The requirement that sites should only be allocated for housing where, having regard to policy requirements, there is a reasonable prospect that housing can be delivered fully accords with para 67 of the NPPF.
Whilst the submission of Delivery Plans as part of a planning application is supported the documents need to recognise that there may be unforeseen material changes in circumstances, which could impact the delivery of an allocation.
The Council’s approach to providing choice and flexibility in terms of housing growth by accommodating 9% more homes than are needed, along with contingency sites, is, in principle, supported.
This buffer will help maintain the supply and delivery of housing, in accordance with the NPPF and specifically the Government’s objective of encouraging authorities to consider more growth than required to meet local housing need, particularly in locations where there is potential for significant economic growth, such as the Cambridge Norwich Tech Corridor.
However, to guard against non-delivery, particularly in relation to the potential failure of larger strategic sites in the Norwich urban area to come forward, a minimum buffer of 10% should be identified. Indeed, the draft GNLP states on page 45 that the Regulation 19 version of the Plan will aim to provide a minimum buffer of 10% (at least 250 further homes), which is likely to be provided through a combination of additional sites proposed through the consultation, and the contingency sites.
This approach will provide certainty for stakeholders, including the public, and ensure that the plan is sufficiently flexible to enable it to respond to changing circumstances.
Based on the foregoing, it is recommended that the contingency locations are upgraded to committed sites. The identification of contingency sites provides ambiguity as to when and where development may be located. This uncertainty has the potential to undermine the ability to ensure that development during the plan period is delivered in a coordinated manner. More specifically, the potential for Wymondham to be required to accommodate between 100 and 1,100 units provides significant uncertainty, making it difficult for stakeholders, such as Norfolk County Council Education, to identify a clear strategy in relation to infrastructure provision.
This is particularly relevant given the under delivery of housing in the Greater Norwich Area between 2011 and 2019, which in locations such as Wymondham has resulted in unplanned and uncoordinated development.
The identification of the Norwich Urban Area and Main Towns, such as Wymondham, as suitable locations for the majority of growth within the Greater Norwich Urban Area, given that they provide a range of services and amenities is supported. For example, Wymondham is identified as a strategic employment location that will make a significant contribution to the Cambridge Norwich Tech Corridor and, accordingly, is a suitable location for additional growth. However, within these locations, clear evidence needs to be provided to demonstrate that there is a realistic prospect of development being delivered on the sites, particularly the large strategic allocations which are classed as existing commitments, but are yet to be delivered.