3. Approach to Preparing the Greater Cambridge Housing Trajectory and Five Year Supply

Comment

Representation ID: 168376

Received: 06/10/2019

Respondent: Fen Ditton Parish Council

We have two queries about the methodology underpinning the trajectory:
1. what is the consideration of growth in numbers of dwellings in the City due to sub-division of large houses into flats without demolition or building of extensions? Are these captured within the historic data given for numbers of new homes or could this be a flaw in the national methodology?
2. how is the past and future change in commuting patterns from Greater Cambridge dealt with in the demand forecast?

Comment

Representation ID: 168382

Received: 08/10/2019

Respondent: Foxton Parish Council

Para 24: 157 questionnaire sent to developer/builders of sites which met the criteria. 105 competed questionnaires were returned giving a 67% response rate. It is stated that follow ups to the non-responders were carried out but as there are 52 of these, why was more effort not made to pursue these companies for information? Does this explain why the 2019-2024 five year land supply figure for Greater Cambridge is now 5.3 years whereas earlier this year it was 6 years? What other explanations are there?

Comment

Representation ID: 168410

Received: 14/10/2019

Respondent: MacTaggart and Mickel

Agent: Rapleys LLP

The Councils have used the NPPF 2019 definition of deliverable, which is supported.

The obligation to provide 'clear evidence' rests fully on the LPA. Support the approach used by the Councils of using the list of examples of clear evidence to inform a questionnaire sent to all relevant sites, alongside the Councils' assumptions in terms of build out and delivery rates. However, it is unclear how the questionnaire outputs have been weighted to inform the judgements regarding deliverability. Deliverability should consider ownership, planning status and site constraints.

Where a questionnaire has not been returned, the Councils have relied on their own assumptions. This approach fails to take account of the requirement to adduce clear evidence. Failure to respond to an invitation to advise on housing delivery should be treated as a significant impediment to housing supply coming forward within the five year period.

Should have full regard to the commentary set out within recent appeal decisions that have grappled with the matter of deliverability.

It is noted that the Councils continue to include major sites without full planning permission. These sites should be rigorously reviewed in accordance with current deliverability criteria.

Comment

Representation ID: 168413

Received: 14/10/2019

Respondent: MacTaggart and Mickel

Agent: Rapleys LLP

Consistent with the PPG the housing trajectories have been presented with market and affordable housing delivery disaggregated. The document states that where the components are unknown data is presented in the form of a total across both types. While it is recognised that affordable and market housing delivery may not have been confirmed for those sites that are delivering later in the plan period, it is unclear why this information would not be available for all sites that are expected to deliver in the next five years. Indeed if such sites could reasonably fall within the definition of deliverable, there should be a degree of certainty in terms of the projected rates of market and affordable housing in the five year period.

Comment

Representation ID: 168419

Received: 14/10/2019

Respondent: Abbey Properties Cambridgeshire Limited

It is correct to review the housing supply position in case it has altered which evidently is the case. The soundness of the Local Plan was considered against the NPPF (2012). The more recent NPPF (2019) includes a much stricter test on whether sites should be considered to be deliverable.

We have undertaken a thorough review of the alleged supply in South Cambridgeshire. We have not undertaken the same exercise for sites within Cambridge City Council due to time constraints: this should not imply in any way that we agree with the assertions for any site within Cambridge City.

There are many examples of sites which fall short of the clear evidence requirement: these include circumstances where detailed planning permissions and/or the discharge of planning conditions have not taken place; it is unclear whether developers are in place; and historic delays.

Comment

Representation ID: 168449

Received: 14/10/2019

Respondent: Gladman Developments

Gladman raise concerns regarding a number of sites included within the deliverable supply, specifically in Cambridge City, as they are currently occupied by an alternative use and there is no evidence provided to demonstrate that they are capable of coming forward for housing in the short term. Whilst the Council has, in some cases, acknowledged the active use and that the site will not come forward in the plan period, and has consequently taken the site out of the trajectory, this approach has not been applied to all sites.

Comment

Representation ID: 168450

Received: 14/10/2019

Respondent: Gladman Developments

Whilst Gladman acknowledge that the report references the new definition of deliverable and also the types of evidence to be used to provide justification, these need to be taken into proper consideration when determining whether sites should be included in the deliverable supply or not. The change in definition of 'deliverable' is significant.

The PPG provides further details on what constitutes a 'deliverable site'. Furthermore an appeal decision for a residential development in Woolpit, Suffolk deals with the issue of deliverable supply and the revised definition. The burden is now with the Councils to demonstrate that sites are deliverable. Gladman note that the level of information provided by the Councils is detailed and that there is good evidence to suggest the Councils have sought to reach out to landowners, agents and developers to inform the trajectory.

Comment

Representation ID: 168454

Received: 14/10/2019

Respondent: Pigeon Land Ltd

Agent: Savills

We are concerned that projected delivery from some sites has been included in the trajectory, without there being sufficient clear evidence of deliverability, contrary to the policy and guidance in the NPPF / PPG.

The default position is that sites in category (b) should not be included in the 5YHLS unless there is clear evidence of deliverability. It should be noted that PPG ID: 68-007-20190722 is only an indication of what might be considered clear evidence. Whilst the conjunctive word is 'or' it is not the case that one of the forms of evidence given as an example will necessarily be sufficient on its own, rather a rounded view of the evidence available has to be reached.

We are concerned that some sites have been included, that fall into Category (b), for which there does not appear to be sufficient, or indeed in some cases any, clear evidence of deliverability.

Comment

Representation ID: 168500

Received: 14/10/2019

Respondent: Endurance Estates

Agent: Carter Jonas

The information published by the Councils' does not provide any specific review of the delivery of affordable housing.

Data shows that the affordable housing need in Greater Cambridge continues to grow year on year. There may be an even greater shortfall given the Councils' reliance on the delivery of large scale strategic developments / new settlements to provide housing, which often require substantial infrastructure investment thus reducing the amount of affordable homes which can be viably delivered. By way of example, Phases 1 and 2 of Northstowe only secured 20% affordable housing against a policy requirement of 40%. Cambourne West secured 30% affordable housing against a policy requirement of 40%.

In the circumstances of a shortfall in affordable provision, the PPG recommends that the local planning authority consider whether the total housing target should be increased above the OAN in order to provide for more affordable homes.

Comment

Representation ID: 168501

Received: 14/10/2019

Respondent: Endurance Estates

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.

Comment

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.

Comment

Representation ID: 168505

Received: 14/10/2019

Respondent: Laragh House Developments Limited

Agent: Carter Jonas

The information published by the Councils' does not provide any specific review of the delivery of affordable housing.

Data shows that the affordable housing need in Greater Cambridge continues to grow year on year. There may be an even greater shortfall given the Councils' reliance on the delivery of large scale strategic developments / new settlements to provide housing, which often require substantial infrastructure investment thus reducing the amount of affordable homes which can be viably delivered. By way of example, Phases 1 and 2 of Northstowe only secured 20% affordable housing against a policy requirement of 40%. Cambourne West secured 30% affordable housing against a policy requirement of 40%.

In the circumstances of a shortfall in affordable provision, the PPG recommends that the local planning authority consider whether the total housing target should be increased above the OAN in order to provide for more affordable homes.

Comment

Representation ID: 168518

Received: 14/10/2019

Respondent: Bloor Homes Eastern

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.

Comment

Representation ID: 168519

Received: 14/10/2019

Respondent: Bloor Homes Eastern

Agent: Carter Jonas

The information published by the Councils' does not provide any specific review of the delivery of affordable housing.

Data shows that the affordable housing need in Greater Cambridge continues to grow year on year. There may be an even greater shortfall given the Councils' reliance on the delivery of large scale strategic developments / new settlements to provide housing, which often require substantial infrastructure investment thus reducing the amount of affordable homes which can be viably delivered. By way of example, Phases 1 and 2 of Northstowe only secured 20% affordable housing against a policy requirement of 40%. Cambourne West secured 30% affordable housing against a policy requirement of 40%.

In the circumstances of a shortfall in affordable provision, the PPG recommends that the local planning authority consider whether the total housing target should be increased above the OAN in order to provide for more affordable homes.

Comment

Representation ID: 168532

Received: 14/10/2019

Respondent: Axis Land Partnerships

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.

Comment

Representation ID: 168533

Received: 14/10/2019

Respondent: Axis Land Partnerships

Agent: Carter Jonas

The information published by the Councils' does not provide any specific review of the delivery of affordable housing.

Data shows that the affordable housing need in Greater Cambridge continues to grow year on year. There may be an even greater shortfall given the Councils' reliance on the delivery of large scale strategic developments / new settlements to provide housing, which often require substantial infrastructure investment thus reducing the amount of affordable homes which can be viably delivered. By way of example, Phases 1 and 2 of Northstowe only secured 20% affordable housing against a policy requirement of 40%. Cambourne West secured 30% affordable housing against a policy requirement of 40%.

In the circumstances of a shortfall in affordable provision, the PPG recommends that the local planning authority consider whether the total housing target should be increased above the OAN in order to provide for more affordable homes.

Comment

Representation ID: 168544

Received: 14/10/2019

Respondent: Bloomhall Ltd

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.

Comment

Representation ID: 168547

Received: 14/10/2019

Respondent: Bloomhall Ltd

Agent: Carter Jonas

The information published by the Councils' does not provide any specific review of the delivery of affordable housing.

Data shows that the affordable housing need in Greater Cambridge continues to grow year on year. There may be an even greater shortfall given the Councils' reliance on the delivery of large scale strategic developments / new settlements to provide housing, which often require substantial infrastructure investment thus reducing the amount of affordable homes which can be viably delivered. By way of example, Phases 1 and 2 of Northstowe only secured 20% affordable housing against a policy requirement of 40%. Cambourne West secured 30% affordable housing against a policy requirement of 40%.

In the circumstances of a shortfall in affordable provision, the PPG recommends that the local planning authority consider whether the total housing target should be increased above the OAN in order to provide for more affordable homes.

Comment

Representation ID: 168560

Received: 14/10/2019

Respondent: Bidwells

There is a notable change in emphasis in the definition of deliverable from the previous NPPF. All major development with the principal of development established but without detailed planning permission will not normally be deliverable unless there is clear evidence.

'Clear evidence' means the assessment must be sensible, logical and supported by enough information to make it obvious how the conclusions were met. It is not intended to be a definitive assessment of probability of what will be delivered but rather what probably could be delivered in the time period.

It is not clear if the new definition of deliverable is a closed list and sites that do not benefit from an allocation or planning permission should not be included. If it is not a closed list, the evidence necessary to demonstrate that sites are deliverable would be greater for those in part (b). The level of evidence necessary to demonstrate deliverability of sites in part (b) would mean that the inclusion of such sites would be exceptionally rare.

Comment

Representation ID: 168561

Received: 14/10/2019

Respondent: Bidwells

It now seems accepted that sites should not be introduced into the 5YHLS after the base date, but new evidence of the deliverability of sites already under consideration is admissible.