It is requested that Policy 1 includes confirmation that the circumstances identified in Paragraphs 010 and 024 of Id.2a of the Planning Practice Guidance are included in the housing target for Draft GNLP e.g. adjustments for economic growth, strategic infrastructure and to meet affordable housing needs. It is also requested that an additional contingency site is identified at Wymondham to address low housing delivery rates if that occurs in the future.

Policy 1 sets out the proposed housing target for the period between 2018 and 2038 and defines the settlement hierarchy and distribution strategy for Draft GNLP.
It is acknowledged that the proposed housing target in Policy 1 is derived from the standard method for calculating local housing needs, as required by Paragraph 60 of the NPPF. The proposed housing target includes a 22% buffer above the figure derived from the standard method. However, what is not certain is whether how the buffer has been calculated is consistent with national guidance.
Section Id.2a of the Planning Practice Guidance explains how housing and economic needs assessments should be undertaken, including how to calculate local housing needs using the standard method. Paragraph 010 of Id.2a makes it clear that the standard method is the minimum starting point for determining local housing needs and acknowledges that there may be circumstances where actual housing need is higher than the standard method indicates. As set out in Paragraph 010 the circumstances where increases to housing need that exceed past trends are as follows:
• Where there is a growth strategy in place to promote and facilitate additional growth;
• Where strategic infrastructure improvements are likely to lead to an increase in the number of homes needed locally; and
• Where an authority has agreed to accommodate unmet housing needs from a neighbouring area.
Greater Norwich is within the Cambridge Norwich Tech Corridor and there is a Greater Norwich City Deal, which indicates that that two of the circumstances – growth strategy and infrastructure improvements – apply to the housing target for Draft GNLP, and adjustments should have been considered and assessed. It is not clear that these factors have been taken into account for the housing target in Policy 1. It is requested that Draft GNLP includes confirmation that the circumstances identified in Paragraph 010 of Id.2a are included in the housing target in Policy 1.
Paragraph 024 of Id.2a explains how the need for affordable housing is calculated, and it is suggested that the overall housing target should be increased where it could help deliver the required number of affordable homes. The latest published Annual Monitoring Report (January 202) includes data on the delivery of affordable housing. The affordable housing completions data shows that delivery is below targets in both percentage and absolute terms overall. The data shows that across Greater Norwich there is a shortfall in the delivery of affordable housing of 449 dwellings. Paragraph 3.26 in the AMR notes some of the challenges of delivering affordable housing, including that affordable housing is not required from non-major developments and the redevelopment of vacant buildings or prior approval of office buildings, and it also notes that viability is an issue for some sites. It is not clear whether the housing requirement for Draft GNLP has considered an uplift to meet affordable housing needs. It is requested that the draft version of GNLP includes confirmation that an uplift to the housing requirement to meet affordable housing needs has been considered and assessed.
The supporting text to Policy 1 also refers to a proposed contingency site, for 800 dwellings at land off Bawburgh Lane and New Road in Costessey (Site Ref. GNLP GNLP0581). As set out in the representations to the Delivery Statement, there a number of constraints to development at this site including transport impacts and it is considered that a single large contingency site in one settlement will not be effective in addressing a housing land supply shortfall in the short term. There are a number of actions that will need to be completed before the contingency site delivers any housing. It is unlikely that housing would be delivered at the proposed contingency site to make a meaningful contribution to the housing supply to address low housing delivery rates. It is considered that a number of contingency sites should be identified in a variety of locations, and that the trigger mechanism for the contingency approach is activated earlier than three years.