5. Conclusions
Comment
Greater Cambridge Housing Trajectory and Five Year Housing Land Supply - Main Document
Representation ID: 168363
Received: 23/09/2019
Respondent: Mrs Susan Slator
It is important that a five year land supply is provided accurately.
South Cambs must not be left at the mercy of speculative development again, due to poor planning and the failure of the last plan.
It is important that a five year land supply is provided accurately.
South Cambs must not be left at the mercy of speculative development again, due to poor planning and the failure of the last plan.
Support
Greater Cambridge Housing Trajectory and Five Year Housing Land Supply - Main Document
Representation ID: 168372
Received: 06/10/2019
Respondent: Fen Ditton Parish Council
FDPC welcomes the consultation and especially the demonstration that with the inclusion of the Wing development in the trajectory no other land in Fen Ditton needs to be put forward for housing development to meet the plan targets. We note that local to Fen Ditton, more houses are planned at fuel depot in Ditton Walk and at the Holy Cross site.
Comment
Greater Cambridge Housing Trajectory and Five Year Housing Land Supply - Main Document
Representation ID: 168379
Received: 08/10/2019
Respondent: Foxton Parish Council
Para 53: Both councils have taken the 5 year housing supply from 2019-2024 to be 5.3 years. How can we be certain that this is accurate? Are there any figures to predict if this 5.3 will remain constant up to 2024 or could the 5 year housing supply drop below the critical 5 years thus opening up the whole of Greater Cambridge and South Cambridgeshire in particular to speculative development again?
Main Document
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?
Para 45: The 5 year rolling supply for 2019-2024 shows Cambridge having 5 years supply, Greater Cambridge having 5.3 years supply and South Cambridgeshire having 5.4 years supply. How is the overlap of sites in both areas dealt with?
Para 48: The reduction from 6 years supply for 2019-2024 is stated as delivery timetables being slower than anticipated. Apart from the reasons given for this delay -
* 'Market conditions, including static house price growth, low market confidence, products not being favoured by purchasers, reduced land value and aborted sale of land to a developer;
* Brexit and the uncertain political climate;
* Rising construction costs, including shortage of labour and materials;
* Site specific issues, such as carrying out habitat relocation at the correct time, archaeological investigations, relocation of the existing uses(s), securing site access and multiple landowners,
* Planning obligations and viability of the proposed development,
* Planning enforcement action being taken,
* Delays in determining planning applications and discharge of conditions applications and,
* Delays in the adoption of the Local Plans.'
What planning measures are being put in place to assist developers in keeping or making up the time loss? How will the new outsourcing of certain planning functions of the Greater Cambridge planning department help?
Para 53: Both councils have taken the 5 year housing supply from 2019-2024 to be 5.3 years. How can we be certain that this is accurate? Are there any figures to predict if this 5.3 will remain constant up to 2024 or could the 5 year housing supply drop below the critical 5 years thus opening up the whole of Greater Cambridge and South Cambridgeshire in particular to speculative development again?
As a general point, does SCDC have the planning resources to ensure that the 5 year housing supply is met?
Object
Greater Cambridge Housing Trajectory and Five Year Housing Land Supply - Main Document
Representation ID: 168383
Received: 14/10/2019
Respondent: Bloor Homes Eastern
Agent: Carter Jonas
It is considered that the Councils' five year housing land supply position is marginal. This concern is compounded by the fact that the Councils' spatial strategy is highly reliant on large scale urban extension and new settlements yet it is well-documented that such sites are slow to deliver housing.
The Councils' have been overly optimistic in the assumptions that they have made regarding delivery rates at a number of sites. The Councils' own documentation confirms that the predictions that they have made in the past have been incorrect.
The reasons set out for actual delays or potential delays are numerous and the information published does not provide any commentary on how the Councils would respond if these lead to the delay of completions.
We have calculated the Councils' five year housing land supply position and separately or jointly, the Councils are not able to demonstrate a five year housing land supply of deliverable sites in accordance with the requirements of the NPPF.
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.
Object
Greater Cambridge Housing Trajectory and Five Year Housing Land Supply - Main Document
Representation ID: 168384
Received: 14/10/2019
Respondent: Axis Land Partnerships
Agent: Carter Jonas
It is considered that the Councils' five year housing land supply position is marginal. This concern is compounded by the fact that the Councils' spatial strategy is highly reliant on large scale urban extension and new settlements yet it is well-documented that such sites are slow to deliver housing.
The Councils' have been overly optimistic in the assumptions that they have made regarding delivery rates at a number of sites. The Councils' own documentation confirms that the predictions that they have made in the past have been incorrect.
The reasons set out for actual delays or potential delays are numerous and the information published does not provide any commentary on how the Councils would respond if these lead to the delay of completions.
We have calculated the Councils' five year housing land supply position and separately or jointly, the Councils are not able to demonstrate a five year housing land supply of deliverable sites in accordance with the requirements of the NPPF.
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.
Object
Greater Cambridge Housing Trajectory and Five Year Housing Land Supply - Main Document
Representation ID: 168385
Received: 14/10/2019
Respondent: Bloomhall Ltd
Agent: Carter Jonas
It is considered that the Councils' five year housing land supply position is marginal. This concern is compounded by the fact that the Councils' spatial strategy is highly reliant on large scale urban extension and new settlements yet it is well-documented that such sites are slow to deliver housing.
The Councils' have been overly optimistic in the assumptions that they have made regarding delivery rates at a number of sites. The Councils' own documentation confirms that the predictions that they have made in the past have been incorrect.
The reasons set out for actual delays or potential delays are numerous and the information published does not provide any commentary on how the Councils would respond if these lead to the delay of completions.
We have calculated the Councils' five year housing land supply position and separately or jointly, the Councils are not able to demonstrate a five year housing land supply of deliverable sites in accordance with the requirements of the NPPF.
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.
Object
Greater Cambridge Housing Trajectory and Five Year Housing Land Supply - Main Document
Representation ID: 168386
Received: 14/10/2019
Respondent: Laragh House Developments Limited
Agent: Carter Jonas
It is considered that the Councils' five year housing land supply position is marginal. This concern is compounded by the fact that the Councils' spatial strategy is highly reliant on large scale urban extension and new settlements yet it is well-documented that such sites are slow to deliver housing.
The Councils' have been overly optimistic in the assumptions that they have made regarding delivery rates at a number of sites. The Councils' own documentation confirms that the predictions that they have made in the past have been incorrect.
The reasons set out for actual delays or potential delays are numerous and the information published does not provide any commentary on how the Councils would respond if these lead to the delay of completions.
We have calculated the Councils' five year housing land supply position and separately or jointly, the Councils are not able to demonstrate a five year housing land supply of deliverable sites in accordance with the requirements of the NPPF.
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.
Object
Greater Cambridge Housing Trajectory and Five Year Housing Land Supply - Main Document
Representation ID: 168387
Received: 14/10/2019
Respondent: Endurance Estates
Agent: Carter Jonas
It is considered that the Councils' five year housing land supply position is marginal. This concern is compounded by the fact that the Councils' spatial strategy is highly reliant on large scale urban extension and new settlements yet it is well-documented that such sites are slow to deliver housing.
The Councils' have been overly optimistic in the assumptions that they have made regarding delivery rates at a number of sites. The Councils' own documentation confirms that the predictions that they have made in the past have been incorrect.
The reasons set out for actual delays or potential delays are numerous and the information published does not provide any commentary on how the Councils would respond if these lead to the delay of completions.
We have calculated the Councils' five year housing land supply position and separately or jointly, the Councils are not able to demonstrate a five year housing land supply of deliverable sites in accordance with the requirements of the NPPF.
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.
Comment
Greater Cambridge Housing Trajectory and Five Year Housing Land Supply - Main Document
Representation ID: 168393
Received: 14/10/2019
Respondent: Cambourne Town Council
Support the identification of a 5 year housing land supply, but have significant concerns regarding the marginal level of supply identified at just 5.3 years. Commend the Councils in the production of a robust and broadly reasonable assessment of forecast supply, but wish to highlight a few of points of concern.
We urge the authorities to press on with the production of their new Joint Local Plan in a timely manner and to consider the need for a broader ranger of smaller housing sites in years 5-10 of the current trajectory where there is an overreliance on strategic scale developments.
Comment
Greater Cambridge Housing Trajectory and Five Year Housing Land Supply - Main Document
Representation ID: 168396
Received: 14/10/2019
Respondent: Cambourne Town Council
Struck by the reliance on delivery from just 4 strategic level developments in years 5-10 of the housing trajectory (i.e. Bourn Airfield, Northstowe, Waterbeach and West Cambourne). These sites are expected to deliver 800 dpa (approximately half the total requirement) which raises significant concern regarding the impact of any delays in the delivery of these sites on future 5 year supply calculations.
Comment
Greater Cambridge Housing Trajectory and Five Year Housing Land Supply - Main Document
Representation ID: 168402
Received: 14/10/2019
Respondent: Natural England
We note that the Greater Cambridge Housing Trajectory and Five Year Housing Land Supply Main Document (16 September 2019) demonstrates that Cambridge City Council and South Cambridgeshire District Council will meet their individual housing requirements for 2011-2031 as set out in the Cambridge Local Plan 2018 and South Cambridgeshire Local Plan 2018. Together, as Greater Cambridge the two planning authorities can demonstrate a five year housing land supply, consistent with the approach set out in the adopted Local Plans and found sound by the examining Inspectors. We note that the individual development sites detailed in the document are either allocated in the adopted Local Plans and/or already have planning permission or resolution to grant planning permission. Natural England has provided comments on relevant sites through previous planning consultations hence we have no additional substantive comments to make at this stage.
Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.
We note that the Greater Cambridge Housing Trajectory and Five Year Housing Land Supply Main Document (16 September 2019) demonstrates that Cambridge City Council and South Cambridgeshire District Council will meet their individual housing requirements for 2011-2031 as set out in the Cambridge Local Plan 2018 (adopted in October 2018) and South Cambridgeshire Local Plan 2018 (adopted in September 2018). Together, as Greater Cambridge the two planning authorities can demonstrate a five year housing land supply, consistent with the approach set out in the adopted Local Plans and found sound by the examining Inspectors. We note that the individual development sites detailed in the document are either allocated in the adopted Local Plans and/or already have planning permission or resolution to grant planning permission. Natural England has provided comments on relevant sites through previous planning consultations hence we have no additional substantive comments to make at this stage
Should the proposal be amended in a way which significantly affects its impact on the natural environment, then in accordance with Section 4 of the Natural Environment and Rural Communities Act 2006, please consult Natural England again.
Comment
Greater Cambridge Housing Trajectory and Five Year Housing Land Supply - Main Document
Representation ID: 168404
Received: 14/10/2019
Respondent: Middle Level Commissioners
It is reassuring that a 5-year plan has been achieved as this will minimise the number of speculative sites and thus reduce the amount of abortive works and hence costs on our respective ratepayers.
Object
Greater Cambridge Housing Trajectory and Five Year Housing Land Supply - Main Document
Representation ID: 168444
Received: 14/10/2019
Respondent: Abbey Properties Cambridgeshire Limited
We consider that the 5 year supply of housing within South Cambridgeshire has been over estimated by 2,164 dwellings. The impact of this over estimation is such that the asserted supply reduces below 5 years for South Cambridgeshire to 3.82 years using the Liverpool method, 3.20 years using the Sedgefield method and 3.89 years using the National Methodology. The impact on the Greater Cambridge figures would be similar and in all circumstances below 5 years also.
Comment
Greater Cambridge Housing Trajectory and Five Year Housing Land Supply - Main Document
Representation ID: 168451
Received: 14/10/2019
Respondent: Gladman Developments
The Council's five year supply position set out within the September 2019 report is considered to be marginal, with only a small level of oversupply identified. It would therefore only take one site not to deliver for this position to negatively affect the supply position.
Having reviewed the Councils' Five Year Housing Land Supply Assessment, Gladman do not consider this to provide a realistic and accurate position. Whilst the document does provide detailed site-by-site evidence and justification for a number of the assumptions made, Gladman consider there to be a number of sites where the assumptions applied are overambitious or not realistic. Gladman believe the housing land supply position for Greater Cambridge currently falls short of the required 5 years, and that this position is likely to remain for the next few years.
Object
Greater Cambridge Housing Trajectory and Five Year Housing Land Supply - Main Document
Representation ID: 168465
Received: 14/10/2019
Respondent: Pigeon Land Ltd
Agent: Savills
We conclude that the 5YHLS is below the five-year requirement.
Collectively, the removal from the trajectory of the following ten sites would reduce the projected five year supply by over 500 dwellings:
* Police Station, Parkside, Cambridge - 50 dwellings
* Orchard Park, Parcel COM4 - 42 dwellings
* Land south of Babraham Road, Sawston - 25 dwellings
* Land south of 1b Over Road, Willingham - 26 dwellings
* South of Thompsons Meadow, Trap Road, Guilden Morden - 8 dwellings
* Rear of 79 High Street, Meldreth - 18 dwellings
* Land at Teversham Road, Fulbourn - 110 dwellings
* Land north east of Rampton Road, Cottenham - 154 dwellings
* Land north of Worts Causeway - 140 dwellings
* Land south of Worts' Causeway - 180 dwellings
The variance in lead-in times for the following strategic sites would reduce the projected five-year supply by over 850 dwellings:
* Cambridge East - land north of Cherry Hinton
* Waterbeach New Town
* Bourn Airfield New Village
The adoption of a peak annual delivery rate of c.70 dpa supported by the evidence in the document, on the Darwin Green (NIAB) site alone would reduce the projected five-year supply by over 150 dwellings.
Comment
Greater Cambridge Housing Trajectory and Five Year Housing Land Supply - Main Document
Representation ID: 168475
Received: 11/10/2019
Respondent: Southern & Regional Developments
Agent: Claremont Planning Consultancy Ltd
Inappropriate reliance on strategic allocations to provide majority of numbers.
The allocations for significant housing delivery at New Settlements within South Cambridgeshire is a primary component of the spatial strategy. The identification of multiple new settlements within the area demonstrates an approach that could be seen as inappropriately relying on strategic numbers for delivery. Delivery rates should be approach in a pragmatic away. Concerns are raised that there is a lack of detailed site assessment work to justify proposed levels of housing. The assumed development yields from the allocated sites appear to be ambiguous and crude densities have been applied. These densities do not appear to allow for wider factors associated with developing sites such as required infrastructure and roads, easements, site shapes or the prevailing character of the wider area in which the site is located.
Comment
Greater Cambridge Housing Trajectory and Five Year Housing Land Supply - Main Document
Representation ID: 168481
Received: 11/10/2019
Respondent: Southern & Regional Developments
Agent: Claremont Planning Consultancy Ltd
Housing trajectory is does not appropriately acknowledge market forces and influences beyond the control of the Council.
A realistic housing trajectory is vital in ensuring that a deliverable 5-year housing land supply is maintained. Local Planning Authorities should pragmatically identify sites that can come forward within a 5-year period that reflect practical delivery rates whilst taking into account limitations and other constraints. Cumulative annual delivery rates should take into account the variation in achievability between sites, reflecting site specific considerations.
In the first instance, whilst Cambridge City and South Cambridgeshire District Councils have moved forward in calculating their housing land supply together, the trajectory in relation to the strategic sites in South Cambridgeshire is a significant consideration given the level of housing they are deeming to be delivered within the next 5 years.
Object
Greater Cambridge Housing Trajectory and Five Year Housing Land Supply - Main Document
Representation ID: 168558
Received: 14/10/2019
Respondent: Bidwells
Conclude that there is a deficit which equates to 4.38 to 4.65 years supply, contrary to the Councils' position of 5.3 years. Whilst there are many sites which contribute to the 5YHLS position, these representations only focus on six of the most concerning sites.
The analysis on the six contested sites concludes that they could realistically contribute 1,613 dwellings to the 5YHLS. This is 1,303 dwellings less than the Councils' assumptions.