MM149 - Costessey Contingency Site

Object

Representation ID: 25493

Received: 11/12/2023

Respondent: Wain Estates

Agent: Stantec

Object to deletion of Costessey Contingency Site

The Council has amended the GNLP to delete section 8 which relates to the Costessey Contingency Site. Given this deletion of Policy GNLP0581/2043 supporting text at Policy 7.1 (MM13) which reads ‘ a large contingency site is identified in Costessey to be brought forward if delivery of
housing in the GNLP area does not meet local plan targets’ and paragraphs 3.20 and 3.21 (MM76) have also been deleted.

We assume that the Inspectors are in agreement that the principle of the contingency site is consistent with national policy 2 but that the issue, as raised in the Inspectors’ letter, is that the trigger mechanism is not deemed to be effective and nor could it be reasonably be made effective by modification. We respectfully disagree with this position as the suggested wording we put forward in our Matter 3 statement (repeated below) would be responsive and therefore successful in producing the desired or intended result of resolving an issue with the housing supply in the Plan:

‘The site will become an allocation for development if any of the following apply at any point in the Plan period:
a) the Council’s Housing Delivery Test shows that delivery has fallen below 95% in the previous year; or
b) if annual monitoring data indicates that forecast housing land supply falls lower than 5.5 years; or
c) net affordable housing delivery (as a percentage of overall housing delivery) falls below 28% over a period of two consecutive years’

Reference is also made in the Inspectors’ letter to there not being a need for the contingency as the housing supply will be ‘sufficient’ to meet housing needs in the Plan period.

We respectfully again disagree and therefore object to this deletion on the basis that removing this site, which could deliver up to 800 homes and supporting infrastructure on a site which, by the Council’s own assessment, is relatively unconstrained and in a sustainable location
consistent with the spatial strategy and objectives of the Plan. Deleting this contingency allocation would undermine the previously identified benefits the site presented in terms of securing flexibility and security of housing supply; which for reasons we set out above and in our earlier representations, is at risk for a number of factors including Nutrient Neutrality.

The purpose of GNLP20943/0581 as a contingency site was that when a specific trigger was met the site would become an allocation. The trigger was originally proposed as follows (we have suggested changes as above):

‘…if there are three consecutive years in which Annual Monitoring Reports show that housing completions in Greater Norwich are more than 15% below annual targets in each year and where under-delivery is the result of site specific constraints (for example there are infrastructure or ownership constraints or significant abnormal costs have been identified) preventing the delivery of committed and allocated housing sites.’

In the Inspectors response, a primary reason for the MM, omitting the contingency site, was that the ‘trigger mechanism is ineffective and could not be madereasonable by modification’

When taken against the updated Housing Delivery Trajectory Document (MM20, now Appendix 4) which establishes a residual annual housing requirement of 1990 homes, a 15% under delivery can be calculated as just 299 homes per annum. That is, any year with a delivery of 1,691 homes or less would surpass this ‘trigger’. In light of potential risks to supply, including the
implications of Nutrient Neutrality upon housing delivery at major sites within the GNLP catchment, the requirement for this contingency site is not unreasonable or unjustified.

As detailed at our response to MM9 above, Nutrient Neutrality has stalled progress and held up delivery of thousands of homes withinthe Local Plan area. The Council have acknowledged, in previous Housing Trajectories, namely that of April 20224 that of the 37,651 forecast housing supply to 2038, 23,948 of these would be impacted/delayed by Nutrient Neutrality.

The updated Housing Trajectory 5 published as part of this Main Modifications stage, ‘Appendix 4’ establishes a ‘Total Forecast Supply’ of 45,041’ which exceeds the requirement for 40,541 to 2037/38. This requirement figure accounts for average delivery 2018/19 to 2021/22 for which annual housing completions kept pace with meeting the need for 40,541 homes by 2038.
Notwithstanding this, average completion progress is based four years prior to the issue of Natural England’s Nutrient Neutrality advice. Following this advice made on 16th March, the GNLP acknowledged minimum delays of 18 months for residential schemes (as set out in our Matters 15 response, ID 24244).

At this current time progress towards certainty around Nutrient Neutrality remains limited and thus impacted development is still stalled. On 13th September 2023, 16 months following the announcement, the House of Lords voted on government proposals which were intended to unlock 100,000 homes between 2023 and 2030 in areas affected by Nutrient Neutrality. However, the necessary amendments to the LURB (now LURA) were not supported in the House of Lords and therefore were not added to the Bill. As such, Nutrient Neutrality, and the resulting delays to housing delivery remain with the Government still to make further announcements. Most recently Government has been reported to confirm that no legislative changes are on the
horizon, with no mention of the issue through the King’s Speech or the Autumn Statement, other than additional funding for mitigation through the Nutrient Mitigation Fund. Whilst the GNLP anticipated an 18-month delay, we suggest that delays are likely to be significantly greater than this as many parts of the country affected by this are still left without mitigation solutions (or at least sufficient mitigation to release all housing required to meet local plan requirements) for 4 -5 years, if not more. This could skew the housing trajectory and implicate delivery of a sufficient supply of homes, particularly in the first 5 years of the plan.

Given the uncertainty presented with regard to housing trajectory, it is critical that additional sites for housing are identified. We strongly object to the omission of the Costessey contingency site on the basis that the flexibility it affords is imperative to the effectiveness of the Local Plan.

The Sustainability Appraisal of the Main Modifications (October 2023) states that ‘new and amended policies would be expected to improve the sustainability performance of the GNLP or would have no significant change with regard to sustainability’. We disagree, not only in relation to the benefits a sustainable site in an accessible location could provide in terms of housing supply in the early years and throughout the Plan period, but also in relation to the unrealised benefits of the contingency site not coming forward, notably around education.

The proposed to be deleted allocation included a requirement that ‘approximately 4 hectares of the site should be safeguarded for education to provide a new primary school and a sixth form college in agreement with the education authority’.

As we have set out in our Matter 5 statement, which includes a Statement of Common Ground with the Local Education Authority, there is significant pressure for secondary school places in the locale, which necessitates the loss of the Ormiston Victory Academy sixth form to expand secondary provision to meet the demand from existing housing growth. Given that one of the
objectives of the Local Plan is to increase inter alia secondary school provision to facilitate this housing growth, one of the infrastructure requirements for the site at Costessey was that ‘approximately 4 hectares of the site should be safeguarded for education to provide a new
primary school and a sixth form college in agreement with the education authority’. This was agreed, as reflected within the Statement of Common Ground with the Education Authority (Appendix 2). Our Education Impact and Mitigation Assessment (EIMA), submitted at part of our Matter 5 response (Appendix 3), explores the Plan’s education requirements. Relating to Sixth Form
need the EIMA sets out that on the basis of ONS population projections, from a baseline date of mid-2021 the number of for 17 and 18 year-olds living in the Norwich, South Norfolk and Broadland District areas is predicted to increase every year until 2030. Between mid-2021 and mid-2030 a 26% increase can be expected. The demand for sixth form places is therefore expected to increase significantly in the foreseeable future. There is a need to increase the supply of Sixth
Form places in the Plan period to meet the current and planned need for housing. It is a clear requirement of National policy to deliver adequate education infrastructure (see NPPF 16, 20, 22, 24-27, 31 and 35). Despite this, there is no identified alternative site for a replacement sixth form college other than our
site. Without our site, there will be insufficient secondary or sixth form places to meet the identified growth in the Plan and will lead to unsustainable patterns of travel
given the lack of sixth form options locally. This will undermine the Plan and its objective to deliver ‘vibrant, healthy, inclusive and growing communities supported by the delivery of new homes, infrastructure’, as set out in our response to Matter 1.