Greater Cambridge Local Plan Preferred Options

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Comment

Greater Cambridge Local Plan Preferred Options

H/AH: Affordable housing

Representation ID: 59494

Received: 11/12/2021

Respondent: Pocket Living

Agent: Quod

Representation Summary:

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’.

Full text:

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).

Comment

Greater Cambridge Local Plan Preferred Options

H/AH: Affordable housing

Representation ID: 59496

Received: 11/12/2021

Respondent: Pocket Living

Agent: Quod

Representation Summary:

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. 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.

Full text:

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.

Comment

Greater Cambridge Local Plan Preferred Options

H/AH: Affordable housing

Representation ID: 59497

Received: 11/12/2021

Respondent: Pocket Living

Agent: Quod

Representation Summary:

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. 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.

Full text:

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.

Comment

Greater Cambridge Local Plan Preferred Options

H/AH: Affordable housing

Representation ID: 59499

Received: 11/12/2021

Respondent: Pocket Living

Agent: Quod

Representation Summary:

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.

Full text:

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.

Comment

Greater Cambridge Local Plan Preferred Options

H/HM: Housing mix

Representation ID: 59502

Received: 11/12/2021

Respondent: Pocket Living

Agent: Quod

Representation Summary:

The proposed flexibility for consideration to be given to site specific circumstances when determining an appropriate unit size mix is strongly supported. This policy should however include specific reference to ‘the nature and location of the site and the type of housing proposed’.
It is not always possible and/or appropriate to provide a specific defined mix of unit sizes. For example, some locations are better suited to smaller households than large families (e.g Town Centres). The addition of this policy reference is therefore critical for ensuring the right homes are built in the right locations and the efficient use of brownfield land for housing delivery. The exact type of housing product proposed may also be more or less suited to particular unit sizes (e.g rents vs sale). Finally, the delivery of smaller unit sizes can indirectly free up highly suitable family homes presently used as HMO’s or informal house shares.

Full text:

The proposed flexibility for consideration to be given to site specific circumstances when determining an appropriate unit size mix is strongly supported. This policy should however include specific reference to ‘the nature and location of the site and the type of housing proposed’.
It is not always possible and/or appropriate to provide a specific defined mix of unit sizes. For example, some locations are better suited to smaller households than large families (e.g Town Centres). Moreover, smaller brownfield sites in urban locations tend to have a range of constraints beyond planning requirements which make it difficult to offer a range of sizes. For example, Pocket’s scheme at Newmarket Road in Cambridge City Centre could not come forward for re-development if it were required to provide a range of unit sizes due to its highly constrained nature. The addition of this policy reference is therefore critical for ensuring the right homes are built in the right locations and the efficient use of brownfield land for housing delivery. The exact type of housing product proposed may also be more or less suited to particular unit sizes (e.g rents vs sale). Finally, the delivery of smaller unit sizes can indirectly free up highly suitable family homes (with front doors and gardens) presently used as HMO’s or informal house shares. The delivery of housing for single persons therefore provides an important opportunity to create family homes.

Comment

Greater Cambridge Local Plan Preferred Options

H/HM: Housing mix

Representation ID: 59504

Received: 11/12/2021

Respondent: Pocket Living

Agent: Quod

Representation Summary:

This policy should include flexibility on unit mix where the large majority (75%+) of housing is proposed as affordable housing.
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 schemes to provide prescribed unit mix may make them less viable/ attractive for Registered Providers and SME developers of affordable housing such as Pocket. The Council’s evidence base illustrates there is significant un-met need for all unit sizes in Greater Cambridge. Allowing some schemes greater flexibility to focus on a particular unit sizes in order to encourage their delivery would therefore make an important contribution to meeting local needs. Attempting to require every scheme to meet every type of housing need is likely to result in a reduction in housing delivery and fewer needs being met.

Full text:

This policy should include flexibility on unit mix where the large majority (75%+) of housing is proposed as affordable housing.
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 schemes to provide prescribed unit mix may make them less viable/ attractive for Registered Providers and SME developers of affordable housing 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). The Council’s evidence base illustrates there is significant un-met need for all unit sizes in Greater Cambridge. Allowing some schemes greater flexibility to focus on a particular unit sizes in order to encourage their delivery would therefore make an important contribution to meeting local needs. Attempting to require every scheme to meet every type of housing need (regardless of the nature of the site, proposal or developer) is likely to result in a reduction in housing delivery and fewer needs being met.

Comment

Greater Cambridge Local Plan Preferred Options

H/HM: Housing mix

Representation ID: 59506

Received: 11/12/2021

Respondent: Pocket Living

Agent: Quod

Representation Summary:

This policy should include specific reference to the need to ‘provide affordable ownership housing for young single person households’.
The growing needs of young single person households is recognised by the Council’s housing evidence base which notes Cambridge has one of the ‘youngest’ populations in the country with people aged 24 and under making up around 37% of the City’s population (page 12). This cohort typically comprises young single person households who have been forced to live in low quality overcrowded or otherwise unsuitable shared rental housing or leave the area. These households are largely aspiring first time buyers who cannot afford to buy locally within a reasonable commuting distance. The number of single person or other households without children in Cambridge City Centres also projected to increase significantly (+8%) by 2043 whilst the number of households with children decreases (-17%) (ONS 2021).

Full text:

This policy should include specific reference to the need to ‘provide affordable ownership housing for young single person households’.
The growing needs of young single person households is recognised by the Council’s housing evidence base which notes Cambridge has one of the ‘youngest’ populations in the country with people aged 24 and under making up around 37% of the City’s population (page 12). This cohort typically comprises young single person households who have been forced to live in low quality overcrowded or otherwise unsuitable shared rental housing or leave the area. These households are largely aspiring first time buyers who cannot afford to buy locally within a reasonable commuting distance (Cambridge City Centre now has one of the longest average commute times of all UK cities). The number of single person or other households without children in Cambridge City Centres also projected to increase significantly (+8%) by 2043 whilst the number of households with children decreases (-17%) (ONS 2021).

Comment

Greater Cambridge Local Plan Preferred Options

H/HD: Housing density

Representation ID: 59508

Received: 11/12/2021

Respondent: Pocket Living

Agent: Quod

Representation Summary:

The policy objective to deliver higher densities on sites with good accessibility is strongly supported. This policy should however specifically reference the need to deliver smaller unit sizes, such as 1 bedroom 1 person homes, in these locations.
Sites located in Town Centes and/ or close to transport interchanges are highly suited to increased densities of housing and people. They are typically however less suited to families. The delivery of smaller unit sizes, such as 1 bedroom 1 person homes, will therefore be important for maximising housing density on these sites.

Full text:

The policy objective to deliver higher densities on sites with good accessibility is strongly supported. This policy should however specifically reference the need to deliver smaller unit sizes, such as 1 bedroom 1 person homes, in these locations.
Sites located in Town Centes and/ or close to transport interchanges are highly suited to increased densities of housing and people. They are typically however less suited to families. The delivery of smaller unit sizes, such as 1 bedroom 1 person homes, will therefore be important for maximising housing density on these sites.

Comment

Greater Cambridge Local Plan Preferred Options

H/HD: Housing density

Representation ID: 59510

Received: 11/12/2021

Respondent: Pocket Living

Agent: Quod

Representation Summary:

The proposed design led approach for making best use of land is strongly supported. This policy should however specifically recognise that smaller more constrained sites are likely to better suited to smaller unit types (i.e those designed for individuals instead of large families).
Constrained sites tend to have fewer opportunities for providing private amenity space and play space. They are therefore better suited to higher densities of smaller unit sizes. Encouraging roof gardens and other innovative uses of community space should be sought in these of locations.

Full text:

The proposed design led approach for making best use of land is strongly supported. This policy should however specifically recognise that smaller more constrained sites are likely to better suited to smaller unit types (i.e those designed for individuals instead of large families).
Constrained sites tend to have fewer opportunities for providing private amenity space and play space. They are therefore better suited to higher densities of smaller unit sizes. Encouraging roof gardens and other innovative uses of community space should be sought in these of locations.

Comment

Greater Cambridge Local Plan Preferred Options

H/SS: Residential space standards and accessible homes

Representation ID: 59512

Received: 11/12/2021

Respondent: Pocket Living

Agent: Quod

Representation Summary:

The policy objective for all homes to meet national internal space standards is strongly supported. The policy should recognise it is not always possible for every home to have direct access to a balcony or other private amenity space. It should also recognise that it is also not always necessary.
Delivering housing for smaller households (i.e single person households) who are in housing need but far less reliant on amenity space and lift access than couples and families will ensure that constrained sites can be unlocked thus making the best and most efficient use of available brownfield housing land. Attempting to require schemes on constrained sites to meet the same standards expected in less constrained sites is likely to result in a significant reduction in housing delivery and the needs of fewer households being met overall.

Full text:

The policy objective for all homes to meet national internal space standards is strongly supported. The policy should recognise it is not always possible for every home to have direct access to a balcony or other private amenity space where the site is constrained. It should also recognise that it is also not always necessary (e.g where the homes are designed for individuals instead of families).
Housing delivered on constrained sites may not be able to accommodate balconies and/or other private amenity space. It may also be extremely challenging to provide lift access and/or any dual aspect homes without rending schemes unviable (noting these types of previously developed site typically have significant viability challenges which require a critical mass of development). Delivery of housing on these sites should not however be discouraged. Delivering housing for smaller households (i.e single person households) who are in housing need but far less reliant on amenity space and lift access than couples and families will ensure these sites can be unlocked thus making the best and most efficient use of available brownfield housing land. It is for this reason 1 bed 1 person homes are not nationally required to provide balconies. Attempting to require schemes on constrained sites to meet the same standards expected in less constrained sites is likely to result in a significant reduction in housing delivery and the needs of fewer households being met overall.

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