Comment

Representation ID: 21904

Received: 12/03/2020

Respondent: Home Builders Federation

Housing needs and supply
In arriving at the local housing needs assessment (LHNA) for the Greater Norwich area the Councils have used the annual household growth between 2019 and 2029. Whilst we recognise that the Government states that the current year should be the base date from which to assess needs if the Councils wish to start their plan from 2018 then it would be logical for the base period of the assessment of household growth to be the 2018 to 2028 period. This would result in a LHNA of 41,040. Slightly higher than the 40,550-figure suggested by the Council.
It will also be necessary for the Council to liaise with neighbouring areas to ensure that they are meeting their housing needs and that they will not need to deliver additional units in line with paragraph 60 of the NPPF. The Council will also need to consider whether the proposed level of housing delivery will support the Councils’ jobs growth expectations. Planning Practice Guidance outlines that there will be circumstances where it will be necessary to consider whether housing need is actually higher than the stand method indicates. One such circumstances is where there are growth strategies for the area. The Greater Norwich Local Plan seeks to deliver an additional 33,000 jobs over the plan period and it will be necessary for the Council to ensure that its proposed housing requirement is sufficient to support the level of jobs growth anticipated.
It is also unclear as to whether the GNLP will ensure the delivery of sufficient homes to meet the targets established in the City Deal. This committed the Greater Norwich authorities to delivering 37,000 between 2008 to 2026. The Authority Monitoring Reports (AMR) for the Greater Norwich area indicate that between 2008/09 and 2018/19 some 18,287 new homes were delivered. Th is leaves a further 18,722 left to deliver by 2026. On the basis of the proposed requirement of 2,027 dpa there will be a shortfall of circa 6,500 homes. It will therefore be important that the Councils seek to ensure that there are sufficient sites allocated in GNLP that can deliver homes in the first five years post adoption to meet the commitments in the City Deal.
With regard to the delivery of new homes to meet needs we welcome the Councils’ decision to include a buffer of 9%. In addition, we note that the Council has not included
any windfall within its assessment of supply which will also provide an additional buffer. We note that a contingency site has been included at Costessey. Whilst we have no objections to its inclusion it would be sensible to include some smaller sites as contingency that could be brought forward more quickly should any of the larger sites not come forward as expected.