Draft Greater Norwich Local Plan – Part 1 The Strategy

Comment

Representation ID: 22635

Received: 13/03/2020

Respondent: M Scott Properties Ltd

Number of people: 2

Agent: Bidwells

Comments
Clarification is required as to the extent of education contributions likely to be required.
Paragraph 229 states that “if a new development is likely to generate enough children to fill a new school, Norfolk County Council asks developers for the full cost of building that school.” However, the paragraph goes onto state that “with the current CIL approach locally, only land can be secured through a S106 agreement and the build cost of the new school is claimed through CIL.”
From discussions with NCC Education and the GNLP it is understood that when a new School is required the situation will remain as existing i.e. the developer will be expected to provide the land for the School, with the construction being funded through CIL. If this position has changed, it will have significant implications for viability.
The flexibility provided in relation to provision of new schools (para 231), ensuring that they are only provided as and when they are required is fully supported.
See comments made in relation to Question 17.

Support

Representation ID: 22636

Received: 13/03/2020

Respondent: M Scott Properties Ltd

Number of people: 2

Agent: 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.
See comments made in relation to Question 17.

Comment

Representation ID: 22637

Received: 13/03/2020

Respondent: M Scott Properties Ltd

Number of people: 2

Agent: Bidwells

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.

Support

Representation ID: 22638

Received: 13/03/2020

Respondent: M Scott Properties Ltd

Number of people: 2

Agent: Bidwells

Support, with comments
The approach to the provision of accessible and specialist housing is supported. However, the policy should recognise that in identifying the need for accessible and specialist housing consideration will be given to the demographics of the area. For example, due to an assessment of the demographics within a certain area, specific demands for a type of accommodation, such as bungalows, may be identified and included within a planning application.

Comment

Representation ID: 22639

Received: 13/03/2020

Respondent: M Scott Properties Ltd

Number of people: 2

Agent: 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. For example on large strategic sites, such as that covered by Policy GNLP0337, this would result in provision of approximately 70 self and custom build units.
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.
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.

Support

Representation ID: 22640

Received: 13/03/2020

Respondent: M Scott Properties Ltd

Number of people: 2

Agent: Bidwells

Strongly support.
As detailed in comments provided in respect of Question 13, the proposed Settlement Hierarchy and the identification of Norwich and the Norwich Fringe as the location to accommodate 69% of the housing growth during the period to 2038 is strongly supported.
Norwich and the Norwich Fringe is the catalyst for economic growth in the area and provides a range of amenities, services and infrastructure to support sustainable housing.
The fringe parishes will play a significant role in providing sustainable growth, given their proximity to employment opportunities, services and strategic infrastructure, such as Broadland Northway. In addition, by virtue of its location, the fringe parishes are in close proximity of the countryside providing ease of access to the leisure and recreation opportunities it provides.
The fringe parishes provide opportunities for strategic growth i.e. over 1,000 units. Developments of this scale are capable of providing a wide range of infrastructure improvements, such as schools, employment, health centres and green infrastructure, which will provide benefits to both existing and future residents.

This approach is entirely consistent with paragraph 72 of the NPPF, which advises that “The supply of large numbers of new homes can often be best achieved through planning for larger scale development, such as new settlements or significant extensions to existing villages and towns, provided that are well located and designed and supported by the necessary infrastructure and facilities.”
The identification of Taverham as a location to accommodate a minimum of 1,400 dwellings by way of a strategic urban extension is fully supported.
Taverham provides an excellent location to provide a strategic urban extension of a minimum of 1,400 units. It represents a highly sustainable location with good access to Norwich, that has been significantly enhanced by the recent delivery of the Broadland Northway. The buffer created by the Broadland Northway presents an opportunity for a logical strategic urban extension to the settlement of Taverham at a size and scale that can, whilst being proportionate to the scale of the settlement, accommodate a significant quantum of the infrastructure and housing required in the Greater Norwich Area over the next two decades.
Taverham already benefits from a variety of amenities including a pub, a supermarket, takeaways, petrol filling station and a garden centre. In addition, the area is within close proximity of the amenities provided within Thorpe Marriott and Drayton. Nightingale and Ghost Hill Infant schools are located in close proximity of the site, as are Taverham Junior and High Schools. A private school (Langley Preparatory School at Taverham Hall) is located nearby. These will be sustained and enhanced by the increased population proposed.
The proposals to enhance the green infrastructure with the fringe parishes network through, amongst other things, improved links to Marriott’s Way is supported.

Comment

Representation ID: 22641

Received: 13/03/2020

Respondent: M Scott Properties Ltd

Number of people: 2

Agent: 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.
In addition, there is concern that the typologies used within the Viability Study are both too general and do not reflect the allocations within the draft GNLP. For example, the largest size development appraised within the Viability Study is 600 units, notwithstanding the fact that a number of the carried forward allocations / preferred sites are well in excess of this figure. These larger sites are likely to require the more significant infrastructure obligations i.e. primary schools and health centres, so an assessment of viability and the implications for deliverability is key. To ensure a more robust and realistic approach we would suggest that site specific viability studies are undertaken of a selection of the preferred sites of varying sizes.
As part of this work, consideration should be given to whether it is viable for some of the larger strategic sites, which have high infrastructure costs associated with their delivery i.e. the requirement to provide schools and health centres on land which otherwise would be land developable for alternative uses, to pay the Community Infrastructure Levy, in addition to the policy requirements of the Local Plan.
The potential for infrastructure costs which are specific to larger strategic sites to be secured by appropriate and negotiable Section 106 planning obligations, in order to ensure that such sites are deliverable and, importantly, that there is certainty regarding the timely delivery of the infrastructure on site, should be fully explored. This approach, which has been adopted by Mid Suffolk District Council, is entirely consistent with the Community Infrastructure Regulations (2019).
In addition to the foregoing, the following comments are made on the Interim Viability Study, with specific regard to Policy GNLP 0337, Land between Fir Covert Road and Reepham Road, Taverham and Typology 9.
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. It is considered based on evidence of local need that the housing mix should be more focused towards smaller dwellings to reflect market requirements.
There should be more 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.
It would appear an error has been made within Table 4 in relation to density. A target of 25 dph nett would be achievable but not gross as stated. The density should be lower than typology 8 to reflect the infrastructure required on a strategic scheme.
In relation to infrastructure for strategic sites we would consider 30% to be the minimum allowance, not 20% as shown Garages should be added into the build cost calculation. No allowance has been made for Abnormals i.e. ground contamination, requirement for foul water pumping stations. This should be included or, alternatively, the contingency should be increased accordingly.
In relation to Affordable Housing, the return is likely to be between 45% / 50% (affordable rent) and 65% / 70% (shared ownership) of open market value.
In terms of Facilities, no allowance is made for education, community, health, commercial or retail, which are likely to be required for strategic sites. This allowance should include any requirement for maintenance contributions.
No allowance is made for planning or promotion costs.
No allowance is made for Third Party Agreements, which are potentially required on a range of sites, but highly likely on the large strategic sites.
An allowance should be made for Services. These are becoming increasingly expensive particularly given the increased requirements anticipated through the Future Homes Standards Consultation.
No allowance is made for phasing. It is likely that the large strategic sites will be delivered in phases. The viability should be amended to reflect this and the finance costs revised to reflect the need for the early delivery of infrastructure.
There is a concern that the £5,000 allowance for energy efficiency measures is too low.