Greater Cambridge Local Plan: Proposed Submission

It is concerning that Greater Cambridge is only planning to meet the ‘minimum’ level of housing need set out by government in national policy (with a modest buffer in the housing supply) and even on its own evidence (which CEG LP disputes) it is not aligning its housing ambitions with those it holds for the economy.

CEG LP is also concerned that the Sustainability Appraisal fails to consider any reasonable alternatives aside from the preferred strategy and indeed is narrowing its options; this does not reflect the PPG.

Policy S/JH should therefore be entirely re-written to reflect a true ‘step change’ in economic circumstances with an appropriate job creation figure at Part 1a). Even if Part 1a) remains unchanged, these modest job growth aspirations must be matched by commensurate housing growth in order to represent sustainable development. As such, Part 1b) would need updating to reflect a housing requirement figure which is substantially uplifted to address this.

1 The implications of CEG LP’s objections are that the dGCLP (Reg 19) would need to identify additional allocations to meet the actual housing needs of Greater Cambridgeshire. Although CEG LP recognises that it is not the purpose of the GCLP examination to consider omission sites, in putting forward the case that additional housing allocations are required, there is the opportunity to allocate land to the south east of Cambridge controlled by CEG LP.

Please see attached document which includes tables and formatting not supported by this text box.

When read alongside CEG LP objections to Policy S/JH and the need to ensure that sustainable patterns of growth are achieved, Policy S/DS criterion 2 b) should be amended to allocate additional land on the edge of Cambridge for residential and employment development. Although omission sites are acknowledged not to be a matter for the examination, to demonstrate that there is suitable and available land available to accommodate growth, CEG LP’s land interest to the South East of Cambridge forms a compelling highly sustainable development location to deliver much needed further housing for Cambridge.

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Spatially, CEG LP consider that the dGCLP (Reg 19) should be amended to allocate additional land on the edge of Cambridge for residential development to meet the actual housing need established in CEG LP’s objections to Policy S/JH. CEG LP’s land interest to the South East of Cambridge forms a compelling highly sustainable development location to deliver much needed further housing for Cambridge.

In terms of application for future development management purposes, this policy must accurately and completely reflect the NPPF by deleting part 1a, b and c and the final half of the last sentence "and having regard to the Cambridge Green Belt purposes set out above".

Please see attached document which includes images and formatting not supported by this text box.

The below changes need to be made to the housing trajectory:

1 A significantly increased buffer between the housing requirement (Policy S/JH) and stated supply needs to be incorporated to ensure delivery and to ensure the dGCLP (Reg 19) is positively prepared and effective.

2 More allocations must be made in the early years of the plan period to ensure that on adoption, when a 5YHLS cannot include a windfall allowance, the GCSP Service has enough sites to demonstrate a 5YHLS on adoption.

3 More realistic lead-in time and build-out rate assumptions need to be utilised to ensure there is no overconfidence by the GCSP Service with the “strength of the market” in light of both the blanket affordable housing policy across the whole area which will impact viability and the wider decline in market absorption rates slowing down market housing delivery.

4 To address the above, more sites for residential development will need to be allocated and included in this trajectory.

This comment relates to Appendix D - Housing trajectory and five-year housing land supply calculation.

Please see attached document which includes images and formatting not supported by this text box.

The HELAA is crude and heavy handed in its assessment and is not in all cases correctly applying its own methodology, it cannot be considered accurate nor robust. CEG LP consider that policies informed by this evidence-based document cannot be justified as per NPPF paragraph 36(b) as the strategy of the dGCLP (Reg 19) is not based on accurate, and therefore not proportionate, evidence. Furthermore, it means the HELAA is not in accordance with NPPF paragraph 32 which states local plan preparation should be underpinned by relevant and up to-date evidence. This cannot be the case when the evidence base itself is inaccurate.

Please see attached document which includes images and formatting not supported by this text box.

Spatially, CEG LP consider that the dGCLP (Reg 19) should be amended to allocate additional land on the edge of Cambridge for residential development to meet the actual housing need established in CEG LP’s objections to Policy S/JH. CEG LP’s land interest to the South East of Cambridge forms a compelling highly sustainable development location to deliver much needed further housing for Cambridge.

In terms of application for future development management purposes, this policy must accurately and completely reflect the NPPF by deleting part 1a, b and c and the final half of the last sentence "and having regard to the Cambridge Green Belt purposes set out above".

Please see attached document which includes images and formatting not supported by this text box.

The below changes need to be made to the housing trajectory:

1 A significantly increased buffer between the housing requirement (Policy S/JH) and stated supply needs to be incorporated to ensure delivery and to ensure the dGCLP (Reg 19) is positively prepared and effective.

2 More allocations must be made in the early years of the plan period to ensure that on adoption, when a 5YHLS cannot include a windfall allowance, the GCSP Service has enough sites to demonstrate a 5YHLS on adoption.

3 More realistic lead-in time and build-out rate assumptions need to be utilised to ensure there is no overconfidence by the GCSP Service with the “strength of the market” in light of both the blanket affordable housing policy across the whole area which will impact viability and the wider decline in market absorption rates slowing down market housing delivery.

4 To address the above, more sites for residential development will need to be allocated and included in this trajectory.

This comment relates to Appendix D - Housing trajectory and five-year housing land supply calculation.

Please see attached document which includes images and formatting not supported by this text box.

The below changes need to be made to the housing trajectory:

1 A significantly increased buffer between the housing requirement (Policy S/JH) and stated supply needs to be incorporated to ensure delivery and to ensure the dGCLP (Reg 19) is positively prepared and effective.

2 More allocations must be made in the early years of the plan period to ensure that on adoption, when a 5YHLS cannot include a windfall allowance, the GCSP Service has enough sites to demonstrate a 5YHLS on adoption.

3 More realistic lead-in time and build-out rate assumptions need to be utilised to ensure there is no overconfidence by the GCSP Service with the “strength of the market” in light of both the blanket affordable housing policy across the whole area which will impact viability and the wider decline in market absorption rates slowing down market housing delivery.

4 To address the above, more sites for residential development will need to be allocated and included in this trajectory.

This comment relates to Appendix D - Housing trajectory and five-year housing land supply calculation.

Please see attached document which includes images and formatting not supported by this text box.

The below changes need to be made to the housing trajectory:

1 A significantly increased buffer between the housing requirement (Policy S/JH) and stated supply needs to be incorporated to ensure delivery and to ensure the dGCLP (Reg 19) is positively prepared and effective.

2 More allocations must be made in the early years of the plan period to ensure that on adoption, when a 5YHLS cannot include a windfall allowance, the GCSP Service has enough sites to demonstrate a 5YHLS on adoption.

3 More realistic lead-in time and build-out rate assumptions need to be utilised to ensure there is no overconfidence by the GCSP Service with the “strength of the market” in light of both the blanket affordable housing policy across the whole area which will impact viability and the wider decline in market absorption rates slowing down market housing delivery.

4 To address the above, more sites for residential development will need to be allocated and included in this trajectory.

This comment relates to Appendix D - Housing trajectory and five-year housing land supply calculation.

Please see attached document which includes images and formatting not supported by this text box.

The below changes need to be made to the housing trajectory:

1 A significantly increased buffer between the housing requirement (Policy S/JH) and stated supply needs to be incorporated to ensure delivery and to ensure the dGCLP (Reg 19) is positively prepared and effective.

2 More allocations must be made in the early years of the plan period to ensure that on adoption, when a 5YHLS cannot include a windfall allowance, the GCSP Service has enough sites to demonstrate a 5YHLS on adoption.

3 More realistic lead-in time and build-out rate assumptions need to be utilised to ensure there is no overconfidence by the GCSP Service with the “strength of the market” in light of both the blanket affordable housing policy across the whole area which will impact viability and the wider decline in market absorption rates slowing down market housing delivery.

4 To address the above, more sites for residential development will need to be allocated and included in this trajectory.

This comment relates to Appendix D - Housing trajectory and five-year housing land supply calculation.

Please see attached document which includes images and formatting not supported by this text box.