This states that ‘this plan also provides choice and flexibility by ensuring there are enough committed sites to accommodate 9% more homes than “need”.’ CPRE Norfolk disagrees that such a high level of sites should be provided within the GNLP. As a starting point please refer to our response to Q3 where we argue that the insistence of the Government to use the 2014 National Household Projections should be challenged to ensure that the most up-to date figures are used instead. In addition, by proposing not to include windfalls in the buffer the over-allocation of unnecessary housing will be compounded further.

It is very disappointing that there is no mention of phasing as an option within the Draft Plan and Housing Delivery Statement, as this would help to prevent the worst excesses of unnecessary development. 68 Parish and Town Councils in Broadland and South Norfolk (over 37%) have supported CPRE Norfolk on this issue and have signed a pledge to this effect. With this groundswell of grassroots opinion making such a strong case, we urge the GNDP in producing the GNLP to consider phasing seriously as the most reasonable way forward.

With an existing commitment (April 2019) of 33,565 houses available in the current JCS (draft GNLP consultation p44), and a long-term delivery rate (2009-2019) that averages 1,652 net completions per annum (figures from JCS Annual Monitoring Reports,) it is highly likely that the current commitment is sufficient to cover at least 18 years of new housing development i.e. to 2038 as a minimum. In these circumstances there really is no need for any new sites to be allocated in the GNLP.