Question 14: Do you support, object or wish to comment on the approach for housing numbers and delivery?

Object

Representation ID: 21823

Received: 12/03/2020

Respondent: Barford Parish Council

• As said above (see attached for full submission), and as highlighted by the CPRE response, the use by Government of the outdated 2014 National Household Projections is leading to unnecessary land allocation for housebuilding.
• Barford and Wramplingham Parish Council wish to see land already allocated for house building used up before any new allocated land is used, with a focus on brownfield sites first – we are pleased to see this has recently happened in Barford.
• Barford and Wramplingham Parish Council do not understand why more land is set to be allocated when the 2016 projections of housing need to 2038 will be met by the area of sites currently allocated as stipulated in the CPRE response.

Object

Representation ID: 21849

Received: 12/03/2020

Respondent: Hempnall Parish Council

Paragraph 145 claims that the strategy ‘is informed by consultation feedback’, yet chooses to ignore much from previous consultations even where such feedback was significantly in favour of a particular approach. An example of this is the position taken towards windfalls. Responses to the Stage A Regulation 18 Site Proposals and Growth Options consultation were significantly against (110 to 45) counting windfalls in addition to the additional (at that point 7,200) housing, and yet this has been ignored in the current draft plan consultation. By not counting windfalls in the calculation for housing numbers in table 6, there will be a resulting over-supply of houses, particularly if the out-of-date 2014 National Housing Projections are used. Windfalls are acknowledged as a reliable source of new housing and many Local Authorities do count them towards their housing targets: their contribution towards housing targets in the GNLP should lead to a reduction in the number of new sites which are allocated.

Hempnall Parish Council also has specific concerns about the approach for housing numbers in the South Norfolk Village Clusters, as there is no total figure given for this new housing, but instead an open-ended ‘minimum of 1,200 homes’. This use of the word “minimum” needs to be removed and replaced by a “maximum” total, so that further potential over-supply is avoided. At best, the actual delivery of new housing in the plan area has only occasionally exceeded 2,000 dwellings per annum, with 1,500 being more typical. At this build-rate, current commitments cover actual housing need to 2038.

Hempnall Parish Council wants to see sites allocated for housing in the existing plan (JCS) developed before any new sites that are likely to be added in to the emerging GNLP are built out. New site allocations for housing should be treated as phased development and these sites should not be built out until the current JCS sites have been used up. We think this is a sensible approach because not only does it protect the countryside, but also at current rates of house building there is enough land already allocated in the JCS to cater for the building that is likely to occur over the new Plan period.

There is very little evidence to show that increasing the amount of land on which houses can be built actually increases the rate at which they are built. All that happens is that developers ‘cherry-pick’ the most profitable sites, which are likely to be the newly allocated green field sites and that this will lead to even more land banking of currently allocated sites. This will also mean that many less sustainable sites for housing are developed rather than those with more sustainable locations. This would result in more pollution and congestion, with the negative consequences for the climate and climate change. It also means that expensive infrastructure which has been provided to facilitate new housing in the existing plan, could end up being an irrelevant and embarrassing white elephant.

It is disappointing that there is no mention of phasing as an option within the consultation document, as this would help to prevent the worst excesses of unnecessary development. Hempnall together with a total of 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, which was included in the previous consultation, but ignored in the current draft Plan. 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. Clearly there is a democratic deficit: meaningful consultation should not ignore this volume of common-sense opinion.

Comment

Representation ID: 21904

Received: 12/03/2020

Respondent: Home Builders Federation

Housing needs and supply
In arriving at the local housing needs assessment (LHNA) for the Greater Norwich area the Councils have used the annual household growth between 2019 and 2029. Whilst we recognise that the Government states that the current year should be the base date from which to assess needs if the Councils wish to start their plan from 2018 then it would be logical for the base period of the assessment of household growth to be the 2018 to 2028 period. This would result in a LHNA of 41,040. Slightly higher than the 40,550-figure suggested by the Council.
It will also be necessary for the Council to liaise with neighbouring areas to ensure that they are meeting their housing needs and that they will not need to deliver additional units in line with paragraph 60 of the NPPF. The Council will also need to consider whether the proposed level of housing delivery will support the Councils’ jobs growth expectations. Planning Practice Guidance outlines that there will be circumstances where it will be necessary to consider whether housing need is actually higher than the stand method indicates. One such circumstances is where there are growth strategies for the area. The Greater Norwich Local Plan seeks to deliver an additional 33,000 jobs over the plan period and it will be necessary for the Council to ensure that its proposed housing requirement is sufficient to support the level of jobs growth anticipated.
It is also unclear as to whether the GNLP will ensure the delivery of sufficient homes to meet the targets established in the City Deal. This committed the Greater Norwich authorities to delivering 37,000 between 2008 to 2026. The Authority Monitoring Reports (AMR) for the Greater Norwich area indicate that between 2008/09 and 2018/19 some 18,287 new homes were delivered. Th is leaves a further 18,722 left to deliver by 2026. On the basis of the proposed requirement of 2,027 dpa there will be a shortfall of circa 6,500 homes. It will therefore be important that the Councils seek to ensure that there are sufficient sites allocated in GNLP that can deliver homes in the first five years post adoption to meet the commitments in the City Deal.
With regard to the delivery of new homes to meet needs we welcome the Councils’ decision to include a buffer of 9%. In addition, we note that the Council has not included
any windfall within its assessment of supply which will also provide an additional buffer. We note that a contingency site has been included at Costessey. Whilst we have no objections to its inclusion it would be sensible to include some smaller sites as contingency that could be brought forward more quickly should any of the larger sites not come forward as expected.

Support

Representation ID: 21929

Received: 13/03/2020

Respondent: Mr Eric Hall

(Representation on behalf of Marstons Estates Ltd)

Please see attached for full comments
We support the overall growth strategy of the Plan and consider that Diss is appropriately identified as a main town to which significant additional development can be directed.

The site allocations plan does not include any allocation for the subject site and the writer therefore infers that the DIS 6 allocation is effectively removed, leaving the site as unallocated land albeit within a defined settlement boundary; moreover as noted above Diss is considered a suitable location for significant development. If the site were to come forward subsequent to the plan it would be considered a windfall; under Policy 1 this would be acceptable in principle at appropriate scales and locations where they would not have a negative impact on the character and scale of the settlement and subject to other local plan policies.

On this basis we support Policy 1 and do not oppose the removal of DIS 6.

Support

Representation ID: 21941

Received: 13/03/2020

Respondent: UEA Estates & Buildings

Agent: Bidwells

For reasons outlined in relation to Question 12, the UEA fully support the identification of the Norwich Urban Area as a location to accommodate additional growth.

Object

Representation ID: 21984

Received: 16/03/2020

Respondent: Ms Carol Sharp

Paragraph 146 claims that the strategy ‘is informed by consultation feedback’, yet chooses to ignore much from previous consultations even where such feedback was significantly in favour of a particular approach. An example of this is the position taken towards windfalls. Responses to the Stage A Regulation 18 Site Proposals and Growth Options consultation were significantly against (110 to 45) counting windfalls in addition to the additional (at that point 7,200) housing, and yet this has been ignored in the current draft plan consultation. By not counting windfalls in the calculation for housing numbers in table 6, there will be a resulting over-supply of houses, particularly if the out-of-date 2014 National Housing Projections are used. Windfalls are acknowledged as a reliable source of new housing and many Local Authorities do count them towards their housing targets: their contribution towards housing targets in the GNLP should lead to a reduction in the number of new sites which are allocated.

159 As previously mentioned in the introduction comment, use of the word “minimum” needs to be
removed and replaced by a “maximum” total.

164-4 We cant see how the growth in villages ‘will support local services’ rather it will be a drain on
them.

As previously mentioned sites in the existing plan (JCS) should be developed before any new sites that are likely to be added in to the emerging GNLP are built out. Although we understand that it will not be possible to prevent new sites being included in the plan, we are asking that these extra land allocations for housing are treated as phased development and that building should not occur on these sites until the current JCS sites have been used up. We think this is a sensible approach because not only does it protect the countryside, but also at current rates of house building there is enough land already allocated in the JCS to cater for the building that is likely to occur over the new Plan period.

As previously mentioned developers ‘cherry-pick’ the most profitable sites, which are likely to be the newly allocated green field sites and that this will lead to even more land banking of currently allocated sites. This will also mean that many less sustainable sites for housing are developed resulting in more pollution and congestion, with the negative consequences for the climate and climate change. It also means that expensive infrastructure which has been provided to facilitate new housing in the existing plan, could end up being an irrelevant and embarrassing white elephant.

It is disappointing that there is no mention of phasing as an option within the consultation document, as this would help to prevent the worst excesses of unnecessary development. 69 Parish and Town Councils in Broadland and South Norfolk (over 38%) have signed a pledge to this effect, which was included in the previous consultation, but ignored in the current draft Plan. 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. Clearly there is a democratic deficit: meaningful consultation should not ignore this volume of common-sense opinion.

Support

Representation ID: 21993

Received: 13/03/2020

Respondent: Redenhall with Harleston Town Council

The Town Council supports the preferred option in Policy 1, (Sustainable Growth Strategy).

Object

Representation ID: 22020

Received: 15/03/2020

Respondent: Mulbarton Parish Council

As above MPC have concerns that there is no maximum number for clusters and notes that at the present build rate current commitments cover actual housing need until 2038. MPC do not understand why new areas have to be allocated when the current JCS sites have not all been used and has the potential to allow developers to cherry pick sites.

Support

Representation ID: 22035

Received: 13/03/2020

Respondent: East Suffolk Council

We support the Greater Norwich Local Plan’s preferred option to support growth, including the use of the Government’s standard methodology for assessing housing numbers and delivery, use of a settlement hierarchy, and approach to the economy. We are pleased the strategy for growth can meet the area’s need for housing, including a buffer, and need for employment land.

Support

Representation ID: 22092

Received: 13/03/2020

Respondent: Watkin Jones Group

WJG support these objectives for creating a vibrant and inclusive area that is enhanced by new homes, infrastructure
and environment.

Comment

Representation ID: 22130

Received: 16/03/2020

Respondent: M Scott Properties Ltd

Agent: Strutt & Parker LLP

In developing the new Greater Norwich Local Plan, it will be important that an adequate mix of sites is promoted including a proportion of smaller sites as well as sites to meet specific housing needs (including housing for older people). Our client’s site, Land between Shelfanger and Mount Street could make a meaningful and positive contribution towards meeting these goals.

With regard to the delivery of new housing, the Greater Norwich Local Plan’s inclusion of a 9% buffer is supported, and while a higher buffer of up to 20% would normally be advisable to offset the potential for slow delivery on some sites, in particular large strategic sites. It is acknowledged that no allowance has been made in this instance for windfall within the overall supply and the contingency of approximately 2,000 homes provides additional flexibility to ensure that the overall housing needs are met. However, as outlined above, given the uncertainty around the Carrow Works site (1,200 homes), it would be advisable to allocate smaller sites up to c. 25 units (c. 1 ha) across the Plan area to help boost the supply of new homes.

It is acknowledged that the Plan aims to comply with paragraph 68 of the NPPF by accommodating at least 10% of the housing requirement on sites no larger than 1 ha, however, where there are reasonable alternatives available these should be included to maintain supply and avoid the need to rely on less certain strategic sites or large contingency sites.

The “presumption in favour of sustainable development” is at the heart of the National Planning Policy Framework 2019 (NPPF). The Planning and Compulsory Purchase Act 2004 (Section 39(2)) establishes a legal requirement for Plans to be prepared with the objective of contributing to the achievement of sustainable development.

Paragraph 16 of the NPPF requires plans to be prepared positively in a way that is aspirational but deliverable. Paragraph 59 reminds Local Planning Authorities that the Government’s objective is to significantly boost the supply of homes and that it is therefore important that a sufficient amount and variety of land comes forward where it is needed.

To ensure that Local Authorities have specific deliverable sites they are required to maintain a 5 Year Housing Land Supply with an appropriate buffer. In addition, to ensure supply is maintained, they are also required to monitor the progress in building out sites, to comply with the housing delivery test. The Government’s recently published housing delivery figures for 2019 indicate delivery for the Greater Norwich area comprising Broadland, Norwich and South Norfolk to be at 140%. This is very encouraging, however, housing delivery can be fragile and susceptible to changes in the economy or delays in the delivery of key infrastructure necessary for strategic sites to come forward.

Further to the above, Policy 1 – The Sustainable Growth Strategy sets the settlement hierarchy for the Plan Area as follows:
1. Norwich Urban Area (Norwich and Norwich Fringe)
2. Main Towns
3. Key Service Centres
4. Village Clusters

Further detail on Village Clusters is provided at Appendix 5 of the Draft Strategy, as the preferred option the Council consider that a ‘cluster approach better reflects the way people access services in rural areas and enhances social sustainability by facilitating levels of growth in small villages’ This statement is supported, however it is unclear how this approach will work effectively within the Plan area and how achievable it will be. As such, a focus should be made on small and medium sites. The distribution of growth to a variety of sites will enable a steady delivery of homes and ensure the District can meet its housing targets throughout the Plan period.

Object

Representation ID: 22150

Received: 15/03/2020

Respondent: Chris and Linda Ball

Number of people: 2

The GNLP calculates housing needs based on the 2014 National Household Projection. It should use the 2016 National Household Projections and there is no acceptable excuse for not doing so. An ill thought-out strategy/proposal in our opinion.

Comment

Representation ID: 22154

Received: 16/03/2020

Respondent: Pigeon Investment Management Ltd

Agent: Pegasus Group

Housing Requirement
The minimum housing need
3.3 The foreword to the Draft Local Plan identifies a requirement for about 44,500 homes over the next 20-years. This is clarified in Policy 1 which identifies a housing requirement for 44,340 homes in response to a need for 40,550.
3.4 The need for 40,550 homes is identified as having been calculated using the standard method according to Table 6 and the box at the bottom of page 53.
3.5 The standard method provides the minimum local housing need according to the PPG (2a-004) and is calculated using the average household growth for 10 consecutive years, with an affordability uplift based on the median workplace-based house price to earnings ratio of the preceding year1.
3.6 The Draft Local Plan covers the period from 1st April 2018. In order to establish the minimum local housing need for the plan period it is therefore necessary to calculate either the standard method at 2018; or to calculate the current standard method and apply this to the remainder of the plan period in addition to the number of completions which have already occurred.
3.7 In the case of the Greater Norwich Plan Area, the average household growth over the 10 consecutive years from 2018, namely 2018-28, was 400 in Broadland, 510 in Norwich and 704 in South Norfolk. The median workplace-based house price to earnings ratios in 2017 were 9.82, 6.93 and 8.91Housing Requirement
The minimum housing need
3.3 The foreword to the Draft Local Plan identifies a requirement for about 44,500 homes over the next 20-years. This is clarified in Policy 1 which identifies a housing requirement for 44,340 homes in response to a need for 40,550.
3.4 The need for 40,550 homes is identified as having been calculated using the standard method according to Table 6 and the box at the bottom of page 53.
3.5 The standard method provides the minimum local housing need according to the PPG (2a-004) and is calculated using the average household growth for 10 consecutive years, with an affordability uplift based on the median workplace-based house price to earnings ratio of the preceding year1.
3.6 The Draft Local Plan covers the period from 1st April 2018. In order to establish the minimum local housing need for the plan period it is therefore necessary to calculate either the standard method at 2018; or to calculate the current standard method and apply this to the remainder of the plan period in addition to the number of completions which have already occurred.
3.7 In the case of the Greater Norwich Plan Area, the average household growth over the 10 consecutive years from 2018, namely 2018-28, was 400 in Broadland, 510 in Norwich and 704 in South Norfolk. The median workplace-based house price to earnings ratios in 2017 were 9.82, 6.93 and 8.91Housing Requirement
The minimum housing need
3.3 The foreword to the Draft Local Plan identifies a requirement for about 44,500 homes over the next 20-years. This is clarified in Policy 1 which identifies a housing requirement for 44,340 homes in response to a need for 40,550.
3.4 The need for 40,550 homes is identified as having been calculated using the standard method according to Table 6 and the box at the bottom of page 53.
3.5 The standard method provides the minimum local housing need according to the PPG (2a-004) and is calculated using the average household growth for 10 consecutive years, with an affordability uplift based on the median workplace-based house price to earnings ratio of the preceding year1.
3.6 The Draft Local Plan covers the period from 1st April 2018. In order to establish the minimum local housing need for the plan period it is therefore necessary to calculate either the standard method at 2018; or to calculate the current standard method and apply this to the remainder of the plan period in addition to the number of completions which have already occurred.
3.7 In the case of the Greater Norwich Plan Area, the average household growth over the 10 consecutive years from 2018, namely 2018-28, was 400 in Broadland, 510 in Norwich and 704 in South Norfolk. The median workplace-based house price to earnings ratios in 2017 were 9.82, 6.93 and 8.91 respectively. Using these figures, the minimum local housing need over the plan period equates to 41,379 homes.
3.8 Alternatively, the minimum local housing need from 2019 onwards can be calculated using the average household growth over the 10 consecutive years from 2019, namely 2019-29, with the affordability ratios of 2018 applied. The average household growth was 397, 505 and 691 respectively and the median workplace-based house price to earnings ratios were 9.23, 7.03 and 8.78 respectively. These figures produce a minimum local housing need of 2,024 homes per annum which equates to 38,460 homes over the period 2019-38. The number of housing completions in 2018/19 need to be added to this figure to provide the minimum local housing need over the plan period. MHCLG Live Tables identify that there were 2,757 housing completions, as well as 260 student bedspaces and 91 other bedspaces completed in this year. Once the appropriate conversion factors as identified in the PPG (68-034) and the PPG (63-016a) are applied this would equate to 2,901 houses2 completed in 2018/19. In addition to the minimum local housing need of 38,460 over the period 2019-38 this would produce a minimum local housing need for 41,361 homes over the plan period.
3.9 Once the median house price to earnings ratio for 2019 and the number of housing and bedspace completions in 2019/20 are available, it will be possible to provide yet another calculation of the minimum local housing need based on the completions in the period 2018-20 and the minimum local housing need over the period 2020-38. However, given the consistency of the preceding figures it would be expected that this would again be broadly consistent.
3.10 In either case, it is apparent that the standard method has been miscalculated within the Draft Local Plan as it is below the minimum local housing need of either 41,379 or 41,361. Policy 1 and all other references to a need for 40,550 are therefore not justified nor are they consistent with national policy.
3.11 Furthermore, the Government has identified that it intends to review the standard method by September 2020. As the Local Plan is not intended to be submitted for examination until June 2021, it is likely that the Local Plan will need to respond to the new standard method, whatever that may be.
Exceeding the minimum housing need
3.12 The standard method also only provides the minimum local housing need, and the PPG (2a-010) identifies that this should be exceeded including in situations where there is a growth strategy or where strategic infrastructure improvements may drive an increase in housing need or where previous assessments of need are significantly greater than the standard method. All three of these situations arise in Greater Norwich.
The City Deal
3.13 Paragraph 13 of the Draft Local Plan identifies that the Greater Norwich City Deal requirements will be met through the Draft Local Plan. As the Greater Norwich City Deal forms a growth strategy which has been agreed with Government, the Local Plan is required to meet the requirements of the City Deal as this forms part of national policy as set out in paragraph 6 of the NPPF.
3.14 The City Deal identifies that strategic infrastructure is needed including to deliver a step change in housing delivery. It sets a target for an average of 3,000 homes per annum in the period 2014-19 and for3.15 MHCLG Live Tables identify that only 10,715 houses were built in the period 2014-19 in addition to the equivalent of 581 homes provided as student and older persons bedspaces. This provides a total of 11,296 or an average of only 2,259 homes per annum. It is therefore apparent that the short-term target of the City Deal has not been met and that accordingly this shortfall of 3,704 homes should be addressed as soon as possible to achieve the objectives of the City Deal. No such short-term uplift to remedy this shortfall is made within the Draft Local Plan contrary to the requirements of national policy in the form of the City Deal.
3.16 In the period 2008-19, the MHCLG Live Tables identify an equivalent of 19,416 housing completions, which means that in order to provide 37,000 homes in the period 2008-26 it will be necessary to deliver the remaining 17,584 in the period 37,000 homes to be delivered in the period 2008-26.2019-26 or an average of 2,512 per annum. However, the housing need identified in emerging Policy 1 of 40,550 homes 1 only provides for an average need of 2,028 homes per annum. The housing need of the Draft Local Plan therefore again does not provide a sufficient number of homes to meet the housing needs identified in the City Deal.
3.17 It is therefore evident that the Draft Local Plan does not meet any of the targets of the City Deal and that it is accordingly not effective, not justified, not positively prepared and inconsistent with national policy.
Previous assessments of need
3.18 The SHMA for Central Norfolk identifies that there was a need to deliver 44,714 homes from 2015-36 to accord with the City Deal. In the period 2015-18, the equivalent of 6,680 homes were delivered and so there is a residual need for 38,034 homes from 2018-36, or 2,113 per annum.
3.19 Assuming that this need remained constant across the period 2036-38, there would be a need for 42,260 homes to accord with the City Deal based on the latest assessment of housing need. The Local Plan does not therefore provide a sufficient number of homes to meet the latest assessment of need or to accord with the City Deal.

Comment

Representation ID: 22160

Received: 16/03/2020

Respondent: Pigeon Investment Management Ltd

Agent: Pegasus Group

Housing Requirement
The minimum housing need
3.3 The foreword to the Draft Local Plan identifies a requirement for about 44,500 homes over the next 20-years. This is clarified in Policy 1 which identifies a housing requirement for 44,340 homes in response to a need for 40,550.
3.4 The need for 40,550 homes is identified as having been calculated using the standard method according to Table 6 and the box at the bottom of page 53.
3.5 The standard method provides the minimum local housing need according to the PPG (2a-004) and is calculated using the average household growth for 10 consecutive years, with an affordability uplift based on the median workplace-based house price to earnings ratio of the preceding year1.
3.6 The Draft Local Plan covers the period from 1st April 2018. In order to establish the minimum local housing need for the plan period it is therefore necessary to calculate either the standard method at 2018; or to calculate the current standard method and apply this to the remainder of the plan period in addition to the number of completions which have already occurred.
3.7 In the case of the Greater Norwich Plan Area, the average household growth over the 10 consecutive years from 2018, namely 2018-28, was 400 in Broadland, 510 in Norwich and 704 in South Norfolk. The median workplace-based house price to earnings ratios in 2017 were 9.82, 6.93 and 8.91respectively. Using these figures, the minimum local housing need over the plan period equates to 41,379 homes.
3.8 Alternatively, the minimum local housing need from 2019 onwards can be calculated using the average household growth over the 10 consecutive years from 2019, namely 2019-29, with the affordability ratios of 2018 applied. The average household growth was 397, 505 and 691 respectively and the median workplace-based house price to earnings ratios were 9.23, 7.03 and 8.78 respectively. These figures produce a minimum local housing need of 2,024 homes per annum which equates to 38,460 homes over the period 2019-38. The number of housing completions in 2018/19 need to be added to this figure to provide the minimum local housing need over the plan period. MHCLG Live Tables identify that there were 2,757 housing completions, as well as 260 student bedspaces and 91 other bedspaces completed in this year. Once the appropriate conversion factors as identified in the PPG (68-034) and the PPG (63-016a) are applied this would equate to 2,901 houses2 completed in 2018/19. In addition to the minimum local housing need of 38,460 over the period 2019-38 this would produce a minimum local housing need for 41,361 homes over the plan period.
3.9 Once the median house price to earnings ratio for 2019 and the number of housing and bedspace completions in 2019/20 are available, it will be possible to provide yet another calculation of the minimum local housing need based on the completions in the period 2018-20 and the minimum local housing need over the period 2020-38. However, given the consistency of the preceding figures it would be expected that this would again be broadly consistent.3.10 In either case, it is apparent that the standard method has been miscalculated within the Draft Local Plan as it is below the minimum local housing need of either 41,379 or 41,361. Policy 1 and all other references to a need for 40,550 are therefore not justified nor are they consistent with national policy.3.11 Furthermore, the Government has identified that it intends to review the standard method by September 2020. As the Local Plan is not intended to be submitted for examination until June 2021, it is likely that the Local Plan will need to respond to the new standard method, whatever that may be.

Comment

Representation ID: 22161

Received: 16/03/2020

Respondent: Pigeon Investment Management Ltd

Agent: Pegasus Group

Housing Requirement
The minimum housing need
3.3 The foreword to the Draft Local Plan identifies a requirement for about 44,500 homes over the next 20-years. This is clarified in Policy 1 which identifies a housing requirement for 44,340 homes in response to a need for 40,550.
3.4 The need for 40,550 homes is identified as having been calculated using the standard method according to Table 6 and the box at the bottom of page 53.
3.5 The standard method provides the minimum local housing need according to the PPG (2a-004) and is calculated using the average household growth for 10 consecutive years, with an affordability uplift based on the median workplace-based house price to earnings ratio of the preceding year1.
3.6 The Draft Local Plan covers the period from 1st April 2018. In order to establish the minimum local housing need for the plan period it is therefore necessary to calculate either the standard method at 2018; or to calculate the current standard method and apply this to the remainder of the plan period in addition to the number of completions which have already occurred.
3.7 In the case of the Greater Norwich Plan Area, the average household growth over the 10 consecutive years from 2018, namely 2018-28, was 400 in Broadland, 510 in Norwich and 704 in South Norfolk. The median workplace-based house price to earnings ratios in 2017 were 9.82, 6.93 and 8.91respectively. Using these figures, the minimum local housing need over the plan period equates to 41,379 homes.
3.8 Alternatively, the minimum local housing need from 2019 onwards can be calculated using the average household growth over the 10 consecutive years from 2019, namely 2019-29, with the affordability ratios of 2018 applied. The average household growth was 397, 505 and 691 respectively and the median workplace-based house price to earnings ratios were 9.23, 7.03 and 8.78 respectively. These figures produce a minimum local housing need of 2,024 homes per annum which equates to 38,460 homes over the period 2019-38. The number of housing completions in 2018/19 need to be added to this figure to provide the minimum local housing need over the plan period. MHCLG Live Tables identify that there were 2,757 housing completions, as well as 260 student bedspaces and 91 other bedspaces completed in this year. Once the appropriate conversion factors as identified in the PPG (68-034) and the PPG (63-016a) are applied this would equate to 2,901 houses2 completed in 2018/19. In addition to the minimum local housing need of 38,460 over the period 2019-38 this would produce a minimum local housing need for 41,361 homes over the plan period.
3.9 Once the median house price to earnings ratio for 2019 and the number of housing and bedspace completions in 2019/20 are available, it will be possible to provide yet another calculation of the minimum local housing need based on the completions in the period 2018-20 and the minimum local housing need over the period 2020-38. However, given the consistency of the preceding figures it would be expected that this would again be broadly consistent.3.10 In either case, it is apparent that the standard method has been miscalculated within the Draft Local Plan as it is below the minimum local housing need of either 41,379 or 41,361. Policy 1 and all other references to a need for 40,550 are therefore not justified nor are they consistent with national policy.3.11 Furthermore, the Government has identified that it intends to review the standard method by September 2020. As the Local Plan is not intended to be submitted for examination until June 2021, it is likely that the Local Plan will need to respond to the new standard method, whatever that may be.

Object

Representation ID: 22163

Received: 16/03/2020

Respondent: Norwich Liberal Democrats

Number of people: 3

However the plan supports a level of growth in rural areas ‘village clusters in South Norfolk’ – 9% of total housing growth over the plan period - which is very hard to reconcile with Section 4 – The delivery of growth and addressing climate change and Policy 7.1 -Strategy for the areas of growth, and will have impacts for infrastructure provision.’ This approach is inconsistent with the emphasis expressed in the document on addressing climate change and significantly reducing carbon emissions in the Vision and Objectives and Climate Change statement, undermining the ability of the plan to deliver sustainable growth.
In addition there is concern about achieving this 9% growth (1,200 homes) in a more difficult village setting where new housing may be resisted.
The inclusion in the plan to site the additional housing in the most rural parts of South Norfolk in ‘village clusters’ in the GNLP but at the same time excluding details of those village sites or evidence as to the justification of such a policy may leave the GNLP vulnerable to challenge on soundness grounds at the public examination stage.

Comment

Representation ID: 22225

Received: 16/03/2020

Respondent: Westmere Homes

Agent: Armstrong Rigg Planning

We have concerns in respect of the housing strategy set by the plan, both in terms of the basic housing target and the way in which these are to be delivered. In short, these concerns relate to the less than aspirational housing figures included in the plan and a failure to recognise the significant growth that an escalation in local job creation will place on the housing market.

Fundamentally we consider that the plan should be doing more to seize on the challenges and opportunities presented by two key economic growth strategies in the region, ensuring that their ambitions can be achieved. Currently the baseline housing need for the plan period 2018-2038 is 40,541 new dwellings representing Greater Norwich’s Local Housing Need (LHN) devised using the government’s Standard Methodology. This approach is in line with the NPPF’s minimum requirements described at paragraph 60 of the Framework.

The plan then proposes to identify sufficient allocations to achieve this requirement plus an additional 10% buffer, required by paragraph 73 of the NPPF to “account for any fluctuation in the market” during the course of the following year. Essentially the plan’s housing requirement comprises close on the bear minimum policy-compliant figure required by the NPPF and certainly does little to recognise additional known factors that will no doubt influence the demand for new homes across the plan area.

Indeed, Planning Practice Guidance (PPG) reaffirms that the standard method provides a minimum starting point in determining the number of homes needed in an area and that there will be circumstances where it is appropriate to consider whether actual housing need is higher than the standard method indicates. The PPG then advises that circumstances where setting a higher housing requirement may be appropriate would include the following two scenarios:

•
“growth strategies for the area that are likely to be deliverable, for example where funding is in place to promote and facilitate additional growth (e.g. Housing Deals); (and)
•
strategic infrastructure improvements that are likely to drive an increase in the homes needed locally…”


Both of these factors are in play in respect of the GNLP.

Firstly, the ongoing Greater Norwich City Deal includes the commitment of the Greater Norwich Growth Board to secure significant infrastructure funding totalling £440 million along with the delivery of 3,000 additional homes at the city by 2026. Whilst it is recognised that the development requirements of the Deal have been facilitated in part by the allocation of 3,000 additional homes in the adopted Growth Triangle Area Action Plan (GTAAP) the delivery of these strategic housing sites has been slow. To this end the emerging GNLP offers the opportunity to provide fresh stimulus to achieving the ambitions of the City Deal prior to 2026 to make up for any shortfall in new jobs and housing.

It does not, however, appear that the plan has grasped this opportunity. Indeed, Norwich City Council in its report to its Sustainable Development Panel on 15th January 2020, raises identical concerns, stating that “the level of growth proposed in the GNLP is considered insufficient to address the growth needs of Greater Norwich as a whole and the Norwich Urban Area in particular, and lacks the ambition express ed through the previous Joint Core Strategy and the Greater Norwich City Deal” .

Secondly, it is vital that the GNLP responds to the ambitions of the Cambridge Norwich Tech Corridor (CNTC), the vision of which seeks to attract 26,000 additional jobs and 46,000 further residents to the corridor prior to 2031. At this stage it is apparent that, whilst the CNTC proposals would be hugely positive for the city area, they currently represent what is still little more than an aspirational programme for growth with limited delivery mechanisms in place. This is where the GNLP must play a major role in making the CNTC vision a reality.

To the plan’s credit it is noted that the spatial distribution of growth included in the draft strategy orientates a high proportion of the plan area’s homes towards the corridor. What is a concern, however, is that the overall housing target for the plan fails to recognise that the CNTC proposals, and the significant investment and jobs growth that will hopefully come with them, will likely result in an increased housing demand above and beyond the baseline requirement calculated using the Government’s Standard Methodology. The strategy of skewing the delivery of new homes which are already required to meet the needs of the local population towards the corridor to satisfy the CNTC’s aspiration does not represent a positive planning response. Instead this will simply create an imbalance in housing delivery across the plan area.

One of the options put forward in the previous Regulation 18 GNLP consultation in March 2018 was to provide an additional uplift in the housing requirement to take account of the City Deal. However, this approach was discounted as it was considered that the uplift applied built into the LHN figure (i.e. that proposed to tackle local issues in respect of affordability) was sufficient swell to accommodate the demands of the City Deal. Assessment of this approach did not even consider the additional implications of the CNTC. We were strong advocates of the City Deal uplift then – little has changed to lead us to alter this view. To simply maintain a figure close to the basic LHN as the need housing figure for the plan demonstrates a critical misunderstanding of the way in which the figure is calculated. Indeed, the absence of an appropriate uplift fails to reflect the fact that the standard method is a ‘policy off’ calculation of the housing requirement and any adjustments required to due to ‘policy on’ decisions (i.e. to sign a City Deal) should be factored in further.

Indeed, we note that the SHMA published in April 2017 identifies that the jobs growth facilitated by the City Deal would likely result in a demand for approximately 8,361 new homes above and beyond those required as a result of general demographic change over the period until 2036. Even when deducting the 3,000 dwellings planned for in the GTAAP this results in an additional requirement of 5,361 homes that appear not to have been considered when setting the GNLP housing requirement.

On this basis we consider that the OAN proposed by the plan falls short of adequately responding to local demand by an approximate 5,4002 homes. This is before the additional demand generated by the CNTC is taken into account. In which case the absolute minimum housing requirement for the GNLP should be somewhere in the region of 46,0003 dwellings before any NPPF paragraph 73 buffer is applied. In which case it is our view that upon the application of the appropriate buffer the GNLP should be planning for somewhere between 48,300 and 50,6004 dwellings as a minimum based on the demand generated by the City Deal alone. In addition, we would urge officers to undertake the work necessary to quantify the impact of the CNTC – the draw of the Corridor will inevitably result in the eventual housing figure rising further.

Comment

Representation ID: 22256

Received: 16/03/2020

Respondent: Carter Jonas LLP

Number of people: 2

The standard method is used in emerging GNLP to determine the minimum number of houses needed during the plan period. Section Id.2a of the Planning Practice Guidance explains how housing and economic needs assessments should be undertaken, including how to calculate local housing needs using the standard method. Firstly, Paragraph 010 identifies the circumstances where increases to housing need might be appropriate, including where there is a growth strategy, strategic infrastructure improvements are proposed, and to meet unmet needs from a neighbouring area. The consultation document for emerging GNLP refers to employment growth and infrastructure. It is Page 3 of 10 requested that the draft version of GNLP includes confirmation that the circumstances identified in Paragraph 010 of Id.2a have been taken into account for the housing requirement. Secondly, Paragraph 024 of Id.2a explains how the need for affordable housing is calculated, and it is suggested that the overall housing target should be increased where it could help deliver the required number of affordable homes. It is not clear whether the housing requirement for emerging GNLP has considered an uplift to meet affordable housing needs. It is requested that the draft version of GNLP includes confirmation that an uplift to the housing requirement to meet affordable housing needs has been considered and assessed.

Comment

Representation ID: 22277

Received: 16/03/2020

Respondent: Barton Willmore

Q14) Do you support, object or wish to comment on the approach for housing
numbers and delivery?
2.42 We support the identification of the Government’s standard methodology as the starting point
for calculating the housing requirements of the Plan. This is consistent with the requirements
of the NPPF as the standard methodology is a demographic-based figure which includes an
uplift for affordability, partly accommodating past shortfall.
2.43 Planning Practice Guidance (Paragraph 010 Reference ID 2a-010-20190220) identifies the
circumstances where it may be appropriate to plan for a higher housing need figure than the
standard method indicates including situations where increases in housing are likely to exceed
past trends because of growth strategies or strategic infrastructure improvements.
2.44 The City Deal, which was signed into effect by the Government in December 2013, gives
Greater Norwich increased freedom to help business grow and create economic growth. As
detailed in the City Deal report (December 2013), the deal aims to bring an additional 13,000
jobs and 3,000 homes (above Joint Core Strategy requirements) to the Greater Norwich Area.
As detailed in the Central Norfolk Strategic Housing Market Assessment (June 2017) this
equates to a total of 45,390 jobs over the plan period.2.45 Paragraph 4.19 of the Growth Options Consultation Document (January 2018) identified the
housing requirement may need to increase to support potential job growth arising from the
City Deal, resulting in 1,700 further dwellings being required. No reference to this is included
in any form within the Draft Strategy. Furthermore, the Strategic Housing Market Assessment
for Central Norfolk, specifically references that the three authorities of Broadland, Norwich
and South Norfolk have agreed a City Deal with ambitious plans for an additional 13,000 jobs
and 3,000 homes by 2026, making their JCS target 27,000 additional jobs, plus those 13,000City Deal jobs, over the period 2008-26. This is referenced in the Economy Chapter and
supporting text to Policy 6 and should be reflected in the Housing Numbers.
2.46 Nevertheless, the Draft Strategy confirms the GNLP will seek to over-allocate by means of a
10% buffer (equating to circa. 4,050 dwellings) to ensure delivery. It needs to be clarified
whether this includes some of the dwellings required by the City Deal (8,361 homes as
advocated at figure 101 of the SHMA), thereby reducing the delivery buffer, or if the City
Deal requirement will be in addition to the housing requirements identified in Table 6.
2.47 It is not clear therefore why Table 6 of the GNLP highlights a need for 40,451 new homes.
Further, the SHMA goes on to highlight that to accommodate the additional workers
associated with the City Deal, a further 8,361 new homes should also be planned for. Table
6 of the GNLP should therefore clearly provide as a minimum for 44,714 homes, and given
the commitment to the City Deal, extend that by a further 8,361 homes in the Plan Period
consistent with the NPPG. 3,000 of these homes should be delivered by 2026 in accordance
with the commitments of the City.
2.48 Similarly the NPPG states: “There may, occasionally, also be situations where previous levels
of housing delivery in an area, or previous assessments of need (such as a recently-produced
Strategic Housing Market Assessment) are significantly greater than the outcome from the
standard method. Authorities will need to take this into account when considering whether it
is appropriate to plan for a higher level of need than the standard model suggests”.
2.49 Given the change associated with the standard method, and the high amount of housing in
the previous GNLP to 2026, against which there is a significant shortfall, we are strongly of
the view that a 20% buffer should be applied. This would support in the region of 9,000
homes over and above the housing need calculated using the standard method and would
thus broadly align with the additional homes that would be required consistent with the City
Deal identified within the SHMA.
2.50 Once this additional quantity of housing has been accounted for – i.e. circa 49,000 – 54,000,
the GNLP should then seek to direct additional growth to the most sustainable locations - for
example the A11 and Cambridge to Norwich Tech Corridor as the priority for growth in the
region.2.51 The ‘alternative approaches’ to housing numbers identifies that whilst the NPPF encourages
a higher housing requirement, this is not the preferred option as evidence of delivery over
the medium and longer term suggests that higher targets are unlikely to be achievable or
deliverable. We do not believe this position is evidenced, and in fact past poor delivery hasbeen as a result of incorrect sites being allocation and an overreliance on sites within the
Growth Triangle (as detailed above and further in response to Questions 38 – 40).

Object

Representation ID: 22283

Received: 16/03/2020

Respondent: Hugh Crane Ltd

Agent: Savills

For full representation, please refer to the attached documents.

For the reasons set out above, there appears to be a conflict within the draft Greater Norwich Local Plan in respect of the aspiration to make to most of economic growth potential however only planning for the minimum number of new homes throughout the plan period.

Allocation of additional housing at ‘Land to the east of Woodbastwick Road, Blofield Heath’ (Draft Policy GNLP1048) will assist the Local Planning Authorities in boosting the supply of housing within Greater Norwich.

Comment

Representation ID: 22326

Received: 16/03/2020

Respondent: Pigeon Investment Management Ltd

Agent: Pegasus Group

3. POLICY 1 – THE SUSTAINABLE GROWTH STRATEGY
3.1 Policy 1 sets out the proposed strategy and includes the proposed housing requirement, the proposed employment land requirement, the approach to fiveyear land supply and the spatial strategy. These are addressed below.
3.2 Policy 1 also sets out the approach to supporting infrastructure and the proposed distribution of development which are addressed in greater detail in Policies 4 and 7.1 to 7.4 respectively. These matters are responded to under those Policies rather than in response to Policy 1.
Housing Requirement
The minimum housing need
3.3 The foreword to the Draft Local Plan identifies a requirement for about 44,500 homes over the next 20-years. This is clarified in Policy 1 which identifies a housing requirement for 44,340 homes in response to a need for 40,550.
3.4 The need for 40,550 homes is identified as having been calculated using the standard method according to Table 6 and the box at the bottom of page 53.
3.5 The standard method provides the minimum local housing need according to the PPG (2a-004) and is calculated using the average household growth for 10 consecutive years, with an affordability uplift based on the median workplacebased house price to earnings ratio of the preceding year1.
3.6 The Draft Local Plan covers the period from 1st April 2018. In order to establish the minimum local housing need for the plan period it is therefore necessary to calculate either the standard method at 2018; or to calculate the current standard method and apply this to the remainder of the plan period in addition to the number of completions which have already occurred.
3.7 In the case of the Greater Norwich Plan Area, the average household growth over the 10 consecutive years from 2018, namely 2018-28, was 400 in Broadland, 510 in Norwich and 704 in South Norfolk. The median workplacebased house price to earnings ratios in 2017 were 9.82, 6.93 and 8.91 respectively. Using these figures, the minimum local housing need over the plan period equates to 41,379 homes.
3.8 Alternatively, the minimum local housing need from 2019 onwards can be calculated using the average household growth over the 10 consecutive years from 2019, namely 2019-29, with the affordability ratios of 2018 applied. The average household growth was 397, 505 and 691 respectively and the median workplace-based house price to earnings ratios were 9.23, 7.03 and 8.78 respectively. These figures produce a minimum local housing need of 2,024 homes per annum which equates to 38,460 homes over the period 2019-38. The number of housing completions in 2018/19 need to be added to this figure to provide the minimum local housing need over the plan period. MHCLG Live Tables identify that there were 2,757 housing completions, as well as 260 student bedspaces and 91 other bedspaces completed in this year. Once the appropriate conversion factors as identified in the PPG (68-034) and the PPG (63-016a) are applied this would equate to 2,901 houses2 completed in 2018/19. In addition to the minimum local housing need of 38,460 over the period 201938 this would produce a minimum local housing need for 41,361 homes over the plan period.
3.9 Once the median house price to earnings ratio for 2019 and the number of housing and bedspace completions in 2019/20 are available, it will be possible to provide yet another calculation of the minimum local housing need based on the completions in the period 2018-20 and the minimum local housing need over the period 2020-38. However, given the consistency of the preceding figures it would be expected that this would again be broadly consistent.
3.10 In either case, it is apparent that the standard method has been miscalculated within the Draft Local Plan as it is below the minimum local housing need of either 41,379 or 41,361. Policy 1 and all other references to a need for 40,550 are therefore not justified nor are they consistent with national policy. 3.11 Furthermore, the Government has identified that it intends to review the standard method by September 2020. As the Local Plan is not intended to be submitted for examination until June 2021, it is likely that the Local Plan will need to respond to the new standard method, whatever that may be.
Exceeding the minimum housing need
3.12 The standard method also only provides the minimum local housing need, and the PPG (2a-010) identifies that this should be exceeded including in situations where there is a growth strategy or where strategic infrastructure improvements may drive an increase in housing need or where previous assessments of need are significantly greater than the standard method. All three of these situations arise in Greater Norwich.
The City Deal
3.13 Paragraph 13 of the Draft Local Plan identifies that the Greater Norwich City Deal requirements will be met through the Draft Local Plan. As the Greater Norwich City Deal forms a growth strategy which has been agreed with Government, the Local Plan is required to meet the requirements of the City Deal as this forms part of national policy as set out in paragraph 6 of the NPPF.
3.14 The City Deal identifies that strategic infrastructure is needed including to deliver a step change in housing delivery. It sets a target for an average of 3,000 homes per annum in the period 2014-19 and for 37,000 homes to be delivered in the period 2008-26.
3.15 MHCLG Live Tables identify that only 10,715 houses were built in the period 2014-19 in addition to the equivalent of 581 homes provided as student and older persons bedspaces. This provides a total of 11,296 or an average of only 2,259 homes per annum. It is therefore apparent that the short-term target of the City Deal has not been met and that accordingly this shortfall of 3,704 homes should be addressed as soon as possible to achieve the objectives of the City Deal. No such short-term uplift to remedy this shortfall is made within the Draft Local Plan contrary to the requirements of national policy in the form of the City Deal.
3.16 In the period 2008-19, the MHCLG Live Tables identify an equivalent of 19,416 housing completions, which means that in order to provide 37,000 homes in the period 2008-26 it will be necessary to deliver the remaining 17,584 in the period 2019-26 or an average of 2,512 per annum. However, the housing need identified in emerging Policy 1 of 40,550 homes 1 only provides for an average need of 2,028 homes per annum. The housing need of the Draft Local Plan therefore again does not provide a sufficient number of homes to meet the housing needs identified in the City Deal.
3.17 It is therefore evident that the Draft Local Plan does not meet any of the targets of the City Deal and that it is accordingly not effective, not justified, not positively prepared and inconsistent with national policy.
Previous assessments of need
3.18 The SHMA for Central Norfolk identifies that there was a need to deliver 44,714 homes from 2015-36 to accord with the City Deal. In the period 2015-18, the equivalent of 6,680 homes were delivered and so there is a residual need for 38,034 homes from 2018-36, or 2,113 per annum.
3.19 Assuming that this need remained constant across the period 2036-38, there would be a need for 42,260 homes to accord with the City Deal based on the latest assessment of housing need. The Local Plan does not therefore provide a sufficient number of homes to meet the latest assessment of need or to accord with the City Deal.
The housing need of students
3.20 The standard method is informed by the 2014-based household projections which assume that the five-year migration trends which were experienced in the period 2009-14 will be maintained. The Higher Education Statistics Authority (HESA) identified that University of East Anglia (UEA) had 16,640 students and the Norwich University of the Arts had 1,485 students in 2009 providing a total of 18,125, but that this had increased to 18,140 by 2014 with 16,265 at UEA and 1,875 at the University of Arts. The 2014-based projections which inform the standard method therefore assumes that the student population will increase by 15 people over five years or 3 per annum.
3.21 Paragraph 45 of the Draft Local Plan however indicates that the Universities in Norwich are expected to expand. In particular, the University of East Anglia (UEA) has announced plans to increase its students from 15,000 to 18,000 in the next decade, an increase of 300 students per annum. 3.22 The increased migration of 297 students per annum3, even assuming that the student population of the University of the Arts remains constant, are not taken into account in the projections.
3.23 These additional students at UEA will clearly have an impact on the housing need in Greater Norwich which is not taken into account within the standard method. Either these will generate a need for an additional 2,970 bedspaces which is equivalent to 1,042 houses or if these students are accommodated in the housing stock it will be necessary to deliver an additional 1,042 homes to accommodate them. It will be necessary to deliver such accommodation to meet the objectively assessed needs and to accord with the Vision of the GNLP.
3.24 Once the needs of these additional students are taken into account this would increase the minimum local housing need from either 41,379 or 41,361 to either 42,421 or 42,403 homes over the plan period. This broadly accords with the 42,260 homes necessary to accord with the City Deal.
The needs of those in institutional accommodation
3.25 The SHMA for Central Norfolk identifies a need for 3,909 people aged 75 or over to be accommodated in residential institutions over the period 2015-36. The 2014 based institutional population projections identify an increase of 2,060 such people within the GNLP area over the period 2015-38 comprising 1,088 in Broadland, 291 in Norwich and 681 in South Norfolk.
3.26 In the period 2015-18, a total of 234 bedspaces in older persons communal establishments were built, including 7 in Broadland, 225 in Norwich and 2 in South Norfolk. This leaves a residual need for 1,826 bedspaces in the period 2018-36, comprising 1,081 in Broadland, 57 in Norwich and 679 in South Norfolk.
3.27 The household projections which inform both the SHMA and the standard method do not include this population and the SHMA correctly recognises that in the absence of 1,826 bedspaces in communal establishments the population who would have occupied these will remain in the dwelling stock rather than releasing them as assumed in the projections. 3.28 It is therefore apparent that there is a need for 1,826 bedspaces in communal establishments in addition to the standard method and that in the absence of such provision the housing requirement will need to increase as fewer dwellings will be released to the market. The number of dwellings that would not be released in the absence of such residential institutions is 987 using the calculation identified in the PPG (63-016a) comprising 584 in Broadland, 33 in Norwich and 369 in South Norfolk.
3.29 It will therefore either be necessary to make provision for the 1,826 bedspaces or increase the housing requirement by 987 homes to meet the objectively assessed needs within the GNLP and to accord with the Vision of the GNLP. This would result in a need for either 43,408 or 43,390 homes or to 42,421 or 42,403 homes and 1,826 bedspaces.
The housing requirement
3.30 The Delivery Statement on page 37 indicates that the Draft Local Plan provides a sufficient supply of housing sites to exceed the identified housing need of 40,550 homes by 9%. However, as identified above, there is actually a need for at least 42,400 homes to accord with the City Deal, meet the minimum local housing need and to accommodate the growth plans of UEA as well as a need for an additional 1,800 bedspaces in communal establishments.
3.31 In order to provide sufficient flexibility to ensure that these minimum needs will be delivered, taking account of the non-delivery of sites, it has been found by numerous Inspectors that it is appropriate to set the housing requirement above the minimum housing need4 as the Draft Local Plan seeks to do.
3.32 In Greater Norwich, the housing trajectory of the Joint Core Strategy identified that there would be 23,637 housing completions in the period 2008-19. However, only 18,835 homes have been delivered which demonstrates that at least historically, the trajectory of Greater Norwich overestimates the developable supply by circa 25%. Assuming that the current trajectory is equally as accurate, it would be appropriate to set a housing requirement 25% in excess of the minimum need for circa 42,400 homes. This would produce a housing requirement for circa 53,000 homes. This is illustrative that there is a need for a significant contingency allowance in Greater Norwich to ensure that needs are actually met. It is therefore recommended that the proposed contingency of 9% is retained as a minimum but this should be significantly greater, which in addition to the minimum housing need for circa 42,400 homes produce a housing requirement for at least 46,216 homes.
Contingency to respond to changes
3.33 The Government has identified an intention to review the standard method in September 2020 and this will be required to be responded to in the Greater Norwich Local Plan to meet the minimum local housing needs at the point of submission as required by the PPG (2a-008). This proposed review of the standard method means that the minimum housing needs may change from the 42,400 identified above. It may be that the minimum housing needs increase significantly and accordingly a sufficient developable supply (including the required contingency set out above) should be planned for to ensure that the emerging GNLP will be able to respond to the identified minimum needs at the point of submission as required by the PPG (2a-008).
3.34 Whilst it is not possible to identify the need which will arise from this review at present, it is considered that a sufficient developable supply (including the required contingency set out above) should be planned for to significantly exceed the identified need for at least 42,400 homes and provide confidence that the minimum needs arising from the review will be able to be accommodated.
Employment Land Requirement
3.35 As set out in the GNLP, there is no quantitative need for additional employment sites across the GNLP area as a whole. Nevertheless, the GNLP allocates an additional 40ha providing a total of 360ha of employment land allocations to meet the underlying demand and provide choice to the market.
3.36 Whilst these allocations will assist the economic growth of the area and represent positive planning, if a significant proportion of these are actually developed and occupied, they will be dependent upon greater numbers of incommuters from outside of the plan area. Accordingly, an appropriate monitoring framework should be put in place to ensure that a sufficient number of homes are provided to accommodate the workforce to avoid the resultantenvironmental harms of a greater dependency on long-distance commuting flows.
3.37 If the monitoring framework indicates that a greater number of jobs have been accommodated than the growth in the resident workforce such that the economy of the area becomes more dependent upon unsustainable long-distance incommuting flows, this should trigger an immediate review of the GNLP alongside a policy response with residential planning applications being considered more favourably until such time as the GNLP review is adopted to address the imbalance.
3.38 Similarly, if an insufficient amount of employment land is actually developed and occupied, this should trigger an immediate review of the GNLP to bring forward additional employment land allocations alongside a policy response to consider employment planning applications more favourably in the interim.
The approach to five-year land supply
3.39 Policy 1 proposes that the five-year land supply will be assessed across the plan area and that enough allocations are provided to demonstrate a five-year land supply at adoption. However, there is no evidence that this is the case as the GNLP is not supported by a housing trajectory contrary to paragraph 73 of the NPPF. Pegasus Group reserve the right to respond on this matter when the necessary evidence is made available.
Spatial Strategy
3.40 The Table at Policy 1 details the distribution of housing supply across the settlement hierarchy, including proposed new allocations as follows;
- Norwich urban area - 30,560 dwellings – approximately 70% of supply
- Main towns – 6,342 dwellings – approximately 14% of supply
- Key Service Centres – 3,417 dwellings – approximately 8% of supply
- Village clusters – 4,024 dwellings – approximately 9% of supply
3.41 Policies 7.1 to 7.5 provide further detail on the distribution of sites and the composition of existing and proposed allocations with regard to their size and brown or green field status. 3.42 We have concerns over the proposed spatial strategy of the emerging GNLP owing to its over reliance on housing delivery in the Norwich urban area and the proposed discrepancy in terms of settlement hierarchy between the quantum of housing allocated to Main Towns, Key Service Centres and Village Clusters.
3.43 While the Norwich urban area is a sustainable location for growth, reliance on this area for the delivery of approximately 70% of the housing growth of the GNLP up to 2038 places a requirement on existing infrastructure to accommodate an additional 30,560 dwellings in the plan period, it also requires an annual delivery rate within the area of 1,698 dwellings per annum over each of the next 18 years. This requires that the level of development in Norwich urban area alone is broadly consistent with that which has been achieved across the entire GNLP plan area since 2008. This does not appear to be realistic. If the necessary boost to housing supply is to be achieved this will require a greater range and choice of sites across all of the sustainable settlements within the plan area.
3.44 Moreover, reference to Policy 7.1 demonstrates that delivery within the Norwich Urban Area is predicated on two substantial brownfield regeneration areas, the Northern City Regeneration Area and the East Norwich Strategic Regeneration Area and several urban extensions of over 1,000 dwellings each.
3.45 Brownfield regeneration is costly and time consuming and often involves the bringing together of multiple delivery partners to achieve. The likelihood of the totality of development proposed through regeneration delivering in the plan period is therefore slim.
3.46 New strategic urban extensions can also be timely to deliver with the need for new strategic infrastructure in terms of highways and drainage to be delivered in advance of new homes.
3.47 The Councils have not produced evidence to substantiate the delivery trajectory of the brownfield regeneration sites or the urban extensions in the Norwich Urban Area. We reserve the right to comment further on this matter at the Regulation 19 consultation stage. Delay in delivery at either source of supply could prejudice the delivery of the housing requirement of the GNLP and therefore go to the soundness of the plan. 3.48 Additional certainty over the delivery of the housing requirement could be achieved by changing the emphasis of the spatial strategy by allocating more housing to the Main Towns and the Key Service Centres, including Hethersett with an associated reduction in the percentage to be delivered in the Norwich urban area and within the Village Clusters.
3.49 Additionally, we have concerns over the fact that more dwellings are proposed in the spatial strategy across Village Clusters than are allocated at Key Service Centres, including a minimum of 1,200 dwellings through a South Norfolk Village Clusters Housing Site Allocations Development Plan Document.
3.50 Without certainty over the supply of land to deliver such a quantum of development in South Norfolk Village Clusters the soundness of the spatial strategy is questionable. As a percentage of the overall new housing allocations in the Reg 18 GNLP the current spatial strategy delegates approximately 15% to a document outside of its control (1200/7,840). This is not considered to be a reasonable approach and prejudices the delivery of the emerging GNLP by 2038.
3.51 A Settlement Hierarchy approach to the distribution of development would look to allocate a higher percentage of housing to more sustainable locations with smaller amounts being allocated to lower order settlements in recognition that small developments at villages can help maintain service provision, provide vitality and help address local market and affordable housing needs.
3.52 The Reg 18 GNLP allocates more development to Village clusters than to Key Service Centres which is a counter intuitive approach to achieving sustainable development. We consider this matter should be addressed by allocating additional sites at Hethersett, with Pigeon being able to provide land for the development of new community facilities, over and above sites for new housing development.
3.53 In failing to provide an increased number of dwellings at Main Towns and Key Service Centres the Councils are also missing the opportunities presented by Pigeon to provide new community facilities that can support existing and proposed new development in sustainable locations for the plan period and beyond. 3.54 The preceding representations on the Spatial Strategy are all set in the context that the identified housing need does not even accord with the minimum set by national policy and does not take account of the needs of specific groups. It is therefore evident that the quantitative elements of the Spatial Strategy will need to be revised to ensure that housing needs can be met across the GNLP area. This should be achieved through directing more growth to the Main Towns and Key Service Centres to counterbalance the disproportionate levels of growth proposed within the Norwich urban area and Village Clusters.

Comment

Representation ID: 22365

Received: 16/03/2020

Respondent: Pigeon Investment Management Ltd

Agent: Pegasus Group

3. POLICY 1 – THE SUSTAINABLE GROWTH STRATEGY
3.1 Policy 1 sets out the proposed strategy and includes the proposed housing requirement, the proposed employment land requirement, the approach to fiveyear land supply and the spatial strategy. These are addressed below.
3.2 Policy 1 also sets out the approach to supporting infrastructure and the proposed distribution of development which are addressed in greater detail in Policies 4 and 7.1 to 7.4 respectively. These matters are responded to under those Policies rather than in response to Policy 1.
Housing Requirement
The minimum housing need
3.3 The foreword to the Draft Local Plan identifies a requirement for about 44,500 homes over the next 20-years. This is clarified in Policy 1 which identifies a housing requirement for 44,340 homes in response to a need for 40,550.
3.4 The need for 40,550 homes is identified as having been calculated using the standard method according to Table 6 and the box at the bottom of page 53.
3.5 The standard method provides the minimum local housing need according to the PPG (2a-004) and is calculated using the average household growth for 10 consecutive years, with an affordability uplift based on the median workplacebased house price to earnings ratio of the preceding year1.
3.6 The Draft Local Plan covers the period from 1st April 2018. In order to establish the minimum local housing need for the plan period it is therefore necessary to calculate either the standard method at 2018; or to calculate the current standard method and apply this to the remainder of the plan period in addition to the number of completions which have already occurred.
3.7 In the case of the Greater Norwich Plan Area, the average household growth over the 10 consecutive years from 2018, namely 2018-28, was 400 in Broadland, 510 in Norwich and 704 in South Norfolk. The median workplacebased house price to earnings ratios in 2017 were 9.82, 6.93 and 8.91 respectively. Using these figures, the minimum local housing need over the plan period equates to 41,379 homes.
3.8 Alternatively, the minimum local housing need from 2019 onwards can be calculated using the average household growth over the 10 consecutive years from 2019, namely 2019-29, with the affordability ratios of 2018 applied. The average household growth was 397, 505 and 691 respectively and the median workplace-based house price to earnings ratios were 9.23, 7.03 and 8.78 respectively. These figures produce a minimum local housing need of 2,024 homes per annum which equates to 38,460 homes over the period 2019-38. The number of housing completions in 2018/19 need to be added to this figure to provide the minimum local housing need over the plan period. MHCLG Live Tables identify that there were 2,757 housing completions, as well as 260 student bedspaces and 91 other bedspaces completed in this year. Once the appropriate conversion factors as identified in the PPG (68-034) and the PPG (63-016a) are applied this would equate to 2,901 houses2 completed in 2018/19. In addition to the minimum local housing need of 38,460 over the period 201938 this would produce a minimum local housing need for 41,361 homes over the plan period.
3.9 Once the median house price to earnings ratio for 2019 and the number of housing and bedspace completions in 2019/20 are available, it will be possible to provide yet another calculation of the minimum local housing need based on the completions in the period 2018-20 and the minimum local housing need over the period 2020-38. However, given the consistency of the preceding figures it would be expected that this would again be broadly consistent.
3.10 In either case, it is apparent that the standard method has been miscalculated within the Draft Local Plan as it is below the minimum local housing need of either 41,379 or 41,361. Policy 1 and all other references to a need for 40,550 are therefore not justified nor are they consistent with national policy. 3.11 Furthermore, the Government has identified that it intends to review the standard method by September 2020. As the Local Plan is not intended to be submitted for examination until June 2021, it is likely that the Local Plan will need to respond to the new standard method, whatever that may be.
Exceeding the minimum housing need
3.12 The standard method also only provides the minimum local housing need, and the PPG (2a-010) identifies that this should be exceeded including in situations where there is a growth strategy or where strategic infrastructure improvements may drive an increase in housing need or where previous assessments of need are significantly greater than the standard method. All three of these situations arise in Greater Norwich.
The City Deal
3.13 Paragraph 13 of the Draft Local Plan identifies that the Greater Norwich City Deal requirements will be met through the Draft Local Plan. As the Greater Norwich City Deal forms a growth strategy which has been agreed with Government, the Local Plan is required to meet the requirements of the City Deal as this forms part of national policy as set out in paragraph 6 of the NPPF.
3.14 The City Deal identifies that strategic infrastructure is needed including to deliver a step change in housing delivery. It sets a target for an average of 3,000 homes per annum in the period 2014-19 and for 37,000 homes to be delivered in the period 2008-26.
3.15 MHCLG Live Tables identify that only 10,715 houses were built in the period 2014-19 in addition to the equivalent of 581 homes provided as student and older persons bedspaces. This provides a total of 11,296 or an average of only 2,259 homes per annum. It is therefore apparent that the short-term target of the City Deal has not been met and that accordingly this shortfall of 3,704 homes should be addressed as soon as possible to achieve the objectives of the City Deal. No such short-term uplift to remedy this shortfall is made within the Draft Local Plan contrary to the requirements of national policy in the form of the City Deal.
3.16 In the period 2008-19, the MHCLG Live Tables identify an equivalent of 19,416 housing completions, which means that in order to provide 37,000 homes in the period 2008-26 it will be necessary to deliver the remaining 17,584 in the period 2019-26 or an average of 2,512 per annum. However, the housing need identified in emerging Policy 1 of 40,550 homes only provides for an average of 2,028 homes per annum. The housing need of the Draft Local Plan therefore again does not provide a sufficient number of homes to meet the housing needs identified in the City Deal.
3.17 It is therefore evident that the Draft Local Plan does not meet any of the targets of the City Deal and that it is accordingly not effective, not justified, not positively prepared and inconsistent with national policy.
Previous assessments of need
3.18 The SHMA for Central Norfolk identifies that there was a need to deliver 44,714 homes from 2015-36 to accord with the City Deal. In the period 2015-18, the equivalent of 6,680 homes were delivered and so there is a residual need for 38,034 homes from 2018-36, or 2,113 per annum.
3.19 Assuming that this need remained constant across the period 2036-38, there would be a need for 42,260 homes to accord with the City Deal based on the latest assessment of housing need. The Local Plan does not therefore provide a sufficient number of homes to meet the latest assessment of need or to accord with the City Deal.
The housing need of students
3.20 The standard method is informed by the 2014-based household projections which assume that the five-year migration trends which were experienced in the period 2009-14 will be maintained. The Higher Education Statistics Authority (HESA) identified that University of East Anglia (UEA) had 16,640 students and the Norwich University of the Arts had 1,485 students in 2009 providing a total of 18,125, but that this had increased to 18,140 by 2014 with 16,265 at UEA and 1,875 at the University of Arts. The 2014-based projections which inform the standard method therefore assumes that the student population will increase by 15 people over five years or 3 per annum.
3.21 Paragraph 45 of the Draft Local Plan however indicates that the Universities in Norwich are expected to expand. In particular, the University of East Anglia (UEA) has announced plans to incre3.22 The increased migration of 297 students per annum3, even assuming that the student population of the University of the Arts remains constant, are not taken into account in the projections.
3.23 These additional students at UEA will clearly have an impact on the housing need in Greater Norwich which is not taken into account within the standard method. Either these will generate a need for an additional 2,970 bedspaces which is equivalent to 1,042 houses or if these students are accommodated in the housing stock it will be necessary to deliver an additional 1,042 homes to accommodate them. It will be necessary to deliver such accommodation to meet the objectively assessed needs and to accord with the Vision of the GNLP.
3.24 Once the needs of these additional students are taken into account this would increase the minimum local housing need from either 41,379 or 41,361 to either 42,421 or 42,403 homes over the plan period. This broadly accords with the 42,260 homes necessary to accord with the City Deal.
The needs of those in institutional accommodation
3.25 The SHMA for Central Norfolk identifies a need for 3,909 people aged 75 or over to be accommodated in residential institutions over the period 2015-36. The 2014 based institutional population projections identify an increase of 2,060 such people within the GNLP area over the period 2015-38 comprising 1,088 in Broadland, 291 in Norwich and 681 in South Norfolk.
3.26 In the period 2015-18, a total of 234 bedspaces in older persons communal establishments were built, including 7 in Broadland, 225 in Norwich and 2 in South Norfolk. This leaves a residual need for 1,826 bedspaces in the period 2018-36, comprising 1,081 in Broadland, 57 in Norwich and 679 in South Norfolk.
3.27 The household projections which inform both the SHMA and the standard method do not include this population and the SHMA correctly recognises that in the absence of 1,826 bedspaces in communal establishments the population who would have occupied these will remain in the dwelling stock rather than releasing them as assumed in the projections. ase its students from 15,000 to 18,000 in the next decade, an increase of 300 students per annum. 3.28 It is therefore apparent that there is a need for 1,826 bedspaces in communal establishments in addition to the standard method and that in the absence of such provision the housing requirement will need to increase as fewer dwellings will be released to the market. The number of dwellings that would not be released in the absence of such residential institutions is 987 using the calculation identified in the PPG (63-016a) comprising 584 in Broadland, 33 in Norwich and 369 in South Norfolk.
3.29 It will therefore either be necessary to make provision for the 1,826 bedspaces or increase the housing requirement by 987 homes to meet the objectively assessed needs within the GNLP and to accord with the Vision of the GNLP. This would result in a need for either 43,408 or 43,390 homes or to 42,421 or 42,403 homes and 1,826 bedspaces.
The housing requirement
3.30 The Delivery Statement on page 37 indicates that the Draft Local Plan provides a sufficient supply of housing sites to exceed the identified housing need of 40,550 homes by 9%. However, as identified above, there is actually a need for at least 42,400 homes to accord with the City Deal, meet the minimum local housing need and to accommodate the growth plans of UEA as well as a need for an additional 1,800 bedspaces in communal establishments.
3.31 In order to provide sufficient flexibility to ensure that these minimum needs will be delivered, taking account of the non-delivery of sites, it has been found by numerous Inspectors that it is appropriate to set the housing requirement above the minimum housing need4 as the Draft Local Plan seeks to do.
3.32 In Greater Norwich, the housing trajectory of the Joint Core Strategy identified that there would be 23,637 housing completions in the period 2008-19. However, only 18,835 homes have been delivered which demonstrates that at least historically, the trajectory of Greater Norwich overestimates the developable supply by circa 25%. Assuming that the current trajectory is equally as accurate, it would be appropriate to set a housing requirement 25% in excess of the minimum need for circa 42,400 homes. This would produce a housing requirement for circa 53,000 homes. This is illustrative that there is a need for a significant contingency allowance in Greater Norwich to ensure that needs are actually met. It is therefore recommended that the proposed contingency of 9% is retained as a minimum but this should be significantly greater, which in addition to the minimum housing need for circa 42,400 homes produce a housing requirement for at least 46,216 homes.
Contingency to respond to changes
3.33 The Government has identified an intention to review the standard method in September 2020 and this will be required to be responded to in the Greater Norwich Local Plan to meet the minimum local housing needs at the point of submission as required by the PPG (2a-008). This proposed review of the standard method means that the minimum housing needs may change from the 42,400 identified above. It may be that the minimum housing needs increase significantly and accordingly a sufficient developable supply (including the required contingency set out above) should be planned for to ensure that the emerging GNLP will be able to respond to the identified minimum needs at the point of submission as required by the PPG (2a-008).
3.34 Whilst it is not possible to identify the need which will arise from this review at present, it is considered that a sufficient developable supply (including the required contingency set out above) should be planned for to significantly exceed the identified need for at least 42,400 homes and provide confidence that the minimum needs arising from the review will be able to be accommodated.
Employment Land Requirement
3.35 As set out in the GNLP, there is no quantitative need for additional employment sites. Nevertheless, the GNLP allocates an additional 40ha providing a total of 360ha of employment land allocations to meet the underlying demand and provide choice to the market.
3.36 Whilst these allocations will assist the economic growth of the area and represent positive planning, if a significant proportion of these are actually developed and occupied, they will be dependent upon greater numbers of incommuters from outside of the plan area. Accordingly, an appropriate monitoring framework should be put in place to ensure that a sufficient number of homes are provienvironmental harms of a greater dependency on long-distance commuting flows.
3.37 If the monitoring framework indicates that a greater number of jobs have been accommodated than the growth in the resident workforce such that the economy of the area becomes more dependent upon unsustainable long-distance incommuting flows, this should trigger an immediate review of the GNLP alongside a policy response with residential planning applications being considered more favourably until such time as the GNLP review is adopted to address the imbalance.
The approach to five-year land supply
3.38 Policy 1 proposes that the five-year land supply will be assessed across the plan area and that enough allocations are provided to demonstrate a five-year land supply at adoption. However, there is no evidence that this is the case as the GNLP is not supported by a housing trajectory contrary to paragraph 73 of the NPPF. Pegasus Group reserve the right to respond on this matter when the necessary evidence is made available.
Spatial Strategy
3.39 The Table at Policy 1 details the distribution of housing supply across the settlement hierarchy, including proposed new allocations as follows;
- Norwich urban area - 30,560 dwellings – approximately 70% of supply
- Main towns – 6,342 dwellings – approximately 14% of supply
- Key Service Centres – 3,417 dwellings – approximately 8% of supply
- Village clusters – 4,024 dwellings – approximately 9% of supply
3.40 Policies 7.1 to 7.5 provide further detail on the distribution of sites and the composition of existing and proposed allocations with regard to their size and brown or green field status.
3.41 Our clients raise concern over the proposed spatial strategy of the emerging GNLP owing to its over reliance on housing delivery in the Norwich urban area and the proposed discrepancy in terms of settlement hierarchy between the ded to accommodate the workforce to avoid the resultant quantum of housing allocated to Main Towns, Key Service Centres and Village Clusters.
3.42 While the Norwich urban area is a sustainable location for growth, reliance on this area for the delivery of approximately 70% of the housing growth of the GNLP up to 2038 places a requirement on existing infrastructure to accommodate an additional 30,560 dwellings in the plan period, it also requires an annual delivery rate within the area of 1,698 dwellings per annum over each of the next 18 years. This requires that the level of development in Norwich urban area alone is broadly consistent with that which has been achieved across the entire GNLP plan area since 2008. This does not appear to be realistic. If the necessary boost to housing supply is to be achieved this will require a greater range and choice of sites across all of the sustainable settlements within the plan area.
3.43 Moreover, reference to Policy 7.1 demonstrates that delivery within the Norwich Urban Area is predicated on two substantial brownfield regeneration areas, the Northern City Regeneration Area and the East Norwich Strategic Regeneration Area and several urban extensions of over 1,000 dwellings each.
3.44 Brownfield regeneration is costly and time consuming and often involves the bringing together of multiple delivery partners to achieve. The likelihood of the totality of development proposed through regeneration delivering in the plan period is therefore slim.
3.45 New strategic urban extensions can also be timely to deliver with the need for new strategic infrastructure in terms of highways and drainage to be delivered in advance of new homes.
3.46 The Councils have not produced evidence to substantiate the delivery trajectory of the brownfield regeneration sites or the urban extensions in the Norwich Urban Area. We reserve the right to comment further on this matter at the Regulation 19 consultation stage. Delay in delivery at either source of supply could prejudice the delivery of the housing requirement of the GNLP and therefore go to the soundness of the plan.
3.47 Additional certainty over the delivery of the housing requirement could be achieved by changing the emphasis of the spatial strategy by allocating more housing to the Main Towns, including Diss, and the Key Service Centres with anassociated reduction in the percentage to be delivered in Norwich urban area and the Village Clusters.
3.48 Diss in particular is identified in the Reg 18 GNLP as having capacity for additional employment development. Diss is a net importer of workers with 2011 Census data showing only 4,939 economically active people living in the town compared to the 5,623 people working there. In order to balance homes and jobs and provide for sustainable development it is necessary for more houses to come forward at Diss, especially given the re-allocation of 10.8ha of employment land at the Town in the Reg 18 GNLP.
3.49 Additionally, we have concerns over the fact that more dwellings are proposed in the spatial strategy across Village Clusters than are allocated at Key Service Centres, including a minimum of 1,200 dwellings through a South Norfolk Village Clusters Housing Site Allocations Development Plan Document.
3.50 Without certainty over the supply of land to deliver such a quantum of development in South Norfolk Village Clusters the soundness of the spatial strategy is questionable. As a percentage of the overall new housing allocations in the Reg 18 GNLP the current spatial strategy delegates approximately 15% to a document outside of its control (1200/7,840). This is not considered to be a reasonable approach and prejudices the delivery of the emerging GNLP by 2038.
3.51 A Settlement Hierarchy approach to the distribution of development would look to allocate a higher percentage of housing to more sustainable locations with smaller amounts being allocated to lower order settlements in recognition that small developments at villages can help maintain service provision, provide vitality and help address local market and affordable housing needs.
3.52 In failing to provide an increased number of dwellings at Main Towns and Key Service Centres the Councils are also missing the opportunities presented by Pigeon to provide new community facilities that can support existing and proposed new development in sustainable locations for the plan period and beyond.
3.53 The preceding representations on the Spatial Strategy are all set in the context that the identified housing need does not even accord with the minimum set by national policy and does not take account of the needs of specific groups. It is therefore evident that the quantitative elements of the Spatial Strategy will need to be revised to ensure that housing needs can be met across the GNLP area. This should be achieved through directing more growth to the Main Towns and Key Service Centres to counterbalance the disproportionate levels of growth proposed within the Norwich urban area and Village Clusters.

Object

Representation ID: 22399

Received: 16/03/2020

Respondent: Norwich Green Party

Object. Plan should ensure delivery of JCS allocations before commencing phased development of new sites allocated in GNLP, starting with brownfield sites in Norwich city centre. Linking delivery of affordable housing to that of private sector housing has failed. Planning authorities have maximised housing numbers to obtain affordable housing whilst developers have claimed that achievement of policy quota of 33% affordable housing is unviable. The only solution to addressing affordable housing need is through public policy intervention, in particular national government facilitating social housing.

Comment

Representation ID: 22431

Received: 16/03/2020

Respondent: Gladman Developments

5.2 Question 14: Housing Numbers and Delivery
Proposed Housing Requirement
5.2.1 Draft Policy 1 proposes a housing requirement of 40,550 dwellings for the plan period 2018 to 2038 (2,028 dpa). This reflects the local housing needs for the Greater Norwich Plan Area using the Government’s standardised methodology. Having reviewed the wider evidence base informing the Plan, Gladman is not convinced that the standard method figure alone provides a sufficient level of housing growth for the Greater Norwich Plan Area especially in the context of the ambitious economic growth objectives set out in the draft GNLP. Further work is therefore necessary to understand the link between planned housing and job targets.
5.2.2 The standard method represents the minimum housing needs for the area and considers only demographic need and affordability. The standard method does not account for the housing needed to support economic growth needs or ambitions, nor does it align to commitments made for strategic investments or funding which might influence the level of housing growth required in an area.
5.2.3 PPG confirms the following circumstances in which the adoption of a higher housing requirement above the standard method may be justified3. This includes but is not limited to:
 Growth Strategies for the area that are likely to be deliverable, for example where funding is in place to promote and facilitate additional growth (e.g. Housing Deals);
 Strategic infrastructure improvements that are likely to drive an increase in the homes needed locally;
 An authority agreeing to take on unmet need from neighbouring authorities, as set out in a statement of common ground; and
 On occasion, situations where previous levels of housing delivery in an area, or previous assessments of need are significantly greater than the outcome from the standard method.
5.2.4 The Greater Norwich authorities benefit from the City Deal which commits to facilitating the delivery of 13,000 more jobs than the target set within the joint Core Strategy. Reflecting this commitment, Draft Policy 1 advises a job target of 33,000 jobs over the period 2018 to 2038. This requirement accounts for the remaining job growth associated with the City Deal and the longer term benefits the City Deal is predicted to have for the Greater Norwich economy. This represents an uplift of around 8,000 jobs against the baseline trend forecast as set out through the East of England Forecasting Model which might have otherwise informed the job targets of the emerging Plan.
5.2.5 Despite having influenced the economic growth strategy of the Draft GNLP, the City Deal does not appear to have been considered in determining the housing requirements of the Greater Norwich Draft Plan. This ignores the intricate links between the supply of housing and employment land, and the constraining nature insufficient delivery of housing can have on securing sustainable jobs growth otherwise recognised in Paragraph 81of the NPPF.
5.2.6 To ensure consistency with national planning policy, the authorities should assess to what degree the proposed housing requirement will support the implementation of the jobs growth figures set out in draft Policy 1. Should this assessment show that the supply of housing land planned through the GNLP would fail to provide for a sufficient economically active workforce, an appropriate upward adjustment should be made to the housing requirement to ensure that housing land supply does not act as a constraint to planned levels of economic growth. At present this additional, but important assessment, is missing from the supporting evidence base to the GNLP and is required to ensure that the proposed housing requirement is robust and consistent with national planning policy.
Supply
5.2.7 Gladman welcomes and is supportive in principle of the proposal to allocate surplus housing land in contrast to proposed requirements through the GNLP. This surplus will help secure a significant boost in housing land supply, heighten the deliverability of the defined housing requirement, and ensure that the GNLP is durable to any changes which might occur over the plan period.
5.2.8 The need to secure deliverability is significant in the case of the GNLP where much of the housing requirement is evidently already met by committed developments (around 85%), and in particular, a relatively small number of larger schemes. This includes the Old Catton, Sprowston, Rackheath, and Thorpe St Andrew growth triangle located north and east of Norwich which will provide around 13,500 dwellings, as well as other strategic development sites at Cringleford, Costessey, Long Stratton and Wymondham. Should any of these sites stall or fail to come forward as envisaged, the GNLP will quickly fail given the significant contribution made by these sites to the housing needs of the plan area. It is therefore important to plan for an increased supply and to allow flexibility to account for any potential shortfall at any of these sites.
5.2.9 A targeted buffer of 10% to the housing land supply is currently proposed through the draft Plan. Noting the significant degree of committed developments and the role played by large scale development cited above, Gladman does not consider this buffer to be sufficient and should be increased to no less than 20%. This would provide for a total supply of 48,660 dwellings (8,110 dwellings in excess of the requirement). The adoption of this higher buffer would provide greater certainty that the housing requirement, as currently defined, is met in full.
Contingency
5.2.10 In addition to the proposed buffer to the housing land supply, the GNLP identifies possible locations for further growth as contingency, should sites fail to come forward as envisaged. This includes 1,000 dwellings at Costessey, and the potential for a further 1,000 dwellings at Wymondham.
5.2.11 Further detail about the merits of specific locations for this contingency is set out under separate cover by Gladman. It is however unclear, at this draft stage, as to how the Councils envisage that the contingency sites might come forward when required in the plan period. As drafted the GNLP sets out no mechanism under which these contingency sites might come forward. The GNLP is therefore silent under what conditions these sites might be permitted by the relevant local authority, and what the approach to securing the delivery the proposed contingency locations are. In this regard the GNLP is ineffective, and a revised approach is necessary to secure its deliverability.
5.2.12 Gladman’s preference is for this contingency (at both Costessey and Wymondham) to be included within the Greater Norwich Local Plan as allocations for housing. This position takes into account comments made above in relation to housing need and the case for flexibility in planned levels of supply, should committed and other allocated sites fail to come to fruition. Allocating this land for housing provides the greatest certainty that sites can come forward without delay, sites are available and deliverable for housing, and reduces the need for future review.
5.2.13 Should the Councils disagree with the above, Gladman considers that additional wording is necessary in Draft Policy 1 to set out how contingency sites would come forward. The need for flexibility in this wording is key in order to minimise delay in meeting any arising unmet need and ensure that identified contingency sites are effective in responding to a requirement for an increase in the supply of housing land. As such, any policy requiring first a review of the GNLP before development is permitted at contingency sites should be avoided owing to the significant delay such a process would have, significantly reducing the merits of contingency sites in addressing any housing shortfall.

Comment

Representation ID: 22488

Received: 16/03/2020

Respondent: Highways England

The proposed long-term future target year is a minimum of 44,340 new homes in twenty years, between 2018 and 2038. The proposed new allocation is 7,840 distributing in Norwich urban areas and in different main towns, key service centres and village clusters. The only thing I could raise is that the number of housing for annual target around two thousand is very high which may become a road junction capacity issue within medium to long term delivery target.

Comment

Representation ID: 22516

Received: 16/03/2020

Respondent: Broadland Green Party

Comment: We have already questioned the projected rise in the population. No satisfactory evidence has been provided for this increase.
There appears to be a circular argument on house numbers and jobs to be created. What comes first? Is it the jobs or is it the people who need the jobs?
We have already seen that with declining birth rates the only way in which the population is going to rise in the lifetime of the plan is through new people arriving. Given that any further developments are going to increase our carbon footprint and degrade our pleasant environment why would we want to encourage an increase in an unsustainable population? The argument in the plan is to increase economic growth but if this growth is at the expense of healthy living and increased carbon emissions then it is neither a welcome nor sustainable way to plan our future.
The housing that is required should be built to provide affordable housing for those who need it and housing for the elderly as indicated by the population mix in Section 2, para 34.
A significant proportion of such housing will need to be social housing for those who cannot afford to buy.

Support

Representation ID: 22631

Received: 13/03/2020

Respondent: M Scott Properties Ltd

Number of people: 2

Agent: Bidwells

Support
See comments made in relation to Question 9.

Object

Representation ID: 22644

Received: 16/03/2020

Respondent: Cllr Julie Neesam

NO - the 9 /10% extra allocations as well as additional windfall sites is excessive given that there are sufficient sites allocated to meet predicted demand.

Comment

Representation ID: 22660

Received: 16/03/2020

Respondent: Saxlingham Nethergate Parish Council

Paragraph 145 claims that the strategy ‘is informed by consultation feedback’, yet chooses to ignore much from previous consultations even where such feedback was significantly in favour of a particular approach. An example of this is the position taken towards windfalls. Responses to the Stage A Regulation 18 Site Proposals and Growth Options consultation were significantly against (110 to 45) counting windfalls in addition to the additional (at that point 7,200) housing, and yet this has been ignored in the current draft plan consultation. By not counting windfalls in the calculation for housing numbers in table 6, there will be a resulting over-supply of houses, particularly if the out-of-date 2014 National Housing Projections are used. Windfalls are acknowledged as a reliable source of new housing and many Local Authorities do count them towards their housing targets: their contribution towards housing targets in the GNLP should lead to a reduction in the number of new sites which are allocated.

CPRE Norfolk also has specific concerns about the approach for housing numbers in the South Norfolk Village Clusters, as there is no total figure given for this new housing, but instead an open-ended ‘minimum of 1,200 homes’. This use of the word “minimum” needs to be removed and replaced by a “maximum” total, so that further potential over-supply is avoided. At best, the actual delivery of new housing in the plan area has just exceeded 2,000 dwellings per annum, with 1,500 being more typical. At this build-rate, current commitments cover actual housing need to 2038.

CPRE Norfolk wants to see sites allocated for housing in the existing plan (JCS) developed before any new sites that are likely to be added in to the emerging GNLP are built out. Although we understand that it will not be possible to prevent new sites being included in the plan, we are asking that these extra land allocations for housing are treated as phased development and that building should not occur on these sites until the current JCS sites have been used up. We think this is a sensible approach because not only does it protect the countryside, but also at current rates of house building there is enough land already allocated in the JCS to cater for the building that is likely to occur over the new Plan period.

There is very little evidence to show that increasing the amount of land on which houses can be built actually increases the rate at which they are built. All that happens is that developers ‘cherry-pick’ the most profitable sites, which are likely to be the newly allocated green field sites and that this will lead to even more land banking of currently allocated sites. This will also mean that many less sustainable (or as CPRE Norfolk would argue, unsustainable) sites for housing are developed rather than those with more sustainable locations. This would result in more pollution and congestion, with the negative consequences for the climate and climate change. It also means that expensive infrastructure which has been provided to facilitate new housing in the existing plan, could end up being an irrelevant and embarrassing white elephant.

It is disappointing that there is no mention of phasing as an option within the consultation document, as this would help to prevent the worst excesses of unnecessary development. 69 Parish and Town Councils in Broadland and South Norfolk (over 38%)have supported CPRE Norfolk on this issue and have signed a pledge to this effect, which was included in the previous consultation, but ignored in the current draft Plan. 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. Clearly there is a democratic deficit: meaningful consultation should not ignore this volume of common-sense opinion.

Comment

Representation ID: 22696

Received: 16/03/2020

Respondent: Strutt & Parker LLP

[On behalf of Scott Properties Ltd]
22. In developing the new Greater Norwich Local Plan, it will be important that an adequate mix of sites is promoted including a proportion of smaller sites as well as sites to meet specific housing needs (including housing for older people). Our client’s site at Briar Farm, Harleston could make a meaningful and positive contribution towards meeting these goals.
23. With regard to the delivery of new housing, the Greater Norwich Local Plan’s inclusion of a 9% buffer is supported, and while a higher buffer of up to 20% would normally be advisable to offset the potential for slow delivery on some sites, in particular large strategic sites. It is acknowledged that no allowance has been made in this instance for windfall within the overall supply and the contingency of approximately 2,000 homes provides additional flexibility to ensure that the overall housing needs are met. However, as outlined above, given the uncertainty around the Carrow Works site (1,200 homes), it would be advisable to allocate smaller sites up to c. 25 units (c. 1 ha) across the Plan area to help boost the supply of new homes.
24. It is acknowledged that the Plan aims to comply with paragraph 68 of the NPPF by accommodating at least 10% of the housing requirement on sites no larger than 1 ha, however, where there are reasonable alternatives available these should be included to maintain supply and avoid the need to rely on less certain strategic sites or large contingency sites.
25. The “presumption in favour of sustainable development” is at the heart of the National Planning Policy Framework 2019 (NPPF). The Planning and Compulsory Purchase Act 2004 (Section 39(2)) establishes a legal requirement for Plans to be prepared with the objective of contributing to the achievement of sustainable development.
26. Paragraph 16 of the NPPF requires plans to be prepared positively in a way that is aspirational but deliverable. Paragraph 59 reminds Local Planning Authorities that the Government’s objective is to significantly boost the supply of homes and that it is therefore important that a sufficient amount and variety of land comes forward where it is needed.
27. To ensure that Local Authorities have specific deliverable sites they are required to maintain a 5 Year Housing Land Supply with an appropriate buffer. In addition, to ensure supply is maintained, they are also required to monitor the progress in building out sites, to comply with the housing delivery test. The Government’s recently published housing delivery figures for 2019 indicate delivery for the Greater Norwich area comprising Broadland, Norwich and South Norfolk to be at 140%. This is very encouraging, however, housing delivery can be fragile and susceptible to changes in the economy or delays in the delivery of key infrastructure necessary for strategic sites to come forward.
28. Further to the above, Policy 1 – The Sustainable Growth Strategy sets the settlement hierarchy for the Plan Area as follows:
1. Norwich Urban Area (Norwich and Norwich Fringe)
2. Main Towns
3. Key Service Centres
4. Village Clusters
29. Further detail on Village Clusters is provided at Appendix 5 of the Draft Strategy, as the preferred option the Council consider that a ‘cluster approach better reflects the way people access services in rural areas and enhances social sustainability by facilitating levels of growth in small villages’ This statement is supported, however it is unclear how this approach will work effectively within the Plan area and how achievable it will be. As such, a focus should be made on small and medium sites. The distribution of growth to a variety of sites will enable a steady delivery of homes and ensure the District can meet its housing targets throughout the Plan period.