Object

Representation ID: 24291

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 particularly sections 4.5.2 - 4.5.8 and section 5.1)

Policy 7.1 – The Norwich urban area including the fringe parishes
4.5.2 A total of 32,691 homes are to be delivered in Norwich and the surrounding parishes accounting for 66% of the overall growth for the GNLP area.
4.5.3 Gladman support the identification of Norwich as the most sustainable location for growth however they consider that there are deliverability concerns regarding the quantum of development which has been directed to Norwich. Out of a total commitment of 32,691 new
homes at the Norwich Urban Area, 79%, or 26,019 homes are expected to be delivered on existing commitments and allocations.
4.5.4 Of particular note is the GNLP’s over reliance on The Growth Triangle which is expected to deliver 13,507 homes within the plan period. Gladman question whether it is realistic to assume that this quantum of development could come forward within the plan period to 2038
due to concerns over market saturation and market interest from developers.
4.5.5 The East Norwich Strategic Regeneration Area was identified in the March 2020 Regulation 18 Draft GNLP as having an existing deliverable commitment of 780 dwellings and a total deliverable commitment of 2,000 dwellings following the allocation of a further 1,220
dwellings. The Regulation 19 GNLP establishes a total deliverable commitment of 4,000 homes for the East Norwich Strategic Regeneration Area. Gladman accept that the Deal Ground has increased in size however sufficient evidence must be supplied to demonstrate that the capacity for the area has the ability to increase by 2,000 dwellings.
4.5.6 Gladman support regeneration however realistic timeframes have to be considered when projecting completions from such sites. The supporting policy text in the Regulation 19 GNLP Greater Norwich Local Plan Gladman Representations Pre-Submission Regulation 19
states that further land is yet to be acquired. Given that land within the area is still to be acquired, in addition to the associated costs and remediation works associated with brownfield development, Gladman consider that there could be significant delays to delivery on this site.
4.5.7 As considered before, Covid-19 has changed home buyers’ priorities with a recent Savills survey finding that 71% of younger buyers crave more outdoor space and rural locations. With this in mind Gladman would also question whether the demand exists for 4,000 dwellings
in this location.
4.5.8 Taking this uncertainty over demand for urban dwellings into consideration, it seems logical that further allocations should be located at the Main Towns.

NORWICH
5.1.1 Gladman supports Norwich being identified at the top of the settlement hierarchy as the mostaccessible and sustainable location in the area. The Pre-Submission Draft GNLP sets out the following housing figures for Norwich:
• Homes delivered in Norwich between 1st April 2018 to 31st March 2020: 1,885
• Unimplemented planning permissions and allocations in existing local plans: 5,254
• New allocations and uplift on existing allocations: 4,527
• Total: 11,666
5.1.2 Gladman notes that whilst a large number of sites contributing to the above benefit from planning permission, there are a number of sites allocated in previous local plans which have been brought forward into the GNLP. Gladman questions whether there is sufficient evidence to confirm that these sites will realistically be delivered within the plan period.
5.1.3 As previously mentioned there are risks to the delivery of a large number of dwellings in one market location such as market saturation and Gladman questions whether it is realistic to assume the total number of dwellings assumed will be delivered
5.1.4 Whilst Gladman supports regeneration there is also the question as to whether sites with medium to long term potential such as the East Norwich Strategic Regeneration Area, will deliver over the plan period. Additional infrastructure requirements, costs and remediation works associated with brownfield development need to be taken into consideration when
making assumptions on delivery timescales.