Comment

Representation ID: 22225

Received: 16/03/2020

Respondent: Westmere Homes

Agent: Armstrong Rigg Planning

We have concerns in respect of the housing strategy set by the plan, both in terms of the basic housing target and the way in which these are to be delivered. In short, these concerns relate to the less than aspirational housing figures included in the plan and a failure to recognise the significant growth that an escalation in local job creation will place on the housing market.

Fundamentally we consider that the plan should be doing more to seize on the challenges and opportunities presented by two key economic growth strategies in the region, ensuring that their ambitions can be achieved. Currently the baseline housing need for the plan period 2018-2038 is 40,541 new dwellings representing Greater Norwich’s Local Housing Need (LHN) devised using the government’s Standard Methodology. This approach is in line with the NPPF’s minimum requirements described at paragraph 60 of the Framework.

The plan then proposes to identify sufficient allocations to achieve this requirement plus an additional 10% buffer, required by paragraph 73 of the NPPF to “account for any fluctuation in the market” during the course of the following year. Essentially the plan’s housing requirement comprises close on the bear minimum policy-compliant figure required by the NPPF and certainly does little to recognise additional known factors that will no doubt influence the demand for new homes across the plan area.

Indeed, Planning Practice Guidance (PPG) reaffirms that the standard method provides a minimum starting point in determining the number of homes needed in an area and that there will be circumstances where it is appropriate to consider whether actual housing need is higher than the standard method indicates. The PPG then advises that circumstances where setting a higher housing requirement may be appropriate would include the following two scenarios:

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“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); (and)
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strategic infrastructure improvements that are likely to drive an increase in the homes needed locally…”


Both of these factors are in play in respect of the GNLP.

Firstly, the ongoing Greater Norwich City Deal includes the commitment of the Greater Norwich Growth Board to secure significant infrastructure funding totalling £440 million along with the delivery of 3,000 additional homes at the city by 2026. Whilst it is recognised that the development requirements of the Deal have been facilitated in part by the allocation of 3,000 additional homes in the adopted Growth Triangle Area Action Plan (GTAAP) the delivery of these strategic housing sites has been slow. To this end the emerging GNLP offers the opportunity to provide fresh stimulus to achieving the ambitions of the City Deal prior to 2026 to make up for any shortfall in new jobs and housing.

It does not, however, appear that the plan has grasped this opportunity. Indeed, Norwich City Council in its report to its Sustainable Development Panel on 15th January 2020, raises identical concerns, stating that “the level of growth proposed in the GNLP is considered insufficient to address the growth needs of Greater Norwich as a whole and the Norwich Urban Area in particular, and lacks the ambition express ed through the previous Joint Core Strategy and the Greater Norwich City Deal” .

Secondly, it is vital that the GNLP responds to the ambitions of the Cambridge Norwich Tech Corridor (CNTC), the vision of which seeks to attract 26,000 additional jobs and 46,000 further residents to the corridor prior to 2031. At this stage it is apparent that, whilst the CNTC proposals would be hugely positive for the city area, they currently represent what is still little more than an aspirational programme for growth with limited delivery mechanisms in place. This is where the GNLP must play a major role in making the CNTC vision a reality.

To the plan’s credit it is noted that the spatial distribution of growth included in the draft strategy orientates a high proportion of the plan area’s homes towards the corridor. What is a concern, however, is that the overall housing target for the plan fails to recognise that the CNTC proposals, and the significant investment and jobs growth that will hopefully come with them, will likely result in an increased housing demand above and beyond the baseline requirement calculated using the Government’s Standard Methodology. The strategy of skewing the delivery of new homes which are already required to meet the needs of the local population towards the corridor to satisfy the CNTC’s aspiration does not represent a positive planning response. Instead this will simply create an imbalance in housing delivery across the plan area.

One of the options put forward in the previous Regulation 18 GNLP consultation in March 2018 was to provide an additional uplift in the housing requirement to take account of the City Deal. However, this approach was discounted as it was considered that the uplift applied built into the LHN figure (i.e. that proposed to tackle local issues in respect of affordability) was sufficient swell to accommodate the demands of the City Deal. Assessment of this approach did not even consider the additional implications of the CNTC. We were strong advocates of the City Deal uplift then – little has changed to lead us to alter this view. To simply maintain a figure close to the basic LHN as the need housing figure for the plan demonstrates a critical misunderstanding of the way in which the figure is calculated. Indeed, the absence of an appropriate uplift fails to reflect the fact that the standard method is a ‘policy off’ calculation of the housing requirement and any adjustments required to due to ‘policy on’ decisions (i.e. to sign a City Deal) should be factored in further.

Indeed, we note that the SHMA published in April 2017 identifies that the jobs growth facilitated by the City Deal would likely result in a demand for approximately 8,361 new homes above and beyond those required as a result of general demographic change over the period until 2036. Even when deducting the 3,000 dwellings planned for in the GTAAP this results in an additional requirement of 5,361 homes that appear not to have been considered when setting the GNLP housing requirement.

On this basis we consider that the OAN proposed by the plan falls short of adequately responding to local demand by an approximate 5,4002 homes. This is before the additional demand generated by the CNTC is taken into account. In which case the absolute minimum housing requirement for the GNLP should be somewhere in the region of 46,0003 dwellings before any NPPF paragraph 73 buffer is applied. In which case it is our view that upon the application of the appropriate buffer the GNLP should be planning for somewhere between 48,300 and 50,6004 dwellings as a minimum based on the demand generated by the City Deal alone. In addition, we would urge officers to undertake the work necessary to quantify the impact of the CNTC – the draw of the Corridor will inevitably result in the eventual housing figure rising further.