Comment

Representation ID: 22274

Received: 16/03/2020

Respondent: Barton Willmore

Q9) Do you support, object, or have any comments relating to the approach to
Housing set out in the Delivery Statement?
2.17 We broadly support the approach to Housing set out in the Delivery Statement.
2.18 The Delivery Statement as set out within Section 4 of the Draft Strategy correctly identifies
how the delivery of housing, jobs and infrastructure are interlinked and mutually supportive.
We support the Plan identifying these matters as being interwoven and expect it to promote
and enable growth within key areas which maximise the benefits in respect of these. However,
we maintain that growth within the Villages should be assessed as part of a single Plan.
Arbitrarily directing 1,200 homes on small sites within villages and small settlements where
jobs, infrastructure and supporting services will be least readily available, is not supported.
The whole housing provision should be directed to this Plan comprehensively.2.19 Key to this is the need for the Plan for the right number of homes (accounting for past underdelivery
anticipated growth). The Authorities appear to have simply identified the minimum
number of homes, by referring to the standard method as 40,451 new homes. However, the
NPPG states that the standard method is the ‘minimum’ starting point for determining the
number of homes needed in the area. It does not reflect changing economic circumstances.
The NPPG specifically highlights that growth strategies and housing deals in place to facilitate
greater growth are such reasons to support housing above the standard method. The
Strategic Housing Market Assessment for Central Norfolk, specifically references that the
three authorities of Broadland, Norwich and South Norfolk have agreed a City Deal with
ambitious plans for an additional 13,000 jobs and 3,000 homes by 2026, making their JCS
target 27,000 additional jobs, plus those 13,000 City Deal jobs, over the period 2008-26. This
is referenced in the Economy Chapter and supporting text to Policy 6 and should be reflected
in the Housing Numbers. Accordingly, the SHMA identifies a need for 44,714 new homes
across the period 2016 – 2036, which equates to an average of 2,236 dwellings per annum.
2.20 It is not clear therefore why Table 6 of the GNLP highlights a need for 40,451 new homes.
Further, the SHMA goes on to highlight that to accommodate the additional workers
associated with the City Deal, a further 8,361 new homes should also be planned for. Table
6 of the GNLP should therefore clearly provide as a minimum for 44,714 homes, and given
the commitment to the City Deal, extend that by a further 8,361 homes in the Plan Period
consistent with the NPPG.
2.21 Similarly the NPPG states: “There may, occasionally, also be situations where previous levels
of housing delivery in an area, or previous assessments of need (such as a recently-produced
Strategic Housing Market Assessment) are significantly greater than the outcome from the
standard method. Authorities will need to take this into account when considering whether it
is appropriate to plan for a higher level of need than the standard model suggests”
2.22 Given the change associated with the standard method, and the high amount of housing in
the previous GNLP to 2026, against which there is a significant shortfall, we are strongly of
the view that a 20% buffer should be applied. This would support in the region of 9,000
homes over and above the housing need calculated using the standard method, and would
thus broadly align with the additional homes that would be required consistent with the City
Deal identified within the SHMA.
2.23 Once this additional quantity of housing has been accounted for – i.e. circa 49,000 – 54,000,
the GNLP should then seek to direct additional growth to the most sustainable locations - for
example the A11 and Cambridge to Norwich Tech Corridor as the priority for growth in the
region.
2.24 The Joint Core Strategy set a requirement for a total of 36,820 homes to be constructed over
the period 2008 to 2026, or 2,046 per year. Expected delivery has failed to materialise
resulting in a total shortfall of housing delivery since the start of the Plan period equating to
4,283 homes (a full 2 years of housing requirements). Within the Norwich Policy Area the
shortfall is greater with a cumulative under delivery of 6,169 homes since the start of the

Table 2.1: Greater Norwich/Joint Core Strategy Area Housing requirements and delivery
(from JCS and AMR’s)
Plan period (3.4 years of NPA housing requirements).
[see attached document]

2.25 We strongly believe that the shortfall in delivery should be remedied in the forthcoming Plan
period. Whilst the Authorities have reported an increase in delivery over the past three years
in their Annual Monitoring reports, the latter of these for the period 2018/2019 has been
specifically reported verbally by the Authorities as ‘Draft’. Notwithstanding, the shortfall
remains significant, and the means of calculating the delivery is not supported
2.26 Further, on the basis of previous under-delivery it is essential that housing numbers are
accelerated in the early years of the Plan Period, where we believe a 20% buffer should be
provided to the Five Year Housing Supply across the Greater Norwich Area, with a
commitment in the Plan to accelerate growth in the first five years of the Plan. Whilst it is
recognised that there are external factors that can affect delivery, the collective failure of
the Joint Core Strategy’s planned allocations in not meeting the target represents a real risk
that the existing commitments will not be fully delivered by 2036.
2.27 We actively encourage the Authorities to be ‘pro-active’ and plan for the homes required in
the Growth Deal and increase the buffer to 20% (against ‘need’). This will also make up for
the shortfall against the Core Strategy to date, which we highlight above.
2.28 Further, based on previous failings, housing should only be allocated to sites where there is
a reasonable prospect of delivery (in line with the requirement of the NPPF). The Plan
currently relies on sites (specifically within the Growth Triangle) which have not delivered as
anticipated against their Joint Core Strategy requirements. Evidence is not provided todemonstrate these sites will deliver within the proposed Plan Period which risks the Plan
being found unsound on account of being unjustified, not effective and not positively prepared
on this basis. This is discussed further in our response to Questions 38 – 40.
2.29 In this respect, it will be critical that the Plan allocates deliverable sites in suitable locations.
Footnote 45 to the Delivery Statement specifically states that: “The housing allocations in
this draft plan will only be carried forward to the submission version of the Plan if evidence
is provided to show that they can be delivered by 2038”. This suggests that the Authorities
have not yet undertaken an assessment of when sites will be delivered. The Housing &
Economic Land Availability Assessment (HELAA) is vague on detail over delivery and provides
no anticipated trajectory as would be expected. As detailed further later in this section, the
Growth Strategy fails to achieve this requirement.
2.30 We strongly recommend the Authorities revisits the strategy to support development in
suitable locations where there has been a track record of delivery. Wymondham, identified
as a contingency location, is such a location and continues to experience high demand for
new homes.2.31 As a key location within the Cambridge Norwich Tech Corridor, Wymondham should be
supported for further growth including upgrading the ‘contingency’ to a full allocation.