Comment

Representation ID: 22277

Received: 16/03/2020

Respondent: Barton Willmore

Q14) Do you support, object or wish to comment on the approach for housing
numbers and delivery?
2.42 We support the identification of the Government’s standard methodology as the starting point
for calculating the housing requirements of the Plan. This is consistent with the requirements
of the NPPF as the standard methodology is a demographic-based figure which includes an
uplift for affordability, partly accommodating past shortfall.
2.43 Planning Practice Guidance (Paragraph 010 Reference ID 2a-010-20190220) identifies the
circumstances where it may be appropriate to plan for a higher housing need figure than the
standard method indicates including situations where increases in housing are likely to exceed
past trends because of growth strategies or strategic infrastructure improvements.
2.44 The City Deal, which was signed into effect by the Government in December 2013, gives
Greater Norwich increased freedom to help business grow and create economic growth. As
detailed in the City Deal report (December 2013), the deal aims to bring an additional 13,000
jobs and 3,000 homes (above Joint Core Strategy requirements) to the Greater Norwich Area.
As detailed in the Central Norfolk Strategic Housing Market Assessment (June 2017) this
equates to a total of 45,390 jobs over the plan period.2.45 Paragraph 4.19 of the Growth Options Consultation Document (January 2018) identified the
housing requirement may need to increase to support potential job growth arising from the
City Deal, resulting in 1,700 further dwellings being required. No reference to this is included
in any form within the Draft Strategy. Furthermore, 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 13,000City 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.
2.46 Nevertheless, the Draft Strategy confirms the GNLP will seek to over-allocate by means of a
10% buffer (equating to circa. 4,050 dwellings) to ensure delivery. It needs to be clarified
whether this includes some of the dwellings required by the City Deal (8,361 homes as
advocated at figure 101 of the SHMA), thereby reducing the delivery buffer, or if the City
Deal requirement will be in addition to the housing requirements identified in Table 6.
2.47 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. 3,000 of these homes should be delivered by 2026 in accordance
with the commitments of the City.
2.48 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”.
2.49 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.
2.50 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.2.51 The ‘alternative approaches’ to housing numbers identifies that whilst the NPPF encourages
a higher housing requirement, this is not the preferred option as evidence of delivery over
the medium and longer term suggests that higher targets are unlikely to be achievable or
deliverable. We do not believe this position is evidenced, and in fact past poor delivery hasbeen as a result of incorrect sites being allocation and an overreliance on sites within the
Growth Triangle (as detailed above and further in response to Questions 38 – 40).