4. Sir Gaerfyrddin – Cyd-destun Strategol

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.

Amend Plan

Please find below my concerns regarding the proposed LDP.
Particularly focusing on urgent measures we will need to take to address our ecological emergenicies.

Please let me know if you’d like to discuss further.

Overview P364:
3.6. Well Being and future Generation Act (Wales) 2015 refocused National planning Policy Wales and the South West Wales Area statement.
Particularly in response to WG Climate emergency declaration.
3.7 Also influenced by Future Wales 2040.
3.12 Renewable energy gets a first mention.
3.12 Links RE to the Ten Towns

We therefore need to be “Globally Responsible”
4.9 A presumption in favour of sustainable development
4.11 “without compromising the ability of future generations to meet their own needs
4.48 27 conservation areas which includes many of the Ten Towns.
Therefore a clear conflict of ideas that always falls in favour of aesthetics of buildings?

e.g. In the case of Llandovery/Newcastle Emlyn-where shall we accommodate our stated renewable energy ambitions?
Not windy enough and prime farmland. Has to be rooves.

5.6 33 Energy efficiency in proposed and existing developments.
This won’t be able to set standards higher than current building regs-which are woefully inadequate due to lobbying and corruption by developers in Westminster.
“We continue to build crappy houses”-Lord Deben-Chair of Climate Change Committee UK GOV.

5.7 Updated Contextual Issues.
UCI 3 is the Climate Emergency.
UCI 4 is the Nature Emergency

What powers does this bring?

ONE CARMS.
6.4 Need to balance conflicting demands.
Do UCI 3&4 hold sway in Conservation Areas?

Policy CCH3 P592
Electric Vehicle Charge Points
1. Every new home with dedicated off road space must have a charge point. As I recently stated when giving evidence at the Senedd-this is misguided and wasteful.
New homes should have three phase to accommodate EVs and heat pumps BUT passive provision of EVCP is sufficient.
This enables the resident to install the latest technology once they need it. Putting charge points that rust on walls is ludicrous if residents don’t have EVs.
Also encouraging car ownership.
2. Installing charge points at 10% of car parking space at non-residential developments is similarly OTT-passive provision and ensuring adequate supply is what should be required.

11.495 Rural challenges for public transport. Clearly a significant challenge. Too many empty buses running infrequently.

11.496 Provision of rapid chargers at new flats a ludicrous idea. Too expensive and unrequired.

SP16 Climate Change P582

11.471-WG is committed to using planning to optimise renewable energy (Llandovery?)
Furthermore Planning Policy Wales states that the Local planning Authority CAN make a +ve provision by considering the contribution that their area can make re. Renewables.

11.476 p586
“Particular support will be given to community renewables which will benefit the host community.
Why has CCC failed to engage with Ynni Sir Gar? And Energy Local?

11.493-embrace new low carbon technology-This would be an opportunity to specifically mention EV Car clubs.
Shared ownership to reduce cars and increase transport options.
Furthermore, Local organisations could allow community to use their vehicles via Community Car Clubs.

11.538 LDP seeks to +vely promote solutions which encourage access to technology changes.
Another opportunity to promote shared ownership to reduce emissions, Increase social inclusion and access to services through EV Car clubs.
This is an ambition of the current transport Minister.
This can replace the aforementioned expensive diesel buses.

I would very much ask that the potential for Community Car clubs is proposed in our LDP to 2033.
This is stated WG policy.