MM2 - Table 6

Comment

Representation ID: 25294

Received: 22/11/2023

Respondent: Hempnall Parish Council

Main Modification strategy - Table 6
Hempnall Parish Council ("HPC") broadly supports the changes in the figures in Table 6 which results in the halving of the housing buffer from 22% to 11%, although we would also like to see the removal of the homes forecast to be delivered under policy 7.5 (see separate submission). This reduction of the buffer should still result on the delivery of more than the national policy requirement within the Plan period, whilst providing more than necessary insurance in the revised buffer and therefore we still consider the overall housing potential to be un-necessarily large.

Comment

Representation ID: 25378

Received: 28/11/2023

Respondent: CPRE Norfolk

CPRE Norfolk broadly supports the changes in the figures in Table 6 which results in the halving of the housing buffer from 22% to 11%, although we would also like to see the removal of the homes forecast to be delivered under policy 7.5 (see separate submission). This reduction of the buffer should still result in the delivery of more than the national policy requirement within the Plan period, whilst providing more than necessary insurance in the revised buffer, and therefore we still consider the overall housing potential to be un-necessarily large.

Object

Representation ID: 25489

Received: 11/12/2023

Respondent: Wain Estates

Agent: Stantec

Support principle of MM9, Object to wider changes underpinned by MM20 reflected in updates to MM1 and MM2

In light of the letter issued from Natural England to 74 different Local Planning Authorities (including Greater Norwich) on 16th March 2023, we support the following addition to Policy 3 (MM9):

‘Within the catchments of the River Wensum Special Area of Conservation (SAC), The Broads SAC and the Broadland Ramsar: Residential development that results
in an increase in the level of overnight stays; … must provide evidence to enable the Local Planning Authority to conclude through a Habitats Regulations Assessment that the proposal will not adversely affect the integrity of sites in an unfavourable condition.’

This will ensure development is only allowed in cases where Nutrient Neutrality can be achieved through effective on and/or off-site mitigation measures and reinforces the same requirements through the Habitats Regulations and the appropriate assessment process.
Whilst we support this MM9, the implications of this with regard to housing delivery are likely to be significant. We do not consider that the MM proposed in respect of housing delivery support the Local Plan as an effective one which will achieve housing numbers required (MM20, MM1 and MM2).

In previous evidence produced by the Partnership, the view was taken that ‘given progress towards identifying mitigation solutions to address NN…the partnership considers that there would be justification to confirm a housing land supply of circa 6.05 years between 1st April 2023 and 31st March 2028’. Within MM20 (Appendix 4 – Housing Delivery Trajectory and 5-year Land Supply), this
five- year housing land supply has been reduced further. The updated calculation is for a 5.77 year supply, a ‘surplus’ of 1,687 homes.

This new 5.77 year figure accounts for a 10% buffer, which is updated and reduced from the previous 22% buffer applied. The reason for this change to the buffer is unclear however, based on NPPF paragraph 74, the 10% buffer ‘accounts for any fluctuations in the market during that year’. An Independent Report published by the Local Plans Expert Group (report to the Secretary of State)
established recommendations to help ensure efficient and effective production of Local Plans. Within this report it is recommended that Local plans should ‘make provision for and provide a mechanism for release of developable reserve sites equivalent to 20% of their housing requirement’ i.e. a 20% buffer. In the context of GNLP spatial constraints specifically, the Nutrient Neutrality catchment area within which many of the sites forming part of the Local Plan sit, it is a realistic concern that a number of the homes contributing to the 5-year supply
will be rendered undeliverable. As such the previous 22% buffer should be reinstated with contingency sites identified.

Whilst the GNLP advise that progress has been made towards Nutrient Neutrality mitigation solutions, the evidence supporting this remains limited with publicly available details scant and high level of uncertainty relating to availability, timing and costs of mitigation . The limited evidence provided suggests that the first credit solution is due to release 5,000 homes 1 however, beyond
this there is no clarification available regarding any other schemes progressed at this stage. Therefore, even with the launch of this first scheme (which has not yet formally launched and begun trading) the 5,000 homes unlocked would not be sufficient to release enough homes to meet the 5-year trajectory. The implications of Nutrient Neutrality are reflected in MM to some strategic
site allocations. For example, MM13 which shows the East Norwich Strategic Regeneration Area which was previously expected to deliver 3,230 homes by March 2038, is now reduced to 2,230.

There is a very real danger of much needed housing not being delivered at the projected rate. The previous April 2022 Housing Delivery Trajectory established ‘existing permissions and allocations’ of 1,987 in 2020/21 and 2,609 in 2021/22. However, the updated Housing Delivery Trajectory shows that ‘delivery’ of homes at 2020/21 was 1,602 – 385 (19%) less than ‘commitments’ and at 2021/22 was 1,886 – 723 (28%) less than ‘commitments’. The delivery shortfall is likely due to the aforementioned unresolved Nutrient Neutrality matters. Given that the ‘total forecast supply’ for the remainder of the plan period (to 2038) is based upon information gathered from developers and industry averages for lead-in times and sales rates for new homes, the predictions are not an absolute and are highly changeable. Compared with the previous trajectory (April 2022), the updated trajectory sees a significant uplift in figures associated with the ‘existing permissions and
allocations’ supply, particularly up to the year 2031/32. It is a justified concern that this uplift may not materialise. In this case, the contingency site at Costessey (Policy GNLP0581/2043), which is demonstrated to be both available and achievable for delivery of 800 homes with the ability to meet a Nutrient Neutrality solution on site (refer Appendix 1 – MEC Report as submitted
alongside our previous ‘Matter 4’ response), is a justified and effective addition to the Local Plan to ensure
robustness.

The updated Trajectory (Appendix 4, MM20) feeds directly into the MM2 at Table 6 which ‘establishes the Plan’s total housing potential figures’. This modification maintains a Housing requirement (2018 to 2038) of 40,541, however it includes an amended ‘Total Forecast Supply’ (previously
‘potential’) of 45,041. This forecast is reduced from the previous forecast of 49, 492 which is in part due to the
reduced ‘buffer’ applied (11%). Comparing the requirement against the forecast supply, this leaves
a buffer across the plan period of 4,500 homes (225 homes per year split across the 20-year plan period). It is our view that this buffer is not sufficient to account for impact upon supply caused by Nutrient Neutrality coupled with potential (currently unknown and unpredictable) market and political/policy changes. The importance of including the GNLP0581/2043 as an allocation, able to provide 800 homes, is clear to ensuring robustness and
flexibility of the Local Plan to respond to supply and delivery challenges. If not allocated, at the very least,
the site should be identified as a contingency site.

Comment

Representation ID: 25495

Received: 11/12/2023

Respondent: Pigeon Investment Management Ltd

Agent: Savills

The proposed modification to Row A of Table 6 of the Plan to clarify that the figure of 40,451 homes forms the 'housing requirement' is noted. The proposed modification to Row B of Table 6 to clarify that 8,728 homes were built during the years 2018/19 to 2021/22 (4 years) is also noted, as is the proposed modification to Row C to clarify that this leaves (a minimum of ) 34,668 homes to be delivered over the remainder of the plan period (2022/23 to 2033/34 - 16 years).