The emphasis on the opportunity to “strengthen Greater Norwich’s role as a key part of the national economy with the Cambridge Norwich Tech corridor becoming an increasingly important axis linking to two other nationally significant growth corridors” is supported.

The delivery statement claims a proactive approach to delivery through only allocating housing sites where a reasonable prospect of delivery, taking into account delivery requirements of the plan can be evidenced.

However, no evidence of delivery of the 36,000 commitments and existing allocations being carried forward is provided within this consultation. It is noted that 13,430 of the commitments are in the Growth Triangle where delivery has been slow to date.

Glavenhill Ltd have queried the lack of availability of delivery evidence and been informed that this information will be provided at the Regulation 19 stage. In our view this is too late for consultees to be able to make any meaningful comments on the likely delivery of these commitments which make up 82% of the required housing numbers to 2038.

In order to be able to test and influence the soundness of the chosen strategy this information is needed at an earlier stage than Regulation 19. It is accepted that the information may change over time, but the current document identifies a commitment figure at this point in time that the Greater Norwich Partnership are asking consultees to assume is deliverable with no evidence to back this up. Evidence of this should be provided prior to Regulation 19 to enable proper opportunity for review and comment by consultees and the potential to suggest changes to the strategy that could be taken on board prior to the Regulation 19 consultation stage.

Compulsory purchase powers are mentioned where delivery turns out not to be in accordance with agreed delivery plans for “strategically significant development”. What is the plan’s definition of “strategically significant development”? This should be defined. How realistic is the use of compulsory purchase when this can be costly and time consuming?

The 9% buffer specified is below the 10% minimum buffer required in the NPPF. It is recognised that two contingency locations have also been identified including a site at Costessey and no specific site at Wymondham.

With the emphasis placed on the deliverability of the selected site allocations and existing commitments as set out in the first part of the Delivery Statement, the size and need for any required future contingency site is assumed to be relatively small. It is not considered that contingency land at both Costessey and Wymondham should be needed and if it is, this would be better allocated as part of an early phase of development at a new settlement at Hethel where it can support jobs growth in the hi-tech corridor and be properly planned to deliver new infrastructure and community facilities taking pressure away from Wymondham in the longer term.

If a contingency option is provided within the plan, it should be clearly identified now and the process for how and when it might be brought forward should be explained. Glavenhill Ltd consider that it would help provide clarity to landowners and developers and speed up delivery if needed.

Currently, the plan identifies reasonable alternative sites in Wymondham for 4000+ homes that could possibly come forward as a contingency if needed. This is a large and vague number that casts doubt on the confidence of the Greater Norwich Partnership about the deliverability of existing commitments and new allocations.