Greater Cambridge Housing Trajectory and Five Year Housing Land Supply - Main Document

Object

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.

Support

Representation ID: 168559

Received: 14/10/2019

Respondent: Bidwells

There is no dispute regarding the housing requirement as set out in Figure 4.

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.

Comment

Representation ID: 168562

Received: 14/10/2019

Respondent: Bidwells

We have some concerns regarding lead-in times and how the evidence provided is applied. However, these do not affect the sites contested in this assessment and are therefore not considered further.

Support

Representation ID: 168563

Received: 14/10/2019

Respondent: Bidwells

We accept the Councils' evidence on lapse and non-implementation rates.

Object

Representation ID: 168564

Received: 14/10/2019

Respondent: Bidwells

PPG states that clear evidence to demonstrate deliverability may include build-out rates. Build-out rates are affected by several factors:
* housing market
* supply market, including materials and labour
* site specific infrastructure
* affordable housing
* type of housing

Where a housebuilder is known for a site, their average market housing sales rate per outlet should be applied, sourced from their annual financial reports. Where the housebuilder is not known, an average sales rate should be applied. These average-sales rates hide significant fluctuations. These rates do not include affordable housing and therefore the relevant requirement should be added to the sales rates.

The total number of outlets is dependent on the overall size of the development and the saturation of the local housing market. These are averages across the entire build, which is likely to see fluctuations with lower rates at the start and end. On average a site needs a capacity of at least 600 dwellings before a second outlet can be supported.

Object

Representation ID: 168565

Received: 14/10/2019

Respondent: Bidwells

Ridgeons, Cromwell Road, Cambridge

The full planning application has not been consented and should be given only limited weight, particularly given the applicants response in relation to viability. This would suggest that there are ongoing discussions to balance the s106 requests against the viability of the scheme, which could well take some time to resolve.

There is clear evidence that progress is being made on the site through ownership being passed to CIP and that permission has been achieved for the demolition of the existing buildings.

Only 245 dwellings pass the 'clear evidence' test and 50 dwellings should be discounted. Likely to have only one sales outlet with a build rate of 61dpa. No evidence is provided to suggest why significantly higher build rates would be realistic or achievable.

There is a realistic prospect that 183 dwellings are deliverable on this site within the five-year period.

Object

Representation ID: 168566

Received: 14/10/2019

Respondent: Bidwells

Darwin Green (NIAB)

287 dwellings fall within part (a) of the definition of deliverable with 330 dwellings falling within the definition of part (b).

It is likely that both Barratt and David Wilson brands will be used on the site - two sales outlets, therefore a total build rate of 124dpa.

Barratt have indicated that they expected to achieve up to 200dpa. It seems ambitious to assume that this maximum rate could be sustained across the entire build. Two local comparables:
* 'frontage' element of Darwin Green which achieved an average build rate of 34dpa.
* Trumpington Meadows which has two sales outlets and has achieved an average of 102dpa.

These comparables, by the same housebuilder and for a similar product in the same housing market, suggest a lower than average built rate. There is certainly no clear evidence that a significantly higher build rate would be realistic. There is a realistic prospect that 620 dwellings are deliverable on this site within the five-year period.

Object

Representation ID: 168567

Received: 14/10/2019

Respondent: Bidwells

Cambridge East - land north of Cherry Hinton

Outline planning application has yet to be determined and there is an outstanding objection by the Environment Agency. Notable that the agent for the outline planning application expected approval in Summer 2019.

Marshall recently announced that they intend to relocate which will result in the closure of the airport. This may mean that the relocation of the airport equipment and infrastructure is no longer practical given that it would only be in use for a few more years.

The Councils' suggest that "there is no evidence that housing completions will not begin on site within five years". This is the wrong test for a site that only benefits from an allocation. Instead the Councils' need to provide clear evidence that there is a realistic prospect of dwellings being deliverable within the five-year period.

Given the lack of any clear evidence, it is concluded that this site should be removed entirely from the 5YHLS.