Comment

Now and next: Inspectors' Reports on Cambridge and South Cambridgeshire Local Plans

It was a long time coming, but finally the Inspectors’ Report into the South Cambridgeshire District Council (SCDC) and Cambridge City Council Local Plans was published on 3 September.

The reports conclude that the Cambridge Local Plan and the South Cambridgeshire Local Plan are both broadly sound and provide an appropriate basis for the planning of the area, provided that a number of main modifications are made.

With regards to SCDC, these modifications include amongst other matters, the confirmation of the council’s intention to carry out an early review of this plan through the preparation of a joint Local Plan with Cambridge City Council and the need to provide more clarity over the calculation of a five year housing land supply. 

We have summarised below the inspectors’ primary comments on key matters and consider what comes next for the area.

Spatial Strategy

The Planning Inspectors wrote to the councils with their interim findings in May 2015 raising some initial queries on a number of matters including the overall development strategy. In short, they were concerned that there was an apparent inconsistency between the Cambridge City and South Cambridgeshire Sustainable Development Strategy Review and the plan’s reliance on meeting development needs in new settlements, rather than in more sustainable locations on the edge of Cambridge, which might have led to a conclusion of unsoundness. The inspectors in their 2015 letter therefore asked for the councils to made clear that the challenges of making such development as sustainable as possible had been addressed, in particular infrastructure requirements and sustainable transport options. At the time, the inspectors considered that the evidence presented to the examination to date indicated that there is a significant funding gap in relation to infrastructure provision. In some cases, the ways in which infrastructure requirements will be met are still at a very early stage of consideration. Moving forward to 2018 nothing much seems to have changed in this respect. As acknowledged by the inspectors, key infrastructure projects such as the segregated bus link is still at an early phase of development. However, on the basis that there is no requirement for these sites to deliver housing in the early years of the plan period consequently there will be an opportunity to review progress through the preparation of the joint local plan with Cambridge City Council. This is actually required by the terms of the Greater Cambridge City Deal and so the inspectors are now satisfied that the spatial strategy is broadly sound in this regard.

Housing Need

The OAHN of 19,000 new homes for South Cambridgeshire, included in the submission draft plan, is derived from the Cambridge Sub Region Strategic Housing Market Assessment (SHMA) (RD/Strat/090). In the inspectors’ interim findings they expressed concerns that the methodology of the 2013 SHMA was not entirely consistent with Planning Policy Guidance (PPG) which was published in 2014. The council commissioned further work to address these issues. The resulting report by Peter Brett Associates (the PBA report) found that the CLG 2012 household projections identify a housing need in the district of 17,579 dwellings for the period 2011-2031. In July 2016 the Government’s 2014-based household projections were issued. The inspectors acknowledge that the PPG states that, wherever possible, assessments of OAHN should be informed by the latest evidence, but that a change does not automatically mean that housing assessments are rendered outdated every time new projections are published.

To avoid further delay in the adoption of the plan, the inspectors have taken the view that the most pragmatic approach is for the latest Government household projections to be considered through the early review of the plan. The inspectors also sympathised with those who raised concerns that the PBA report only dealt with the needs of Cambridge City and South Cambridgeshire, whereas the NPPF requires an assessment of the wider Housing Market Area. However, with the various authorities in the HMA all at different stages in preparing or reviewing their local plans, the inspectors were of the opinion that this work could lead to an excessive delay in completing the current examination if an update for the whole HMA were to be required at this point in time.

As such this was another issue that the inspectors felt could be dealt with as part of an early review of the Plan.With regards to market signals, the Inspectors agreed with the council that an uplift of only 10% would be acceptable. Applying a 10% uplift, (17,579 x 110%) the overall housing need amounts to 19,337 over the plan period. The council decided to revise the housing requirement in the plan to 19,500 new homes and the inspectors considered this approach to be sound and would provide a degree of flexibility.

Housing Land Supply

In light of persistent under-delivery over many years the inspectors concluded that the appropriate buffer is 20%. They confirmed that there has been a shortfall in housing delivery since the start of the plan period of 1,880 dwellings up to 31 March 2017 but that this could be recovered using the Liverpool method. Despite the fact that South Cambs and Cambridge City had not prepared a Joint Plan, the inspectors did endorse the use of a joint housing trajectory, under the current Memorandum of Understanding. This was stated as being justified on the basis that the foundation for the two plans is the Sustainable Development Strategy Review and that the use of the joint trajectory across the two plans will only be a temporary measure until such time as a joint local plan is prepared. The inspectors consider that this will then bring the situation fully into line with the PPG. With regards to the various components of housing supply, the inspectors considered the council’s assessment of supply to be reasonable and evidence-based. We are however not convinced that under the new stricter definition of deliverability as set out in the revised NPPF, that all of these sites would be considered deliverable if considered against these new delivery tests.

Conclusions

To summarise and as expected, it appears that the original significant concerns raised by the inspectors as part of their interim findings have not been suitably resolved and have been only temporarily addressed with the required main modifications .

However, due no doubt to the importance of the Cambridge Sub-Region to the national economy, the inspectors have effectively allowed these issues to be temporarily paused so as to be dealt with at a later date as part of a Local Plan review, which appears to be popular compromise these days judging by a number of recent Inspectors’ Reports.

However, what South Cambs will be unable to mask is their identified poor historical track record in terms of housing delivery. Therefore, whilst the inspectors’ findings will no doubt provide South Cambs with some comfort and a temporary reprieve, we anticipate that their position will once again become vulnerable in the future, notably when the full effect of the new Housing Delivery Test comes into force.

Where Next? 

As is often pronounced by politicians and Government bodies, the Oxford to Cambridge Growth Corridor is a ‘once in a generation opportunity’, but only with an integrated and ambitious strategy to deliver new homes, connectivity and opportunities can it realise its full potential.

The very limited consideration in the Inspectors’ Report to the evidence presented by the industry with regards to the area’s future housing needs and in particular the implications of the economic based projections for growth, seems to sum up the position we have arrived at. This version of the Local Plan very much feels like a warm up act to the main event. This being the case, top billing at the forthcoming review, commencing in 2019, will be the consideration of key issues including housing need, housing distribution and Green Belt.

Despite the plans being found sound, there is no time to pause and reflect. In additional to the Local Plan Review, the Mayor’s Non-Statutory Spatial Plan across Greater Cambridgeshire and the announcement on the route of the rail link between Bedford and Cambridge are due at the end of the year. We will be watching to see how these key milestones could shape the course of growth across this important and dynamic sub region.

Turley and Beacon, part of Turley have a wealth of experience across Cambridge and the East. For further information on the issues raised above and to find out how our teams can assist you, please contact Nichola Traverse-Healy or Steven Kosky.

7 September 2018