CHAPTER 5 COMMENTS
5.10 The AECOM report of 2017, predates the planning approvals which have subsequently been granted for some 530 homes. The 91 "affordable homes" identified in the AECOM report need to be adjusted to take account of the provisions for affordable homes which have been made as part of the 530 home planning approvals.
5.11 The "need" for 91 affordable homes is not justified due to the issues made in the discussion above. In addition to this the SEA produced by AECOM and published in Oct 2018, highlighted the need for 1 and 2 bedroom flats, but this has not been taken into account by the Parish Council, even though the SEA report postdates the 530 home planning permissions and contains more accurate data on the "need" in Cottenham.
"Meeting the need" Section
* The logic in this section is flawed as the conclusion reached in the later part of the segment are not based on the information provided at the beginning. In item 5.20 confirms the planning approvals for 530 homes and that the locally assessed objective was exceeded by more than 100 homes. Item 5.23 goes on to confirm that from the 520 homes 90 affordable homes would be made available as part of these planning permissions, meaning the AECOM 2017 assessment of 91 will have been met, this is particularly the case when the flats included in item 5.22 are taken into account.
* Item 5.24 the Parish Council make the statement that affordable homes are not locally affordable but provides no justification for why they disagree with the SCDC definition. The Parish Council provides no definition for what "locally affordable" means and given no opportunity for it to be debated.
* In item 5.25 SCDC identified 91 local households fall between local authority intervention and the ability to afford local homes at market rates. However, this does not define the ability of these local householders to afford, "affordable" homes and "locally affordable" homes. In item 5.26 it is stated that AECOMs assessed need is for 91 "locally affordable" homes, however the AECOM report does not use the term "locally affordable", in fact in the AECOM report summary table 39 the report says "...there is no requirement for the Cottenham neighbourhood plan to set its own policy in this area...".
* In summary a report that predates the recent 530 home planning permission should not be used to justify the conclusions of the housing need, unless it is updated by AECOM to take these planning permissions into account. If the AECOM report is not to be updated then the conclusions should take into account the recommendations of the more recent SEA to build 1 or 2 bed flats and prorate the 91 affordable home requirement to take into account people who can afford "affordable" homes and "locally affordable" homes.
Item 5.30, the consultation pre-dates the 530 home planning permissions and therefore does not take into consideration changes in Cottenham residents thoughts now that permission has already been granted for 530 new homes.
Page 39, COH 2-2b states, "Cottenham is particularly vulnerable to flood risk...", which raises the question why is one of the rural exception sites being promoted by the NP when it is actually on the flood plain. Not that any of this is readily apparent from the NP as actual details of the rural exception sites are almost entirely absent.
Page 41, COH 2-3, fig 14 underestimates the number of 1 or 2 bed flats could be built at these locations and therefore the contribution which could be made to the "locally affordable" need.
Page 43, COH 2-4, this has not been updated to take account of the 530 home planning permissions, which means the need for 225 homes identified in 2-4d has already been met, meaning this policy no longer has any justification.
General comment: whilst elsewhere in the NP significant detail is given for other proposed developments (Durman Stearn site for instance) with layout plans and location details, no such information is given for the Rural Exception sites. It is not possible to tell from the NP submitted to SCDC that one of the preferred sites (Broad Lane) is on the flood plain, which directly contradicts the appendix C Drainage and Flooding requirements. It also removes the ability for anybody commenting on the NP to comment directly on the individual rural exception sites, which seems odd given how important the rural exception sites are to the NP housing policy and in particular, given that approval of the NP would effectively give the Parish Council approval to develop the rural exception sites in accordance with Policy COH 2-4. This also hides the fact that to build the 91 "locally affordable" homes using the CLT model could lead to the need to build an additional 250 homes if the example of Stretham CLT is used as a guide, where two thirds market rate houses were needed to fund the one third affordable homes. It seems unlikely that the NP would get a warm welcome if it was known to be promoting 250 new homes in addition to the 530 home already granted planning permission.