Further to representations made at the Regulation 18 draft consultation stage (09 March 2021) – attached - it remains our view that Policy 5 – insofar as it relates to Affordable Housing - is unsound.

The 2017 SHMA identifies a need for 28% affordable housing; why then is the policy seeking a minimum of 33% (outside of Norwich City Centre)? The implication – although somewhat disingenuous – is that the shortfall arising from the Government policy of excluding affordable housing provision from housing developments of fewer than 10 units must be made up by inflating the evidentially-based 28% (SHMA) proportion. In effect, cross-subsidising the perceived ‘shortfall’ through major housing schemes (10 or more units). We believe there is a clear case for the Local Plan to reflect its evidence base (insofar as it relates to affordable housing) by requiring that the proportion of affordable housing sought reflects the most up-to-date needs assessment, i.e. 28%. Indeed, that the approach adopted in Policy 4 (Housing Delivery) of the adopted Joint Core Strategy (JCS) is carried forward into the new Local Plan: “The proportion of affordable housing, and mix and tenure sought will be based on the most up to date needs assessment for the plan area.” Policy 5 (Greater Norwich Local Plan) only says that “a mix of affordable housing sizes, types, and tenures…” should take account of the most up-to-date evidence, not the proportion. The proportion has changed over the Plan (JCS) period – notably since the publication of the 2017 SHMA - and has been reflected in Councils’ approaches to decision making thereafter.

There now appears to be a marked change in the Councils’ approach to an evidentially-based and up-to date proportion of affordable housing, without justification. The GNDP may feel it has a case to make – other than simply to make up the overall affordable housing levels through its absence in minor (sub 10 unit) developments - but we cannot find any proper rationalisation in the emerging Local Plan, nor in its supporting evidence, including the Viability Appraisal (December 2020). This is a serious omission that should be properly addressed, to avoid adverse impacts on housing delivery and viability through the Plan period. As it stands, we contend that Policy 5 is therefore unsound.

Further to representations made at the Regulation 18 draft consultation stage (09 March 2021) – attached - it remains our view that Policy 5 – insofar as it relates to Affordable Housing - is unsound.

The 2017 SHMA identifies a need for 28% affordable housing; why then is the policy seeking a minimum of 33% (outside of Norwich City Centre)? The implication – although somewhat disingenuous – is that the shortfall arising from the Government policy of excluding affordable housing provision from housing developments of fewer than 10 units must be made up by inflating the evidentially-based 28% (SHMA) proportion. In effect, cross-subsidising the perceived ‘shortfall’ through major housing schemes (10 or more units). We believe there is a clear case for the Local Plan to reflect its evidence base (insofar as it relates to affordable housing) by requiring that the proportion of affordable housing sought reflects the most up-to-date needs assessment, i.e. 28%. Indeed, that the approach adopted in Policy 4 (Housing Delivery) of the adopted Joint Core Strategy (JCS) is carried forward into the new Local Plan: “The proportion of affordable housing, and mix and tenure sought will be based on the most up to date needs assessment for the plan area.” Policy 5 (Greater Norwich Local Plan) only says that “a mix of affordable housing sizes, types, and tenures…” should take account of the most up-to-date evidence, not the proportion. The proportion has changed over the Plan (JCS) period – notably since the publication of the 2017 SHMA - and has been reflected in Councils’ approaches to decision making thereafter.

There now appears to be a marked change in the Councils’ approach to an evidentially-based and up-to date proportion of affordable housing, without justification. The GNDP may feel it has a case to make – other than simply to make up the overall affordable housing levels through its absence in minor (sub 10 unit) developments - but we cannot find any proper rationalisation in the emerging Local Plan, nor in its supporting evidence, including the Viability Appraisal (December 2020). This is a serious omission that should be properly addressed, to avoid adverse impacts on housing delivery and viability through the Plan period. As it stands, we contend that Policy 5 is therefore unsound.