Carmarthenshire County Council / Cyngor Sir Gâr

Gwrthwynebu

Ail Gynllun Datblygu Lleol Adneuo Diwygiedig Sir Gaerfyrddin

ID sylw: 5553

Derbyniwyd: 12/04/2023

Respondent ID: 5816

Ymatebydd: Welsh Government

Cydymffurfio â’r gyfraith? Heb nodi

Cadarn? Heb nodi

Crynodeb o'r Gynrychiolaeth:

Category B Delivery and Viability
We note that the plan is supported by a high-level viability study prepared by Burrows-Hutchinson Ltd. Section 6.4 of the Report states that further work is needed to establish site-specific affordable housing percentages for key sites (including existing allocations) and that this work will be done during this consultation. The report notes that further work is needed with stakeholders in order meet the delivery and viability requirements of PPW and the DPM. This work should already have been undertaken. If this ‘further work’ results in changes to the affordable housing targets or introduction of new targets for sites through new or amended policies in the plan, then these changes (supported by new evidence) would be significant, and it is imperative that all parties are able to comment on them. Such a change(s) would be focussed changes.
(Category B objection)

Newid wedi’i awgrymu gan ymatebydd:

Amend Plan 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 updated evidential work through the Burrows Hutchinson Financial Viability Assessment to
test and consider the affordable housing targets for the Plan. This work has been prepared using up to date costs considered at a Development Stakeholder Viability workshop and updated affordable housing costs. It is not considered that changes to the Affordable Housing targets will be necessary through this updated work, and further consideration can be addressed at examination.

In terms of key sites, reference is drawn to the publications of statements of common ground undertaken. Whilst a number of sites have been granted planning permission previously, new allocations to be brought forward within the Revised LDP have been considered against the targets set out in Policy AHOM1.