Draft Affordable Housing SPD

RESPONSE ON BEHALF OF BERKELEY HOMES (EASTERN COUNTIES)
LTD.
Introduction
1. Following the success of previous developments within Cambridge, Berkeley Homes are keen to pursue further opportunities in the city. With potential development interests for Berkeley Homes in mind, the draft affordable housing SPD has been carefully considered to ensure that planning guidance for Cambridge will provide developers with appropriate support and clarity in relation to the delivery of affordable housing in the city and would not give rise to any unrealistic burdens that would potentially render developments unviable or unduly impede development opportunities.

2. In consideration of this draft SPD, regard has been had to the emerging Cambridge Local Plan 2014: Proposed Submission, particularly to Policy 45 - Affordable housing and dwelling mix, as well as the National Planning Policy Framework (NPPF) and the National Planning Practice Guidance (PPG) to
ensure that the proposed SPD accords with the policy and guidance set out by Government.

3. The relationship between the emerging CIL regime, Draft Planning Obligations SPD and this Draft Affordable Housing SPD are of particular importance, in view of the combined implications these will have for the delivery of housing and related infrastructure in Cambridge City in the context of significant housing need and Government policy on both the need to secure housing growth and the
need to have regard to viability considerations.

Section 2 - Planning Policy Context

4. The clarification of definitions provided at paragraphs 2.1 - 2.3 is a welcomed aid to the correct interpretation of policy and guidance.

5. Paragraphs 2.4 - 2.9 relate to government guidance on affordable housing, with reference made to that provided by the NPPF and The Government's Housing Standards Review. Regard is also had at paragraph 2.6 to the recently published PPG with mention, albeit somewhat briefly, of the sections on planning obligations and design. It is noted that no mention was made of the PPG's provision with regard to viability, which should have also been a key consideration, particularly paragraph ID 10-010, where it states that "The National Planning Policy Framework is clear that local planning authorities, when requiring obligations, should be sufficiently flexible to prevent planned development being stalled". It is considered that more explicit reference should be made to the policy basis for flexibility based on viability considerations in the context of the clear assertions of national policy and guidance on this matter, albeit it is acknowledged that provision is ultimately made for a degree of flexibility in exceptional circumstances, as noted below, which is welcomed.

Section 3 - Delivering Affordable Housing

6. Paragraph 3.14 helpfully sets out how the mix of affordable housing types should be provided through smaller developments (less than 18 units). It is unclear from the details how the mix should be catered for on developments of more than 18 units however and further clarification for developers on this would be beneficial.

7. The degree of flexibility indicated through paragraph 3.23 recognises that complexities can arise which prevent the delivery of affordable housing on a particular site. The opportunity, although reserved for exceptional circumstances, to address this by financial contributions is an acceptable mechanism to ensure that the policy requirements are not overly restrictive or an impediment to development.

8. Similarly, the flexibility described through paragraph 3.30 in relation to viability, where in exceptional circumstances the Council may consider a reduced level of contribution in one or more area is also welcomed, particularly in light of the fixed and non-negotiable nature of the CIL charge. The relationship between CIL and the funding and provision of affordable housing will clearly be crucial in
affecting the overall viability of developments, and whilst the need for housing is acknowledged, including that for affordable provision, it would be counter-productive to harm the delivery prospects of housing in Cambridgeshire due to insufficient consideration being given to the implications of these competing demands.

9. The guidance in relation to viability at paragraphs 3.27 - 3.40 is informative and the use of the Homes and Communities Agency's Development Appraisal Tool is supported.

Section 4 - Site Layout & Distribution

10. The guidance emphasises that regardless of tenure and type, housing should be optimally distributed throughout sites. Whilst it is agreed that the layout of developments should allow affordable housing to be located fairly and equitably, there are merits in clustering suitable numbers of affordable housing to assist in the management of the units and the recognition for this at paragraph 4.2 is
welcomed.

11. With regard to dwelling mix, Berkley Homes supports the use of the Cambridge sub-region Strategic Housing Market Assessment to establish the level of housing need and steer the guidance document. The data will need to be maintained up to date to keep account of market changes so that affordable
housing mix requirements and negotiations are fully informed and reflect current need.

Section 5 - Building Design

12. Berkeley Homes supports the approach that all housing should be built to similar standards regardless of tenure and the expectation that all homes are to be capable of conversion to Lifetime Homes standard. These are key principles that Berkeley Homes adopt in their commitment to design quality and already apply in the design of new homes.

13. It is accepted that design review panels can provide a constructive mechanism within the design and development process, however it is a procedure that should be reserved for sites of a suitable size or sensitivity, where there are particular design and conservation issues.

RESPONSE ON BEHALF OF BERKELEY HOMES (EASTERN COUNTIES)
LTD.
Introduction
1. Following the success of previous developments within Cambridge, Berkeley Homes are keen to pursue further opportunities in the city. With potential development interests for Berkeley Homes in mind, the draft affordable housing SPD has been carefully considered to ensure that planning guidance for Cambridge will provide developers with appropriate support and clarity in relation to the delivery of affordable housing in the city and would not give rise to any unrealistic burdens that would potentially render developments unviable or unduly impede development opportunities.

2. In consideration of this draft SPD, regard has been had to the emerging Cambridge Local Plan 2014: Proposed Submission, particularly to Policy 45 - Affordable housing and dwelling mix, as well as the National Planning Policy Framework (NPPF) and the National Planning Practice Guidance (PPG) to
ensure that the proposed SPD accords with the policy and guidance set out by Government.

3. The relationship between the emerging CIL regime, Draft Planning Obligations SPD and this Draft Affordable Housing SPD are of particular importance, in view of the combined implications these will have for the delivery of housing and related infrastructure in Cambridge City in the context of significant housing need and Government policy on both the need to secure housing growth and the
need to have regard to viability considerations.

Section 2 - Planning Policy Context

4. The clarification of definitions provided at paragraphs 2.1 - 2.3 is a welcomed aid to the correct interpretation of policy and guidance.

5. Paragraphs 2.4 - 2.9 relate to government guidance on affordable housing, with reference made to that provided by the NPPF and The Government's Housing Standards Review. Regard is also had at paragraph 2.6 to the recently published PPG with mention, albeit somewhat briefly, of the sections on planning obligations and design. It is noted that no mention was made of the PPG's provision with regard to viability, which should have also been a key consideration, particularly paragraph ID 10-010, where it states that "The National Planning Policy Framework is clear that local planning authorities, when requiring obligations, should be sufficiently flexible to prevent planned development being stalled". It is considered that more explicit reference should be made to the policy basis for flexibility based on viability considerations in the context of the clear assertions of national policy and guidance on this matter, albeit it is acknowledged that provision is ultimately made for a degree of flexibility in exceptional circumstances, as noted below, which is welcomed.

Section 3 - Delivering Affordable Housing

6. Paragraph 3.14 helpfully sets out how the mix of affordable housing types should be provided through smaller developments (less than 18 units). It is unclear from the details how the mix should be catered for on developments of more than 18 units however and further clarification for developers on this would be beneficial.

7. The degree of flexibility indicated through paragraph 3.23 recognises that complexities can arise which prevent the delivery of affordable housing on a particular site. The opportunity, although reserved for exceptional circumstances, to address this by financial contributions is an acceptable mechanism to ensure that the policy requirements are not overly restrictive or an impediment to development.

8. Similarly, the flexibility described through paragraph 3.30 in relation to viability, where in exceptional circumstances the Council may consider a reduced level of contribution in one or more area is also welcomed, particularly in light of the fixed and non-negotiable nature of the CIL charge. The relationship between CIL and the funding and provision of affordable housing will clearly be crucial in
affecting the overall viability of developments, and whilst the need for housing is acknowledged, including that for affordable provision, it would be counter-productive to harm the delivery prospects of housing in Cambridgeshire due to insufficient consideration being given to the implications of these competing demands.

9. The guidance in relation to viability at paragraphs 3.27 - 3.40 is informative and the use of the Homes and Communities Agency's Development Appraisal Tool is supported.

Section 4 - Site Layout & Distribution

10. The guidance emphasises that regardless of tenure and type, housing should be optimally distributed throughout sites. Whilst it is agreed that the layout of developments should allow affordable housing to be located fairly and equitably, there are merits in clustering suitable numbers of affordable housing to assist in the management of the units and the recognition for this at paragraph 4.2 is
welcomed.

11. With regard to dwelling mix, Berkley Homes supports the use of the Cambridge sub-region Strategic Housing Market Assessment to establish the level of housing need and steer the guidance document. The data will need to be maintained up to date to keep account of market changes so that affordable
housing mix requirements and negotiations are fully informed and reflect current need.

Section 5 - Building Design

12. Berkeley Homes supports the approach that all housing should be built to similar standards regardless of tenure and the expectation that all homes are to be capable of conversion to Lifetime Homes standard. These are key principles that Berkeley Homes adopt in their commitment to design quality and already apply in the design of new homes.

13. It is accepted that design review panels can provide a constructive mechanism within the design and development process, however it is a procedure that should be reserved for sites of a suitable size or sensitivity, where there are particular design and conservation issues.

RESPONSE ON BEHALF OF BERKELEY HOMES (EASTERN COUNTIES)
LTD.
Introduction
1. Following the success of previous developments within Cambridge, Berkeley Homes are keen to pursue further opportunities in the city. With potential development interests for Berkeley Homes in mind, the draft affordable housing SPD has been carefully considered to ensure that planning guidance for Cambridge will provide developers with appropriate support and clarity in relation to the delivery of affordable housing in the city and would not give rise to any unrealistic burdens that would potentially render developments unviable or unduly impede development opportunities.

2. In consideration of this draft SPD, regard has been had to the emerging Cambridge Local Plan 2014: Proposed Submission, particularly to Policy 45 - Affordable housing and dwelling mix, as well as the National Planning Policy Framework (NPPF) and the National Planning Practice Guidance (PPG) to
ensure that the proposed SPD accords with the policy and guidance set out by Government.

3. The relationship between the emerging CIL regime, Draft Planning Obligations SPD and this Draft Affordable Housing SPD are of particular importance, in view of the combined implications these will have for the delivery of housing and related infrastructure in Cambridge City in the context of significant housing need and Government policy on both the need to secure housing growth and the
need to have regard to viability considerations.

Section 2 - Planning Policy Context

4. The clarification of definitions provided at paragraphs 2.1 - 2.3 is a welcomed aid to the correct interpretation of policy and guidance.

5. Paragraphs 2.4 - 2.9 relate to government guidance on affordable housing, with reference made to that provided by the NPPF and The Government's Housing Standards Review. Regard is also had at paragraph 2.6 to the recently published PPG with mention, albeit somewhat briefly, of the sections on planning obligations and design. It is noted that no mention was made of the PPG's provision with regard to viability, which should have also been a key consideration, particularly paragraph ID 10-010, where it states that "The National Planning Policy Framework is clear that local planning authorities, when requiring obligations, should be sufficiently flexible to prevent planned development being stalled". It is considered that more explicit reference should be made to the policy basis for flexibility based on viability considerations in the context of the clear assertions of national policy and guidance on this matter, albeit it is acknowledged that provision is ultimately made for a degree of flexibility in exceptional circumstances, as noted below, which is welcomed.

Section 3 - Delivering Affordable Housing

6. Paragraph 3.14 helpfully sets out how the mix of affordable housing types should be provided through smaller developments (less than 18 units). It is unclear from the details how the mix should be catered for on developments of more than 18 units however and further clarification for developers on this would be beneficial.

7. The degree of flexibility indicated through paragraph 3.23 recognises that complexities can arise which prevent the delivery of affordable housing on a particular site. The opportunity, although reserved for exceptional circumstances, to address this by financial contributions is an acceptable mechanism to ensure that the policy requirements are not overly restrictive or an impediment to development.

8. Similarly, the flexibility described through paragraph 3.30 in relation to viability, where in exceptional circumstances the Council may consider a reduced level of contribution in one or more area is also welcomed, particularly in light of the fixed and non-negotiable nature of the CIL charge. The relationship between CIL and the funding and provision of affordable housing will clearly be crucial in
affecting the overall viability of developments, and whilst the need for housing is acknowledged, including that for affordable provision, it would be counter-productive to harm the delivery prospects of housing in Cambridgeshire due to insufficient consideration being given to the implications of these competing demands.

9. The guidance in relation to viability at paragraphs 3.27 - 3.40 is informative and the use of the Homes and Communities Agency's Development Appraisal Tool is supported.

Section 4 - Site Layout & Distribution

10. The guidance emphasises that regardless of tenure and type, housing should be optimally distributed throughout sites. Whilst it is agreed that the layout of developments should allow affordable housing to be located fairly and equitably, there are merits in clustering suitable numbers of affordable housing to assist in the management of the units and the recognition for this at paragraph 4.2 is
welcomed.

11. With regard to dwelling mix, Berkley Homes supports the use of the Cambridge sub-region Strategic Housing Market Assessment to establish the level of housing need and steer the guidance document. The data will need to be maintained up to date to keep account of market changes so that affordable
housing mix requirements and negotiations are fully informed and reflect current need.

Section 5 - Building Design

12. Berkeley Homes supports the approach that all housing should be built to similar standards regardless of tenure and the expectation that all homes are to be capable of conversion to Lifetime Homes standard. These are key principles that Berkeley Homes adopt in their commitment to design quality and already apply in the design of new homes.

13. It is accepted that design review panels can provide a constructive mechanism within the design and development process, however it is a procedure that should be reserved for sites of a suitable size or sensitivity, where there are particular design and conservation issues.