Comment

Representation ID: 22269

Received: 16/03/2020

Respondent: Barton Willmore

Q3, Q4 & Q5) Greater Norwich Spatial Profile
2.7 Table 1 highlights the size of Wymondham as a settlement of significantly greater scale than
other centres. It is over double the size of the next settlement (Diss), and the facilities
available in Wymondham reflect that. Further Wymondham is served by a train station with
regular services to the regional employment hubs of Cambridge and Norwich. It is on the A11
linking the cities and within the Cambridge – Norwich Tech Corridor, highlighted in the
previous chapter as a strategic objective for growth. It is an obvious location to accommodate
growth.
2.8 Paragraph 34 acknowledges the residential profile of the area with a high student population
and an ageing population. It is accepted that students will live in smaller accommodation,
but page 16 of the Strategy clearly highlights that 81% of the housing need is for houses. As
such seeking higher density development (i.e. flatted developments) within the City Centre,
or within the Norwich Policy Area, will not deliver this need. High density family houses need
to be delivered in areas that are appropriate to that context, and where those most in needcan access local facilities. The focus of housing within the most urban areas will arguably
deliver housing that is not tailored to need. The Strategy and direction of growth should
clearly correspond to where the need can be provided for – and that is locations that can
deliver a range of 2 to 5-bedroom houses, including the appropriate amount of affordable
housing. Further, consistent with the vision, it should be directed to locations such as the
A11 and Cambridge to Norwich Growth Corridor, rather than such a broad distribution as
advocated. Again, it is clear that housing has been delivered in Wymondham and has delivered
the type of homes tailored to the local need, including 1-bed to 5-bed market and affordable
homes. This makes it a location to ‘rely’ on when actually ‘delivering growth’. In the context
of under-supply, and the unreliability of existing/previous allocations to deliver, the
Authorities should place greater emphasis on where the market is confident it can deliver.
Wymondham is this such location.
2.9 Reference at Paragraph 44 of the Draft Strategy that 87% of the Housing Target has been
delivered is inaccurate. Against a requirement of 22,506 dwellings in the period 2008/09 –
2018/19, only 18,221 dwellings have been delivered (a 4,283 dwelling shortfall), representing
circa. 80% delivery. The situation is even worse in the Norwich Policy Area where, against a
requirement of 20,163 dwellings only 13,994 dwellings have been delivered (a 6,169 dwelling
shortfall), representing only circa. 69% delivery.
2.10 Further reference to 133% of the housing target being delivered between 2015/16 and
2017/18 is wholly misleading, given the shortfall that exists (as highlighted further in
response to Question 9) of 4,283 homes. The shortfall increases to 6,169 homes within the
‘Norwich Policy Area’ where growth has been directed in the previous Plan period to 2026.
This extent of under-delivery requires the Authorities to fully assess how to ensure delivery
of the growth to 2038. It requires a review of where delivery has successfully occurred vs
where it has not, and as necessary re-calibrate the direction and location of growth to those
locations that have met or exceeded delivery requirements such as Wymondham.2.11 Drawing comparison to average performance across the Country is irrelevant, and the extent
of under-delivery we highlight in response to Question 9 should be clearly highlighted here,
as it impacts on affordability of housing, which is as local issue, rather than a national issue,
and highlighted as an acute issue in the Greater Norwich Area, worse than the national
average. It clearly provides the justification for a 20% buffer to be applied rather than the
9% advocated, a matter supported in assertions from the HBF.