Draft Greater Norwich Local Plan – Part 1 The Strategy

Comment

Representation ID: 22701

Received: 16/03/2020

Respondent: Strutt & Parker LLP

[On behalf of Scott Properties Ltd]
37. The Draft Strategy acknowledges at paragraph 245 that an increasing proportion of the population is over 65 or suffers from a disabilty which affects daily activities, increasing the demand for supported accommodation, including care accommodation. The Central Norfolk Strategic Housing Market Assessment 2017 identifies a growth of 3,909 people in care homes for the period 2015 to 2036. It points out that if these bed spaces are not provided, older people will not vacate dwellings and therefore the Local Plan will need to deliver a proportionate increase in housing numbers.
38. The Plan seeks to assist Norfolk County Council’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’.
39. This approach is supported in both National Policy and Planning Practice Guidance (PPG). In particular the ‘Housing for Older and Disabled People’ PPG, which requires Plan-makers to consider the diverse needs of older people, including those approaching retirement. The PPG also states that 'Plan-making authorities should set clear policies to address the housing needs of groups with particular needs such as older and disabled people' (Paragraph: 006 Reference ID: 63-006-20190626). The Draft Strategy’s recognition of the need to provide suitable homes in the right locations is supported. A lack of availability of suitable accommodation forces people to move away from friends and family to find a property more suited to their needs, or, to make costly adaptions to their own homes.
40. In order to ensure an adequate provision of specialist housing, Scott Properties believes that Policy 5 – Homes should encourage a range of properties to suit a variety of needs, and specific allocations or requirements within site specific policies should be made for specialist housing, including care homes. Allocations such as Land at Briar Farm, Harleston which will provide opportunities for specialist housing and care facilities should be encouraged. This will ensure that a varied range of accommodation can come forward to meet the diverse needs of older people as set out in PPG and provide choice for those in later life, which can include:
- Age-restricted general market housing;
- Retirement living or sheltered housing;
- Extra care housing or housing-with-care; and
- Residential Care Homes
41. To ensure a variety of the housing, as identified within PPG above is delivered within Greater Norwich, the Plan should make specific allocations as opposed to just a generic housing mix policy that requires a diverse mix of housing. General housebuilders do not build specialist housing, and by providing housing that is deemed as suitable for older people that is also available to the general housing market does not adddress the varied and diverse needs of older people, or those with a disability.
42. We would draw attention to the recent interim findings of the Inspector following the examination of the Suffolk Coastal Local Plan, which states:
'The Plan as submitted seeks to address the needs of older people through Policy SCLP5.8 Housing Mix. The Policy however, whilst supporting the provision of housing for older people, does not address clearly the significant need identified and would not be effective in delivering the market or affordable housing units for older people required. The Policy and supporting text should be amended to set out how the housing needs of older people will be addressed through the provision of housing and to boost the supply of this type of housing.'
43. We would therefore encourage the Council to consider the merits of allocating specific sites for specialist accommodation within the Greater Norwich Local Plan. It is vitally important that suitable housing is provided to meet the needs of an ageing population.
44. The inclusion of a site for a 90 bed C3 care block will ensure that there is accommodation to meet the needs of an ageing population at a local level. Additional specialist accommodation for older people (circa 30 units) is also proposed as part of the area highlighted for “Care” use on the Masterplan. Furthermore, it is proposed that approximately 20% of the dwellings comprise single storey properties suitable for those older members of the community as well as those with or supporting someone with a disability are also proposed at Briar Farm, Harleston. These combined measures will enable people to downsize while remaining in the local area and close to friends, family, and local support networks. By providing this type of accommodation on an edge of town location, it allows people wishing to move to a property better suited to their current or future needs.
45. At present, the retirement housing market is dominated by a handful of providers who typically produce flatted developments within town centres for those approaching the later years of their lives (predominantly 75+ years of age). This results in a lack of choice and highly inflated prices for those aged 75+, who are looking to move to a property more suited to their current or future needs but also wish to remain close to friends and family. Needless to say, the couples and individuals who are of the 60-75 age bracket are left with no alternative housing option, other than making costly adaptations to their existing property.
46. Extensive research has shown a number of benefits arising from the provision of suitable specialist accommodation for the older population. The lack of suitable alternative and attractive accommodation acts as a significant barrier to down-sizing for the over 55s. Providing such accommodation will facilitate the release of under-occupied housing through downsizing. This will free up more housing in the locality for families, thus reducing the pressures on the local authority to make provisions for additional housing and costly adaptations to their existing housing stock.
47. The proposed development could make significant contribution to not only accessible and specialist housing but also much need affordable and market housing within the Greater Norwich area.

Comment

Representation ID: 22702

Received: 16/03/2020

Respondent: Strutt & Parker LLP

[On behalf of Scott Properties Ltd]
48. The requirement for self/custom-build within Policy 5 – Homes of the Draft Strategy requires 5% of plots on residential proposals of over 40 dwellings to be serviced self/custom build plots unless a lack of a need can be demonstrated or plots have been marketed for 12 months and not sold. This approach is considered to represent too high a proportion and if implemented would deliver significantly more plots than there is currently demand for. Currently there are 113 people on the self and custom build register in the Greater Norwich Area (2018/19). This is not a significant number of plots to identify and if some of the reasonable alternative sites were reviewed, a range of smaller dedicated self and custom build sites could potentially be allocated across the Plan area. These sites could also contribute to site allocations of less than 1 ha, which would equate to the need to find approximately six sites to meet the demand on the current register rather than requiring inclusion on larger sites.
49. Furthermore, self/custom-build units are considered slower to deliver on larger sites when they are expected to be brought forward alongside mainstream construction. If specific sites were allocated, construction activities could be managed phased without conflicting with mainstream construction which would demonstrably deliver new homes at a much faster rate than can be achieved through the self and custom build route. As such, it would be our recommendation that the requirement for such plots should be based on a locally identified need or demand rather than blanket approach of 5% across the Plan area with the identification of specific self and custom build site allocations.

Comment

Representation ID: 22703

Received: 16/03/2020

Respondent: Strutt & Parker LLP

[On behalf of Scott Properties Ltd]
50. Policy 7.2 – The Main Towns outlines that the settlements in the Plan area of Aylsham, Diss (with part of Roydon), Harleston, Long Stratton and Wymondham will provide for substantial development of around 6,300 homes. We support this approach although given the dispersed nature of the settlements consider that a more ambitious level of growth would be deliverable and would provide greater support to enable these rural communities to prosper and thrive. Such an approach would provide the Plan with a greater degree of flexibility in the event the larger allocations in the Norwich fringe deliver more slowly than anticipated.
51. The Main Towns are sustainable locations that are suitable to accommodate additional growth to contribute to the overall Plan area’s housing need. This approach is supported by paragraph 72 of the NPPF which identifies that the supply of a large number of new homes can often best be achieved through planning for larger scale development, including extensions to existing villages and towns, where they are well located and supported by the necessary infrastructure and facilities.

Comment

Representation ID: 22704

Received: 16/03/2020

Respondent: Strutt & Parker LLP

[On behalf of Scott Properties Ltd]
52. In respect of Aylsham, Diss and Harleston, these settlements are more dispersed lying on the peripheries of the Local Plan area and support wider rural communities in adjoining districts. They have been identified for lower levels of growth than Long Stratton and Wymondham. As such we strongly support the proposed allocations in these towns which will help these rural communities to prosper and thrive. To this extent, in addition to the preferred allocations, we recommend that further consideration should be given to those sites identified as reasonable alternative allocations to further boost housing supply and support a prosperous rural economy. In particular, we strongly support the proposed allocation of sites such as the land at Briar Farm, Harleston (GNLP2136) which are included as preferred options and provide for positive growth in relation to the settlement hierarchy, infrastructure and local constraints. In respect of our clients site, Land at Briar Farm, Harleston it will not only provide much needed housing, but also specialist homes C3 care accommodation, along with a retail area, and extensive open space and recreational facilities. The site is available now and developable, it can come forward and start to deliver significant numbers of new homes in the first five years of the Plan period and because of the mix of residential units there will be a wider range of market demand so that delivery is not restricted due to concerns about market saturation.
53. In summary, the site is immediately available for development and delivery could be completed within a short term period.

Comment

Representation ID: 22705

Received: 16/03/2020

Respondent: Strutt & Parker LLP

[On behalf of Scott Properties Ltd]
54. In response to Question 48, the below comments have been made in respect of the Greater Norwich Local Plan Interim Viability Study (November 2019) We are generally supportive to the approach taken but have some observations in respect of the detail which we hope are helpful:
Density (Table 4)
- Net areas are only used on Typologies 6-9, but are also applicable to Typology 4, where sites will also be required to provide on-site public open space, green infrastructure and SUDS, as well as often needing to ‘gift’ land for community uses.
- The density figures are presumably based on the indicative mixes in Table 5, but these do not have any allowance for housing for older people (single-storey), which will again reduce density. This will mean that the proposed density of 25 dwelling per hectare (gross) will be difficult to achieve where large proportions of bungalows are to be included.
- The net: gross ratios are likely to be circa 66% on these sites, meaning a net density of circa 38 dph will be needed.
Housing Mix (Table 5)
- As mentioned above, there is nothing for single-storey accommodation, for example housing for older people and accessible housing, despite the strong demographic arguments which demonstrate the need to provide accommodation for an ageing population.
- While housing need may suggest the proportion of 3 bedroom homes should be high in the Main Towns, demand for market properties is likely to be higher for larger family properties. Such a high percentage of two bed houses seems high at the expense of 3 and 4+ bed family housing in the Main Towns. In particular 8% of 4+ seems very low. Market demand is likely to be circa 20% of the private dwellings with 4+ bedrooms (13% aggregated).
- The 20% for flats also seems high, the market for private flats is limited in rural locations, so we would expect this to be closer to 10% overall.
Size of Dwellings (Table 6)
- Again no information has been provided for single-storey properties.
- The 3-bedroom house size (102 sq. m) is for a 6-person property, so comes out large at 1,100 sq. ft.
Affordable Housing (Table 7 & Table 15)
- Typology 4 (Main Town) is assessed at 28% Affordable Housing but 33% is sought by policy.
- At 28% (and with current assumptions) it is the 2nd least viable (£115,872 surplus) and as such, on the Sensitivity Testing it fails across all scenarios.
- Affordable Rent – 60% is very ambitious as a return, it is recognised in the report that the range is 45% to 65%, so 50% would be a better assumption to use.
- Affordable Ownership – again it is recognised that the range can be 60% to 80%, so 70% would be a better assumption than 75%.
- As mentioned in the caveats, no account has been taken of the 5% custom build policy requirement.
Access
- For specialist housing developments, all (not just 20%) of homes will meet at least the M4(2) access requirement, which adds up at £940 per dwelling. It is our consideration that a new house type is required for the Study.
RAMS
- A justification is required in relation to the recommendation for £200 per dwelling. This was recently revised down to £122 in neighbouring Suffolk.

Market Revenue
- The values do not correlate with what is currently on the market, especially for the 4 bedroom properties, for which the values are overstated by as much as 33%. The below tables (see attachment) show all of the new build (estate) houses on Rightmove as of the 18th February 2020.

Build Costs
- The costs for Bungalows will be higher than £1,221 per square metre and it is suggested that consideration of bungalows is included within the Study.
- The costs for Garages have been contained within the site and infrastructure costs. CIL will also be payable on the garages which will increase the cost.
- No allowance is made for ground conditions / ground water protection / flood risk. It is important that these are factored in.
Sites and Infrastructure Costs (Table 10)
- 15% seems low for site and infrastructure costs, it is considered that these costs will rise over the Plan period with increased electricity requirements etc.
CIL/S106 (Table 11)
- As mentioned above, Garages have been excluded but will be chargeable.
- For Typology 4 – the majority of the Main Towns are in Zone B so it would make sense to use the appropriate figure.
- The 2020 figures are now available and as such should be used (£70.46 per sq. metre).
- No allowance has been made for site-specific Section 106 works such as Public Rights of Way improvements etc.
Benchmark Land Value (Table 12a)
- The figure for Typology 4 is £432,432 / ha = £175k / acre (gross). This does not reflect that most land is purchased at a discount to reflect the planning and promotion risks / cost time. It also doesn’t consider sales agent and legal fees.
- Taking the example in the report shown below, the figure should be revised accordingly and checked against actual transactions to show that the transaction levels (and therefore expectations) are still far higher at circa £300,000 gross per acre.
- 7.5 acres @ £175k per acre = £1.312m
 minus Agent’s Fees @ 1.5% = £1.292m
 minus Sales Legal Fees @ £10k = £1.282m
 minus Recoverable Promotion Costs @ £150k = £1.132m
 minus Promoter’s Share @ 20% = £906k
 = £121k per acre (= EUV x 12, not 17.5)

Support

Representation ID: 22782

Received: 16/03/2020

Respondent: Strutt & Parker LLP

The vision for the Local Plan is to achieve a ‘vibrant, healthy, inclusive and growing communities supported by the delivery of new homes, infrastructure and an enhanced environment.’ It is clear from Section 3 – The Vision and Objectives for Greater Norwich that a key theme throughout is playing a part in the national commitments to achieving net zero greenhouse gas emissions by 2050.

Scott Properties is passionate about the need to address Climate Change. It is agreed that this is one of the most important factors to our future and as such should be a key consideration in the preparation of the new Local Plan.

Chapter 14 of the National Planning Policy Framework (NPPF) focusses on ‘Meeting the challenge of climate change, flooding and coastal change’.
“The planning system should support the transition to a low carbon future in a changing climate, taking full account of flood risk and coastal change. It should help to: shape places in ways that contribute to radical reductions in greenhouse gas emissions, minimise vulnerability and improve resilience; encourage the reuse of existing resources, including the conversion of existing buildings; and support renewable and low carbon energy and associated infrastructure.”
(Paragraph 148 – NPPF, 2019)

The Plan needs to be visionary looking forward beyond 2038 in particular having regard to the Government’s commitment to reach Net Zero Carbon by 2050. The Plan needs to understand what the implications of Net Zero Carbon will be, and develop an appropriate strategy to ensure that this will be achievable within the plan area.

We believe that our client’s site can help address the visions and objectives for the Greater Norwich area, and strongly support its inclusion in the draft Local Plan as a Site Allocation.

The proposed development of the site will involve the development of up to 200 homes, an area for the expansion for the existing Diss Cemetery as well as the provision of a link road along the northern edge of the site, to link Shelfanger Road in the west to Heywood Road in the east.

Support

Representation ID: 22783

Received: 16/03/2020

Respondent: Strutt & Parker LLP

The Delivery Statement set out at Paragraph 139 of the Draft Strategy sets out that the Plan will promote a pro-active approach to delivery through only allocating housing sites where a reasonable prospect of delivery can be evidenced, taking into account policy requirements. This approach accords with para 67 of the NPPF and is supported. In terms of providing flexibility and including a 9% buffer this accords with the objective of ensuring that a sufficient amount and variety of land can come forward. It is also recognised that it is proposed that the buffer will increase to 10% at the regulation 19 stage, when the village clusters allocations will be included. It is acknowledged that the plan aims to comply with the NPPF paragraph 68 requirement to accommodate at least 10% of housing requirement on sites no larger than 1 ha. However, given the uncertainty around the Carrow Works site (1,200 homes), it is recommended that where reasonable alternative sites exist in sustainable locations, additional smaller sites of up to circa 25 dwellings (the expected yield from a site of 1 ha) should also be allocated throughout the Plan area to increase certainty around delivery and supply, particularly in the early parts of the Plan period, supporting the Government’s objective of significantly boosting the supply of homes.

Support

Representation ID: 22784

Received: 16/03/2020

Respondent: Strutt & Parker LLP

Further to the above, the Delivery Statement states that it will continue to work to coordinate delivery with providers including Highways England and Anglian Water to ensure infrastructure will be delivered. The below approach outlined within the statement is also supported by my client.

- On-site and off-site provision required of development through conditions or legal agreements;
- Pooled use of CIL;
- Maximising opportunities to access Government and other sources of funding;
- Capital investment of public bodies and utilities companies; and
- Locally led delivery vehicles.

Support

Representation ID: 22785

Received: 16/03/2020

Respondent: Strutt & Parker LLP

Scott Properties is passionate about the need to address Climate Change and as such supports the Climate Change Statement that has been included within the Draft Strategy at paragraph 141.

Support

Representation ID: 22786

Received: 16/03/2020

Respondent: Strutt & Parker LLP

The preferred option for the Local Plan combines the concentration of the majority of development in and around Norwich and on the Cambridge to Norwich Tech Corridor, a large focus on market towns, with an element of dispersal to villages. This approach is supported and provides a balance across a range of the objectives of the Local Plan.

This approach would see housing commitments providing a total minimum deliverable commitment of 6,342 within the Main Towns over Plan period of 2018 – 2038.

The settlement hierarchy’s recognition of the contribution that the Main Towns like Diss make to the delivery of housing is acknowledged and supported. While it is acknowledged that Norwich should be the principal focus growth, the market towns have an important role in creating a vibrant sub-region, and in the case of Diss serve wide hinterlands from which people are drawn to use the town’s shops, services, and facilities, including primary schools, and a secondary school.