Support

Representation ID: 23077

Received: 16/03/2020

Respondent: Orbit Homes

Agent: David Lock Associates

We support the general approach to the growth of the economy and welcome the recognition of the Tech Corridor and its relationship to the globally significant axis between Cambridge and Oxford. We are however concerned that the Plan is not optimistic enough in making provision for economic growth, both in planning for sufficient jobs and planning for sufficient housing to support these jobs.

The Draft Plan targets the creation of at least 33,000 jobs over the plan period (2018-38) and confirms that this ‘has been established through local trend-based evidence’ (Paragraph 149 of the GNLP Strategy Document) . Whilst the Draft Plan attributes this to the East of England Forecast Model (EEFM) it also confirms its origination from evidence included in the Employment, Town Centre and Retail Study produced by consultancy GVA in 2017. This study used the then-latest published iteration of the EEFM to explore scenarios of job growth based on ‘business as usual’ and the potential for ‘enhanced economic growth’.

The latter scenario, which the Draft Plan confirms underpins its job target, identified that between 2014 and 2036 around 44,000 jobs could be created, an average of 2,000 jobs per annum. It built from the EEFM but applied positive adjustments to a number of sectors which were considered to better reflect local and national growth potential.

The 33,000-job target in the Draft Plan is explained as being based on:
• A netting off of the 15,000 jobs created to 2018 from the 45,000 jobs forecast in the Employment, Town Centre and Retail Study; and
• An extension of the forecast by a further two years to 2038, the extension implied to be based on the latest EEFM outputs.

Such an approach is considered to have a number of significant limitations:
• The Employment, Town Centre and Retail Study is now comparatively dated and should be revisited to ensure it is based on up-to-date economic datasets;
• The GNDP approach to manipulate the previously evidenced job forecast fundamentally fails to take into account the approach taken to generate the enhanced growth scenario or its forecast of job growth over the long-term; and
• At a wider level there have been more marked local and national changes to the economy which have a bearing on the forecasting of future job growth and should be taken into account through an updated evidence base. This will ultimately ensure that the Local Plan takes full account of the current ambitions of the GNDP and the Local Enterprise Partnership, as well as national Government.

It is noted that in seeking to justify the 33,000-job growth target the GNDP, through the Draft Plan, advance an argument of dismissing the potential for higher growth targets, as have evidently been set previously. This justification is predicated on questions as to whether ‘significantly higher targets’ are ‘achievable’ given ‘current economic uncertainties’ and the ‘enhanced growth’ that is ostensibly already provided for.

The suggestion that higher levels of growth would not be ‘achievable’ does not stand up to scrutiny when recognised that the target of 33,000 jobs represents a markedly lower rate of growth than that which has been seen in recent years, as used in the GNDP derivation of its target. The last three years alone have cumulatively seen nearly half as many jobs created than are assumed to be created over the much longer twenty-year period covered by the target.

The NPPF confirms that ”planning policies should…set out a clear economic vision and strategy which positively and proactively encourages sustainable growth, having regard to Local Industrial Strategies and other local policies for economic development and regeneration” (NPPF Paragraph 81a). In the context of economic growth priorities provided by the Cambridge-Norwich Tech Corridor and the importance of the New Anglia Local Enterprise Partnership’s existing Norfolk and Suffolk Economic Strategy (NSES) and the emerging Norfolk and Suffolk Local Industrial Strategy (LIS), it is undoubtedly appropriate for the Draft Plan to target an enhanced level of employment growth than implied by trend-based or ‘off-the-shelf’ forecasts. Given an evolving economic strategy context, the reliance on forecasts presented within a study produced in 2017 creates a concerning risk that the latest understanding of this growth potential is not fully captured. The strength of the local economy in creating new jobs would imply that whilst it represents an ‘enhanced’ outlook of growth it appears unduly modest when compared to this historic success.

We therefore, consider that to support the enhanced levels of economic growth that are evidently capable of being achieved and should be encouraged, the Plan should seek to make further provision for employment opportunities and these should be well located to the economic priority area – most significant the Tech Corridor. Supporting the continued success of Norwich Research Park should also be a key objective and should be promoted through ensuring new homes as well as complementary employment opportunities are made available at SGV.

The SGV proposition includes a ‘Tech Hub’ which has the potential to offer a range of flexible employment land opportunities associated with the key sectors of agri-tech and energy. As such an allocation at SGV would provide a necessary increase in the jobs target for the Plan and this would be supported by an interrelated increase in the number of homes to support these jobs. This is further explained in the ‘Technical Review of Housing Needs in Greater Norwich’ Report by Turley, February 2020, included at Appendix 3 which indicates a minimum of 40,000 jobs should be planned for in the GNLP.

We also note and support the importance of Hethel as a key economic destination in the Tech Corridor. We therefore consider it critical that the current employment uses at Hethel are not compromised through incompatible development and its potential to expand as an employment hub should be safeguarded. This would align well with a strategic Garden Village allocation at SGV.