Draft Greater Norwich Local Plan – Part 1 The Strategy

Comment

Representation ID: 23190

Received: 16/03/2020

Respondent: Orbit Homes

Agent: Armstrong Rigg Planning

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Policy 1 proposes the following settlement hierarchy:
1. Norwich urban area (Norwich and Norwich Fringe)
2. Main towns (Aylsham, Diss, Harleston, Long Stratton and Wymondham)
3. Key service centres
4. Village clusters
It states that growth is distributed in line with the settlement hierarchy to provide good access to
services, employment and infrastructure through urban and rural regeneration, along with sustainable
urban and village extensions. It focusses most of the housing, employment and infrastructure growth
in the Strategic Growth Area (i.e. Norwich, the A11 corridor and the Growth Triangle), but also allocates
growth to towns and villages to support vibrant rural communities.
Orbit Homes is broadly supportive of the proposed settlement hierarchy, but as set out in the separate
representations prepared by David Lock Associates promoting Silfield Garden Village on behalf of Orbit
Homes and Bowbridge Strategic Land, it considers that Wymondham should be considered above the
other main towns. Wymondham is the second largest settlement in Greater Norwich and is almost twice
the size of the next largest town. There is therefore a good argument for it to be considered above the
other main towns in the hierarchy as a ‘key town’. It is also strategically located in the heart of the
Cambridge to Norwich Tech Corridor and is ideally placed to provide strategic scale growth that is
sustainable and deliverable.
Orbit Homes therefore consider that the settlement hierarchy should be changed as follows:
1. Norwich urban area (Norwich and Norwich Fringe)
2. Key town (Wymondham)
3. Main towns (Aylsham, Diss, Harleston, and Long Stratton and Wymondham)
4. Key service centres
5. Village clusters
In Table 1 below, we provide a comparison of the distribution of existing and proposed growth to
different levels of the hierarchy.

See Attachment for Table 1

Table 1 above demonstrates that, compared to existing commitments, the strategy for new allocations
focusses a significantly higher proportion of growth to the village clusters (increased from 6.5% of
existing commitments to 21.5% of new allocations), broadly similar levels of growth to the main towns
(increased from 14%-16%) and key service centres (decreased from 8 to 6.5%) and a significant
decrease in growth directed to the Norwich urban area (decreased from 71.5% to 56%).
Orbit Homes is aware of Norwich City Council’s objections1 to this change of focus, as it considers
additional growth should be focussed on the city and that this change in strategy goes against the
professed aims of the GNLP’s Climate Change Statement to deliver growth in sustainable locations that
reduce the need to travel. Orbit Homes recognises this argument and notes that there has been no
assessment of the ability of village clusters in South Norfolk to accommodate the high level of growth
proposed. Orbit Homes is however concerned that, due to significant existing commitments, any
significant additional growth in and adjoining the Norwich urban area would suffer from the same
deliverability issues that have plagued the current development plan. To avoid this issue whilst ensuring
development is directed to sustainable locations, Orbit Homes considers that a higher proportion of the
housing requirement should be directed to deliverable sites at the Main Towns.
As set in Orbit Homes’ representations to Policy 7.2, the Main Towns are sustainable locations with
deliverable housing options that could deliver much of the growth needed in Greater Norwich. As set
out under Question 14 below, Orbit Homes considers that the proposed housing requirement should be
significantly increased to account for City Deal growth commitments. In this respect, it would clearly
be inappropriate to allocate the same proportion of growth to village clusters if a higher requirement is
set. A higher proportion of this additional growth will therefore need to be met in settlements further
up the hierarchy, and particularly in the Main Towns, where the resultant strategic levels of growth
would be most sustainably accommodated.

Comment

Representation ID: 23191

Received: 16/03/2020

Respondent: Orbit Homes

Agent: Armstrong Rigg Planning

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

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

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

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

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

• growth strategies for the area that are likely to be deliverable, for example where funding is in place to promote and facilitate additional growth (e.g. Housing Deals);

• strategic infrastructure improvements that are likely to drive an increase in the homes needed locally; or

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

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

requirements of the City Deal have been facilitated in part by the allocation of 3,000 additional homes in the adopted Growth Triangle Area Action Plan (GTAAP), the delivery of these strategic housing sites has been slow. To this end the emerging GNLP offers the opportunity to provide fresh stimulus to achieving the ambitions of the City Deal prior to 2026 to make up for any shortfall in new jobs and housing.

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

One of the options put forward in the previous regulation 18 GNLP consultation in March 2018 was to provide an additional uplift in the housing requirement to take account of the City Deal, but this was discounted as the authorities claimed that the uplift applied by the standard method (i.e. the uplift to account for the affordability of homes that is built into the standard methodology) was sufficient to account for the City Deal uplift required. We disagree with this approach as it fails to reflect the fact that the standard method is a ‘policy off’ calculation of the housing requirement and any adjustments required to due to ‘policy on’ decisions (i.e. to sign a City Deal) should be on top of this.

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

Comments on Housing Requirement

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

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

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

An alternative way of assessing the additional housing required to meet City Deal demand is to look at the SHMA published in April 2017. This document identifies that the jobs growth facilitated by the City Deal would likely result in a demand for approximately 8,361 new homes above and beyond those required as a result of general demographic change over the period until 2036. Even when deducting the 3,000 dwellings planned for in the GTAAP this results in an additional requirement of 5,361 homes (i.e. very similar to the 4,964 additional homes identified by the assessment of shortfall in table 2) that appear not to have been considered when setting the GNLP housing requirement.

On this basis we consider that the housing requirement proposed by the plan falls short of adequately responding to local demand by an approximate 5,000-5,4002 homes. This is before the additional demand generated by the CNTC is taken into account. In which case the absolute minimum housing requirement for the GNLP should be somewhere in the region of 45,500-46,0003 dwellings before any buffer is applied. In which case it is our view that upon the application of the appropriate buffer the GNLP should be planning for somewhere between 48,300 and 50,6004 dwellings as a minimum,

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

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

Support

Representation ID: 23192

Received: 16/03/2020

Respondent: Orbit Homes

Agent: Armstrong Rigg Planning

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Orbit Homes supports the approach to calculating the 5 year housing land supply across the whole of the three districts, but object to the proposal to review the Local Plan 5 years after adoption. The NPPF at paragraph 60 states that “Reviews should be completed no later than five years from the adoption date of a plan”. The wording of this policy therefore clearly needs amending to clarify that the review of the Local Plan needs to be completed within 5 years of adoption, as follows:

This plan will be reviewed The Councils will complete and publish a review of this plan 5 years after adoption to assess whether it needs to be updated.

In light of the above discussion on the Greater Norwich City Deal commitment to deliver 40,000 dwellings by 2026, Orbit Homes also considers that an additional criteria should be added to the policy to require a review of the plan if delivery falls significantly below (e.g. below c.80%) the City Deal housing commitment.

Comment

Representation ID: 23193

Received: 16/03/2020

Respondent: Orbit Homes

Agent: Armstrong Rigg Planning

“Respect, protect and enhance landscape
character…”
There is no requirement in the NPPF for proposals to
protect landscape character. This requirement only
applies to ‘valued landscapes’ (para 170). For other
landscapes there is a requirement recognise (para 170)
and be sympathetic too (para 127) character. To accord
with the NPPF this policy should be revised to read
“Recognise and be sympathetic to landscape character…”

“Housing development will meet the Building Regulations part G (amended 2016) water efficiency higher optional standard;”
“If the potential to set more demanding standards locally is established by the Government up to 2038, the highest potential standard will be applied in
Greater Norwich.”

This policy opts to set the higher optional standard for water efficiency (i.e. 110 l/p/d). This will need to be justified by viability evidence. There is no justification for requiring an unknown potential future government
requirement.

“All new developments will provide a
20% reduction against Part L of the 2013
Building Regulations (amended 2016);”
Orbit Homes recognises that there is a need to move
towards stronger measures to improve energy efficiency.
However, Orbit Homes considers a national and
standardised approach to strengthening requirements to
be the most effective approach that balances
improvements with continued delivery. Prior to the
implementation of the government’s Future Homes
Standard, the Councils must take account of current NPPF
policy that requires any local requirements to reflect
national policy and technical standards.

Support

Representation ID: 23194

Received: 16/03/2020

Respondent: Orbit Homes

Agent: Armstrong Rigg Planning

The policy sets an affordable housing requirement of at least 33% across the plan area and at least 28% in Norwich City Centre (to encourage the development of brownfield sites). Orbit Homes considers this approach to be appropriate, but would recommend that the term “at least” is removed from the policy prior to each percentage requirement. Policies on affordable housing should not seek to establish requirements as minimums. This does not provide the necessary certainty for either the decision maker or applicant as to the required level of provision.

The policy also states that 10% of the affordable homes should be for affordable home ownership. This requirement has been included to accord with NPPF paragraph 64, but is incorrect. NPPF paragraph 64 requires 10% of all the homes on major developments to be for affordable home ownership, not just 10% of the affordable housing contribution. 10% of all homes would equal 30% of the tenure split at 33% affordable housing or 36% of the tenure split at 28% affordable housing. NPPF Paragraph 64 provides two possible exceptions to setting this policy requirement:

• “unless this would exceed the level of affordable housing required in the area, …” – This clearly
wouldn’t apply in Greater Norwich;

• “… or significantly prejudice the ability to meet the identified affordable housing needs of specific groups” – There is clearly a critical need for affordable rented housing in Great Norwich and there may be an argument to provide a lower proportion of affordable home ownership on this basis, but the Greater Norwich authorities would need to provide a detailed evidence to justify this.

NPPF paragraph 64 also includes exemptions from this 10% rule for specific sites/developments for Build to Rent homes, specialist accommodation, self/custom-build homes and 100% affordable housing developments. These are important exemptions and should be included in Policy 5.

Comment

Representation ID: 23195

Received: 16/03/2020

Respondent: Orbit Homes

Agent: Armstrong Rigg Planning

The policy requires all dwellings to meet the nationally described space standards. Orbit Homes

recognises the good intention behind this policy, but is very concerned about its impact on the viability of affordable housing developments. As a Registered Social Landlord (RSL), Orbit Homes has access to Homes England grants to fund the delivery of affordable housing, but these grants are based on a maximum floorspace per size of dwelling (i.e. number of bedrooms) that is approximately 85% of that required to meet the nationally described space standards. Policy 5, as currently worded, would therefore have a significant negative impact on Orbit Homes’ and other RSL’s ability to deliver affordable housing in the area as their funding would not cover the costs of building the larger dwellings. In order to resolve this issue, we recommend that the policy is amended to allow flexibility where the grants available for affordable housing delivery would fail to fully fund the costs of delivering larger dwellings.

Support

Representation ID: 23196

Received: 16/03/2020

Respondent: Orbit Homes

Agent: Armstrong Rigg Planning

Policy 5 requires at least 20% of homes on major developments to be built to M4(2) accessibility standards. Orbit Homes considers this requirement to be reasonable based on the need for such dwellings in the local population.

Comment

Representation ID: 23197

Received: 16/03/2020

Respondent: Orbit Homes

Agent: Armstrong Rigg Planning

Orbit Homes does not object to setting a percentage requirement for self/custom-build dwellings in principle, but consider that any requirement set needs to be sufficiently evidence based. The Councils’ self-build registers should provide a broadly accurate indication of demand for self-build plots (although there may be some duplication with people registering in more than one authority) and also of the type of plots in demand. This data should be used to inform the policy. Paragraph 250 notes that at present there are 113 people on the self-build register for the Greater Norwich Area. Given the number of sites which would be required to meet this policy then it is likely that the number of plots will far exceed demand. We are also aware from other LPA’s self-build registers that the actual demand for self-build plots has been for individual plots in rural locations, as opposed to plots on suburban housing estates. We therefore recommend that in addition to reviewing the percentage requirement, additional flexibility is allowed for the development of self/custom-build dwellings on sites adjoining existing settlements.

Comment

Representation ID: 23198

Received: 16/03/2020

Respondent: Orbit Homes

Agent: Armstrong Rigg Planning

The policy does not contain any guidance on the required housing size mix. We would expect this to be included and Orbit Homes favours a flexible approach in this regard that requires broad accordance with the latest SHMA evidence.

Comment

Representation ID: 23199

Received: 16/03/2020

Respondent: Orbit Homes

Agent: Armstrong Rigg Planning

As set out in Orbit Homes’ representations to Policy 1, the proposed spatial strategy for allocating additional growth in the GNLP focusses a significantly higher proportion of total growth to the proposed village clusters and a lower proportion of growth to the Norwich urban area compared to existing commitments, while the strategy for the Main Towns and Key Services Centres remains broadly similar. In particular, the Main Towns continue to be allocated a comparatively low level of growth. These settlements form the second tier in the settlement hierarchy and are the most sustainable options for growth outside Norwich and yet are allocated just 14.5% of total growth during the plan period. This strategy fails to take full advantage of the potential of these settlements to sustainably grow and meet the housing needs of their catchment areas.

In addition to the current spatial strategy not recognising the potential of the main towns to sustainably accommodate higher levels of growth, Orbit Homes’ representations to Policy 1 also identifies a need to allocate an additional 4,000 to 6,300 dwellings above those currently proposed to be allocated in the GNLP. In order to meet this requirement, it would clearly be unsustainable to allocate additional high levels of growth to smaller rural settlements and Orbit Homes’ are concerned that due to significant existing commitments, any significant additional growth in the urban area may suffer from deliverability issues. We therefore consider that a higher proportion of the increased housing requirement should be directed to deliverable sites in the Main Towns.