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

Object

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.

Object

Representation ID: 168488

Received: 14/10/2019

Respondent: Endurance Estates

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.

Object

Representation ID: 168489

Received: 14/10/2019

Respondent: Endurance Estates

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: 168490

Received: 14/10/2019

Respondent: Endurance Estates

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: 168491

Received: 14/10/2019

Respondent: Endurance Estates

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: 168492

Received: 14/10/2019

Respondent: Endurance Estates

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: 168493

Received: 14/10/2019

Respondent: Endurance Estates

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.

Object

Representation ID: 168494

Received: 14/10/2019

Respondent: Endurance Estates

Agent: Carter Jonas

Waterbeach New Town

The Councils' commentary regarding this site is broken into two parts, although it is noted that the figures included in the trajectory are not which adds ambiguity to these. In order to get a better understanding of the likely timescales associated with first completions on this site comparable sites have been considered. With regard to the western portion of the site where there is a resolution to grant planning permission (made in May 2019) it is therefore reasonable to assume that no decision notice will be issued before November 2020. In light of the experience at Northstowe it is also reasonable to assume that it will take a further two years for deliveries to come forward on this site meaning that completions cannot be anticipated until November 2022. Accordingly, the Councils' trajectory is over ambitious and should be amended.

Object

Representation ID: 168495

Received: 14/10/2019

Respondent: Endurance Estates

Agent: Carter Jonas

Bourn Airfield New Village

The typical lead-in times that the Councils' have published do not include assumptions which relate specifically to strategic sites such as this. The only comparable sites are Cambourne and Northstowe - Phase 1. Taking an average of these two sites, it took 4.8 years from the registration of a planning application to first completions. Accordingly, the earliest monitoring year in which completions can be expected at Bourn Airfield New Village is 2022/2023. Even if it is accepted that the site is deliverable in accordance with the NPPF definition, which is considered to be questionable, the Councils' trajectory would need to be amended as follows to reflect lead in times for similar sites.

Object

Representation ID: 168496

Received: 14/10/2019

Respondent: Endurance Estates

Agent: Carter Jonas

Fulbourn & Ida Darwin Hospitals

A resolution to grant outline planning permission was made in August 2017, now more than two years ago. No details have been published regarding the s106 matters that remain outstanding, how these are to be resolved or a timetable for this. It is also noted that the Councils' previous housing trajectory data stated that completions were anticipated on this site in 2020/2021 demonstrating that the Council have been over ambitious in the timescales that they have included for completions from this site previously. The Councils' have not, therefore presented any evidence that housing completions will begin on site within five years.