Second Deposit LDP

Object

Representation ID: 4764

Received: 11/04/2023

Respondent: The Home Builders Federation

Legally compliant? Yes

Sound? Yes

Under the 'A Prosperous Carmarthenshire' section the need for new homes to support economic growth should be included.
No.19 should be amended to remove reference to the five year land supply which is no longer relevant in Wales.
No.21 What housing sites are these previous allocations?

Comments noted. The matter can be given further consideration during Examination

Object

Representation ID: 4765

Received: 11/04/2023

Respondent: The Home Builders Federation

Legally compliant? Yes

Sound? Yes

The role of housing in both supporting Economic growth (SO11), Wellbeing (SO2) and Equal opportunities (SO4) should be acknowledged.

Disagree. The aim of this strategic objective is specific to what is stated i.e making provision for an appropriate number and mix of quality homes across the County. The other SOs highlighted by the respondent are specific to their own objectives and the need to cross reference each SO is not necessary and not in the remit of this section of the Plan.

Object

Representation ID: 4766

Received: 11/04/2023

Respondent: The Home Builders Federation

Legally compliant? No

Sound? No

The figures in the table do not appear to add up, although it is noted that the table is very complicated and hard to follow. Adding the overall allocations, commitments, windfalls, small sites and taking away completions does not result in the identified requirement figure.

Why does the trajectory include a five year land supply calculation as this is not longer required or used in Wales.

The Council has undertaken additional work to comply with key sections of the DPM and this is addressed within the Position Statement on Housing Growth. This relates to work on the housing trajectory and spatial distribution papers and will be submitted to the Inspector as part of the Council's evidence base.

Object

Representation ID: 4767

Received: 11/04/2023

Respondent: The Home Builders Federation

Legally compliant? Yes

Sound? Yes

This text is not required as any development would have to comply with these polices and any other relevant policies in the plan.

Disagree. The paragraph is included for emphasis / clarification as to what policies will need to be accorded with.

Object

Representation ID: 4769

Received: 11/04/2023

Respondent: The Home Builders Federation

Legally compliant? Yes

Sound? Yes

How do the housing numbers relate to the plans housing figure and the plans flexibility allowance.

It is not currently clear whether or not the housing numbers identified within this policy form part of the current planned housing allocation figure or how they relate to the 10% flexibility allowance.

Question reserved sites being released by a plan review as this could be four years away and would be a process which would allow new housing sites to be allocated if required.

The policy indicates that in bringing sites forward they must not result in 'over provision' clarification is required on how this can be proved, for instance would confirmation that either an allocated site or committed site not come forward due to a change in circumstances be enough or would a committed site planning consent need to lapse.

The Reserve sites identified within the Revised LDP do not form part of the housing supply figure. The inclusion of Reserve Sites will be a consideration for the Revised LDP examination

Object

Representation ID: 4770

Received: 11/04/2023

Respondent: The Home Builders Federation

Legally compliant? Yes

Sound? Yes

The policy as worded has no requirements it is just a statement of facts.

Comments noted, consideration to be given to the policy wording at examination.

Object

Representation ID: 4771

Received: 11/04/2023

Respondent: The Home Builders Federation

Legally compliant? Yes

Sound? Yes

The reference to SuDS in the policy wording is not necessary as it is required by separate legislation. It can if required be referred to in the supporting text.

The final paragraph relating to Phosphates needs to be reworded as mitigation will not be required in all cases due to the approach taken by NRW following the ongoing permit reviews.

Disagree. PPW makes reference to SuDS and it it’s importance in being integral to the design of new development.
In respect of the second part of the objection, it is considered that the wording of the Policy is appropriate and more guidance will provided in Supplementary Planning Guidance.

Object

Representation ID: 4774

Received: 11/04/2023

Respondent: The Home Builders Federation

Legally compliant? Yes

Sound? No

The proposed policy goes beyond the requirements with national policy.

If removal of the policy is not accepted then the requirement should be reduced to require developers to provide a connection point ready for the charging unit but not the actual charging unit. The choice of charging unit should be left to the customer and only needs to be fitted if the customer chooses to own an electric car. The technology associated with EV charging is changing rapidly so will become outdated very quickly.

Anghytuno. Mae'r Cynllun yn cynnwys amrywiaeth o bolisïau a darpariaethau mewn perthynas â chyfrannu a mynd i'r afael â heriau newid hinsawdd o safbwynt cynllunio defnydd tir, gyda'r polisi hwn yn un. Yn hyn o beth, fe'i paratowyd mewn perthynas â darpariaethau Polisi Cynllunio Cymru a chynlluniau a strategaethau eraill gan gynnwys yr argyfyngau newid yn yr hinsawdd fel y'u datganwyd gan LlC a'r Cyngor.
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Disagree. The Plan includes a range of policies and provisions in relation to contributing and addressing the challenges of climate change from a land use planning perspective, this policy being one. In this respect it has been prepared with regard to the provisions of PPW and other plans and strategies including the climate change emergencies as declared by the WG and the Council.

Object

Representation ID: 4775

Received: 11/04/2023

Respondent: The Home Builders Federation

Legally compliant? Yes

Sound? Yes

The HBF notes that many of the requirements within this policy are repeated in other policies so are unnecessary. They are also covered by national policy in many cases so are unnecessary, an example being SuDS.

Disagree, The wording in this paragraph is considered to be sufficiently robust and in accordance with PPW.

Object

Representation ID: 4776

Received: 11/04/2023

Respondent: The Home Builders Federation

Legally compliant? Yes

Sound? Yes

The HBF asks for clarifications on why the Policy does not allow for adopting any new public open space as traditionally has been the case. The need for a private management company imposes an additional cost on the home owner and arguably is seen as a double payment of the Council Tax.

A policy on the adoption of open space by the local authority is outside the remit of the Plan.