We have already commented on our concerns regarding the deliverability of the large housing commitment which makes up 82% of the housing requirement that has been set out to 2038. There is no evidence to assess regarding this at the present time and this should be provided prior to the Regulation 19 stage.

Lanpro also believe that the overall housing requirement figure should be larger than the 44,343 homes set out in the draft plan. It is accepted that the updated NPPF now requires the new Standard Methodology to be used to assess housing need. However, the City Deal numbers have not been added to the need figure generated through the Standard Methodology. It is recognised that the Standard Methodology includes an uplift for affordability, but the NPPG clearly states that:

“The standard method for assessing local housing need provides a minimum starting point in determining the number of homes needed in an area.”

The NPPG recognises that there will be circumstances where it is appropriate to consider whether actual housing need is higher than the Standard Method indicates. It states that circumstances where this may be appropriate include, but are not limited to situations where increases in housing need are likely to exceed past trends because of factors such as:

“growth strategies for the area that are likely to be deliverable, for example where funding is in place to promote and facilitate additional growth (e.g. Housing Deals).”

The agreed City Deal included the delivery of 3000 additional homes on top of JCS targets and an additional 13000 jobs. It is considered that these housing numbers should be added to the overall housing requirement figure.

Paragraph 162 refers to building in flexibility to support higher than trend economic growth incorporating the City Deal through contingency and windfalls only, rather than making it a key part of the strategy and identified housing requirement. If the Greater Norwich Authorities are serious about supporting the Vision set out in the plan for above target economic growth including within the Cambridge-Norwich Tech corridor and are serious about supporting the strategic initiatives of the LEP and Norfolk and Suffolk Economic Plan for jobs growth, then these additional housing numbers should be added to the standard methodology housing need figures to form part of the housing requirement figure. Furthermore, additional employment land should be allocated within the Hi-Tech corridor at Hethel as part of a new Garden Village settlement.

As set out above, we consider that a new settlement at Hethel should be allocated now. We support paragraph 167, which recognises the potential for a longer-term new settlement, provided this is located within the Cambridge Norwich Tech corridor.

We consider that greater clarity should be provided under Policy 1 regarding the housing numbers allocated to Norwich City itself and its fringe parishes to correspond with the preferred allocations document. Greater clarity is also needed regarding the proposed uplift figures. At the moment the table in policy 1 includes uplift as a commitment which is confusing when compared to the preferred new allocations tables which also include uplift. This needs to be properly and clearly explained.