GNLP 2045 Regulation 20 Scoping Consultation

Additional strengths that should be recognised include the established three-tier settlement hierarchy which provides a clear spatial framework for growth, and the ability for land to be assessed and allocated on its actual merits rather than through blanket restriction. The plan area benefits from geographic balance and multi-directional growth potential, avoiding over-concentration of development pressure, alongside good public transport and rail connectivity serving settlements across the area and meeting sustainable location criteria. There is capacity to deliver housing across a broad range of scales, densities and tenures capable of matching full identified need, while varied environmental catchments create early-delivery opportunities in some locations while compliance solutions are progressed elsewhere.
Additional weaknesses include the material reduction in deliverable housing supply caused by nutrient neutrality and Special Area of Conservation constraints, and limited capacity for further significant brownfield intensification within the urban core. The uneven distribution of infrastructure and service capacity across the plan area restricts where and how quickly growth can come forward, while surface water drainage and flood risk constraints affect key growth corridors. Affordability gaps limit delivery of the required housing mix without policy flexibility or subsidy, and multi-authority governance introduces coordination challenges, inconsistent policy interpretation and slower decision-making.
Important opportunities to recognise include national planning policy changes that allow for a more flexible growth strategy, and major road infrastructure improvements that will increase capacity for growth in connected locations. The rising statutory housing requirement including the mandatory buffer means existing allocations are now mathematically insufficient to meet the baseline, while the GNLP review and Call for Sites process provides a formal opportunity to update housing numbers and identify additional suitable land through to 2045. Demonstration of less than five years' effective housing land supply triggers national policy provisions and the presumption in favour of sustainable development, while emerging plan-wide environmental mitigation frameworks offer the potential to reduce per-site costs and remove delivery barriers at scale.
Key threats include significant utilities and water resource constraints that limit growth, alongside evolving environmental regulations and tightening catchment standards that could render existing allocations undeliverable retrospectively. Rising infrastructure and developer contribution costs are outpacing land value growth and eroding viability across the plan area, while long lead times and capacity deficits in utilities and water infrastructure risk delays beyond the plan timetable. Protected landscape and environmental designations severely restrict available growth directions, and policy uncertainty or legal challenge to the plan strategy risks delaying examination and implementation. Local opposition to settlement edge extensions creates reliance on demonstrating national policy need over purely local acceptability.
In summary, the adopted strategy was built on assumptions that are no longer valid. Deliverable supply has fallen due to environmental constraints, statutory housing need has risen, and national policy now engages to favour additional release. The original GNLP baseline is mathematically and environmentally unable to meet the requirement, and the plan must therefore allocate more land across a balanced geography to restore supply resilience, spread infrastructure costs, and deliver homes at the scale the law now demands.

There is key baseline data that should be incorporated into the evidence base to ensure the SWOT and analysis of key issues is complete. Only 4.85 years' deliverable housing land supply is currently available, which falls below the statutory five-year requirement, while approximately 2,405 homes have effectively been removed from deliverable supply due to nutrient neutrality constraints. The new national housing need methodology introduced in December 2024 raises the baseline figure materially above the numbers used in the adopted GNLP. There is also a significant historic shortfall, with approximately 8,727 homes undershot since 2011, meaning the current trajectory will fail to meet even the original 2038 target.
Large areas of the plan area are covered by environmental designations including the Broads, AONB, SAC, SPA and Ramsar sites which restrict growth directions, while nutrient mitigation costs and availability directly determine whether individual sites can come forward. Surface water drainage and flood risk constraints further limit capacity in key growth corridors. An infrastructure funding gap has been confirmed, meaning that S106 and Community Infrastructure Levy revenue alone cannot fund all required strategic works, and utilities and water capacity deficits exist with connection lead times estimated at three to five years or more. House price-to-earnings affordability ratios of between 7.0 and 9.2 mean that standard policy contribution requirements risk rendering sites unviable without adjustment. Additional factors including an ageing population driving rising specialist housing need, neighbourhood plan restrictions that cap growth at local level, and potential devolution reforms altering funding and decision-making arrangements during the plan period should also be acknowledged.
The key conclusion to draw is that housing need is rising, deliverable supply is falling, and infrastructure funding cannot bridge the gap alone. These facts mean that existing allocations are mathematically insufficient, and this reality must be clearly reflected in the SWOT analysis and assessment of key issues.

We broadly support the proposed structure and welcome the shift to a streamlined, digital map-based plan built around measurable outcomes. The three core components comprising the growth strategy and settlement hierarchy, site allocations, and targeted local policies provide a sound foundation upon which to build.
There are, however, important refinements that should be made to ensure the structure is fit for purpose. The growth strategy must open with explicit presentation of the evidence gap, clearly stating the statutory housing requirement, supply lost to environmental constraints, and the historic delivery backlog, so that the settlement hierarchy and distribution of allocations are justified against actual need rather than outdated figures. The settlement hierarchy section should indicate capacity ranges rather than simply setting distribution percentages, showing how much growth each tier can accommodate and confirming that existing caps will be raised to meet the rising requirement rather than retained at levels that are already demonstrably insufficient.
The site allocations section should include supporting deliverability data alongside mapping, indicating phasing, known constraints and infrastructure requirements for allocated sites so that the plan demonstrates a realistic delivery trajectory rather than presenting only a list of locations. Local policies should be targeted to address the unique local constraints that national policy does not resolve, specifically nutrient mitigation, infrastructure funding mechanisms, and viability flexibility, as these are the matters currently blocking delivery across the area. Finally, measurable outcomes should include annual delivery rates and the position of the five-year housing land supply so that the plan can be held to account on whether homes are actually being built at the required pace.
In summary, the proposed structure is welcome but must embed evidence of the supply gap and address known delivery barriers. Without these adjustments, the plan risks being structurally sound but mathematically insufficient, repeating the shortfalls of the plan it replaces.

The principle of the four-tier settlement hierarchy has worked well and provides a logical and generally sustainable spatial framework that remains fit for purpose. The Main Towns tier in particular has performed strongly, exceeding its targeted share of growth by delivering eighteen percent against a target of fifteen percent, demonstrating that settlements at this scale can absorb growth sustainably. Overall housing delivery across the plan period to date has been marginally ahead of target at 14,803 completions against a planned 14,078, and the approach of aligning housing allocations with strategic employment sites has successfully supported sustainable travel patterns and economic growth.
Aspects of the strategy that have not worked well relate primarily to the distribution percentages and caps set at each tier, particularly within Key Service Centres and Village Clusters where delivery rates are nearly double the original planned figures, proving that the caps were set too low and have unnecessarily constrained supply. The overall housing figures adopted in the original plan are now substantially out of date and no longer align with statutory housing need, while the strategy did not anticipate the scale of supply loss that would result from nutrient neutrality and other environmental constraints.
The conclusion is that the structure of the settlement hierarchy should be retained, but the percentage caps must be rewritten to reflect proven delivery capacity. Limits should be raised at every tier, and the overall housing total must be increased to match the new statutory requirement rather than being constrained by outdated distribution percentages.

To support brownfield development, the plan should retain a brownfield-first policy approach but set realistic targets based on actual capacity evidence rather than unachievable aspirations. Viability support should be provided through flexible density policies, recognition of abnormal remediation costs within contribution calculations, and enabling mixed-use development to cross-subsidise difficult sites. Windfall development should be encouraged and unnecessary thresholds removed to allow smaller sustainable brownfield sites to come forward, while public infrastructure investment should be prioritised to unlock complex sites ahead of requiring private delivery.
In terms of the types of development that should be supported as part of the updated Growth Strategy, brownfield intensification is endorsed in principle but it must be acknowledged that capacity is limited and cannot meet the full scale of identified need. Strategic urban extensions of more than one thousand homes are strongly supported as a proven model that delivers scale alongside coordinated infrastructure, as are large and medium extensions of between five hundred and one thousand homes which suit Main Towns and Key Service Centres well and support phased delivery. Smaller urban extensions and proportionate village extensions are also strongly supported, delivering early housing supply and spreading growth sustainably across all tiers of the hierarchy. Development anchored around employment sites and public transport hubs should be prioritised to maximise sustainable travel patterns. New settlements should be explored as a longer-term option but should not be relied upon to meet core housing need for the 2026 to 2045 period given that first deliveries would not realistically occur before the mid-2030s.
The overall position is that brownfield should be prioritised but cannot be relied upon exclusively. Evidence confirms that brownfield capacity alone is insufficient, and the additional homes now required must therefore come from a balanced mix of urban extensions at all scales alongside proportionate village growth.

Growth should be directed to locations that are demonstrably sustainable and capable of accommodating additional housing. The Norwich Urban Area provides opportunities through selective brownfield intensification within the core and strategic and medium-scale extensions at the urban edge. Main Towns including Wymondham, Aylsham, Diss, Long Stratton and Harleston have proven sustainable capacity and are appropriate locations for medium and large extensions. Key Service Centres should be allowed to expand through proportionate extensions given that delivery data shows their actual capacity to be nearly double the previously planned levels. Well-served villages should also be permitted limited proportionate extension where services and transport links support growth, and locations close to railway stations and along the Tech Corridor should be prioritised to maximise sustainable accessibility. New settlements should be explored for longer-term potential but should not be relied upon to meet the requirement for the plan period given the time needed to bring such sites forward.
Infrastructure that should be prioritised to enable growth includes transport improvements such as the Norwich Western Link, ongoing A47 upgrades, rail service enhancements and targeted local highway works. In the water environment sector, priority should be given to wastewater treatment works upgrades and strategic nutrient mitigation infrastructure to unlock constrained catchments. Community infrastructure including school places, healthcare capacity, open space and recreational facilities should be planned in step with housing delivery. A pooled contributions framework should be adopted to ensure infrastructure funding is fairly distributed, and all infrastructure should be phased to come forward alongside housing rather than being made an impossible upfront barrier to development.
In summary, growth should be distributed across all tiers of the settlement hierarchy with caps raised to match proven delivery capacity, and strategic infrastructure should be prioritised where it unlocks the largest areas of development potential.

Yes, the settlement hierarchy should be updated while retaining its fundamental structure. The four-tier framework comprising the Norwich Urban Area, Main Towns, Key Service Centres and Village Clusters remains sound and fit for purpose, and should be retained as the basis for the new plan. The necessary changes relate to the capacity limits set at each tier, which are based on outdated evidence and have been proven by delivery rates to be unrealistically restrictive, particularly within Key Service Centres and Village Clusters where actual output is nearly double the original planned figures. Caps must therefore be revised upwards to reflect real demonstrated capacity rather than retained at levels that create artificial supply constraints.
The methodology used to classify settlements should also be enhanced. Alongside traditional service audits, the Department for Transport Connectivity Tool should be used to assess sustainable travel links, enabling identification of settlements that may have been under-classified due to an over-reliance on on-site service availability alone. Individual settlement rankings should be reviewed to reflect changes that have occurred since the last plan was adopted including new development, infrastructure improvements and changes to local services. The Village Clusters model should be retained and refined to reflect shared service catchments and sustainable travel linkages rather than being based purely on administrative boundaries.
Overall capacity across the entire hierarchy must be increased to reflect the new housing requirement. The thirty-four percent rise in statutory housing need together with the mandatory buffer creates a requirement for approximately twenty thousand additional homes, and this cannot be met simply by redistributing growth between existing tiers. Every part of the hierarchy must contribute more to meet the identified need.

To improve housing delivery rates through the new plan, the council should allocate more land across all tiers of the settlement hierarchy to widen the development pipeline and reduce over-reliance on a small number of large slow-delivery sites. The plan should aim to meet and exceed the national minimum site mix requirement of ten percent of homes on small sites of one hectare or less and ten percent on medium-sized sites, given that smaller sites come forward faster, carry lower upfront risk, and maintain delivery rates even when large sites stall. Targets should be set based on realistic build-out rates rather than theoretical maximum outputs, with particular focus on bringing forward early-delivery sites to restore the five-year housing land supply position as quickly as possible.
On viability and infrastructure, costs including nutrient mitigation, drainage and transport improvements should be pooled across developments rather than charged individually, spreading burden fairly and preventing single-site viability failure. S106 and CIL requirements should be simplified through publication of standardised schedules to remove repeated scheme-by-scheme negotiation that causes delay. Brownfield sites should be supported through flexible density policies and recognition of abnormal remediation costs within viability assessments.
In terms of process and governance, while housing land supply remains below the statutory five-year requirement the councils should work constructively with proposals brought forward under the national policy presumption in favour of sustainable development rather than resisting necessary growth. Planning decisions should be made consistently, with clear pre-application advice and timely determination of applications. Delivery against targets should be monitored annually, and policy adjusted where evidence shows that targets are not being met or constraints are preventing progress.
The overall approach should be to widen the development pipeline, spread infrastructure costs fairly, simplify planning requirements, and work with national policy provisions while supply remains short. Increasing the amount of allocated land while reducing unnecessary complexity will together deliver improved housing output.

Yes, the plan should aim for a proportion significantly higher than the ten percent minimum requirement set out in national policy. Evidence collected across the plan area shows that small and medium-sized sites deliver reliably, come forward more quickly than large strategic allocations, carry lower upfront risk, and are less vulnerable to cost inflation and market delays. Over-reliance on a small number of very large strategic sites creates vulnerability in overall delivery rates, whereas a healthy distribution of smaller sites maintains output at a consistent level.
Encouraging a diverse mix of site sizes also supports a more resilient development market by sustaining the presence of small and medium-sized housebuilders who deliver a substantial proportion of all new homes. Performance data across Greater Norwich shows that windfall and smaller sites already deliver approximately thirty-two percent of all new homes, meaning that setting a target of only ten percent falls far short of demonstrated market capacity and would unnecessarily constrain supply. Smaller developments also tend to deliver a broader range of home types, tenures and price points, better matching the full spectrum of local housing need and supporting affordability. Spreading housing supply across more individual developments also reduces overall delivery risk, ensuring that if one site experiences delay others continue to progress — a particularly important safeguard while overall housing supply remains below the statutory five-year threshold.
For these reasons the recommendation is that the plan should target at least fifteen to twenty percent of homes on each category of small and medium-sized site rather than adopting the minimum ten percent baseline. Policy should seek to reflect and encourage proven delivery capacity rather than setting targets that sit well below what the market already delivers.

For affordable housing, the plan should retain differentiated targets of twenty-eight percent in the city centre and thirty-three percent elsewhere but these must be reviewed and tested against up-to-date viability evidence to ensure they remain deliverable. Flexibility should be permitted through mechanisms including commuted payments, off-site delivery, adjustments to tenure mix, and clawback provisions where on-site provision is demonstrated to be unviable. Developer contributions should be aggregated across multiple sites where appropriate to prevent individual schemes becoming unviable due to cumulative policy burdens.
Accessible and adaptable housing standards should be progressed gradually towards the forty percent combined standard referenced in the draft NPPF, moving up from the current twenty percent requirement in a measured way. Standards should be closely aligned to Building Regulations requirements to avoid imposing conflicting or unnecessarily costly additional requirements that sit outside national building standards.
For specialist housing including homes for older people and those requiring supported accommodation, need should be assessed through an updated evidence base, and suitable sites should be allocated in locations close to services and community facilities. Specialist housing should be treated as a mainstream housing requirement and integrated within general allocations rather than being treated as an exception category.
Evidence relating to the accommodation needs of Gypsy, Traveller and Travelling Showpeople communities should be updated urgently given that existing targets are clearly undeliverable. Specific sites should be allocated in suitable locations alongside a supportive windfall policy to ensure provision keeps pace with identified need.
Self-build and custom-build housing demand should be assessed through registers and needs evidence, with capacity allocated proactively across the plan area. Unnecessary thresholds should be removed to enable delivery,.
The overarching principle is that targets should be set using up-to-date evidence, flexibility should be built into policy requirements to maintain deliverability, and suitable sites should be allocated proactively so that all housing needs are addressed through the plan rather than through exception-based processes alone. Realistic policy supported by positive allocation will deliver more homes than fixed targets that prove undeliverable on the ground.