Draft Greater Cambridge Local Plan for consultation

COMMENT
Policy WS/NC of draft GCLP seeks to ensure that new development contributes towards the delivery of new services and facilities to meet the needs of residents. The supporting text to Policy WS/NC identifies the types of services and facilities that the policy applies to, including education, libraries, health, indoor and outdoor sports facilities, and community development. Reference is included to identified and addressing needs, the provision of indoor community facilities and implementation.
Of relevance, part 3 of Policy WS/NC requires that Developments of sufficient scale to generate the need for new on-site facilities will be required to do so, unless it can be demonstrated that there would be advantages in delivering the facilities off site.
Part 5 concerns the delivery of indoor community facilities, requiring that all housing developments will contribute towards the provision of indoor community facilities to meet the need generated by the development. Developments of sufficient scale to generate the need for new on-site facilities will be required to do so, unless it can be demonstrated that there would be advantages in off-site delivery.
CIP supports Policy WS/NC in principle and delivering appropriate community facilities.
The wording however as drafted under Parts 3 and 5 of Policy WS/NC concerning the delivery of onsite facilities is considered as vague and unclear when the policy requirements will be triggered. The threshold for “Developments of sufficient scale” should be defined and specified. There is also general overlap in the requirements of part 3 and 5 and for purposes of conciseness, it is requested that these are combined.

The requirement also to provide onsite indoor community facilities as required under part 5 of Policy WS/NC when balancing against other policy requirements as set out in the draft GCLP, namely Policy BG/BG, BG/GI, Policy BC/TC, Policy BG/EO and Policy H/SS, restrict opportunities for density uplift and achieving the housing numbers as set out under the draft site allocations listed in draft policy S/LAC. There are also risks for site viability to accommodate for these considerations, essential in delivering affordable housing requirements (draft policy H/AH) and infrastructure delivery (draft policy I/ID).
It is considered that draft part 5 of draft policy WS/NC needs to better align with other draft GCLP policies and housing requirements, in order to ensure that such provisions are feasibly deliverable.
REQUESTED CHANGE

To clarify the threshold for “Developments of sufficient scale” as listed under parts 3 and 5 of Policy WS/NC.

To request parts 3 and 5 of Policy WS/NC are merged for conciseness and avoidance of replication.

To request the requirement to provide onsite indoor community facilities as required under part 5 of Policy WS/NC is more aligned with other policy requirements to accommodate for the feasibility in achieving housing requirements and infrastructure delivery.

COMMENT

CIP in principle supports the sequential approach to the location of retail and other main town centre uses in Greater Cambridge.

Part 4 of the policy sets out when residential development will be regarded as acceptable in such designated town centre, district and local centre locations.

Part 5 of the policy, specifically criterion 5a and 5b permit establish criteria where the loss of retail uses or potential merging/sub division of such units will be supported.

It is requested that in the justification criteria for both parts 4 and 5 that appropriate wording and flexibility is also included to allow for commercial viability considerations and when such circumstances would allow for the loss of retail uses or potential merging/sub division of units alongside residential uses.

REQUESTED CHANGE

It is requested that in the justification criteria for both parts 4 and 5 that appropriate wording and flexibility is also included to allow for commercial viability considerations and when such circumstances would allow for the loss of retail uses or potential merging/sub division of units alongside residential uses.

Policy H/AH: Affordable housing

COMMENT

Policy H/AH sets out the requirements for affordable housing delivery on new housing developments,
including specifying the size of developments on which affordable homes will be provided and the proportion of affordable homes required, and setting out the tenures of affordable housing required to address identified needs

Part 5 of the policy stipulates affordable housing tenures for schemes of 10-14 dwellings and then 15 dwellings or more.

CIP supports in principle the requirements set out under Policy H/AH. However, it is requested that the requirement to provide 25% of all affordable homes as shared ownership is removed. If not removed it should be amended as below. The Council through the Cambridge Investment Partnership is the major provider of new affordable housing in Cambridge City. The Council only retains legacy shared ownership stock. It does not have the capacity to administer a new shared ownership programme and whether delivered directly by the Council or through partners this would undermine the viability of schemes and detract from the delivery of housing to meet priority needs. The Council’s approach does acknowledge the importance of a mix of affordable housing and for this reason it applies a range of price points to the housing it delivers: social rents, affordable rents at 60% and affordable rents at 80%. Coupled with the right to buy which applies after a tenant has held a Council tenancy for three years the Right to Buy effectively creates a route to home ownership. Proceeds of Right to Buy sales are recycled into the housing programme.

REQUESTED CHANGE

Delete or replace Part 2 of policy wording with "25% Shared Ownership Homes, or other affordable homes which provide a route to Home Ownership, or are made subject to Right To Buy"

Policy H/SS: Residential space standards and accessible homes


COMMENT

Policy H/SS sets out the required standards for internal spaces within new homes, the proportion of accessible and adaptable dwellings to be provided, and the required standards for external private and shared amenity space. Parts 1 and 2 concerns internal residential space standards. Parts 3 and 4 stipulate external residential space standards that should be met or exceeded. This includes for new build, conversions and change of use with houses (irrespective of the number of bedrooms) to provide a minimum of 30 sqm; ground floor apartments (irrespective of the number of bedrooms) to provide a minimum of 10 sqm; and upper floor apartments to have a minimum of 5 sqm, with an additional 1 sqm for each additional bedspace.


Part 5 sets out the design principles for external amenity spaces to adhere to. Part 6 outlines exemptions for provision of private external amenity space. Parts 7-9 concerns accessible and adaptable homes requiring all new residential buildings to be built to M4(2) standard and for development proposals providing 20 or more new build dwellings, 10% of the affordable units and 5% of the market units to be to M4(3) standard.


CIP supports in principle the need to deliver high standards of amenity and accessibility in new homes.

However, the requirements under parts 3 and 4 for the stipulated minimum external residential space standards when balancing against other policy requirements as set out in the draft GCLP, namely Policy BG/BG, BG/GI, Policy BC/TC, Policy BG/EO, and Policy WS/NC may constraint site opportunities. This is particular for density uplift and achieving the housing numbers as set out under the draft site allocations listed in draft policy S/LAC or to implement when accommodating for the presumption in retention and reuse of existing buildings as issued under policy CC/CE.

Similarly to parts 7-9 regarding the delivery of required M4(3) units, there may be risks for site viability to accommodate for these considerations, essential in delivering affordable housing requirements (draft policy H/AH) and infrastructure delivery (draft policy I/ID).

It is considered that draft Policy H/SS needs to better align with other draft GCLP policies and housing requirements, in order to ensure that such housing space standards are feasibly deliverable.
It is also requested that wording is added to Policy H/SS to allow for a maximum cap on the total number of M4(3) units to be delivered as required on the 10% of all affordable units to be provided as M4(3). This is to accommodate for developments which may be providing developments as 100% affordable housing and where a need for such quantity of M4(3) units would be unnecessary. It is suggested that if schemes deliver more than 50% affordable housing, the M4(3) requirement is capped and the number based on more than 50% of the total affordable housing numbers to be provided.

REQUESTED CHANGE

To request that the minimum external amenity space requirements are more aligned with other policy requirements and consideration for site feasibility and viability.
To request that the minimum requirement for delivery of M4(3 units) is more aligned with other policy requirements and consideration for site feasibility and viability.

Policy H/CB: Self and Custom Build homes


COMMENT

Policy H/CB concerns self and custom build home delivery in Greater Cambridge. Part 1 requires that developments of 20 or more dwellings must provide at least 5% of the new homes as serviced plots for custom and self build houses and/or serviced custom-build flats. Exemptions from this requirement, which amongst other things, include schemes where a minimum of 80% homes are delivered as affordable. Unless specified all custom and self build plots will be classified as market housing as stated under part 2. Part 3 sets out the marketing criteria for custom and self build plots.

CIP in principle support the delivery of self and custom build home delivery in Greater Cambridge.

However, it is requested that the currently proposed threshold of 80% affordable homes listed under part 1 a ii allowing for the exemption of delivery of custom and self build plots is decreased to 50%.

Cambridge City Council’s ten-year development programme seeks to deliver 1000 net additional council rented homes between 2022 and 2032, of which CIP is the main delivery vehicle to achieve this target. CIP has already delivered residential redevelopments across the city which provide in excess of the minimum policy requirement of 40% affordable housing.

To achieve the above affordable housing target however, site viability is key, alongside the securing of funding from the Homes England Local Authority Strategic Partnership. It is considered that the proposed 80% threshold would affect this delivery and feasibility to meet the 2022-2032 council rented home target.

REQUESTED CHANGE

To request the 80% affordable housing exemption of self and custom home plot delivery listed under part 1 a ii of Policy H/CB is decreased to 50%.

COMMENT

Policy I/EV sets out the requirements for cycle and vehicle parking. Amongst other things, part 2 concerns cycle parking and sets out associated design principles listed in criteria 2a-i. Part 2h specifically cycle parking for residential development to be located in a purpose-built area at the front of the house or within a garage.
Part 3 of Policy I/EV states that at least 5-10% of cycle parking provision must be designed to accommodate nonstandard cycles and should consider appropriate provision for electric charging points.

Part 4 sets out cycle parking standards, with Part 5 confirming disabled parking provision and associated design principles. Part 6 then requires the submission of a site-wide Electric Vehicle charging strategy for large-scale major sites.

CIP supports in principle the vehicular and cycle parking standards and associated design requirements.

It is requested however that the policy wording of Part 2h is updated; the wording as currently stated does not accommodate for provision in different types of residential dwellings, for example flats or maisonettes, where cycle parking will not be able to be provided in a garage or to the front of a house. Reference should be included to accommodate for such alternative residential accommodation provision, for example to include reference to a purpose built ancillary secure communal area.

The requirement under Part 3 to provide at least 5-10% of non-standard cycle parking is non-specific and does not provide sufficient flexibility for minor developments where such provision is unlikely to be required, nor necessarily feasible to deliver. The wording should be updated to include a threshold for the requirement to nonstandard cycle parking provision. The 5-10% range is also regarded as vague and should be further specified. Non-standard cycle parking should also be defined to specifically reference the alternative cycle parking to be accommodated for, such as cargo or electric bike provision.

Criteria 6 does not specify the threshold for large scale major developments and it is unclear the threshold requirement for the submission of a site wide electric vehicle charging strategy. A threshold should be specified.

REQUESTED CHANGE

To update the wording of part 2h of Policy I/EV to accommodate for cycle parking design requirements for alternative residential accommodation provision.

To clarify the type of non-standard cycle parking provision to be provided for in developments as required under Part 3 of Policy I/EV. To also include a development quantum threshold for such provision. To also specify a fixed percentage provision for the overall non-standard cycle parking provision.

To clarify the threshold for large scale major sites and associated requirement for a site wide electric vehicle charging strategy as requested by part 6 of Policy I/EV.

COMMENT

Policy I/ID seeks to ensure there is sufficient infrastructure capacity to support and meet all the requirements arising from the new development, and its associated phasing. Part 1 outlines proposals will need to make appropriate arrangements for infrastructure improvement and provision. Part 2 outlines infrastructure phasing requirements. Part 3 states the need for proposals to demonstrate sufficient capacity with parts 4 and 5 expanding upon this further. Part 6 confirms the requirements for the submission of a utilities statement.


CIP supports in principle the importance of new developments to support infrastructure delivery. The wording under part 3 of Policy I/ID as inserted below:

Proposals for new development will be required to demonstrate adequate capacity exists or can be secured both on and off site to serve the development

It is requested that the wording is amended to ensure liability is not solely placed on the developer to address any potential infrastructure deficiencies where unreasonable and not directly related to the impact of any prospective development. This reflects concerns raised under draft Policy CC/WE.

REQUESTED CHANGE

It is requested that the wording is amended to ensure liability is not solely placed on the developer to demonstrate sufficient infrastructure capacity.

COMMENT

Policy I/CM sets out how developments should contribute to Greater Cambridge’s access to broadband, telecommunication infrastructure and smart infrastructure.
For telecommunications infrastructure, part 6 requires for schemes of 30 or more dwellings to include suitable infrastructure that would support any future rollout of appropriate telecommunications equipment such as small cell mobile communications technology or mobile masts and towers.
CIP do not object to the principle of the policy but request the wording is updated to ensure full responsibility is not placed on the developer to provide the appropriate infrastructure.

REQUESTED CHANGE
It is requested that the wording is amended to ensure liability is not solely placed on the developer to provide digital and telecommunications infrastructure.