Comment

Representation ID: 22432

Received: 16/03/2020

Respondent: Gladman Developments

5.3 Question 16: Review and Five-Year Land Supply
Plan Review
5.3.1 Commitment is made within the GNLP to review after 5-years. Whilst the inclusion of this review within the Plan is welcomed, Gladman considers that wording relating to the timing of this review should be revised to ensure full consistency with national planning policy.
5.3.2 The GNLP should be reviewed within 5 years where necessary in response to significant changes in evidence, or where housing supply falls significantly and cannot be effectively addressed by the policies of the GNLP. This will provide flexibility for the Councils should conditions relevant to policy change significantly and unpredictably between adoption of the Plan and ahead of the 5-yearly review, ensuring that the development plan is responsive and durable to change.
5.3.3 In addition, and consistent with Paragraph 33 of the NPPF, the Councils should aim to complete the 5-year review of the GNLP ahead of the 5-year anniversary of adoption in order to avoid the Plan becoming out-of-date should land requirements depart significantly from evidence of needs. This takes into account the fact that national planning policy advises that the standard method will provide the basis for the calculation of five-year land supply where housing needs evidence supporting existing Local Plans becomes more than five-years old4.
5.3.4 Gladman considers that the future and early review of the GNLP should be inserted in draft Policy 1 or as a new policy.
Five-year land supply
5.3.5 The draft GNLP advises that the five-year housing land supply position for the plan area will be calculated as a whole, rather than on a district or sub-district basis. The move away from a subdistrict basis for this calculation is supported by Gladman. The current approach produces a fiveyear supply position for the Norwich Policy Area, and then a different supply position in the wider Districts beyond this location. This creates unnecessary complexity, reduces the scope for any deficiency in supply to be effectively addressed, and potentially removes the need or responsibility for action to address any supply shortages.
5.3.6 The proposed approach to calculate five-year supply across the GNLP area will address these flaws, securing a role for all of the Greater Norwich Councils in maintaining a sufficient level of supply over the plan period. The approach adopted is also responsive to the Housing Delivery Test which examines supply on this cross-boundary basis providing a single result for the authorities each year.