Object

Representation ID: 24289

Received: 22/03/2021

Respondent: Gladman Developments

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Please find attached the representations of Gladman in response to the Reg 19 Pre-submission Draft consultation.

Policy 1 – The Growth Strategy

4.2.1 As discussed in Section 3, the local housing needs assessment conducted using the Standard Method set out in national planning guidance forms only the minimum level of housing need for a local authority and does not establish a housing requirement figure.
4.2.2 Using the Government’s standard methodology for identifying local housing need, based on the 2014 household projections, the GNLP’s housing requirement for the period 2018-2038 is 40,541.
4.2.3 Nonetheless, the standard method does not account for changing economic circumstances, government policies or other issues that may affect demographic behaviour. In this instance, national planning policy does highlight circumstances whereby additional housing growth above the figure indicated by the standard method may be appropriate, including:
• “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.”
4.2.4 It is vital that the Plan considers economic growth when assessing the local housing need and considers if it is appropriate to set a higher housing requirement than indicated by the standard method to support economic growth ambitions
. Further to this, the Greater Norwich City Deal was signed with Government in December 2013 which aimed to create an additional 19,000 jobs and 3,000 homes. In order to support the enhanced growth potential, it is vital
that the GNLP plans for a sufficient number of new homes.
4.2.5 Additionally, the Government has highlighted the long-term role the planning system and housebuilding has to play in the economic recovery from the COVID-19 pandemic, locally and nationally
. In this way, Gladman encourages the GNDP to fully consider the merits of planning for a housing figure beyond the minimum requirement of 2,027 dwellings per annum. For instance, an increased housing figure would enable the Greater Norwich authorities to capture
a larger proportion of the £7 billion yearly housebuilder contributions10. With 218,000 homes predicted not to be built due to COVID-19 from now to 2024/2511, it is also imperative that the GNLP identifies sufficient land to support the delivery of homes.
4.2.6 In order for the housing needs for the whole plan period to be met, it will also be essential to provide sufficient headroom within the housing supply. In this regard, Gladman supports the Home Builders Federation’s recommendation that local plans should seek to identify sufficient deliverable sites to provide a 20% buffer between the housing requirement and supply.
4.2.7 Table 6 sets out the GNLP’s total housing potential between 2018 and 2038 which establishes that the GNLP has the potential to provide a buffer of 22% over its housing requirement. Gladman acknowledges and supports the GNLP in its provision of a 22% buffer above thelocal housing need figure but questions whether the buffer is sufficient after taking into consideration the additional housing needs of Norwich due to the signed City Deal. Any homes which are included in the figures to meet the need of the greater growth aspirations should not be included within the buffer. If the result of removing this additional need from the current 22% buffer resulted in a buffer of below 20%, then further sites should be
allocated.
4.2.8 Gladman notes that 74% of the growth expected to come forward over the plan period to 2038 is from completions since the start of the plan period in 2018, permitted sites and existing allocations and commitments from the Site Allocations Plans, Area Action Plans for
Wymondham, Long Stratton and the Growth Triangle and Neighbourhood Plans. Gladman acknowledges that a proportion of these sites already benefit from planning permission however raise concern over the deliverability of these sites.
4.2.9 Gladman has specific concerns that the levels of housing proposed will not be delivered on these existing allocations, many of which have been allocated for over five years and have not come forward to date. Gladman questions whether any further analysis or evidence has been provided to understand why these sites have not delivered and to demonstrate clearly that
these sites will realistically be delivered within the plan period to 2038.
4.2.10 In order to achieve the figure of 31,452 dwellings coming from existing commitments, the GNLP is reliant upon an uplift of the housing density on the existing allocated sites. Gladman questions whether this approach is realistic or feasible. It appears to be an uncertain strategy to assume densities will increase on allocated sites and any uplift needs to be fully supported
by evidence that there is a realistic chance that the uplifted quantum of development is achievable on the site. It is important to consider the implications Covid-19 has had on the demand on certain types of properties. A recent Savills Survey12 found that 39% of under 50s
now want a bigger home with greater importance being put on more outdoor space. With this in mind, Gladman questions if it is realistic to assume that an uplift in the density of existing allocations can be achieved and suggests a more appropriate strategy would be to
allocate further sites to ensure that a sufficient buffer is available.
Settlement Hierarchy
4.2.11 Table 7 sets out Policy 1’s settlement hierarchy. The hierarchy comprises four tiers to support
a proportionate amount of growth according to the size and role of the settlement.
4.2.12 Gladman is supportive of the settlement hierarchy and particularly the identification of Diss and Wymondham as Main Towns. Table 7 shows that the growth in this tier of the hierarchy is 6,806 additional dwellings up to 2038. The amount of growth allocated to the Norwich Urban Fringe is 32,691 dwellings to 2038. Gladman submits that there is a risk to the delivery
of the sites identified on the Norwich Urban Fringe due to issues such as market saturation. Gladman also questions whether the uplift to the assumed densities on sites in this location are realistic and achievable.
4.2.13 Gladman submits that further growth should be allocated to the Main Towns to ensure the housing need figure is delivered and to allow for greater flexibility. Offering a wider variety of sites to the market in varied locations across the Greater Norwich area will provide greater certainty that the housing requirement will be met. Gladman’s submissions in respect of the growth strategy are provided in more detail below under Policy 7 – Strategy for Areas of Growth.