SCDC revealed today that it had received a letter from Laura Graham, the Planning Inspector examining the Draft Local Development Plan.
In her letter Ms Graham pointed out some inconsistencies in the plan as it stands and that the way in which the Council’s evidence base was presented did not give a clear understanding of how the various elements of sustainable development were assessed.
The three key issues raised in the letter are as follows:
Overall Development Strategy
The Inspector question the Council’s approach to concentrating development in new self contained settlements as opposed to on the edge of Cambrige, considering the issue of sustainability. The letter states that “The consideration of new settlements finds that “depending on their overall scale new settlements should be sustainable due to their self- containment…” However, the assessment notes the various challenges to the delivery of self-contained settlements and that out-commuting to workplaces and other facilities and services is likely.”
The Inspector also seem to indicate that there were shortcomings in the Green Belt Review, and that the Council had not considered sufficiently the need to create sustainable development on the urban edge of Cambridge by potentially releasing more land.
The letter also went on to state that according to the Councils’s own figures, “A situation where almost half of new allocations are at the third tier of the (spatial strategy) sequence does not appear to support the contention that the Plans accord with the SDSR”
In addition, the Inspector pointed out that “the Council had not made very clear how it would overcome the challenges of making new settlements sustainable, in particular the infrastructure and transport requirements”.
She specifically mentioned the case of Bourn Airfield Development (BAD) proposal, where the Council had proposed a segregated bus link to serve the new settlement. She said “The evidence the Councils presented showed that little work has yet been done on the feasibility of, or options of such a scheme as the off-line route proposed.
The likely difficulties of land assembly, apart from any other considerations, could well have significant implications for cost and timing which are as yet unknown. The lack of evidence available at this stage does not provide any reassurance that the Plans will deliver sustainable development, bearing in mind the reservations expressed in the SDSR”.
Objectively Assessed Need for Housing
The Inspector observed that it is generally accepted that there is a chronic shortage of affordable housing in Cambridge. But she then went on to say that the Councils had not provided evidence to show that the Strategic Housing Market Assessment (SHMA) had taken into account market signals relating to affordability.
She also indicated that the figures of 14,000 for Cambridge and 19,000 for South Cambridgeshire might be at the lower end of what is needed. Some land promoters had indicated from their calculations that the combined authorities would need up to 43,000 homes in the plan period.
The Council, it would seem, would need to revise upwards, its projection for affordable housing.
Conformity with Revisions to National Planning Policy
The Inspector has also indicated that aspects of the two local plans do not take into account guidelines published in two recent Written Ministerial Statements (WMS), in relation to the provision of affordable housing on small sites less than 10 dwellings, housing standards and car parking provision. She therefore advised the Councils to undertake a rigorous audit of both plans and propose modifications to ensure compliance with both WMSs.
Next Steps
This is the Inspectors conclusion statement:
In the circumstances, we consider that the best course of action would be for the Examinations to be suspended while the Councils revisit the sustainability appraisals so as to appraise all reasonable alternatives (including sites on the urban edge) to the same level as the preferred option, and to suggest modifications based on that work.
For the avoidance of any doubt this letter should not be interpreted as an indication that further releases of Green Belt land would be necessary to ensure soundness.
We envisage that further modifications would either align the plans with the SDSR; or more fully explain the reasons for departing from that Strategy together with a clearer and more fully evidenced explanation of how the challenges of delivering sustainable development in the proposed new settlements will be met.
During the suspension further work could be undertaken on the other issues raised in this letter
My Comments:
I am not entirely surprised by the preliminary conclusion that the Inspector has reached. Whilst it puts SCDC in a difficult position of having to go back to the drawing board on some issues, it vindicates the arguments that those of us who have raised questions about the suitability of BAD, especially in relation to transport and infrastructure issues. We told SCDC, but it would not listen.
StopBAD have campaigned long and hard, and we should appreciate the work that all the volunteers have done to date to put forward the case for Stopping BAD.
Whilst the examination has not considered BAD in its own merit, it is also clear from existing information that it would also have been found wanting with respect to the number of houses being proposed for the site.
I just hope going forward, SCDC will be more transparent and clearer in how it presents its strategy and information, actually listen to local people instead of pretending to do so, and undertakes a rigorous appraisal of the infrastructure implications of all the proposed new settlements, in particular BAD.
I am sure there will be more to report next week after we have had time to digest the implications of the findings.