Comment

Draft Greater Norwich Local Plan – Part 1 The Strategy

Representation ID: 21375

Received: 16/03/2020

Respondent: Glavenhill Ltd

Agent: Stephen Flynn

Representation Summary:

Glavenhill Ltd has a number of comments/questions on the following: It would be useful if actual numbers of required homes were specified in the document. Does the delivery percentage figure for 2015/16 and 2017/18 relate to the combined annual requirement for these years? Please can this be clarified? More information is needed on the City Deal: what it is and what it commits the Councils to deliver in terms of extra housing and employment over and above the JCS targets?

Full text:

Paragraph 43 refers to the percentage numbers of required homes which were delivered 2011 to 2019 (87%) and 2015/16 to 2017/18 (133%). It would be useful if actual numbers were specified in the document as well. From the figures given, it is assumed that the numbers mean that 32,033 homes were delivered between 2011 and 2019 out of a JCS target of 36,820. Is this correct?

Paragraph 156 of the consultation document explains that existing commitments (sites which are allocated or with planning permission) provide 82% of the housing growth identified in the new plan to 2038. From the point of view of the reader, it is difficult to understand how there can be both an 87% delivery figure against JCS targets and an almost equally high figure of 82% of the new housing requirement to 2038 made up of carried forward allocations and other commitments making up the required numbers. It would be useful if this could be explained with information provided about the deliverability of sites making up the identified commitment.

Does the delivery percentage figure for 2015/16 and 2017/18 relate to the combined annual requirement for these years? Please can this be clarified?

Paragraph 44 states that in 2018 Greater Norwich had a five-year housing supply. This was only when measured against the Strategic Housing Market Assessment (SHMA) and not against the Joint Core Strategy (JCS). It was disputed at various appeals where Inspectors upheld the view that the SHMA figures held limited weight e.g. APP/L2630/W/15/3039128. Therefore, it can only be claimed to be the Greater Norwich authorities’ opinion that there was a 5-year supply in 2018, rather than a fact. We would suggest that this paragraph is removed from the document as it serves little purpose.

Paragraph 57 vaguely mentions the City Deal but provides no detail about it for readers of the plan. More information is needed on the City Deal – what it is and what it commits the Councils to deliver in terms of extra housing and employment over and above the JCS targets.