(i) Introduction
The Plan seeks to identify land to deliver additional homes beyond the 37,200 dwellings currently in the supply. The Plan therefore has identified land that the Councils’ consider capable of delivering 11,460 dwellings. This includes a 10% buffer in addition to the proposed housing requirement of 2,111 dwellings per annum set out in Policy S/JH so as to ensure flexibility to deal with unforeseen circumstances.
A ‘whole plan buffer’ is both supported and considered necessary to enable the housing requirement to be met, with any failure to meet the requirement likely to mean that the Plan area’s needs are not met contrary to the objectives of national policy. A whole plan buffer future-proofs the plan and makes it more robust.
Sitting behind the ‘First Proposals’ is the November 2020 Development Strategy Options Report, which sets out 8 strategic options for growth. These options are as follows;
• Densification of existing urban areas;
• Edge of Cambridge – Outside Green Belt;
• Edge of Cambridge – Green Belt;
• Dispersal – New Settlements;
• Dispersal – Villages;
• Public Transport Corridors;
• Integrating jobs and homes – southern cluster;
• Growth focussed on Public Transport Nodes – Cambourne/A428
As set out in the Committee version of the ‘First Proposals’, the proposed development strategy for Greater Cambridge is to “direct development to where it has the least climate impact, where active and public transport is the natural choice, where green infrastructure can be delivered alongside new development, and where jobs, services and facilities can be located near to where people live, whilst ensuring all necessary utilities can be provided in a sustainable way”.
Development is expected to be focussed on the edge of Cambridge and by expanding the ‘new settlements’ at Cambourne, Northstowe, Waterbeach and Bourn Airfield. Some minor development is proposed in the rural area to the south of Cambridge (the Rural Southern Cluster), with very limited development across the rest of the Greater Cambridge Plan area.
As set out in these representations it is considered that the higher growth scenarios provide a true reflection of the actual demand for housing linked to reasonable forecasts for employment growth. However, even using the Councils’ ‘medium’ scenario, without prejudice to the reservations in these representations, the Councils’ Preferred Approach represents a significant increase in the requirements for development.
To address this, the Councils are only proposing a limited number of new allocations at urban extensions and new settlements and is seeking to realise additional capacity from existing allocated and committed sites within the confines of the existing strategy. In practice, the risks to delivery mean that the Councils’ stated provision for the ‘medium’ scenario plus a 10% buffer is unlikely to be achieved within the plan period with very limited additional sources of flexibility.
This concentration of development in the Cambridge and the ‘new settlements’ will only further exacerbate the affordability problems in the remainder of the rural settlements. Paragraph 79 of the Framework seeks to promote sustainable development in rural areas to maintain and enhance rural vitality and viability. It is essential, therefore, that the needs of the sustainable rural settlements across the Plan area are assessed and a meaningful level of growth apportioned to them to ensure their ongoing vitality and viability. This will help to preserve and enhance rural services and facilities and allow local rural communities to meet their own needs for housing whilst providing much needed affordable housing in the parts of the borough that suffer with the greatest affordable housing need.
In addition to the need to support a wider spectrum of settlements, a reliance on strategic scale growth should be carefully considered. With the potential for multiple factors to cause delay in the delivery of the large strategic sites including, for example, infrastructure which often takes longer to come forward than envisaged. Arguably the low contingency and over reliance on strategic sites, exposes the Plan to a greater degree of uncertainty and risk. To remedy this, arguably the Plan should propose the allocation of further, non-strategic sites that could be delivered quicker and would ensure a rolling provision of housing.
Within this context an increase in the overall buffer to at least 20% should be considered. This would better address the need to recognise risks to the planned strategy and would also be a more appropriate measure to reflect the Council’s reliance on windfall supply. To ensure that the Plan is effective a significant proportion of any buffer should be accommodated specifically through support for the allocation of sites in the rural area.
In distributing the growth, the Plan could also act to maximize housing supply across the widest possible range of sites, by size and market location, so that house builders of all types and sizes have access to suitable land in order to offer the widest possible range of products. The key to increased housing supply is the number of sales outlets. A wider variety of sites in the widest possible range of locations ensures all types of house builder have access to suitable land which in turn increases housing delivery and the success of the Plan.
(ii) Summary of Housing Delivery Concerns within the First Proposals Strategy Options
There is significant research that considers the lead-in and rate of delivery of development on the scale of that proposed at North-East Cambridge, Northstowe, Cambourne and Waterbeach. The level of infrastructure required and the ability to have multiple builders on one site often results in slower delivery than anticipated by Councils. It should be noted that as is set out in Policy S/DS, in addition to the expected delivery in line with the adopted Local Plans, additional delivery, or the faster delivery of homes, is expected to contribute to the additional 11,640 homes planned for. Whilst it is not necessary to revisit the allocations that have already been subject to Examination and subsequently adopted, it is reasonable to consider, on the basis of new evidence, the contribution that they can make to meeting the overall housing need of 2,111 dwellings per annum plus 10% buffer over the 2020-2041 plan period.
Lichfields’ “Start to finish” (Second Edition) states that the average annual build-out rate for a schemes of 2,000+ dwellings is 160 dpa with a median of 137dpa. It should be acknowledged that not all sites will deliver at this rate. Further, the Lichfields research shows that if a scheme of more than 500 dwellings has an outline permission, then on average it delivers its first home in approximately 3 years. However, from the date at which an outline application is validated, the average figures can be between 5.0 and 8.4 years for the first home to be delivered; such sites would make no contribution to completions in the first five years.
The largest proposed allocation in respect of contribution to meeting the additional housing requirement of 11,640, is that at North-East Cambridge (S/NEC) The Councils are proposing mixed use development including residential uses, with an Area Action Plan currently being prepared. The Councils have assumed that North-East Cambridge will have some early delivery on the Chesterton Sidings parcel, but to date only pre-application discussions have occurred. The build out rates, of 350 dpa are based on the recommendations set out in the Housing Delivery Study. It is unclear how the Councils have determined that the proposed allocation will deliver 3,900 dwellings over the plan period given that the Housing Delivery Study suggests, against an unjustified build-out rate, only 2,200 dwellings will be delivered to 2041.
In respect of Cambridge Airport (S/CE), the main landowner, Marshall of Cambridge, announced in April 2010 that the relocation of Cambridge Airport would not happen before 2031 at least, as there were currently no suitable relocation options. Despite this under Policy S/DS, the site is expected to contribute 2,850 dwellings by 2041. Once again, this figure differs from the yield set out in the Housing Delivery Study, which sets out a maximum contribution of 2,200 dwellings over the plan period.
The Councils have assumed that the site will contribute 50 dwellings in 2033, just two years after the 2031 date for the relocation of the airport. In reality, it is likely that this 2031 deadline for identifying suitable sites and relocating the airport will be missed and even if it were to be hit, given the work that would be required to bring the site into a suitable condition to accommodate residential development, there is very little reasonable chance of anything being delivered in 2033. Realistically, it is unlikely that the site will contribute more than 400 dwellings over the plan period.
In respect of Northstowe, it is noted that in addition to the expected delivery set out in the adopted Development Plan, an additional 750 dwellings (faster delivery of homes already planned) are expected to contribute to the 11,640 additional dwellings being planned for.
As is set out in the latest Annual Monitoring Report, even with 5-housebuilders on-site, the average number of dwellings completed between 2016 and 2020 on the Northstowe site thus far, is just 169 per year. The Councils’ trajectory, set out in the Housing Delivery Study, requires 300 dwellings per annum to be delivered on-site. If the historic rate of delivery were to be carried through over the 2020-2041 plan period only 3,549 dwellings would be delivered against the Councils’ assumption of 6,304 and clearly the additional 750 dwellings being planned for under Policy S/DS would simply contribute to the currently adopted requirement only.
It is noted that significant weight is being placed on the modern methods of construction proposed for Phase II of the Northstowe development and the rate of delivery indicated by Homes England on the other Phases. There appears little by way of clear evidence to suggest that this will result in increased delivery beyond the average already demonstrated.
In line with the standard assumptions being made in respect of delivery, the Housing Delivery Study expects the Waterbeach New Town to deliver between 250 and 300 dwellings per year from 2023/2024, or 5,700 over the plan period to 2041. If the average of 160 dwellings per annum, as is set out in the Lichfield’s research, were to be applied, the contribution that the site could make to meeting the plan period housing requirement would be just 3,120 dwellings. Further, it is accepted, as confirmed in the South Cambridgeshire Local Plan Inspector’s Report, that the site requires significant investment in infrastructure and, realistically, may not start to deliver new housing until the mid or later years of the plan period.
Given the above, there are serious concerns in respect of the ability of a number of strategic allocations to deliver development at the scale that is required to meet the identified housing proposed housing requirement of 2,111 dwellings plus a buffer, let alone the requirement of 2,549 dwellings plus a buffer that is justified on the basis of economic growth and funding.
(iii) Levels of Growth in the Rural Area and Contribution to Overall Supply
Accordingly, the Greater Cambridge Plan fails to identify sufficient land for housing to meet the housing requirement. The identification of additional land should recognise that allocating a range of sites, both in terms of size and location, will provide the best reasonable prospect of meeting and maintaining the supply of housing as is required by national policy.
Page 40 (Figure 10) of the ‘First Proposals’ consultation indicates that the Greater Cambridge Local Plan strategy (including windfalls) would achieve only 18% of growth in rural areas over the 2020 to 2041 period. This is a substantial reduction on the distribution of growth in previous development plans. The Councils’ evidence base demonstrates that this approach is unsound: not effective and not consistent with national policy including providing for flexibility in accordance with Paragraph 82 of the NPPF2021.
The Councils fail to recognise the role of growth in the rural areas in sustaining the benefits associated with recent increases in delivery.
The most recent April 2021 Housing Trajectory suggests that allocations in rural areas of South Cambridgeshire will comprise around 15% of delivery between 2021/22 and 2025/26. This increases to over 40% (around 930dpa in total) when Unallocated Sites with Planning Permission or Resolution to Grant Planning Permission in South Cambridgeshire are included, which predominantly comprise land within the rural areas and a number of schemes granted when the Council was previously unable to demonstrate a robust five year supply. The Councils’ latest Authority Monitoring Report reflects that this will sustain recent levels of completions being disproportionately concentrated in South Cambridgeshire and not principally related to the delivery of Urban Fringe/New Settlement sites.
Adopting these broad assumptions this total (4650 dwellings) would comprise around 50% of the 18% total growth allowed for in rural areas but forecast for delivery ahead of adoption of the Greater Cambridge Local Plan. This would broadly tally with the Councils’ assumptions that windfall in South Cambridgeshire (2,570) plus small allocations in the southern cluster and rural area villages (384 dwellings) and remaining commitments on allocated rural sites (1,903) and unallocated sites (1,539) (6,396 dwellings total) would comprise the remaining potential sources of supply in rural areas. A small proportion of these categories would nonetheless relate to other components of the spatial distribution.
The practical implication is that average growth in the rural areas for the remaining 15 years of the plan period is likely to amount to only 310 dwellings per annum. This reinforces that the evidence in the Housing Delivery Study does not support the conclusion that rates of completions exceeding 2,000 homes can be achieved without a significantly greater proportion of supply from rural areas.
(iv) Windfall and Small Sites Delivery Assumptions
The Councils’ assumptions for windfall supply over the 2020 to 2041 plan period (5,345 dwellings) exceed the total allowance for flexibility within the trajectory (4,400 dwellings). Within these circumstances the Councils plainly cannot claim that the windfall allowance is not central to achieving the planned requirement. The ‘First Proposals’ consultation also accepts that windfall supply is relied upon to ensure at least 10% of homes are delivered on sites of less than 1 hectare, in accordance with Paragraph 69(a) of the NPPF2021.
The Councils’ approach in relation to windfall supply and managing the delivery of small sites as a component of the planned strategy is unsound: not effective and not consistent with national policy. Increases to the assumed level of windfall supply are not supported by robust evidence. Notwithstanding some evidence that rates of supply from unidentified sites have exceeded past estimates Paragraph 71 of the NPPF2021 also requires consideration of expected future trends and the reliability of sources of supply.
The Councils’ Housing Delivery Study does not undertake any analysis of the impact of the Councils’ proposed development strategy and arbitrary limits to levels of growth across the settlement hierarchy in terms of the effect on windfall supply. This is despite paragraph 3.9 suggesting that the potential for additional large windfall development should be assessed where it would be consistent with the Councils’ policies. The arbitrary limits to scheme size are likely to reduce the scale of potential ‘large’ windfall sites relative to past examples and provide an additional incentive to ensure total potential capacity for development is taken up more slowly (across multiple applications) below the threshold for affordable housing contributions).
The Councils’ suggested reasons to depart from the requirements of national policy in NPPF2021 Paragraph 69(a) – stating that if it were to allocate specific sites it would need us to develop large numbers of sites in the rural area in what it claims are potentially unsustainable locations – is not justified or effective.
Allocating suitable sites such as our client’s land at Steeple Morden would overcome the risks identified with the Councils’ reliance on a high level of windfall supply. This would provide overall flexibility and could secure benefits under the policies of the development plan including contributions towards affordable housing and necessary community infrastructure. This is consistent with the Government’s objectives for housing in rural areas, whereas the Councils’ suggested approach does not seek to risks deliberately failing to meet the needs of these communities.
For the avoidance of doubt, updated details of our client’s land submitted with these representations (including a revised Site Boundary at Appendix 1) confirm that the site could suitably be identified for allocation comprising an area no greater than 1 hectare in accordance with national policy.
(v) Neighbourhood Planning (S/JH)
Paragraph 66 of the NPPF2021 strategic policies should also set out a housing requirement for designated neighbourhood areas which reflects the overall strategy for the pattern and scale of development and any relevant allocations.
Page 24 of the ‘First Proposals’ consultation suggests that the approach to providing targets for designated neighbourhood areas will be upon the basis of apportioning a share of the area’s windfall figures and will not form part of the target for new homes to be allocated. This approach is unsound: not positively prepared and not consistent with national policy.
It is clear that the Councils are reliant on assumptions for windfall supply in order to deliver the planned strategy and housing requirement. In these circumstances the approach to apportion levels of windfall development as the basis for neighbourhood plan housing requirements is likely to compound risks to relying to a large extent upon supply from unidentified sites and the Councils’ arbitrary limits to acceptable scales of development at individual settlements based on the proposed policies of the Greater Cambridge Local Plan.
In these circumstances it is unclear how Neighbourhood Plans would, for example, facilitate opportunities to increase levels of housing delivery of secure benefits such as sites contributing towards affordable housing. This reinforces how the overall strategy is likely to fail to address needs within the rural area. By extension, the approach presents additional risks to ensuring housing needs are met in full.
In the context of our client’s site at Steeple Morden it is suggested that the identification of an appropriate housing requirement should reflect the relative sustainability of the Group Village and the ability of the settlement to support an appropriate level of growth. In suitable locations such as Steeple Morden it would be appropriate for the approach to provide a housing requirement for the neighbourhood area and also to facilitate the allocation of sites that would also assist in the wider Plan area’s ability to secure at least 10% of new homes on sites no larger than one hectare.