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

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: 168411

Received: 14/10/2019

Respondent: MacTaggart and Mickel

Agent: Rapleys LLP

As required by the respective adopted Local Plans, the 5YHLS has been calculated on a joint basis having regard to the combined housing requirement in the plan period 2011 to 2031, and the housing trajectory of both Councils. On this basis, no comments to make on the housing requirement, the buffer (20%), or the approach to the shortfall informing the 5YHLS calculation.

Support

Representation ID: 168412

Received: 14/10/2019

Respondent: MacTaggart and Mickel

Agent: Rapleys LLP

Welcome the opportunity to comment prior to the final version being published. Such an approach is consistent with Government expectations regarding positive engagement between plan-making authorities and the development industry.

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: 168414

Received: 14/10/2019

Respondent: MacTaggart and Mickel

Agent: Rapleys LLP

In principle, the identification of assumptions is consistent with the PPG.

The following comments should be addressed in pursuit of a robust analysis. When selecting sites to be used to act as a barometer for delivery timescales, the Councils have elected to exclude a number of sites they consider to be 'abnormal'. Contrary to the Councils' assertion that these instances are 'abnormal', such occurrences affect many major sites and are not untypical. By choosing to exclude such circumstances, delivery is unduly positively skewed.

The assumptions made on lead-in times appear to relate to the interval between approval and a 'start on site' rather than to first housing completions. The commencement of construction will often involve a long lead in time and it is not unusual for 6-9 months between the start of development and the first houses being finished and released onto the market. Such factors must be accounted for when determining actual housing delivery.

Comment

Representation ID: 168415

Received: 14/10/2019

Respondent: MacTaggart and Mickel

Agent: Rapleys LLP

The delivery rates relied upon by the Councils are very high. The Councils acknowledge that accelerated delivery rates in Cambridge are influenced by the development of flats rather than houses. While build out rates in the two administrative areas will be different, it is important not to over state the number of units that can reasonably be delivered in any one year. Historically, such an approach has led to delivery falling short of projections.

On some of the large strategic sites the Councils have assumed delivery of up to 250 units per annum. This assumption relies on delivery from several sales outlets operating simultaneously. When establishing the credibility of these delivery rates it is important that the Councils consider, on a site by site basis, the likelihood of multiple sales outlets operating concurrently.

Comment

Representation ID: 168416

Received: 14/10/2019

Respondent: MacTaggart and Mickel

Agent: Rapleys LLP

It is also noted that South Cambridgeshire Council is required to prepare an 'Action Plan' because the Housing Delivery Test indicates that delivery has fallen below 95% of the local planning authority's housing requirement over the previous three years. Would welcome the opportunity to engage in the preparation of the action plan to help significantly boost the supply of new homes in the district. The effect of the significant under supply in new homes in the period up to 2018 should not be overlooked.