Question 9: Do you support, object, or have any comments relating to the approach to Housing set out in the Delivery Statement?

Delivery statement fine, but would haver liked emphasis on affordable housing through council housing.

House building speed is placed above all other considerations in my opinion, you advocate climate change on one hand then, pretty much since my return to Norfolk in April 2018 have been closing or reducing traffic flow through the City and expecting people to use limited public transport whilst increasing traffic in the growth areas by smashing up new housing developments.

We support the CPRE in challenging the 2014 household projections: 2016 projections to be adopted. Windfall sites must be taken into account when calculating new site requirements. Over-allocating housing sites and allowing land owners/builders to decide if, when and where housing takes place (SNDC acknowledge this is the case) local authorities lose control. (a) There can be no effective coordination of infrastructure provision. A sustainable plan cannot be followed (b) there can be no link between housing need and access for those in need to housing built. "Affordable Housing" is not effective in addressing the most serious need.

I think that to protect the countryside it would be best to develop sites already allocated in the Joint Core Strategy before any further sites allocated in the GNLP are built on. This could also have a beneficial impact on climate change as people will be closer to places of work and services enhancing the opportunities for sustainable travel.

There is a disconnect between the provision of housing and the implementation of infrastructure improvements to deal with growth. The improved infrastructure needs to be put in place BEFORE the development, or at least during it, so that villages do not suffer continued disruption , high volumes of traffic on B roads that cannot deal with it and make the villages unsafe, poor essential services, low level speeds for wireless and poor mobile signal strength. For these villages home working, whilst ideal for some, is just not possible.

New Houses should only be constructed within three miles of employment. Over the past thirty years Tacolneston, despite considerable housing development and still more being sought has become increasingly quiet during daylight hours. Virtually nobody works within the village any more. We are constantly exhorted to tackle the perils of climate change, the very first thing to do is to match housing with local employment. Before the advent of widespread car ownership town properties were more valuable than village houses. Climate change and the accompanying changes to our lifestyles may well leave these rural housing estates an unwanted anachronism.

There is far too much housing in this plan. The plain fact seems to be that almost anything proposed by get rich quick developers is passed in the indiscriminate hast to cover more and more land with concrete. No mention of space for nature. Without the complete natural cycle humans will not last much longer on this earth. The deign of housing also needs attention. So much uninspired over crowded jumble is being added to towns and villages by speculative builders the wonder is that anyone would want to live in such conurbations.

We object to the approach to housing set out in the Delivery Statement in respect of the contingency locations for growth at Wymondham to offset any non-delivery of housing elsewhere, and in particular the sites selected as reasonable alternatives/contingency locations in those settlements.

A number of strategic extensions (for 1,500 dwellings) and garden villages (for 6,500 dwellings) have been identified as reasonable alternative housing allocations at Wymondham. A contingency approach of only 1,000 dwellings for Wymondham is proposed to offset non-delivery of housing allocations and commitments. It is clear that the scale of development anticipated in the proposed strategic extensions and garden villages are inconsistent with the contingency approach for only 1,000 dwellings. It is very unlikely that strategic extensions or garden villages would be delivered quickly enough to address a housing land supply shortfall in Wymondham in the short term. The lead-in times for these types of developments are typically more than 5 years, largely because they are complex and require significant levels of primary infrastructure to be provided e.g. roads and drainage in advance of housing. Therefore, it is considered that the reasonable alternative sites selected for the contingency approach at Wymondham i.e. the strategic extensions and garden villages are not deliverable as contingencies. In addition, as set out in the representations to the Site Allocations document, there are smaller sites in Wymondham that are deliverable and where constraints can be mitigated, which should have been identified as reasonable alternatives to meet the contingency approach e.g. land south of Gonville Hall Farm in Wymondham (Ref. GNLP0320).

The approach to housing delivery to direct development to the smaller villages is supported. However, as set out in the representations to the Site Allocations document, it is considered that a more suitable site should have been selected as a housing allocation in Marsham i.e. the former poultry unit at Fengate Farm Marsham (Ref. GNLP3035) which is a vacant developed site that is available for redevelopment for new housing.

This states that ‘this plan also provides choice and flexibility by ensuring there are enough committed sites to accommodate 9% more homes than “need”.’ CPRE Norfolk disagrees that such a high level of sites should be provided within the GNLP. As a starting point please refer to our response to Q3 where we argue that the insistence of the Government to use the 2014 National Household Projections should be challenged to ensure that the most up-to date figures are used instead. In addition, by proposing not to include windfalls in the buffer the over-allocation of unnecessary housing will be compounded further.

It is very disappointing that there is no mention of phasing as an option within the Draft Plan and Housing Delivery Statement, as this would help to prevent the worst excesses of unnecessary development. 68 Parish and Town Councils in Broadland and South Norfolk (over 37%) have supported CPRE Norfolk on this issue and have signed a pledge to this effect. With this groundswell of grassroots opinion making such a strong case, we urge the GNDP in producing the GNLP to consider phasing seriously as the most reasonable way forward.

With an existing commitment (April 2019) of 33,565 houses available in the current JCS (draft GNLP consultation p44), and a long-term delivery rate (2009-2019) that averages 1,652 net completions per annum (figures from JCS Annual Monitoring Reports,) it is highly likely that the current commitment is sufficient to cover at least 18 years of new housing development i.e. to 2038 as a minimum. In these circumstances there really is no need for any new sites to be allocated in the GNLP.

This states that ‘this plan also provides choice and flexibility by ensuring there are enough committed sites to accommodate 9% more homes than “need”.’ Hempnall Parish Council disagrees that such a high level of sites should be provided within the GNLP. As a starting point please refer to our response to Q3 where we argue that the insistence of the Government to use the 2014 National Household Projections should be challenged to ensure that the most up-to date figures are used instead. In addition, by proposing not to include windfalls in the buffer the over-allocation of unnecessary housing will be compounded further.

It is very disappointing that there is no mention of phasing as an option within the Draft Plan and Housing Delivery Statement, as this would help to prevent the worst excesses of unnecessary development. We are one of 68 Parish and Town Councils in Broadland and South Norfolk (over 37%) that has supported CPRE Norfolk on this issue and have signed a pledge to this effect. With this groundswell of grassroots opinion making such a strong case, we urge the GNDP in producing the GNLP to consider phasing seriously as the most reasonable way forward.

With an existing commitment (April 2019) of 33,565 houses available in the current JCS (draft GNLP Plan page 44), and a long-term delivery rate (2009-2019) that averages 1,652 net completions per annum (figures from JCS Annual Monitoring Reports,) it is highly likely that the current commitment is sufficient to cover at least 18 years of new housing development i.e. to 2038 as a minimum. In these circumstances there really is no need for any new sites to be allocated in the GNLP.

The requirement that sites should only be allocated for housing where, having regard to policy requirements, there is a reasonable prospect that housing can be delivered fully accords with para 67 of the NPPF.
Whilst the submission of Delivery Plans as part of a planning application is supported the documents need to recognise that there may be unforeseen material changes in circumstances, which could impact the delivery of an allocation.
The Council’s approach to providing choice and flexibility in terms of housing growth by accommodating 9% more homes than are needed, along with contingency sites, is, in principle, supported.
This buffer will help maintain the supply and delivery of housing, in accordance with the NPPF and specifically the Government’s objective of encouraging authorities to consider more growth than required to meet local housing need, particularly in locations where there is potential for significant economic growth, such as the Cambridge Norwich Tech Corridor.
However, to guard against non-delivery, particularly in relation to the potential failure of larger strategic sites in the Norwich urban area to come forward, a minimum buffer of 10% should be identified. Indeed, the draft GNLP states on page 45 that the Regulation 19 version of the Plan will aim to provide a minimum buffer of 10% (at least 250 further homes), which is likely to be provided through a combination of additional sites proposed through the consultation, and the contingency sites.
This approach will provide certainty for stakeholders, including the public, and ensure that the plan is sufficiently flexible to enable it to respond to changing circumstances.
Based on the foregoing, it is recommended that the contingency locations are upgraded to committed sites. The identification of contingency sites provides ambiguity as to when and where development may be located. This uncertainty has the potential to undermine the ability to ensure that development during the plan period is delivered in a coordinated manner. More specifically, the potential for Wymondham to be required to accommodate between 100 and 1,100 units provides significant uncertainty, making it difficult for stakeholders, such as Norfolk County Council Education, to identify a clear strategy in relation to infrastructure provision.
This is particularly relevant given the under delivery of housing in the Greater Norwich Area between 2011 and 2019, which in locations such as Wymondham has resulted in unplanned and uncoordinated development.
The identification of the Norwich Urban Area and Main Towns, such as Wymondham, as suitable locations for the majority of growth within the Greater Norwich Urban Area, given that they provide a range of services and amenities is supported. For example, Wymondham is identified as a strategic employment location that will make a significant contribution to the Cambridge Norwich Tech Corridor and, accordingly, is a suitable location for additional growth. However, within these locations, clear evidence needs to be provided to demonstrate that there is a realistic prospect of development being delivered on the sites, particularly the large strategic allocations which are classed as existing commitments, but are yet to be delivered.

Yes, there are too many existing permissions without action

The statements contained in these sections are both relevant and compelling. However, the approach to housing is inconsistent with those statements, for example the use of old statistics on housing need, the overshoot of planned numbers of houses, the developing reliance on 'other villages' to provide housing growth without any clear statement as to the provision of infrastructure to support this growth. The contents of the climate change statement is worthy enough but lack both coherence and targets eg: 'increase sustainable transport use and transport solutions' - worthy stuff but in the GNLP support section it states 'support' not initiate.

The proposal to only allocate housing sites where there is a reasonable prospect of delivery can be evidenced is fully supported, and accords with paragraph 67 of the NPPF.

The requirement for delivery plans to be submitted with planning applications is supported, but it is important to recognise that there may be unforeseen material changes in circumstances which could impact the delivery of an allocation, and consequently, a degree of flexibility will be required to ensure viable and sustainable development.

The Plan’s proposal to accommodate 9% more homes than “need” indicates is supported; this buffer will help ensure that the supply and delivery of housing is maintained.

The proposal to only allocate housing sites where there is a reasonable prospect of delivery can be evidenced is fully supported, and accords with paragraph 67 of the NPPF.

The requirement for delivery plans to be submitted with planning applications is supported, but it is important to recognise that there may be unforeseen material changes in circumstances which could impact the delivery of an allocation, and consequently, a degree of flexibility will be required to ensure viable and sustainable development.

The emphasis on the opportunity to “strengthen Greater Norwich’s role as a key part of the national economy with the Cambridge Norwich Tech corridor becoming an increasingly important axis linking to two other nationally significant growth corridors” is supported.

The delivery statement claims a proactive approach to delivery through only allocating housing sites where a reasonable prospect of delivery, taking into account delivery requirements of the plan can be evidenced.

However, no evidence of delivery of the 36,000 commitments and existing allocations being carried forward is provided within this consultation. It is noted that 13,430 of the commitments are in the Growth Triangle where delivery has been slow to date.

Lanpro have queried the lack of availability of delivery evidence and been informed that this information will be provided at the Regulation 19 stage. In our view this is too late for consultees to be able to make any meaningful comments on the likely delivery of these commitments which make up 82% of the required housing numbers to 2038.

In order to be able to test and influence the soundness of the chosen strategy this information is needed at an earlier stage than Regulation 19. It is accepted that the information may change over time, but the current document identifies a commitment figure at this point in time that the Greater Norwich Partnership are asking consultees to assume is deliverable with no evidence to back this up. Evidence of this should be provided prior to Regulation 19 to enable proper opportunity for review and comment by consultees and the potential to suggest changes to the strategy that could be taken on board prior to the Regulation 19 consultation stage.

Compulsory purchase powers are mentioned where delivery turns out not to be in accordance with agreed delivery plans for “strategically significant development”. What is the plan’s definition of “strategically significant development”? This should be defined. How realistic is the use of compulsory purchase when this can be costly and time consuming?

The 9% buffer specified is below the 10% minimum buffer required in the NPPF. It is recognised that two contingency locations have also been identified including a site at Costessey and no specific site at Wymondham.

With the emphasis placed on the deliverability of the selected site allocations and existing commitments as set out in the first part of the Delivery Statement, the size and need for any required future contingency site is assumed to be relatively small. It is not considered that contingency land at both Costessey and Wymondham should be needed and if it is, this would be better allocated as part of an early phase of development at a new settlement at Hethel where it can support jobs growth in the hi-tech corridor and be properly planned to deliver new infrastructure and community facilities taking pressure away from Wymondham in the longer term.

If a contingency option is provided within the plan, it should be clearly identified now and the process for how and when it might be brought forward should be explained. Lanpro consider that it would help provide clarity to landowners and developers and speed up delivery if needed.

Currently, the plan identifies reasonable alternative sites in Wymondham for 4000+ homes that could possibly come forward as a contingency if needed. This is a large and vague number that casts doubt on the confidence of the Greater Norwich Partnership about the deliverability of existing commitments and new allocations.

Why is a 9% surfeit of sites needed? If windfall predictions were included in the calculations there would not need to be any surfeit at all.
And why has phasing of the housing growth not been put forward as an option?

The emphasis on the opportunity to “strengthen Greater Norwich’s role as a key part of the national economy with the Cambridge Norwich Tech corridor becoming an increasingly important axis linking to two other nationally significant growth corridors” is supported.

The delivery statement claims a proactive approach to delivery through only allocating housing sites where a reasonable prospect of delivery, taking into account delivery requirements of the plan can be evidenced.

However, no evidence of delivery of the 36,000 commitments and existing allocations being carried forward is provided within this consultation. It is noted that 13,430 of the commitments are in the Growth Triangle where delivery has been slow to date.

Glavenhill Ltd have queried the lack of availability of delivery evidence and been informed that this information will be provided at the Regulation 19 stage. In our view this is too late for consultees to be able to make any meaningful comments on the likely delivery of these commitments which make up 82% of the required housing numbers to 2038.

In order to be able to test and influence the soundness of the chosen strategy this information is needed at an earlier stage than Regulation 19. It is accepted that the information may change over time, but the current document identifies a commitment figure at this point in time that the Greater Norwich Partnership are asking consultees to assume is deliverable with no evidence to back this up. Evidence of this should be provided prior to Regulation 19 to enable proper opportunity for review and comment by consultees and the potential to suggest changes to the strategy that could be taken on board prior to the Regulation 19 consultation stage.

Compulsory purchase powers are mentioned where delivery turns out not to be in accordance with agreed delivery plans for “strategically significant development”. What is the plan’s definition of “strategically significant development”? This should be defined. How realistic is the use of compulsory purchase when this can be costly and time consuming?

The 9% buffer specified is below the 10% minimum buffer required in the NPPF. It is recognised that two contingency locations have also been identified including a site at Costessey and no specific site at Wymondham.

With the emphasis placed on the deliverability of the selected site allocations and existing commitments as set out in the first part of the Delivery Statement, the size and need for any required future contingency site is assumed to be relatively small. It is not considered that contingency land at both Costessey and Wymondham should be needed and if it is, this would be better allocated as part of an early phase of development at a new settlement at Hethel where it can support jobs growth in the hi-tech corridor and be properly planned to deliver new infrastructure and community facilities taking pressure away from Wymondham in the longer term.

If a contingency option is provided within the plan, it should be clearly identified now and the process for how and when it might be brought forward should be explained. Glavenhill Ltd consider that it would help provide clarity to landowners and developers and speed up delivery if needed.

Currently, the plan identifies reasonable alternative sites in Wymondham for 4000+ homes that could possibly come forward as a contingency if needed. This is a large and vague number that casts doubt on the confidence of the Greater Norwich Partnership about the deliverability of existing commitments and new allocations.

I have not observed any provision for allotment space in any of the current developments despite it being a clearly stated Policy 2 objective.

Please see attached for consultation response from Hempnall Parish Council.

Please see also the Hempnall Parish Council Position Statement on sites in Hempnall proposed by landowners for inclusion in the GNLP - included with this submission. This Position Statement, which deals directly with the detail of what Hempnall Parish Council wants for Hempnall, should be considered alongside our consultation response which makes a number of more general comments about the Draft GNLP.

We support the approach to housing set out in the Delivery Statement. We would raise a query as to what will be considered as a “reasonable prospect of delivery”, this is particularly pertinent for those allocations proposed to be carried forward, some of which were carried forward from the 2004 Plan, which as yet remain undelivered.
The proposed new settlement Honingham Thorpe would deliver significant housing numbers together with jobs and on site infrastructure to create a truly sustainable community. The relationship of the site with the Food Enterprise Park would support a key growth area and the emerging agri-tech corridor, creating a holistic and mutually supportive relationship between the new community, the Food Enterprise Park, Easton College, Norwich Research Park and the UEA.
Clarion, as the country’s largest housing association and one of the country’s leading developers, are well placed to deliver, and have experience on a number of large joint venture schemes. A suite of technical information has been gathered by the comprehensive technical team of local consultants and Clarion’s own dedicated internal team to assess the site and ensure deliverability.

Please see attached for full submission

Please see attached for full submission

Please see attached for full submission

Please see attached for full submission

Please see attached for full submission

On behalf of Carl Palmer & Wellington
Please find attached a full Statement (and appendices including a Connectivity Assessment –Canhams Consulting Ltd.) in response to the exclusion of the above site (GNLP 0283) as a preferred site, for your consideration ; and covering individual policies as considered necessary with reference to Policies 7.3 & 7.4 in particular.

Please see attached for full submission

On behalf of my client, Taylor Wimpey Strategic Land, please find attached representations relating to Land South of Townhouse Road, Costessey, and Green Lane West, Rackheath.