Draft Greater Cambridge Local Plan for consultation

Proposed standards outlined in part 2 should not be included in the local plan.

The Council say that they are currently exploring the potential require a standard for major residential development. HBF is not supportive of such standards as they often fail to take account of areas where there is surfeit of open spaces, play space and outdoor sports facilities and as such less the need for open space on site may be less than in an area where there is a lower level open space in the local area. For example, where there are play spaces with in close proximity to a development it may be a more effective approach for improvement to be made to those spaces rather than requiring provision on site. HBF would suggest the proposed standards in part 2 are not included in the local plan.

Need clarification - see comments

Part 4 requires residential sites of 200 or more dwellings or groups of smaller sites which cumulatively exceed this figure to be informed by detailed assessment of community needs and include strategies to meet those needs. Firstly, it is not clear how the council will define the area within which smaller developments will need to assess the potential impact and how such assessments will be undertaken. It is unlikely to be the case that all sites in an area will come forward at once leaving the first development to undertake the assessment as to the impact and then seek to address any identified infrastructure needs prior to other development coming forward. Such an approach is impractical and could fall foul of the test relating to planning obligations set out in paragraph 58 of the NPPF. HBF would therefore recommend that the requirements for groups smaller sites to assess needs is removed.
58. The policy should also provide clarity as to the assessment so community needs. This should be to assess the needs additional need created by the development and not be seeking to address any existing shortfalls within area as this would not necessarily be related directly to the development. At present policy reads as if the Council are seeking a wider assessment as to the needs of the community within which development is located rather than the needs resulting from that development and whether existing infrastructure is sufficient to meet those needs. This would appear to be in intention from the supporting text, but clarity must be provided in the policy to ensure the decision makers do not seek to require the provision of infrastructure that is not directly related to the development and necessary to make the development acceptable in planning terms.

See comments

59. This policy sets out the Council’s intention to continue with the application of national described space standards NDSS). Firstly, HBF do not consider it necessary to repeat the space standards in the local plan. Thesis unnecessary repetition of national policy and should be removed. Secondly, the Housing Topic Paper notes that since the introduction of the standard the majority of planning applications comply with NDSS. In addition, it is noted that the policy has been applied flexibly. To ensure that the policy continues to be applied flexibly HBF would suggest that some wording is added to the policy stating that this is the case.
60. Similarly, the requirement with regard to external space standards lack sufficient flexibility to take account of circumstances where they cannot be met. The Council state in the topic paper that some flexibility has been provided in terms of the form of the external space provided. HBF does not consider this to be sufficient. There should be a wider considerations as to the extent of any private external space standards such as viability and other site-specific circumstances such as the delivery of BNG on site which could restrict a developer’s ability to meet the proposed external space standards.
61. The policy requires 10% of affordable units and 5% of market homes on sites of more than 20 homes to be built to part M4(3). This is on the basis of the statement in paragraph 11.105 of the Housing Needs of Specific Groups report. However, the overall need for such homes in table 11.14 outlines that the need for such homes is 968 across Greater Cambridge – just 2% of overall housing need over the plan period. Based on the new sites allocated in this local plan and the fact that sites allocated for development from previous pan the number of accessible homes is likely to substantially exceed what is needed leaving developers with homes that are difficult to sell on the general market. HBF recognises that there is need for some market homes to be built for wheelchair users however this must be based on evidence with a reasonable chance that these will be bought by those who needed them.

See above

What is not clear from the local plan or evidence base is whether the Council have allocated any specific sites provide specialist housing needs. While HBF notes that paragraph 63-013 of PPG states that it is up to the plan making body to decide whether to allocate sires for specialist accommodation it does note that allocating sites provides greater certainty for developers and is more likely to see provision of such development in suitable locations. Given the aging population and the pressure on the housing market HBF consider it essential that specific allocations are made in sustainable locations to meet the needs of older people. Only through allocated sites can the council be certain that the needs for older people will be met in the right locations.

Alongside taking a positive approach to allocations the Council should also establish a more positive decision-making framework for older peoples housing. Paragraph 63-006 outlines that in setting clear policies local planning authorities should consider setting out an indicative figures or a range for the number of units of specialist housing for older people needed across the plan area throughout the plan period. HBF would consider this to be essential for any positive policy relating to older peoples housing as it assists decision makers in understanding how many homes are needed across Greater Cambridge to meet the needs of older people and ensure that they take a positive approach to supporting applications for such accommodation. Where needs are not being met the policy should also state that the Council will apply a presumption in favour of development.

see comments

The policy requires development of 20 or more units to provide at least 5% of homes as self and custom build. This is based on the number of entries on the Self Build Register which indicates a significant shortfall in the number of self-build home the councils must permit in each base period. However, what is notable is that in the latest base period the number of annual entries has fallen drastically following the application of a small administration fee. This would suggest that the level of demand for self-build may not be as high as earlier base period suggest. It will therefore be essentially that a full review of the register is undertaken to understand whether those on the register are still looking to build their own home.

HBF continue to consider the 20-unit threshold is too small as they will be delivered alongside market homes with a failure to develop plots having a far greater impact than on much larger sites where there is more opportunity to separation. The complexity and logistics of developing such sites alongside self-builders could also create significant difficulties. Often there are multiple contractors and large machinery operating on-site, the development of single plots by individuals operating alongside this construction activity raises both practical and health & safety concerns. Unsold plots should not be left empty to the detriment of neighbouring dwellings or the whole development. Any differential between the lead-in times/build out rates of self & custom build plots and the wider site may lead to construction work outside of specified working hours, building materials stored outside of designated compound areas and unfinished plots next to completed/occupied dwellings resulting in customer dissatisfaction. As such we would suggest that if there is to be requirement to provide plots for self-build plots it is on much larger sites.

Consideration needs to be given to increasing the housing requirement and supply.

This policy establishes that the housing requirement for the Greater Cambridge area as 48,195 over the plan period 2024 to 2045 – a total of 2,295 dpa – which is consistent with the outputs of the Standard Method. As the Council will be aware this is the minimum number of homes needed and there may be circumstances where it is necessary to plan for a level of housing needs above that required by the NPPF. The first of these, referenced in paragraph 62 of the NPPF, is where there are unmet needs in neighbouring areas. The second consideration is set out in paragraph 88 of the NPPF which outlines that planning policies seek to address potential barriers to investment such as inadequate infrastructure, services and housing.

With regard to unmet needs the Duty to Co-operate compliance statement provides no detail as to whether neighbouring areas will be able to meet their needs in full. The Council state in the local plan that they have not been asked to address the needs of another area. However, the focus of the correspondence with neighbouring areas appears to be solely in relation to the whether there was capacity elsewhere to meet some of Greater Cambridge’s housing needs rather than whether those areas are able to meet their own needs. HBF recognises that following the publication of the Housing and Planning Minister Written Ministerial Statement on the 27th of November the Government have decided not to save the Duty to Co-operate. Therefore, once the relevant regulations have been enacted Greater Cambridge will no longer be under a duty to co-operate with its neighbours. However, this does not remove the policy requirement in the NPPF to maintain effective co-operation nor the need to consider, in addition to their own housing needs, “… any needs that cannot be met within neighbouring areas …” as set out in paragraph 62 of the NPPF. The only difference arising from the removal of the duty is that a failure to co-operate effectively is a soundness matter that can be rectified through main modifications. Therefore, it will be necessary, as the plan progresses, to establish and set out within statements of common ground how many homes will be built in neighbouring areas and the likelihood of unmet needs arising over the plan period.

With regard to paragraph 88 of the NPPF the Council has undertaken an assessment as to the number of homes that are required to meet the jobs growth expectations over the plan period. The outcome of this assessment in the Employment and Housing Needs Update is that the preferred employment scenario which would see the delivery of 73,248 jobs over the plan period is closely matched by the level of jobs growth supported by the standard method of 73,632. The conclusion of the EHN is based on the central growth as-sumptions which is considered to be the most likely scenario with the higher growth scenario being dis-missed. However, it is noted in paragraph 3.62 of the EHN that the high scenario could be achieved with step change in investment.

Given that the Government have recently announced a £400 million investment in Cambridge to overcome the barriers to growth, such as housing supply and affordability, there is clearly an ambition to sustain the economic growth in the long term there would appear to be some justification for adopting a higher growth scenario and ensuring that housing needs are not a barrier to future investment. HBF would suggest that with the proposed investment the higher growth figures that see a balanced return to the 20 year trend growth ambitions that see a continuation of the 10 year trend compared to the central assessment are adopted.

HBF also note that the previous assessment of need required 2,463 dpa to deliver employment growth over 21 years of 66,000 jobs, compared to 2,292 dpa to deliver 73,200 jobs over the number of years. The reason given for this is the fact that average house hold sizes are now larger, an increase in people of working age and more in-commuting which reduces the number of local people required to fill the jobs created. It is accepted that changing demographics such as increased working age population will impact on the number of homes needed however we are concerned that a reliance on larger household size and increased commuting are not sustainable approaches to ensuring the balance between economic needs and housing growth. Increasing household size can be a result of poor affordability with younger people unable out move out of the family home due to housing costs – an issue that should be addressed through the plan not embedded by it. With regard to commuting patterns the evidence would appear to indicate that the plan is promoting less sustainable patterns of travel rather than, as is required by paragraph 111 of NPPF using planning policies to mini-mise the length and journeys needed for employment.

In conclusion HBF would suggest the evidence on economic growth and housing needs suggest more homes are required in order to support the growth of the Greater Cambridge area. We would recommend that the higher growth scenario is used to inform housing needs in the next iteration of the local plan.
Housing supply

In order to meet the minimum number of homes required by the standard method the Council state that once existing allocations, sites with permission and those with a resolution to grant permission land for a further 10,330 homes will need to be allocated. Table 4 of the local plan indicates that the Council have identified sites to deliver a further 13,463 homes. This results in a total land supply over the plan period to deliver 51,328 homes. This increases to 55,278 if supply from North East Cambridge (NEC) is included. This means that without NEC there is a contingency of 6.5% and with NEC 14.7%. HBF recommends a contingency of between 10% and 20% depending on the sites that form part to of the supply. Where there are a significant number of larger sites delivering home at the end of the plan period HBF would consider to necessary for the contingency to be closer to 20% to ensure that any delay in the delivery of such sites does not require intervention over the life time of this plan. On the basis that 94% of the home expected to be delivered on the latest allocation are over 1,000 homes, with four of this allocations delivering well beyond the plan period, HBF considers it necessary for the contingency in this local plan to be closer to 20%.

HBF also note that the housing land supply across the plan period does not exceed 5.5 years, with land sup-ply on adoption in 2027/28 estimated to be 5.15 years. As such the land supply is relatively fragile and that any delay to the delivery of the newly allocated sites could mean the Council falling below the required 5 years. Additional small and medium sized sites coming forward the first five years post adoption would pro-vide the necessary contingency to ensure the five-year supply is maintained and the plan remain up to date.
10% small sites

In paragraph 2.43 the Council notes the requirement in paragraph 73 of NPPF that at least 10% of the homes delivered over the plan period should be on sites no larger than one hectare. The Council outline that in order to meet this requirement they will have to identify sufficient land to accommodate over 4,820 homes on such sites. The Council consider that they can meet this through identified sites and windfall on small sites which are anticipated to deliver 6,976 homes over the plan period. However, it is noted that only 1,694 of these homes are on identified sites. In meeting the requirement of paragraph 73 the NPPF is clear that these homes must be on identified sites – either as an allocation in the local plan or as a site in the Council’s Brownfield Register. Windfall development is defined in the NPPF Glossary as “Sites not specifically identified in the development plan”. As such the Council cannot rely on assumed levels of windfall delivery on small sites to meet this requirement. In order to ensure the plan meets this requirement the Council must identify, either an an allocation in the local plan or as a sites on the brownfield register, small sites that have the potential to de-liver a further 3,126 homes.

The Council state this is an appropriate response as to allocate these sites would require the delivery of a large number homes in less sustainable locations where levels of car use would be higher. The Council also site that it may require the release of land from the Green Belt to achieve this objective. However, it is not a forgone conclusion that small sites will be in less sustainable locations, this is simply an assumption that has been made by the Councils. There must be a proactive effort to identify small sites with a view to allocating these in the local plan and not simply dismiss further allocations as being unsustainable.

As part of this HBF urges the Council to give careful consideration when updating its Green Belt Study as to whether there are any small sites in locations that are defined as grey belt that could be allocated in order to increase the supply of homes on identified sites of no more than one hectare. HBF recognise that green belt boundaries can only be altered in exceptional circumstances. NPPF notes that one such circumstances is where the Council cannot meet its needs in full but recognises that the inability to meet development needs is not the only circumstance. HBF would suggest the significant shortfall in identified small sites in the local plan and the over reliance on strategic sites to meet needs is justification for allocating small sites in locations that are identified as grey belt.

The Council state that the windfall allowance supports the overall aim of this policy. HBF disagrees. It is important to recognise that the allocation of small sites is a priority and stems from the need to support small house builders by ensuring that they benefit from having their sites identified for development either through the local plan or brownfield register. The effect of an allocation is to take some of the risk out of that development and provide greater certainty that those sites come forward. This in turn will allow the SME sector to grow, deliver homes that will increase the diversity of the new homes that are available as well as bring those homes forward earlier in the plan period. Requiring small developers to rely solely on windfall means that they receive none of the benefits of allocation which remain almost solely the preserve of larger developers in Greater Cambridge.

The Council should also recognise that allocating small sites and supporting SME house builders not only ensures a stronger supply in the short term but also improves the diversity of choice within local housing markets, support local and regional supply chains and are often pivotal in bring forward innovation and sup-porting jobs growth locally, with 1 in 5 of the SME work force comprising of apprentices. A failure to allocate small sites will contribute to the continued decline in small and medium sized house builders. Recent re-search by the HBF has found that there are 85% fewer small house builders today than there were 20 years ago and that of a survey of SME house builders 93% said that planning was a major barrier to SME growth. Whilst this decline is due to a range of factors, more allocations of small sites would ease the burden on many SME developers and provide more certainty that their scheme will be permitted, allowing them to se-cure the necessary finance that is often unavailable to SMEs until permission is granted.