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

Object

Representation ID: 168497

Received: 14/10/2019

Respondent: Endurance Estates

Agent: Carter Jonas

Cambourne West (land north west of Lower Cambourne)

No reserved matters application has been made for housing as yet although the Council states that this is anticipated in autumn 2019. The information published by the Councils' confirms that the site has multiple landowners. Additionally it confirms that the site is currently controlled by the developers via an option with the land purchase to take place once the reserved matters for housing is approved. This information is clearly contradictory, although it is considered the second statement more accurately sets out the position. There will clearly need to be land deals made outside of the planning process once the first reserved matters for housing is approved. The above clearly calls into the question the deliverability of the site and the information presented does not constitute evidence that housing completions will begin on site within five years. The site should therefore be removed from the trajectory.

Object

Representation ID: 168498

Received: 14/10/2019

Respondent: Endurance Estates

Agent: Carter Jonas

Land south of Babraham Road, Sawston

The commentary states that the landowners will be selecting a developer in 2019. As no developer is on board as yet there can be no certainty regarding a scheme that will come forward on the site or the timescales associated with the submission of an application, its determination and the subsequent timescales for the completion of dwellings on site.

There are just two comparable sites Former Bayer CropScience Site, Hauxton and Cambourne - additional 950 dwellings. This gives an average of 7.5 years from the submission of an application to delivery being achieved. As no application has been received by the Council as yet, this site should clearly be removed from the trajectory as it cannot be considered deliverable.

Comment

Representation ID: 168499

Received: 14/10/2019

Respondent: Endurance Estates

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.

Comment

Representation ID: 168500

Received: 14/10/2019

Respondent: Endurance Estates

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: 168501

Received: 14/10/2019

Respondent: Endurance Estates

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.

Comment

Representation ID: 168574

Received: 14/10/2019

Respondent: Endurance Estates

Agent: Carter Jonas

Given that the Councils' spatial strategies are highly reliant on strategic sites, the lead in times for these sites have been considered further, particularly as it is well documented that such sites are slow to deliver housing. NLP study identifies that the average lead-in time for sites of 2000+ dwellings is just under 7 years from the submission of a planning application, and the lead in time is similar for schemes of 1500-1999 dwellings.