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

Object

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.

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.

Object

Representation ID: 168545

Received: 14/10/2019

Respondent: Bloomhall Ltd

Agent: Carter Jonas

Housing Delivery Test

It is understood that South Cambridgeshire District Council have also published its Housing Delivery Test Action Plan. It is understood that this document has not been published for consultation, however, it is considered that the Action Plan is not in accordance with the requirements of national planning policy and guidance.

The PPG makes clear that where an adopted joint local plan has a joint housing requirement and trajectory, the authorities will be treated as one authority for the purposes of the HDT. SCDC and CCC do not have an adopted joint local with an adopted joint housing requirement. HDT is not related to the Councils' housing trajectories, which project forward as opposed to considering past delivery. The Inspector that examined the Councils' Local Plans gave no consideration to HDT and no confirmation has been received that it is acceptable for the Councils' to be considered jointly for the purposes of HDT.

The Council's published Action Plan focusses solely on the case for considering the HDT jointly and this position is not considered to be supported by guidance. As a result of this focus it is not apparent that the Council has engaged with any of the potential stakeholders or undertaken any analysis of under-delivery in order to ascertain what steps could be taken to assist with this in the future. It is considered that the Action Plan will be ineffective in addressing under delivery.

Object

Representation ID: 168546

Received: 14/10/2019

Respondent: Bloomhall Ltd

Agent: Carter Jonas

Paragraph 028 of the NPPG is considered to provide useful clarification regarding the Councils' position that the housing trajectories for Cambridge and South Cambridgeshire will be considered together for the purposes of phasing of housing delivery, including for calculating 5-year housing land supply. The guidance is clear in that this applies to areas with joint local plans. South Cambridgeshire District Council and Cambridge City Council do not have a joint local plan and their respective plans contain annual housing requirement figures on a single authority basis. It is not, therefore, considered that the Councils' considering their housing trajectories together for the purpose of calculating five year housing land supply accords with national guidance.

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: 168548

Received: 14/10/2019

Respondent: Bloomhall Ltd

Agent: Carter Jonas

Agree that the differentiation between strategic and non-strategic sites is reasonable and sensible. The Councils' have set out Typical Assumptions for Built Out Rates, excluding strategic sites, at Figure 17. This figure does not include all of the information contained at Figure 16. The reasoning for this is not clear. It is also noted that the Councils' have included information on peak delivery but not lowest delivery rates. The most robust approach is considered to be in utilising average figures as this will capture the greatest fluctuations in delivery. Need to take account of the fact that Huntingdonshire Local Plan Inspector modified the delivery rates anticipated for their strategic allocations.

Object

Representation ID: 168549

Received: 14/10/2019

Respondent: Bloomhall Ltd

Agent: Carter Jonas

NIAB Main (Darwin Green)

In the absence of any evidence being presented by the Councils' it is not considered that the 317 dwellings with outline planning permission, and without a reserved matters submitted, will be completed on site within the five year period. These should therefore be removed from the trajectory. The housebuilder has identified market conditions, discharging conditions and delays in the planning application process as the constraints, market factors or cost factors that could delay the delivery of the development. These risks highlight that the more cautious approach set out above is justified. Adjustments should also be made to the trajectory to reflect actual delivery rates that have been achieved on this site over the past four years.

Object

Representation ID: 168550

Received: 14/10/2019

Respondent: Bloomhall Ltd

Agent: Carter Jonas

Land north of Worts Causeway

Despite ongoing pre-application discussions, there is no timetable available for the submission of an outline application. Timescales associated with other comparable allocations on the Cambridge Fringe have therefore been considered. Utilising the average figure is therefore considered to be the most reasonable approach. The site is currently controlled by a promoter rather than a developer or housebuilder. The evidence demonstrates that it is unlikely that housing completions will begin on site within five years. Accordingly, the site is not deliverable in accordance with the NPPF definition and should be removed from the trajectory.

Object

Representation ID: 168551

Received: 14/10/2019

Respondent: Bloomhall Ltd

Agent: Carter Jonas

Land south of Worts Causeway

The documentation does not contain any data regarding lead in times associated with sites where outline planning applications have been made within Cambridge City. Timescales associated with other comparable allocations on the Cambridge Fringe have therefore been considered. Utilising the average figure is therefore considered to be the most reasonable approach. The evidence demonstrates that it is unlikely that housing completions will begin on site within five years. Accordingly, the site is not deliverable in accordance with the NPPF definition and should be removed from the trajectory.

Object

Representation ID: 168552

Received: 14/10/2019

Respondent: Bloomhall Ltd

Agent: Carter Jonas

Cambridge East - North of Newmarket Road

Timescales associated with other comparable allocations on the Cambridge Fringe have therefore been considered. The delivery rates included within the Councils' trajectory have also been considered and are thought to be overly ambitious. The Councils' trajectory is over optimistic and should be amended.