Growth Options document

SECTION 7 - MONITORING THE PLAN

Context

7.1 Effective monitoring will be central to understanding how well the draft plan's vision and objectives are being achieved. To ensure that the strategy remains on track, the plan will require an effective, appropriate and proportionate monitoring framework to record development progress, assess whether its objectives are being met and gauge the effectiveness of policies, highlighting the need for any policy review at an early stage. Any GNLP policies which are not capable of being monitored effectively may need special justification for inclusion in the plan.

7.2 To do this, LPAs are required to publish an AMR. As a minimum, this must cover the preparation and implementation of local plans and report on Duty to Co-operate activities.

7.3 Since the JCS was originally adopted in March 2011, monitoring has been undertaken against a range of indicators based on that plan's 12 spatial planning objectives, as well as the separate social, economic and environmental indicators deriving from the JCS sustainability appraisal. The results are published in the Greater Norwich authorities' AMR. As of the last published AMR, which reports on progress for the 2015-16 monitoring year, a total of 53 separate monitoring indicators were used. Monitoring of separate local plan documents in the three districts is included within the overall JCS AMR.

Monitoring of the GNLP

7.4 As central and local government resources have reduced in recent years, so monitoring of some contextual plan indicators has also reduced somewhat, with the focus being on key policy information (such as housing and employment land development).

7.5 Given that the GNLP will be allocating individual sites, rather than simply setting out strategic development locations as the JCS did, it will be important to ensure that a detailed monitoring framework is in place to record progress on the implementation and delivery of the plan allocations, as well as the strategic area wide policies. This is particularly important in relation to maintaining a five year housing land supply. One specific issue policy may need to cover, however, is the approach that would be taken to help address a shortfall in the five-year supply of deliverable housing land (see below).

Shortfall in Housing Land Supply

7.6 The NPPF^[135] requires LPAs to "identify and update annually a supply of specific deliverable sites sufficient to provide five years' worth of housing against their housing requirements…". Where this cannot be met from existing permissions and unphased allocations in the local plan, allocations phased for delivery later in the plan period should be brought forward. If, despite these steps, it is still not possible to demonstrate a five-year supply of land, then it may be useful for the GNLP to state how additional sites could be considered in a semi-planned way.

7.7 The most obvious solution is for the Greater Norwich authorities to turn to the annually-updated Housing and Economic Land Availability Assessment (HELAA). There are likely to be unallocated sites in the HELAA list which could potentially come forward for development. These would have the advantage over completely new sites in that they have already undergone a level of assessment, and so there could be a higher level of certainty of their delivery compared to windfall developments, which are inherently somewhat unpredictable.

Options

7.8 One approach would be to not have a specific policy approach in the GNLP on this matter. In the event of a shortfall in housing land supply, the NPPF requires^[136] that the presumption in favour of sustainable development be applied, with reduced weight afforded to "out-of-date" local plan policies. In practical terms, this means that housing applications on unallocated land should not be refused unless the harm would "significantly and demonstrably outweigh the benefits". However, having no policy would not meet the NPPF requirement ^[137] that steps be taken to "boost significantly the supply of housing". This option is therefore considered to be unreasonable.

Option HLS1 – Allow the most appropriate HELAA sites to come forward if there were no 5-year housing land supply Depending on the extent of the housing land supply shortfall, a shortlist of potentially acceptable sites would be in the annual Housing Land Supply report. There would need to be a surplus of HELAA sites identified, to ensure choice and competition to be able to demonstrate that there was a five-year supply. Criteria would need to be developed against which to assess the HELAA sites. The councils would aim to work with developers and landowners to deliver sites identified through this process. This is considered to be the favoured option.

Option HLS2 – Do a review of the GNLP to allocate more deliverable sites if there were no 5-year housing land supply The NPPF[138] states that a local plan "can be reviewed in whole or in part to respond flexibly to changing circumstances", and the HWP suggests that local plans should be reviewed at least every five years. Given the time it takes to prepare or review even a relatively straightforward local plan, this is unlikely to be a quick solution to remedying a housing land supply shortfall, but it is a reasonable alternative.