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0581 2043 Policy
Representation ID: 24244
Received: 22/03/2021
Respondent: Terra Strategic
Number of people: 2
Agent: Barton Willmore
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
The Site is currently allocated as part of draft Policy GNLP0581/2043 as a contingency site for residential-led development. For the avoidance of doubt, Terra Strategic control the northern section of the allocation, which has the site reference: GNLP0581. This area of land has the ability to deliver approximately 600 dwellings alongside a primary school, sixth form college and local centre. The Site is allocated alongside adjacent site ref: GNLP2043 (North of New Road, east of A47), which will deliver an additional 200 dwellings – approximately 800 dwellings across the draft allocation. Terra Strategic are in discussions with the adjoining landowners with a Masterplan provided at Appendix 1 which details how the two parcels of land could come forward.
As currently drafted, the Site would come forward for development if there were 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
As will be set out within these representations, this approach is considered to be unsound and should instead be identified as a full allocation within the forthcoming GNLP as an available, suitable and sustainable location to deliver residential-led development.
See attachment for full representation
As it currently stands, the site will become an allocation 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”.
The policy is unsound in its current form due to the proposed trigger mechanism which would allow the site to come forward. In particular, through Examination of the Local Plan, the Council should have robustly assessed the ‘site specific constraints’ of the alternative commitments and allocations. Indeed, the draft Delivery Statement sets out a pro-active approach to delivery through only allocating housing sites where a reasonable prospect of delivery can be evidenced. As a result, this requirement should be deleted and instead focused on any subsequent shortfall in housing delivery.
The PPG sets out that from the day following publication of the Housing Delivery Test measurement, where delivery of housing has fallen below the housing requirement, certain policies set out in the
NPPF will apply. Depending on the level of delivery, this states that the LPA should publish an action plan if housing delivery falls below 95% (NPPF, para 75).
To ensure consistency with the national policy and guidance, the following policy wording is suggested:
The site will become an allocation if the Council’s Housing Delivery Test trajectory shows that delivery is expected to fall below 95% 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.
See full detail in attachment
In response to the Regulation 19 Pre-submission Draft Plan, please find attached form, letter and appended Masterplan. Terra Strategic have interests in land on the edge of Costessey, referred to as ‘Land off Bawburgh Lane, Costessey’.
