Object

Representation ID: 22968

Received: 16/03/2020

Respondent: Barratt David Wilson Homes

Agent: Pegasus Planning Group

If the Councils do not plan for enough homes for the Greater Norwich area it will worsen the existing affordability issues, limit the benefit that the area has for the local and national economy, damage social inclusion, and have negative implications for climate change as people have to travel further to access jobs. We make this comment in the context of a plan that seeks to significantly increase jobs over the plan period and yet suppresses the potential development yield from a site in one of the most sustainable locations within the plan area (i.e. GNLP0307).

We support the fact that headline housing numbers have been identified as a minimum figure. However, given the planned growth of the economy of the Greater Norwich area the Local Plan needs to take every opportunity to exceed the minimum figures identified for delivery by maximising the use of land on allocated sites. We have already recommended that the delivery of homes at the GNLP0307 site should be increased and we would add that the figures should be set as a minimum in order to boost the supply of new homes in accordance with paragraphs 59 and 60 of the NPPF and support the economic growth of the plan.

Aligned to this, we wish to raise serious concerns that in order to meet the proposed numbers in the Greater Norwich Local Plan there is reliance on the allocation of several thousand new homes through the South Norfolk Village Clusters Housing Sites Allocation document. Presently there are no details as to how these sites will be allocated or when the document will be prepared. There is no evidence that the new homes will be accommodated in the most sustainable locations or within a timescale that will ensure that the needs identified in the plan will be met. Clearly this approach is inconsistent with paragraphs 20 and 23 of the NPPF, which require that Councils make sufficient provision for housing through strategic policies that provide a clear strategy for bringing sufficient land forward.

Without a strategic approach to where these additional allocations are to be located there is no certainty over whether they will deliver sustainable forms of developments. The need to draft and adopt the Housing Sites Allocation Plan will also represent a further delay to the delivery of new homes after the Greater Norwich Local Plan has been adopted. This delay, and uncertainty about the delivery of sites has the potential to limit delivery rates in the short and medium term.

The Greater Norwich Local Plan needs to take a more proactive approach to securing the delivery of new homes to avoid any doubt around delivery timescales and rates on yet to be allocated sites. The most expedient way to provide certainty around delivery of new homes is by ensuring that proposed allocations in the higher order settlements make the most efficient use of land by increasing densities where it is appropriate to do so. Our client’s site at Cringleford would be an ideal location to increase densities in line with already consented development sites in the village.