Object

Representation ID: 9065

Received: 12/11/2021

Respondent: Colmworth Parish Council

Agent: Troy Planning + Design

8.1. Paragraph 74 of the NPPF states that: “Strategic policies should include a trajectory illustrating the expected rate of housing delivery over the plan period, and all plans should consider whether it is appropriate to set out the anticipated rate of development for specific sites”.
8.2. Despite the requirement of the NPPF, he Draft Local Plan fails to include a housing trajectory so that consultees can comment on the potential timing of housing delivery and the need for supporting infrastructure that needs to be delivered in close coordination. This makes it rather difficult to comment on any delivery assumptions for particular options or sites when the Council has not considered this despite it selected its preferred development options. The Draft Local Plan states:
“As well as setting the housing requirement for the plan period, the plan for submission will also include a trajectory to provide an indication of the timing of the delivery of the housing sites which are identified to meet the target. This will flow from the identification of the plan strategy and work on detailed site assessment and a greater understanding of the timing of the delivery of infrastructure needed to support growth.”
8.3. CPC considers that BBC has failed to appropriately outline how 12,500 homes is deliverable within the plan period and is concerned that there has been insufficient regard to the time taken for new developments to pass through both the planning and construction phases.
8.4. The Lichfields ‘From Start to Finish’ Review Second Edition (2020) and the Letwin Review (2018) highlight the delays with the delivery of large development proposals should not be underestimated as there will be many aspects of housing trajectory that are beyond the immediate control of a local planning authority.
8.5. For larger sites (2000+ homes), the Lichfield Report(2020) outlines an average lead in time of 8.4 years for the average time from validation of the first planning application to the first dwelling being completed. This is based on an average build-out rate of 160 dwellings per annum. On this basis and in the case of Dennybrook, it would take 15.6 years to deliver the figure of 2,500 dwellings set out in the Draft Local Plan. If one were to add the average lead in time to these 15.6 years, it would equate to 24 years from the validation of the first planning application.
8.6. The Letwin Review (2018) is also helpful in outlining a median build-out rate for large sites at 15.5 years.

INCLUDES FIGURE 8.1 TIMELINE FOR THE DELIVERY OF STRATEGIC HOUSING SITES - LICHFIELDS REVIEW (2020)

8.7. This demonstrates that the Dennybrook site and other larger sites cannot be delivered within the stated plan period of 2040 and would not make any meaningful contribution to the Council’s housing needs for many years to come.
8.8. The land promoted for development at Dennybrook is owned by multiple landowners and by our estimate approximately 56 land parcels. This highlights the complexity of the land assembly and delivery issues that the scheme would likely face if it were to be selected. Please note the landownership map is based on an initial assessment of HM Land Registry information and would need to be confirmed by BBC and the landowners as to its accuracy.

INCLUDES FIGURE 8.2 LANDOWNERSHIP PARCELS DENNYBROOK AREA

8.9. BBC’s options presented fail to reflect the lead times associated with various stages of the planning process, including:
• The preparation of relevant Development Plan Documents, Supplementary Planning Documents or Design Codes which aid the delivery of larger sites;
• The Pre-application process, including consultation and engagement with relevant consultees and stakeholders;
• Potential delays in determining Outline planning permissions;
• Approval of Reserved Matters and agreement of relevant phasing;
• The discharge of conditions;
• The preparatory site works, to be informed by site-specific survey recommendations and monitoring before commencement;
• Securing of relevant funding (including S106 and CIL); and
• Delivery of on-site and off-site infrastructure, (associated with larger sites and the creation of a new settlement).
8.10. Delivery will also rely on cooperation with adjoining authorities and liaison and negotiation with statutory consultees. Even the slightest delay in the start date will result in a slower performance, which is then likely to render the assumed delivery rates unachievable.
8.11. Overall, CPC considers that the preparation of a potential housing trajectory is urgently needed, considering a more realistic rate of delivery then the crude assumptions included in the Draft Local Plan. Further evidence gathering should also assess whether BBC should be considering a larger number of smaller sites to meet housing delivery across the Local Plan period.
8.12. The potential for up to 2,500 homes in one location such as Dennybrook and potentially other sites nearby could flood the housing market within one location impacting on market choice and resiliency of the local housing market which will further impact on the ability to delivery homes quickly
8.13. The Council’s poorly thought-out assumptions regarding housing delivery and lack of a housing trajectory result in the Draft Local Plan being currently unjustified and requiring much further evidence looking closely at what could realistically be delivered sustainably in the borough.