Draft Greater Norwich Local Plan – Part 1 The Strategy

Support

Representation ID: 22721

Received: 16/03/2020

Respondent: Pegasus Group

The Draft GNLP identifies 6 objectives (Economy, Communities, Homes, Infrastructure, Delivery and Environment) which will shape development in the Greater Norwich area over the plan period 2018-2038. Our client supports and agrees with these objectives and is confident that Halsbury Homes Ltd will assist in delivering sustainable development to meet the needs of the local community and the Greater Norwich’s agenda for growth.
Our client is promoting Land off Norton Road, Loddon. It is considered that the site will deliver upon the draft objectives of the GNLP by providing a high quality well-designed development in a sustainable location with good access to jobs, services and facilities which will to foster vibrant and healthy communities.

Comment

Representation ID: 22722

Received: 16/03/2020

Respondent: Pegasus Group

Paragraph 59 of the National Planning Policy Framework (NPPF) sets out to support the Government’s
drive to boost housing supply, a sufficient amount and variety of sites must come forward, specific
housing requirements are met, and that consented sites are developed without unnecessary delay.
The GNLP Delivery Statement sets out that housing sites will only be allocated where it can be
Evidenced that delivery can be achieved within the plan period. In addition to this, applicants are
required to submit delivery plans alongside planning applications to provide a guide of their expected
delivery rates. Where agreed delivery rates are not met then the Councils would have the option to
bring forward development sites through compulsory purchase orders. Furthermore, the GNLP allows
for some flexibility by including a total housing figure 9% higher than the governments’ standard
method figure (which as outlined in Question 14 has been miscalculated), and is considering two
contingency sites at Costessey and Wymondham (both for approximately 1,000 homes each) to offset
any non-delivery within the plan period. Given that the Councils are proposing such strategies
indicate that the Councils are clearly concerned with the continuation of historic under-delivery
persisting into the new Plan period. To avoid a continuation of delays to the delivery of large-scale
Sustainable Urban Extensions (SUEs) including contingency sites, a range of smaller sites should also
be included.
Consequently, to provide the Councils with greater certainty, they should consider increasing the
housing figure above the housing target figure. In doing so, Councils should identify land and
development sites on the edge of established sustainable settlements which are capable of
accommodating housing growth within the plan period. These sites are able to come forward at a
faster rate and are fully capable of delivering sustainable development in accordance with paragraph
8 of the NPPF.
Land off Norton Road, Loddon falls outside of the current settlement boundary but adjoins it to the north west with the proposed allocation of Policy GNLP0312 (Land to the east of Beccles Road). The village of Loddon is classed as a Key Service Centre, the largest, one of the most sustainable villages in the area. Indeed, the settlement possesses a wide range of shops, services, infrastructure, employment opportunities and public transport links. Thereby the allocation of the small-scale housing site of Land off Norton Road would lead to the natural extension of the sustainable settlement of Loddon and will assist in providing the Councils with greater certainty over housing delivery during the 2 next plan period.

Support

Representation ID: 22723

Received: 16/03/2020

Respondent: Pegasus Group

Our client is broadly supportive of the approach to Infrastructure as set out in the Delivery Statement, which includes that infrastructure can be delivered through on-site and off-site contributions and the pooled use of the Community Infrastructure Levy (CIL). Notwithstanding this, the level of financial contribution should be subject to a formal viability exercise being conducted.

Comment

Representation ID: 22724

Received: 16/03/2020

Respondent: Pegasus Group

The Climate Change Statement sets out the Council’s measures to support the transition to a post carbon future as set out in joint Royal Town Planning Institute (RTPI) and Town and Country Planning Association (TCPA) guidance. Our client supports and agrees with this approach to development and is confident that their site at Land off Norton Road, Loddon will assist in meeting the Council’s Climate Change reduction aspirations.
Loddon has a direct bus link to Norwich city centre and its public transport hubs (including Norwich Train Station). These excellent connections offer sustainable travel options to major employment hubs and recreation/leisure destinations in Norwich and further afield. The settlement also possesses a wide range of shops, services including a high school, medical centre, library, public houses and employment opportunities, such as at the Loddon Industrial Estate. Therefore, services and jobs can be accessed sustainably either on foot, by cycle or by public transport; reducing the need for travel by private car.
It should also be noted that Environment Agency mapping shows that the site is within Flood Zone 1 and therefore at very low risk from flooding from surface water and aligns with the GNLP in minimising flood risk through the location of development.

Comment

Representation ID: 22725

Received: 16/03/2020

Respondent: Pegasus Group

Policy 1 – The Sustainable Growth Strategy provides a settlement hierarchy which reflects materially different levels of service between different types of places. The hierarchy splits Greater Norwich into four tiers comprising the Norwich urban area, main towns, key service centres and village clusters. It goes on to detail the levels of housing each tier is expected to provide over the period 2018-2038 with the concentration of growth higher up the hierarchy.
Our client broadly agrees with the proposed settlement hierarchy and the need to focus larger development in accessible locations with good access to jobs, services and existing and planned infrastructure. They also support the use of minimum housing commitments which provide the opportunity to boost housing supply in line with the Government’s objective and in light of the districts consistent under delivery. Halsbury Homes Ltd does, however, question the reliance on allocations through the South Norfolk Village Clusters Housing Sites Allocation Plan and this mechanisms ability to deliver the required housing stock in the plan period.
Our client is promoting a site in Loddon as identified on Map 7 – the Housing Growth Locations of the draft GNLP. The village of Loddon is classified as a ‘Key Service Centre’ with an expected delivery of 400 minimum new homes between 2018 – 2038.
Land off Norton Road, Loddon falls outside of the current settlement boundary but adjoins it to the north west and within the proposed allocation of Policy GNLP0312 (Land to the east of Beccles Road).

The site is easily accessible to Loddon’s High Street (less than 10 minutes walk from the site), which has an excellent range of shops, services, employment opportunities and a frequent bus line to Norwich city centre (one bus every 30 minutes). Furthermore, there are employment opportunities available at Loddon Industrial Estate (less than 10 minutes walk from the site). By affording sustainable levels of growth to areas such as this it will assist in safeguarding existing services, public transport links and infrastructure which local people currently rely upon and support vibrant rural communities.

Comment

Representation ID: 22726

Received: 16/03/2020

Respondent: Pegasus Group

Paragraph 60 of the NPPF outlines that strategic policies should be informed by local housing needs, using the Government’s standard method unless exceptional circumstances for an alternative approach can be justified which reflect current and future demographic trends and market signals.
Paragraph 11 NPPF confirms that for plan-making, the presumption in favour of sustainable development means that:
• Plans should positively seek opportunities to meet the development needs of their area, and be sufficiently flexible to adapt to rapid change; and
• Strategic policies should, as a minimum, provide for objectively assessed needs for housing and other uses, as well as any needs that cannot be met within neighbouring areas…
Minimum housing requirement
The need for 40,550 homes is identified as having been calculated using the standard method. Albeit it is noted that the Draft Strategy states that the published version of the plan will aim to provide a minimum 10% buffer (a minimum of a further 250 homes) which is likely to be provided through a combination of additional sites proposed through this consultation and contingency sites identified in the draft plan.
The standard method provides the minimum local housing need and is calculated using the average household growth for 10 consecutive years, with an affordability uplift based on the median workplace-based house price to earnings ratio of the preceding year[1]. The Draft Local Plan covers the period from 1st April 2018. In order to establish the minimum local housing need for the plan period it is therefore necessary to calculate either the standard method at 2018; or to calculate the current standard method and apply this to the remainder of the plan period in addition to the number of completions which have already occurred.
The Draft Local Plan covers the period from 1st April 2018. In order to establish the minimum local housing need for the plan period it is therefore necessary to calculate either the standard method at 2018; or to calculate the current standard method and apply this to the remainder of the plan period in addition to the number of completions which have already occurred.
In the case of the Greater Norwich Plan Area, the average household growth over the 10 consecutive years from 2018, namely 2018-28, was 400 in Broadland, 510 in Norwich and 704 in South Norfolk. The median workplace-based house price to earnings ratios in 2017 were 9.82, 6.93 and 8.91 respectively. Using these figures, the minimum local housing need over the plan period equates to 41,379 homes.
Alternatively, the minimum local housing need from 2019 onwards can be calculated using the average household growth over the 10 consecutive years from 2019, namely 2019-29, with the affordability of 2018 applied. The average household growth was 397, 505 and 691 respectively and the
median workplace-based house price to earnings ratios were 9.23, 7.03 and 8.78 respectively. These
figures produce a minimum local housing need of 2,024 homes per annum which equates to 38,460
homes over the period 2019-38. The number of housing completions in 2018/19 need to be added to
this figure to provide the minimum local housing need over the plan period. Ministry of Housing
Communities and Local Government Live Tables identify that there were 2,757 housing completions,
as well as 260 student bedspaces and 91 other bedspaces completed in this year. Once the appropriate
conversion factors as identified in the Planning Performance Guidance (PPG) (68-034) and the PPG
(63-016a) are applied this would equate to 2,901 houses[2] completed in 2018/19. In addition to the
minimum local housing need of 38,460 over the period 2019-38 this would produce a minimum local
housing need for 41,361 homes over the plan period. It is apparent that the standard method has
been miscalculated within the Draft Local Plan as it is below the minimum local housing need of either
41,379 or 41,361. Policy 1 and all other references to a need for 40,550 are therefore not justified nor
are they consistent with national policy. Furthermore, the Government has identified that it intends to
review the standard method by September 2020. As the Local Plan is not intended to be submitted for
examination until June 2021, it is likely that the Local Plan will need to respond to the new standard
method, whatever that may be.
Historic under-delivery
In Greater Norwich, the housing trajectory of the Joint Core Strategy identified that there would be
23,637 housing completions in the period 2008-19. However, only 18,835 homes have been delivered
which demonstrates that at least historically, the trajectory of Greater Norwich overestimates the
developable supply by circa 25%. The overestimations of supply can be mainly attributed to the
delivery rates of strategic infrastructure projects, and consequently, the ability of large scale SUE’s to
be delivered across Greater Norwich. Assuming that the current trajectory is equally as accurate, it
would be appropriate to set a housing requirement 25% in excess of the minimum need for circa
41,400 homes. This would produce a housing requirement for circa 52,000 homes. This illustrates that
there is a need for a significant contingency allowance in Greater Norwich to ensure that needs are
actually met. It is therefore recommended that the proposed contingency of 9% is retained as a
minimum, which in addition to the minimum housing need for circa 41,400 homes produce a housing
requirement for at least 45,126 homes.
Expected Economic Growth
In addition to this, given the early stage of the plan preparation and the need for further technical
work and analysis regarding economic growth and housing need it is recommended that the additional
33,000 new jobs, is viewed as a minimum by the Councils. The Councils will need to adopt a flexible
approach to setting the increased housing target to ensure that available land is used efficiently to
meet the economic and housing needs of the area.
By planning proactively for increased rates of housing the GNLP will support and stimulate the
anticipated economic growth and job creation in the area and in turn support the growth of the
Cambridge Norwich Tech Corridor. Preparing the GNLP on the basis of an enhanced figure to address
economic growth is entirely justified given the context provided by the Greater Norwich City Deal,
which identifies that strategic infrastructure is needed including to deliver a step change in housing
delivery. The City Deal identifies that a target for an average of 3,000 homes per annum in the period
2014-19 and for 37,000 homes to be delivered in the period 2008-26. The Government encourages authorities to consider higher levels of growth than that required to meet local housing need, particularly where there is the potential for significant economic growth.
In our assessment, based on the information available and content of the Draft Strategy document, it is strongly recommended that the GNLP plans for an increased housing need figure. This will support economic growth, reduce inequality, increase affordability levels and promote wellbeing through the delivery of additional market and affordable housing in sustainable locations. Even at this early stage of the plan preparation process it is evident that exceptional circumstance exists in this instance to justify increased housing delivery in accordance with paragraph 60 of the NPPF.
Land off Norton Road, Loddon
Our client considers that the Councils should consider identifying additional available and deliverable small and medium sized sites from a range of locations, which are capable of accommodating housing growth within the plan period.
Our client’s site is available and deliverable within the plan period, with site access feasible to both the Northern and Southern sections of the site from Norton Road. There is also some scope to create through access from the proposed allocation of Land to the east of Beccles Road (GNLP0312) to the west. Furthermore, the village of Loddon is classed as a Service Centre, the largest, most sustainable villages in the area. Indeed, the settlement possesses a wide range of shops, services, infrastructure, employment opportunities and public transport links. Thereby the allocation of the small-scale housing site of Land off Norton Road would lead to the natural extension of the sustainable settlement of Loddon and would assist in providing the Councils with greater certainty over housing delivery during the next plan period.

[1] As confirmed in paragraph 15 of the Housing Delivery Test Measurement Rule Book
[2] Calculated using the average number of students per household of 2.85 in Norwich and applying
this to the 260 student bedspaces which equates to 91 houses; and using the average number of
adults per household of 1.85 in Broadland and applying this to the 8 older persons bedspaces which
equates to 4 houses; and using the average number of adults per household of 1.72 in Norwich and
applying this to be 83 older persons bedspaces which equates to 48 houses.

Comment

Representation ID: 22727

Received: 16/03/2020

Respondent: Pegasus Group

Our client agrees with the broad sustainable growth strategy to support improvements to the transport system, green infrastructure and services. In particular, Policies 1 and 4, along with appendix 1, set out the infrastructure requirements to serve the growth in Greater Norwich based on evidence in the Greater Norwich Local Plan Infrastructure Needs Report. Appendix 1 includes proposed junction improvements to the A47/A146 Loddon Road. In the context of Land off Norton Road, our client would be supportive of these proposed works.
The GNLP should promote sustainable growth by allocating housing sites in sustainable locations in established settlements which possess high-quality public transport links and good range of services. A direct bus link serves Loddon to Norwich city centre and its public transport hubs (including Norwich train station). These excellent connections offer sustainable travel options to major employment hubs and recreation/leisure destinations in Norwich and further afield. Loddon also possesses a wide range of shops, services including a high school, medical centre, library, public houses and employment opportunities, including at the Loddon Industrial Estate. On this basis, the allocation of Land off Norton Road, Loddon site would be in accordance with paragraph 102 of the NPPF and encourage modal shift away from the private car. This, in turn, would assist the Councils in delivering their sustainable growth strategy.

Support

Representation ID: 22728

Received: 16/03/2020

Respondent: Pegasus Group

Policy 2 – Sustainable Communities is a broad strategic policy covering a range of economic, environmental, and social imperatives for development with the ultimate objective of reducing emissions. The policy, therefore, details the importance of high quality development, contributing to inclusive growth in mixed, resilient and sustainable communities and mitigating and adapting to climate change.
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Our client supports the Council’s approach to sustainable communities and the requirement for housing developments of 100 dwellings or more to submit a Delivery Statement such that the key objectives of Policy 2 are implemented which reflect the overarching aims of the NPPF. They also believe that their site at Land off Norton Road, Loddon would align with these objectives in the delivery of a sustainable community.
Land off Norton Road is considered to be located in a sustainable location as it is easily accessible to Loddon’s High Street (less than 10 minutes walk from the site), which has an excellent range of shops, services, employment opportunities and bus stops with a frequent bus service to Norwich city centre (one bus every 30 minutes). Furthermore, there are employment opportunities available at Loddon Industrial Estate (less than 10 minutes walk from the site). By affording sustainable levels of growth to areas such as this it will assist in safeguarding existing services, public transport links and infrastructure which local people currently rely upon and support vibrant rural communities.
Our client is actively developing sites across Greater Norwich, which have delivered well-designed and high quality developments which are long lasting and make the best use of the land available through appropriate housing densities. The proposed development at Land off Norton Road would similarly align with this with indicative minimum densities of 25 dwellings per hectare across the plan area. It would be designed in such a way that actively encourages walking and cycling.

Support

Representation ID: 22729

Received: 16/03/2020

Respondent: Pegasus Group

Paragraph 170 of the National Planning Policy Framework highlights the importance of protecting the natural environment, including ensuring biodiversity net gain. Policy 3 Environmental Protection and Enhancement reflects these objectives.
Our client supports this approach to the natural environment and would ensure that any scheme on the Land off Norton Road site would be brought forward with the aim of achieving net gain in biodiversity through retention, protection and enhancement of any on-site habitats, provision of new public open space and high quality landscaped areas.

Support

Representation ID: 22730

Received: 16/03/2020

Respondent: Pegasus Group

The GNLP Draft Strategy states that transport improvements will support the role of Norwich as the regional capital and support strategic growth in the Cambridge Norwich Tech Corridor.
In particular, our client supports the Strategy’s commitment to continue to improve public transport accessibility to and between main towns and key service centres. The Village of Loddon is classed as a ‘Key Service Centre’ in the GNLP Draft Strategy and is well served by a frequent service to Norwich City Centre and Lowestoft (one bus every 30 minutes). Our client would welcome any further improvements to increase the accessibility of Loddon by sustainable modes of transport, and thereby encourage a shift towards non-car use.