Comment

Representation ID: 22726

Received: 16/03/2020

Respondent: Pegasus Group

Paragraph 60 of the NPPF outlines that strategic policies should be informed by local housing needs, using the Government’s standard method unless exceptional circumstances for an alternative approach can be justified which reflect current and future demographic trends and market signals.
Paragraph 11 NPPF confirms that for plan-making, the presumption in favour of sustainable development means that:
• Plans should positively seek opportunities to meet the development needs of their area, and be sufficiently flexible to adapt to rapid change; and
• Strategic policies should, as a minimum, provide for objectively assessed needs for housing and other uses, as well as any needs that cannot be met within neighbouring areas…
Minimum housing requirement
The need for 40,550 homes is identified as having been calculated using the standard method. Albeit it is noted that the Draft Strategy states that the published version of the plan will aim to provide a minimum 10% buffer (a minimum of a further 250 homes) which is likely to be provided through a combination of additional sites proposed through this consultation and contingency sites identified in the draft plan.
The standard method provides the minimum local housing need and is calculated using the average household growth for 10 consecutive years, with an affordability uplift based on the median workplace-based house price to earnings ratio of the preceding year[1]. The Draft Local Plan covers the period from 1st April 2018. In order to establish the minimum local housing need for the plan period it is therefore necessary to calculate either the standard method at 2018; or to calculate the current standard method and apply this to the remainder of the plan period in addition to the number of completions which have already occurred.
The Draft Local Plan covers the period from 1st April 2018. In order to establish the minimum local housing need for the plan period it is therefore necessary to calculate either the standard method at 2018; or to calculate the current standard method and apply this to the remainder of the plan period in addition to the number of completions which have already occurred.
In the case of the Greater Norwich Plan Area, the average household growth over the 10 consecutive years from 2018, namely 2018-28, was 400 in Broadland, 510 in Norwich and 704 in South Norfolk. The median workplace-based house price to earnings ratios in 2017 were 9.82, 6.93 and 8.91 respectively. Using these figures, the minimum local housing need over the plan period equates to 41,379 homes.
Alternatively, the minimum local housing need from 2019 onwards can be calculated using the average household growth over the 10 consecutive years from 2019, namely 2019-29, with the affordability of 2018 applied. The average household growth was 397, 505 and 691 respectively and the
median workplace-based house price to earnings ratios were 9.23, 7.03 and 8.78 respectively. These
figures produce a minimum local housing need of 2,024 homes per annum which equates to 38,460
homes over the period 2019-38. The number of housing completions in 2018/19 need to be added to
this figure to provide the minimum local housing need over the plan period. Ministry of Housing
Communities and Local Government Live Tables identify that there were 2,757 housing completions,
as well as 260 student bedspaces and 91 other bedspaces completed in this year. Once the appropriate
conversion factors as identified in the Planning Performance Guidance (PPG) (68-034) and the PPG
(63-016a) are applied this would equate to 2,901 houses[2] completed in 2018/19. In addition to the
minimum local housing need of 38,460 over the period 2019-38 this would produce a minimum local
housing need for 41,361 homes over the plan period. It is apparent that the standard method has
been miscalculated within the Draft Local Plan as it is below the minimum local housing need of either
41,379 or 41,361. Policy 1 and all other references to a need for 40,550 are therefore not justified nor
are they consistent with national policy. Furthermore, the Government has identified that it intends to
review the standard method by September 2020. As the Local Plan is not intended to be submitted for
examination until June 2021, it is likely that the Local Plan will need to respond to the new standard
method, whatever that may be.
Historic under-delivery
In Greater Norwich, the housing trajectory of the Joint Core Strategy identified that there would be
23,637 housing completions in the period 2008-19. However, only 18,835 homes have been delivered
which demonstrates that at least historically, the trajectory of Greater Norwich overestimates the
developable supply by circa 25%. The overestimations of supply can be mainly attributed to the
delivery rates of strategic infrastructure projects, and consequently, the ability of large scale SUE’s to
be delivered across Greater Norwich. Assuming that the current trajectory is equally as accurate, it
would be appropriate to set a housing requirement 25% in excess of the minimum need for circa
41,400 homes. This would produce a housing requirement for circa 52,000 homes. This illustrates that
there is a need for a significant contingency allowance in Greater Norwich to ensure that needs are
actually met. It is therefore recommended that the proposed contingency of 9% is retained as a
minimum, which in addition to the minimum housing need for circa 41,400 homes produce a housing
requirement for at least 45,126 homes.
Expected Economic Growth
In addition to this, given the early stage of the plan preparation and the need for further technical
work and analysis regarding economic growth and housing need it is recommended that the additional
33,000 new jobs, is viewed as a minimum by the Councils. The Councils will need to adopt a flexible
approach to setting the increased housing target to ensure that available land is used efficiently to
meet the economic and housing needs of the area.
By planning proactively for increased rates of housing the GNLP will support and stimulate the
anticipated economic growth and job creation in the area and in turn support the growth of the
Cambridge Norwich Tech Corridor. Preparing the GNLP on the basis of an enhanced figure to address
economic growth is entirely justified given the context provided by the Greater Norwich City Deal,
which identifies that strategic infrastructure is needed including to deliver a step change in housing
delivery. The City Deal identifies that a target for an average of 3,000 homes per annum in the period
2014-19 and for 37,000 homes to be delivered in the period 2008-26. The Government encourages authorities to consider higher levels of growth than that required to meet local housing need, particularly where there is the potential for significant economic growth.
In our assessment, based on the information available and content of the Draft Strategy document, it is strongly recommended that the GNLP plans for an increased housing need figure. This will support economic growth, reduce inequality, increase affordability levels and promote wellbeing through the delivery of additional market and affordable housing in sustainable locations. Even at this early stage of the plan preparation process it is evident that exceptional circumstance exists in this instance to justify increased housing delivery in accordance with paragraph 60 of the NPPF.
Land off Norton Road, Loddon
Our client considers that the Councils should consider identifying additional available and deliverable small and medium sized sites from a range of locations, which are capable of accommodating housing growth within the plan period.
Our client’s site is available and deliverable within the plan period, with site access feasible to both the Northern and Southern sections of the site from Norton Road. There is also some scope to create through access from the proposed allocation of Land to the east of Beccles Road (GNLP0312) to the west. Furthermore, the village of Loddon is classed as a Service Centre, the largest, most sustainable villages in the area. Indeed, the settlement possesses a wide range of shops, services, infrastructure, employment opportunities and public transport links. Thereby the allocation of the small-scale housing site of Land off Norton Road would lead to the natural extension of the sustainable settlement of Loddon and would assist in providing the Councils with greater certainty over housing delivery during the next plan period.

[1] As confirmed in paragraph 15 of the Housing Delivery Test Measurement Rule Book
[2] Calculated using the average number of students per household of 2.85 in Norwich and applying
this to the 260 student bedspaces which equates to 91 houses; and using the average number of
adults per household of 1.85 in Broadland and applying this to the 8 older persons bedspaces which
equates to 4 houses; and using the average number of adults per household of 1.72 in Norwich and
applying this to be 83 older persons bedspaces which equates to 48 houses.