Object
Publication
Representation ID: 24384
Received: 22/03/2021
Respondent: Executors of JM Crane Will Trust & Trustees of JM Crane Children's 2001 Settlement
Agent: Savills
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
Affordable Housing
Draft Policy 5 states: “Major residential development proposals and purpose-built student accommodation will provide:
• at least 33% affordable housing on-site across the plan area, except in Norwich City Centre where the requirement is at least 28% …”
This policy wording is not considered to be effective by inclusion of the reference “at least 33% affordable housing”.
In addition the policy wording does not appear to be robustly justified by the support evidence base. It is stated at paragraph 271 that the supporting Strategic Housing Market Assessment 2017 identifies a need for 11,030 affordable homes across Greater Norwich from 2015 to 2038, 28% of the total housing need identified at that point. In addition it is also stated at paragraph 271 that “The most recent viability study findings… conclude… generally able to provide 28% affordable housing”. Whilst it is noted that the Council has updated its Viability Evidence in December 2020 it doesn’t appear to relate to Broadland Village Clusters. In addition I am aware that Broadland Council has been seeking 28% affordable housing in recent S106 agreements based upon the relevant evidence base.
NDSS
The Pre-Submission Plan does not adequately demonstrate that a policy requirement for all new housing residential development comply with the Nationally Described Space Standards (NDSS) is ‘needed’. The fact that some proposals are already providing development which complies with the relevant standards is not sufficient justification. As such, the Plan is not justified, will not be effective, and is not consistent with national policy.
Affordable Housing
It is requested the policy is amended to state: “Major residential development proposals will provide 28% affordable housing on-site across the plan area. The Council will negotiate with developers if an accurate viability assessment indicates that this target cannot be met in full.”
NDSS
Specific reference to compliance with the NDSS should therefore be removed as it is not justified.
Please find enclosed representations made on behalf of landowner ‘Executors of JM Crane Will Trust’ and ‘Trustees of the JM Crane Children’s 2001 Settlement’ in response to the consultation on the draft Greater Norwich Local Plan (Pre-Submission Plan / GNLP) consultation and accompanying evidence base, including in respect of Land to the east of Aylsham Road, Buxton (site ref. GNLP0297).