Object

Representation ID: 22762

Received: 16/03/2020

Respondent: Mr Bryan Robinson

I support the position of CPRE Norfolk who has questioned the calculation for housing targets using the ONS statistics on household creation. It argues that these are out-of-date and are more recent statistics which show a slower rate of household creation. If this approach was adopted by the GNDP it would negate the need for any further need for new housing in the GNLP. Despite claims to the contrary (draft GNLP consultation p41), the GNDP is not using the most up-to-date evidence, as its figures are based on the 2014 ONS figures rather than those from 2016.

Not only are the increased housing targets unnecessary, increasing them further by allocating a 9% buffer seems absurd. What is more, windfalls, which are a proven reliable source of new housing, are not going to be counted towards the new target which is irrational.

A problem with the consultation is that phasing is not specifically offered as an option within the documentation. We feel this is a serious omission given the fact that 69 Parish and Town Councils within the GNLP area share the CPRE Norfolk view that a phased approach should be adopted. We urge the Greater Norwich Growth Board to seriously reconsider including phasing as the right approach to development.

There is no commitment in the GNLP to build new housing to the highest environmental standards, but rather follows minimal Government requirements. This is highly regrettable.