GNLP 2045 Regulation 20 Scoping Consultation

The proposed purpose for each of the three statutory consultation stages is correctly identified and aligns appropriately with the requirements of the new plan-making process covering scoping, emerging content and draft plan stages. The range of audiences identified is broadly appropriate and includes all major stakeholder groups, though it is recommended that land promoters, developers and strategic landowners should be explicitly named as key stakeholders at every consultation stage given the central role they play in bringing forward housing supply. The proposed engagement methods provide a well-balanced foundation combining digital delivery with appropriate alternative provision, and should be enhanced through addition of dedicated technical stakeholder workshops, timely publication of consultation feedback summaries demonstrating how comments have been addressed, and appointment of a consistent single point of contact throughout the plan-making process.

In addition to the proposals already set out, engagement should be strengthened through provision of dedicated technical workshops for landowners and developers to enable early two-way dialogue, briefing sessions held with Parish and Town Councils ahead of consultations to assist them in engaging their communities, and publication of interactive online mapping showing emerging options and allocations in an accessible visual format.
To support engagement with groups who are currently hard to reach, the plan should make use of a mobile engagement unit and hold pop-up consultation sessions at community locations including village halls, markets, transport hubs and workplaces to meet people where they are. Simplified plain-language summaries and easy-read versions should be published alongside full consultation documents, and evening and weekend sessions held in rural areas to accommodate working patterns. Assistance should be provided to those who require help responding online, a telephone comment option should be available, and paper copies should be provided free of charge with pre-paid return postage where required. Partnership should be established with the younger communities, faith groups and trusted community organisations to extend reach into communities who do not traditionally engage with planning processes.

The most fundamental point missing from the emerging strategy is explicit recognition of the scale of change that has occurred since the original plan was prepared. Housing need has risen substantially while deliverable supply has fallen due to environmental constraints, creating a gap of approximately twenty thousand homes that cannot be bridged through redistribution alone. The plan must start from this evidence base and allocate sufficient additional land across a balanced geography to restore supply resilience and meet statutory obligations. Immediate priority should be given to identifying and allocating early-delivery sites to restore the five-year housing land supply position and manage the national policy presumption in favour of sustainable development.
Nutrient neutrality and wastewater capacity must be addressed and the early-delivery potential of areas outside constraint zones should be maximised. Infrastructure costs should be pooled across developments to prevent individual schemes becoming unviable, and all infrastructure should be phased to come forward alongside housing rather than acting as an upfront barrier.
Policy targets should be reviewed and set from up-to-date evidence including housing mix percentages, affordable housing requirements and design standards, with appropriate flexibility built in where viability is demonstrated to be constrained. Progress should be monitored annually including delivery rates and housing supply position, and consultation feedback should be published promptly to maintain transparency and demonstrate how views have shaped the plan.
Above all, the new plan must be deliverable in practice as well as sound in policy terms. The strategy must acknowledge changed circumstances, remove unnecessary constraints, and set realistic requirements that can be achieved, so that the homes needed across Greater Norwich are actually built.