Comment

Representation ID: 22795

Received: 16/03/2020

Respondent: Strutt & Parker LLP

In response to Question 48, the below comments have been made in respect of the Greater Norwich Local Plan Interim Viability Study (November 2019) We are generally supportive to the approach taken but have some observations in respect of the detail which we hope are helpful:

Density (Table 4)
- Net areas are only used on Typologies 6-9, but are also applicable to Typology 4, where sites will also be required to provide on-site public open space, green infrastructure and SUDS, as well as often needing to gift land for community uses.
- The density figures are presumably based on the indicative mixes in Table 5, but these do not have any allowance for housing for older people (single-storey), which will again reduce density. This will mean that the proposed density of 25 dwelling per hectare (gross) will be difficult to achieve where large proportions of bungalows are to be included.
- The net: gross ratios are likely to be circa 66% on these sites, meaning a net density of circa 38 dph will be needed.

Housing Mix (Table 5)
- As mentioned above, there is nothing for single-storey accommodation, for example housing for older people and accessible housing, despite the strong demographic arguments which demonstrate the need to provide accommodation for an ageing population.
- While housing need may suggest the proportion of 3 bedroom homes should be high in the Main Towns, demand for market properties is likely to be higher for larger family properties. Such a high percentage of two bed houses seems high at the expense of 3 and 4+ bed family housing in the Main Towns. In particular, 8% of 4+ seems very low. Market demand is likely to be circa 20% of the private dwellings with 4+ bedrooms (13% aggregated).
- The 20% for flats also seems high, the market for private flats is limited in rural locations, so we would expect this to be closer to 10% overall.
- Again no information has been provided for single-storey properties
- The 3-bedroom house size (102 sq. m) is for a 6-person property, so comes out large at 1,100 sq. ft.

Affordable Housing (Table 7 & Table 15)
- Typology 4 (Main Town) is assessed at 28% Affordable Housing but 33% is sought by policy.
- At 28% (and with current assumptions) it is the 2nd least viable (£115,872 surplus) and as such, on the Sensitivity Testing it fails across all scenarios.
- Affordable Rent – 60% is very ambitious as a return, it is recognised in the report that the range is 45% to 65%, so 50% would be a better assumption to use.
- Affordable Ownership – again it is recognised that the range can be 60% to 80%, so 70% would be a better assumption than 75%.
- As mentioned in the caveats, no account has been taken of the 5% custom build policy requirement.

Access
- For specialist housing developments, all (not just 20%) of homes will meet at least the M4(2) access requirement, which adds up at £940 per dwelling. It is our consideration that a new house type is required for the Study.

RAMS
- A justification is required in relation to the recommendation for £200 per dwelling. This was recently revised down to £122 in neighbouring Suffolk.

Market Revenue
- The values do not correlate with what is currently on the market, especially for the 4 bedroom properties, for which the values are overstated by as much as 43%. The below tables show all of the new build (estate) houses on Rightmove as of the 18th February 2020.
(see attached document for additional figures (para 39)

Build Costs
- The costs for Bungalows will be higher than £1,221 per square metre and it is suggested that consideration of bungalows is included within the Study.
- The costs for Garages have been contained within the site and infrastructure costs. CIL will also be payable on the garages which will increased the cost.
- No allowance is made for ground conditions / ground water protection / flood risk. It is important that these are factored in.

Sites and Infrastructure Costs (Table 10)
- 15% seems low for site and infrastructure costs, it is considered that these costs will rise over the Plan period with increased electricity requirements etc.

CIL/S106 (Table 11)
- As mentioned above, Garages have been excluded but will be chargeable.
- For Typology 4 – the majority of the Main Towns are in Zone B so it would make sense to use the appropriate figure.
- The 2020 figures are now available and as such should be used (£70.46 per sq. metre).
- No allowance has been made for site-specific Section 106 works such as Public Rights of Way improvements etc.

Benchmark Land Value (Table 12a)
- The figure for Typology 4 is £432,432 / ha = £175k / acre (gross). This does not reflect that most land is purchased at a discount to reflect the planning and promotion risks / cost time. It also doesn’t consider sales agent and legal fees.
- Taking the example in the report shown below, the figure should be revised accordingly and checked against actual transactions to show that the transaction levels (and therefore expectations) are still far higher at circa £300,000 gross per acre.
- 7.5 acres @ £175k per acre = £1.312m
• minus Agent’s Fees @ 1.5% = £1.292m
• minus Sales Legal Fees @ £10k = £1.282m
• minus Recoverable Promotion Costs @ £150k =
£1.132m
• minus Promoter’s Share @ 20% = £906k
• = £121k per acre (= EUV x 12, not 17.5)