Object

Representation ID: 23076

Received: 16/03/2020

Respondent: Orbit Homes

Agent: David Lock Associates

The Greater Norwich area has real potential for growth and compete as a nationally significant economic area. Such growth and success requires a positive and proactive policy basis; growth must be encouraged and not stifled. The GNLP approach to identifying the housing need for the area does not take a proactive approach; moreover, it risks inhibiting the economic and jobs growth that has been agreed as part of the City Deal, and more importantly the recent growth trends that have been evident.

Even more worryingly, there has been a very recent indication that the Greater Norwich housing delivery across Greater Norwich has achieved targets for the first time. This is a positive sign, but the numbers proposed as part of the GNLP would actually result in a reduction of delivery. This is a serious concern at a time when a key Government priority is to significantly boost the supply of housing, and in the context of strong local delivery which would be inhibited by the GNLP numbers.

The GNDP are aiming to meet a need of 2,027 homes per annum, with some further allowances for supply. It appears that GNDP have arrived at such a level of need by simply applying the standard method, introduced for the purposes of establishing a minimum need through recent revisions to the National Planning Policy Framework (NPPF) and related Planning Practice Guidance (PPG).

It is understood that GNDP view the outcome of this formula as an appropriate representation of the full need for housing in Greater Norwich, albeit there is a concerning lack of evidence to substantiate their position in this regard. This lack of consideration conflicts with national policy and guidance, which emphasises that the standard method produces only a minimum starting point and makes clear that there should be an assessment of whether housing need will actually be higher than implied by its formula.

The NPPG requires consideration of a number of factors as part of determining housing need from the starting point of the standard method including any affordability adjustment and taking account of economic circumstances. The GNDP do not appear to make any adjustment from the baseline of the standard method.

In this context we are concerned that the standard method baseline alone would not provide sufficient need as outcome of the method is intrinsically linked to projections that have underestimated population growth to date in Greater Norwich, and particularly failed to anticipate a more pronounced – and increasingly vital – net inflow of people from other parts of the UK. This calls into question whether the method is accurately capturing the housing needed by the population in this area, both now and in the future.

As noted above simply meeting the need implied by the method would also prompt a 16% reduction in the annual rate of housing delivery belatedly achieved over the past three years, when adopted housing targets were met for the first time. Such a reduction is unjustified at a time when the Government remains committed to significantly boosting housing supply and in light of the GNLP objectives to encourage growth and support the Tech Corridor.

Given the economic objectives and wider strategies and commitments to significant jobs growth in Greater Norwich, it is concerning also that with no adjustment for this, simply meeting the need implied by the method would likely grow the labour force and support in the order of 37,000 new jobs. Whilst this supposedly surpasses the target proposed in the Draft Plan (33,000), it falls short of the job growth that can be reasonably expected to result from an ongoing economic growth strategy, this is covered in more detail on the economy below.

The GNDP target is considered inadequate in this regard, given that it is derived from an unjustified and unduly simplistic manipulation of a scenario presented in an evidence base document which is now comparatively dated and pre-dates the revised NPPF. Equally, as a result of the datedness of the informing analysis, it is considered to fail to adequately reflect the strong economic context which Greater Norwich has demonstrated for a sustained period of time or the full impact of planned investment. In this context it is considered that planning for in the order of 40,000 jobs as a minimum over the plan period would be more reflective of the strong potential for truly enhanced growth in Greater Norwich. This clearly would not be supported where housing provision is restricted to the level implied by the standard method, and the associated ageing of the labour force also appears unlikely to support the desired shift towards higher value sectors. Based on the above, we consider that GNDP must update their evidence base prior to the next stage of consultation on the emerging Local Plan, to comply with the NPPF and PPG. This should properly evaluate the level of job growth that is likely in Greater Norwich, taking recent successes – no doubt linked to the City Deal and other initiatives – into account while reconsidering the prospects for long-term growth beyond “business as usual” in key locations and sectors. A related assessment of housing needs should also be produced, to locally test the minimum need implied by any standard method in and ensure that the housing needed to support a growing economy can be planned for.

GNDP also appear to have misconstrued the supply-led buffer proposed as part of its housing requirement, claiming that it provides flexibility to accommodate the consequences of successful investment strategies. The Draft Plan states:
“Our overall approach, including to windfalls and contingency, builds in flexibility to support higher than trend economic growth incorporating the Greater Norwich City Deal” (Paragraph 163 of the GNLP Strategy Document)

The NPPF and PPG are clear that it is a requirement of Local Plans that they are deliverable and sufficiently flexible to adapt to rapid change. The plan’s soundness will be judged against these requirements. The buffer is required to ensure an appropriate allowance for unforeseen circumstances or non-delivery of sites which might otherwise pass the ‘developable’ test. Whilst the Councils have recognised this general point, and the resultant need for an increased level of flexibility, this should not be seen to provide capacity to accommodate need pressures; it is intended to alleviate risks to supply. In this context, the PPG (PPG Reference ID: 2a-010- 20190220) is explicit in recognising that where authorities should consider the appropriateness of a higher housing need figure:
“This will need to be assessed prior to, and separate from, considering how much of the overall need can be accommodated (and then translated into a housing requirement figure for the strategic policies in the plan)”

The Draft Plan later describes another supposed reason as to why the GNDP have not sought to explore the appropriateness of a higher housing need figure, stating with reference to a higher housing figure being considered under a section titled ‘alternative approaches’ that:
“This is not the preferred alternative as evidence of delivery rates over the medium and longer term suggests that higher targets are unlikely to be achievable or deliverable. Setting a higher target that can* be achieved undermines the plan-led system [*it is assumed this should read cannot] (Page 54 of the GNLP Strategy Document)

This is not considered to represent an appropriate or PPG-compliant justification for not attempting to explore the appropriateness of a higher housing need figure. It is of note that the standard methodology recognises the realism of ‘delivery’ with regards to the capping of the adjustment from the baseline to 40%. The PPG specifically acknowledges (Paragraph Reference ID: 2a-007-20190220):
“The standard method may identify a minimum local housing need figure that is significantly higher than the number of homes currently being planned for. The cap is applied to help ensure that the minimum local housing need figure calculated using the standard method is as deliverable as possible”

It is of note that the adjustments for Greater Norwich are notably smaller than 40% and that, as is considered above in our representations [Paragraph 4.50], recent rates of delivery have exceeded the current plan target. As such, there is no justification for suggesting that deliverability concerns represent a valid reason for dismissing the appropriateness of a higher figure.

As previously mentioned in the context of delivery concerns with some of the allocated sites, the absence of a trajectory of this stage at the process to evidence how the sites will contribute to the housing need over the plan period, is a serious issue. This trajectory is required by the NPPF and by not having it available for representors to review and assess alongside the allocations, there is no certainty as to whether the housing needs will actually be met through the identified spatial strategy.

Based on the above, it is considered that the Councils must update their evidence base prior to the next stage of consultation on the emerging Local Plan to comply with the NPPF and PPG. Our objection to the housing needs to be met through the GNLP is set out in greater detail in the ‘Technical Review of Housing Needs in Greater Norwich’ Report by Turley, February 2020, included at Appendix 3.