MAC 012

Gwrthwynebu

ID sylw: 6011

Derbyniwyd: 26/06/2026

Respondent ID: 645

Ymatebydd: Ms Zoe Aubery

Asiant : Boyer Planning

Cadarn? Nac Ydi

Strategic Policy SP4 sets out the Council’s overall housing requirement of 8,822 homes for the plan period (2018-2033), and to achieve it makes provision for up to 9,814 new homes. Whilst BR fully support the principle of increasing the Council’s overall housing target. It is important to note that in reality the proposed increase only equates to a provision of 110no. new dwellings over the emerging plan period, and therefore is minimal in nature.

Although we appreciate that in turn the proposed amendments lead to an increase in CCC’s flexible allowance bring it up to circa 11.24%. BR maintain there are sufficient circumstances to warrant increasing both the proposed housing figure and associated flexible allowance further in order to provide greater certainty that emerging RLDP is capable of meet housing across Carmarthenshire. This is particular important to ensure sufficient flexibility is built into the plan itself from the outset. The overarching purpose of which is to account for any unforeseen changes and potential shortfalls/ delays to the strategic site allocations whilst still enabling the overall housing requirement to be delivered.

In terms of the proposed flexibility allowance, whilst we acknowledge the latest figure of 11.24% technically exceeds the 10% threshold commonly referenced in the plan-making process.

Paragraph 5.59 of the DPM clearly states that “The level of flexibility will be for each LPA to determine based on local issues; the starting point for such considerations could be 10% flexibility with any variation robustly evidenced”.

Having reviewed the technical evidence base we understand the current housing figures have been informed by the trends set out within the 2018-based demographic projections. Although we appreciate that more recent data has emerged following consultation on the additional sites towards the end of last year. From a procedural perspective it is important to recognise that the 2018-based projections have now been formally superseded by more recent findings which includes Welsh Government’s 2022-Based Local authority household projections (Dated 20th November 2025) and 2025-based estimates of additional housing need (Dated 12th February 2026).

Given the emerging RLDP is at an advanced stage of the plan-making process we would not necessarily expect the Council to formally reassess its housing need position. However, in the interests of soundness, we strongly believe the Council’s housing target, and by virtue of which flexible allowance, should be uplifted to better align with the latest demographic evidence available. Most notably this includes the fact that in the case of Carmarthenshire, from mid-2022 to mid-2032 the overall number of households is projected to increases by around 7%, which is broadly in line with the national average.
In turn these trends are carried through into WG’s 2025-based estimates of additional housing need, which identifies an existing unmet need of 9,400 homes. This is supplemented by a requirement to deliver an average of 8,700 new homes annually over the next five years to account for newly arising need alone.

The combination of which demonstrates that there is an urgent need to increase delivery rates on both a national and local level, and therefore it’s imperative that the latest position with regards to the need for affordable and full market homes are better reflected within the emerging RLDP’s overall housing requirement. This is fundamental to ensure the emerging RLDP is locally specific and thus supported by a robust, proportionate and credible evidence to demonstrate compliance with Test 2 of the DPM.

The Council considers sufficient flexibility within its housing supply. This has been subject to detailed consideration through the examination process and the current 11.24% being considered an appropriate flexibility