Carmarthenshire County Council / Cyngor Sir Gâr

Gwrthwynebu

Ail Gynllun Datblygu Lleol Adneuo Diwygiedig Sir Gaerfyrddin

ID sylw: 5543

Derbyniwyd: 12/04/2023

Respondent ID: 5816

Ymatebydd: Welsh Government

Cydymffurfio â’r gyfraith? Heb nodi

Cadarn? Heb nodi

Crynodeb o'r Gynrychiolaeth:

Base Date Inconsistencies
The DPM (5.62) specifically states that all housing components must have the same base date. This is essential to avoid confusion and issues of consistency. The Council has used a base date of 01st April 2022 for completions/under-construction category and October 2022 for the timing and phasing or large sites. This approach does not comply with the DPM and as a result there is no accurate picture of housing in the plan, and the supporting evidence. The Council must either roll back the housing figures and all components of supply to 01st April 2022 or move everything forward to 01st April 2023.
(Category B objection)

Newid wedi’i awgrymu gan ymatebydd:

Amend Plan / background documents as set out in summary.

Testun llawn:

Thank you for consulting the Welsh Government on the Carmarthenshire County Council Local Development Plan (LDP) 2nd Deposit plan and documents. It is essential the authority is covered by an up-to-date LDP to give certainty to local communities and business.
Without prejudice to the Minster’s powers, the Welsh Government is committed to helping Local Planning Authorities (LPAs) minimise the risk of submitting unsound plans by making comments at the earliest stages of plan preparation. The Welsh Government looks for clear evidence that the plan is in general conformity with Future Wales: The National Development Framework and aligns with Planning Policy Wales (PPW), and that the tests of soundness (as set out in the ‘LDP Manual’) are addressed.
National planning policies are set out in Planning Policy Wales (PPW) Edition 11, which seeks to deliver high quality, sustainable places through a place-making approach. The implementation of the core policy areas in PPW, such as adopting a sustainable spatial strategy, appropriate housing and economic growth levels, infrastructure delivery and place-making, are articulated in more detail in the LDP Manual (Edition 3). We expect the core elements of the Manual, in particular Chapter 5 and the ‘De-risking Checklist(s) to be followed. The development planning system in Wales is evidence led and demonstrating how a plan is shaped by the evidence is a key requirement of the LDP examination.
After considering the key issues and policies in Future Wales, the Welsh Government is of the view that the level and spatial distribution of growth is in general conformity with Future Wales: The National Development Framework. However, the Statement of General Conformity (Annex 1 to this letter) is a ‘caveated response’. Annex 2 of this letter raises fundamental inconsistencies regarding the total housing provision and until these matters have been addressed and their implications understood, it is not possible to give a firm view on matters of general conformity at this time. Annex 2 of this letter also highlights a range of issues that need to be addressed for the plan to align with PPW and DPM. Collectively, our comments highlight a range of issues that need to be addressed for the plan to be considered ‘sound’ as follows:
Annex 1 – General Conformity with Future Wales (Caveated Response)
· Regional Collaboration/Level of growth Further clarity required. Annex 2 – Core matters that need to be addressed (PPW and the DPM)
Our representations are separated into three categories set out by topic area, with further detail in the attached annex.
Category A: Fundamental issues that are considered to present a significant degree of risk for the LPA if not addressed prior to submission stage and may have implications for the plan’s strategy.
None.
Category B: Matters where it appears that the deposit plan has not satisfactorily translated national policy down to the local level and there may be tensions within the plan, namely (not exhaustive):
· Level of Housing Provision
· Delivery and Viability
· Restriction of new homes to Class C3 only
· Gypsy and Traveller Provision
· Best and Most Versatile Land (BMV)
Category C: Whilst not considered to be fundamental to the soundness of the LDP, we consider there to be a lack of certainty or clarity on the following matters:
· Flooding
· Renewable Energy
· Minerals
· Phosphates
I would urge you to seek your own legal advice to ensure you have met all the procedural requirements, including the Sustainability Appraisal (SA), Strategic Environmental Assessment (SEA) and Habitats Regulation Assessment (HRA), as responsibility for these matters rests with your authority. A requirement to undertake a Health Impact Assessment (HIA) arising from the Public Health (Wales) Act 2017, if appropriate, should be carried out to assess the likely effect of the proposed development plan on health, mental well-being and inequality.
It is for your Authority to ensure that the LDP is ‘sound’, and it will be for the Inspector to determine how the examination proceeds if you submit the plan without addressing the concerns we raise. My colleagues and I look forward to meeting you and the team to discuss matters arising from this response.

Atodiadau:

letter - redacted (727.34 KB)

Ein hymateb:

The Council has undertaken additional work to comply with key sections of the DPM and this is addressed within the Position Statement on Housing Growth. This relates to work on configurating the base date, updates to the housing trajectory and spatial distribution papers and these documents will be submitted to the Inspector as part of the Council's evidence base.