Draft Greater Norwich Local Plan – Part 1 The Strategy

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Comment

Draft Greater Norwich Local Plan – Part 1 The Strategy

Question 14: Do you support, object or wish to comment on the approach for housing numbers and delivery?

Representation ID: 21576

Received: 16/03/2020

Respondent: Persimmon Homes (Anglia)

Representation Summary:

There is a need to ensure that the deliverable housing commitment figure does not double count those sites proposed for allocation and those sites that already benefit from an extant planning permission, which will ensure that the housing commitment is sufficient to meet the identified need.

The South Norfolk Village Cluster sites should be considered simultaneously with the GNLP sites and not as part of a separate plan.

Comment

Draft Greater Norwich Local Plan – Part 1 The Strategy

Question 16: Do you support, object or wish to comment on the approach to Review and Five-Year Land Supply?

Representation ID: 21607

Received: 16/03/2020

Respondent: Persimmon Homes (Anglia)

Representation Summary:

The Strategy Document states that “the preferred option commits to a review of the plan after 5 years”. However, Paragraph 33 of the NPPF requires reviews of local plans and development strategies to be completed no later than five years from the adoption of the plan. The approach to review should therefore be amended to align with the aforementioned requirements of the NPPF.

Object

Draft Greater Norwich Local Plan – Part 1 The Strategy

Question 18: Do you support, object or have any comments relating to the preferred approach to sustainable communities including the requirement for a sustainability statement?

Representation ID: 21624

Received: 16/03/2020

Respondent: Persimmon Homes (Anglia)

Representation Summary:

The requirement for major developments to provide a Sustainability Statement is supported. However, the requirement for specific types of development to include a Health Impact Assessment is questioned.

Comment

Draft Greater Norwich Local Plan – Part 1 The Strategy

Question 19: Do you support, object or have any comments relating to the specific requirements of the policy?

Representation ID: 21667

Received: 16/03/2020

Respondent: Persimmon Homes (Anglia)

Representation Summary:

Various comments to Points 2, 4, 9 & 10 pf the Policy.

Comment

Draft Greater Norwich Local Plan – Part 1 The Strategy

Question 27: Do you support, object or have any comments relating to approach to affordable homes?

Representation ID: 21696

Received: 16/03/2020

Respondent: Persimmon Homes (Anglia)

Representation Summary:

Would support a housing requirement uplift.
The requirement for 33% affordable housing is questioned given that the evidence suggests 28% would be appropriate.

Object

Draft Greater Norwich Local Plan – Part 1 The Strategy

Question 28: Do you support, object or have any comments relating to the approach to space standards?

Representation ID: 21700

Received: 16/03/2020

Respondent: Persimmon Homes (Anglia)

Representation Summary:

Persimmon Homes (Anglia) acknowledge that the provision of adequate space in homes is an important element of good design and influences the take up and delivery of new housing. However, there is insufficient evidence to suggest that homes slightly below national space standards are not meeting a need and demand for this size of housing.

Object

Draft Greater Norwich Local Plan – Part 1 The Strategy

Question 32: Do you support, object or have any comments relating to the approach to Self/Custom-Build?

Representation ID: 21702

Received: 16/03/2020

Respondent: Persimmon Homes (Anglia)

Representation Summary:

Persimmon Homes (Anglia) acknowledge the role that self-build housing plays in meeting the needs of groups with specific housing requirements. However, the imposition of a requirement to provide 5% of plots on residential proposals of 40 dwellings or more is not considered to be necessary nor the most appropriate mechanism for ensuring that sufficient planning permissions are granted to meet the demand for self-build and custom housebuilding across the housing area.

Comment

Draft Greater Norwich Local Plan – Part 1 The Strategy

Question 24: Do you support, object or have any comments relating to the approach to other strategic infrastructure (energy, water, health care, schools and green infrastructure)?

Representation ID: 21742

Received: 16/03/2020

Respondent: Persimmon Homes (Anglia)

Representation Summary:

We note the Interim Viability Study does not include a typology of schemes in excess of 600 dwellings. This creates a gap in terms of taking account of the site-specific infrastructure costs of larger, strategic level housing schemes and the associated viability implications.

A lower level CIL tariff, applied to larger scale developments, should be considered in order to address this issue and support the delivery of strategic sites. Further representation will be submitted on this point in response to Question 48 of the current Regulation 18 consultation.

Comment

Draft Greater Norwich Local Plan – Part 1 The Strategy

Question 48. Do you support or object or wish to comment any other aspect of the draft plan not covered in other questions? This includes the appendices below. Please identify particular issues.

Representation ID: 21751

Received: 16/03/2020

Respondent: Persimmon Homes (Anglia)

Representation Summary:

Persimmon Homes (Anglia) will be submitting further evidence in response to the Interim Viability Study in the near future.

Comment

Draft Greater Norwich Local Plan – Part 1 The Strategy

Question 48. Do you support or object or wish to comment any other aspect of the draft plan not covered in other questions? This includes the appendices below. Please identify particular issues.

Representation ID: 23188

Received: 27/04/2020

Respondent: Persimmon Homes (Anglia)

Number of people: 4

Agent: Bidwells

Representation Summary:

Viability Inputs
127. Revenues are overstated and unsubstantiated.
128. Discounts to affordable rent tenure are too low and do not reflect registered provider bids in the current market.
129. Build costs adopted are below BCIS median rates. No explanation or rationale is provided for this.
130. Build costs make no allowance for Part L of the 2020 Building Regulations nor for
regulations M49”) and M4(3).
131. The allowance for Site and Infrastructure works is likely to prove inadequate for most schemes. This allowance should not include the cost of garages which are a build cost.
132. Benchmark land values have been reduced by 30% from the 2017 Hamson report without any reference to data, reasoning or justification. The levels adopted are likely to prevent land coming forward for development.
133. The outcome of using the inputs chosen in the interim study produces appraisals that
very significantly over-state viability.

Typologies
134. We have focussed only on Typology 9 in this report. We make no comment about any other typologies.
135. A Typology for large (1,000 unit plus) schemes should be provided accounting for the specific infrastructure and community facilities these sites are expected to provide.
136. Without this typology, the study cannot be considered complete.

Appraisals
137. Based on our review of Typology 9 only, we consider the methodology adopted in the preparation of the appraisals to be sound.
138. We cannot calculate the interest charges to match those used in the interim study, but this is not unusual when comparing viabilities.

General
139. We are concerned that the instructions to the consultant that prepared the interim study are not made clear in the report. We are also concerned that there may be a conflict of interest that has not been declared.
140. Both issues undermine the veracity of the report and its conclusions, especially when combined with the consistent adoption of inputs that improve viability.
141. We are especially concerned at the lack of background data, reasoning and justification for many of the inputs to the interim study.

142. We therefore conclude that the NPS Interim Viability Study does not provide a reliable, robust or accurate assessment of viability for the purposes of the emerging GNLP.

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