Comment

Representation ID: 23191

Received: 16/03/2020

Respondent: Orbit Homes

Agent: Armstrong Rigg Planning

The Strategy Document proposes to set a housing requirement of 40,541 new dwellings between 2018 and 2038 (2,027 dpa) which has been calculated using the government’s standard methodology, but seeks to plan for a 9% buffer (to be increased to 10% in the final plan) on top of this requirement by delivering 44,343 new homes by 2038. Existing allocations and commitments total 36,503 dwellings which comprises 82% of the proposed housing growth (and 90% of the housing requirement) to 2038. The GNLP and separate South Norfolk Village Clusters (SNVC) plan therefore only seeks to plan for the additional 18% of growth, totalling 7,840 dwellings (split between 6,640 dwellings in the GNLP and 1,200 dwellings in the SNVC plan).

Under potential alternative approaches, the Strategy Document states that there are no exceptional circumstances to justify setting a lower housing requirement than that identified using the standard methodology. We would agree with this statement in accordance with the test set by NPPF Paragraph
60. However, in terms of whether a higher housing requirement may be needed, the justification provided is clearly not in accordance with national policy. The Strategy Document states that:

“The NPPF does encourage a higher housing requirement to be considered. This is not the preferred alternative as evidence of delivery over the medium and longer term suggests that higher targets are unlikely to be achievable or deliverable. Setting a higher target than can be achieved undermines the plan- led system. However, if additional need and demand for housing materialises, it can be facilitated through the flexibility built into the local plan.”

Not only is the above statement contradictory (as it claims that a higher target could not be delivered and at the same time says that if additional need materialises it could be facilitated through flexibility in the plan), but it is entirely contrary to national policy set out in Planning Practice Guidance (PPG) on Housing and economic needs assessments (ID: 2a-010) which provides advice on when it might be appropriate to plan for a higher housing need figure than the standard method indicates. The PPG clearly states that the standard method provides a minimum starting point in determining the number of homes needed in an area. There will, therefore, be circumstances where it is appropriate to consider whether actual housing need is higher than the standard method indicates. The PPG advises that “This will need to be assessed prior to, and separate from, considering how much of the overall need can be accommodated”. The approach taken by the Greater Norwich authorities of restricting the housing requirement to what can be accommodated is therefore completely contrary to the PPG.

The PPG additionally advises that circumstances where setting a higher housing requirement may be appropriate include, but are not limited to, situations where increases in housing need are likely to exceed past trends because of:

• growth strategies for the area that are likely to be deliverable, for example where funding is in place to promote and facilitate additional growth (e.g. Housing Deals);

• strategic infrastructure improvements that are likely to drive an increase in the homes needed locally; or

• an authority agreeing to take on unmet need from neighbouring authorities, as set out in a statement of common ground.

The first two of the points above clearly apply in Greater Norwich with respect Greater Norwich City Deal and the ambitions of the Cambridge Norwich Tech Corridor. The City Deal was signed in December 2013 and commits the authorities to secure significant infrastructure funding totalling £440 million and to bring forward 3,000 additional homes by 2026 in the North East Growth Triangle (on top of the target of 37,000 set by the JCS for the whole plan area). Whilst it is recognised that the development

requirements of the City Deal have been facilitated in part by the allocation of 3,000 additional homes in the adopted Growth Triangle Area Action Plan (GTAAP), the delivery of these strategic housing sites has been slow. To this end the emerging GNLP offers the opportunity to provide fresh stimulus to achieving the ambitions of the City Deal prior to 2026 to make up for any shortfall in new jobs and housing.

Secondly, it is vital that the GNLP responds to the ambitions of the Cambridge Norwich Tech Corridor (CNTC), the vision of which seeks to attract 26,000 additional jobs and 46,000 further residents to the corridor prior to 2031. At this stage it is apparent that whilst the CNTC proposals would be hugely positive for the plan area they currently represent what is still little more than an aspirational programme for growth with limited delivery mechanisms in place. This is where the GNLP must play a major role in making the CNTC vision a reality.

One of the options put forward in the previous regulation 18 GNLP consultation in March 2018 was to provide an additional uplift in the housing requirement to take account of the City Deal, but this was discounted as the authorities claimed that the uplift applied by the standard method (i.e. the uplift to account for the affordability of homes that is built into the standard methodology) was sufficient to account for the City Deal uplift required. We disagree with this approach as it fails to reflect the fact that the standard method is a ‘policy off’ calculation of the housing requirement and any adjustments required to due to ‘policy on’ decisions (i.e. to sign a City Deal) should be on top of this.

In light of the above, Orbit Homes wishes to raise a significant concern regarding the approach employed to set the housing requirement. The use of the standard methodology simply adopts the minimum requirements set by the government and fails to recognise the City Deal growth commitments and ambitions of the CNTC proposals. The significant investment and jobs growth that will result from both these growth strategies will result in an increased housing demand above and beyond the baseline requirement calculated using the Government’s Standard Methodology. It is therefore critical that the housing requirement is increased to meet this increased demand. The majority of this increased growth will be in the Cambridge Norwich Tech Corridor (i.e. along the A11 southwest of Norwich), but it is critical also that the needs of the local population across the plan area are planned for so as to avoid creating an imbalance in housing delivery across the plan area.

Comments on Housing Requirement

The currently proposed housing requirement does not account for the City Deal or Cambridge Norwich Tech Corridor (CNTC) which must both be taken into account if the housing requirement is provide a positive approach to meeting housing needs. This section provides an analysis of the impact of these growth strategies on the housing requirement.

As set out above, the City Deal commits the Councils to delivering 3,000 additional homes in the Growth Triangle on top of the Joint Core Strategy housing requirement by 2026. In order to analyse performance against the City Deal commitment we need to account for how many homes have been delivered and how may homes are currently forecast to be delivered during the JCS plan period between 2008 and 2026 and whether this delivery will meet the 40,000 home commitment set by the City Deal (i.e. 37,000 JCS requirement + 3,000 in the Growth Triangle). Table 2 utilises data in the JCS Annual Monitoring Reports to provide this information.

The above table demonstrates that at the end 2017/18, Greater Norwich had delivered 15,472 net new homes against a commitment to deliver 40,000 by 2026 set out in the City Deal. This leaves a total of 24,528 still to be delivered by 2026 or 3,066 dpa over 8 years. Against this requirement, there is a current shortfall in forecast delivery of 4,964 dwellings. The GNLP offers the opportunity to provide fresh stimulus to achieving the ambitions of the City Deal by making additional allocations on short term deliverable housing sites to provide 4,964 new homes.

An alternative way of assessing the additional housing required to meet City Deal demand is to look at the SHMA published in April 2017. This document identifies that the jobs growth facilitated by the City Deal would likely result in a demand for approximately 8,361 new homes above and beyond those required as a result of general demographic change over the period until 2036. Even when deducting the 3,000 dwellings planned for in the GTAAP this results in an additional requirement of 5,361 homes (i.e. very similar to the 4,964 additional homes identified by the assessment of shortfall in table 2) that appear not to have been considered when setting the GNLP housing requirement.

On this basis we consider that the housing requirement proposed by the plan falls short of adequately responding to local demand by an approximate 5,000-5,4002 homes. This is before the additional demand generated by the CNTC is taken into account. In which case the absolute minimum housing requirement for the GNLP should be somewhere in the region of 45,500-46,0003 dwellings before any buffer is applied. In which case it is our view that upon the application of the appropriate buffer the GNLP should be planning for somewhere between 48,300 and 50,6004 dwellings as a minimum,

2 4,964-5,361 dwellings rounded up to the nearest 100
3 LHN of 40,541 dwellings plus 5,000-5,400 uplift rounded up to nearest 100
4 Range calculated on the basis of a 5% and 10% buffer above 46,000, in response to paragraph 73 of the NPPF

against which there are existing commitments of c.36,5005 dwellings, leaving a requirement for the GNLP to deliver a minimum of between 11,800 and 14,1006 additional dwellings, or between approximately 4,000 and 6,3007 dwellings higher than the current GNLP additional growth figure of 7,840. This highlights the need for significant additional allocations in the GNLP.