Draft Local Plan-Part 2 Site Allocations

Re: Greater Norwich Local Plan – Regulation 18 Draft Plan Consultation

We write in response to the consultation of the above document.

Rosconn Strategic Land (RSL) welcome the opportunity to comment on the Draft GNLP and having reviewed the document and its supporting evidence, provide comments below. RSL represent the owners of land to the south of Flowerpot Lane, Long Stratton who we have entered into a promotion agreement with in order to promote their land for residential development. The site has not previously been considered for development by the Councils and as such, a completed Site Submission Form also accompanies these representations which demonstrates it is suitable, available and deliverable.

Part 1 – The Strategy

Question 9

RSL fully support the overall purpose of the Delivery Statement which recognises the importance of inclusive growth and sustainable development, and more specifically the acknowledgment of the interrelationship between the delivery of housing, jobs and infrastructure.

In terms of Housing, again we generally support a pro-active approach of only allocating housing sites where there is a reasonable prospect that their delivery, taking account of policy requirements in the Plan, can be evidenced. However, it is notable that approximately 83% of the minimum Local Housing Need figure is to be delivered through existing commitments, some of which are from sites already allocated in existing development plans. These existing development plans include the 2011 Joint Core Strategy, alongside subsequent Site Allocations and Area Action Plans dating from 2014-2016.

It is not clear from the evidence provided to date what proportion of the commitments are on sites for which no planning permission has yet been secured despite being allocated for several years, but there is certainly some indication that not all historic allocations are likely to remain deliverable, particularly in the context of a more stringent national planning policy framework. Furthermore, in reviewing the latest Annual Monitoring Report 2018-19, it is stated at paragraph 3.21 that despite recent successes, housing delivery overall within the Greater Norwich area has fallen 4,255 homes below the JCS target since the start of the plan period, with the under delivery resulting in housing shortfalls in the NPA that total 6,076 homes, with shortfalls particularly acute in the Broadland part of the NPA. It concludes by stating that it remains a significant challenge to achieve and sustain a level of delivery that would enable the JCS housing target to be met by 2026.

It is also notable that footnote 45 of the Delivery Statement in respect of Housing, states that housing allocations in the Draft Plan will only be carried forward to the Submission Version of the Plan if evidence is presented to show that they will be delivered by 2038. Whilst we would support this approach, we would encourage the authorities to rigorously review the deliverability of long-standing allocated housing sites which have not progressed to date. Similarly, those sites with outline planning permissions where reserved matters have not followed in a reasonable period of time should also be carefully scrutinised to determine whether they remain deliverable during the plan period.

Question 11

Again, RSL generally support the overarching approach with respect to prioritising the benefits and delivery of infrastructure in order to benefit existing communities, support growth and improve connectivity. However, alongside the other providers mentioned, recognition should also be given to the development industry’s role in bringing forward key infrastructure. They are often central to the funding and delivery of infrastructure alongside new housing and economic development, which benefits the wider community.

Question 13

Whilst RSL generally agree with the proposed settlement hierarchy, there appears to be no explanation within Policy 1 or elsewhere, as to what the purpose of the hierarchy is other than to confirm that this has been used to inform the distribution of growth. Whilst paragraph 166 confirms which settlements fall into which level of the hierarchy, there appears to be no explanation as to what the role and function of each tier in the hierarchy is. It is therefore difficult to comment on whether the proposed distribution of growth within the hierarchy is appropriate or not. It would therefore assist the reader if the role and function for each tier in the hierarchy could be clearly set out within the policy or otherwise within the explanatory text.

Notwithstanding the above, further explanation is required as to the role and function of the Stratgeic Growth Area (SGA). Whilst Policy 1 and paragraph 166 state that it is the settlement hierarchy that has guided the distribution of growth, this appears to then be contradicted by the statement at paragraph 169 which suggests that the strategy is to direct 78% of the growth to the SGA. It is therefore unclear whether it is the settlement hierarchy or the SGA that have influenced the distribution of growth and this should be clarified.

In terms of the distribution of growth, Policy 1 states that growth has been distributed in line with the settlement hierarchy to provide good access to services, employment and infrastructure. However, in reality, the majority of growth (83% of the minimum Local Housing Need) is already committed through historic allocations and existing permissions, 72% of which are within the Norwich Urban Area. Considering the overall geographical scale of the 3 authorities, this is a significant amount of development committed to a relatively small area. Whilst it is agreed that a large proportion of growth should be located in and around the principal settlement within the Plan area, directing further growth through new allocations to an area which is already well-catered for in terms of future growth is questionable, particularly from a deliverability perspective. Is it realistic to expect that the scale of growth already committed, alongside an additional 4,395 homes through new allocations is likely to be deliverable within the Plan period? The evidence referred to earlier has highlighted the real challenge to achieving the levels of growth identified for the NPA through the current JCS. Directing further growth to this area must therefore raise concerns about whether this is a justified and effective strategy. Furthermore, will this achieve the objectives set out at paragraph 164, particularly (4) focussing a reasonable level of growth in the main towns, key service centres and village clusters to support a vibrant rural economy, and (6) allocating a significant number of medium and smaller scale sites in towns and villages to provide a balanced range of site types to allow choice, assist delivery and allow smaller scale developers and builders into the market?

In summary, RSL object on the basis that further consideration should be given to directing a greater proportion of the residual housing requirement through new allocations towards the Main Towns and Key Service Centres, particularly those that are located outside the SGA in order to enable the sustainability benefits of housing growth to be distributed more widely and fairly. Settlements such as Long Stratton and Aylsham for instance play a wider role in serving a principally rural hinterland and growth can assist in maintaining and enhancing services and facilities that these wider rural communities are reliant on. This approach would remain aligned with the preferred growth option of directing the majority of growth around the Norwich Urban Area and within the SGA, whilst allowing a greater level of dispersal to support thriving rural communities. Such an approach is also likely to be more deliverable than the current “all the eggs in one basket” approach where almost all of the growth is directed to the Norwich Urban Area / SGA with very little being directed to the rural communities elsewhere within the plan area. This is not considered to be consistent with the objectives of paragraph 78 of the NPPF.

Question 14

Policy 1 states that there is a need for ‘around 40,550 new homes’ during the plan period 2018-2038. Table 6 confirms that the Local Housing Need figure, being the minimum local housing need figure as calculated using the Government’s standard methodology is 40,541 dwellings. The PPG ‘Housing and economic needs assessment’ states at paragraph 2 that the standard method identifies a minimum annual housing need figure but does not produce a housing requirement figure. Paragraph 10 then explains when it may be appropriate to plan for a higher housing need figure than the standard method indicates. It also reiterates the Government’s commitment to more homes being built and support for ambitious authorities who want to plan for growth. In also confirming that the local housing need figure provides only a minimum starting point in determining the number of homes needed in an area, it acknowledges that it does not attempt to predict the impact of future government policies, changing economic circumstances or other factors that might have an impact on demographic behaviour. As such, it then outlines some of the circumstances where it may be appropriate to plan for a higher number of houses. This includes where growth strategies are proposed (e.g. Housing Deals), strategic infrastructure is planned or where an authority agree to take on unmet need from a neighbouring authority.

RSL consider that the housing requirement set out in the Plan should be described as a minimum and not be seen as a ceiling on a greater level of housing coming forward during the Plan period, so that it is consistent with the NPPF’s focus on significantly boosting the supply of housing. It is also considered that the housing requirement within the Draft Plan does not reflect government guidance in that it only proposes to meet the minimum starting point figure and no evidence has been provided to support why this decision has been made or why it is considered to be appropriate. It is notable that the Draft Plan also sets an objective to deliver around 33,000 new jobs by 2038, this target being derived from an analysis of ‘enhanced growth’.

The Strategy Advice document of December 2017 highlights that the detailed assessment of the Greater Norwich sub-region set out within the Employment Land Assessment confirms the considerable potential of the area in the future to achieve significant levels of economic growth based on an assessment of the key economic assets and drivers within the Greater Norwich economy. It continues that these strengths suggest that the growth potential of Greater Norwich extends beyond ‘business as usual’ base growth, leading to GVA’s assessment which identifies an ‘enhanced’ growth scenario that maximise the area’s economic growth potential. This is due to the area having a strong foundation of academic and commercial research, an increasingly entrepreneurial economy, a base of internationally recognised businesses and a diverse property portfolio which suggest Greater Norwich is well positioned nationally and internationally to compete for future business investment as well as continuing to grow its own business base. The document does however highlight at paragraph 2.7 that the base model used to develop the future employment growth does include an assumed level of population growth to balance jobs growth with labour supply and migration, albeit recognising this does not necessarily align with objectively assessed housing needs.

Policy 6 later on in the Draft Plan further elaborates on the proposed economic growth strategy for the area which makes reference to supporting and delivering the ambitions of a series of other related strategies such as the LEP’s Economic Strategy and Local Industrial Strategy, the Cambridge Norwich Tech Corridor initiative and the enhanced growth outlined in the Greater Norwich City Deal, as well as acknowledging the wider benefits of linkages to the Oxford Cambridge Arc and the London Stansted Cambridge corridor.

In such circumstances, RSL object and consider that the authorities should consider a meaningful uplift to the minimum Local Housing Need figure to help support and deliver the ambitious, above-trend economic growth strategy that the Draft Plan is seeking to deliver.

In other respects, reference is made at paragraph 159 to the fact that the housing figures within Policy 1 make provision for a 9% buffer over and above the minimum Local Housing Need figure. Notwithstanding comments above regarding the need to uplift the housing requirement to reflect economic growth aspirations, 9% is not considered to be sufficient when considered in the context of the overall scale of housing need within the 3 authorities and the fact the majority of this is being met by long-standing housing allocations many of which have failed to come forward as planned. In such circumstances, RSL object and consider a much larger buffer of 20% would be more appropriate to ensure there is flexibility in the housing supply to respond to rapid changes, as required by paragraph 11 of the NPPF.

It is acknowledged that some additional flexibility is offered, as detailed at paragraph 162 with reference to a proposed contingency site for 1,000 dwellings at Costessey and potentially a further 1,000 dwellings contingency site at Wymondham, albeit no specific site has been identified at present. Whilst RSL are supportive of the principle of identifying contingency sites, we do object to the approach to allocating such large strategic sites and the decision on where such sites should be located. Contingency sites should, by their very nature, be ‘oven-ready’ sites that could be delivered quickly in order to meet a shortfall in the housing land supply until such time as allocated sites are able to deliver. Allocating one or two strategic sites of 1,000 dwellings are likely to face similar difficulties to the sites they are seeking to supplement in view of longer lead-in times compared to smaller sites. A more credible solution would be to identify a greater number of smaller sites in a variety of locations that could collectively bring forward housing quickly to address short term shortfalls in housing supply. Geographically, as highlighted earlier in our representations, identifying contingency sites in the same location as the majority of allocated housing sites is more than likely to result in a similar fate. A much more credible approach would be to identify contingency sites in a range of locations across the Plan area to maximise their ability to address a rapid change in circumstances and avoid any potential localised issues that may arise in the housing market, such as absorption rates in the Norwich Urban Area as a result of multiple housing sites competing against each other in a very small geographical area. Therefore, distribution of some or all of the contingency sites outside the Norwich Urban Area may be a more effective and justified approach than the one currently proposed.

Question 15

In connection with our response to Question 14 above, it is not clear whether the economic growth ambitions of Policy 6 are fully consistent with the housing requirement set out within the Plan. Moreover, is there any evidence to indicate that 40,541 dwellings in the period to 2038 is sufficient to support the economic aspirations of the emerging Plan to 2038? Until such time as this is clarified, we wish to maintain an objection that the economic objectives are not deliverable, justified or effective due to a lack of suitable housing for the employees required to service future jobs growth or otherwise, there is likely to be an increase in in-commuting to the area from outside in order to service these newly arising jobs which would not be a sustainable approach to adopt.

Question 16

RSL support the intention that the five-year housing land supply should be calculated on the basis of the whole of the Greater Norwich area.

Question 42

RSL wish to comment on Policy 7.2 and the associated text with specific reference to Long Stratton. At paragraph 326, it is stated that due to the scale of existing commitments in the settlement, the Plan does not make any further allocations in addition to Long Stratton’s Action Area Plan. It then goes on to state that evidence shows that the scale of commitments means that parts of the site allocated in the AAP will not be delivered until after 2038. We cannot locate the evidence referred to at footnote 104 ‘Analysis of Commitments’ and the Councils have been unable to confirm where this is located.

In reviewing the circumstances, it is clear that the allocation of land to the east of Long Stratton in the AAP (2016) for approximately 1,800 dwellings was in order to aid the delivery of the Long Stratton bypass. The AAP seeks the delivery of at least 1,800 dwellings by 2026, with no more than 250 dwellings to be occupied until such time as the bypass is completed. Funding for the bypass, as detailed within the AAP, is to be from a number of sources including developer contributions (S106/CIL). Clearly the development itself is unable to fully fund the cost of the bypass, particularly as it is to be completed in advance of the majority of housing being completed. Of the total budget of £29m, it is understood that £10m has already been secured via the City Deal, but the remaining £19m has yet to be secured. The construction of the bypass had originally intended to start in 2020 with completion by 2022. More recent evidence suggests construction will now start in 2020.

In terms of the delivery of the 1,800 dwellings and associated bypass, two planning applications were made in January 2018 for the two principal elements of the overall development and the bypass. These applications however remain undetermined as they are the subject of a holding objection from the Highways Agency in view of the potential implications of the wider development on the operation of the A47 trunk road and in particular its junction with the A140. As such, it appears unlikely that the bypass will commence construction during 2020.

As such, it is apparent that the strategic allocation at Long Stratton has been severely delayed, as has progress on delivering the bypass. It is therefore unlikely that any meaningful housing numbers will be delivered from these sites within the next 5 years and it is difficult to see more than 100 dwellings being delivered by 2026 compared with the 1,800 envisaged in the 2016 AAP. Furthermore, there is serious doubt about whether any meaningful development will be delivered from this site by 2038 and probably significantly less than has been assumed when determining commitments from this particular allocation. However, the AMR 2018/19 does not provide sufficient detail to determine what has been assumed to contribute towards the overall housing commitment identified within Policy 1 and the ‘Analysis of Commitments’ referred to at paragraph 326 cannot be provided by the Councils at this time.

The implications of a failure to bring forward the strategic allocation at Long Stratton, alongside the delivery of the bypass have serious consequences for the settlement and the wider area in a number of ways which have serious social, economic and environmental consequences. In such circumstances, RSL consider that scope to bring forward a further housing site within the settlement should be given serious consideration. This would have potential benefits in helping to address short term local housing needs, provides scope to provide additional funding to address the funding gap for the bypass, whilst making a meaningful contribution to the wider delivery of housing within the Greater Norwich area in a highly sustainable location that aligns with the overall spatial strategy of the emerging Local Plan.

RSL are promoting land to the south of Flowerpot Lane, Long Stratton and further details of this site are provided in the separate Call for Sites submission in view of the fact the land has not been promoted previously. This is an unconstrained site which is well-related to the south western edge of the settlement and is available, deliverable and suitable. It offers scope for a smaller site for approximately 150 dwellings, or a larger scheme in the region of 700 dwellings. RSL would welcome the opportunity of discussing the site’s potential in greater detail with the authorities.

Part 2 – Site Allocations

In respect of Long Stratton, RSL wish to object to the fact that no allocations are proposed within the Part 2 Draft Plan. The reasoning for the Councils approach on this matter is that, despite the settlement being identified as a Main Town, there is already a total deliverable housing commitment for Long Stratton of 1,892 homes between 2018-2038.

As highlighted in our comments to Part 1, there are no deliverable planning permissions in respect of the sites allocated at Long Stratton within the Action Area Plan (2 planning applications are pending since January 2018). Paragraph 326 of Part 1 of the Draft Plan also confirms that evidence (which is not available) shows that the scale of the commitments means that part of the site allocated in the AAP will not be delivered until after 2038. It also confirms there may be additional capacity within the existing allocations but these are unlikely to be delivered until late in the plan period or beyond. Finally, it is also apparent that the bypass that is required to help deliver the existing commitments has been delayed and is not fully funded, which calls into question whether this is likely to further undermine the timely delivery of these existing sites unless the funding gap of circa £19m can be found. In the circumstances, RSL are concerned that the approach adopted is not sound, both in respect of the fact that the overall housing requirement for the authorities may not be achievable and that housing growth and the associated benefits within Long Stratton, one of the plan area’s most sustainable settlements, may not be achieved.

In considering ‘Reasonable Alternatives’, it is noted that the Part 2 document states “No Reasonable Alternative Sites”. However, the accompanying ‘Main Towns Assessment Booklet’ for Long Stratton concludes that following detailed assessment, 3 sites were identified as reasonable alternatives, but later in the document it states that in order to allow permitted housing sites in Long Stratton to be developed and existing service capacity to be clarified, there will be no new allocations in the GNLP. As such, it concludes that it considers there are no reasonable alternatives to this approach.

In light of the circumstances, in that the delivery of the allocated (but not permitted) sites is unlikely to occur fully during the Plan period, considering reasonable alternatives is clearly an alternative approach that should have been considered as part of the Plan-making process. This is particularly important if such alternatives are able to assist in helping to contribute towards addressing the current funding gap that exists in respect of the bypass, critical to facilitating planned growth and the associated benefits for existing residents and other road users.

In considering reasonable alternatives, RSL request that the land south of Flowerpot Lane, Long Stratton should also be considered in these terms. Whilst the site has not been previously considered through the HELAA, we enclose a copy of a completed Call for Sites submission form and OS Plan which provide further details of the site. These demonstrate the suitability, availability and deliverability of the site which is well-related to the urban area and capable of being brough forward in full during the Plan period. Importantly, it can also make a meaningful contribution towards funding the Long Stratton bypass, thereby helping to facilitate the delivery of wider strategic growth in the area.
We trust the above comments are of assistance and we welcome the opportunity to engage further during the preparation of the Greater Norwich Local Plan and/or to discuss our site in further detail with you. If in the meantime there are any queries or further information is required, please do not hesitate to contact me.