Draft Greater Norwich Local Plan – Part 1 The Strategy

Support

Representation ID: 22787

Received: 16/03/2020

Respondent: Strutt & Parker LLP

In developing the new Greater Norwich Local Plan, it will be important that an adequate mix of sites is promoted including a proportion of smaller sites as well as sites to meet specific housing needs (including housing for older people). Our client’s site at West of Shelfhanger Road, Diss could make a meaningful and positive contribution towards meeting these goals.

With regard to the delivery of new housing, the GNLP’s inclusion of a 9% buffer is supported, and while a higher buffer of up to 20% would normally be advisable to offset the potential for slow delivery on some sites, in particular large strategic sites. It is acknowledged that no allowance has been made in this instance for windfall within the overall supply and the contingency of approximately 2,000 homes provides additional flexibility to ensure that the overall housing needs are met. However, given the uncertainty around the Carrow Works site, (1,200 homes), it would be advisable to allocate smaller sites up to c. 25 units (c. 1 ha) across the Plan area to help boost the supply of new homes. It is acknowledged that the Plan aims to comply with para 68 of the NPPF by accommodating at least 10% of the housing requirement on sites no larger than 1 ha, however, where there are reasonable alternatives available these should be included to maintain supply and avoid the need to rely on less certain strategic sites or large contingency sites.

The “presumption in favour of sustainable development” is at the heart of the National Planning Policy Framework 2019 (NPPF). The Planning and Compulsory Purchase Act 2004 (Section 39(2)) establishes a legal requirement for Plans to be prepared with the objective of contributing to the achievement of sustainable development.

Paragraph 16 of the NPPF requires plans to be prepared positively in a way that is aspirational but deliverable. Paragraph 59 reminds Local Planning Authorities that the Government’s objective is to significantly boost the supply of homes and that it is therefore important that a sufficient amount and variety of land comes forward where it is needed.

To ensure that Local Authorities have specific deliverable sites they are required to maintain a 5 Year Housing Land Supply with an appropriate buffer. In addition, to ensure supply is maintained, they are also required to monitor the progress in building out sites, to comply with the housing delivery test. The Government’s recently published housing delivery figures for 2019 indicate delivery for the Greater Norwich area comprising Broadland, Norwich and South Norfolk to be at 140%. This is very encouraging, however, housing delivery can be fragile and susceptible to changes in the economy or delays in the delivery of key infrastructure necessary for strategic sites to come forward.

Further to the above, Policy 1 – The Sustainable Growth Strategy sets the settlement hierarchy for the Plan Area as follows:
1. Norwich Urban Area (Norwich and Norwich Fringe)
2. Main Towns
3. Key Service Centres
4. Village Clusters

Further detail on Village Clusters is provided at Appendix 5 of the Draft Strategy, as the preferred option the Council consider that a ‘cluster approach better reflects the way people access services in rural areas and enhances social sustainability by facilitating levels of growth in small villages’ This statement is supported, however it is unclear how this approach will work effectively within the Plan Area and how it will be achievable. As such, a focus should be made on small and medium sites. The distribution of growth to a variety of sites will enable a steady delivery of homes and ensure the District can meet its housing targets throughout the plan period.

Support

Representation ID: 22788

Received: 16/03/2020

Respondent: Strutt & Parker LLP

Policy 1: The Sustainable Growth Strategy states that the Plan will be reviewed 5 years after its adoption. At Paragraph 33, the NPPF states that Local Plans should be “reviewed to assess whether they need updating at least once every five years” and goes on to state that reviews “should be completed no later than five years after the adoption date of that plan”. As such, it is not considered that Policy 1 is consistent with national policy and this needs to be made more clear, that a review will be undertaken within five years after adoption or in the event housing delivery falls, or housing land supply falls below the annual requirement.

In respect of Five-year land supply, as outlined at Policy 1 of the Draft Strategy, the Five-year housing land supply will be calculated across the whole of the three districts comprising Greater Norwich. This approach is supported, however, given the political nature of planning decisions it should be monitored to ensure that all three districts continue to deliver in a proportionate manner.

Comment

Representation ID: 22789

Received: 16/03/2020

Respondent: Strutt & Parker LLP

we support the approach to infrastructure that has been set out within Policy 1 – The Sustainable Growth Strategy in that the sustainable growth strategy will be supported by improvements to the transport system, green infrastructure and services. Adequate infrastructure provision is key to supporting the development of the Plan area and enabling development to come forward. The statement provided within Policy 1 is vague and needs a greater explanation as to how the Greater Norwich Local Plan will ensure sustainable growth is supported by improvements to infrastructure.

Support

Representation ID: 22790

Received: 16/03/2020

Respondent: Strutt & Parker LLP

The preferred approach to sustainable communities is the requirement for sustainability assessments to accompany planning applications for major developments. This approach is supported and is considered to be in line with the National Planning Policy Framework.

Support

Representation ID: 22791

Received: 16/03/2020

Respondent: Strutt & Parker LLP

Policy 4 – Strategic Infrastructure outlines the key elements to strategic infrastructure improvements that will be undertaken to support timely delivery of growth. The approach for on-site and local infrastructure, services and facilities is as follows:
‘Development proposals will provide on-site services and facilities and support local infrastructure capacity improvements through on-site provision, providing land and developer contributions.’

There is scope within this part of Policy 4 to also address the need to provide community uses on larger schemes that will benefit both future and existing residents.

This approach is supported by our client and as shown within the accompanying plans and technical notes, this approach is being taken to ensure the site brings forward the required on-site services and facilities required.

Object

Representation ID: 22792

Received: 16/03/2020

Respondent: Strutt & Parker LLP

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 (2018/119). 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 approximately six sites, to meet the demand on the current register.

Furthermore, self/custom-build units are considered slower to deliver on larger sites when they are expected to be brought forward alongside main stream 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: 22793

Received: 16/03/2020

Respondent: Strutt & Parker LLP

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 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. The Main Towns are sustainable locations that are suitable to accommodate additional growth to contribute to the overall Plan area’s housing need. In particular, we support the approach to allocate development of the combined sites to the north of Diss which form the subject of Policy GNLP0250/0342/0119/0291 which are included as preferred options and provide a suitable amount of growth in relation to the settlement hierarchy, infrastructure and local constraints. 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.

Support

Representation ID: 22794

Received: 16/03/2020

Respondent: Strutt & Parker LLP

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 respect of Diss, as outlined above, we support the approach to allocate the sites located to the north of the town under Policy GNLP0250/0342/0119/0291, Land north of the cemetery, West of Shelfanger Road and East of Heywood Road, Diss. The sites combined comprise approximately 8.91 hectares for residential development and could likely accommodate 200 dwellings. However, it is recommended that the site under reference 0119 is removed from the Draft Strategy as an allocation as it has recently changed ownership and would not be viable to bring forward as part of the allocation.

Comment

Representation ID: 22795

Received: 16/03/2020

Respondent: Strutt & Parker LLP

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.
- 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 43%. The below tables show all of the new build (estate) houses on Rightmove as of the 18th February 2020.
(see attached document for additional figures (para 39)

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 increased 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)