Comment

Representation ID: 22276

Received: 16/03/2020

Respondent: Barton Willmore

Q13) Do you agree with the proposed Settlement Hierarchy and the proposed
distribution of housing within the hierarchy?
2.33 Simply put, No. Firstly, as highlighted in our response to Question 9, we believe the amount
of homes to be identified within the GNLP should as a very minimum be consistent with
housing need calculated by the Standard Method and then be increased to account for the
Growth Deal, advocated in the SHMA. This would also help make up for the shortfall we have
highlighted against the GNLP to 2026. Second, as detailed in our response to questions 38 to
46, the proposed distribution of housing within the hierarchy is unjustified and would not be
effective at delivering housing requirements over the plan period.
2.34 We would stress that a number of the allocations that appear to have been ‘rolled forward’
are failing to deliver homes. Allocation GT6 (Land at Brook & Laurel Farm) has not yet
commenced, despite permission being granted in June 2014. Work is yet to commence on
Allocation GT11, and we note that planning permission has not yet been granted for the
Larkfleet Homes site East of Broadland Business Park. Combined these sites are anticipated
to deliver 1,450 homes. Accounting for the “Nathaniel Lichfield & Partners Start to Finish –
How Quickly do large scale housing sites deliver” (NLP November 2016) on average these
sites would take 5.3 years to actually deliver houses, of which circa 13 months would be post
approval of planning. The lead in time for smaller sites below 500 units extends to circa 2
years from the grant of planning permission. Sites GT13, GT14, DRA1, HEL1 and REP1 fall
into this category. The AMR provides no evidence of delivery or update on progress. As such
to carry forward such allocations, the Authorities must (a) be confident (through the provision
of clear evidence) that they will be granted planning permission and commence in the Plan
period; and (b) be confident that sites GT6 and GT11 will start delivering units before 2028
given the average build out rates for sites of this size are identified by NLP to represent no
more than 86 dwellings per annum on Greenfield sites and no more than 52 dwellings per
annum on brownfield sites.2.35 In addition, we highlight that Sites GT12 and GT16 are anticipated to deliver 3,500 and 3,000
dwellings respectively in the Plan period. To date neither have commenced – despite being
anticipated to deliver from 2019/2020 and 2016/2017 respectively. In the case of GT12, the
latter phases are dependent on Infrastructure Forward Funding. Neither sites have secured
detailed permission for any phase. Even if permission was to be granted now, accounting for
NLP lead in times, they would not commence before 2021. This is ambitious, and even then
would have to deliver housing at a rate of 220 dwellings per annum in the case of GT12, and
227 dwellings per annum in the case of GT16 (as set out in the AMR which anticipates no
housing on site until 2024). NLP 2016, highlights average build out rates of 171 dwellings per
annum on greenfield sites of this size, reducing to 148 dwellings per annum for brownfieldsites. Based on these averages and the anticipated delivery rates in the 2018/2019 AMR, it
would result in a housing shortfall of over 1,200 homes in itself. Accordingly, these allocations
should be reduced to 2,927 (GT12) and 2,388 (GT16) respectively. The shortfall must be
accounted for elsewhere.
2.36 Further, we would highlight that the sites identified above are within the Growth Triangle,
where there are clearly questions over deliverability. Allocating additional homes to the
Growth triangle in the context of under-delivery on housing to date (a shortfall of 6,169
homes in the NPA), and uncertainty over delivery of sites, would further undermine confidence
in the ability of the GNLP to deliver on its needs to 2038.
2.37 In addition we note that Page 46 of the GNLP highlights uncertainty over the site of Carrow
Works. This accounts for a further 1,200 homes. If there is uncertainty over delivery it should
be removed from the Plan. Accordingly, accounting for Carrow Works, and the reductions to
allocations GT12, and GT16 we have highlighted above, a further 2,400 need to be identified
in the Plan to alternative locations, notwithstanding the additional housing we believe should
be provided for in response to Question 9.
2.38 We would also stress that Long Stratton is subject to 2no. Hybrid applications submitted Jan
and Feb 2018 for 600 dwellings (213 detailed) and 1,275 dwellings (zero detailed)
respectively. Both applications remain undetermined. Based on the NLP lead in times, it is
unlikely either of these will deliver any houses before 2023/24 (accounting for 5.3 years for
schemes of 500-999 dwellings and 5.7 years for schemes of 1,001 – 1,499 dwellings). Based
on average build out rates of 86 dwellings per annum, it is unlikely all of the 1,800 homes
can be delivered within the plan period to 2038, requiring a further adjustment.2.39 Accounting for the matters we highlight in paragraphs 2.33 – 2.36 above, the distribution of
housing set out in Map 7 and Policy 1 should be adjusted. In addition, we strongly object to
simply allocating 1,200 additional homes to South Norfolk Village clusters on the grounds of
sustainable development. These 1,200 homes should be brought back into the GNLP. Together
there is therefore a need to identify additional land for circa 4,000 homes as a minimum,
which would increase to circa 13,000 further homes should growth from the New Deal be
planned for, as we advocate in response to earlier questions.
2.40 As set out in our March 2018 representations we endorse a strategic growth option which
serves and supports an identified ‘Core Area’ whilst focusing and delivering development
along the A11 corridor, fulfilling the Spatial Objectives of supporting the Cambridge to
Norwich Tech Corridor plus locating growth near to jobs and infrastructure. We continue to
advocate this approach which will fulfil the Vision and Objectives of the GNLP, whilst achievingthe full potential of the Cambridge Norwich Tech Corridor in a sustainable way that is
consistent with the Climate Change Statement. This area should be the focus of
accommodating the above shortfall, and the Housing Growth Allocations and Policy 1 should
be updated to reflect that.
2.41 The proposed dispersal should align more closely with the Growth Strategy. As discussed
above there are aspects of the current approach which need amending and will require
additional new allocations to be identified. This should include locating additional
development in Wymondham, one of the largest towns on the Cambridge Norwich Tech
Corridor, and a reduction in reliance of Sites in the Growth Triangle in recognition of past
poor delivery.