Object
Publication
Representation ID: 24369
Received: 22/03/2021
Respondent: Hopkins Homes
Agent: Bidwells
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
The policy’s objective of providing a full range of types, tenure and costs of housing to meet varied housing needs is, in principle, supported. In addition, the provision of minimum space standards and requirements for adaptable homes to be provided to improve the quality of life and meet the needs of an ageing population is, in principle, also supported. However, whilst we share the GNLP’s desire to provide good quality homes there are a number of elements of the Policy that require alteration to ensure soundness.
Affordable Housing
As drafted the policy states that only applications on brownfield sites will be able to challenge affordable housing provision at the application stage. The policy should, in accordance with paragraph 57 of the NPPF recognise that, notwithstanding work to inform a site allocation in the Local Plan, a viability assessment can be submitted at the application stage. The NPPF advises that the weight afforded to the viability assessment at the application stage will be a matter for the decision maker and will have regard to all circumstances in the case, including whether the evidence underpinning the local plan is up to date and whether there has been a change in circumstances since the plan was brought into force.
On this basis, to ensure the policy is justified and consistent with national policy and, therefore, sound, it is recommended that the wording of the policy is revised to state that regard will be given to viability considerations at the application stage for both brownfield and greenfield sites.
Space Standards
Whilst the intention to adopt the Government’s Nationally Described Space Standard (NDSS) is readily acknowledged, it is essential that the policy explicitly provides the necessary justification, as required by footnote 46 of paragraph 127 NPPF. This clearly states: “Policies may also make use of the nationally described space standard, where the need for internal space standard is justified”.
This justification is essential, as strict adherence to space standards can, in some instances, have a negative impact upon affordability issues and reduce customer choice. For example, in terms of choice some developers will provide entry level two, three and four-bedroom properties which may not meet the optional nationally described space standards, but which would allow those on lower incomes to afford a property which has their required number of bedrooms.
At this stage, notwithstanding the PPG, there would appear to be no robust evidence that would suggest that development below space standards is a particular concern throughout the GNLP area, and that the rigid adherence to NDSS is necessary.
Accordingly, we would suggest that if this element of the policy is to be retained that, as a minimum requirement, the policy should provide some flexibility to recognise need and viability, where necessary.
Self and Custom Build
The provision of self and custom build is recognised. However, the threshold that at least 5% of plots on residential proposals of 40 dwellings or more should provide serviced self/custom-build plots is not considered to be justified.
The threshold would result in the number of self and custom build units provided being substantially in excess of the identified need. As stated at paragraph 282, there are only 113 people on the self and custom build register in the Greater Norwich Area (2018/19). The strategic sites identified on the GNLP i.e. those over 1,000 units, would on their own, deliver substantially more than the identified need.
Whilst it is recognised (and welcomed) that the policy includes wording that provision is not required if there is no need, it is suggested that the threshold is increased to a level which better reflects need.
On this basis, the policy is neither considered to be justified or effective and, therefore, is not sound.
Affordable Housing
The policy should be revised to state that regard will be given to viability considerations at the application stage for both brownfield and greenfield sites.
Space Standards
In the apparent absence of the necessary robust evidence to justify it, the policy should provide some flexibility to recognise need and viability, where necessary.
Self and Custom Build
The threshold should be increased, to better reflect the likely need.
The policy’s objective of providing a full range of types, tenure and costs of housing to meet varied housing needs is, in principle, supported. In addition, the provision of minimum space standards and requirements for adaptable homes to be provided to improve the quality of life and meet the needs of an ageing population is, in principle, also supported. However, whilst we share the GNLP’s desire to provide good quality homes there are a number of elements of the Policy that require alteration to ensure soundness.
Affordable Housing
As drafted the policy states that only applications on brownfield sites will be able to challenge affordable housing provision at the application stage. The policy should, in accordance with paragraph 57 of the NPPF recognise that, notwithstanding work to inform a site allocation in the Local Plan, a viability assessment can be submitted at the application stage. The NPPF advises that the weight afforded to the viability assessment at the application stage will be a matter for the decision maker and will have regard to all circumstances in the case, including whether the evidence underpinning the local plan is up to date and whether there has been a change in circumstances since the plan was brought into force.
On this basis, to ensure the policy is justified and consistent with national policy and, therefore, sound, it is recommended that the wording of the policy is revised to state that regard will be given to viability considerations at the application stage for both brownfield and greenfield sites.
Space Standards
Whilst the intention to adopt the Government’s Nationally Described Space Standard (NDSS) is readily acknowledged, it is essential that the policy explicitly provides the necessary justification, as required by footnote 46 of paragraph 127 NPPF. This clearly states: “Policies may also make use of the nationally described space standard, where the need for internal space standard is justified”.
This justification is essential, as strict adherence to space standards can, in some instances, have a negative impact upon affordability issues and reduce customer choice. For example, in terms of choice some developers will provide entry level two, three and four-bedroom properties which may not meet the optional nationally described space standards, but which would allow those on lower incomes to afford a property which has their required number of bedrooms.
At this stage, notwithstanding the PPG, there would appear to be no robust evidence that would suggest that development below space standards is a particular concern throughout the GNLP area, and that the rigid adherence to NDSS is necessary.
Accordingly, we would suggest that if this element of the policy is to be retained that, as a minimum requirement, the policy should provide some flexibility to recognise need and viability, where necessary.
Self and Custom Build
The provision of self and custom build is recognised. However, the threshold that at least 5% of plots on residential proposals of 40 dwellings or more should provide serviced self/custom-build plots is not considered to be justified.
The threshold would result in the number of self and custom build units provided being substantially in excess of the identified need. As stated at paragraph 282, there are only 113 people on the self and custom build register in the Greater Norwich Area (2018/19). The strategic sites identified on the GNLP i.e. those over 1,000 units, would on their own, deliver substantially more than the identified need.
Whilst it is recognised (and welcomed) that the policy includes wording that provision is not required if there is no need, it is suggested that the threshold is increased to a level which better reflects need.
On this basis, the policy is neither considered to be justified or effective and, therefore, is not sound.