan. 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 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 100 dwellings proposed on site 40554, 40 dwellings – of which at least 10 will be allocated as ‘First Homes’ under the national First Homes initiative - would be sought for affordable housing under this policy. As well as helping to address the current shortage of affordable housing over the Greater Cambridge area, the delivery of up to 40 affordable dwellings would satisfy the full affordable housing need in Linton – a significant benefit for local residents.

The affordable housing policy should support the principle of homes for NHS Staff (key workers), and support access for NHS staff to affordable housing, as a priority, where there is an evidenced need.

Cambourne Town Council , while accepting that the aim of the policy is to have 40% appropriate on most developments, consideration should be given to a stepped approach. New settlements subject to location (those close or adjacent to Cambridge would be able to support a higher percentage due to access to existing provision) and any expansion of Cambourne should have a threshold of 30% for affordable homes. Existing settlements have a low percentage of affordable homes and new developments will help to raise the percentage of affordable homes therefore providing homes where they are needed meaning that family members do not need to move out of their community when they leave home aiding their health and wellbeing. Cambourne has been developed with 30% affordable housing which has proved a sustainable community. That is able to provide the facilities and infrastructure needed to support the health and wellbeing.

You must be rigorous in holding developers to affordable housing standards and not allowing them to escape their obligations by claiming lack of viability etc after grant of planning permission.

AFFORDABLE HOMES
The increase in house building does not reduce house prices, and does nothing to address the inequality that, according to the Centre for Cities, has marked Cambridge out as the most unequal city in Britain. Inequality creates "pernicious effects…eroding trust, increasing anxiety and illness, (and) encouraging excessive consumption". There is also evidence that overseas investors number amongst the purchasers of new homes in the area, which contributes to the housing cost crisis.
The plan states that 40% of the new housing stock will be ‘affordable’ (currently 80% of the market price). As the average house price in Cambridge is around £500,000, this would mean an ‘affordable’ house would cost £400,000, clearly well beyond the reach of first-time buyers without substantial independent savings or inheritances/parental donations. Of these new homes, it is stated that 75% will be social rented (75% of 40% = 14,400). While this is welcome, current dominant forms of social housing are built by the council (or at least by a public-private partnership) or housing associations. These rental homes can be purchased under right-to-buy legislation after 5-10 years, and many are sold on very quickly. According to The Independent, 40% of housing sold through the right-to-buy scheme are now private rentals. There have to be more imaginative ways to address the housing crisis for first-time buyers and those on low-moderate incomes (housing co-operatives, community land trusts etc) that guarantee that these homes are not subject to sale and cost inflation. Those in existing social rented homes urgently need their homes to be retrofitted to high energy efficiency standards (Cambridge City Council has acknowledged by supporting nef’s Great Homes Upgrade campaign). Further, a great deal of housing units in Cambridge that would suit first-time buyers trying to get into the housing market, are frequently snapped up by buy-to-let landlords, which makes it even more difficult for people to escape the rental-trap.

Shepreth Parish Council (SPC) supports the expanded provision of affordable housing.

The overarching policy objective to provide enough homes to meet objectively assessed local need, including housing that is affordable to buy, is strongly supported. This policy should however specifically reference the need to ‘significantly increase the number of affordable ownership homes for those who can’t afford to buy their own homes’.
The NPPG confirms (Paragraph: 020 Reference ID: 2a-020-20190220) that affordable housing need includes those that cannot afford their own homes, either to rent, or to own, where that is their aspiration. The British Social Attitudes Survey (2018) reports that c.87% of households aspire to own their own home. On this basis, nearly all households presently living in the Greater Cambridge private rented sector can be assumed to be in need of an affordable ownership home option. This conclusion is supported by the Council’s Housing Strategy (2019) evidence base which confirms demand for low-cost home ownership options outstrips supply (page 11).
However, the Council’s Housing Needs of Specific Groups (2021) evidence base report significantly understates the scale of this need by assuming only households who can’t afford a home costing £200,000 or more require affordable home ownership. Homes at this very low price point are unlikely to be of reasonable quality and/or in the right locations close enough to where people work (e.g Cambridge City Centre). The assessment also incorrectly assumes all those who can’t afford private rents would be unable to afford to access affordable home ownership products. This is not the case in many locations (including within Cambridge City Centre) where private rents (£1,000 PCM) can exceed mortgage payments on discounted market sale homes (£790 PCM).

The policy objective to require the delivery of new affordable home ownership products on all sites is strongly supported (except where solely Build to Rent). This policy should however specifically reference strong support for developments where the large majority (75%+) of homes are proposed as affordable home ownership products regardless of the size of these homes.
The need to significantly increase the delivery of home ownership products within Greater Cambridge is highlighted throughout the Councils Housing Strategy (2019) evidence base. Specifically, the strategy notes lack of affordable homes within commuting distances is having a negative impact on economic growth (page 10) and there is a need to provide housing for essential key workers (page 16). Proposals for a high proportion of this type of affordable housing should therefore be afforded strong policy support to encourage their delivery regardless of the overall mix of tenures and unit sizes proposed.

This policy should include an exemption to First Homes and/or any other specific tenure split requirements where the large majority (75%+) of housing is proposed as affordable housing (as defined by Annex 2 of the NPPF).
Encouraging the delivery of schemes in which the large majority of homes (75%+) are affordable homes is important for increasing and accelerating the delivery of new affordable homes and meeting unmet local housing need. Requiring these very important schemes to also provide First Homes and or other specific tenures would make them less viable/attractive for Registered Providers and other SME affordable housing developers such as Pocket. The need to support SME developers to widen housing choice is noted in the Council’s Housing Strategy (2019) evidence base (page 21). Flexibility on tenure for schemes providing more than 75% affordable housing has successfully been implemented in London through Policy H5 of the London Plan (2021) and has supported increased affordable housing delivery.

The affordable housing target for schemes which provide a mix of Build to Rent and conventional homes should be a blend of both targets (apportioned according to the number of homes proposed). The targets for each housing type should be set with reference to relevant viability evidence.
It is widely acknowledged that Build to Rent is less viable than conventional private sale housing due to its distinct economics. This should be reflected in the affordable housing policy target to ensure this type of housing remains viable and deliverable. If the policy target for a mix of housing types (including Build to Rent) is the same percentage as for a solely conventional sale scheme it is unlikely to be viable and deliverable. Setting an undeliverable policy target may discourage developers from bringing forward much needed new housing in Greater Cambridge.

Homes policies
83. As already expressed above, CPRE’s concern is that this draft Plan includes house-building far in excess of
necessary or statutory requirements. It appears to be based on a growth agenda which in turn is based
upon encouraging unsustainable inward migration to the area.
84. CPRE believes that the greatest housing need is for affordable homes and would like to see Policy H/AH:
Affordable housing, strengthened and enforced as far as possible. We would like to see increasing
numbers of small sites developed with affordable housing included.
85. CPRE has some concerns about the use of Policy H/ES: Exception sites for affordable housing, because in
one district we know of, the exception site rules have been used to approve major, market led,
developments posing as community-led exception sites, when they contain the minimum requirement of
affordable housing. We trust that South Cambridgeshire will not countenance this deceptive approach
through the application of this policy.

Introduction
Thank you for consulting Central Bedfordshire Council (CBC) on the first proposals consultation for the Greater Cambridge Local Plan 2041. Please accept this letter as our formal response. We welcome the opportunity to respond to the proposals in this consultation and look forward to continuing the good working relations that CBC has already forged with the two substantive authorities. We have provided some comments below on the consultation documentation which we hope are useful. Please do not hesitate to contact us if you have any further questions.

General Comments on Strategy

Overall, the Council supports the approach you have taken in terms of undertaking a joint local plan to ensure a consistent approach to planning and building across both Cambridge City Council and South Cambridgeshire District Council up to 2041.

We support the proposed Vision for the Greater Cambridge Plan especially as it places climate impacts at the heart of key decisions. It states that Greater Cambridge will be a place where a big decrease in your climate impacts comes with a big increase in the quality of everyday life for all your communities. It also promotes new development minimising carbon emissions and reliance on the private car; creating thriving neighbourhoods with the variety of jobs and homes you need; increasing nature, wildlife and green spaces; and safeguarding your unique heritage and landscapes. CBC considers this to be a laudable, succinct overarching Vision that we hope you will be able to carry through to effective policy and decision-making on the ground.

CBC considers that the proposed strategy outlined within the First Proposals could help ensure that Greater Cambridge makes a valuable contribution to the Oxford to Cambridge Arc and to the overall delivery of the Government’s ambitious growth aspirations. However, the Council considers that it would be useful to include reference to the emerging Arc Spatial Framework, identifying that alongside the NPPF, this will set the overarching strategic framework for the area with which all local plans within the Arc must accord. CBC would be keen to understand the timescales for the delivery of the Greater Cambridge Plan and how the emerging Spatial Framework will be taken into consideration to inform future iterations of the plan.

We appreciate that the Plan is at an early stage of development, and at the current time you are considering locations that could be delivered alongside allocated sites being carried forward from the adopted 2018 Local Plans for Cambridge and South Cambridgeshire, as well as sites which already have planning permission.

We note that you are proposing to meet in full your objectively assessed needs of 44,400 new homes to 2041, which is supported by CBC and is necessary to ensure needs can be met across the area.

CBC recognises that Cambridge has seen significant economic and jobs growth in recent years and that there is an ambition to maintain this direction of growth as the impacts of the recent pandemic subside. As stated in our comments made in response to your Issues and Options Consultation in February 2020, we would not support a level of jobs growth that could detrimentally impact upon the ability of neighbouring authorities, such as Central Bedfordshire, to meet and deliver their own economic ambitions and growth aspirations. CBC therefore supports the housing numbers proposed to meet the OAN and the identified buffer and welcomes the move away from the higher job number which were put forward in your Issues and Options consultation. We agree that the higher jobs forecast previously considered would not be the most appropriate scenario to pursue. Overall, CBC considers that the proposed level of housing of 44,400 new homes and complementary economic growth of 58,500 new jobs across all sectors including business, retail, leisure, education and healthcare, is an appropriate level of growth to deliver for over the plan period.

The First Proposals have suggested 19 new possible locations that might be suitable for additional development to meet your needs across the Greater Cambridge area up to 2041. Overall, CBC supports the proposed approach taken to the geographical spread of these sites and welcomes the inclusion of sites in the most sustainable locations around the Cambridge urban area and on the outskirts of the City, where existing and future residents can take most advantage of the proximity to jobs and services using public transport and active travel options. The proposals to direct development to where it has the least climate impact, where active and public transport is the natural choice is logical and fully supported.

It is noted that the consultation material suggests that the majority of your objectively assessed need can be provided for in the core preferred strategic sites of North East Cambridge, Cambridge East and Cambourne. This approach is supported as the locations will reduce potential climate impacts through the delivery of well connected, sustainable, compact development where active and sustainable travel can be maximised.

CBC have not provided detailed comments on all of the proposed 19 sites included within the consultation material but note the proposals for new strategic scale development at Cambourne which lies in close proximity to Central Bedfordshire. It is noted that in total, there are 3 development sites proposed for Cambourne - two of these are existing allocations; Cambourne West which has capacity for 2,590 units and Bourn Airfield which has capacity for 2,460 units, alongside a new proposed broad location for growth at Camborne - expected to deliver 1,950 homes.

CBC recognises that whilst a final decision has not yet been announced, the preferred East West Rail route between Bedford and Cambridge will likely result in a new stopping station at Cambourne and that this will transform the area, maximising sustainable opportunities for growth. Whilst we support the opportunities that the proposed new station would potentially bring, CBC would suggest that any future transport impact assessments and traffic modelling associated with the proposals should consider the cumulative impacts of both existing and proposed development at Cambourne and any implications for the wider area, including potential impact upon the strategic and local road network within Central Bedfordshire. It is likely that there will be cumulative impacts from growth at Cambourne on communities within CBC related to an increase in demand on the A1, particularly if / when the A428 dualling and Black Cat works are carried out, and also the more minor roads through areas like Potton, Sandy, Biggleswade. Whilst outside of the Greater Cambridge plan area, the capacity of the A1 in this area is already a key concern that affects a much wider area and must be considered carefully and comprehensively when decisions are being made in relation to future growth.

We would, therefore, welcome further engagement to understand the scale of those impacts and their likely implications for Central Bedfordshire communities as the work on the local plan and the sites themselves, progresses. We would welcome being involved in early engagement with National Highways in relation to these impacts. We would also be keen to look at opportunities to secure sustainable links (via public transport) between CBC and the development areas to the west and south of the Greater Cambridgeshire area.

As noted above, whilst a formal decision is yet to be announced in relation to EWR between Bedford and Cambridge, or indeed the location of a new stopping station at either Tempsford or to the south of St Neots, CBC consider it essential that the Greater Cambridge Plan considers the wider context of strategic growth within the Arc, particularly in terms of future connectivity opportunities that will undoubtedly arise as proposals within neighbouring authority areas emerge. Your approach to enabling some development within smaller villages is supported as this will support rural services and the vitality and viability of villages and their shops and services contributing to overall sustainability. We appreciate that it is unsustainable to encourage high levels of growth where car travel predominates and that therefore, in smaller villages you will continue to support infill development and affordable housing on suitable sites only. This approach is supported, especially given the very rural nature of the areas close to the Central Bedfordshire border.

The 7 Themes
We welcome the approach taken in this consultation to identify 7 key themes and we have provided some high-level comments on each of them below. It is understood that each of the themes will influence how you will plan homes, jobs and infrastructure and ultimately where growth will be directed. In our previous response to the Issues and Options stage of consultation (February 2020) we suggested that “connectivity” both within and beyond the Greater Cambridge area should perhaps be considered as an additional theme. Whilst we note this suggestion has not been taken onboard, CBC considers that connectivity is the ‘golden thread’ that runs through all the key themes and could potentially be referenced as such within the Greater Cambridge Plan.

Climate Change
We support your aim to help Greater Cambridge to transition to net zero carbon by 2050 through a number of comprehensive measures including ensuring that development is sited in places that help to limit carbon emissions, is designed to the highest achievable standards for energy and water use and is resilient to current and future climate risks. It is clear that responding to climate change has influenced the shape of the plan as an important factor in determining where future development should be located and how it should be built. CBC would be keen to have future conversations to share experiences and to understand how net zero carbon can be achieved in terms of viability, and to explore how this can be monitored to ensure the approach is successful. In terms of detailed policy, Policy GP/QD could benefit by also referring to building orientation to maximise the opportunities for renewables.

Biodiversity and Green Spaces
We support your aim for biodiversity and green space policies to increase and improve your extensive network of habitats for wildlife and green spaces for people, ensuring that development leaves the natural environment better than it was before. We also welcome confirmation that the Oxford to Cambridge Arc Environmental Principles have informed your approach to this theme, in particular, we welcome and support the ambitious policy to require 20% Biodiversity Net Gain. As this will be an issue for all Local Authorities within the Arc, CBC would also be keen to discuss how this could be delivered and the impacts this might have not only on site viability, but
the delivery of other key services and facilities across the Arc .

Wellbeing and Social Inclusion
We support your aim of helping people in Greater Cambridge to lead healthier and happier lives ensuring everyone benefits from the development of new homes and jobs.

Great Places
We support your aim for the delivery of great places through policies that sustain the unique character of Cambridge and South Cambridgeshire and compliment the area with beautiful and distinctive new development, creating a place where people will want to live, work and play.
The themes from the Cambridgeshire Quality Charter for Growth covering the four “Cs” of Community, Connectivity, Climate and Character is a sensible approach consistent with the National Model Design Code.

Jobs
CBC supports the aim of your proposed jobs policies in terms of encouraging a flourishing and mixed economy which includes a wide range of jobs while maintaining the areas global reputation for innovation. The Council considers the policies are positive and forward thinking in the current climate in that they seek to reflect how the approach to working environments is changing, by supporting remote working and improving facilities on employment parks.
We support the inclusion of a remote working policy but consider that it could be strengthened to refer to the provision of home office space in new dwellings as the emphasis is currently on the delivery of external hubs or extensions of existing dwellings.

Homes
As commented above, the Council supports the proposed strategy to plan for and deliver enough housing to meet your objectively assessed needs, including significant amounts of affordable housing and a mix of tenures to suit your diverse community’s needs. The proposed policy requiring 40% affordable housing in new developments is particularly supported.

Infrastructure
We support the approach taken that the relationship between jobs and homes and sustainable transport opportunities has been a key consideration and influence of the development strategy proposed. Recognising that infrastructure is not limited to the provision of new roads, CBC also supports the recognition for the need to consider and plan for water, energy and digital networks, and health and education and cultural facilities in the right places and at the right times to ensure your growing communities are supported. Looking to the future, your policies on electric vehicle charging points and digital infrastructure will be key given the need to move away from carbon-based vehicle fuels and the shift to homeworking that has been accelerated by the pandemic. We also note that whilst there is an objective for Air Quality within the Sustainability Appraisal, there is no objective included for Transport and Access.

We welcome this opportunity to comment on this latest stage of your development plan proposals and largely offer our support to the approach you have taken. We also appreciate how you have digitally presented and structured the documentation in order to make it as accessible as possible to everyone. The use of maps and diagrams throughout the document is an effective way of setting out the context and portraying the information within the text. In addition, the ability to explore the documentation through the “themes” and “maps” is a particularly helpful way of organising the consultation.
I hope you find these comments useful and look forward to continued engagement as your plan progresses.

Paragraph 65 b) of the Framework makes clear that proposals for specialist accommodation should be exempt from providing at least 10% of properties for affordable home ownership, stating: “Exemptions to this 10% requirement should also be made where the site or proposed development: b) provides specialist accommodation for a group of people with specific needs (such as purpose-built accommodation for the elderly or students)”; Government policy is therefore clear that specialist accommodation should be exempt from this affordable housing policy requirement.
The proposed development at Branch Lane and Long Lane, Comberton would include a mix of C3 general needs dwellings and Use Class C2 Extra Care accommodation. The provision of affordable housing contributions will need to be assessed with this consideration in mind and as such the policy approach must support the separate assessment of affordable housing contributions on these types of mixed-use sites. For example, the Council’s proposals under Policy H/AH for mixed-tenure schemes including Build-to-Rent elements may be subject to making up any shortfall in affordable homes across the remainder of the development. Without prejudice to the justification for that position, Policy H/AH must be clarified to ensure that similar arrangements will not be applied to mixed-use sites incorporating specialist housing for older people.
Proposed Policy H/AH also sets out that on sites of 10 or more dwellings 40% of new homes will be required to be affordable, except where: there can be a proportionate reduction as a result of vacant buildings being re-used or re-developed (as set out in national planning policy), the development is solely for Build to Rent, the development is for some types of specialist accommodation that fall within Use Class C2, or the development is solely for residential caravans. Further clarification is required as to which types of specialist accommodation that fall within Use Class C2 would be exempt in light of the Framework and Planning Practice Guidance.
Retirement Communities providing for Extra Care take the form of a “core building” and containing a mix of service and residential uses and surrounding purpose designed specialist accommodation.
The village core will provide a number of communal facilities focussed on facilitating wellness and typically comprise up to 25% of its floorspace as non-saleable space. This includes the communal and care facilities available to its residents. These facilities may vary from village to village but will always include a minimum level of communal provision.
The specialist accommodation will be carefully designed to incorporate features that allow for practical living for older people and the delivery of care and assistance safely within that setting, which can be increased over time as necessary.
The proposed site would provide a mixed-use development with part of the site including the following features which suggest that some of the site falls within Use Class C2:
• The development provides for specialist housing that caters for the specific needs of older persons
• The care village provides a wide range of communal facilities to promote physical and mental health and wellbeing, including a wellness spa, restaurant, meeting spaces/library, transport services, landscaped grounds, back offices and staff facilities
• The accommodation would provide for specialist features including level access, maximised natural daylight, internal room layout, connectivity to staff
• The development would provide specialist management services including a village manager, wellbeing navigator and reassurance response co-ordinated through the central reception;
• An extensive review process to identify Registered Domiciliary Care Providers to provide Personal Care to residents
• Restriction of use through a legal agreement so that units are only used for Class C2 purposes in perpetuity
In this regard, Integrated Retirement Communities which provide Extra Care housing fall within use Class C2 of the Use Classes Order.
For the reasons outlined above, the delivery of Affordable Housing on Extra Care sites is typically challenging, which is why paragraph 10-007-20190509 of the PPG states that viability may need to be considered on schemes where particular types of development are proposed which may significantly vary from standard models of development for sale (for example housing for older people). Whilst an initial purchase may be discounted, the ongoing service charge for access to the village’s services and facilities cannot be discounted. It would also not be possible to discount the cost of care for residents within units provided as affordable tenures. It is considered that these practical issues should be addressed within policy as otherwise it could be difficult to implement and be ineffective.
The integrated retirement community/Extra Care model predominantly operates on the sale of individual units as part of a managed development. Care packages are purchased either from the operator or by a third-party care provider. This differs from care homes which are sold or let to an operator with individual residents paying for their room, board, and care.
The integrated retirement community/Extra Care model also differs from more general development in that they incorporate a significant level of facilities which results in the net to the total gross floorspace being significantly poorer than in traditional/general housing needs. This means that such schemes have a substantially lower amount of saleable floorspace compared with traditional developments and such schemes will also require the additional costs of lifts and specially adapted bathrooms and other such facilities appropriate to the target age group and level of care.
At paragraph 10-007-20190509 of the PPG, it states that: “Where up to date policies have set out the contributions expected from development, planning applications that fully comply with them should be assumed to be viable. It is up to the applicant to demonstrate whether particular circumstances justify the need for a viability assessment at the application stage. Policy compliant in decision making means that the development fully complies with up-to-date plan policies”.
The PPG continues to outline that: “Such circumstances could include, for example, where development is proposed on unallocated sites of a wholly different type to those used in the viability assessment that informed the plan; where particular types of development are proposed which may significantly vary from standard models of development for sale (for example built to rent or housing for older people), or where a recession or similar significant economic changes have occurred since the plan was brought into force”.
The First Proposals set out that the Plan will be subject to a viability assessment at each stage of plan making, including a whole plan viability assessment that will accompany the draft plan and be updated at subsequent stages of plan making. It adds that current evidence indicated that securing 40% affordable homes is deliverable across Greater Cambridge taking account of other development costs assumed so far but will be kept under review as the plan progresses.
The Viability Assessment that supports this consultation, paragraph 2.45 sets out that the Council have appraised generic retirement living or sheltered housing schemes typically delivered by developers such as McCarthy and Stone or Churchill retirement living, and these have been included within the residential typology rather than a separate element which therefore means it becomes tied up with Class C3 for viability purposes.
It is considered that the evidence base has failed to assess the different typologies available for the provision of specialist housing for older people by only appraising generic retirement living or sheltered housing schemes. The evidence is not reflective of the viability of schemes which seek to deliver Extra Care provision. The Councils evidence should therefore assess a range of typologies including Extra Care schemes up to 200 units to consider the viability of these developments to come forward.
The Viability Assessment should also consider the provision of affordable housing on such type of schemes as it is often the case that Affordable Housing is unlikely to be viable for Extra Care schemes.
It is imperative that careful consideration is given to the forms of specialist accommodation which relate to older persons’ housing and the different types of accommodation that can be provided as these can vary significantly.

The rejection of planning sites put forward for development in Histon & Impington, in the first phase of a new Local Plan should be mitigated by the need for some affordable housing units to sustain the villages in the future as a viable community. The current Villages’ Neighbourhood Plan emphasises this need, which can be met by the provision of smaller Rural Exception Sites, delivered by the local Community Land Trust.
HICLT understands the rejection of large-scale sites in and around Histon and Impington, following the recent call for sites. The fact that our community is surrounded by either the green belt or the City boundary means that large scale development will always conflict with existing well-established policies to prevent urban sprawl. We have no desire to see these protections removed or weakened. Bringing large sites within our settlements’ development envelope will only exacerbate the problems of unaffordability and capital extraction from the community. All it will mean is that high priced housing for sale will be developed making little or no contribution to meeting local housing need for genuinely affordable options. In these circumstances large developers will build out most of the site minimising their affordable contribution through viability assessments and deliver whatever they choose to provide by partnering with large registered social housing providers, with no community specific connection or commitment.

The HBF has concerns that the viability assessment has underestimated some of the costs in relation to polices and land values. Given that affordable housing is the principal cost placed on development through local plans it will therefore be necessary to reconsider this policy through an updated viability assessment. It may be necessary to reduce the affordable housing requirement on some development typologies in order to ensure the local plan is consistent with paragraph 58 of the NPPF which states that decision makers should be able to assume that applications that comply with all policies are viable.

Introduction

Thakeham Homes Ltd (Thakeham) is pleased to be participating in this consultation and has outlined its position below in response to the consultation on the Greater Cambridge Local Plan – The First Proposals (1st November to 13th December 2021).

About Thakeham

Thakeham prides itself in being an infrastructure-led sustainable placemaker and is committed to creating new, extraordinary places, where the highest attention to detail makes a positive difference.

Thakeham build for the future, for communities and individuals. Our approach sets us apart from our competitors. We deliver our schemes with a focus on sustainable development, looking ahead of current housing standards. From 2025, all Thakeham Homes will be carbon neutral in production and zero carbon in lifetime use.

Each development is different and tailored to its locality with careful consideration of the area’s character, as well as the environment. As a sustainable placemaker first and foremost, Thakeham’s commitment to improving existing communities means its schemes are design and infrastructure-led; engaging with education, highways, healthcare, utilities and other local community, cultural and environmental stakeholders from the start of each project. The delivery of homes facilitates the delivery of physical, social and green/blue infrastructure which benefits the wider surrounding area, as well as the new residents, and ensures that Thakeham create sustainable places to live and work.

As one of 12 members of the NHS Healthy New Towns network, Thakeham is a committed advocate of developing healthy places in line with the Healthy New Town principles. But over time, we have realised that these principles are just the starting blocks, and at Thakeham, as a founder member of the HBF Future Homes Task Force, we are committed to delivering sustainable, zero carbon communities. Out approach sets us apart from our competitors. We deliver our schemes with a focus on infrastructure-led sustainable development.

Sustainability

There is an evident theme in Greater Cambridge in respect of environmental impact and the importance of ensuring any development, whether that be residential or infrastructure, seeks to minimise its impact. Thakeham would like to take this opportunity to outline the measures implemented on its developments to minimise environmental impacts as a direct and indirect result of development:

• From 2025, all Thakeham homes will be net-zero carbon in lifetime use.
• From 2025, all Thakeham homes will be carbon neutral in production. Our off-site panellised system will make construction more efficient, faster, enhancing quality and reducing construction traffic.
• Thakeham is committed to offsetting the embodied impact from the production of new houses, as well as development houses that are zero carbon in lifetime operation.
• Thakeham support the Wildlife Trust’s guidance on Homes for People and Wildlife. Our commitment is to at least 20% biodiversity net gain (double the government’s target within the recent Environment Act 2021) on all our developments post-2025 with attractive and functional green and blue infrastructure.
• Through placemaking and the implementation of sustainable travel plans, Thakeham prioritises walking and cycling over car travel, helping people make more sustainable choices around walking, cycling and taking public transport, as well as highlighting innovative car-sharing online platforms such as LiftShare to reduce single-occupancy car use and facilitating use of autonomous vehicle/pods.
• Thakeham provides electric car charging points at all of their homes both market and affordable alike, reducing barriers to customers purchasing emission-free vehicles.
• Thakeham is keen to champion low carbon transport in the local area, encouraging local transport services such as buses to electrify their fleet.
• Mechanical Ventilation with Heat Recovery (MHVR) is installed in our homes, which has a filter built-in to capture incoming pollution to provide fresh filtered air.
• Thakeham works with its supply chain with an aim that all mechanical plant on site is less than 18 months old, which means it is less polluting and more fuel efficient

Response to Options

Thakeham has reviewed the consultation documents and has chosen to comment on key questions and themes where relevant to our business to comment on.

Vision and development strategy
Section / Policy Your comments
Vision and aims Thakeham supports the Council’s vision for new development to come forward with sustainability and healthy place shaping at the forefront.

As we’ve touched on above, Thakeham support the focus on healthy place shaping, with a need to ensure that future development maximises opportunities for journeys to be made on foot or bicycle. This will necessitate ensuring new developments prioritise non- motorised transport and are easily accessible to full range of day-to- day services and facilities.

Thakeham has made a number of commitments in respect of its own carbon impact, ensuring that all its development will be net-zero carbon in lifetime use and carbon neutral in production by 2025.
Additionally, Thakeham has made a commitment to achieve 20% biodiversity net gain on all projects post-2025 which is double that set out in the Environment Act 2021.
How much development, and where – general comments Whilst Thakeham supports a weighted distribution of development towards the most sustainable locations and key employment hubs, we would emphasise the importance of a variety of growth locations and sizes to support housing growth. New settlements, strategic extensions and development in rural locations all form a key part in meeting varying housing needs and ensuring a consistent supply of housing delivery.
S/JH: New jobs and homes Thakeham is supportive of the Councils’ conclusions that adopting the suggested ‘standard method minimum homes and related jobs’ approach would not be appropriate for Greater Cambridge and would not support its economic growth aspirations.

It is acknowledged that the Councils’ have sought to accommodate an uplift to accommodate their economic growth aspirations, suggesting that the ‘medium level of homes’ approach is justified, resulting in a need for 44,400 homes over the plan period 2020-2041 amounting

the 2,111 homes per annum, alongside provision of 58,500 new jobs over the plan period.

Whilst the ‘maximum level of homes’ does not represent the Councils’ preferred approach; it is worth noting that this approach does acknowledge housing need arising out of fast job growth and therefore the Employment Land Review makes recommendations to provide more that the ‘medium’ scenario level of jobs to provide flexibility.

Thakeham is supportive of the Councils’ intention to accommodate their full objectively assessed needs for housing and jobs within the plan area. It is also acknowledged that a 10% buffer has also been added into their housing requirement to provide flexibility, amounting to a housing requirement of 48,840 over the plan period.

The Greater Cambridge Local Plan will need to ensure that it is planning for a sufficient number of new homes to support its economic growth aspirations. Whilst it is acknowledged that the medium option for new homes does incorporate an uplift for economic growth in the area, in addition to the application of a 10% buffer to reach the suggested housing requirement. Thakeham would suggest that the Councils undertake further work to ensure that the correct uplift has been applied to ensure that the Councils can meet their relevant aspirations in terms of job creation and growth, and as consequence provide the right level of housing to support this. This is important to ensure that existing employers in the area can continue to thrive and expand importantly retaining and attracting staff including graduates, in what is a global recruitment marketplace for many of the industries already located in Greater Cambridge. Further, in order to ensure Greater Cambridge continues to be a focus for inward investment into the UK, following on from the successes of the past, continued focus on supporting employment growth will be key and part of that will be providing housing to attract not just highly skilled staff but also for the variety of lower paid workers such as cleaners, delivery drivers and shop workers. These lower paid workers are necessary to support the wider community and economy such as in Greater Cambridge, where land and house prices are high. These people are either driven out, much has been the case in London and has been seen in parts of Greater Cambridge to more
affordable locations, but with the consequence of a longer commute,

or greater affordable housing provision is required to accommodate them.
S/DS:
Development strategy The first proposals consultation is suggesting a focus on existing commitments and expansion of existing sites to meet the suggested housing need. Where new sites are proposed these are focussed predominantly within and around the edge of Cambridge.

The background text to S/DS suggests that very limited development is proposed in rural areas due the Councils’ desire to focus growth to more readily sustainable locations. Whilst, as we have touched on above, Thakeham supports a weighted distribution of development towards the most sustainable locations and key employment hubs, we would emphasise the importance of a variety of growth locations and sizes to support housing growth. New settlements, strategic extensions and development in rural locations all form a key part in meeting varying housing needs and ensuring a consistent supply of housing delivery.
S/SH: Settlement hierarchy The settlement hierarchy seeks to group together similar settlements into categories that reflect their scale, characteristics and sustainability. It then seeks to limit development in any settlements which fall within the ‘Minor Rural Centre’ category and below.

Thakeham considers this view is overly prescriptive. The Settlement hierarchy identifies just 8 settlements which would have no limit on individual scheme size:

City: Cambridge
Town: Cambourne, Northstowe and Waterbeach New Town
Rural Centres: Bourn Airfield New Village, Histon & Impington, Great Shelford and Stapleford and Sawston

The Greater Cambridge Area covers a significant geographical area and this suggested policy approach limits development opportunities across the plan area. It is suggested that development at Minor Rural Centre’s should incorporate schemes of a maximum scheme size of 30 dwellings with lower tiers suggesting significantly less.

Policies should retain a flexible approach to ensure that promotion sites and applications can be assessed on a site by site basis on the
merits and positive contribution they could make to an existing and

future community. Development opportunities in these communities could have significant longer-term sustainability benefits by helping existing services remain, and where appropriate levels of growth are accommodated, new services could be provided as a result of development.

Climate change
Policy Your comments
Climate change - general comments Thakeham is supportive of the Councils’ objectives to enhance climate change resilience and transition Greater Cambridge to net zero carbon by 2050.

As a developer, Thakeham prides itself in the objectives it has set in respect of climate change and the impact development can have.
Thakeham has a key focus on sustainable practices both in construction and placemaking. Our approach sets us apart from our competitors. Thakeham’s schemes are delivered with a focus on sustainable development, looking ahead of current housing standards. From 2025, all Thakeham homes will be carbon neutral in production and zero carbon in lifetime use. Thakeham are a founding member of the HBF Future Homes Task Force, which examines
how the house building industry can work toward delivering net
zero carbon homes in order to support the Government’s target of the country delivering ne zero carbon emissions by 2050. Thakeham has a particular focus on first improving the fabric of buildings, constructed from sustainable timber sources, consideration of sustainable energy features and a sustainable procurement strategy which encourages the use of recycled materials. Thakeham intends to open a new MMC factory in the future, which will provide locally sourced MMC constructed homes further helping to reduce the environmental impact of construction.
CC/NZ: Net zero carbon new buildings Thakeham considers that the proposed policy direction is too prescriptive and does not provide sufficient flexibility for advances in technologies and Building Regulations. Policy wording should be less prescriptive on the measures used to achieve net zero carbon buildings, rather there should be sufficient flexibility to allow the methods for achieving such targets to be assessed on a site-by-site basis. This is critical as technology is advancing quickly and will
continue to do so during the lifetime of the emerging local plan and

consequently to set prescriptive policies will have the effect of the local plan being out of date before or at adoption.

As above, Thakeham prides itself in its own objectives for all its new homes to the zero-carbon in lifetime use and carbon neutral in production by 2025.

Biodiversity and green spaces
Policy Your comments
BG/BG: Biodiversity and geodiversity Thakeham is supportive of the policy direction of BG/BG and the Councils’ aspiration to require a minimum of 20% biodiversity net gain, whilst also acknowledging the difficulties this may bring for smaller sites with a suggested contribution mechanism to allow these sites to meet the requirements of the proposed policy. However, the current policy direction seeks to limit off-site habitat measures to align with the Greater Cambridge green infrastructure network strategic initiatives.
Whilst it is acknowledged that this may represent a preferred approach, this may cause issues in deliverability due to availability of such land. Policy BG/BG should incorporate sufficient flexibility to allow sites to achieve the required biodiversity net gain requirements by measures which are most appropriate to that site, if this requires off-site habitat creation there should be sufficient flexibility to allow consideration of all suitable options to ensure such requirements do not stifle development.

Thakeham itself has already made a commitment to achieve at least 20% biodiversity net gain as a result of our projects post- 2025.

Wellbeing and inclusion
Policy Your comments
Policy WS/HD: Creating healthy new developments Thakeham supports the objective and policy direction of Policy WS/HD, requiring health principles to be applied to new development, drawing on the ten principles developed from the Healthy New Towns Initiative.

In our view, relevant policies in respect of wellbeing and inclusion could go further to set out requirements on not only creating healthy new developments, but other measures which maximise wellbeing

benefits that developments can offer those who build them, those who live in them and the communities around them now and into the future.

Thakeham itself is passionate about having a positive impact on people’s wellbeing, constantly striving to deliver against our four key- focus areas:

• Building local communities via excellent placemaking that creates interconnected communities that challenge issues of loneliness and promoting healthy living, and via our long-term charity partnerships.
• Building future generations via our school
engagement programmes, including our industry leading holistic ecology programme ‘Eddie and Ellie’s Wild Adventures’ for primary age pupils, and providing inspiring careers support to secondary age pupils through our Cornerstone Employer status with The Careers Enterprise Company.
• Building a stronger Industry with our support of small and medium size enterprises and upskilling for local workers, supporting apprenticeships, and actively contributing to the diversification and upskilling of the construction sector.
• Building Sustainable places by tackling issues of climate change, biodiversity loss and societal disconnects via our ambitious Sustainability Strategy.
WS/IO: Creating inclusive employment and business opportunities through new
developments Thakeham is supportive of the policy direction of Policy WS/IO and as touched on above, adopts its own approach to creating inclusive employment and business opportunities through our support of small and medium size enterprises and upskilling for local workers, supporting apprenticeships, and actively contributing to the diversification and upskilling of the construction sector.

Homes policies
Policy Your comments
H/AH: Affordable housing Thakeham support the Councils’ policy direction in respect of Affordable Housing and the importance that such homes are built with inclusion, health and wellbeing at the forefront. Thakeham continues to provide policy compliant affordable housing across all of our developments whilst adopting a truly tenure blind approach to affordable housing which creates cohesive communities.

H/SS: Residential space standards and accessible homes Whilst Thakeham supports the Councils’ aspiration to see good quality homes delivered across their district, such policy requirement which seeks all dwellings to meet NDSS needs to be supported by robust evidence that there is a specific need to introduce such standards.

Any policy requirements in respect of housing accessibility requirements should be based off identified need, with sufficient flexibility incorporated to ensure that provision is directed to the right places. In particular, blanket policy requirements for M4(2) in all new developments should not be adopted as these requirements should be based off identified need, whilst requirements in relation to M4(3) can be particularly onerous and should only be directed to developments where there is an identified end user.
H/CB: Self- and custom-build homes Whilst Thakeham is supportive of self and custom build home provision in Greater Cambridge, it is not considered that a blanket policy as suggested by H/CB on developments of 20 or more is appropriate or feasible. Self and custom-build products should be directed towards key strategic allocations to ensure such homes are deliverable. Self and custom build home provision should also be based off identified need.

We trust that these representations are useful and clear, and we would be grateful for confirmation of receipt of our submission. In the meantime, please do not hesitate to contact me if you have any further queries or require any further information.

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.

Draft Policy H/AH of the First Proposals plan requires 40% affordable housing on sites of 10 or more dwellings. With a total of 45 dwellings,18 dwellings would be sought for affordable housing under this policy (as shown on the Indicative Site Plan). As well as helping to address the current shortage of affordable housing over the Greater Cambridge area, the delivery of up to 78 affordable dwellings would represent a considerable contribution to the social sustainability of the local area.

The provision of affordable housing should be a key priority for the new Local Plan. Affordability of housing across the Greater Cambridge area is a significant issue, with the Median Affordability ratios being 12.95 and 10.25 for Cambridge City and South Cambridgeshire district respectively.
It will be important that the affordable housing requirement set through the new Local Plan is tested through the Local Plan Viability Assessment and that it is set at a deliverable level, whilst also ensuring that the housing needs are met.
It may be necessary for the Local Plan to include varied affordable housing requirements based on site type and location. This will need to be considered further through the preparation of the Plan. Gladman support the provision of affordable housing through a balanced and robust spatial strategy.

As has been set out above, all of the ‘Group Villages’ as defined in the settlement hierarchy are limited to developments of up to 8 dwellings or 15 dwellings in exceptional circumstances, which means that the threshold for triggering the requirement for affordable housing in these localities will not typically arise as this is currently set at a threshold of 10 dwellings. Given that the 15 dwelling threshold is envisaged in relation to single brownfield sites within settlement boundaries the level of development realised under this part of the strategy is expected to be extremely limited and any such sites are highly likely to have already been considered and proposed for allocation.
This is significant given the requirements of Paragraph 64 of the Framework which states that “Provision of affordable housing should not be sought for residential developments that are not major developments, other than in designated rural areas (where policies may set out a lower threshold of 5 units or fewer).”
The Councils’ proposed approach also appears to ignore that it would encourage piecemeal and incremental development of potentially suitable development sites across multiple applications seeking to comply with the policy criteria in proposed Policy S/SB. This would be likely to result in potentially significant cumulative levels of development wherein individual applications have been determined as being below the thresholds for affordable housing provision.
Thus, the mechanism that has been created by the policy means that there will be no affordable dwellings being provided in rural areas particularly ‘Group Villages’ over the course of the plan period, subject to rural exception and exceptional schemes being brought forward outside of the Local Plan.
Given that the evidence base for the First Proposals consultation does not cite designated rural areas as reasons to apply the lower threshold the maximum number of dwellings that has been imposed on Group Villages should be lifted to allow for sites to be viewed on their individual merits and allow for the provision of affordable housing in all areas of the district. This also complies with Chapter 11 (Making effective use of land) of the Framework which supports the 8 dwelling limit being lifted to allow for the sites to make best use of available land rather than be limited.

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.
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.

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.
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.

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.

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.
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. Fulbourn).
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.

See attached comments.

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. For example, 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 705 affordable units for homeownership will be needed across South Cambridgeshire to satisfy housing demands. 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.

Whilst Taylor Wimpey are understanding of the requirements set out under this policy, comments are made in response to the point that ‘affordable homes must be designed to be indiscernible from market homes, and affordable homes should be distributed throughout the site in small groups or clusters, in accordance with the guidance provided in the Greater Cambridge Housing Strategy Annexe 10: Clustering and Distribution of Affordable Housing (Cambridge City Council and South Cambridgeshire District Council, June 2021) or a successor document.’
The document referenced sets out maximum cluster numbers in relation to the total number of units proposed. For example, developments of 30 to 200 units must have maximum clusters of 15 units. Concern is raised on this point. It is considered that flexibility should be allowed for clusters to exceed the 15 unit restriction where this has been agreed with the relevant Registered Provider. The clustering of affordable housing units is generally a practical requirement for Registered Providers for management and maintenance reasons. As such, the policy should allow a degree of flexibility here.

Greater Cambridge Local Plan – The First Proposals Consultation
Land east of Long Road, Comberton

Thakeham Homes Ltd (Thakeham) is writing in respect of the Greater Cambridge Local Plan – The First Proposals Consultation (1st November to 13th December 2021), specifically in relation to Land east of Long Road, Comberton located to the east of Comberton (‘The Site’)

Introduction Thakeham is pleased to be participating in this consultation and has outlined its position below in response to the Greater Cambridge Local Plan (GCLP) – The First Proposals Consultation.

Thakeham is promoting a site: Land east of Long Road, Comberton which is located on the eastern edge of Comberton. This site is available, within single ownership and is achievable and deliverable to contribute towards the development needs of Greater Cambridge in the first five years of the plan period.

An Evolution Document accompanies these representations, which further sets out Thakeham’s vision for the site, incorporating 400 new homes (inclusive of policy compliant affordable housing provision) alongside key community benefits including a new flexible co-working space, a new Multi Use Games Area and community allotments alongside play space and open space provision.

About Thakeham
Thakeham prides itself in being an infrastructure-led sustainable placemaker and is committed to creating new, extraordinary places, where the highest attention to detail makes a positive difference.

Thakeham build for the future, for communities and individuals. Our approach sets us apart from our competitors. We deliver our schemes with a focus on sustainable development, looking ahead of current housing standards. From 2025, all Thakeham Homes will be carbon neutral in production and zero carbon in lifetime use.

Each development is different and tailored to its locality with careful consideration of the area’s character, as well as the environment. As a sustainable placemaker first and foremost, Thakeham’s commitment to improving existing communities means its schemes are design and infrastructure-led; engaging with education, highways, healthcare, utilities and other local community, cultural and environmental stakeholders from the start of each project. The delivery of homes facilitates the delivery of physical, social and green/blue infrastructure which benefits the wider surrounding area, as well as the new residents, and ensures that Thakeham create sustainable places to live and work.

As one of 12 members of the NHS Healthy New Towns network, Thakeham is a committed advocate of developing healthy places in line with the Healthy New Town principles. But over time, we have realised that these principles are just the starting blocks, and at Thakeham, as a founder member of the HBF Future Homes Task Force, we are committed to delivering sustainable, zero carbon communities. Out approach sets us apart from our competitors. We deliver our schemes with a focus on infrastructure-led sustainable development.

Sustainability
There is an evident theme in Greater Cambridge in respect of environmental impact and the importance of ensuring any development, whether that be residential or infrastructure, seeks to minimise its impact. Thakeham would like to take this opportunity to outline the measures implemented on its developments to minimise environmental impacts as a direct and indirect result of development: • From 2025, all Thakeham homes will be net-zero carbon in lifetime use. • From 2025, all Thakeham homes will be carbon neutral in production. Our off-site panellised system will make construction more efficient, faster, enhancing quality and reducing construction traffic. • Thakeham is committed to offsetting the embodied impact from the production of new houses, as well as development houses that are zero carbon in lifetime operation. • Thakeham support the Wildlife Trust’s guidance on Homes for People and Wildlife. Our commitment is to at least 20% biodiversity net gain (double the government’s target within the recent Environment Act 2021) on all our developments post-2025 with attractive and functional green and blue infrastructure. • Through placemaking and the implementation of sustainable travel plans, Thakeham prioritises walking and cycling over car travel, helping people make more sustainable choices around walking, cycling and taking public transport, as well as highlighting innovative car-sharing online platforms such as LiftShare to reduce single-occupancy car use and facilitating use of autonomous vehicle/pods. • Thakeham provides electric car charging points at all of their homes both market and affordable alike, reducing barriers to customers purchasing emission-free vehicles. • Thakeham is keen to champion low carbon transport in the local area, encouraging local transport services such as buses to electrify their fleet. • Mechanical Ventilation with Heat Recovery (MVHR) is installed in our homes, which has a filter built-in to capture incoming pollution to provide fresh filtered air. • Thakeham works with its supply chain with an aim that all mechanical plant on site is less than 18 months old, which means it is less polluting and more fuel efficient.

Response to Options
Thakeham has reviewed the consultation documents and has chosen to comment on key questions and themes where relevant to our business to comment on.

Vision and development strategy
Vision and aims Thakeham supports the Council’s vision for new development to come forward with sustainability and healthy place shaping at the forefront. As we’ve touched on above, Thakeham supports the focus on healthy place shaping, with a need to ensure that future development maximises opportunities for journeys to be made on foot or bicycle. This will necessitate ensuring new developments prioritise non-motorised transport and easy access to full range of day-to-day services and facilities. Thakeham has made a number of commitments in respect of its own carbon impact, ensuring that all its development will be net zero carbon in lifetime use and carbon neutral in production by 2025. Additionally, Thakeham has made a commitment to achieve 20% biodiversity net gain on all projects post-2025 which is double that set out in the Environment Act 2021.

How much development, and where – general comments

Whilst Thakeham supports a weighted distribution of development towards the most sustainable locations and key employment hubs, we would emphasise the importance of a variety of growth locations and sizes to support housing growth. New settlements, strategic extensions and development in rural locations all form a key part in meeting varying housing needs and ensuring a consistent supply of housing delivery.

S/JH: New jobs and homes
Thakeham is supportive of the Councils’ conclusions that adopting the suggested ‘standard method minimum homes and related jobs’ approach would not be appropriate for Greater Cambridge and would not support its economic growth aspirations.

It is acknowledged that the Councils’ have sought to accommodate an uplift to accommodate their economic growth aspirations, suggesting that the ‘medium level of homes’ approach is justified, resulting in a need for 44,400 homes over the plan period 2020-2041 amounting the 2,111 homes per annum, alongside provision of 58,500 new jobs over the plan period.

Whilst the ‘maximum level of homes’ does not represent the Councils’ preferred approach; it is worth noting that this approach does acknowledge housing need arising out of fast job growth and therefore the Employment Land Review makes recommendations to provide more that the ‘medium’ scenario level of jobs to provide flexibility.

Thakeham is supportive of the Councils’ intention to accommodate their full objectively assessed needs for housing and jobs within the plan area. It is also acknowledged that a 10% buffer has also been added into their housing requirement to provide flexibility, amounting to a housing requirement of 48,840 over the plan period.

The Greater Cambridge Local Plan will need to ensure that it is planning for a sufficient number of new homes to support its economic growth aspirations. Whilst it is acknowledged that the medium option for new homes does incorporate an uplift for economic growth in the area, in addition to the application of a 10% buffer to reach the suggested housing requirement. Thakeham would suggest that the Councils undertake further work to ensure that the correct uplift has been applied to ensure that the Councils can meet their relevant aspirations in terms of job creation and growth, and as a result provide the right level of housing to support this. This is important to ensure that existing employers in the area can continue to thrive and expand retaining and attracting staff including graduates, in what is a global recruitment marketplace for many of the industries already located in Greater Cambridge. Further, in order to ensure Greater Cambridge continues to be a focus for inward investment into the UK, following on from the successes of the past, continued focus on supporting employment growth will be key and part of that will be providing housing to attract not just highly skilled staff but also for the variety of lower paid workers such as cleaners, delivery drivers and shop workers. These lower paid workers are necessary to support the wider community and economy such as in Greater Cambridge where land and house prices are high. These people are either driven out, much has been the case in London and has been seen in parts of Greater Cambridge to more affordable locations, but with the consequence of a longer commute, or greater affordable housing provision is required to accommodate them

S/DS: Development strategy

The first proposals consultation is suggesting a focus on existing commitments and expansion of existing sites to meet the suggested housing need. Where new sites are proposed these are focussed predominantly within and around the edge of Cambridge.

The background text to S/DS suggests that very limited development is proposed in rural areas due the Councils’ desire to focus growth to more readily sustainable locations. Whilst, as we have touched on above, Thakeham supports a weighted distribution of development towards the most sustainable locations and key employment hubs, we would emphasise the importance of a variety of growth locations and sizes to support housing growth. New settlements, strategic extensions and development in rural locations all form a key part in meeting varying housing needs and ensuring a consistent supply of housing delivery. In particular, growth in rural areas can contribute to improving and maintaining the vibrancy of these areas and is of great importance to ensuring these communities thrive. The important role that development in these rural areas can play should not be overlooked in the GCLP development strategy.

S/SH: Settlement hierarchy
The settlement hierarchy seeks to group together similar settlements into categories that reflect their scale, characteristics and sustainability. It then seeks to limit development in any settlements which fall within the ‘Minor Rural Centre’ category and below.

Thakeham considers this view is overly prescriptive. The Settlement hierarchy identifies just 8 settlements which would have no limit on individual scheme size:
City: Cambridge
Town: Cambourne, Northstowe and Waterbeach New Town
Rural Centres: Bourn Airfield New Village, Histon & Impington, Great Shelford and Stapleford and Sawston

The Greater Cambridge Area covers a significant geographical area and this suggested policy approach limits development opportunities across the plan area. It is suggested that development at Minor Rural Centre’s should incorporate schemes of a maximum scheme size of 30 dwellings with lower tiers suggesting significantly less.

Policies should retain a flexible approach to ensure that promotion sites and applications can be assessed on a site-by site basis on the merits and positive contribution they could make to an existing and future community. Development opportunities in these communities could have significant longer term sustainability benefits by helping existing services remain, and where appropriate levels of growth are accommodated, new services could be provided as a result of development.

Rest of the rural area
Rest of the rural area - general comments

As we have discussed above, Thakeham do not consider that the Greater Cambridge Local Plan goes far enough to support rural villages to allow them to thrive and grow in a sustainable way.

The supporting text and preferred options throughout this consultation suggest that growth has been directed away from rural areas to meet the plans climate objectives and encourage a modal transport shift from private car use. The importance of rural communities and ensuring they have the ability to grow appropriately to accommodate their needs and improve their services is paramount to ensuring these communities thrive alongside larger towns and cities. Importantly, appropriate growth at smaller settlements can help contribute to local services and facilities, including public transport provision and internalisation.

As discussed in these representations, Thakeham is promoting Land east of Long Road, Comberton as a sustainable extension to the village. Thakeham prides itself on being and infrastructure-led placemaker who seeks to ensure that social, physical, green and technological infrastructure is delivered as a result of its developments, in appropriate manner in relation to scale and siting of such sites. As part of its promotion at Land east of Long Road. Comberton Thakeham has sought to adopt a landscape a social infrastructure-led approach to its proposals. Alongside open space and play provision the proposals also include a co-working hub, community allotments and a Multi Use Games Area. Thakeham has proven track record for early infrastructure delivery, ensuring that existing and new communities’ benefit from the outset.

In addition, Thakeham has its own approach to sustainable movement starting with the principle of reducing the need for travel, which in part can be achieved by offering bespoke home offices for all of our houses. The focus is then on shifting the mode of travel by ensuring pedestrian and cycle movement is prioritised and links into the existing network where possible, encouraging private vehicles to be a tertiary mode of transport. Thakeham has also made a commitment to provide easily accessible cycle storage with charging for electric bikes and scooters and the provision of fast electric vehicle charging points for all houses.

Climate change
Climate change - general comments
Thakeham is supportive of the Councils’ objectives to enhance climate change resilience and transition Greater Cambridge to net zero carbon by 2050.

As a developer, Thakeham prides itself in the objectives it has set in respect of climate change and the impact development can have. Thakeham has a key focus on sustainable practices both in construction and placemaking. Our approach sets us apart from our competitors. Thakeham’s schemes are delivered with a focus on sustainable development, looking ahead of current housing standards. From 2025, all Thakeham homes will be carbon neutral in production and zero carbon in lifetime use. Thakeham are a founding member of the HBF Future Homes Task Force, which examines how the house building industry can work toward delivering net zero carbon homes in order to support the Government’s target of the country delivering ne zero carbon emissions by 2050. Thakeham has a particular focus on first improving the fabric of buildings, constructed from sustainable timber sources, consideration of sustainable energy features and a sustainable procurement strategy which encourages the use of recycled materials. Thakeham intends to open a new MMC factory in the future, which will provide locally sourced MMC constructed homes further helping to reduce the environmental impact of construction.

CC/NZ: Net zero carbon new buildings
Thakeham considers that the proposed policy direction is too prescriptive and does not provide sufficient flexibility for advances in technologies and Building Regulations. Policy wording should be less prescriptive on the measures used to achieve net zero carbon buildings, rather there should be sufficient flexibility to allow the methods for achieving such targets to be assessed on a site-by-site basis. This is critical as technology is advancing quickly and will continue to do so during the lifetime of the emerging local plan and consequently to set prescriptive policies will have the effect of the local plan being out of date before or at adoption.
As above, Thakeham prides itself in its own objectives for all its new homes to the zero-carbon in lifetime use and carbon neutral in production by 2025.

Biodiversity and green spaces
BG/BG: Biodiversity and geodiversity
Thakeham is supportive of the policy direction of BG/BG and the Councils’ aspiration to require a minimum of 20% biodiversity net gain, whilst also acknowledging the difficulties this may bring for smaller sites with a suggested contribution mechanism to allow these sites to meet the requirements of the proposed policy. However, the current policy direction seeks to limit off-site habitat measures to align with the Greater Cambridge green infrastructure network strategic initiatives. Whilst it is acknowledged that this may represent a preferred approach, this may cause issues in deliverability due to availability of such land.

Policy BG/BG should incorporate sufficient flexibility to allow sites to achieve the required biodiversity net gain requirements by measures which are most appropriate to that site, if this requires off-site habitat creation there should be sufficient flexibility to allow consideration of all suitable options to ensure such requirements do not stifle development. Thakeham itself has already made a commitment to achieve at least 20% biodiversity net gain as a result of our projects post 2025.

Wellbeing and Inclusion
Policy WS/HD: Creating healthy new developments
Thakeham supports the objective and policy direction of Policy WS/HD, requiring health principles to be applied to new development, drawing on the ten principles developed from the Healthy New Towns Initiative.

In our view, relevant policies in respect of wellbeing and inclusion could go further to set out requirements on not only creating healthy new developments, but other measures which maximise wellbeing benefits that developments can offer those who build them, those who live in them and the communities around them now and into the future.

As one of 12 members of the NHS Healthy New Towns, Thakeham supports such policy initiatives and itself is a committed advocate of developing healthy places in line with the Healthy New Town principles. But over time, we have realised that these principles are just starting blocks, and at Thakeham, as a founder member of the HBF Future Homes Task Force, we are committed to delivering sustainable zero carbon communities. Our approach sets us apart from our competitors, Thakeham is passionate about having a positive impact on people’s wellbeing, constantly striving to deliver against our four key focus areas:
-Building local communities via excellent placemaking that creates interconnected communities that challenge issues of loneliness and promoting healthy living, and via our long-term charity partnerships.
-Building future generations via our school engagement programmes, including our industry leading holistic ecology programme ‘Eddie and Ellie’s Wild Adventures’ for primary age pupils, and providing inspiring careers support to secondary age pupils through our Cornerstone Employer status with The Careers Enterprise Company.
-Building a stronger Industry with our support of small and medium size enterprises and upskilling for local workers, supporting apprenticeships, and actively contributing to the diversification and upskilling of the construction sector.
-Building Sustainable places by tackling issues of climate change, biodiversity loss and societal disconnects via our ambitious Sustainability Strategy.

WS/IO: Creating inclusive employment and business opportunities through new developments
Thakeham is supportive of the policy direction of Policy WS/IO and as touched on above, adopts its own approach to creating inclusive employment and business opportunities through our support of small and medium size enterprises and upskilling for local workers, supporting apprenticeships, and actively contributing to the diversification and upskilling of the construction sector.

Homes policies Policy
H/AH: Affordable housing
Thakeham support the Councils’ policy direction in respect of Affordable Housing and the importance that such homes are built with inclusion, health and wellbeing at the forefront. Thakeham continues to provide policy compliant affordable housing across all of our developments whilst adopting a truly tenure blind approach to affordable housing which creates cohesive communities.

H/SS: Residential space standards and accessible homes
Whilst Thakeham supports the Councils’ aspiration to see good quality homes delivered across their districts, such policy requirement which seeks all dwellings to meet NDSS needs to be supported by robust evidence that there is a specific need to introduce such standards. Any policy requirements in respect of housing accessibility requirements should be based on identified need, with sufficient flexibility incorporated to ensure that provision is directed to the right places. In particular, blanket policy requirements for M4(2) in all new developments should not be adopted as these requirements should be based on identified need, whilst requirements in relation to M4(3) can be particularly onerous and should only be directed to developments where there is an identified end user.

H/CB: Self- and custom build homes
Whilst Thakeham is supportive of self and custom build home provision in Greater Cambridge, it is not considered that a blanket policy as suggested by H/CB on developments of 20 or more is appropriate or feasible. Self and custom-build products should be directed towards key strategic allocations to ensure such homes are deliverable. Self and custom build home provision should also be based on an identified need.

Land east of Long Road, Comberton

The accompanying Evolution Document outlines the constraints and opportunities associated with Land east of Long Road, Comberton and provides a high-level illustrative masterplan and delivery strategy. The site can accommodate circa 400 dwellings alongside significant community benefits on an edge of settlement location, with close proximity to existing facilities and services, with main vehicular access from Long Road.

The landscape and social infrastructure-led scheme is planned around the provision of open space incorporating a number of community benefits including: play space, a Multi Use Games Area, community allotments and a new flexible co-working space.

On the edge of Comberton, the site is situated in a sustainable location with opportunities to access existing local services and amenities within the village. There is also access to public transport provision within close proximity of the site.

The site is within single ownership, within the control of Thakeham and on that basis Thakeham confirms that the site is available and deliverable within the first five years of the plan period.

We trust that these representations are useful and clear, and we would be grateful for confirmation of receipt of our submission. In the meantime, please do not hesitate to contact me if you have any further queries or require any further information.