Greater Cambridge Local Plan Issues & Options 2020

5.2.1 Whilst Gladman recognise the importance of good design, it is critical that the Local Plan does not include overly onerous design policies which could restrict the delivery of much needed housing across the Greater Cambridge area. 5.2.2 In this regard, Gladman refer to paragraph 128 of the NPPF which states: “Design quality should be considered throughout the evolution and assessment of individual proposals. Early discussions between applicants, the local planning authority and local community about the design and style of emerging schemes is important for clarifying expectations and reconciling local and commercial interests….”

Very important

6.1.1 Continuing economic growth across the Greater Cambridge area is of fundamental importance and needs to be properly considered and planned for through the new Local Plan. Greater Cambridge is a key component of the Oxford to Cambridge growth arc, which is of national significance and therefore the Greater Cambridge Local Plan will have a key role to play in shaping this area and delivering transformational scales of growth. 6.1.2 It will be important that these growth opportunities are maximised and that the Councils work alongside the other LPA’s in the arc to ensure the potential of the area is realised. 6.1.3 Gladman also refer to the Cambridgeshire and Peterborough Devolution Deal which was agreed by the seven Councils across Cambridgeshire and Peterborough and the LEP back in November 2016, with the Order being signed in March 2017. The Devolution deal includes a £600 million fund to support economic growth as well as a £100 million housing fund and £70 million fund to build more Council rented homes. 6.1.4 Gladman note the importance of the economy of Cambridge nationally and the fact that this needs to be a key consideration during the preparation of the Greater Cambridge Local Plan.

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7.1.1 The consultation document outlines that the current calculations, using the Government’s standard method, indicate a need for 1,800 homes per year or 40,900 homes for the plan period 2017-2040. Through the process of preparing the Greater Cambridge Local Plan, the 1,800 figure should be considered as a minimum needed and the Councils should be open minded to the fact that this figure may increase due to other considerations. Once the minimum figure has been established further interrogation of this figure will be required to ensure that this is appropriate, for example it may be necessary to increase this figure to support economic growth or to meet affordable housing need as set out in the PPG. 7.1.2 Specifically, Gladman refer to Paragraph ID 2a-010-20190220 which states: “…Therefore, there will be circumstances where it is appropriate to consider whether actual housing need is higher than the standard method indicates. This will need to be assessed prior to, and separate from, considering how much of overall need can be accommodated (and then translated into a housing requirement figure for the strategic policies in the plan). Circumstances where this may be appropriate include, but are not limited to situations where increases in housing need are likely to exceed past trends because of: • Growth strategies for the area that are likely to be deliverable, for example where funding is in place to promote and facilitate additional growth (e.g. Housing Deals); • Strategic infrastructure improvements that are likely to drive an increase in the homes needed locally; or • An authority agreeing to take on unmet need from neighbouring authorities, as set out in the statement of common ground;…” 7.1.3 The consultation document acknowledges this when it outlines the scale of economic growth which the Council signed up to as part of the Cambridgeshire and Peterborough Devolution Deal. Whilst the consultation document outlines that further detailed work is required, it does also outline that a rough indicative calculation suggests that if this scale of jobs growth is achieved, around 2,900 homes a year would be needed across Greater Cambridge, which would require 66,700 homes between 2017-2040. 7.1.4 Gladman strongly believe that the new Local Plan should be planning for a significantly higher number of homes that the minimum identified by the standard method and that they should be seeking to deliver the homes necessary to align with the scale of economic growth. 7.1.5 In this regard Gladman also refer to the Cambridgeshire and Peterborough Independent Economic Review (CPIER) September 2018, which sets out a compelling case for higher levels of housing growth across the Greater Cambridge area. Specifically, Gladman note Key Recommendation 5 which points to the need to review the housing requirement based on the need for high economic growth and also how the report warns of significant negative impacts, both to the local and national economy should housing needs continue to be constrained. 7.1.6 In addition to the Cambridgeshire and Peterborough Devolution Deal and the economic growth associated with this, it is important for the new Local Plan to recognise the areas position within the Oxford to Cambridge Growth Arc and the implications that this will have for additional growth in the area. 7.1.7 The Government has designated the Oxford to Cambridge Growth Arc as a key economic priority and has stated the objective to deliver up to 1 million high quality new homes across the Arc up to 2050. Given that growth across the Arc is of national importance, Gladman believe it is imperative that the Local Plan seek do deliver a higher number of homes than the minimum requirement derived from the standard method. The economy of Cambridge is too important nationally for the Councils to be planning for the minimum number of homes required by the standard method. 7.1.8 The consultation document claims that there are 36,400 homes already in the pipeline to be built between 2017 and 2040, and that if this figure is correct then there may the case for making additional provision if the Local Plan does seek to deliver a higher housing figure then the standard method. 7.1.9 If the Council were to progress with the economic growth led scenario discussed in the consultation document this would suggest the need to identify sites for around an additional 30,000 homes in the next Local Plan. Gladman agree that the new Local Plan will need to be identifying significant amounts of land available to deliver the pro-growth strategy. The scale of this residual land to be identified will need to be clarified through further work on the housing need/requirement figure. 7.1.10 Given the factors identified above it is clear that the Councils will need to establish a housing requirement well in excess of the minimum number of homes required by the Standard Method. Gladman reserve the right to comment on the housing and jobs growth proposals when these are developed further and the preferred option is presented in the next stage of public consultation (Draft Plan).

7.2.1 In allocating sites the Council should be mindful that to maximize housing supply the widest possible range of sites, by size and market location are required so that house builders of all types and sizes have access to suitable land in order to offer the widest possible range of products. The key to increased housing supply is the number of sales outlets. Whilst SUEs and new settlements may have multiple outlets, in general increasing the number of sales outlets available means increasing the number of housing sites. The maximum delivery is achieved not just because there are more sales outlets but because the widest possible range of products and locations are available to meet the widest possible range of demand. In summary a wider variety of sites in the widest possible range of locations ensures all types of house builder have access to suitable land which in turn increases housing delivery. Housing Mix 7.2.2 In terms of housing mix, Gladman would recommend that the Local Plan avoids a prescriptive housing mix requirement, rather that the policy should allow for schemes to determine the most appropriate housing mix for the particular location. The Plan could include an indicative mix which may be encouraged if appropriate rather than a strict requirement. The housing provided will need to reflect the needs across the area and any policy will need to be flexible and recognise that the specific housing needs may change over the course of the plan period. Affordable Housing 7.2.3 The provision of affordable housing should be a key priority for the new Local Plan. Affordability of housing across the Greater Cambridge area is a significant issue, with the Median Affordability ratios being 12.95 and 10.25 for Cambridge City and South Cambridgeshire district respectively. 7.2.4 It will be important that the affordable housing requirement set through the new Local Plan is tested through the Local Plan Viability Assessment and that it is set at a deliverable level, whilst also ensure that the housing needs are met. 7.2.5 It may be necessary for the Local Plan to include varied affordable housing requirements based on site type and location. This will need to be considered further through the preparation of the Plan. Housing for Older People 7.2.6 The provision of specialist housing to meet the needs of older people is of increasing importance and the Councils need to ensure that this is reflected through a positive policy approach within the new Local Plan. The Councils need a robust understanding of the scale of this type of need across the Greater Cambridge area and need to set out an approach capable of delivering accommodation to meet this need. Gladman believe that it would be appropriate for the Local Plan to seek to identify specific sites to deliver for this specific need as this would provide a greater level of certainty regarding delivery. 7.2.7 Specialist housing with care for older people is a type of housing which provides choice to adults with varying care needs and enables them to live as independently as possible in their own self contained homes, where people are able to access high quality, flexible support and care services on site to suit their individual needs (including dementia care). Such schemes differ from traditional sheltered/retirement accommodation schemes and should provide internally accessible communal facilities including residents’ lounge, library, dining room, guest suit, quiet lounge, IT suit, assisted bathroom, internal buggy store and changing facilities, reception and care managers office and staff facilities. Self-build and Custom-build Housing 7.2.8 Gladman would welcome the addition of a policy in relation to self-build housing within the Greater Cambridge Local Plan. This would be in line with current government thinking and objectives. It is key that the development industry are able to understand the implications of any such policy requirement, to assist with the design of schemes and the consideration of financial viability. 7.2.9 Gladman recommend that any policy requirement in relation to self-build housing has an element of flexibility built in to allow for negotiation over self-build plots on the basis of identified demand and also viability to ensure that site delivery is not delayed or prevented from coming forward. Any specific requirement to include self-build plots should be tested through the Council’s viability assessment of the Local Plan policies to ensure that the cumulative impacts of all proposed local standards and policy requirements do not put the implementation of the Plan as a whole at risk. 7.2.10 Further to this, Gladman urge the Council to ensure the policy has added flexibility as there is no guarantee that these units will be delivered and there may be situations when they are difficult to deliver which may result in the non-delivery of otherwise sustainable land for housing. Therefore, Gladman recommend that any policy specific requirement needs to include a mechanism whereby if the self-build plots are not taken up within a given time period then these revert back to market housing to be provided as part of the wider scheme. This would provide flexibility and help to ensure that the required housing is delivered.

7.3.1 Whilst Gladman recognise the importance of ensuring high quality design it is also important to ensure that the new Local Plan does not impose overly onerous design policies which could unnecessarily restrict sustainable development from coming forwards. Optional Standards 7.3.2 With regards to optional technical standards for accessible and adaptable homes, if the Councils wish to include a policy in the Local Plan adopting these optional standards, M4(2) and M4(3), then this should only be done in accordance with the NPPF (2019) specifically paragraph 127.f, footnote 46 and the guidance contained in the PPG. 7.3.3 Footnote 46 states “planning policies for housing should make use of the Government’s optional technical standards for accessible and adaptable housing where this would address an identified need for such properties.” Any such policies would need to be based on relevant and up to date evidence to justify specific policy requirements. 7.3.4 Gladman refer to the PPG which sets out the evidence necessary to justify a policy requirement for M4(2) and M4(3). Specifically paragraph ID 56-007 which states: “There is a wide range of published official statistics and factors which local planning authorities can consider and take into account, including: • The likely future need for housing for older and disabled people (including wheelchair user dwellings). • Size, location, type and quality of dwellings needed to meet specifically evidenced needs (for example retirement homes or care homes). • The accessibility and adaptability of existing housing stock. • How needs vary across different housing tenures. • The overall impact on viability.” (ID: 56-007-20150327) 7.3.5 Gladman also note that it may be the case that any policy relating to optional standards may need to vary in different locations across the plan area, as the justification for requirements may differ. It may not be justified or appropriate, based on the up to date evidence, to set a blanket approach across the plan area. Nationally Described Space Standards (NDSS) 7.3.6 The Councils will need clear and robust evidence to justify the inclusion of any policy requirement for the NDSS and will need to undertake viability testing in relation to any specific requirements which they wish to impose. 7.3.7 The Written Ministerial Statement (WMS) dated 25th March 2015 confirms that “the optional new national technical standards should only be required through any new Local Plan policies if they address a clearly evidenced need, and where their impact on viability has been considered, in accordance with the NPPG”. 7.3.8 Furthermore, with reference to the nationally described space standard the PPG (ID: 56-02020150327) confirms “where a need for internal space standards is identified, local planning authorities should provide justification for requiring internal space policies”. If the Council wishes to adopt this standard it should be justified by meeting the criteria set out in the PPG including need, viability and impact on affordability. 7.3.9 The identification of a need for the NDSS must be more than simply stating that in some cases the standard has not been met, it should identify the harm caused or that may be caused in the future.

8.1.1 Consideration regarding infrastructure requirements need to begin early in the process and it is of fundamental importance that the infrastructure provision aligns with the growth strategy for the area. 8.1.2 The Council, when establishing its housing requirement, will need to consider the likely implications of key infrastructure projects in the area such as the East West Rail link between Cambridge, Oxford and Milton Keynes and the economic benefits that may stem from this.

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9.3.1 Gladman recognise that the Green Belt covers around 25% of South Cambridgeshire and adjoins much of the built edge of Cambridge. Gladman submit that the Councils should undertake the evidence base work, through the form of a Green Belt Assessment, to inform any decisions made regarding development options within the Green Belt. 9.3.2 In this regard, Gladman refer to paragraph 138 of the NPPF – “When drawing up or reviewing Green Belt boundaries, the need to promote sustainable patterns of development should be taken into account. Strategic policy-making authorities should consider the consequences for sustainable development of channelling development towards urban areas inside the Green Belt boundary, towards towns and villages inset within the Green Belt or towards locations beyond the outer Green Belt boundary. Where it has been concluded that it is necessary to release Green Belt land for development, plans should give first consideration to land which has been previously developed and/or is well served by public transport. They should also set out ways in which the impact of removing land from the Green Belt can be offset through compensatory improvements to the environmental quality and accessibility of remaining Green Belt land.”

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9.4.1 Gladman recommend that the new Local Plan should take a flexible approach to growth within and on the edge of villages. The Local Plan should avoid blanket protection policies as they may act to unnecessarily stifle sustainable growth opportunities on the edge of settlements. This is at odds with national policy, seeking to boost significantly the supply of housing and applying a presumption in favour of sustainable development. 9.4.2 Gladman recommend that the Council could incorporate a criteria based policy, such an approach would allow the plan to protect itself against unsustainable development at the same time as being open and flexible to additional development opportunities to come forward to meet identified needs.

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9.4.1 Gladman recommend that the new Local Plan should take a flexible approach to growth within and on the edge of villages. The Local Plan should avoid blanket protection policies as they may act to unnecessarily stifle sustainable growth opportunities on the edge of settlements. This is at odds with national policy, seeking to boost significantly the supply of housing and applying a presumption in favour of sustainable development. 9.4.2 Gladman recommend that the Council could incorporate a criteria based policy, such an approach would allow the plan to protect itself against unsustainable development at the same time as being open and flexible to additional development opportunities to come forward to meet identified needs.

9.6.1 Gladman are supportive of the efficient use of land, as required by 117 of the NPPF (2019): “Planning policies and decisions should promote an effective use of land in meeting the need for homes and other uses, while safeguarding and improving the environment and ensuring safe and healthy living conditions. Strategic policies should set out a clear strategy for accommodating objectively assessed needs, in a way that makes as much use as possible of previously-developed or ‘brownfield’ land.” 9.6.2 Notwithstanding this, it should be recognised that an approach seeking densification can only go so far and will not be a solution on its own, but rather as one element of a hybrid strategy. When looking at densification it is important to remember that proposals will still need to be brought forward at an appropriate density for the site and particular location, therefore a blanket approach is unlikely to be appropriate. 9.6.3 Paragraph 122 of the NPPF outlines things that should be taken into account when considering the density of development. Paragraph 123 goes on to state “Where there is an existing or anticipated shortage of land for meeting identified housing needs, it is especially important that planning policies and decisions avoid homes being built at low densities, and ensure that developments make optimal use of the potential of each site…”