Question 15: Do you support, object or wish to comment on the approach for the Economy?

Comment

Representation ID: 20098

Received: 25/02/2020

Respondent: RJ Baker & Sons

Agent: Cheffins

We support the identification of land at Browick Interchange, Wymondham as a strategic employment location. The potential economic growth associated with this site is important and supports the concept of additional housing growth at Wymondham.

Object

Representation ID: 21283

Received: 16/03/2020

Respondent: Lanpro Services

Agent: Stephen Flynn

It would appear that the additional target jobs growth agreed through the City Deal has not been included. The 33,000 figure seems unambitious in the context of the Vision set out for the Cambridge Norwich Tech Corridor and the number of jobs previously delivered in the 7 years to 2018. In summary, we submit, that the emerging GNLP will be reliant upon an employment land supply that is not flexible or diverse enough; that is not ambitious enough; or have other infrastructure and environmental constraints to expansion. Therefore the emerging GNLP plan will conflict with the NPPF and is unsound.

Object

Representation ID: 21393

Received: 16/03/2020

Respondent: Glavenhill Ltd

Agent: Stephen Flynn

It would appear that the additional target jobs growth agreed through the City Deal has not been included. The 33,000 figure seems unambitious in the context of the Vision set out for the Cambridge Norwich Tech Corridor and the number of jobs previously delivered in the 7 years to 2018. In summary, we submit, that the emerging GNLP will be reliant upon an employment land supply that is not flexible or diverse enough; that is not ambitious enough; or have other infrastructure and environmental constraints to expansion. Therefore the emerging GNLP plan will conflict with the NPPF and is unsound.

Object

Representation ID: 21462

Received: 16/03/2020

Respondent: Mrs Georgina Brotherton

See Lawson Planning Partnership Statement

Comment

Representation ID: 21516

Received: 16/03/2020

Respondent: Hingham Town Council

please refer to full text

Siting a housing development so close to a “employment area” which is already home to heavy industry can have many negative impacts on residents, with regard to road safety, increased traffic in a confined area, noise and pollution. It should also be recognised that employment does not occur in just one designated area within a community.

Support

Representation ID: 21734

Received: 16/03/2020

Respondent: Brown & Co

The proposed new settlement Honingham Thorpe would support and enhance the Food Enterprise Park, providing the opportunity for a holistic approach with a mutually supportive provision of jobs, education and housing which would help to attract skilled workers, companies and investment. The proposed new settlement would support changes in working practices including working-from-home, and the needs of small and start-up businesses with smaller and flexible spaces within the village centre. The new settlement would aim to create a circle economy, ensuring economic growth is retained within the Greater Norwich area, and is not lost to other locations along the A11.

Comment

Representation ID: 21942

Received: 13/03/2020

Respondent: UEA Estates & Buildings

Agent: Bidwells

Whilst it is appreciated that the UEA does not solely comprise a strategic employment location, it is suggested that the policy is amended to reflect the valuable role which the UEA provides to the Norwich and UK economy. The UEA contributes £1.04 billion to the UK economy, of which £468 million is retained within Norwich.

Accordingly, development on GNLP0133-B, GNLP0133 C, GNLP-133-D, GNLP0133-E and GNLP0140-C will help support and sustain the important contribution of the UEA to the economy.

Comment

Representation ID: 22058

Received: 13/03/2020

Respondent: Norwich International Airport

Agent: Barton Willmore

5.2 Norwich Airport partly supports Policy 1 as the Airport area is considered a strategic
employment location. It is ideally located on the strategic road network, as shown in
Figure 1. The Site is suitable to support a wide range of economic sectors, helping to
contribute to the delivery of 33,000 additional jobs throughout the Plan period.
5.3 However, Norwich Airport would question the assertion that the land provided for in 2018
is sufficient for the region’s needs throughout the Plan period. The Report undertaken by
Bidwells and Roche has demonstrated that the existing employment floorspace is not of
a high quality to support new businesses, shown at Appendix 2. New companies require
flexibility and the Site is able to provide suitable floorspace that is beneficial from a
quantitative (it would be the largest single allocation in the Plan) and qualitative (it would provide modern floorspace, adapting to companies’ requirements and market changes)
perspective.

Support

Representation ID: 22088

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: 22178

Received: 16/03/2020

Respondent: Pigeon Investment Management Ltd

Agent: Pegasus Group

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 provided to accommodate the workforce to avoid the resultant environmental 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.

Comment

Representation ID: 22328

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: 22366

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: 22400

Received: 16/03/2020

Respondent: Norwich Green Party

Sites allocated in the JCS should be developed first of all before bringing forward new sites allocated in the GNLP. Sites with good access to rail and public transport, walking and cycling facilities should be given preference. Too many strategic employment sites reliant on car and lorry use have been permitted, adding to carbon emissions eg Longwater, Broadland Business Park, Norwich Research Park, Easton/Honigham, Hethel. Employment sites not required should be de-allocated. The JCS failed to achieve sustainable development and the draft GNLP is continuing along a business as usual path.

Comment

Representation ID: 22415

Received: 16/03/2020

Respondent: Horsham Properties Ltd

Agent: Mrs Georgina Brotherton

Question 15 - Do you support, object or wish to comment on the approach for the Economy?
4.6 As explained above, the site owners do not support the Plan’s approach to the economy with regards to existing small and medium size employment sites. Section 3 sets out the reasons why Policy 6 ‘The Economy’ requires amending. It is therefore, requested that Policy 6 is amended to allow for the expansion of small and medium sized employment sites.
4.7 With the above national policy context in mind, we consider draft Policy 6 is not flexible enough to meet the changing requirements of businesses and request that paragraph 2 is amended to allow for the expansion of small and medium sized sites, such as Abbey Farm Commercial Park. We therefore request that Policy 6, Paragraph 2 is amended as follows:
2.The needs of small, medium and start-up businesses are addressed through: • the allocation and retention of smaller scale employment sites across the area and the potential expansion of, a range of existing small and medium sized sites (LPP suggested text); • encouraging the provision of small-scale business opportunities in all significant residential and commercial developments and through the appropriate use of rural buildings; • Encouraging flexible building design and innovative approaches in new and existing residential developments to encourage local working and business opportunities.
Question 34 - Do you support, object or have any comments relating to the approach to employment land?
4.8 As explained above, the site owners do not support the approach to employment land with regards to existing small and medium size employment sites. Section 3 sets out the reasons why Policy 6 ‘The Economy’ requires amending. It is therefore, requested that Policy 6 is amended to allow for the expansion of small and medium sized employment sites.
4.9 With the above national policy context in mind, we consider draft Policy 6 is not flexible enough to meet the changing requirements of businesses and request that paragraph 2 is amended to allow for the expansion of small and medium sized sites, such as Abbey Farm Commercial Park. We therefore request that Policy 6, Paragraph 2 is amended as follows:
2.The needs of small, medium and start-up businesses are addressed through: • the allocation and retention of smaller scale employment sites across the area and the potential expansion of, a range of existing small and medium sized sites (LPP suggested text); • encouraging the provision of small-scale business opportunities in all significant residential and commercial developments and through the appropriate use of rural buildings; • Encouraging flexible building design and innovative approaches in new and existing residential developments to encourage local working and business opportunities.
Question 46 - Do you support or object or wish to comment on the approach for specific Village Clusters?
4.10 The site owners do not support the approach to Village Clusters as drafted within Policy 7.4 for the reasons set out in Section 3. It is requested that the policy is amended to include the existing employment allocation (site reference HNF3) land West of Abbey Farm Commercial Park within the policy. It is also requested that the text is amended to allow for the expansion of small and medium sized employment sites. We therefore request that the penultimate paragraph of Policy 7.4 is amended as follows: • Other small-scale employment development will be acceptable in principle elsewhere within village development boundaries or through the re-use of rural buildings or through the potential expansion of existing small and medium sized employment sites (LPP suggested text) subject to meeting other policies in the development plan.

Comment

Representation ID: 22469

Received: 16/03/2020

Respondent: Breckland District Council

BDC seeks confirmation that the proposed growth from GNLP will not be of detriment to the growth planned within Breckland.
In particular the Council is concerned that the cumulative growth impacts on transport, power, water supply have been adequately addressed.

For information, BDC has significant growth in these areas with 4000 dwellings and employment land west of London Road at Attleborough, the significant employment growth plans for Snetterton Heath and housing and employment growth along A47 particularly at Dereham.

BDC has concerns whether the proposed improvements on A11 and A47 will be sufficient to meet the needs of the cumulative grois there sufficient Railway capacity to cope with increased growth. Equally is there sufficient Railway capacity to cope with increased growth.

Under the Duty to Cooperate, Breckland District Council would welcome the opportunity to engage with GNLP to explore a joint approach to any constraints which may arise as a result of the cumulative growth in both planned areas.

Support

Representation ID: 22674

Received: 16/03/2020

Respondent: Mrs Nicole Wright

ECONOMY

An additional insert is required in support of appropriate growth and expansion of existing businesses and live-work units taking account of current trends and increase in home working.

The policy lacks support for and provides an insufficient response to new and changing business needs.

Comment

Representation ID: 22747

Received: 16/03/2020

Respondent: Rosconn Group

In connection with our response to Question 14 above, it is not clear whether the economic growth ambitions of Policy 6 are fully consistent with the housing requirement set out within the Plan. Moreover, is there any evidence to indicate that 40,541 dwellings in the period to 2038 is sufficient to support the economic aspirations of the emerging Plan to 2038? Until such time as this is clarified, we wish to maintain an objection that the economic objectives are not deliverable, justified or effective due to a lack of suitable housing for the employees required to service future jobs growth or otherwise, there is likely to be an increase in in-commuting to the area from outside in order to service these newly arising jobs which would not be a sustainable approach to adopt.

Object

Representation ID: 22760

Received: 16/03/2020

Respondent: Mr Bryan Robinson

I am concerned at the over-simplistic principles for growth and the employment agenda arising therefrom. Growth seems to be assumed to be limited to more people employed preferably at higher income jobs.

The fallacy of this approach is that Norfolk has a historic low level of unemployment and therefore an inability of available labour to fulfil these ambitions, resulting in competition with other regions for this extra labour leading to inward migration. This in turn leads to more demand for housing and infrastructure. The housing need numbers in the consultation would be significantly less without this inward migration.

Another consequence of promoting competition with similar geographic areas both within and outside the UK is that there is often migration of labour and jobs away from the Norwich area as exampled by Colmans and Britvic.

It is acknowledged that land should be made available for employment opportunities but unfortunately the consultation does not indicate what the drivers for the locations proposed are and the impact elsewhere.

Can growth be achieved other than by more jobs? Growth is defined as increased output and which can also be realised by extra productivity per operative.

Despite the net loss of employment floorspace in the last decade, unemployment in Greater Norwich has fallen which would indicate that other factors are having a positive impact on the economy outside the unfulfilled allocations for office space in Broadland.

The GNLP lacks an understanding of these factors and do not consider other avenues for increasing the GDP of the area such as education and investment in technology. Both would assist the economy without the damage of inward population migration, more housing and more roads.

The specific growth area is set out in the proposals as the Cambridge to Norwich corridor through the city centre and finishing at the north/east growth triangle.

The towns in this linear development will all benefit from the growth investments but the strategy makes any proposals for other major towns outside this corridor.

Past policies for employment locations were haphazard and are now being repeated. An example is the location of the Food Enterprise Park at Honingham. A FEZ for food related activities was an ideal opportunity to help create employment in the countryside closer to where the crops are grown. Instead the various authorities supported the location on the outskirts of the city necessitating both labour on products having to use the road system.

Despite a £1m grant to the landowner, the single occupant is a processing plant for what is left of Colmans. We now have mustard seed being stored in the Fens, transported to Norwich for processing and then transported to Burton-on-Trent for final production. Previously the final production was at the same site as the processing so how can these extra road miles be good for the environment?

There are road restrictions associated with the locations which are impacting the designs of the A47 improvements between Easton and North Tuddenham. The grade separated junction at Blind Lane/Taverham Road is solely to service the Food Enterprise Park. There are still unresolved problems in that other HGV’s leaving Honington Thorpe Farms are prevented from using Blind Lane to access this junction and must still use Church Lane with implications for Easton.

This is another example of a poor planning decision for a vanity project.

Bluntly, I am unhappy with the extent of public money being given to a private landowner for a limited questionable economic return without any public debate.

Object

Representation ID: 22851

Received: 16/03/2020

Respondent: Crown Point Estate

Agent: Miss Kate Wood

Policy 1 refers to the allocation of smaller scale employment sites within built up areas, but misses the opportunity to support the allocation of sites where the conversion of existing rural buildings would contribute to employment in lower value sectors, where premium locations would prevent such businesses from establishing.

Comment

Representation ID: 22904

Received: 13/03/2020

Respondent: Bidwells

Number of people: 2

Comments.
Whilst it is appreciated that the UEA does not solely comprise a strategic employment location, it is suggested that the policy is amended to reflect the valuable role which the UEA provides to the Norwich and UK economy. The
UEA contributes £1.04 billion to the UK economy, of which £468 million is retained within Norwich.

Accordingly, development on GNLP0133-B, GNLP0133-C, GNLP-133-D, GNLP0133-E and GNLP0140-C will help support and sustain the important contribution of the UEA to the economy.

Comment

Representation ID: 22936

Received: 13/03/2020

Respondent: Bidwells

Number of people: 2

Comments.
Whilst it is appreciated that the UEA does not solely comprise a strategic employment location, it is suggested that the policy is amended to reflect the valuable role which the UEA provides to the Norwich and UK economy. The UEA contributes £1.04 billion to the UK economy, of which £468 million is retained within Norwich.
Accordingly, development on GNLP0133-B, GNLP0133-C, GNLP-133-D, GNLP0133-E and GNLP0140-C will help support and sustain the important contribution of the UEA to the economy.

Comment

Representation ID: 22956

Received: 13/03/2020

Respondent: Bidwells

Number of people: 2

Comments.
Whilst it is appreciated that the UEA does not solely comprise a strategic employment location, it is suggested that the policy is amended to reflect the valuable role which the UEA provides to the Norwich and UK economy. The UEA contributes £1.04 billion to the UK economy, of which £468 million is retained within Norwich.
Accordingly, development on GNLP0133-B, GNLP0133-C, GNLP-133-D, GNLP0133-E and GNLP0140-C will help support and sustain the important contribution of the UEA to the economy.

Comment

Representation ID: 22991

Received: 13/03/2020

Respondent: Bidwells

Comments.
Whilst it is appreciated that the UEA does not solely comprise a strategic employment location, it is suggested that the policy is amended to reflect the valuable role which the UEA provides to the Norwich and UK economy. The UEA contributes £1.04 billion to the UK economy, of which £468 million is retained within Norwich.
Accordingly, development on GNLP0133-B, GNLP0133-C, GNLP-133-D, GNLP0133-E and GNLP0140-C will help support and sustain the important contribution of the UEA to the economy.

Object

Representation ID: 23010

Received: 16/03/2020

Respondent: Hingham Town Council

The allocation of employment locations should be considered in relation to allocation of preferred sites for housing development, and it should be considered how the 2 areas would impact on each other both positively and negatively. In Hingham a preferred site for housing development is sited opposite the designated employment area, only the “positive” of the potential for providing local employment (within walking distance) to residents of the new development has been highlighted. Siting a housing development so close to a “employment area” which is already home to heavy industry can have many negative impacts on residents, with regard to road safety, increased traffic in a confined area, noise and pollution. It should also be recognised that employment does not occur in just one designated area within a community.

There appears to be no time scales with regard to the development of the employment area - i.e when would the jobs be delivered?

Support

Representation ID: 23077

Received: 16/03/2020

Respondent: Orbit Homes

Agent: David Lock Associates

We support the general approach to the growth of the economy and welcome the recognition of the Tech Corridor and its relationship to the globally significant axis between Cambridge and Oxford. We are however concerned that the Plan is not optimistic enough in making provision for economic growth, both in planning for sufficient jobs and planning for sufficient housing to support these jobs.

The Draft Plan targets the creation of at least 33,000 jobs over the plan period (2018-38) and confirms that this ‘has been established through local trend-based evidence’ (Paragraph 149 of the GNLP Strategy Document) . Whilst the Draft Plan attributes this to the East of England Forecast Model (EEFM) it also confirms its origination from evidence included in the Employment, Town Centre and Retail Study produced by consultancy GVA in 2017. This study used the then-latest published iteration of the EEFM to explore scenarios of job growth based on ‘business as usual’ and the potential for ‘enhanced economic growth’.

The latter scenario, which the Draft Plan confirms underpins its job target, identified that between 2014 and 2036 around 44,000 jobs could be created, an average of 2,000 jobs per annum. It built from the EEFM but applied positive adjustments to a number of sectors which were considered to better reflect local and national growth potential.

The 33,000-job target in the Draft Plan is explained as being based on:
• A netting off of the 15,000 jobs created to 2018 from the 45,000 jobs forecast in the Employment, Town Centre and Retail Study; and
• An extension of the forecast by a further two years to 2038, the extension implied to be based on the latest EEFM outputs.

Such an approach is considered to have a number of significant limitations:
• The Employment, Town Centre and Retail Study is now comparatively dated and should be revisited to ensure it is based on up-to-date economic datasets;
• The GNDP approach to manipulate the previously evidenced job forecast fundamentally fails to take into account the approach taken to generate the enhanced growth scenario or its forecast of job growth over the long-term; and
• At a wider level there have been more marked local and national changes to the economy which have a bearing on the forecasting of future job growth and should be taken into account through an updated evidence base. This will ultimately ensure that the Local Plan takes full account of the current ambitions of the GNDP and the Local Enterprise Partnership, as well as national Government.

It is noted that in seeking to justify the 33,000-job growth target the GNDP, through the Draft Plan, advance an argument of dismissing the potential for higher growth targets, as have evidently been set previously. This justification is predicated on questions as to whether ‘significantly higher targets’ are ‘achievable’ given ‘current economic uncertainties’ and the ‘enhanced growth’ that is ostensibly already provided for.

The suggestion that higher levels of growth would not be ‘achievable’ does not stand up to scrutiny when recognised that the target of 33,000 jobs represents a markedly lower rate of growth than that which has been seen in recent years, as used in the GNDP derivation of its target. The last three years alone have cumulatively seen nearly half as many jobs created than are assumed to be created over the much longer twenty-year period covered by the target.

The NPPF confirms that ”planning policies should…set out a clear economic vision and strategy which positively and proactively encourages sustainable growth, having regard to Local Industrial Strategies and other local policies for economic development and regeneration” (NPPF Paragraph 81a). In the context of economic growth priorities provided by the Cambridge-Norwich Tech Corridor and the importance of the New Anglia Local Enterprise Partnership’s existing Norfolk and Suffolk Economic Strategy (NSES) and the emerging Norfolk and Suffolk Local Industrial Strategy (LIS), it is undoubtedly appropriate for the Draft Plan to target an enhanced level of employment growth than implied by trend-based or ‘off-the-shelf’ forecasts. Given an evolving economic strategy context, the reliance on forecasts presented within a study produced in 2017 creates a concerning risk that the latest understanding of this growth potential is not fully captured. The strength of the local economy in creating new jobs would imply that whilst it represents an ‘enhanced’ outlook of growth it appears unduly modest when compared to this historic success.

We therefore, consider that to support the enhanced levels of economic growth that are evidently capable of being achieved and should be encouraged, the Plan should seek to make further provision for employment opportunities and these should be well located to the economic priority area – most significant the Tech Corridor. Supporting the continued success of Norwich Research Park should also be a key objective and should be promoted through ensuring new homes as well as complementary employment opportunities are made available at SGV.

The SGV proposition includes a ‘Tech Hub’ which has the potential to offer a range of flexible employment land opportunities associated with the key sectors of agri-tech and energy. As such an allocation at SGV would provide a necessary increase in the jobs target for the Plan and this would be supported by an interrelated increase in the number of homes to support these jobs. This is further explained in the ‘Technical Review of Housing Needs in Greater Norwich’ Report by Turley, February 2020, included at Appendix 3 which indicates a minimum of 40,000 jobs should be planned for in the GNLP.

We also note and support the importance of Hethel as a key economic destination in the Tech Corridor. We therefore consider it critical that the current employment uses at Hethel are not compromised through incompatible development and its potential to expand as an employment hub should be safeguarded. This would align well with a strategic Garden Village allocation at SGV.

Comment

Representation ID: 23165

Received: 16/03/2020

Respondent: Pigeon Investment Management Ltd

Agent: Pegasus Group

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 in-commuters 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 resultant environmental 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 in-commuting 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.