Object
Publication
Representation ID: 24537
Received: 19/03/2021
Respondent: Mr Bryan Robinson
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
Affordable Housing
10.1. Policy 516 appears to restrict the use of Viability Assessments (VA)s in planning applications with the intention of reducing the percentage of Affordable Housing to Brownfield sites.
10.2. Whilst this is welcome to counter the misuse VAs which has almost become almost standard practice, Section 57 of NPPF states that it is up to the applicant to
demonstrate whether particular circumstances justify the need for a VA and therefore the legality of this Policy needs to be considered.
10.3. Does this Policy restricting the use of VAs to brownfield sites create a conflict with
the NPPF?
10.4. Policy 5 also differentiates sites allocated within Neighbourhood Plans proposing that a different percentage of affordable housing can be stated therein, overridingthe minimum of 33% across the plan area.
10.5. The Affordable Housing Need is stated at paragraph 271 of Reg. 19 v 1.7 as 11,030 between 2015 and 2036 being 28% of the overall housing need as established in the 2017 SHMA Report.
10.6. The Housing Need has since been recalculated as 40,541 but the number of affordable housing has not been reassessed over the revised timescales.
10.7. Assuming the affordable housing percentages will apply to the 22% buffer of allocations above the defined overall housing need, basic mathematics
determines that the number of affordable housing units will exceed the need by 2,427 if all the sites are developed over the period.
10.8. Affordable Housing provision on a site is a contributor to establishing profitability for the developer and therefore may inhibit development if there is an
overprovision, continuing to the circularity of controlling the supply of all housing.
10.9. The Plan does not indicate the reduced number of affordable homes are already in the system through the reductions in Neighbourhood plans and committed
sites with approved lower percentages of affordable housing.
10.10. All this data should be readily available to the GNDP and the plan should show the numbers of affordable houses which will be provided against this policy for meeting the overall housing need target and how this will be managed in scenarios where the overall need is not being met and if annual completions are
nearer to the target including the 22% buffer.
10.11. Without this study comparing potential extra affordable homes if the buffer is built out and reductions from Neighbourhood plans and lower approved numbers
in existing commitments the policy on affordable homes is meaningless.
1. Introduction
1.1. Comments have been invited under Reg. 19 of the Town and Country Planning Act(Local Planning) (England) Regulations 2012 on the soundness of the draft Greater Norwich Local Plan (GNLP) prior to submission to the Planning Inspectorate.
1.2. Soundness is defined as:
1.2.1. Positively prepared: The plan should be based on a strategy which seeks to meet objectively assessed development and infrastructure requirements, including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent which achieving sustainable development.
1.2.2. Justified: The plan should be the most appropriate strategy when considered against the reasonable alternatives, based on proportionate evidence.
1.2.3. Effective: The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities.
1.2.4. Consistent with national policy: The plan should enable the delivery of sustainable development in accordance with the policies in the National Policy Framework.
1.3. There are several reasons why I consider the Draft Plan in Reg. 19 is unsound but initially question the legitimacy of the changes in the Reg. 19 draft which fundamentally change the principles of the Reg. 18 consultation and on which the public are being denied representation which is patently unfair.
2. Fairness
2.1. It is trite law that a public body must adopt a fair procedure to decision-making to ensure that members of the public are given a fair and informed say before the decision comes into effect.
2.2. The draft Reg. 19 v 1.7 documents have significantly increased by 15% the housing provision over the life of the plan above the proposals in the Reg. 18 consultations initially citing Government proposals in the ‘Planning for the future’ consultation but later changing this to the fact that the 2018-based Government projections for Greater Norwich are higher than the 2014-based projections, as justification for going back on the intention for a further stage 18D consultation.
2.3. This approach of planning for the higher numbers in the 2018-based projections goes against the Government statement that the 2014-based projections should continue to be used in Local Plans.
For full representation view attachment.