Draft Greater Norwich Local Plan – Part 1 The Strategy

Support

Representation ID: 23021

Received: 13/03/2020

Respondent: Bidwells

Support, with comments.
The principle of ensuring that developments are high quality and contribute to delivering inclusive growth in mixed, resilient and sustainable communities, whilst assisting in mitigating and adapting to climate change is supported. To demonstrate the ability to secure these objectives, the preparation of a Sustainability Statement as part of an application for a major development is supported.

Whilst the requirement to ensure the efficient use of land by, amongst other things, providing an indicative minimum density of 25 dwellings per hectare, is supported, the policy, or supporting text, should make it clear that, as well as giving consideration to on site characteristics, consideration will be given to a range of other site / scheme specific issues, such as housing mix, design considerations and the densities of the surrounding area.

Support

Representation ID: 23022

Received: 13/03/2020

Respondent: Bidwells

Support, with comments.
As detailed in relation to Question 18, whilst the requirement to ensure the efficient use of land by, amongst other things, providing an indicative minimum density of 25 dwellings per hectare, is supported, the policy, or supporting text should make it clear that, as well as giving consideration to on site characteristics, consideration will be given to a range of other site / scheme specific issues, such as housing mix, design considerations and the densities of the surrounding area.

Comment

Representation ID: 23023

Received: 13/03/2020

Respondent: Bidwells

Comments
The approach adopted by Anglian Water (zonal charging) in relation to infrastructure provision should be explored to see if it can be applied to other types of strategic infrastructure, such as electricity. Anglian Water provide a set fee per plot in relation to infrastructure costs, with costs being equally applied across a range of developments. This, in the same way as the Community Infrastructure Levy, would provide certainty for developers, particularly in relation to viability.

Support

Representation ID: 23024

Received: 13/03/2020

Respondent: Bidwells

Support, with comments.
The need to support sustainable growth through the provision of infrastructure improvements, such as schools and health centres, is in principle, supported. However, the policy should recognise that infrastructure provision must be proportionate to each development, based on a local need and not undermine delivery.

Support

Representation ID: 23025

Received: 13/03/2020

Respondent: Bidwells

Support, with comments.
Support principle, but notwithstanding Government guidance regarding the need for allocations to demonstrate there is a realistic prospect of being delivered, the policy should, as per the existing policy within the Joint Core Strategy, recognise that there may be a material change in circumstance, that may warrant the submission of a viability assessment.

Support

Representation ID: 23026

Received: 13/03/2020

Respondent: Bidwells

Support, with comments.
Whilst the general principle of providing development that adheres to space standards is supported, the policy should incorporate a degree of flexibility to ensure that consideration is given to site specific issues, as well as need and financial considerations. For example, there may be circumstances where there is a clear need for homes which fall below the space standards. The lack of flexibility within the policy would prevent this need from being satisfied.
In addition, whilst the provision of space standards in relation to internal room size is supported, the Council should not place undue restrictions on developers by enforcing requirements in relation to storage space. Developers ultimately need to have flexibility to react to buyer / market demands whilst operating within an overall minimum space standard regime.

Comment

Representation ID: 23027

Received: 13/03/2020

Respondent: Bidwells

Comments.
The objective of providing self and custom build is generally supported. However, the proposed threshold (5% of plots on residential proposals of 40 dwellings or more) is questioned, given that it would result in the delivery of substantially more self build and custom build units than for which there is an identified need.

The majority of sites that are identified to meet the housing growth targets are likely to be in excess of 40 dwellings. If, as a very broad calculation, the threshold is applied to only the new allocations identified in the draft GNLP (7,840 homes), this would result in the provision of approximately 392 units self and custom build units. This is substantially more than the 113 people on the self and custom build register in the Greater Norwich Area (2018/19). The figure would substantially increase were the threshold applied to existing commitments which are yet to granted planning permission.

In addition, consideration needs to be given to local need within a specific area. For example, on sites in Key Service Centres, such as that covered by Policy GNLP0520, this would result in provision of approximately 10 self and custom build units. This may be substantially more than the local need.

Therefore, the inclusion within the policy that the requirement for self and custom build units will be subject to evidence of need is supported. The policy should, in accordance with the PPG, recognises that as well as the self build / custom build register, additional data from secondary sources should be considered to better understand the demand for self and custom build plots. For example, the demand for self / custom build units may be for stand alone or small development opportunities, not the large estate style developments that would be required to deliver self / custom build units under the policy.

Support

Representation ID: 23028

Received: 13/03/2020

Respondent: Bidwells

Support, with comments
As recognised in Question 1, the overall approach for Key Service Centres is fully supported. The identification of Hingham as a Key Service Centre is fully supportive of the approach for Key Service Centres, as Hingham is a location which has a range of services and amenities to support day to day life, including a primary school, Co-op Food, White Hart Pub, library, a doctor’s surgery, alongside a range of employment uses. Accordingly, the identification of Hingham as a Key Service Centre supports the GNLP’s aspirations of focusing growth in locations with access to jobs and services, whilst supporting a vibrant rural economy.
In addition, the suitability and sustainability of Hingham for growth has been demonstrated through The Hops, a development of 88 dwellings. The Hops, which was allocated under Policy HIN 1 of the Adopted Development Plan, which had a delivery rate of three and a half years (from submission of planning application to completion).
Therefore, we support the identification of a 21% increase in growth for Key Service Centres, which will result in them occupying 8% of total housing growth.

Support

Representation ID: 23030

Received: 13/03/2020

Respondent: Bidwells

Support, with comments
As recognised in Question 1, the overall approach for Key Service Centres is fully supported. The identification of Hingham as a Key Service Centre is fully supportive of the approach for Key Service Centres, as Hingham is a location which has a range of services and amenities to support day to day life, including a primary school, Co-op Food, White Hart Pub, library, a doctor’s surgery, alongside a range of employment uses. Accordingly, the identification of Hingham as a Key Service Centre supports the GNLP’s aspirations of focusing growth in locations with access to jobs and services, whilst supporting a vibrant rural economy.
In addition, the suitability and sustainability of Hingham for growth has been demonstrated through The Hops, a development of 88 dwellings. The Hops, which was allocated under Policy HIN 1 of the Adopted Development Plan, which had a delivery rate of three and a half years (from submission of planning application to completion).
Therefore, we support the identification of a 21% increase in growth for Key Service Centres, which will result in them occupying 8% of total housing growth.

Comment

Representation ID: 23031

Received: 13/03/2020

Respondent: Bidwells

The following comments relate to the Greater Norwich Local Plan, Interim Viability Study, prepared by NPS Group (November, 19).

Whilst there is general support for the approach adopted and the collaborative approach that the GNLP Team are seeking to adopt, there is concern that the assumptions made within the Viability Study in relation to, amongst other things, sales values, build costs and benchmark land values are too generic and not backed up by comparable evidence. Further evidence on this is provided below.

● The assumed land values are too low and not representative of market values. Comparable evidence needs to be provided to justify the figures used.
● The assumption that 54% of dwellings are 3 bedroom is considered high. In addition, the number of 1 bedroom units will vary between Norwich and the market towns, with the latter being lower.
● There appears to be no consideration of demographics. In our view, the identified housing mix should include a significant number of bungalows as the greatest rise within the age groups occurs in the 65 plus band. This will influence build cost, densities and sales values and is fundamental on any strategic site.
● Garages should be added into the build cost calculation.
● No allowance has been made for Abnormals. This should be included or, alternatively, the contingency should be increased accordingly.
● No allowance is made for planning or promotion costs.
● An allowance should be made for Services. These are becoming increasingly expensive particularly given the increased requirements anticipated through the Future Homes Standards Consultation.
● There is a concern that the £5,000 allowance for energy efficiency measures is too low.