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

Support

Representation ID: 22711

Received: 03/04/2020

Respondent: CODE Development Planners Ltd

We support the general strategy which seeks to distribute housing growth in line with a settlement hierarchy of:
1) The Norwich urban area
2) The main towns
3) The key service centres
4) Village clusters
As stated in policy 1 "The distribution of development in the plan tends to focus more growth higher up the hierarchy maximising the use of brownfield land and providing for urban extensions close to existing Jobs services and infrastructure" This approach is most likely to achieve the sustainable development required by the NPPF.
Reference accompanying Position Statement and appended reports
- Landscape and Visual Appraisal prepared by Robert Myers Associates (March 2020)
• Landscape Report (incorporating Illustrative development framework plan) prepared by Robert Myers Associates (March 2020)
• Heritage Desk Based Assessment prepared by Orion (May 2019)
• Tree Survey and Constraints Plan prepared by Hayden's (February 2020)
• Preliminary Ecological Appraisal prepared by Wild Frontier Ecology (June 2019)
• Bird Hazard Risk Assessment prepared by Airfield Wildlife Management Ltd (July 2019
• The Monitoring and Management of Gulls on Commercial and Industrial Buildings in the Vicinity of Norwich International Airport prepared by Airfield Wildlife Managements Ltd (July 2019)
• Surface Water Drainage Strategy prepared by Richard Jackson Engineering Consultants (March 2020)
• Access and Transportation Strategy prepared by Richard Jackson Engineering Consultants (March 2020)

Object

Representation ID: 22719

Received: 12/03/2020

Respondent: Mrs Janet Hill

Question 14.

The statements throughout the document indicate time and again that the new proposed development will somehow bring improvements to peoples lives, their environment and their social and employment welfare. However, there does not appear to be any evidential justification for any such statements. Without any empirical evidence to support such statements, and in the light of past experience, to state that 'more of the same' will actually bring different results is clearly misleading and wrong. All such statements and allusions should be struck from the plan and in their place, it needs a clear indication of the effects and results of the development of the past 30 years -not dressed up and partially chosen bits of statistics that cover up the real truth of what people know to have happened in their county and to their lives, but an independently undertaken review of all the above areas of the functioning of the GNDP area (by at least two teams of independent academics from universities not in the region - who will allow peer review and accountability to their reports) this will then provide the basis for a new plan and a new set of objectives with information to allow reasoned judgement.

In the meantime, the proposals in the report to continue to add further development to the GNDP area should be halted as it is clearly unsustainable to propose more development when the existing development has failed to produce a sustainable, good society, economy and environment. There is already a vast amount of consented development potential which has yet to be realised in the current Plans - and which will no doubt continue to contribute to the decline in the quality of life of the County. There is therefore NO justification for more until proven evidence is available and presented to the Public in a manner which is not partisan and biased, and which will allow real assessment of the true effects of such development to be understood balanced against any benefits.

Summary
The evidence of the past 30 years of a growth strategy similar to that which is being proposed, has been unsustainable in terms of its adverse impacts on the environment (traffic density, air pollution, water resource impacts, loss of countryside, damage to biodiversity), society (increased crime, reduced social cohesion, failing schools, failing health services, failing social services) and the lowering in the quality of life for residents resulting from this and other related factors. More of the same is therefore unsustainable and fails the NPPF test in relation to suitable development. The plan should be completely re-thought
It cannot even be stated that 'growth' has brought about real increases in peoples incomes - with income levels for the median and lower incomes (the vast majority) lower in real terms than 10 years ago.

Comment

Representation ID: 22726

Received: 16/03/2020

Respondent: Pegasus Group

Paragraph 60 of the NPPF outlines that strategic policies should be informed by local housing needs, using the Government’s standard method unless exceptional circumstances for an alternative approach can be justified which reflect current and future demographic trends and market signals.
Paragraph 11 NPPF confirms that for plan-making, the presumption in favour of sustainable development means that:
• Plans should positively seek opportunities to meet the development needs of their area, and be sufficiently flexible to adapt to rapid change; and
• Strategic policies should, as a minimum, provide for objectively assessed needs for housing and other uses, as well as any needs that cannot be met within neighbouring areas…
Minimum housing requirement
The need for 40,550 homes is identified as having been calculated using the standard method. Albeit it is noted that the Draft Strategy states that the published version of the plan will aim to provide a minimum 10% buffer (a minimum of a further 250 homes) which is likely to be provided through a combination of additional sites proposed through this consultation and contingency sites identified in the draft plan.
The standard method provides the minimum local housing need 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 year[1]. 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.
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.
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.
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 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. Ministry of Housing
Communities and Local Government 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 Planning Performance Guidance (PPG) (68-034) and the PPG
(63-016a) are applied this would equate to 2,901 houses[2] 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. 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. 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.
Historic under-delivery
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%. The overestimations of supply can be mainly attributed to the
delivery rates of strategic infrastructure projects, and consequently, the ability of large scale SUE’s to
be delivered across Greater Norwich. 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
41,400 homes. This would produce a housing requirement for circa 52,000 homes. This illustrates 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, which in addition to the minimum housing need for circa 41,400 homes produce a housing
requirement for at least 45,126 homes.
Expected Economic Growth
In addition to this, given the early stage of the plan preparation and the need for further technical
work and analysis regarding economic growth and housing need it is recommended that the additional
33,000 new jobs, is viewed as a minimum by the Councils. The Councils will need to adopt a flexible
approach to setting the increased housing target to ensure that available land is used efficiently to
meet the economic and housing needs of the area.
By planning proactively for increased rates of housing the GNLP will support and stimulate the
anticipated economic growth and job creation in the area and in turn support the growth of the
Cambridge Norwich Tech Corridor. Preparing the GNLP on the basis of an enhanced figure to address
economic growth is entirely justified given the context provided by the Greater Norwich City Deal,
which identifies that strategic infrastructure is needed including to deliver a step change in housing
delivery. The City Deal identifies that 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. The Government encourages authorities to consider higher levels of growth than that required to meet local housing need, particularly where there is the potential for significant economic growth.
In our assessment, based on the information available and content of the Draft Strategy document, it is strongly recommended that the GNLP plans for an increased housing need figure. This will support economic growth, reduce inequality, increase affordability levels and promote wellbeing through the delivery of additional market and affordable housing in sustainable locations. Even at this early stage of the plan preparation process it is evident that exceptional circumstance exists in this instance to justify increased housing delivery in accordance with paragraph 60 of the NPPF.
Land off Norton Road, Loddon
Our client considers that the Councils should consider identifying additional available and deliverable small and medium sized sites from a range of locations, which are capable of accommodating housing growth within the plan period.
Our client’s site is available and deliverable within the plan period, with site access feasible to both the Northern and Southern sections of the site from Norton Road. There is also some scope to create through access from the proposed allocation of Land to the east of Beccles Road (GNLP0312) to the west. Furthermore, the village of Loddon is classed as a Service Centre, the largest, most sustainable villages in the area. Indeed, the settlement possesses a wide range of shops, services, infrastructure, employment opportunities and public transport links. Thereby the allocation of the small-scale housing site of Land off Norton Road would lead to the natural extension of the sustainable settlement of Loddon and would assist in providing the Councils with greater certainty over housing delivery during the next plan period.

[1] As confirmed in paragraph 15 of the Housing Delivery Test Measurement Rule Book
[2] Calculated using the average number of students per household of 2.85 in Norwich and applying
this to the 260 student bedspaces which equates to 91 houses; and using the average number of
adults per household of 1.85 in Broadland and applying this to the 8 older persons bedspaces which
equates to 4 houses; and using the average number of adults per household of 1.72 in Norwich and
applying this to be 83 older persons bedspaces which equates to 48 houses.

Comment

Representation ID: 22748

Received: 16/03/2020

Respondent: Rosconn Group

Policy 1 states that there is a need for ‘around 40,550 new homes’ during the plan period 2018-2038. Table 6 confirms that the Local Housing Need figure, being the minimum local housing need figure as calculated using the Government’s standard methodology is 40,541 dwellings. The PPG ‘Housing and economic needs assessment’ states at paragraph 2 that the standard method identifies a minimum annual housing need figure but does not produce a housing requirement figure. Paragraph 10 then explains when it may be appropriate to plan for a higher housing need figure than the standard method indicates. It also reiterates the Government’s commitment to more homes being built and support for ambitious authorities who want to plan for growth. In also confirming that the local housing need figure provides only a minimum starting point in determining the number of homes needed in an area, it acknowledges that it does not attempt to predict the impact of future government policies, changing economic circumstances or other factors that might have an impact on demographic behaviour. As such, it then outlines some of the circumstances where it may be appropriate to plan for a higher number of houses. This includes where growth strategies are proposed (e.g. Housing Deals), strategic infrastructure is planned or where an authority agree to take on unmet need from a neighbouring authority.

RSL consider that the housing requirement set out in the Plan should be described as a minimum and not be seen as a ceiling on a greater level of housing coming forward during the Plan period, so that it is consistent with the NPPF’s focus on significantly boosting the supply of housing. It is also considered that the housing requirement within the Draft Plan does not reflect government guidance in that it only proposes to meet the minimum starting point figure and no evidence has been provided to support why this decision has been made or why it is considered to be appropriate. It is notable that the Draft Plan also sets an objective to deliver around 33,000 new jobs by 2038, this target being derived from an analysis of ‘enhanced growth’.

The Strategy Advice document of December 2017 highlights that the detailed assessment of the Greater Norwich sub-region set out within the Employment Land Assessment confirms the considerable potential of the area in the future to achieve significant levels of economic growth based on an assessment of the key economic assets and drivers within the Greater Norwich economy. It continues that these strengths suggest that the growth potential of Greater Norwich extends beyond ‘business as usual’ base growth, leading to GVA’s assessment which identifies an ‘enhanced’ growth scenario that maximise the area’s economic growth potential. This is due to the area having a strong foundation of academic and commercial research, an increasingly entrepreneurial economy, a base of internationally recognised businesses and a diverse property portfolio which suggest Greater Norwich is well positioned nationally and internationally to compete for future business investment as well as continuing to grow its own business base. The document does however highlight at paragraph 2.7 that the base model used to develop the future employment growth does include an assumed level of population growth to balance jobs growth with labour supply and migration, albeit recognising this does not necessarily align with objectively assessed housing needs.

Policy 6 later on in the Draft Plan further elaborates on the proposed economic growth strategy for the area which makes reference to supporting and delivering the ambitions of a series of other related strategies such as the LEP’s Economic Strategy and Local Industrial Strategy, the Cambridge Norwich Tech Corridor initiative and the enhanced growth outlined in the Greater Norwich City Deal, as well as acknowledging the wider benefits of linkages to the Oxford Cambridge Arc and the London Stansted Cambridge corridor.

In such circumstances, RSL object and consider that the authorities should consider a meaningful uplift to the minimum Local Housing Need figure to help support and deliver the ambitious, above-trend economic growth strategy that the Draft Plan is seeking to deliver.

In other respects, reference is made at paragraph 159 to the fact that the housing figures within Policy 1 make provision for a 9% buffer over and above the minimum Local Housing Need figure. Notwithstanding comments above regarding the need to uplift the housing requirement to reflect economic growth aspirations, 9% is not considered to be sufficient when considered in the context of the overall scale of housing need within the 3 authorities and the fact the majority of this is being met by long-standing housing allocations many of which have failed to come forward as planned. In such circumstances, RSL object and consider a much larger buffer of 20% would be more appropriate to ensure there is flexibility in the housing supply to respond to rapid changes, as required by paragraph 11 of the NPPF.

It is acknowledged that some additional flexibility is offered, as detailed at paragraph 162 with reference to a proposed contingency site for 1,000 dwellings at Costessey and potentially a further 1,000 dwellings contingency site at Wymondham, albeit no specific site has been identified at present. Whilst RSL are supportive of the principle of identifying contingency sites, we do object to the approach to allocating such large strategic sites and the decision on where such sites should be located. Contingency sites should, by their very nature, be ‘oven-ready’ sites that could be delivered quickly in order to meet a shortfall in the housing land supply until such time as allocated sites are able to deliver. Allocating one or two strategic sites of 1,000 dwellings are likely to face similar difficulties to the sites they are seeking to supplement in view of longer lead-in times compared to smaller sites. A more credible solution would be to identify a greater number of smaller sites in a variety of locations that could collectively bring forward housing quickly to address short term shortfalls in housing supply. Geographically, as highlighted earlier in our representations, identifying contingency sites in the same location as the majority of allocated housing sites is more than likely to result in a similar fate. A much more credible approach would be to identify contingency sites in a range of locations across the Plan area to maximise their ability to address a rapid change in circumstances and avoid any potential localised issues that may arise in the housing market, such as absorption rates in the Norwich Urban Area as a result of multiple housing sites competing against each other in a very small geographical area. Therefore, distribution of some or all of the contingency sites outside the Norwich Urban Area may be a more effective and justified approach than the one currently proposed.

Support

Representation ID: 22787

Received: 16/03/2020

Respondent: 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 at West of Shelfhanger Road, Diss could make a meaningful and positive contribution towards meeting these goals.

With regard to the delivery of new housing, the GNLP’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, 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 para 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 it will be achievable. 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: 22804

Received: 16/03/2020

Respondent: Peter Rudd

Agent: Pegasus Planning Group

We do raise concerns about the reservation of the sites to be allocated for housing in the South Norfolk villages as part of a separate plan-making exercise (South Norfolk Village Clusters Housing Site Allocations document). We consider that it is more appropriate for this to be considered as part of this plan-making exercise so that any issues with the delivery of housing to meet the needs identified can be rectified by an alternative distribution across the hierarchy. The unknown outcome of that exercise could have significant implications for the distribution of housing across the settlements.

Object

Representation ID: 22850

Received: 16/03/2020

Respondent: Crown Point Estate

Agent: Miss Kate Wood

We are concerned that the Plan relies on the, yet to be formulated, South Norfolk Village Clusters Housing Sites Allocation document. Without this, there is no evidence that the GNLP’s target numbers can be met, which may well lead to a delay in the GNLP process. Such approach is inconsistent with paragraphs 20 and 23 of the NPPF, which require that Councils make sufficient provision for housing through strategic policies that provide a clear strategy for bringing sufficient land forward.

Despite the representation of housing numbers as a minimum figure, the reality at planning application stage is that sites that have not been allocated will be technically contrary to policy. Additionally, the housing numbers should be sufficient to keep up with additional job numbers, anticipated and indeed promoted by the GNLP to facilitate growth. It is therefore imperative that opportunities to allocate sites for housing are taken. We are promoting land at Octagon Farm for mixed use development, building upon the presence of the business use of the converted Octagon Barn and mindful of the presence of new development on the opposite side of the road and the presence of the site on the edge of Poringland, a high order settlement in the hierarchy which has no proposed new allocations. We consider that this site should be allocated to support sustainable growth.

Support

Representation ID: 22877

Received: 13/03/2020

Respondent: Bidwells

Number of people: 2

Support, with comments
For reasons outlined in relation to Question 13, we support the identification of 480 new allocations in village clusters in Broadland to accommodate additional growth

Object

Representation ID: 22922

Received: 16/03/2020

Respondent: Barratt David Wilson Homes

Agent: Savills

There is a conflict in the GNLP between i) the desire to ‘drive economic growth’ and ii) the provision of only the minimum number of new homes.

Support

Representation ID: 22935

Received: 13/03/2020

Respondent: Bidwells

Number of people: 2

Support, with comments.
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.

Support

Representation ID: 22955

Received: 13/03/2020

Respondent: Bidwells

Number of people: 2

Support, with comments.
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: 22968

Received: 16/03/2020

Respondent: Barratt David Wilson Homes

Agent: Pegasus Planning Group

If the Councils do not plan for enough homes for the Greater Norwich area it will worsen the existing affordability issues, limit the benefit that the area has for the local and national economy, damage social inclusion, and have negative implications for climate change as people have to travel further to access jobs. We make this comment in the context of a plan that seeks to significantly increase jobs over the plan period and yet suppresses the potential development yield from a site in one of the most sustainable locations within the plan area (i.e. GNLP0307).

We support the fact that headline housing numbers have been identified as a minimum figure. However, given the planned growth of the economy of the Greater Norwich area the Local Plan needs to take every opportunity to exceed the minimum figures identified for delivery by maximising the use of land on allocated sites. We have already recommended that the delivery of homes at the GNLP0307 site should be increased and we would add that the figures should be set as a minimum in order to boost the supply of new homes in accordance with paragraphs 59 and 60 of the NPPF and support the economic growth of the plan.

Aligned to this, we wish to raise serious concerns that in order to meet the proposed numbers in the Greater Norwich Local Plan there is reliance on the allocation of several thousand new homes through the South Norfolk Village Clusters Housing Sites Allocation document. Presently there are no details as to how these sites will be allocated or when the document will be prepared. There is no evidence that the new homes will be accommodated in the most sustainable locations or within a timescale that will ensure that the needs identified in the plan will be met. Clearly this approach is inconsistent with paragraphs 20 and 23 of the NPPF, which require that Councils make sufficient provision for housing through strategic policies that provide a clear strategy for bringing sufficient land forward.

Without a strategic approach to where these additional allocations are to be located there is no certainty over whether they will deliver sustainable forms of developments. The need to draft and adopt the Housing Sites Allocation Plan will also represent a further delay to the delivery of new homes after the Greater Norwich Local Plan has been adopted. This delay, and uncertainty about the delivery of sites has the potential to limit delivery rates in the short and medium term.

The Greater Norwich Local Plan needs to take a more proactive approach to securing the delivery of new homes to avoid any doubt around delivery timescales and rates on yet to be allocated sites. The most expedient way to provide certainty around delivery of new homes is by ensuring that proposed allocations in the higher order settlements make the most efficient use of land by increasing densities where it is appropriate to do so. Our client’s site at Cringleford would be an ideal location to increase densities in line with already consented development sites in the village.

Support

Representation ID: 22990

Received: 13/03/2020

Respondent: Bidwells

Support, with comments.
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: 23009

Received: 16/03/2020

Respondent: Hingham Town Council

Hingham has a allocation of 120 new homes (including 16 existing commitment), however the consideration of Windfall sites as being “acceptable in principle” – of sites of up to 3 homes within each parish would mean the ACTUAL homes that will be delivered is potentially unquantifiable (Policy 7.5 is ambiguous in its meaning and needs clarification).

Housing figures are not discussed inline with actual need within the community or taking into account the number of vacant properties already in existence.

Hingham Town Council have been told that “deliverability” is a key component to housing development site allocation. The Council would like to sate that just because something is deliverable it does not mean that it is right for a community, and there are concerns regarding the push to deliver housing development “en masse” which could potentially overwhelm the town’s facilities and infrastructure. The GNLP runs until 2038 and the Town Council are of the opinion that a phased approach to delivering smaller developments, as and when needed, with a higher focus on affordability for local people would be a more acceptable and appropriate approach.

Support

Representation ID: 23018

Received: 13/03/2020

Respondent: Bidwells

Support, with comments.
For reasons outlined in relation to Question 13, we fully support the identification of Key Service Centres as locations to accommodate additional growth

Object

Representation ID: 23076

Received: 16/03/2020

Respondent: Orbit Homes

Agent: David Lock Associates

The Greater Norwich area has real potential for growth and compete as a nationally significant economic area. Such growth and success requires a positive and proactive policy basis; growth must be encouraged and not stifled. The GNLP approach to identifying the housing need for the area does not take a proactive approach; moreover, it risks inhibiting the economic and jobs growth that has been agreed as part of the City Deal, and more importantly the recent growth trends that have been evident.

Even more worryingly, there has been a very recent indication that the Greater Norwich housing delivery across Greater Norwich has achieved targets for the first time. This is a positive sign, but the numbers proposed as part of the GNLP would actually result in a reduction of delivery. This is a serious concern at a time when a key Government priority is to significantly boost the supply of housing, and in the context of strong local delivery which would be inhibited by the GNLP numbers.

The GNDP are aiming to meet a need of 2,027 homes per annum, with some further allowances for supply. It appears that GNDP have arrived at such a level of need by simply applying the standard method, introduced for the purposes of establishing a minimum need through recent revisions to the National Planning Policy Framework (NPPF) and related Planning Practice Guidance (PPG).

It is understood that GNDP view the outcome of this formula as an appropriate representation of the full need for housing in Greater Norwich, albeit there is a concerning lack of evidence to substantiate their position in this regard. This lack of consideration conflicts with national policy and guidance, which emphasises that the standard method produces only a minimum starting point and makes clear that there should be an assessment of whether housing need will actually be higher than implied by its formula.

The NPPG requires consideration of a number of factors as part of determining housing need from the starting point of the standard method including any affordability adjustment and taking account of economic circumstances. The GNDP do not appear to make any adjustment from the baseline of the standard method.

In this context we are concerned that the standard method baseline alone would not provide sufficient need as outcome of the method is intrinsically linked to projections that have underestimated population growth to date in Greater Norwich, and particularly failed to anticipate a more pronounced – and increasingly vital – net inflow of people from other parts of the UK. This calls into question whether the method is accurately capturing the housing needed by the population in this area, both now and in the future.

As noted above simply meeting the need implied by the method would also prompt a 16% reduction in the annual rate of housing delivery belatedly achieved over the past three years, when adopted housing targets were met for the first time. Such a reduction is unjustified at a time when the Government remains committed to significantly boosting housing supply and in light of the GNLP objectives to encourage growth and support the Tech Corridor.

Given the economic objectives and wider strategies and commitments to significant jobs growth in Greater Norwich, it is concerning also that with no adjustment for this, simply meeting the need implied by the method would likely grow the labour force and support in the order of 37,000 new jobs. Whilst this supposedly surpasses the target proposed in the Draft Plan (33,000), it falls short of the job growth that can be reasonably expected to result from an ongoing economic growth strategy, this is covered in more detail on the economy below.

The GNDP target is considered inadequate in this regard, given that it is derived from an unjustified and unduly simplistic manipulation of a scenario presented in an evidence base document which is now comparatively dated and pre-dates the revised NPPF. Equally, as a result of the datedness of the informing analysis, it is considered to fail to adequately reflect the strong economic context which Greater Norwich has demonstrated for a sustained period of time or the full impact of planned investment. In this context it is considered that planning for in the order of 40,000 jobs as a minimum over the plan period would be more reflective of the strong potential for truly enhanced growth in Greater Norwich. This clearly would not be supported where housing provision is restricted to the level implied by the standard method, and the associated ageing of the labour force also appears unlikely to support the desired shift towards higher value sectors. Based on the above, we consider that GNDP must update their evidence base prior to the next stage of consultation on the emerging Local Plan, to comply with the NPPF and PPG. This should properly evaluate the level of job growth that is likely in Greater Norwich, taking recent successes – no doubt linked to the City Deal and other initiatives – into account while reconsidering the prospects for long-term growth beyond “business as usual” in key locations and sectors. A related assessment of housing needs should also be produced, to locally test the minimum need implied by any standard method in and ensure that the housing needed to support a growing economy can be planned for.

GNDP also appear to have misconstrued the supply-led buffer proposed as part of its housing requirement, claiming that it provides flexibility to accommodate the consequences of successful investment strategies. The Draft Plan states:
“Our overall approach, including to windfalls and contingency, builds in flexibility to support higher than trend economic growth incorporating the Greater Norwich City Deal” (Paragraph 163 of the GNLP Strategy Document)

The NPPF and PPG are clear that it is a requirement of Local Plans that they are deliverable and sufficiently flexible to adapt to rapid change. The plan’s soundness will be judged against these requirements. The buffer is required to ensure an appropriate allowance for unforeseen circumstances or non-delivery of sites which might otherwise pass the ‘developable’ test. Whilst the Councils have recognised this general point, and the resultant need for an increased level of flexibility, this should not be seen to provide capacity to accommodate need pressures; it is intended to alleviate risks to supply. In this context, the PPG (PPG Reference ID: 2a-010- 20190220) is explicit in recognising that where authorities should consider the appropriateness of a higher housing need figure:
“This will need to be assessed prior to, and separate from, considering how much of the overall need can be accommodated (and then translated into a housing requirement figure for the strategic policies in the plan)”

The Draft Plan later describes another supposed reason as to why the GNDP have not sought to explore the appropriateness of a higher housing need figure, stating with reference to a higher housing figure being considered under a section titled ‘alternative approaches’ that:
“This is not the preferred alternative as evidence of delivery rates over the medium and longer term suggests that higher targets are unlikely to be achievable or deliverable. Setting a higher target that can* be achieved undermines the plan-led system [*it is assumed this should read cannot] (Page 54 of the GNLP Strategy Document)

This is not considered to represent an appropriate or PPG-compliant justification for not attempting to explore the appropriateness of a higher housing need figure. It is of note that the standard methodology recognises the realism of ‘delivery’ with regards to the capping of the adjustment from the baseline to 40%. The PPG specifically acknowledges (Paragraph Reference ID: 2a-007-20190220):
“The standard method may identify a minimum local housing need figure that is significantly higher than the number of homes currently being planned for. The cap is applied to help ensure that the minimum local housing need figure calculated using the standard method is as deliverable as possible”

It is of note that the adjustments for Greater Norwich are notably smaller than 40% and that, as is considered above in our representations [Paragraph 4.50], recent rates of delivery have exceeded the current plan target. As such, there is no justification for suggesting that deliverability concerns represent a valid reason for dismissing the appropriateness of a higher figure.

As previously mentioned in the context of delivery concerns with some of the allocated sites, the absence of a trajectory of this stage at the process to evidence how the sites will contribute to the housing need over the plan period, is a serious issue. This trajectory is required by the NPPF and by not having it available for representors to review and assess alongside the allocations, there is no certainty as to whether the housing needs will actually be met through the identified spatial strategy.

Based on the above, it is considered that the Councils must update their evidence base prior to the next stage of consultation on the emerging Local Plan to comply with the NPPF and PPG. Our objection to the housing needs to be met through the GNLP is set out in greater detail in the ‘Technical Review of Housing Needs in Greater Norwich’ Report by Turley, February 2020, included at Appendix 3.

Object

Representation ID: 23106

Received: 31/03/2020

Respondent: Salhouse 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.

Support

Representation ID: 23134

Received: 16/03/2020

Respondent: Hopkins Homes

Agent: Bidwells

For reasons outlined in relation to Question 13, we support the identification of 300 new allocations in
Broadland’s Main Town to accommodate additional growth.

Comment

Representation ID: 23164

Received: 16/03/2020

Respondent: Pigeon Investment Management Ltd

Agent: Pegasus Group

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 five-year 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 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
1 As confirmed in paragraph 15 of the Housing Delivery Test Measurement Rule Book 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.
2 Calculated using the average number of students per household of 2.85 in Norwich and applying this to the 260 student bedspaces which equates to 91 houses; and using the average number of adults per household of 1.85 in Broadland and applying this to the 8 older persons bedspaces which equates to 4 houses; and using the average number of adults per household of 1.72 in Norwich and applying this to be 83 older persons bedspaces which equates to 48 houses.
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 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 = 300 students per annum identified in paragraph 3.21 – 3 students per annum identified in paragraph 3.20.
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
4 Including in Aylesbury Vale and Gloucester, Cheltenham and Tewkesbury needs are actually met. It is therefore recommended that the proposed contingency of 9% is retained as a minimum, 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.

Comment

Representation ID: 23191

Received: 16/03/2020

Respondent: Orbit Homes

Agent: Armstrong Rigg Planning

The Strategy Document proposes to set a housing requirement of 40,541 new dwellings between 2018 and 2038 (2,027 dpa) which has been calculated using the government’s standard methodology, but seeks to plan for a 9% buffer (to be increased to 10% in the final plan) on top of this requirement by delivering 44,343 new homes by 2038. Existing allocations and commitments total 36,503 dwellings which comprises 82% of the proposed housing growth (and 90% of the housing requirement) to 2038. The GNLP and separate South Norfolk Village Clusters (SNVC) plan therefore only seeks to plan for the additional 18% of growth, totalling 7,840 dwellings (split between 6,640 dwellings in the GNLP and 1,200 dwellings in the SNVC plan).

Under potential alternative approaches, the Strategy Document states that there are no exceptional circumstances to justify setting a lower housing requirement than that identified using the standard methodology. We would agree with this statement in accordance with the test set by NPPF Paragraph
60. However, in terms of whether a higher housing requirement may be needed, the justification provided is clearly not in accordance with national policy. The Strategy Document states that:

“The NPPF does encourage a higher housing requirement to be considered. This is not the preferred alternative as evidence of delivery over the medium and longer term suggests that higher targets are unlikely to be achievable or deliverable. Setting a higher target than can be achieved undermines the plan- led system. However, if additional need and demand for housing materialises, it can be facilitated through the flexibility built into the local plan.”

Not only is the above statement contradictory (as it claims that a higher target could not be delivered and at the same time says that if additional need materialises it could be facilitated through flexibility in the plan), but it is entirely contrary to national policy set out in Planning Practice Guidance (PPG) on Housing and economic needs assessments (ID: 2a-010) which provides advice on when it might be appropriate to plan for a higher housing need figure than the standard method indicates. The PPG clearly states that the standard method provides a minimum starting point in determining the number of homes needed in an area. There will, therefore, be circumstances where it is appropriate to consider whether actual housing need is higher than the standard method indicates. The PPG advises that “This will need to be assessed prior to, and separate from, considering how much of the overall need can be accommodated”. The approach taken by the Greater Norwich authorities of restricting the housing requirement to what can be accommodated is therefore completely contrary to the PPG.

The PPG additionally advises that circumstances where setting a higher housing requirement may be appropriate include, but are not limited to, situations where increases in housing need are likely to exceed past trends because of:

• 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; or

• an authority agreeing to take on unmet need from neighbouring authorities, as set out in a statement of common ground.

The first two of the points above clearly apply in Greater Norwich with respect Greater Norwich City Deal and the ambitions of the Cambridge Norwich Tech Corridor. The City Deal was signed in December 2013 and commits the authorities to secure significant infrastructure funding totalling £440 million and to bring forward 3,000 additional homes by 2026 in the North East Growth Triangle (on top of the target of 37,000 set by the JCS for the whole plan area). Whilst it is recognised that the development

requirements of the City 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.

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 plan 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.

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, but this was discounted as the authorities claimed that the uplift applied by the standard method (i.e. the uplift to account for the affordability of homes that is built into the standard methodology) was sufficient to account for the City Deal uplift required. We disagree with this approach as it 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 on top of this.

In light of the above, Orbit Homes wishes to raise a significant concern regarding the approach employed to set the housing requirement. The use of the standard methodology simply adopts the minimum requirements set by the government and fails to recognise the City Deal growth commitments and ambitions of the CNTC proposals. The significant investment and jobs growth that will result from both these growth strategies will result in an increased housing demand above and beyond the baseline requirement calculated using the Government’s Standard Methodology. It is therefore critical that the housing requirement is increased to meet this increased demand. The majority of this increased growth will be in the Cambridge Norwich Tech Corridor (i.e. along the A11 southwest of Norwich), but it is critical also that the needs of the local population across the plan area are planned for so as to avoid creating an imbalance in housing delivery across the plan area.

Comments on Housing Requirement

The currently proposed housing requirement does not account for the City Deal or Cambridge Norwich Tech Corridor (CNTC) which must both be taken into account if the housing requirement is provide a positive approach to meeting housing needs. This section provides an analysis of the impact of these growth strategies on the housing requirement.

As set out above, the City Deal commits the Councils to delivering 3,000 additional homes in the Growth Triangle on top of the Joint Core Strategy housing requirement by 2026. In order to analyse performance against the City Deal commitment we need to account for how many homes have been delivered and how may homes are currently forecast to be delivered during the JCS plan period between 2008 and 2026 and whether this delivery will meet the 40,000 home commitment set by the City Deal (i.e. 37,000 JCS requirement + 3,000 in the Growth Triangle). Table 2 utilises data in the JCS Annual Monitoring Reports to provide this information.

The above table demonstrates that at the end 2017/18, Greater Norwich had delivered 15,472 net new homes against a commitment to deliver 40,000 by 2026 set out in the City Deal. This leaves a total of 24,528 still to be delivered by 2026 or 3,066 dpa over 8 years. Against this requirement, there is a current shortfall in forecast delivery of 4,964 dwellings. The GNLP offers the opportunity to provide fresh stimulus to achieving the ambitions of the City Deal by making additional allocations on short term deliverable housing sites to provide 4,964 new homes.

An alternative way of assessing the additional housing required to meet City Deal demand is to look at the SHMA published in April 2017. This document 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 (i.e. very similar to the 4,964 additional homes identified by the assessment of shortfall in table 2) that appear not to have been considered when setting the GNLP housing requirement.

On this basis we consider that the housing requirement proposed by the plan falls short of adequately responding to local demand by an approximate 5,000-5,4002 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 45,500-46,0003 dwellings before any 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,

2 4,964-5,361 dwellings rounded up to the nearest 100
3 LHN of 40,541 dwellings plus 5,000-5,400 uplift rounded up to nearest 100
4 Range calculated on the basis of a 5% and 10% buffer above 46,000, in response to paragraph 73 of the NPPF

against which there are existing commitments of c.36,5005 dwellings, leaving a requirement for the GNLP to deliver a minimum of between 11,800 and 14,1006 additional dwellings, or between approximately 4,000 and 6,3007 dwellings higher than the current GNLP additional growth figure of 7,840. This highlights the need for significant additional allocations in the GNLP.