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:

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.

Full text:

The housing commitment numbers reflect the proposed growth distribution of the Settlement Hierarcy, which is supported. The approach to housing numbers appears to be sound, but we note that the draft plan proposes to allocate sites that already have the benefit of having been granted planning consent. 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 approach to providing allocations in village clusters in South Norfolk within a separate plan is questioned and serves to add uncertainty regarding the ability of the plan to allocate sufficient sites to meet housing need across the Greater Norwich area over the plan period. A better approach would be to run consultation on all GNLP sites simultaneously.

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:

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.

Full text:

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:

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.

Full text:

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.

Any requirements for new health care or sports facilities to support the scale of new development in Greater Norwich should be identified strategically in the preparation of the Local Plan and allocation of sites, in consultation with the NHS. Where large scale development (100+ homes) is proposed on unallocated sites then there would be greater justification to require applications to be supported by a bespoke Health Impact Assessment, but further guidance must be provided to understand the level of detail that would be required under such circumstances.

Where a need for health care infrastructure has been identified, whether through the Local Plan process or submission of HIAs on unallocated sites, funding should be delivered through the Community Infrastructure Levy.

Appropriate development management policies on design, open space and access can achieve the aim of ensuring schemes give new communities the best opportunity to live healthy and active lifestyles. These policies can be addressed generally within the Design and Access Statement rather than a separate Health Impact Assessment.

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:

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

Full text:

Point 2: Persimmon Homes (Anglia) recognise the importance of delivering new and changing technologies in terms of supporting a healthy economy, satisfying modern business needs and for social well-being.

With respect to electric vehicles, Persimmon Homes (Anglia) acknowledge the environmental importance of ensuring that all new cars are effectively zero emissions by 2040 and share the Government’s ambition to achieve this target. We also recognise that the transition to electric vehicles is still at a relatively early stage of development and, as such, the existing electricity network may be limited in terms of accommodating electric vehicle charging with respect to the associated increase in domestic energy demand that such provision is likely to generate.

Policy 2 must therefore be informed through consultation with UKPN to ensure that the associated requirements are deliverable without creating any unsustainable pressure upon the network.

Whilst the delivery of new and changing technologies is supported, these must be factored into the Council’s Viability Report as they will undoubtedly carry cost implications for new development.

Point 4: The approach to encouraging higher densities in more sustainable locations is supported, but it is considered that indicative minimum densities across the plan area should be higher, especially if the policy objective of making efficient use of land is to be realised. It is considered that a minimum indicative density of 30 dwellings per hectare would be more appropriate in this respect, but that the Policy should acknowledge the suitability for higher densities more generally, for example in town centres where sustainable transport links and good access to jobs/services are more likely to be available.

Persimmon Homes (Anglia) does not consider that additional Strategic Gaps need to be designated. Since the existing Strategic Gaps were designated based on high level landscape assessment, policies should include sufficient flexibility to enable development in the Strategic Gaps where site specific LVIAs demonstrate there would not be a significant adverse impact.

Points 9 & 10: In terms of water efficiency and energy demand, Persimmon Homes (Anglia) would support a policy approach that delivers consistency with the most up-to-date Building Regulation standards. In this respect, the Policy must be updated to take account of Part L of the Building Regs (future homes standard) once this has been formally implemented. The update to Part L of the Building Regulation may include a requirement for 31% reduction in carbon emissions compared to the current standard. It is imperative that the Council’s Viability Report makes an assessment of the potential cost implications of the amended Building Regulations (Part L).

Moving forward, between now and adoption, there needs to be a mechanism enabling continual review of any further change to national regulations that might carry implications for development viability so that these can be captured in the plan making process.

Persimmon Homes (Anglia) recognise the contribution that battery storage can make in terms of enhancing energy resilience. However, at present, the costs of providing such infrastructure are high and the industry is hampered by a skills/knowledge gap. An opportunity exists for local government to work collaboratively with developers to help research and fund energy storage schemes through pilot projects. Such an approach should be adopted before this aspect of the policy is taken forward.

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:

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

Full text:

Persimmon Homes (Anglia) prides itself on building market homes that are more affordable by those on average household incomes as well as playing a significant role in delivering affordable rent and low cost home ownership tenures for those households whose needs are not met by the market. Persimmon Homes would support an appropriate housing requirement uplift to ensure delivery of the full affordable housing need to compensate for lack of delivery on small and unviable sites. Increasing the housing requirement would in itself increase competition and improve affordability of market housing.

If a higher affordable housing percentage is adopted as proposed under Policy 5, this could have an effect on the viability of some sites. In these cases, the policy should be clear that flexibility on percentage and tenure will be accommodated where there is reasonable justification as part of normal negotiations with Officers without the need for rigorous open book assessments which create uncertainty, expense and delay in delivering housing.

Persimmon Homes (Anglia) also question the justification for applying 33% affordable housing across the plan area, except in Norwich City Centre where the requirement is for 28%. As highlighted in Paragraph 241 of the Strategy Document, the Strategic Housing Market Assessment 2017 identifies a need for 28% affordable housing as a percentage of the total housing need. We therefore question the justification for introducing a higher affordable housing requirement across the plan area.

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:

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.

Full text:

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.

The Council’s approach of collating evidence of the size of dwellings completed does not, in itself, accurately and robustly reflect need, the requirement for which is set out in the NPPG or local demand as set out in the NPPG. The evidence base should also take account of market indicators such as quality of life impacts or reduced sales in areas where the standards are not currently being met.

There is no evidence provided that the size of the homes being completed are not meeting the housing needs of those purchasing them or that these homes are struggling to be sold in comparison to homes that do meet the standards. In terms of supporting evidence, the Council largely base its assessment upon a sample size of 245 homes across the Greater Norwich Area, the results of which show that 75% of homes have achieved NDSS GIA requirements.

The Council’s evidence base fails to take account of market information reflecting customer levels of satisfaction for new homes. In neglecting to take account of customer satisfaction levels, the Council have failed to demonstrate a need to adopt an internal space standard, as required by the NPPF (footnote 46).

Persimmon Homes (Anglia) does not therefore support the introduction of residential space standards and take the view that there is a lack of evidence to demonstrate a need to adopt space standards in Greater Norwich. Persimmon Homes prides itself on building well-designed homes that are more affordable by those on average household incomes, helping many households step onto the housing ladder. The adoption of residential space standards would worsen affordability issues and reduce the overall number of homes delivered. If space standards are to be introduced it is suggested that a more appropriate approach would be to require a proportion of new homes to be built to NDSS. This would then enable the continued delivery of well-designed, smaller and more affordable units to meet local household need.

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:

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.

Full text:

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.

There is concern that such a requirement is likely to deliver self-build plots on large house building sites whereas the demand for self-build plots is more likely to be for individual plots in more rural locations. Furthermore, as highlighted in Paragraph 250 of the Strategy Document, in 2018/19 there were only 113 people on the registers in Greater Norwich. The proposed policy is therefore likely to result in the delivery of a large number of self-build plots that far exceeds the level of self-build demand in the housing area. In turn, this could result in self-build plots left empty where they are not sold, which would be to the detriment of neighbouring dwellings and the development as a whole.

Furthermore, by their very nature, self-build houses afford an opportunity to customise and achieve bespoke design to satisfy specific needs and circumstances of an individual. Persimmon Homes (Anglia) are therefore concerned with the design implications of allowing a limited number of bespoke dwellings with regards to their relationship with the character and appearance of the wider development. It is considered that self-build housing would be more appropriately delivered as part of smaller housing schemes or housing schemes that are exclusively self-build. Persimmon Homes (Anglia) therefore echo the comments of the HBF in taking the view that a more effective approach to meeting the needs of self-builders would be through Policy 7.5, but with an adjustment to allow developments of up to 5 dwellings.

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:

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.

Full text:

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:

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

Full text:

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:

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.

Full text:

Also submitted by Bidwells on behalf of Consortium.

See attachment for full submission

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