Comment
Greater Cambridge Housing Trajectory and Five Year Housing Land Supply - Main Document
Representation ID: 168502
Received: 14/10/2019
Respondent: Laragh House Developments Limited
Agent: Carter Jonas
It is considered that the evidence presented by the Councils' to demonstrate that sites are deliverable is lacking. The definition makes clear that the onus is on the Councils' to provide clear evidence. The Councils' have used a different test stating "There is no evidence that the site will not be delivered within five years". This is clearly not in accordance with national policy.
It is also noted that the evidence presented by the Councils' relies heavily on questionnaires received from landowners, promoters and developers. These parties clearly have a vested interest in demonstrating that their land interests are deliverable. It is therefore considered that relying on these alone is not sufficient evidence of a site's deliverability. Rather this needs to be considered in the context of demonstrable lead-in times and delivery rates achieved on comparable sites.
The information contained within the uploaded Housing Land Supply Assessment makes clear that the Councils', whether considered separately or jointly, are not able to demonstrate a five year housing land supply of deliverable sites in accordance with the requirements of the NPPF.