Policy 5 Homes
Object
Publication
Representation ID: 24369
Received: 22/03/2021
Respondent: Hopkins Homes
Agent: Bidwells
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
The policy’s objective of providing a full range of types, tenure and costs of housing to meet varied housing needs is, in principle, supported. In addition, the provision of minimum space standards and requirements for adaptable homes to be provided to improve the quality of life and meet the needs of an ageing population is, in principle, also supported. However, whilst we share the GNLP’s desire to provide good quality homes there are a number of elements of the Policy that require alteration to ensure soundness.
Affordable Housing
As drafted the policy states that only applications on brownfield sites will be able to challenge affordable housing provision at the application stage. The policy should, in accordance with paragraph 57 of the NPPF recognise that, notwithstanding work to inform a site allocation in the Local Plan, a viability assessment can be submitted at the application stage. The NPPF advises that the weight afforded to the viability assessment at the application stage will be a matter for the decision maker and will have regard to all circumstances in the case, including whether the evidence underpinning the local plan is up to date and whether there has been a change in circumstances since the plan was brought into force.
On this basis, to ensure the policy is justified and consistent with national policy and, therefore, sound, it is recommended that the wording of the policy is revised to state that regard will be given to viability considerations at the application stage for both brownfield and greenfield sites.
Space Standards
Whilst the intention to adopt the Government’s Nationally Described Space Standard (NDSS) is readily acknowledged, it is essential that the policy explicitly provides the necessary justification, as required by footnote 46 of paragraph 127 NPPF. This clearly states: “Policies may also make use of the nationally described space standard, where the need for internal space standard is justified”.
This justification is essential, as strict adherence to space standards can, in some instances, have a negative impact upon affordability issues and reduce customer choice. For example, in terms of choice some developers will provide entry level two, three and four-bedroom properties which may not meet the optional nationally described space standards, but which would allow those on lower incomes to afford a property which has their required number of bedrooms.
At this stage, notwithstanding the PPG, there would appear to be no robust evidence that would suggest that development below space standards is a particular concern throughout the GNLP area, and that the rigid adherence to NDSS is necessary.
Accordingly, we would suggest that if this element of the policy is to be retained that, as a minimum requirement, the policy should provide some flexibility to recognise need and viability, where necessary.
Self and Custom Build
The provision of self and custom build is recognised. However, the threshold that at least 5% of plots on residential proposals of 40 dwellings or more should provide serviced self/custom-build plots is not considered to be justified.
The threshold would result in the number of self and custom build units provided being substantially in excess of the identified need. As stated at paragraph 282, there are only 113 people on the self and custom build register in the Greater Norwich Area (2018/19). The strategic sites identified on the GNLP i.e. those over 1,000 units, would on their own, deliver substantially more than the identified need.
Whilst it is recognised (and welcomed) that the policy includes wording that provision is not required if there is no need, it is suggested that the threshold is increased to a level which better reflects need.
On this basis, the policy is neither considered to be justified or effective and, therefore, is not sound.
Affordable Housing
The policy should be revised to state that regard will be given to viability considerations at the application stage for both brownfield and greenfield sites.
Space Standards
In the apparent absence of the necessary robust evidence to justify it, the policy should provide some flexibility to recognise need and viability, where necessary.
Self and Custom Build
The threshold should be increased, to better reflect the likely need.
The policy’s objective of providing a full range of types, tenure and costs of housing to meet varied housing needs is, in principle, supported. In addition, the provision of minimum space standards and requirements for adaptable homes to be provided to improve the quality of life and meet the needs of an ageing population is, in principle, also supported. However, whilst we share the GNLP’s desire to provide good quality homes there are a number of elements of the Policy that require alteration to ensure soundness.
Affordable Housing
As drafted the policy states that only applications on brownfield sites will be able to challenge affordable housing provision at the application stage. The policy should, in accordance with paragraph 57 of the NPPF recognise that, notwithstanding work to inform a site allocation in the Local Plan, a viability assessment can be submitted at the application stage. The NPPF advises that the weight afforded to the viability assessment at the application stage will be a matter for the decision maker and will have regard to all circumstances in the case, including whether the evidence underpinning the local plan is up to date and whether there has been a change in circumstances since the plan was brought into force.
On this basis, to ensure the policy is justified and consistent with national policy and, therefore, sound, it is recommended that the wording of the policy is revised to state that regard will be given to viability considerations at the application stage for both brownfield and greenfield sites.
Space Standards
Whilst the intention to adopt the Government’s Nationally Described Space Standard (NDSS) is readily acknowledged, it is essential that the policy explicitly provides the necessary justification, as required by footnote 46 of paragraph 127 NPPF. This clearly states: “Policies may also make use of the nationally described space standard, where the need for internal space standard is justified”.
This justification is essential, as strict adherence to space standards can, in some instances, have a negative impact upon affordability issues and reduce customer choice. For example, in terms of choice some developers will provide entry level two, three and four-bedroom properties which may not meet the optional nationally described space standards, but which would allow those on lower incomes to afford a property which has their required number of bedrooms.
At this stage, notwithstanding the PPG, there would appear to be no robust evidence that would suggest that development below space standards is a particular concern throughout the GNLP area, and that the rigid adherence to NDSS is necessary.
Accordingly, we would suggest that if this element of the policy is to be retained that, as a minimum requirement, the policy should provide some flexibility to recognise need and viability, where necessary.
Self and Custom Build
The provision of self and custom build is recognised. However, the threshold that at least 5% of plots on residential proposals of 40 dwellings or more should provide serviced self/custom-build plots is not considered to be justified.
The threshold would result in the number of self and custom build units provided being substantially in excess of the identified need. As stated at paragraph 282, there are only 113 people on the self and custom build register in the Greater Norwich Area (2018/19). The strategic sites identified on the GNLP i.e. those over 1,000 units, would on their own, deliver substantially more than the identified need.
Whilst it is recognised (and welcomed) that the policy includes wording that provision is not required if there is no need, it is suggested that the threshold is increased to a level which better reflects need.
On this basis, the policy is neither considered to be justified or effective and, therefore, is not sound.
Object
Publication
Representation ID: 24373
Received: 22/03/2021
Respondent: Savills
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
Our previous Regulation 18 representation sought to comment on the sections relation to affordable housing
and purpose-built student accommodation (PBSA). In terms of the first bullet point of this policy, we requested
that the following wording (underlined) should be added:
“at least 33% affordable housing on-site across the plan area, except in Norwich City Centre where the requirement is at least 28%, unless the site is allocated in this plan or a Neighbourhood Plan for a
different percentage of affordable housing, and subject to viability testing in line with the NPPF”
The revised policy has been re-worked and now includes a section (b) relating to brownfield sites and affordable
housing. This states:
“for brownfield sites where the applicant can demonstrate that particular circumstances justify the need
for a viability assessment at decision-making stage;
affordable housing on-site except where exceptional circumstances justify off-site provision;
a mix of affordable housing sizes, types, and tenures in agreement with the local authority, taking
account of the most up-to-date local evidence of housing need. This will include 10% of the
affordable homes being available for affordable home ownership where this meets local needs;
affordable housing of at least equivalent quality to the market homes on-site”
We welcome the inclusion of viability text within the policy, however, would request the below amendment on
the first bullet point to ensure that the viability testing as referred to within the NPPF is appropriately
incorporated into the policy:
“affordable housing on-site except where viability assessments or exceptional circumstances justify offsite provision”;
See attachment for full submission and suggested amendments to the policy.
See attachment for full submission and suggested amendments to the policy.
I trust my letter is clear and helpful, and that the Inspector will take full and proper account of our client’s request and clear objectives. As stressed throughout the letter, a considerable amount of work has already gone into the development of a scheme on this site, and we hope that the Inspector can take the clients requests forward into the assessment of the soundness and legal compliance of the GNLP.
See attachment for full submission.
Object
Publication
Representation ID: 24376
Received: 22/03/2021
Respondent: Berliet Limited
Agent: Quantum Land
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
Policy 5 – Homes –we welcome the acknowledgement that high costs can have an impact on viability, and the adjustment to this Policy at ‘Affordable Housing, 1st bullet, (b)’ for brownfield sites. However, it is our view that this approach should not be restricted solely to brownfield sites. All sites within the Norwich Urban Area and Fringe will by their urban nature be constrained and will face the same challenges as City centre sites, and it is our view that the same flexible approach should be applied to those sites, with the lower 28% threshold being applied. As acknowledged by the proposed amendment to the Policy, this would need to be supported by viability evidence;
See attachment
We would add the following:
i. Policy 5 – Homes –we welcome the acknowledgement that high costs can have an impact on viability, and the adjustment to this Policy at ‘Affordable Housing, 1st bullet, (b)’ for brownfield sites. However, it is our view that this approach should not be restricted solely to brownfield sites. All sites within the Norwich Urban Area and Fringe will by their urban nature be constrained and will face the same challenges as City centre sites, and it is our view that the same flexible approach should be applied to those sites, with the lower 28% threshold being applied. As acknowledged by the proposed amendment to the Policy, this would need to be supported by viability evidence; and
ii. Policy 7.1 – The Norwich Urban Area including the fringe parishes – we continue to object to this policy on the grounds that there are no new allocations, including those proposed at GNLP2170 and GNLP2171, within the Thorpe St Andrew area. These sites were considered to be reasonable alternatives within the HELAA and are sustainable urban previously developed sites. There is no evidence to support the development of these sites as resulting in a loss of playing pitches, and the presence of Ancient Woodland is not considered to be a barrier to their development, rather an asset to be managed and protected within a redevelopment scheme.
Object
Publication
Representation ID: 24384
Received: 22/03/2021
Respondent: Executors of JM Crane Will Trust & Trustees of JM Crane Children's 2001 Settlement
Agent: Savills
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
Affordable Housing
Draft Policy 5 states: “Major residential development proposals and purpose-built student accommodation will provide:
• at least 33% affordable housing on-site across the plan area, except in Norwich City Centre where the requirement is at least 28% …”
This policy wording is not considered to be effective by inclusion of the reference “at least 33% affordable housing”.
In addition the policy wording does not appear to be robustly justified by the support evidence base. It is stated at paragraph 271 that the supporting Strategic Housing Market Assessment 2017 identifies a need for 11,030 affordable homes across Greater Norwich from 2015 to 2038, 28% of the total housing need identified at that point. In addition it is also stated at paragraph 271 that “The most recent viability study findings… conclude… generally able to provide 28% affordable housing”. Whilst it is noted that the Council has updated its Viability Evidence in December 2020 it doesn’t appear to relate to Broadland Village Clusters. In addition I am aware that Broadland Council has been seeking 28% affordable housing in recent S106 agreements based upon the relevant evidence base.
NDSS
The Pre-Submission Plan does not adequately demonstrate that a policy requirement for all new housing residential development comply with the Nationally Described Space Standards (NDSS) is ‘needed’. The fact that some proposals are already providing development which complies with the relevant standards is not sufficient justification. As such, the Plan is not justified, will not be effective, and is not consistent with national policy.
Affordable Housing
It is requested the policy is amended to state: “Major residential development proposals will provide 28% affordable housing on-site across the plan area. The Council will negotiate with developers if an accurate viability assessment indicates that this target cannot be met in full.”
NDSS
Specific reference to compliance with the NDSS should therefore be removed as it is not justified.
Please find enclosed representations made on behalf of landowner ‘Executors of JM Crane Will Trust’ and ‘Trustees of the JM Crane Children’s 2001 Settlement’ in response to the consultation on the draft Greater Norwich Local Plan (Pre-Submission Plan / GNLP) consultation and accompanying evidence base, including in respect of Land to the east of Aylsham Road, Buxton (site ref. GNLP0297).
Object
Publication
Representation ID: 24392
Received: 22/03/2021
Respondent: Hopkins Homes, Persimmon Homes and Taylor Wimpey
Agent: Bidwells
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
The policy’s objective of providing a full range of types, tenure and costs of housing to meet varied housing
needs is, in principle, supported. In addition, the provision of minimum space standards and requirements
for adaptable homes to be provided to improve the quality of life and meet the needs of an ageing
population is also supported.
However, there are a number of elements of the Policy that are not currently sound, as they are not justified
or consistent with national policy.
Affordable Housing
As drafted the policy states that only applications on brownfield sites will be able to challenge affordable
housing provision at the application stage. The policy should, in accordance with paragraph 57 of the NPPF
recognise that, notwithstanding work to inform a site allocation in the Local Plan, a viability assessment
can be submitted at the application stage. The NPPF advises that the weight afforded to the viability
assessment at the application stage will be a matter for the decision maker and will have regard to all
circumstances in the case, including whether the evidence underpinning the local plan is up to date and
whether there has been a change in circumstances since the plan was brought into force.
On this basis, to ensure the policy is justified and consistent with national policy and, therefore, sound, it
is recommended that the wording of the policy is revised to state that regard will be given to viability
considerations at the application stage for both brownfield and greenfield sites.
Space Standards
Whilst the intention to adopt the Government’s Nationally Described Space Standard (NDSS) is readily
acknowledged, it is essential that the policy explicitly provides the necessary justification, as required by
footnote 46 of paragraph 127 NPPF. This clearly states: “Policies may also make use of the nationally
described space standard, where the need for internal space standard is justified”.
This justification is essential, as strict adherence to space standards can, in some instances, have a
negative impact upon affordability issues and reduce customer choice. For example, in terms of choice
some developers will provide entry level two, three and four-bedroom properties which may not meet the
optional nationally described space standards, but which would allow those on lower incomes to afford a
property which has their required number of bedrooms. At this stage, notwithstanding the PPG, there
would appear to be no robust evidence that would suggest that development below space standards is a
particular concern throughout the GNLP area, and that the rigid adherence to NDSS is necessary.
Accordingly, we would suggest that if this element of the policy is to be retained that, as a minimum
requirement, the policy should provide some flexibility to recognise need and viability, where necessary.
Self and Custom Build
The provision of self and custom build is recognised. However, the threshold that at least 5% of plots on
residential proposals of 40 dwellings or more should provide serviced self/custom-build plots is not
considered to be justified.
The threshold would result in the number of self and custom build units provided being substantially in
excess of the identified need. As stated at paragraph 282, there are only 113 people on the self and custom
build register in the Greater Norwich Area (2018/19). The strategic sites identified on the GNLP i.e. those
over 1,000 units, would on their own, deliver substantially more than the identified need.
Whilst it is recognised (and welcomed) that the policy includes wording that provision is not required if
there is no need, it is suggested that the threshold is increased to a level which better reflects need.
Affordable Housing
The policy should be revised to state that regard will be given to viability considerations at the application stage for both brownfield and greenfield sites.
Space Standards
In the apparent absence of the necessary robust evidence to justify it, the policy should provide some flexibility to recognise need and viability, where necessary.
Self and Custom Build
The threshold should be increased, to better reflect the likely need.
Comments on behalf of clients Hopkins Homes, Persimmon Homes, Taylor Wimpey with regard to site GNLP0132 in Sprowston
The policy’s objective of providing a full range of types, tenure and costs of housing to meet varied housing
needs is, in principle, supported. In addition, the provision of minimum space standards and requirements
for adaptable homes to be provided to improve the quality of life and meet the needs of an ageing
population is also supported.
However, there are a number of elements of the Policy that are not currently sound, as they are not justified
or consistent with national policy.
Affordable Housing
As drafted the policy states that only applications on brownfield sites will be able to challenge affordable
housing provision at the application stage. The policy should, in accordance with paragraph 57 of the NPPF
recognise that, notwithstanding work to inform a site allocation in the Local Plan, a viability assessment
can be submitted at the application stage. The NPPF advises that the weight afforded to the viability
assessment at the application stage will be a matter for the decision maker and will have regard to all
circumstances in the case, including whether the evidence underpinning the local plan is up to date and
whether there has been a change in circumstances since the plan was brought into force.
On this basis, to ensure the policy is justified and consistent with national policy and, therefore, sound, it
is recommended that the wording of the policy is revised to state that regard will be given to viability
considerations at the application stage for both brownfield and greenfield sites.
Space Standards
Whilst the intention to adopt the Government’s Nationally Described Space Standard (NDSS) is readily
acknowledged, it is essential that the policy explicitly provides the necessary justification, as required by
footnote 46 of paragraph 127 NPPF. This clearly states: “Policies may also make use of the nationally
described space standard, where the need for internal space standard is justified”.
This justification is essential, as strict adherence to space standards can, in some instances, have a
negative impact upon affordability issues and reduce customer choice. For example, in terms of choice
some developers will provide entry level two, three and four-bedroom properties which may not meet the
optional nationally described space standards, but which would allow those on lower incomes to afford a
property which has their required number of bedrooms. At this stage, notwithstanding the PPG, there
would appear to be no robust evidence that would suggest that development below space standards is a
particular concern throughout the GNLP area, and that the rigid adherence to NDSS is necessary.
Accordingly, we would suggest that if this element of the policy is to be retained that, as a minimum
requirement, the policy should provide some flexibility to recognise need and viability, where necessary.
Self and Custom Build
The provision of self and custom build is recognised. However, the threshold that at least 5% of plots on
residential proposals of 40 dwellings or more should provide serviced self/custom-build plots is not
considered to be justified.
Page 2
The threshold would result in the number of self and custom build units provided being substantially in
excess of the identified need. As stated at paragraph 282, there are only 113 people on the self and custom
build register in the Greater Norwich Area (2018/19). The strategic sites identified on the GNLP i.e. those
over 1,000 units, would on their own, deliver substantially more than the identified need.
Whilst it is recognised (and welcomed) that the policy includes wording that provision is not required if
there is no need, it is suggested that the threshold is increased to a level which better reflects need.
Object
Publication
Representation ID: 24405
Received: 22/03/2021
Respondent: Trustees of Richard Gurney Children's Settlement
Agent: Mrs Nicole Wright
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
Policy 5 has not been positively prepared, is unjustified, ineffective, and inconsistent with national policy as it fails to secure a suitable strategy to deliver high-quality elderly accommodation in sufficient numbers to address an identified need.
Paragraphs 275 to 277 of the GNLP discuss an identified need regarding elderly accommodation (there is discrepancy in the councils figures regarding need with 2842, 3857, and 3909 spaces identified as needed). The GNLP identifies the strategy to address this need through a mix of allocated sites (4 in total, equating to approximately 300 spaces) and the rest of the identified need to be taken up on housing allocations. It is known that having a small proportion of elderly needs units on larger allocations creates a poor quality of life for residents, as they are typically isolated, away from POS and interaction with others. Additionally, such policies have additional viability implications, potentially undermining housing allocations. This is reinforced by the Inspectors report when assessing the Vale of Aylesbury Local Plan Policy H6, summarising that specialist housing for older people cannot be expected on mainstream housing sites and these should be addressed by specific allocations. This is reflected in paragraphs 59 to 61 of the NPPF where a variety of land is needed to come forward to ensure the needs of groups with specific requirements are addressed.
The current plan places a great emphasis on the delivery of elderly accommodation through housing allocations, which is not considered to be an effective or justified strategy, nor a strategy consistent with national policy.
It is considered that to make the plan sound, a significant number of dedicated allocations should be made regarding the provision of elderly accommodation. It is considered that traditional C2 institutions are not the answer, but instead the promotion of ‘care villages’ where semi-independence can be secured for elderly people, with care and welfare available on site as their health deteriorates. Given the substantial need, it is considered that a policy supporting elderly care provision is not sufficient, and that as a strategic priority more dedicated sites should be allocated to provide elderly accommodation.
One potential site that could be allocated to help address the need is the Sprowston Sports and Social Club. The loss of the site would be mitigated through the allocation of a care village, providing necessary social infrastructure. Additionally, with the provision of POS on site, it would benefit the local community whilst encouraging a healthier and active lifestyle for the elderly residents, adhering to the aspirations of the GNLP.
This representation is submitted by Le Ronde Wright on behalf of the Trustees of site at Sprowston Sports and Social Club.
This submission relates to Policy 1, Policy 2 & 3, Policy 5 and paragraphs 275 to 277, and Policy 6. See summaries for detail.
Object
Publication
Representation ID: 24416
Received: 22/03/2021
Respondent: Mr Andrew Cawdron
Legally compliant? No
Sound? No
Duty to co-operate? Not specified
There should be an objective that addresses the ongoing failures to deliver ‘affordable’ housing. The cynical use of value assessments by developers to reduce the numbers of affordable dwellings should be resisted.
A straightforward solution would be to revise the Reg. 19 draft to align with the Reg. 18 proposals for target housing numbers; justify the job numbers target as realistic, remove the NWL from the plan and tighten up the policies and provide targets for the environment and climate change before submission to the Inspector for approval.
THE FOLLOWING IS AN OFFICER-CREATED SUMMARY OF MR CAWDRON’S REPRESENTATION. THE FULL TRANSCRIPTION IS ALSO ATTACHED
The changes between the Reg18C draft plan and the Reg 19 version include a significant increase in housing numbers, which has not been subject to public consultation. Furthermore, the latest Government advice from December 2020 is that the 2017 method of calculating housing requirement would continue, negating the need for the additional housing and buffer. Using the 2017 method, the projected need for 20 years for Greater Norwich is around 40,000 homes, closely aligning with the Reg18C draft plan. The Norwich Wensum Link should not be included as a legal assessment made in 2016, which is still current, found that the integrity of the SAC would be adversely affected and only relatively little weight would be attached to the need to relieve congestion in the Norwich area. The GNLP attempts to distance itself from the HRA obligations connected to the NWL, which is a project which overrides a legal opinion in 2016. There is no mention of the December 2020 Government carbon target emissions reduction of at least 68% by 2030.
To correct these issues, revise the Reg. 19 draft to align with the Reg. 18 proposals for target housing numbers; justify the job numbers target as realistic, remove the NWL from the plan and tighten up the policies and provide targets for the environment and climate change before submission to the Inspector for approval.
Object
Publication
Representation ID: 24429
Received: 22/03/2021
Respondent: Trustees of First Viscount Mackintosh of Halifax and Trustees of CM Watt Residual Trust
Agent: La Ronde Wright
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
It is considered that Policy 5, and the handling of elderly accommodation has not been positively prepared, is unjustified, ineffective, and inconsistent with national policy due to the failure to secure a suitable strategy to deliver quality elderly accommodation in sufficient numbers to address an identified need.
Paragraph 275 of the Strategy states “an increasing proportion of the population is over 65 or disabled, increasing the demand for supported accommodation such as sheltered housing, extra care housing and care homes, residential care and supported living. The local plan seeks to assist County’s aim to reduce residential care home and nursing home dependency and support people to remain more independent in their own homes or in supported housing.” There is an ever expanding need for older persons' accommodation. In fact, we applaud the efforts of the Greater Norwich Local Plan in trying to reduce the reliance in the traditional sense of residential care homes. Many individuals have seen how traumatic it is moving loved relatives in the later years of their life to such institutions which are often unfamiliar surroundings which exacerbate deteriorating health conditions.
Paragraph 276 of the Strategy states that “the policy therefore supports the provision of housing to meet the needs of older people and others with support needs, including sheltered housing, residential/nursing care accommodation and extra care housing. Norfolk County Council strategy identifies the need for 2842 additional extra care units by 2028. County wide evidence has identified the need for 3857 specialist retirement units (sheltered, age restricted or extra care housing) in Greater Norwich between 2020 and 2038.” Both of these figures differ from the stated 3,909 spaces within C2 institutions that the SHMA is expecting to be used. Given the discrepancy in the evidence base, it appears that these statistics are not based off of a robust up-to-date evidence base as required by paragraph 35 of the NPPF and as such, do not constitute a justified or sound approach.
Paragraph 277 of the Strategy states “to help provide for this need, the plan contains a specific allocation for a specialised development for active ageing at Colney Hall on site allocations with an element of specialist housing in the policy (Taverham, Aylsham, Harleston and Barrack Street, Norwich). In addition, policy 5 supports the delivery of older peoples and supported accommodation on housing sites with good access to local services including on sites allocated for residential use. The aim of this is to integrate older people and others with supported housing needs with the wider community, assisting active retirement and community cohesion. Development Management officers will ensure that the need for specialist housing for the elderly and other needs is considered on all housing schemes and advise applicants on the most up to date evidence of need.” As paragraph 276 states that there is a need for 3857 specialist units, as paragraph 277 states, this will be addressed through the provision of four dedicated sites with the shortfall being taken up in allocated residential sites.
Taking the above allocations into consideration, they would cumulatively result in the provision of approximately 300 dedicated elderly accommodation units. This is not a sound or appropriate strategy, nor is it positively prepared as the proposed allocations do not meet the areas need, nor does it meet even 25% of the area's identified need. As such, it is considered this approach is not sound in accordance with paragraph 35 of the NPPF.
As stated within the Inspectors report when assessing the Vale of Aylesbury Local Plan Policy H6, specialist housing for older people cannot be expected on mainstream housing sites and these should be addressed by specific allocations. This view is also echoed in paragraph 61 of the NPPF. Schemes that propose elderly care within larger residential allocations typically provide designated cul-de-sacs or clusters of specialist accommodation that does not help in providing or reinforcing community cohesion. Instead, such schemes promote isolation from the wider locality, as these elements within large residential sites are often inwardly focused with either secluded elements of public open space or a lack of connection to wider provision on site. This undermines the aspirations of delivering a healthy and cohesive community in conflict with the aims of the NPPF ultimately resulting in an unsound strategy in conflict with paragraph 35 of the NPPF.
Overall, the plan fails to secure a suitable strategy to deliver quality elderly accommodation in sufficient numbers to address an identified need and as such has not been positively prepared, is unjustified, ineffective, and is inconsistent with national policy.
Many individuals have seen how traumatic it is moving loved relatives in the later years of their life to C2 institutions which often result in unfamiliar surroundings which can exacerbate deteriorating health conditions. As such, the allocation of more 'Care Village' sites, where residents can age gracefully in the relative comfort of their own homes, whilst having independence, as well as medical and social care on site for when they need it, is a better strategy to address the needs of the aging population in the GNLP area. Additionally, through the allocation of specific additional sites, the significant identified need can be better addressed.
For example, one such site of the many needed is the Racecourse Community Park. this site promotes the concept of creating a care village which residents can move into before the critical stage of later life begins whilst they have full cognitive functions. This would foster community cohesion as well aid in stimulating community activities. There would be great benefit in allocating site GNLP0177-B at the Racecourse Community Park for specialist older persons accommodation and care provision to address the identified need. Through the allocation of Site GNLP0177-B , the Plan would not only better address the identified need for elderly accommodation, but provide a better alternative to C2 institutions and be in keeping with the aims and objectives of the GNLP and wider national strategies and ambitions.
As stated with the various evidence bases, there is a predicted short fall of over 3500 specialist units, if these were not to be provided across the residential allocations within the Greater Norwich Local Plan area. Incorporating so many of these in housing allocations has negative repercussions for future residents. Humans by nature thrive in communities, places where social interaction amongst like-minded and similar aged individuals helps retain and improve cognitive functions. The Racecourse Community Park provides the setting, and aspiration to deliver not only purpose-built homes in a community, but homes that would foster and encourage interactions amongst elderly occupiers and residents, whilst also being able to cater for a large dedicated variety of elderly care needs. Additionally, given the rise in suicide rates for elderly individuals due to depression and isolation it is viewed that providing more specialist accommodation clusters, such as this site in a setting which encourages outdoor social interaction could accommodate and help provide a better quality of life. This would also negate the inevitable token 3 or 4 units that will be sandwiched within large residential allocations in order to be policy compliant. As such, it is viewed that dedicated allocations of designated elderly accommodation is preferable not only for future occupiers, but also for developers aiding viability and ensuring deliverability of the residential allocations.
Policy 5 of the Greater Norwich Local Plan relates to the provision of housing. The policy encompasses all elements of housing including affordable housing, space standards, accessible and specialist housing, gypsy and traveler accommodation, purpose-built student accommodation, and self or custom build housing. Regarding the need for the provision of elderly accommodation, Policy 5 supports the incorporation of specialist accommodation within residential proposals. The Racecourse Community Park would include a significant element of specialist accommodation for the elderly and employment generating uses. The site therefore not only ties in with a wider strategic vision for the greater Norwich area but also adheres to the requirements of policy 5. It is noted that policy 5 will support specialist elderly accommodation where there is good access to local services. As part of the overall proposals for this site it is envisaged that a range of services will be provided that not only cover amenity, encouraging a healthy lifestyle, but also basic services to supplement those offered within both Hethersett and Cringleford. This is reinforced by the proposed Highways England improvement works to the A47/ A11 Thickthorn Junction Improvement scheme and the Parkland Management Plan for the Racecourse Community Park which has identified the need for minor allocations (for employment generating uses in close proximity to the Thickthorn Park & Ride extension and new link road) in support of the long-term ambitions and management strategy for the site.
The GNLP is deficient in housing for the elderly, employment land, and the impact on the environment. See rep summaries for detail.
Object
Publication
Representation ID: 24430
Received: 22/03/2021
Respondent: Trustees of First Viscount Mackintosh of Halifax and Trustees of CM Watt Residual Trust
Agent: La Ronde Wright
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
The Local Plan identifies a significant need regarding the provision of elderly accommodation. Taking the available evidence, (paragraph 276 of the Strategy and the SHMA) this need is identified as between 2842 and 3857 additional specialist retirement units. The local plan identifies 4 sites to accommodate this additional need, however the sites in combination barely provide in excess of 300 units, leaving a potential 3500 units identified as being unmet by the proposed plan. This has further repercussions for neighbouring authorities who may not be able to take the additional need that would be unmet by dedicated allocations. As such, it is considered that draft Policy 5 in regard to elderly accommodation has not been positively prepared. Draft Policy 5 states that any shortfall shall be met through the requirement of making generic housing be accessible and easily adaptable (20% on all major housing developments). Although this is recognised as one potential solution from a housing perspective, adaptable homes do not facilitate medical care or truly enable the occupiers to remain in perpetuity. When occupiers require a few hours a week of care, this will have to be readily available and will likely result in the need for occupiers to vacate their homes for residential institutions causing much distress and at greater cost. The most efficient and viable from a national perspective, is to provide sites that cater specifically for the needs of older people where care is available 24/7 as needed and medical services can be provided to multiple residents in one trip. Such facilities that are age restricted also allow occupiers to enter before their needs are urgent, allowing them to become more accustomed to their surroundings and generally aid their declining years in comfort, knowing whatever happens they will be looked after. As such, the proposed solution of making multiple small pockets of isolated elderly communities is not considered to be justified as an appropriate strategy. Furthermore, this approach of not addressing and catering for elderly need, rather leaving it to chance for being delivered as part of larger residential schemes is not considered to be consistent with paragraph 61 of the NPPF or in accordance with Inspectors rulings regarding other Local Plan adoption processes (see Aylesbury Vale District Council, Vale of Aylesbury Local Plan Policy H6 (C2) Process Note, July 2019, pp 1-5.). A copy id annexed to this submission.
Regarding making the plan sound, it is viewed necessary that new sites be considered for allocation that provide dedicated elderly care facilities in meaningful numbers, to foster new elderly communities in sustainable locations and settings conducive to promoting active living as much as possible. It is considered essential that such facilities do not replicate old care-home institutions, but are more akin to the 'care village model', where independence is guaranteed through individual and self-contained accommodation, and both medical and social care are available on site around the clock. This reduces the need for turbulent evictions of those too old or ill to look after themselves and allows residents to retain an active lifestyle through available community facilities and open space in close proximity. Furthermore, through creating safe environments for residents, active social lives can be encouraged, where public open space is provided in abundance for all. This comes without the necessary maintenance issues that would deter older people from utilising private outdoor amenity space such as private gardens in their later years. Through the allocation of specific sites, the identified need is addressed more comprehensively, and this not only satisfies paragraph 61 of the NPPF but accommodates the vision outlined in the Strategy for promoting healthy vibrant lifestyles for communities.
The GNLP is deficient in housing for the elderly, employment land, and the impact on the environment. See rep summaries for detail.
Object
Publication
Representation ID: 24442
Received: 22/04/2021
Respondent: Trustees of First Viscount Mackintosh of Halifax and Trustees of CM Watt Residual Trust
Agent: La Ronde Wright
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
The Local Plan identifies a significant need regarding the provision of elderly accommodation. Taking the available evidence, (paragraph 276 of the Strategy and the SHMA) this need is identified as between 2842 and 3857 additional specialist retirement units. The local plan identifies 4 sites to accommodate this additional need, however the sites in combination barely provide in excess of 300 units, leaving a potential 3500 units identified as being unmet by the proposed plan. This has further repercussions for neighbouring authorities who may not be able to take the additional need that would be unmet by dedicated allocations. As such, it is considered that draft Policy 5 in regard to elderly accommodation has not been positively prepared. Draft Policy 5 states that any shortfall shall be met through the requirement of making generic housing be accessible and easily adaptable (20% on all major housing developments). Although this is recognised as one potential solution from a housing perspective, adaptable homes do not facilitate medical care or truly enable the occupiers to remain in perpetuity. When occupiers require a few hours a week of care, this will have to be readily available and will likely result in the need for occupiers to vacate their homes for residential institutions causing much distress and at greater cost. The most efficient and viable from a national perspective, is to provide sites that cater specifically for the needs of older people where care is available 24/7 as needed and medical services can be provided to multiple residents in one trip. Such facilities that are age restricted also allow occupiers to enter before their needs are urgent, allowing them to become more accustomed to their surroundings and generally aid their declining years in comfort, knowing whatever happens they will be looked after. As such, the proposed solution of making multiple small pockets of isolated elderly communities is not considered to be justified as an appropriate strategy. Furthermore, this approach of not addressing and catering for elderly need, rather leaving it to chance for being delivered as part of larger residential schemes is not considered to be consistent with paragraph 61 of the NPPF or in accordance with Inspectors rulings regarding other Local Plan adoption processes (see Aylesbury Vale District Council, Vale of Aylesbury Local Plan Policy H6 (C2) Process Note, July 2019, pp 1-5.). A copy id annexed to this submission.
Regarding making the plan sound, it is viewed necessary that new sites be considered for allocation that provide dedicated elderly care facilities in meaningful numbers, to foster new elderly communities in sustainable locations and settings conducive to promoting active living as much as possible. It is considered essential that such facilities do not replicate old care-home institutions, but are more akin to the 'care village model', where independence is guaranteed through individual and self-contained accommodation, and both medical and social care are available on site around the clock. This reduces the need for turbulent evictions of those too old or ill to look after themselves and allows residents to retain an active lifestyle through available community facilities and open space in close proximity. Furthermore, through creating safe environments for residents, active social lives can be encouraged, where public open space is provided in abundance for all. This comes without the necessary maintenance issues that would deter older people from utilising private outdoor amenity space such as private gardens in their later years. Through the allocation of specific sites, the identified need is addressed more comprehensively, and this not only satisfies paragraph 61 of the NPPF but accommodates the vision outlined in the Strategy for promoting healthy vibrant lifestyles for communities.
Please find attached representations in relation to the GNLP Regulation 19 consultation with regard to site GNLP0177-B. These representations are submitted by Le Ronde Wright Limited on behalf of the Trustees of the site.
This representation relates to Policy 3, 5, 6 and the SA. For more details please view the summaries.
Object
Publication
Representation ID: 24443
Received: 22/04/2021
Respondent: Trustees of First Viscount Mackintosh of Halifax and Trustees of CM Watt Residual Trust
Agent: La Ronde Wright
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
It is considered that Policy 5, and the handling of elderly accommodation has not been positively prepared, is unjustified, ineffective, and inconsistent with national policy due to the failure to secure a suitable strategy to deliver quality elderly accommodation in sufficient numbers to address an identified need.
Paragraph 275 of the Strategy states “an increasing proportion of the population is over 65 or disabled, increasing the demand for supported accommodation such as sheltered housing, extra care housing and care homes, residential care and supported living. The local plan seeks to assist County’s aim to reduce residential care home and nursing home dependency and support people to remain more independent in their own homes or in supported housing.” There is an ever expanding need for older persons' accommodation. In fact, we applaud the efforts of the Greater Norwich Local Plan in trying to reduce the reliance in the traditional sense of residential care homes. Many individuals have seen how traumatic it is moving loved relatives in the later years of their life to such institutions which are often unfamiliar surroundings which exacerbate deteriorating health conditions.
Paragraph 276 of the Strategy states that “the policy therefore supports the provision of housing to meet the needs of older people and others with support needs, including sheltered housing, residential/nursing care accommodation and extra care housing. Norfolk County Council strategy identifies the need for 2842 additional extra care units by 2028. County wide evidence has identified the need for 3857 specialist retirement units (sheltered, age restricted or extra care housing) in Greater Norwich between 2020 and 2038.” Both of these figures differ from the stated 3,909 spaces within C2 institutions that the SHMA is expecting to be used. Given the discrepancy in the evidence base, it appears that these statistics are not based off of a robust up-to-date evidence base as required by paragraph 35 of the NPPF and as such, do not constitute a justified or sound approach.
Paragraph 277 of the Strategy states “to help provide for this need, the plan contains a specific allocation for a specialised development for active ageing at Colney Hall on site allocations with an element of specialist housing in the policy (Taverham, Aylsham, Harleston and Barrack Street, Norwich). In addition, policy 5 supports the delivery of older peoples and supported accommodation on housing sites with good access to local services including on sites allocated for residential use. The aim of this is to integrate older people and others with supported housing needs with the wider community, assisting active retirement and community cohesion. Development Management officers will ensure that the need for specialist housing for the elderly and other needs is considered on all housing schemes and advise applicants on the most up to date evidence of need.” As paragraph 276 states that there is a need for 3857 specialist units, as paragraph 277 states, this will be addressed through the provision of four dedicated sites with the shortfall being taken up in allocated residential sites.
Taking the above allocations into consideration, they would cumulatively result in the provision of approximately 300 dedicated elderly accommodation units. This is not a sound or appropriate strategy, nor is it positively prepared as the proposed allocations do not meet the areas need, nor does it meet even 25% of the area's identified need. As such, it is considered this approach is not sound in accordance with paragraph 35 of the NPPF.
As stated within the Inspectors report when assessing the Vale of Aylesbury Local Plan Policy H6, specialist housing for older people cannot be expected on mainstream housing sites and these should be addressed by specific allocations. This view is also echoed in paragraph 61 of the NPPF. Schemes that propose elderly care within larger residential allocations typically provide designated cul-de-sacs or clusters of specialist accommodation that does not help in providing or reinforcing community cohesion. Instead, such schemes promote isolation from the wider locality, as these elements within large residential sites are often inwardly focused with either secluded elements of public open space or a lack of connection to wider provision on site. This undermines the aspirations of delivering a healthy and cohesive community in conflict with the aims of the NPPF ultimately resulting in an unsound strategy in conflict with paragraph 35 of the NPPF.
Overall the plan fails to secure a suitable strategy to deliver quality elderly accommodation in sufficient numbers to address an identified need and as such has not been positively prepared, is unjustified, ineffective and is inconsistent with national policy.
Many individuals have seen how traumatic it is moving loved relatives in the later years of their life to C2 institutions which often result in unfamiliar surroundings which can exacerbate deteriorating health conditions. As such, the allocation of more 'Care Village' sites, where residents can age gracefully in the relative comfort of their own homes, whilst having independence, as well as medical and social care on site for when they need it, is a better strategy to address the needs of the aging population in the GNLP area. Additionally, through the allocation of specific additional sites, the significant identified need can be better addressed.
For example, one such site of the many needed is the Racecourse Community Park. this site promotes the concept of creating a care village which residents can move into before the critical stage of later life begins whilst they have full cognitive functions. This would foster community cohesion as well aid in stimulating community activities. There would be great benefit in allocating site GNLP0177-B at the Racecourse Community Park for specialist older persons accommodation and care provision to address the identified need. Through the allocation of Site GNLP0177-B , the Plan would not only better address the identified need for elderly accommodation, but provide a better alternative to C2 institutions and be in keeping with the aims and objectives of the GNLP and wider national strategies and ambitions.
As stated with the various evidence bases, there is a predicted short fall of over 3500 specialist units, if these were not to be provided across the residential allocations within the Greater Norwich Local Plan area. Incorporating so many of these in housing allocations has negative repercussions for future residents. Humans by nature thrive in communities, places where social interaction amongst like-minded and similar aged individuals helps retain and improve cognitive functions. The Racecourse Community Park provides the setting, and aspiration to deliver not only purpose-built homes in a community, but homes that would foster and encourage interactions amongst elderly occupiers and residents, whilst also being able to cater for a large dedicated variety of elderly care needs. Additionally, given the rise in suicide rates for elderly individuals due to depression and isolation it is viewed that providing more specialist accommodation clusters, such as this site in a setting which encourages outdoor social interaction could accommodate and help provide a better quality of life. This would also negate the inevitable token 3 or 4 units that will be sandwiched within large residential allocations in order to be policy compliant. As such, it is viewed that dedicated allocations of designated elderly accommodation is preferable not only for future occupiers, but also for developers aiding viability and ensuring deliverability of the residential allocations.
Policy 5 of the Greater Norwich Local Plan relates to the provision of housing. The policy encompasses all elements of housing including affordable housing, space standards, accessible and specialist housing, gypsy and traveler accommodation, purpose-built student accommodation, and self or custom build housing. Regarding the need for the provision of elderly accommodation, Policy 5 supports the incorporation of specialist accommodation within residential proposals. The Racecourse Community Park would include a significant element of specialist accommodation for the elderly and employment generating uses. The site therefore not only ties in with a wider strategic vision for the greater Norwich area but also adheres to the requirements of policy 5. It is noted that policy 5 will support specialist elderly accommodation where there is good access to local services. As part of the overall proposals for this site it is envisaged that a range of services will be provided that not only cover amenity, encouraging a healthy lifestyle, but also basic services to supplement those offered within both Hethersett and Cringleford. This is reinforced by the proposed Highways England improvement works to the A47/ A11 Thickthorn Junction Improvement scheme and the Parkland Management Plan for the Racecourse Community Park which has identified the need for minor allocations (for employment generating uses in close proximity to the Thickthorn Park & Ride extension and new link road) in support of the long-term ambitions and management strategy for the site.
Please find attached representations in relation to the GNLP Regulation 19 consultation with regard to site GNLP0177-B. These representations are submitted by Le Ronde Wright Limited on behalf of the Trustees of the site.
This representation relates to Policy 3, 5, 6 and the SA. For more details please view the summaries.
Object
Publication
Representation ID: 24457
Received: 22/03/2021
Respondent: Orbit Homes
Agent: David Lock Associates
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
GNLP evidence base does not include any housing needs assessment, or equivalent, nor is there any record of the self-build and custom housebuilding register for the GNLP area to align the 5% requirement with the underlying demand evidence.
SEE FULL REP ATTACHED
Include housing needs assessment and register for self build housing. Amend viability assessment to take account of 5% policy requirement for self build. SEE FULL REP ATTACHED.
Representation on behalf of Orbit Homes, J Alston and Sons and Pelham Homes in relation to Silfield Garden Village.
The team led by Orbit Homes are generally supportive of the GNLP (Pre-submission) as currently drafted but consider that some aspects of the Pre-submission GNLP would benefit from amendment and/or further detail to ensure the GNLP meets the soundness test as set out at paragraph 35 of the NPPF. Please see the enclosed representation submission for details.
Object
Publication
Representation ID: 24480
Received: 22/03/2021
Respondent: Silvis Development
Agent: La Ronde Wright
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
Policy 5 states that at least 5% of plots on residential proposals of 40 dwellings or more should provide serviced self/custom build plots. It is considered that this policy is not effective to ensure the delivery of self or custom build dwellings.
Speaking from a practical point of view, the attraction of custom and self-build dwellings lies in the flexibility of the design and layout. Given the size of the proposed allocations within the GNLP, it is fair to assume that volume house builders will be delivering the majority of sites, this means in reality that economies of scale will be used to produce standardised dwellings, where bespoke units will appear incongruous. Additionally, incorporating a small proportion of self or custom build dwellings within such schemes are unlikely to attract the individuals looking for purpose built bespoke homes. As such, the strategy is considered to be unjustified as the plan does not respond to the evidence that custom builders prefer development on smaller, more rural sites, not within large housing allocations.
The policy states that 5% of plots on residential proposals of 40 dwellings or more should provide serviced self/custom-build plots unless there is no need, or plots have been marketed for 12 months and have not been sold. Given that these plots will be unattractive to self builders, it is likely any need will not be met by this policy as vacant plots will eventually be re-developed when final phases of large allocations are completed. Additionally, logistical complexities of delivering sites with multiple contractors simultaneously will further reduce the attraction for smaller self-builders.
This means that there are questions regarding the deliverability of the policy over the plan period given that an inadequate strategy has been provided that is not positively prepared. This is because the policy is not providing enough flexibility and choice to address the areas objectively assessed need, and will fail to secure delivery of a mix of sites to enable choice for self-builders. As such the policy is found to be ineffective, not positively prepared, and unjustified in conflict with paragraph 35 of the NPPF.
To make the policy and plan sound, it is considered that a more flexible policy be proposed. Policies HOU03 and HOU05 of the Breckland Local Plan (see Annex 1) facilitate a more flexible approach that directly responds to the needs of custom/self-builders. These policies recognise the principle aspirations of self-builders and sets a favourable framework for approving self-build dwellings in small villages and hamlets outside of settlement boundaries. This is done by allowing for development in more rural locations and actively encouraging smaller sites, which are more likely to be delivered through a windfall style policy, than tying self-build plots in large housing allocations. It is considered that given the overall need for the joint authorities, that a mix of dedicated allocations in more rural locations be provided, alongside a policy that actively supports small scale self-build and custom build plots on land that relates well to existing settlements.
Policy 5 states that at least 5% of plots on residential proposals of 40 dwellings or more should provide serviced self/custom build plots. It is considered that this policy is not effective to ensure the delivery of self or custom build dwellings.
Speaking from a practical point of view, the attraction of custom and self-build dwellings lies in the flexibility of the design and layout. Given the size of the proposed allocations within the GNLP, it is fair to assume that volume house builders will be delivering the majority of sites, this means in reality that economies of scale will be used to produce standardised dwellings, where bespoke units will appear incongruous. Additionally, incorporating a small proportion of self or custom build dwellings within such schemes are unlikely to attract the individuals looking for purpose built bespoke homes. As such, the strategy is considered to be unjustified as the plan does not respond to the evidence that custom builders prefer development on smaller, more rural sites, not within large housing allocations.
The policy states that 5% of plots on residential proposals of 40 dwellings or more should provide serviced self/custom-build plots unless there is no need, or plots have been marketed for 12 months and have not been sold. Given that these plots will be unattractive to self builders, it is likely any need will not be met by this policy as vacant plots will eventually be re-developed when final phases of large allocations are completed. Additionally, logistical complexities of delivering sites with multiple contractors simultaneously will further reduce the attraction for smaller self-builders.
This means that there are questions regarding the deliverability of the policy over the plan period given that an inadequate strategy has been provided that is not positively prepared. This is because the policy is not providing enough flexibility and choice to address the areas objectively assessed need, and will fail to secure delivery of a mix of sites to enable choice for self-builders. As such the policy is found to be ineffective, not positively prepared, and unjustified in conflict with paragraph 35 of the NPPF.
Object
Publication
Representation ID: 24512
Received: 22/03/2021
Respondent: Executors of JM Crane Will Trust & Trustees of JM Crane Children's 2001 Settlement
Agent: Savills
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
Affordable Housing
Draft Policy 5 states: “Major residential development proposals and purpose-built student accommodation will provide:
• at least 33% affordable housing on-site across the plan area, except in Norwich City Centre where the requirement is at least 28% …”
This policy wording is not considered to be effective by inclusion of the reference “at least 33% affordable housing”.
In addition the policy wording does not appear to be robustly justified by the support evidence base. It is stated at paragraph 271 that the supporting Strategic Housing Market Assessment 2017 identifies a need for 11,030 affordable homes across Greater Norwich from 2015 to 2038, 28% of the total housing need identified at that point. In addition it is also stated at paragraph 271 that “The most recent viability study findings… conclude… generally able to provide 28% affordable housing”. Whilst it is noted that the Council has updated its Viability Evidence in December 2020 it doesn’t appear to relate to Broadland Village Clusters. In addition I am aware that Broadland Council has been seeking 28% affordable housing in recent S106 agreements based upon the relevant evidence base.
NDSS
The Pre-Submission Plan does not adequately demonstrate that a policy requirement for all new housing residential development comply with the Nationally Described Space Standards (NDSS) is ‘needed’. The fact that some proposals are already providing development which complies with the relevant standards is not sufficient justification. As such, the Plan is not justified, will not be effective, and is not consistent with national policy.
Affordable Housing
It is requested the policy is amended to state: “Major residential development proposals will provide 28% affordable housing on-site across the plan area. The Council will negotiate with developers if an accurate viability assessment indicates that this target cannot be met in full.”
NDSS
Specific reference to compliance with the NDSS should therefore be removed as it is not justified.
Please find enclosed representations made on behalf of landowner ‘Executors of JM Crane Will Trust’ and ‘Trustees of the JM Crane Children’s 2001 Settlement’ in response to the consultation on the draft Greater Norwich Local Plan (Pre-Submission Plan / GNLP) consultation and accompanying evidence base, including in respect of Land to the east of Aylsham Road, Buxton (site ref. GNLP0297).
Object
Publication
Representation ID: 24537
Received: 19/03/2021
Respondent: Mr Bryan Robinson
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
Affordable Housing
10.1. Policy 516 appears to restrict the use of Viability Assessments (VA)s in planning applications with the intention of reducing the percentage of Affordable Housing to Brownfield sites.
10.2. Whilst this is welcome to counter the misuse VAs which has almost become almost standard practice, Section 57 of NPPF states that it is up to the applicant to
demonstrate whether particular circumstances justify the need for a VA and therefore the legality of this Policy needs to be considered.
10.3. Does this Policy restricting the use of VAs to brownfield sites create a conflict with
the NPPF?
10.4. Policy 5 also differentiates sites allocated within Neighbourhood Plans proposing that a different percentage of affordable housing can be stated therein, overridingthe minimum of 33% across the plan area.
10.5. The Affordable Housing Need is stated at paragraph 271 of Reg. 19 v 1.7 as 11,030 between 2015 and 2036 being 28% of the overall housing need as established in the 2017 SHMA Report.
10.6. The Housing Need has since been recalculated as 40,541 but the number of affordable housing has not been reassessed over the revised timescales.
10.7. Assuming the affordable housing percentages will apply to the 22% buffer of allocations above the defined overall housing need, basic mathematics
determines that the number of affordable housing units will exceed the need by 2,427 if all the sites are developed over the period.
10.8. Affordable Housing provision on a site is a contributor to establishing profitability for the developer and therefore may inhibit development if there is an
overprovision, continuing to the circularity of controlling the supply of all housing.
10.9. The Plan does not indicate the reduced number of affordable homes are already in the system through the reductions in Neighbourhood plans and committed
sites with approved lower percentages of affordable housing.
10.10. All this data should be readily available to the GNDP and the plan should show the numbers of affordable houses which will be provided against this policy for meeting the overall housing need target and how this will be managed in scenarios where the overall need is not being met and if annual completions are
nearer to the target including the 22% buffer.
10.11. Without this study comparing potential extra affordable homes if the buffer is built out and reductions from Neighbourhood plans and lower approved numbers
in existing commitments the policy on affordable homes is meaningless.
1. Introduction
1.1. Comments have been invited under Reg. 19 of the Town and Country Planning Act(Local Planning) (England) Regulations 2012 on the soundness of the draft Greater Norwich Local Plan (GNLP) prior to submission to the Planning Inspectorate.
1.2. Soundness is defined as:
1.2.1. Positively prepared: The plan should be based on a strategy which seeks to meet objectively assessed development and infrastructure requirements, including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent which achieving sustainable development.
1.2.2. Justified: The plan should be the most appropriate strategy when considered against the reasonable alternatives, based on proportionate evidence.
1.2.3. Effective: The plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities.
1.2.4. Consistent with national policy: The plan should enable the delivery of sustainable development in accordance with the policies in the National Policy Framework.
1.3. There are several reasons why I consider the Draft Plan in Reg. 19 is unsound but initially question the legitimacy of the changes in the Reg. 19 draft which fundamentally change the principles of the Reg. 18 consultation and on which the public are being denied representation which is patently unfair.
2. Fairness
2.1. It is trite law that a public body must adopt a fair procedure to decision-making to ensure that members of the public are given a fair and informed say before the decision comes into effect.
2.2. The draft Reg. 19 v 1.7 documents have significantly increased by 15% the housing provision over the life of the plan above the proposals in the Reg. 18 consultations initially citing Government proposals in the ‘Planning for the future’ consultation but later changing this to the fact that the 2018-based Government projections for Greater Norwich are higher than the 2014-based projections, as justification for going back on the intention for a further stage 18D consultation.
2.3. This approach of planning for the higher numbers in the 2018-based projections goes against the Government statement that the 2014-based projections should continue to be used in Local Plans.
For full representation view attachment.
Object
Publication
Representation ID: 24545
Received: 22/03/2021
Respondent: Gladman Developments
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
See attachment for full representation
Policy 5 – Homes
Affordable Housing
4.4.1 Policy 5 sets out that major residential development proposals of ten dwellings or more will provide at least 33% affordable housing on-site across the plan area except in Norwich City Centre where the requirement is at least 28%. Gladman supports the principle of improving
affordability across Greater Norwich and the need to identify an appropriate affordable housing target for differing built environments that reflects the local circumstances.
4.4.2 Notwithstanding the above support, the Councils will need to be able to demonstrate through clear, robust, up-to-date viability assessment that the provision of affordable housing in line with the proposed policy is viable on the majority of schemes.
4.4.3 Gladman supports the element of flexibility within the draft policy allowing viability assessments to be submitted in respect of brownfield sites in particular circumstances. To confirm, the sites which are being promoted by Gladman for inclusion within the plan can all
provide a policy compliant level of affordable housing, if not greater for example Poringland offers 36% affordable housing.
Accessible and Specialist Housing
4.4.4 The policy states that development proposals providing specialist housing options for older people’s accommodation and others with support needs, including sheltered housing, supported housing, extra care housing and residential/nursing care homes will be supported
on sites with good access to local services including on sites allocated for residential use.
4.4.5 Gladman is supportive of this policy approach as the provision of specialist housing to meet
the needs of older people is of increasing importance.
4.4.6 Specialist housing with care for older people is a type of housing which provides choice to adults with varying care needs and enables them to live as independently as possible in their own self-contained homes, where people are able to access high quality, flexible support and care services on site to suit their individual needs (including dementia care). Such schemes differ from traditional sheltered/retirement accommodation schemes and should provide
internally accessible communal facilities including a residents’ lounge, library, dining room,
guest suite, quiet lounge, IT suite, assisted bathroom, internal buggy store and changing facilities, reception and care manager’s office and staff facilities.
Self/Custom Build
4.4.7 The policy states that with the exception of flats, at least 5% of plots on residential proposals of 40 dwellings or more should provide serviced self/custom-build plots unless a lack of need can be demonstrated or plots have been marketed for 12 months and have not been sold.
4.4.8 Gladman objects to the inclusion of a fixed percentage requirement in relation to the provision
of serviced self-build plots.
4.4.9 Whilst recognising the role attributed towards self-build in national planning policy as a source of housing land supply, we do not consider the inclusion of a requirement for all housing schemes over 40 dwellings to commit to onsite provision forms the most effective
approach of responding to this source of housing need.
4.4.10 Gladman believes that those wishing to bring forward a self-build or custom build house are unlikely to wish to do this alongside a large-scale housing development. Consequently, rather than including a strict requirement for this provision Gladman would recommend the policy encourages the consideration of the provision of self-build plots in locations where the
demand exists.
4.4.11 Gladman would prefer to see policy which seeks self-build plots being considered on an ad hoc basis as windfall rather than as a percentage requirement of larger development schemes. We consider this approach to be more in line with the wants and needs for the individuals
seeking the plot and the developer’s requirements for larger sites.
4.4.12 Should a percentage approach be taken forward, the requirement should be supported by clear and robust evidence of this source of housing need. Gladman recommends that any policy requirement in relation to self-build housing has an element of flexibility built in to
allow for negotiation over self-build plots on the basis of viability to ensure that site delivery is not delayed or prevented from coming forward. Any specific requirement to include selfbuild plots should be tested through the Council’s viability assessment of the Local Plan
policies to ensure that the cumulative impacts of all proposed local standards and policy
requirements do not put the implementation of the Plan as a whole at risk.
4.4.13 Gladman notes that the proposed policy does include a mechanism which allows developers the opportunity after 12 months to either continue to market the plots for self-build or to revert back to them being delivered as part of the wider market housing scheme. Gladman supports the inclusion of this policy mechanism as it is necessary to ensure that housing land
is not unnecessarily prevented from being brought forward. This helps to provide flexibility and helps to ensure that the required housing is delivered. If there is genuine demand for selfbuild housing it is likely that these plots would be brought forward relatively quickly
See attachment for full representation (Section 4.4)
Please find attached the representations of Gladman in response to the Reg 19 Pre-submission Draft consultation.