Draft Greater Norwich Local Plan – Part 1 The Strategy

Flexibility should be provided within the Policy to deviate from the stated percentages, should unforeseen circumstances arise that threaten the viability of a site, or where there are changes in the most up-to-date evidence of need. In this regard, the Policy should delete reference to the words ‘at least’ as affordable housing requirements should not be expressed as minimums.

In accordance with PPG requirements, space standards should only be introduced where there is robust evidence to demonstrate that they are required. The evidence referenced within the draft Plan indicates that, in fact, 75% of homes in Greater Norwich were delivered to the necessary standards between 2016-2018, which calls into question the need for a policy requiring strict adherence.

Notwithstanding the above, the policy should include flexibility in its wording to allow delivery of homes that are below the space standards, where they are well-designed and meet specific needs.

The proposal to require all developments of 40+ dwellings to provide 5% of plots as serviced self/custom build plots is considered inappropriate and unjustified. The supporting text indicates that at present there are 113 people on the Self Build Register in the Greater Norwich Area. The proposed policy will result in a level of supply which significantly exceeds the demand. Furthermore, particularly for the larger sites, it will have a significant impact on continuity in delivery, which is critical for both the developers and for the Councils in ensuring they are able to maintain a 5-year land supply.

In addition, it may make it difficult to achieve a well-integrated development from a design perspective.

Self/Custom Build plots should be secured on a site-by-site basis, dependent on local need at the time of the development, or alternatively an exception site approach could be taken to stimulate supply.

We strongly support the proposed allocation of an additional 1200 dwellings (minimum) at White House Farm, Sprowston. The site has previously been demonstrated, through earlier Representations and a Delivery Statement, to be suitable, available and viable for up to 1350 dwellings, and the Consortium have an excellent track-record of delivery in the immediate area. The site is highly sustainable and a logical location for further growth, being well-related to services and employment opportunities. This allocation will provide continuity in delivery for the three housebuilders, and assist in providing an appropriate buffer to safeguard against any potential under-delivery of other sites.

The Consortium have reviewed the Interim Viability Study (November 2019) and have a number of comments. Of particular concern is the lack of consideration given to strategic-scale sites (i.e. 1000+ dwellings). The largest scale development typology is 600 units, which is significantly smaller than the scale of development proposed on a number of sites, including site GNLP0132, and therefore not a reliable or robust comparator. Furthermore, no allowance is included for the provision of strategic infrastructure on larger sites.

In addition, the timing of the CIL Review is such that any comments regarding viability must be accepted on the basis of the current regime, and the outcome of the CIL Review may have significant implications on viability, and this must be acknowledged by the Councils.

This policy approach is supported, and accords with the NPPF.