Gwrthwynebu
Ail Gynllun Datblygu Lleol Adneuo Diwygiedig Sir Gaerfyrddin
ID sylw: 5548
Derbyniwyd: 12/04/2023
Ymatebydd: Welsh Government
Cydymffurfio â’r gyfraith? Heb nodi
Cadarn? Heb nodi
Welsh Language
Policy SP8 identifies the entirety of the County as a linguistic sensitive area. We note that the Welsh Language Impact Assessment (WLIA) has concluded that the level of housing growth (8,822 homes, plus 10% flexibility) will not negatively impact on the Welsh Language. Paragraph 63 of the WLIA states that a reduction in the level of flexibility from the Preferred Strategy from 15% to 10% “together with the effective implementation of Strategic Policy SP3, is more likely to reduce unforeseen distribution of growth on specific locations particularly in communities where the use of the Welsh language is sensitive to change. In our view, Policy WL1 strengthens the Council’s ability to ensure that such unanticipated development is screened for adverse impact”.
The Welsh Government has raised a series of concerns regarding the clarity of housing supply and the identification of reserve sites that collectively may increase the level of housing provision and consequently the level of flexibility in the plan is significantly higher (around 27%) than is set out on Policy SP4. The conclusions of the WLIA are predicated a total housing provision of 9,704 homes. (10% flexibility). The implication being that a higher level of housing provision may have adverse impacts on the Welsh Language. This is particularly important as the vast majority of the population and housing growth will be accounted for by in migration rather than natural growth of the existing population. The council must provide clarification on these matters and explain the implications for the plan.
(Category B objection)
Amend Plan as set out in summary.
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.
The WLIA considers the implications of inmigration on the Welsh language and draws conclusions on the matter. Further evidential work has been prepared which considers the best available data including 2021 Census data. Further clarity and consideration can be given to the matter at Examination.