H/ES: Exception sites for affordable housing

Exceptions sites should only be granted permission if they have the full support of local communities/Parish Councils. Concern about market housing being included within this policy. Custom/self build will also create scheme management and maintenance issues, due to unpredictability of length of build and that the properties will be 'built and sold on'- which negates the aspiration of this policy to create stable communities. Resale of self builds should be restricted for at least 5 years after completion.

This should be on suitable sites, and with the cooperation of the existing settlement.

The bar for permitting exception sites for affordable housing on Green Belt land needs to be set far higher. Whilst affordable homes are important, protection of the Green Belt is even more important, and once destroyed, can never be reclaimed. There is a good analogy here with climate change – stop damaging the Green Belt now before it is too late.

If it can “be demonstrated that non-Green-Belt alternative sites are not available” for affordable housing, then the test criteria for this “demonstration” are too weak. More sites outside the Green Belt can always be found. Simply forcing developers to actually stick to the 40% target for affordable housing within non-Green-Belt developments, rather than continually allowing them to not meet these targets on the grounds of “commercial viability” would solve the whole problem. The shareholders of major developers have no financial problems. These companies make large profits, and currently find it more profitable to engage lawyers to argue about how few affordable homes they can get away with building than to actually build them. Green Belt land should not be the victim in this failed process.

A policy for rural exception sites and First Homes exception sites is supported as this is a way of meeting affordable housing requirements. In order for these to be viable however some level of market housing should be allowed where it can be justified. This market housing should not be restricted to custom and self-build housing but open market housing should be allowed to ensure that a viable development can come forward. This policy should not restrict rural exception sites or First Home exception sites within the Green Belt as these locations are often ideally placed for this type of development particularly when located adjacent to settlements in the rural area.

A policy for rural exception sites and First Homes exception sites is supported as this is a way of meeting affordable housing requirements. In order for these to be viable however some level of market housing should be allowed where it can be justified. This market housing should not be restricted to custom and self-build housing but open market housing should be allowed to ensure that a viable development can come forward. This policy should not restrict rural exception sites or First Home exception sites within the Green Belt as these locations are often ideally placed for this type of development particularly when located adjacent to settlements in the rural area.

A policy for housing mix is required to ensure that an appropriate mix of housing sizes will be provided to address the identified need and create balanced and mixed communities. Objection is raised to the potential for a condition to be attached to end planning permissions to remove the permitted development rights for extensions that would harm the housing mix that the development was responding to. This approach is considered overly cautious and too restrictive.

Huntingdonshire District Council has no comment on this matter.

Policy H/ES supports exception sites in appropriate locations, typically adjoining existing settlements, and that are proportionate in scale to those settlements where there is an identified need. This approach is supported, but does need to be reflected in the wording of the policy and not create a reduced limit on the numbers allowed on sites adjoining Group Villages.

In support of such a policy approach is a proposed development on land south of Lanacre, Chrishall Road, Fowlmere. This site has previously been put forward through the Call for Sites (Site URN ref 450). The site area is 3.39 hectares and has capacity for 26 No. affordable houses, with 6 No. private dwellings to support the viability of the scheme.

An indicative masterplan layout is included with this submission showing a low density development that reflects a sensitive transition from the more urban village area out towards open countryside.

Fowlmere is identified as a Group Village, but has services and facilities including a primary school, village hall and store, church, and a number of businesses. It also has a bus service to the surrounding area and Cambridge. The village therefore has very good sustainability credentials which would support a Rural Exception scheme. It has also been demonstrated through a 2020 Housing Need Survey that the village requires the delivery of 38 affordable homes, which this scheme would go a significant way to meeting.

Taking into account the sustainability credentials of the scheme and village, this form of Rural Exception site at land south of Lanacre, Chrishall Road, Fowlmere should be supported by Policy H/ES.

Delivering new affordable housing is vital to support the prosperity local communities and economic growth. The GCLP’s ‘proposed policy direction’ on this matter confirms that a small amount of market housing will be allowed on Exception Sites where it can be justified on viability or deliverability grounds. This approach is supported by our client as providing a proportion of market housing plays an important role in enabling Exception Sites to come forward.

The future planning policy on this issue should acknowledge that all established settlements are capable of supporting Exceptions Sites as long as they are proportionate in scale. Our client’s sites at Weston Colville, Weston Green and West Wratting all have an active role to play in providing proportionate levels of market and affordable housing and delivering a legacy of the local community.

While I can see the possible need for exception sites to accommodate affordable housing in some places, it is essential that any such schemes should originate from and be directed by the local community, not a developer. They should only be allowed outside existing planning boundaries in very exceptional circumstances where there is a very strong and demonstrable need, and there are no sites available within the boundary.

There is demand in Bassingbourn-cum-Kneesworth for affordable housing. Significant development of market housing is not sustainable and therefore the need for affordable housing will need to be met on exception sites.

The issue of affordability is complex and can be significantly impacted by the location of homes (in terms of transportation costs) and the quality of the build. The concept of "appropriate locations" needs to explicitly consider access to the village infrastructure (walking and cycling) and frequent and efficient public transportation (to places of work and education). There is no point in building affordable homes in locations remote from good transportation options.

Against “small amount of market housing will be allowed on exception sites”

The policy of exception sites on the edges of villages is a good one. What mechanism would be applied to assigning the home if the identified need at the time of the site allocation is less than the need at the time the site built out? Would there be cascading out to nearby villages for those with local connections to those villages or will it be open to anyone in the district?

CambridgePPF support that first home exception sites will not be allowed in greenbelt.

When the detail of this policy is drafted, it should expressly deal with the opportunity to provide key worker housing on exception sites where they are suitably located to serve the needs of a specific group.

The First Proposals consultation suggests that First Homes will be excluded from consideration on Green Belt sites. It is essential that Key worker Housing is catered for in the future policy and, that it is permissible on Green Belt land in principle.

The policy for rural exception sites should ensure that First Homes exception sites do not replace traditional exception sites as the preferred type of delivery. Within the Greater Cambridge Housing Market the traditional form of exception site helps to meet local needs. Given the scarcity of rural exception sites further flexibility within the Green Belt should be allowed for traditional rural exception sites where there is a demonstrable local housing need.

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.

We want to propose, within the existing policy framework, the development of some rural exception sites to provide affordable housing. We would propose two routes for this:
1. Rural exception sites to be carved out of some of the larger sites put forward, providing a much more modest and acceptable scale development.
2. Put forward possible rural exception sites in locations not submitted in the wider call for sites. There may be smaller parts of existing agricultural sites that landowners had not considered for submission, but which may nonetheless, in the context of the rural exception policy, provide better located opportunities than some of the larger previously submitted sites. A particular local constraint is the 800 metre radius from the two village centres within which housing development should take place. This current constraint points us to potential small sites at the top of Mill Lane on either or both sides, where Chivers Farms and the County Council hold land.

FORM RESPONSE

Vision and development strategy
Section / Policy Your comments
Vision and aims
How much development, and where – general comments Support the approach to contain any development to major clusters.
S/JH: New jobs and homes
S/DS: Development strategy Support to the extent that development should be very restricted in smaller rural villages with limited public transport.
S/SH: Settlement hierarchy Support Steeple Morden is a group village and should remain in this category. It is well down the sustainability hierarchy.
S/SB: Settlement boundaries Support tightly drawn development boundaries are important to reduce encroachment into the countryside and particularly for linear villages protecting their character. Also assists in delivering exception sites.

Cambridge urban area
Policy Your comments
Cambridge urban area - general comments
S/NEC: North East Cambridge
S/AMC: Areas of Major Change
S/OA: Opportunity Areas in Cambridge
S/LAC: Land allocations in Cambridge

Edge of Cambridge
Policy Your comments
Edge of Cambridge - general comments
S/CE: Cambridge East
S/NWC: North West Cambridge
S/CBC: Cambridge Biomedical Campus
S/WC: West Cambridge
S/EOC: Other existing allocations on the edge of Cambridge

New settlements
Policy Your comments
New settlements - general comments
S/CB: Cambourne
S/NS: Existing new settlements

Rural southern cluster
Policy Your comments
Rural southern cluster - general comments
S/GC: Genome Campus, Hinxton
S/BRC: Babraham Research Campus
S/RSC: Village allocations in the rural southern cluster
S/SCP: Policy areas in the rural southern cluster

Rest of the rural area
Policy Your comments
Rest of the rural area - general comments
S/RRA: Allocations in the rest of the rural area
S/RRP: Policy areas in the rest of the rural area

Climate change
Policy Your comments
Climate change - general comments Future development and trends will increase the use of electricity so do we have an obligation to consider where we might generate this locally? There should be clear comments on how and where solar PV farms and windfarms are going to be planned
CC/NZ: Net zero carbon new buildings Should not be specific about not connecting a gas pipe to new housing. This might prevent the future distribution of Hydrogen. Should keep this option open
CC/WE: Water efficiency in new developments Absolutely necessary.
CC/DC: Designing for a changing climate
CC/FM: Flooding and integrated water management Infrastructure should be operational before housing occupation. Especially managing hard surface run off.
CC/RE: Renewable energy projects and infrastructure Support for community led projects but should include access to funding.
CC/CE: Reducing waste and supporting the circular economy
CC/CS: Supporting land based carbon sequestration

Biodiversity and green spaces
Policy Your comments
Biodiversity and green spaces - general comments
BG/BG: Biodiversity and geodiversity Biodiversity Net Gain conditions should include developer funds for monitoring and remedialaction if required.
BG/GI: Green infrastructure Support for recognition of Pollinator corridors. Strategic Green Infrastructure should include protection and enhancement of chalk aquifer spring line.
BG/TC: Improving Tree canopy cover and the tree population Support particularly providing enhanced protection to existing mature trees.
BG/RC: River corridors Support Steeple Morden has an important tributary of the Cam flowing through the Parish – The Rhee. There should also be recognition enhancement and protection for the brooks which emanate from the aquifer spring line and help feed the river system.
BG/PO: Protecting open spaces Support
BG/EO: Providing and enhancing open spaces Support

Wellbeing and inclusion
Policy Your comments
Wellbeing and inclusion - general comments
WS/HD: Creating healthy new developments
WS/CF: Community, sports, and leisure facilities Support
WS/MU: Meanwhile uses during long term redevelopments
WS/IO: Creating inclusive employment and business opportunities through new developments
WS/HS: Pollution, health and safety Support

Great places policies
Policy Your comments
Great places – general comments
GP/PP: People and place responsive design Support
GP/LC: Protection and enhancement of landscape character Support. Need to ensure protection of landscape setting of villages and penetration of countryside gaps as an important element of character particularly those villages with a predominantly linear form.
GP/GB: Protection and enhancement of the Cambridge Green Belt
GP/QD: Achieving high quality development Support
GP/QP: Establishing high quality landscape and public realm Support
GP/HA: Conservation and enhancement of heritage assets Support Need to complete Conservation Area Assessments for villages
GP/CC: Adapting heritage assets to climate change
GP/PH8: Protection of Public Houses Support but condition included that if part of Pub is agreed for another use the marketing policy remains.

Jobs policies
Policy Your comments
Jobs – general comments
J/NE: New employment development proposals
J/RE: Supporting the rural Economy Support
J/AL: Protecting the best agricultural land Strongly support particularly in the light of grade I peat soil requiring remedial action and the need for increased food security.
J/PB: Protecting existing business space
J/RW: Enabling remote working Support
J/AW: Affordable workspace and creative industries
J/EP: Supporting a range of facilities in employment parks
J/RC: Retail and centres
J/VA: Visitor accommodation, attractions and facilities
J/FD: Faculty development and specialist / language schools

Homes policies
Policy Your comments
Homes – general comments
H/AH: Affordable housing
H/ES: Exception sites for affordable housing Support but all types of sites should retain local connection and permanence criteria
H/HM: Housing mix
H/HD: Housing density
H/GL: Garden land and subdivision of existing plots Support
H/SS: Residential space standards and accessible homes
H/SH: Specialist housing and homes for older people
H/CB: Self- and custom-build homes
H/BR: Build to rent homes
H/MO: Houses in multiple occupation (HMOs)
H/SA: Student accommodation
H/DC: Dwellings in the countryside Support but would stress the importance of ensuring that structures are sound.
H/RM: Residential moorings
H/RC: Residential caravans
H/GT: Gypsy and Traveller and Travelling Show People sites
H/CH: Community led housing Support and encouraged where there is no conflict with exception site policy.

Infrastructure policies
Policy Your comments
Infrastructure – general comments Agree there should be support for community led projects but should describe what form the support should take.

Infrastructure should be operational before occupation of new housing particularly the need to manage surface water runoff from hard surfaces to minimise the amount of sewage being released into the waterways
I/ST: Sustainable transport and connectivity Support but Improvements required to rural public transport and the last mile congestion into Cambridge City.
I/EV: Parking and electric vehicles Support for rural public charging points at community facilities
I/FD: Freight and delivery consolidation
I/SI: Safeguarding important infrastructure Support. Should also include disused railway lines with potential for future use.
I/AD: Aviation development Airfields are an important resource and difficult to replace. Local Plan should recognise the need for National Network of General Airfields.Government National Planning Policy Framework section 106.f, to ensure that planning decisions have regard to the importance of the national network of General Aviation airfields is clear. Environmental health concerns should be taken into account when deciding on housing location to avoid new occupants stress, disappointment and possible conflict.
I/EI: Energy infrastructure masterplanning
I/ID: Infrastructure and delivery Greater Cambridge is in a severely water stressed area and is causing environmental damage. Development should be curtailed until new water supply and sewage infrastructure is operational.
I/DI: Digital infrastructure Need for enhancement of mobile phone coverage in villages with poor reception by well sited and suitably camouflaged masts.

Supporting documents on which we are consulting
Policy Your comments
Sustainability Appraisal (incorporating the requirements of the Strategic Environmental Assessment)
Habitats Regulations Assessment

Firstly, the Form To Assist gives a comment column for Vision and Aims.
We have numerous comments to make under this heading but I have not been able to locate this on the online system.
Secondly, the online system asks "Did you raise the matter that is the subject of your representation with the LPA earlier in the process?"
Guilden Morden Parish Council have not been involved earlier in the process. I have therefore clicked "No" but the system will not allow me to proceed further.
The online system allows only 100 words for each comment and to summarise the comments to avoid exceeding 100 words. It would have been helpful if the Form To Assist had stated that.
Vision and development strategy
Section / Policy Your comments
Vision and aims 1.Guilden MordenParish Council has concerns that the increase in population resulting from the additional homes target of 44,000 will have a negative impact on an already struggling traffic, school and healthcare infrastructure.
Specifically on traffic and congestion:
Commuting into and out of Cambridge at peak times already attracts significant congestion and delay for commuters.
This not only effects commuting by car but also bus and the Park&Ride buses as these typically use the same roads as the other commuters and the bus lane network doesn’t extend to where it’s needed.
Links between the train stations and the city centre are also currently inadequate and equally effected by commuter congestion.
The guided busway is too infrequent to be a viable alternative and typically the Park& Ride parking is at capacity leaving commuters with little alternative other than to drive into the city centre.
All of the above describes the current situation which will clearly be significantly worsened by the addition of 44,000 homes by 2041.
2. Is the methodology used in arriving at the figure of 44,000 defendable?

How much development, and where – general comments Support that the proposed developments are to be in major clusters in areas with good public transport.
S/JH: New jobs and homes
S/DS: Development strategy Support to the extent that development should be very restricted in smaller rural villages with limited public transport.
S/SH: Settlement hierarchy Support. Guilden Morden is a group village and should remain in this category. It is well down the sustainability hierarchy.
S/SB: Settlement boundaries Support. Tightly drawn development boundaries are important to reduce encroachment into the countryside.

Cambridge urban area
Policy Your comments
Cambridge urban area - general comments
S/NEC: North East Cambridge
S/AMC: Areas of Major Change
S/OA: Opportunity Areas in Cambridge
S/LAC: Land allocations in Cambridge

Edge of Cambridge
Policy Your comments
Edge of Cambridge - general comments
S/CE: Cambridge East
S/NWC: North West Cambridge
S/CBC: Cambridge Biomedical Campus
S/WC: West Cambridge
S/EOC: Other existing allocations on the edge of Cambridge

New settlements
Policy Your comments
New settlements - general comments
S/CB: Cambourne
S/NS: Existing new settlements

Rural southern cluster
Policy Your comments
Rural southern cluster - general comments
S/GC: Genome Campus, Hinxton
S/BRC: Babraham Research Campus
S/RSC: Village allocations in the rural southern cluster
S/SCP: Policy areas in the rural southern cluster

Rest of the rural area
Policy Your comments
Rest of the rural area - general comments
S/RRA: Allocations in the rest of the rural area
S/RRP: Policy areas in the rest of the rural area

Climate change
Policy Your comments
Climate change - general comments Future development and trends will increase the use of electricity. Where might this be generated locally by solar and/or wind?
CC/NZ: Net zero carbon new buildings Support
CC/WE: Water efficiency in new developments Absolutely necessary
CC/DC: Designing for a changing climate
CC/FM: Flooding and integrated water management Infrastructure should be operational before housing occupation
CC/RE: Renewable energy projects and infrastructure Support for community led projects but should include access to funding
CC/CE: Reducing waste and supporting the circular economy
CC/CS: Supporting land based carbon sequestration

Biodiversity and green spaces
Policy Your comments
Biodiversity and green spaces - general comments
BG/BG: Biodiversity and geodiversity Biodiversity Net Gain conditions should include developer funds for monitoring and remedial action if required
BG/GI: Green infrastructure Support for recognition of pollinator corridors. Strategic Green Infrastructure should include protection and enhancement of chalk aquifer spring line.
BG/TC: Improving Tree canopy cover and the tree population Support
BG/RC: River corridors Support
BG/PO: Protecting open spaces Support
BG/EO: Providing and enhancing open spaces Support

Wellbeing and inclusion
Policy Your comments
Wellbeing and inclusion - general comments
WS/HD: Creating healthy new developments
WS/CF: Community, sports, and leisure facilities Support
WS/MU: Meanwhile uses during long term redevelopments
WS/IO: Creating inclusive employment and business opportunities through new developments
WS/HS: Pollution, health and safety

Great places policies
Policy Your comments
Great places – general comments
GP/PP: People and place responsive design Support
GP/LC: Protection and enhancement of landscape character Support. Need to ensure protection of landscape setting of villages and penetration of countryside gaps as an important element of character.
GP/GB: Protection and enhancement of the Cambridge Green Belt
GP/QD: Achieving high quality development Support
GP/QP: Establishing high quality landscape and public realm Support
GP/HA: Conservation and enhancement of heritage assets Support
GP/CC: Adapting heritage assets to climate change
GP/PH8: Protection of Public Houses Support

Jobs policies
Policy Your comments
Jobs – general comments
J/NE: New employment development proposals
J/RE: Supporting the rural Economy Support
J/AL: Protecting the best agricultural land Support
J/PB: Protecting existing business space
J/RW: Enabling remote working Support
J/AW: Affordable workspace and creative industries
J/EP: Supporting a range of facilities in employment parks
J/RC: Retail and centres
J/VA: Visitor accommodation, attractions and facilities
J/FD: Faculty development and specialist / language schools

Homes policies
Policy Your comments
Homes – general comments
H/AH: Affordable housing
H/ES: Exception sites for affordable housing Support but all types of sites should retain local connection and permanence criteria
H/HM: Housing mix
H/HD: Housing density
H/GL: Garden land and subdivision of existing plots Support
H/SS: Residential space standards and accessible homes
H/SH: Specialist housing and homes for older people
H/CB: Self- and custom-build homes
H/BR: Build to rent homes
H/MO: Houses in multiple occupation (HMOs)
H/SA: Student accommodation
H/DC: Dwellings in the countryside Support
H/RM: Residential moorings
H/RC: Residential caravans
H/GT: Gypsy and Traveller and Travelling Show People sites
H/CH: Community led housing Support

Infrastructure policies
Policy Your comments
Infrastructure – general comments Agree there should be support for community led projects but should describe what form the support should take.
Infrastructure should be operational before occupation of new housing particularly the need to manage surface water runoff fromhard surfacesto minimise the amount of sewage being released into the waterways
I/ST: Sustainable transport and connectivity Support but improvements required rural public transport and congestion into Cambridge (see comments under Vision and Aims)
I/EV: Parking and electric vehicles Support
I/FD: Freight and delivery consolidation
I/SI: Safeguarding important infrastructure Support
I/AD: Aviation development Support
I/EI: Energy infrastructure master planning
I/ID: Infrastructure and delivery Greater Cambridge is in a severely water stressed area and is causing environmental damage. Development should be curtailed until new water supply and sewage infrastructure is operational.
I/DI: Digital infrastructure Need for enhancement of mobile phone coverage in villages with poor reception by well sited and suitably camouflaged masts.

See attached comments.

We broadly support this policy direction, as long as a) exception sites are only created in response to objectively assessed local need, and b) the clause “Rural exception sites will be allowed in the Green Belt only when it can be demonstrated that non Green-Belt alternative sites are not available” is rigorously enforced. We are concerned by the statement that “A small amount of market housing will be allowed on exception sites where it can be justified on viability or deliverability grounds”: there will need to be very clear and well-enforced rules about when this is allowable, with a quantified definition of “a small amount”, to avoid Exception Sites policy becoming a loophole for building on sites where development would not otherwise be permitted.
We are very pleased to see mention of “community led housing initiatives such as community land trusts,
co-housing and co-operatives” and would like to see these types of housing given greater policy emphasis.
We agree that rural exception sites must not be ‘squeezed out’ by First Home sites and support policies
intended to prevent this.