Greater Cambridge Local Plan Issues & Options 2020

These representations are provided by Persimmon Homes Ltd (Persimmon) in response to the Greater Cambridge Local Plan Issues and Options Consultation. Persimmon is one of the largest residential developers in the UK building around 16,000 new homes per year nationwide and is an active in the Greater Cambridge Area. Persimmon would emphasise the need for any future plan covering the area to be both aspirational but also deliverable supported by detailed policies that are underpinned by an appropriately robust evidence base. We hope that the following comments will assist the councils in their preparation of a sound plan.

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Strongly disagree

The consultation document proposes a 15 year plan period. Paragraph 22 of the National Planning Policy Framework 2019 (NPPF) which states that strategic policies should look ahead over a minimum 15 year period to adoption. Given the future opportunities posed by the Oxford to Cambridge Growth Arc, Persimmon strongly disagrees with the councils’ suggestion that it plan for the minimum period allowable by national policy. Looking to 2040 will not allow for an appropriately ambitious, longer-term outlook at significantly detract from the efficacy of the plan, likely necessitating an early review soon after adoption. We would refer the councils to “The Oxford-Cambridge Arc: Government Ambition and Joint Declaration between Government and Local Partners” released March 2019 by the Ministry of Housing, Communities, and Local Government which states: “We recognise that meeting all these ambitions for the Arc requires us to take a long-term view, at least to 2050, and for us to work collaboratively across geographical, political and thematic boundaries." On this basis, in order to align with the Government’s growth agenda for the region, we would suggest that the councils plan to at least 2050.

When framing their priorities the councils should be mindful that they are working within the parameters of the existing legislative and policy framework as it relates to plan-making. The councils’ broader aspirations should not undermine the key objective of appropriately defining and then meeting housing and other development needs through suitable and deliverable sites. Recognising the national housing shortage and the well-documented problems with affordability of homes Greater Cambridge, the councils should carefully consider the consequences of introducing planning policy burdens on new development recognising that the costs of these will ultimately be passed onto the consumer and reduce the ability of new development to viably mitigate its impact or deliver benefits in other areas (e.g. through affordable housing and infrastructure). The soundness of any future plan will turn on among other things its compliance with national planning policy. Paragraph 50, b) of the NPPF states that “Any local requirements for the sustainability of buildings should reflect the Government’s policy for national technical standards.” The Planning Practice Guidance (PPG) expands on this provision stating that policies requiring higher energy performance standards than building regulations “should not be used to set conditions on planning permissions with requirements above the equivalent of the energy requirement of Level 4 of the Code for Sustainable Homes (this is approximately 20% above the current Building Regulations across the build mix).” The ambitions of the plan around energy efficiency should be framed in light this guidance otherwise the resultant policies will not be sound for want of compliance with national policy. Finally, we would emphasise the need for any enhanced energy standards adopted as part of the local plan to incorporate appropriate allowances for viability and feasibility in line with paragraph 153 a) of the NPPF 2019.

When framing their priorities the councils should be mindful that they are working within the parameters of the existing legislative and policy framework as it relates to plan-making. The councils’ broader aspirations should not undermine the key objective of appropriately defining and then meeting housing and other development needs through suitable and deliverable sites. Recognising the national housing shortage and the well-documented problems with affordability of homes Greater Cambridge, the councils should carefully consider the consequences of introducing planning policy burdens on new development recognising that the costs of these will ultimately be passed onto the consumer and reduce the ability of new development to viably mitigate its impact or deliver benefits in other areas (e.g. through affordable housing and infrastructure). The soundness of any future plan will turn on among other things its compliance with national planning policy. Paragraph 50, b) of the NPPF states that “Any local requirements for the sustainability of buildings should reflect the Government’s policy for national technical standards.” The Planning Practice Guidance (PPG) expands on this provision stating that policies requiring higher energy performance standards than building regulations “should not be used to set conditions on planning permissions with requirements above the equivalent of the energy requirement of Level 4 of the Code for Sustainable Homes (this is approximately 20% above the current Building Regulations across the build mix).” The ambitions of the plan around energy efficiency should be framed in light this guidance otherwise the resultant policies will not be sound for want of compliance with national policy. Finally, we would emphasise the need for any enhanced energy standards adopted as part of the local plan to incorporate appropriate allowances for viability and feasibility in line with paragraph 153 a) of the NPPF 2019.

Nothing chosen

When framing their priorities the councils should be mindful that they are working within the parameters of the existing legislative and policy framework as it relates to plan-making. The councils’ broader aspirations should not undermine the key objective of appropriately defining and then meeting housing and other development needs through suitable and deliverable sites. Recognising the national housing shortage and the well-documented problems with affordability of homes Greater Cambridge, the councils should carefully consider the consequences of introducing planning policy burdens on new development recognising that the costs of these will ultimately be passed onto the consumer and reduce the ability of new development to viably mitigate its impact or deliver benefits in other areas (e.g. through affordable housing and infrastructure). The soundness of any future plan will turn on among other things its compliance with national planning policy. Paragraph 50, b) of the NPPF states that “Any local requirements for the sustainability of buildings should reflect the Government’s policy for national technical standards.” The Planning Practice Guidance (PPG) expands on this provision stating that policies requiring higher energy performance standards than building regulations “should not be used to set conditions on planning permissions with requirements above the equivalent of the energy requirement of Level 4 of the Code for Sustainable Homes (this is approximately 20% above the current Building Regulations across the build mix).” The ambitions of the plan around energy efficiency should be framed in light this guidance otherwise the resultant policies will not be sound for want of compliance with national policy. Finally, we would emphasise the need for any enhanced energy standards adopted as part of the local plan to incorporate appropriate allowances for viability and feasibility in line with paragraph 153 a) of the NPPF 2019.

When framing their priorities the councils should be mindful that they are working within the parameters of the existing legislative and policy framework as it relates to plan-making. The councils’ broader aspirations should not undermine the key objective of appropriately defining and then meeting housing and other development needs through suitable and deliverable sites. Recognising the national housing shortage and the well-documented problems with affordability of homes Greater Cambridge, the councils should carefully consider the consequences of introducing planning policy burdens on new development recognising that the costs of these will ultimately be passed onto the consumer and reduce the ability of new development to viably mitigate its impact or deliver benefits in other areas (e.g. through affordable housing and infrastructure). The soundness of any future plan will turn on among other things its compliance with national planning policy. Paragraph 50, b) of the NPPF states that “Any local requirements for the sustainability of buildings should reflect the Government’s policy for national technical standards.” The Planning Practice Guidance (PPG) expands on this provision stating that policies requiring higher energy performance standards than building regulations “should not be used to set conditions on planning permissions with requirements above the equivalent of the energy requirement of Level 4 of the Code for Sustainable Homes (this is approximately 20% above the current Building Regulations across the build mix).” The ambitions of the plan around energy efficiency should be framed in light this guidance otherwise the resultant policies will not be sound for want of compliance with national policy. Finally, we would emphasise the need for any enhanced energy standards adopted as part of the local plan to incorporate appropriate allowances for viability and feasibility in line with paragraph 153 a) of the NPPF 2019.

Yes, strongly agree

Persimmon strongly agrees that Greater Cambridge should plan for a greater number of new homes than required by the councils’ respective minimum housing need figures calculated using the standard methodology. The councils correctly identify affordability as a key issue for this plan to address and this is a particularly urgent concern as the affordability of homes in Greater Cambridge acts as a significant constraint to economic growth of this strategically important area. The affordability problem in and around Cambridge also means that people cannot afford to live close where they work adding to private vehicle use and pressure on the road network. Solving the affordability problem is not just a question of planning for more homes that are specifically affordable as defined in the NPPF but also increasing the number and variety of market homes on offer. Positive and proactive planning now and providing increased flexibility in future housing land supply will ensure that developments in the future remain plan-led and obviate the need for the delivery of unallocated sites.

Whilst Persimmon recognises the need for appropriate diversity in the delivery of housing types and tenures, the quantitative need for and the potential uptake of these must be properly understood if they are to be planned for effectively. The application of any detailed policies must specifically respond to the scale of need and demand and this must be demonstrated through an appropriately robust evidence base. In addition, where a quantitative need and demand is identified for a specific housing type/tenure, we would encourage the councils to proactively plan for these through specific site allocations and appropriately flexible development management policies rather than imposing blanket policy requirements on all sites above a certain threshold. A broad policy allowing for self-build or other specialist housing “exception sites” on land well-related to existing settlement boundaries would be an example of how the councils could meet future specialist housing demand proactively.

Persimmon would emphasise the need for any review of the current nationally-described space standards (NDSS) in Greater Cambridge to be accompanied by sensible and proportionate evidence to understand whether these still need to be applied through the new local plan. In most cases introduction of NDSS reduces market choice and affordability to the detriment of consumers. More floorspace per residential unit does not necessarily equate to more space per person. As house prices are driven up by policy burdens such as the NDSS, individuals (particularly those in need of smaller housing types such as single working professionals) tend to over-occupy the current housing stock (e.g. HMOs) resulting in less space per person than if smaller, more affordable unit types were available. Centre for Cities, an independent, non-partisan urban policy research organisation, published research looking into this issue and found that: “ Reintroducing national minimum space standards would not ensure people have more space per person, because people make choices abou t how much space they want to buy depending on their local housing market. A national minimum standard would have a limited effect in cities where housing is inexpensive and people can afford to buy lots of space. But in expensive cities, minimum floor are as would force people to either pay for bigger (and thereby more expensive) homes than they would wish to, or share a too - large dwelling with other households to save money. ” The research shows that introduction of NDSS in unaffordable places such as Greater Cambridge can have the opposite of its intended effects by reducing housing quality and choice. We would encourage the councils to undertake a wide ranging review of NDSS in the area to understand how well these are working and if they are indeed delivering significantly more space-standard compliant dwellings than would’ve been the case anyway. In terms of other optional technical standards, we would highlight the need for these to be supported by appropriately robust evidence which demonstrates the need for such standards in Greater Cambridge and allow for considerations such as viability and feasibility. Wherever additional housing standards are introduced, their impact on the viability of specific site allocations will need to be appropriately assessed at the local plan stage and infrastructure/affordable housing policy requirements framed accordingly.