Greater Cambridge Local Plan Preferred Options

Search representations

Results for Home Builders Federation search

New search New search

Comment

Greater Cambridge Local Plan Preferred Options

CC/DC: Designing for a changing climate

Representation ID: 60166

Received: 10/12/2021

Respondent: Home Builders Federation

Representation Summary:

Firstly, the Councils’ viability assessment consider this policy to be deliverable at no extra cost. However, there could be additional costs associated with this policy and it will be necessary that these extra costs are factored into the viability assessment to ensure they are fully considered.

Secondly, whilst the HBF accept that new homes must be designed to take account of the impacts of climate change we do not agree with the Councils’ assertion that they should designed using the Good Homes Alliance Overheating in New Homes Tool and Guidance. As such we would suggest that any references to such toolkits are made outside of policy.

Comment

Greater Cambridge Local Plan Preferred Options

CC/WE: Water efficiency in new developments

Representation ID: 60167

Received: 10/12/2021

Respondent: Home Builders Federation

Representation Summary:

The Council recognise that this policy requirement is significantly lower than the minimum allowable technical standard for water efficiency as set out in PPG. The reason for placing an 80 litres per person per day is due to the unsustainable levels of abstraction from the chalk aquifer used to supply the Greater Cambridge area. However, the Council have noted that the position with regard to future supply and the necessary infrastructure to meet demands is still uncertain and that more detail will be known on publication of the net Water Resource Management Plan in 2022. Clearly should the necessary infrastructure be provided to address the demands in this area then the Council will need to review the necessity of the 80 litre per person per day requirement.

Comment

Greater Cambridge Local Plan Preferred Options

CC/NZ: Net zero carbon new buildings

Representation ID: 60168

Received: 10/12/2021

Respondent: Home Builders Federation

Representation Summary:

Recognise the need to move towards greater energy efficiency but this should be done via a nationally consistent set of standards and timetable e.g. Future Homes Standard. Support the Government’s approach in allowing for a transition to the Future Homes Standard.

A policy proposing its own standards is not consistent with national policy. The Councils should comply with the Government’s intention of setting standards for energy efficiency through Building Regulations.

Part C - in some cases it may not be possible to meet the required standard, and this should be recognised in the policy. The policy also makes no allowance for the decarbonisation of the national grid. Such improvements will need to be taken into account within any assessment of energy use and the level of onsite renewable energy that is required to be generated.

Part D - development should deliver the energy efficiency improvement required by building regulations and where feasible and viable meet some its energy demand through onsite renewable energy generation. Further offsetting should not be required.

The most effective mechanism for ensuring a building is built to the required standard is through building regulations.

Comment

Greater Cambridge Local Plan Preferred Options

S/SB: Settlement boundaries

Representation ID: 60169

Received: 10/12/2021

Respondent: Home Builders Federation

Representation Summary:

Whilst the Council reference rural exceptions sties in this policy no mention is made to First Home exception sites. Given that First Home exception sites are referred to in policy HE/S the Councils must ensure that policy S/SB refers to both rural exception sites and first homes exception sites in order to maintain consistency between these two policies.

Comment

Greater Cambridge Local Plan Preferred Options

S/SH: Settlement hierarchy

Representation ID: 60170

Received: 10/12/2021

Respondent: Home Builders Federation

Representation Summary:

Do not agree with the proposed policy that will limit the size of schemes within minor rural centres, group villages and infill villages. To set an indicative maximum scheme size fails to recognise the full potential of a site in such locations nor the potential benefits of such schemes in ensuring existing services remains sustainable into the long term. Rather than place an arbitrary limit on the size of development in these communities we would suggest a more appropriate approach would be to reflect paragraph 124 and 125 of the NPPF to make the most effective use of land whilst taking into account housing needs, market conditions, infrastructure and serves as well as the character of the area. Such an approach would provide the necessary flexibility to maximise delivery whilst also taking into account wider considerations regarding the wider sustainability of such sites.

Comment

Greater Cambridge Local Plan Preferred Options

S/DS: Development strategy

Representation ID: 60171

Received: 10/12/2021

Respondent: Home Builders Federation

Representation Summary:

Water Supply
The Councils’ Integrated Water Management Plan indicates that current levels of abstraction from the chalk aquifer used to supply the Greater Cambridge area are unsustainable. Water companies have a statutory duty to develop and maintain an efficient and economical system of water supply in their areas and the Councils and relevant water companies need to ensure that the necessary resources and infrastructure are in place to secure the necessary supply required to meet the demands of not only Greater Cambridge, but all those areas affected.

If the necessary infrastructure is not in place a stepped requirement may be necessary but should be seen as a last resort. It will also be necessary, as set out in paragraph 68-021 of PPG, that the Councils will need to ensure that planned housing requirements can still be met within the plan period and does not become continually delayed.

Comment

Greater Cambridge Local Plan Preferred Options

STRATEGY

Representation ID: 60175

Received: 10/12/2021

Respondent: Home Builders Federation

Representation Summary:

Viability Assessment
In order for a local plan to be considered sound the cumulative impact of the policies it contains should not undermine its deliverability. It is therefore essential that the viability assessment takes into account all the policy costs being imposed on development and that benchmark land values are accurate. The following policy costs have been underestimated in the viability assessment:
• First Homes
• Biodiversity Net Gain
• Electric Vehicle Charging Points
• Designing for a changing climate

The HBF are concerned that the land values used in relation to brownfield sites appear to be low for an area with a strong economy. The land values for brownfield sites should be reconsidered and increased to reflect the higher existing use values for brownfield land in the Greater Cambridge area.

Comment

Greater Cambridge Local Plan Preferred Options

S/DS: Development strategy

Representation ID: 60180

Received: 10/12/2021

Respondent: Home Builders Federation

Representation Summary:

Buffer - recommend at least 20% in order to offset the potential risks that development will not come forward as planned. There is always uncertainty when bringing forward strategic sites, and important to ensure that these risks are mitigated through a higher buffer and the inclusion of additional sites.

Comment

Greater Cambridge Local Plan Preferred Options

S/DS: Development strategy

Representation ID: 60181

Received: 10/12/2021

Respondent: Home Builders Federation

Representation Summary:

Windfall allowance - whilst the evidence suggests delivery has been higher than previous estimates, there is a finite supply of previously developed land and as such fewer homes will come from such sites in future. It is difficult to say how steeply this decline, but we would suggest consider increased supply or apply a discount to offset any potential future decline in delivery from windfalls.

Comment

Greater Cambridge Local Plan Preferred Options

S/DS: Development strategy

Representation ID: 60182

Received: 10/12/2021

Respondent: Home Builders Federation

Representation Summary:

Five Year Supply - note that the expectation is that the five-year housing land supply on adoption will be 5.15 years. This is a marginal five-year housing land supply. We would recommend that the Council give more consideration to allocating small sites that would bolster the Councils’ housing land supply in the first five years following adoption.

For instructions on how to use the system and make comments, please see our help guide.