Comment

Representation ID: 22431

Received: 16/03/2020

Respondent: Gladman Developments

5.2 Question 14: Housing Numbers and Delivery
Proposed Housing Requirement
5.2.1 Draft Policy 1 proposes a housing requirement of 40,550 dwellings for the plan period 2018 to 2038 (2,028 dpa). This reflects the local housing needs for the Greater Norwich Plan Area using the Government’s standardised methodology. Having reviewed the wider evidence base informing the Plan, Gladman is not convinced that the standard method figure alone provides a sufficient level of housing growth for the Greater Norwich Plan Area especially in the context of the ambitious economic growth objectives set out in the draft GNLP. Further work is therefore necessary to understand the link between planned housing and job targets.
5.2.2 The standard method represents the minimum housing needs for the area and considers only demographic need and affordability. The standard method does not account for the housing needed to support economic growth needs or ambitions, nor does it align to commitments made for strategic investments or funding which might influence the level of housing growth required in an area.
5.2.3 PPG confirms the following circumstances in which the adoption of a higher housing requirement above the standard method may be justified3. This includes but is not limited to:
 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);
 Strategic infrastructure improvements that are likely to drive an increase in the homes needed locally;
 An authority agreeing to take on unmet need from neighbouring authorities, as set out in a statement of common ground; and
 On occasion, situations where previous levels of housing delivery in an area, or previous assessments of need are significantly greater than the outcome from the standard method.
5.2.4 The Greater Norwich authorities benefit from the City Deal which commits to facilitating the delivery of 13,000 more jobs than the target set within the joint Core Strategy. Reflecting this commitment, Draft Policy 1 advises a job target of 33,000 jobs over the period 2018 to 2038. This requirement accounts for the remaining job growth associated with the City Deal and the longer term benefits the City Deal is predicted to have for the Greater Norwich economy. This represents an uplift of around 8,000 jobs against the baseline trend forecast as set out through the East of England Forecasting Model which might have otherwise informed the job targets of the emerging Plan.
5.2.5 Despite having influenced the economic growth strategy of the Draft GNLP, the City Deal does not appear to have been considered in determining the housing requirements of the Greater Norwich Draft Plan. This ignores the intricate links between the supply of housing and employment land, and the constraining nature insufficient delivery of housing can have on securing sustainable jobs growth otherwise recognised in Paragraph 81of the NPPF.
5.2.6 To ensure consistency with national planning policy, the authorities should assess to what degree the proposed housing requirement will support the implementation of the jobs growth figures set out in draft Policy 1. Should this assessment show that the supply of housing land planned through the GNLP would fail to provide for a sufficient economically active workforce, an appropriate upward adjustment should be made to the housing requirement to ensure that housing land supply does not act as a constraint to planned levels of economic growth. At present this additional, but important assessment, is missing from the supporting evidence base to the GNLP and is required to ensure that the proposed housing requirement is robust and consistent with national planning policy.
Supply
5.2.7 Gladman welcomes and is supportive in principle of the proposal to allocate surplus housing land in contrast to proposed requirements through the GNLP. This surplus will help secure a significant boost in housing land supply, heighten the deliverability of the defined housing requirement, and ensure that the GNLP is durable to any changes which might occur over the plan period.
5.2.8 The need to secure deliverability is significant in the case of the GNLP where much of the housing requirement is evidently already met by committed developments (around 85%), and in particular, a relatively small number of larger schemes. This includes the Old Catton, Sprowston, Rackheath, and Thorpe St Andrew growth triangle located north and east of Norwich which will provide around 13,500 dwellings, as well as other strategic development sites at Cringleford, Costessey, Long Stratton and Wymondham. Should any of these sites stall or fail to come forward as envisaged, the GNLP will quickly fail given the significant contribution made by these sites to the housing needs of the plan area. It is therefore important to plan for an increased supply and to allow flexibility to account for any potential shortfall at any of these sites.
5.2.9 A targeted buffer of 10% to the housing land supply is currently proposed through the draft Plan. Noting the significant degree of committed developments and the role played by large scale development cited above, Gladman does not consider this buffer to be sufficient and should be increased to no less than 20%. This would provide for a total supply of 48,660 dwellings (8,110 dwellings in excess of the requirement). The adoption of this higher buffer would provide greater certainty that the housing requirement, as currently defined, is met in full.
Contingency
5.2.10 In addition to the proposed buffer to the housing land supply, the GNLP identifies possible locations for further growth as contingency, should sites fail to come forward as envisaged. This includes 1,000 dwellings at Costessey, and the potential for a further 1,000 dwellings at Wymondham.
5.2.11 Further detail about the merits of specific locations for this contingency is set out under separate cover by Gladman. It is however unclear, at this draft stage, as to how the Councils envisage that the contingency sites might come forward when required in the plan period. As drafted the GNLP sets out no mechanism under which these contingency sites might come forward. The GNLP is therefore silent under what conditions these sites might be permitted by the relevant local authority, and what the approach to securing the delivery the proposed contingency locations are. In this regard the GNLP is ineffective, and a revised approach is necessary to secure its deliverability.
5.2.12 Gladman’s preference is for this contingency (at both Costessey and Wymondham) to be included within the Greater Norwich Local Plan as allocations for housing. This position takes into account comments made above in relation to housing need and the case for flexibility in planned levels of supply, should committed and other allocated sites fail to come to fruition. Allocating this land for housing provides the greatest certainty that sites can come forward without delay, sites are available and deliverable for housing, and reduces the need for future review.
5.2.13 Should the Councils disagree with the above, Gladman considers that additional wording is necessary in Draft Policy 1 to set out how contingency sites would come forward. The need for flexibility in this wording is key in order to minimise delay in meeting any arising unmet need and ensure that identified contingency sites are effective in responding to a requirement for an increase in the supply of housing land. As such, any policy requiring first a review of the GNLP before development is permitted at contingency sites should be avoided owing to the significant delay such a process would have, significantly reducing the merits of contingency sites in addressing any housing shortfall.