Testun llawn:
Policy SP1: Strategic Growth
We support Policy SP1 which includes provision for 9,704 new homes to meet the identified housing requirement of 8,822 and consider this to be an achievable level of growth for the County.
We would reiterate the importance of enabling appopriate levels of growth in smaller sustainable villages, such as Pendine, in addition to larger key settlements, to ensure these housing targets for the Plan period can be achieved.
Policy SP3: Sustainable Distribution – Settlement Framework
The categorisation of Pendine as a ‘Tier 3 Sustainable Village’ within the Settlement Framework is supported. We agree that locations in this tier are
suitable for housing allocations, as per paragaph 11.74 of the Written Statement. In terms of the distribution of growth in Carmarthenshire, we support the notion at
paragraph 11.72, which recognises that much of the County is rural and housing is needed in these locations, not just in the larger top tier settlements. Accordingly,
the Plan should enable and encourage incremental growth of smaller sustainable villages, such as Pendine, to support their local population and economy.
Increased housing supply should be supported in locations where people already live, to ensure that local people have the opportunity to buy homes and continue to live in these areas, rather than needing to move elsewhere within or outside the
County. This will be crucial to address one of Carmarthenshire’s key issues: ageing population and out-migration of younger and working age people.
Policy SD1: Development Limits
We wholly support the alterations proposed to the development limit boundary of Pendine, which now includes Curtilage of Nieuport Farmhouse (Candidate Site Ref: SR/126/004); the western part of Land adjacent to Crofters Rest (Candidate Site Ref: SR/126/001); and a small area of Land rear of St Margarets Park (Candidate Site Ref: SR/126/002), to form a slightly larger housing allocation at Nieuport Yard (ref: SuV61/h1).
The inclusion of these sites ensures that the organic growth of Pendine can be supported through deliverable, viable and policy-compliant housing schemes,
which will contribute towards meeting the RLDP’s objectives. The above sites (as well as additional adjacent land) lie within the ownership of the site promoter, Mr T. Pearce, and represent logical extensions to the existing built form of Pendine. We
therefore support that these sites present valuable opportunities for a suitable level of growth within this ‘sustainable village’ (Tier 3 as per Policy SP3).
Notwithstanding the above, we propose that the development limit should be extended further to also include the remaining part of Land adjacent to Crofters
Rest, to encompass the full site as per the candidate site submission originally submitted in 2018 (ref: SR/126/001). Inclusion of the full extent of the Land adjacent to Crofters Rest presents an opportunity to provide a modest amount of additional housing. The site is also entirely within the site promoter’s ownership, thereby eliminating any land ownership constraints to delivery. The total site is a rectangular parcel of land comprising approximately 0.5ha, which is currently arable/general agricultural land. The site is relatively free from physical constraints, with a flat topography. There is
an existing hedgerow bounding the site to the north, separating the site from the B4314 road. Other than this hedgerow, the site is free from other landscape
constraints. The site is not subject to any statutory nature conservation or archaeological designations, nor tree preservations orders. The site does not lie
within a defined flood plain (TAN 15 Development Advice Maps). We note that the site is located within a Special Landscape Area, however so is the majority of the built settlement of Pendine. Considering this, together with the
partial inclusion of the site within the amended development limits, the landscape designation is not considered to unacceptably constrain the future development of the whole site at Crofters Rest.
As demonstrated for the western part of the site (now proposed to be included within the settlement) the access track off B4314 can suitably be extended
eastwards to accommodate further housing. Inclusion of this land would represent a logical extension to Pendine that would provide symmetry with the existing
housing located immediately north of B4314 (detached bungalows) yet would not extend the built settlement any further eastwards than the existing situation to the
north. The site lies in close proximity to existing residential development in Pendine and
is therefore assumed to be capable of providing appropriate services and utilities
connections. In our view, the extension of the development limit to include the remaining land
adjacent to Crofters Rest within the forthcoming LDP, represents a viable and deliverable opportunity to provide an appropriate range and choice of housing to
meet small scale additional growth within Pendine. The allocation of the full extent of the site would also provide additional flexibility as to the size and range of units
that could be offered on site, to meet local demand in a sustainable manner.
Policy HOM1: Housing Allocations
In particular, we support the allocation of site ref: SuV61/h1 - Land at Nieuport Yard, for the delivery of 10 units. Part of the site already benefits from an
implemented planning permission for 5 units (planning permission ref: 2/21251).
Policy HOM2: Housing within Development Limits
We support Policy HOM2, which notes that whilst sites capable of delivering 5 or more dwellings are allocated for housing, there are smaller unallocated sites within
the settlement limits throughout the County which may be available for the delivery of small scale housing development. We support that proposals on such sites
should be permitted provided they accord with the relevant RLDP policies. Policy AHOM1: Provision of Affordable Homes We support the RLDP objectives for delivery of affordable housing in meeting the
needs of Carmarthenshire. We note that on-site AH contributions will be sought on developments of 10 or more dwellings, based on a percentage that rises
incrementally depending on the total number of dwellings proposed. Policy AHOM1 states that: “The affordable housing target percentage noted is a target
to be used as a starting point for affordable housing negotiations.” We would agree that among other considerations, viability should be taken into account when negotiating the amount of affordable housing contribution that should be sought for
any given scheme, to ensure the deliverability of market housing schemes.Policy AHOM1 also notes that: “Where adjacent and related residential proposals
result in combined numbers meeting or exceeding the above thresholds, the council will seek an element of affordable housing based on applying the above
target percentages to the aggregate number of dwellings.” Again, we would reiterate that this policy should be applied with careful consideration of the overall
viability of housing developments between the LPA and developers.
Policy SP16: Climate Change
We support this policy and recognise the importance of the Council’s wider goals to address climate change, including reducing greenhouse gas emissions.
However we would suggest that, in terms of Policy SP16, the design requirements for small-scale housing developments should be no more onerous than the
relevant Building Regulations requirements, in order to ensure that proposals remain deliverable and viable to meet the identified housing need over the Plan period.
