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

Comment

Representation ID: 168474

Received: 11/10/2019

Respondent: Southern & Regional Developments

Agent: Claremont Planning Consultancy Ltd

It is appropriate to separate the windfall assessment between Cambridge City and South Cambridgeshire given the significant difference between their urban nature and rural characteristics. Support is given to the exclusion of garden land from the windfall allowance calculations.

It is considered that the historic assumptions should not be applied to the new windfall figures without compelling evidence that these will realistically be achieved in the future. The figures for both Cambridge City and especially South Cambridge appear overly optimistic.

In regard to rural exception sites, the Council have an allowance for these sites within their windfall allowance. It is considered that a better mechanism for delivery of Rural Exception sites should be to plan them as part of the allocation process (or specifically within Neighbourhood Plans) to provide certainty rather than relying on them coming forward as windfall development.

Comment

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

Representation ID: 168476

Received: 11/10/2019

Respondent: Southern & Regional Developments

Agent: Claremont Planning Consultancy Ltd

Lack of acknowledgement of market influences in delivery rates. Appendix B fails to recognise forces beyond the Council's and developer's control which can significantly impact on rates of delivery. Whilst a focus on Northstowe has been used as a reference, the consideration of market driven forces and the impact it has on the wider economy is relevant to all forms of site delivery.

Comment

Representation ID: 168477

Received: 11/10/2019

Respondent: Southern & Regional Developments

Agent: Claremont Planning Consultancy Ltd

Northstowe

It is recognised that the delivery of Northstowe New Town represents the most deliverable strategic site that will provide the most achievable numbers within the next 5-year period. Phase 1 is now in the process of implementation through build-out by five housebuilders. The trajectory identifies that over the period 2019/2020 to 2023/2024, a total of 1,084 dwellings will be built, which is on average 43 dwellings per year per housebuilder. Whilst this would appear to be a realistic annual delivery rate, Appendix B fails to recognise forces beyond the Council's and developer's control which can significantly impact on rates of delivery.

For example, the questionnaire for Parcel H3 identified that there are concerns relating to market forces that could result in delay of the site moving forward. It is clear that the Councils have not taken into appropriate account the forces that are beyond theirs, and the developers, control that could influence the achievability of a development proposal.

Comment

Representation ID: 168478

Received: 11/10/2019

Respondent: Southern & Regional Developments

Agent: Claremont Planning Consultancy Ltd

Waterbeach New Town

It is recognised that although the Section 106 for the initial phase is yet to be agreed, the package covering infrastructure upgrades has been agreed by the Highway Authority. A Reserved Matters application for the infrastructure upgrades for the first phase is yet to be consented and therefore, the presumption that dwellings will begin to contribute to the 5-year supply from 2020/2021 is not realistic.

This demonstrates the issues that strategic allocations face in terms of infrastructure constraints and their significant requirements to deliver upgrades to ensure that housing can be implemented in practical terms. The Council has not appropriately incorporated any provision for contingency for the delivery of housing numbers.

Comment

Representation ID: 168479

Received: 11/10/2019

Respondent: Southern & Regional Developments

Agent: Claremont Planning Consultancy Ltd

Although the evidence that has been collated on build out rates has shown that there has been moderate to strong delivery rates within both Council areas, it is maintained that the position of the Council remains presumptuous when looking over the longer term.

Comment

Representation ID: 168480

Received: 11/10/2019

Respondent: Southern & Regional Developments

Agent: Claremont Planning Consultancy Ltd

Paragraph C.56 of the appendix establishes that the lapse rates of the Council are optimistic in comparison to the national average. Whilst this is reflective of the historically robust delivery of the Councils, this should not wholly inform the strategy moving forward that establishes the 5-year housing land supply.

The same paragraph also establishes the presumption that these lapse rates will continue in "reflection of the strong housing market in the area." Although this has been the case previously, which has provided for a rapid build out for most developers engaging with this strong market trend, this demonstrates the position that is being taken by the Council which is based on presumption. Given that the housing market is vulnerable to outside influences beyond the control of the Councils, it is not appropriate for this presumption to be continued without the incorporation of any contingency.

Comment

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

Representation ID: 168482

Received: 11/10/2019

Respondent: Southern & Regional Developments

Agent: Claremont Planning Consultancy Ltd

Northstowe - Phase 1

The site has multiple avenues for implementation and this provides a strong basis for delivery as the risk of delay is shared between multiple builders. It is recognised that a number of parcels are currently being actively delivered and therefore are robustly and materially contributing towards the housing supply of the Councils.

However, it is considered that the position of Parcels H8 and H9 does not demonstrate assurance of delivery that is required to calculate an accurate housing trajectory. These sites benefit from an extant outline consent, but currently do not have the requisite Reserved Matters permissions to provide for their delivery. Parcels H8 and H9 (203 dwellings) are yet to be granted their detailed consent, without which they cannot be delivered. Objection is raised to the identified delivery of these parcels as this does not demonstrate a realistic approach, especially where Barratt Homes have not provided a response to the Council.

Object

Representation ID: 168483

Received: 11/10/2019

Respondent: Southern & Regional Developments

Agent: Claremont Planning Consultancy Ltd

Northstowe - Phase 2

Concern is raised in respect of the timing of Phase 2. This is considered to be overly optimistic given the conditions imposed on the outline consent that restrict any dwellings from being occupied on Phase 2 prior to the A14 improvements. It is suggested that the potential delays over the delivery of this large infrastructure scheme have not been adequately taken into consideration. The timing identified by the developer is optimistic who anticipates construction on the first houses in mid-2020 and it is understood the Reserved Matters are not even under consideration yet.

If the trajectory is to accurately reflect the delivery rates of housing, a more conservative, but realistic, approach is required whereby the act of implementing presumptive delivery rates is removed.