Object

Representation ID: 23672

Received: 12/03/2021

Respondent: Home Builders Federation

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Housing needs
3. The Council state that the application of the standard method results in a minimum housing need across the plan period 2018 to 2038 of 40,541 homes – 2,027 dwelling per annum (dpa). However, we could not find in the Council’s evidence any clarity as to which years have been used in terms of household growth and the affordability ratio. It would be helpful if the Council could provide a statement on this matter on submission of the local plan and any justification for the data used.
4. It is also important to note that the application of the standard method and the resulting local housing needs assessment is the minimum level of housing needs local planning authorities are required to meet. Planning Practice Guidance states at paragraph 2a-010 that there will be circumstances where it is appropriate to consider whether actual housing need is higher than the standard method indicates. This paragraph goes on to outline three such situations.
5. One of the situations identified in PPG is the presence of a strategy in an area that is in place to facilitate additional growth. It is therefore important to consider the City Deal1 agreed with Government in December 2013. This deal committed the authorities in the Greater Norwich area, in return for significant additional funding, to achieve growth above what was being planned for the area. In relation to housing the City Deal states the Councils in the Greater Norwich Area would deliver an additional 3,000 homes above the Core Strategy target of 36,820 homes by 2026. In short there was a commitment that circa 40,000 homes would have been built between 2008 and 2026 - over 2,200 dpa. Between 2008/09 and 2017/18 the Councils’ monitoring reports show that 15,472 new homes were built. When this is added to the number of homes expected be delivered between 2018/19 and 2025/26 (20,871 new homes) there is a shortfall in delivery of 3,477 against its commitment in the City Deal. This shortfall suggests that there will be a higher minimum level of housing need in this plan than results from the standard method. The HBF considers it to be essential that the Council continues to support the level of growth it committed to in the City Deal, and this must be reflected in the GNLP’s housing requirement.

Housing supply
6. With regard to supply the HBF welcomes the Council’s decision to include a substantial buffer between its housing requirement and housing supply. This is essential in order to ensure the plan has sufficient flexibility to meet needs in full across the plan period. However, whilst the Council has included a housing trajectory at Appendix 6 of the GNLP we could not find included in the evidence as to when each of the allocated sites is expected to contribute to this supply. This evidence is an essential part of any local plan examination as it ensures effective scrutiny of the delivery assumptions made with regard to each site and whether these assumptions are sound. In particular it is important part of any discussion regarding the 5-year housing land supply and whether the development supporting supply in the first five years of the plan is deliverable as defined in the National Planning Policy Framework (NPPF).