Comment
Draft Greater Norwich Local Plan – Part 1 The Strategy
Representation ID: 22641
Received: 13/03/2020
Respondent: M Scott Properties Ltd
Number of people: 2
Agent: Bidwells
The following comments relate to the Greater Norwich Local Plan, Interim Viability Study, prepared by NPS Group (November, 19).
Whilst there is general support for the approach adopted and the collaborative approach that the GNLP Team are seeking to adopt, there is concern that the assumptions made within the Viability Study in relation to amongst other things, sales values, build costs and benchmark land values are too generic and not backed up by comparable evidence. Further evidence on this is provided below.
In addition, there is concern that the typologies used within the Viability Study are both too general and do not reflect the allocations within the draft GNLP. For example, the largest size development appraised within the Viability Study is 600 units, notwithstanding the fact that a number of the carried forward allocations / preferred sites are well in excess of this figure. These larger sites are likely to require the more significant infrastructure obligations i.e. primary schools and health centres, so an assessment of viability and the implications for deliverability is key. To ensure a more robust and realistic approach we would suggest that site specific viability studies are undertaken of a selection of the preferred sites of varying sizes.
As part of this work, consideration should be given to whether it is viable for some of the larger strategic sites, which have high infrastructure costs associated with their delivery i.e. the requirement to provide schools and health centres on land which otherwise would be land developable for alternative uses, to pay the Community Infrastructure Levy, in addition to the policy requirements of the Local Plan.
The potential for infrastructure costs which are specific to larger strategic sites to be secured by appropriate and negotiable Section 106 planning obligations, in order to ensure that such sites are deliverable and, importantly, that there is certainty regarding the timely delivery of the infrastructure on site, should be fully explored. This approach, which has been adopted by Mid Suffolk District Council, is entirely consistent with the Community Infrastructure Regulations (2019).
In addition to the foregoing, the following comments are made on the Interim Viability Study, with specific regard to Policy GNLP 0337, Land between Fir Covert Road and Reepham Road, Taverham and Typology 9.
The assumed land values are too low and not representative of market values. Comparable evidence needs to be provided to justify the figures used.
The assumption that 54% of dwellings are 3 bedroom is considered high. It is considered based on evidence of local need that the housing mix should be more focused towards smaller dwellings to reflect market requirements.
There should be more consideration of demographics. In our view, the identified housing mix should include a significant number of bungalows as the greatest rise within the age groups occurs in the 65 plus band. This will influence build cost, densities and sales values and is fundamental on any strategic site.
It would appear an error has been made within Table 4 in relation to density. A target of 25 dph nett would be achievable but not gross as stated. The density should be lower than typology 8 to reflect the infrastructure required on a strategic scheme.
In relation to infrastructure for strategic sites we would consider 30% to be the minimum allowance, not 20% as shown Garages should be added into the build cost calculation. No allowance has been made for Abnormals i.e. ground contamination, requirement for foul water pumping stations. This should be included or, alternatively, the contingency should be increased accordingly.
In relation to Affordable Housing, the return is likely to be between 45% / 50% (affordable rent) and 65% / 70% (shared ownership) of open market value.
In terms of Facilities, no allowance is made for education, community, health, commercial or retail, which are likely to be required for strategic sites. This allowance should include any requirement for maintenance contributions.
No allowance is made for planning or promotion costs.
No allowance is made for Third Party Agreements, which are potentially required on a range of sites, but highly likely on the large strategic sites.
An allowance should be made for Services. These are becoming increasingly expensive particularly given the increased requirements anticipated through the Future Homes Standards Consultation.
No allowance is made for phasing. It is likely that the large strategic sites will be delivered in phases. The viability should be amended to reflect this and the finance costs revised to reflect the need for the early delivery of infrastructure.
There is a concern that the £5,000 allowance for energy efficiency measures is too low.
On behalf of M Scott Properties Ltd we are instructed to submit representations to the Greater Norwich Local Plan Regulation 18 (c) consultation. The representations are split into two, reflecting the two parts of the Greater Norwich Local Plan; the Strategy Document and the Sites Plan, in respect of GNLP0337.
The attached document provides a complete record of the representations made on behalf of M Scott Properties Ltd.
The various technical studies referred to in the Representation and the Delivery Statement can be accessed in the attachments also.