Object
Greater Cambridge Housing Trajectory and Five Year Housing Land Supply - Main Document
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.
The information contained within the uploaded Housing Land Supply Assessment makes clear that the Councils', whether considered separately or jointly, are not able to demonstrate a five year housing land supply of deliverable sites in accordance with the requirements of the NPPF.