Greater Cambridge Local Plan: Proposed Submission

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Therefore, without clear evidence that all homes need to be built to M4(2) HBF would recommend that the Council adopt a policy that is in line with HO5 in NPPF26 and require no less than 40% of homes on major development to be delivered as M4(2).

Therefore, the Council can only require M4(3)(b) where it has nominating rights over who lives in the that house and not as the council suggests where they consider to be a need for such homes. This distinction must be made in the policy.

Part 2 of the requires all new homes to be built to the Nationally Described Space Standards. These are then repeated in the policy itself. This is inconsistent with paragraph 16 of the NPPF which states that local plans should avoid duplication with national policies.

With regard to accessible housing this policy requires all homes to be built to M4(2) and 5% of market housing and 10% of affordable housing built to be M4(3) for wheelchair users. With regard to M4(2) the evidence supporting this policy in the Housing Needs of Specific Groups Update (HNSPU) report.

While HBF would agree that there is a need for some homes to be built to part M4(2) the evidence in the HNSPU relies on the fact that the projected change in the number of people mobility problems is evidence of the need for all homes to be built to part M4(2). However, what does not appear to have been considered is that many of those whose needs change will already live in the Borough with their home being able to be adapted to meet their needs. Therefore, without clear evidence that all homes need to be built to M4(2) HBF would recommend that the Council adopt a policy that is in line with HO5 in NPPF26 and require no less than 40% of homes on major development to be delivered as M4(2).

In relation to wheelchair user housing the policy states that “These homes should be delivered as Building Regulations M4(3)(a) ‘wheelchair adaptable’ dwellings unless the Council has identified a need for Building Regulations M4(3)(b) ‘wheelchair accessible’ dwellings”. This is not consistent with paragraph 56-009 of PPG which states that “Local Plan policies for wheelchair accessible homes should be applied only to those dwellings where the local authority is responsible for allocating or nominating a person to live in that dwelling”. Therefore, the Council can only require M4(3)(b) where it has nominating rights over who lives in the that house and not as the council suggests where they consider to be a need for such homes. This distinction must be made in the policy.

See comments

Even if the principle that these should offered to a registered provider was considered to be sound it is unjustified that these should be offered at affordable housing land values. If an RP wished to purchase these plots, given that they are plots for market housing it would need to be at market rates. HBF consider the following amendments are required to make the policy sound:
“Each plot must be marketed for at least a 12 month marketing period in accordance with a marketing strategy and valuation approved by the local planning authority at the outline or full planning application stage. Once plots have been marketed for the minimum period, they will transfer back to the developer to be built out as market housing. either be further marketed for a period of time as has been agreed by the local planning authority or will be transferred to a Registered Provider for the provision of affordable housing at affordable housing land values”

Part 3 of this policy states that following a marketing period of 12 months they will be market for a time period as agreed with the local authority or transferred to a registered provider. HBF support the marketing period but consider the second part of this policy to be unsound. There is no justification as to why self-build plots should be retained on the open market following the 12-month period nor is there any justification for having to offer these to a registered provider. This was an issue considered at the examination of the Spelthorne Local Plan with the inspector requiring the Council to remove a similar phrase from their local plan due to the soundness concerns raised by the HBF.
The reason why this approach is unjustified is that these are plots that are provided for market housing with the only difference being that they are built out by an individual. As such if there is no demand for these plots after the 12-month market period they should return to the developers to be built out as market housing. The fact that no purchasers came forward within 12 months should be seen by the Council that their evidence overestimated the demand for self-build plots and that it should review the policy and reduce the number of self-build plots a developer is required to provide.
Even if the principle that these should offered to a registered provider was considered t be sound it is unjustified that these should be offered at affordable housing land values. If an RP wished to purchase these plots, given that they are plots for market housing it would need to be at market rates. HBF consider the following amendments are required to make the policy sound:
“Each plot must be marketed for at least a 12 month marketing period in accordance with a marketing strategy and valuation approved by the local planning authority at the outline or full planning application stage. Once plots have been marketed for the minimum period, they will transfer back to the developer to be built out as market housing. either be further marketed for a period of time as has been agreed by the local planning authority or will be transferred to a Registered Provider for the provision of affordable housing at affordable housing land values”