Policy 13b: Affordable housing

Object

Representation ID: 52006

Received: 12/08/2020

Respondent: Miss Fiona Hynd

So affordable to rent, but not affordable to buy????!!!!

Comment

Representation ID: 54514

Received: 05/10/2020

Respondent: Cambridge Cycling Campaign

Affordable housing should have the same or better cycle parking provision as other residential units on the site including facilities for large and adapted cycles and for storing cycle accessories such as child seats and trailers.

Support

Representation ID: 55649

Received: 05/10/2020

Respondent: Cambridgeshire & Peterborough Sustainability & Transformation Partnership

Agent: No. 6 Developments

The acknowledgement that in order to be genuinely affordable the provision of affordable housing
must be informed by the context of local rent levels, house prices and local incomes is welcomed.
The average house price in Cambridge is 13 to 14 times that of the average annual household
income, meaning that housing in Cambridge is unaffordable for the majority of workers,
especially those on lower to middle incomes and as such genuinely affordable housing linked to
incomes rather than market values should be encouraged.
In line with our published housing needs evidence (shared with the Council as part of our
response to the Issues & Options consultation, CUH wishes to encourage the Council to consider
housing tenure types suitable to meet the needs of Hospital and other NHS workers within the
development.

Support

Representation ID: 55683

Received: 02/10/2020

Respondent: St John's College

Agent: Savills

The expectation in Policy 13d that developments including affordable private rent as part of their affordable housing allocation demonstrate how these homes will be targeted to meet local worker need is welcomed.

Comment

Representation ID: 55738

Received: 05/10/2020

Respondent: Brookgate

Agent: Bidwells

Neutral:
Policy 13b states that the AAP requires 40% of new homes to be delivered as
affordable housing.
Subject to viability testing, the 40% requirement is supported in terms of being
applied to the NEC AAP as a whole. The very heavy infrastructure costs and
brownfield nature of the land with associated remediation costs must however be
recognised and viability is of key importance.
The Policy also recognises that Build to Rent Schemes deliver fewer than 40%
affordable homes, and that this shortfall needs to be made up for by other schemes
coming forward in North East Cambridge. This fundamentally misunderstands the
contribution BTR makes to housing supply in Cambridge and the LPA must take a
more nuanced approach to housing tenures.

Support

Representation ID: 55770

Received: 05/10/2020

Respondent: Rentplus UK Ltd

Agent: Tetlow King Planning

Rentplus welcomes the commitment by the Greater Cambridge councils to prepare an Area Action Plan
for North East Cambridge. This prominent site presents an important opportunity to provide a
significant amount of new housing to meet the urgent needs of Cambridge and its immediate
surroundings.

Housing affordability is a serious concern in Cambridge and South Cambridgeshire. In 2019, the ONS
reported that lower quartile house prices equated to 13.51 times lower quartile earnings in
Cambridge; and an equivalent figure of
10.77 times for South Cambridgeshire. Any household on a low or middle income in the City or South
Cambridgeshire faces a serious challenge in affording a home without access to either substantial
savings or inherited wealth. The high cost of housing makes saving for any kind of deposit – even
that for a shared ownership home – very difficult for many households including those of key
workers. The implications this has for the sustainable development of Greater Cambridge are well
documented, with many households forced to look for housing further afield in
neighbouring authorities, resulting in high levels of out-commuting. The long-standing
Sustainable Development Sequence in Cambridge and South Cambridgeshire has sought to direct
development to Cambridge and the edges of Cambridge in the first instance. In this context, it is
important that housing in and around Cambridge is affordable to as many people as possible. This
will ensure that people of all incomes in Greater Cambridge are able to live close to their place
of work and moreover, access the security and long-term stake in their community that homeownership
provides.

Policy 13B ‘Affordable Housing’ sets a requirement to deliver 40% affordable housing, of which 60%
is expected to be for affordable housing for rent, and the remaining 40% for ‘intermediate’
tenures. The supporting text rightly identifies rent to buy as an affordable route to home
ownership. The 2020 Housing Topic Paper explains that the 60:40 split between tenures delivers more
affordable home ownership dwellings than either the adopted Cambridge Local Plan or South
Cambridgeshire Local Plan. It also notes that this “could help to provide a wider range of housing
options beyond the more traditional shared ownership model, and also support local businesses by
improving provision of housing which is accessible to a wider range of local workers.” The Housing
Topic Paper also specifically identifies rent to buy as one of the affordable ownership models.

Rentplus therefore supports policy 13B as drafted, although would welcome recognition of the role
of affordable routes
to home ownership within the policy itself. Similarly, the policy would benefit from
additional flexibility, given the
Neutral

complex nature of the site, to vary the tenure mix to suit site circumstances and viability. We
therefore recommend that the second paragraph of policy 13b is amended as below (additions in bold,
deletions in strikethrough):



It is expected that a minimum of 60% of the affordable homes will be social/affordable rent (i.e.
housing currently set at Social and/or Affordable Rents) to provide a balanced mix appropriate to
the development but still prioritising this tenure. The remaining affordable homes will be for
affordable routes to home ownership, such as rent to buy,
shared ownership, discounted market sale and other affordable routes to home ownership.

Object

Representation ID: 56020

Received: 05/10/2020

Respondent: Endurance Estates

Agent: Barton Willmore

Draft Policy 13b requires 40% of new homes to be delivered as affordable housing, comprising a minimum of 60% social/affordable rent and 40% intermediate housing products. This reduces the level of social/affordable rent from the existing 75/25 split required in Cambridge City Council and 70/30 split in South Cambridgeshire Council. This is reasoned on the basis that this could help to provide a wider range of housing options beyond the more traditional shared ownership model, and also support local businesses by improving provision of housing which is accessible to a wider range of local workers.

The National Planning Policy Framework says that plans should set out the contributions expected from development. This should include setting out the levels and types of affordable housing provision required, along with other infrastructure (such as that needed for education, health, transport, flood and water management, green and digital infrastructure). Such policies should not undermine the deliverability of the plan. Policy requirements for developer contributions should be informed by proportionate evidence of infrastructure and affordable housing need and be assessed for viability at the plan-making stage in accordance with guidance.

We note that there is a lack of any viability evidence in the NECAAP supporting documents and evidence base. This is a concern for several reasons.

The majority of the housing allocation is proposed to the northern half of the NEC site where the current WwTW lies and where there will be significant costs in terms of remediating the land. In addition, there will be costs associated with land assembly and the use of Compulsory Purchase Order or compensatory agreements for existing businesses that will be relocated off the site. It is unclear to what extent these issues have been accounted for in setting out the viability of the plan and the level of affordable housing requirement.

This is a critical issue not only for meeting local affordable housing needs but also ensuring policy compliant affordable housing levels can be delivered on site rather than being displaced elsewhere. The total quantity of affordable housing would amount to 3,200 homes, which represents a significant proportion of the area’s affordable housing need. It would not be possible to absorb such a high level of affordable housing through windfall or rural exception sites once the AAP is adopted and therefore understanding the viability of implementing the plan is critical at this stage of policy drafting.

Our concerns regarding the lack of financial viability evidence extend to Policy 13c and the proposal for a maximum of 10% Build to Rent (800 units) across all housing within the AAP, comprising a minimum of 20% affordable private rent units. Built to Rent is a relatively untested product within Cambridge and would likely achieve lower land sale values compared to normal market products in this area. We would question whether this has been considered in the financial viability review work that supports the AAP. Also, how applicable is the research on Built to Rent to the Cambridge market? The AAP’s Housing Topic paper references evidence to Build to Rent demand within a document titled ‘Private Rented Sector (Build to Rent) research – national and emerging local’ but this does not appear to be published on the NECAAP consultation page. We therefore do not know the assumptions on likely take-up of Build to Rent at NEC and the impacts on the financial viability of implementing the plan, along with delivery of affordable housing delivery.