Second Deposit LDP

Object

Representation ID: 4777

Received: 11/04/2023

Respondent ID: 2558

Respondent: The Home Builders Federation

Legally compliant? Yes

Sound? Yes

Remove the requirement to require a 'natural materials management plan' as this is not supported by national policy.

Include these requirements in other policies in the plan such as PSD1.

Disagree. Making best use of material resources and promoting the
Circular Economy is a key principle within Planning Policy Wales. Choices about the use of material resources should be based on making the most appropriate and sustainable use of finite resources and promoting the principles of a circular economy. It is considered that the submission of a natural materials management plan through Policy PSD5 will be an appropriate method to facilitate these requirements.

Object

Representation ID: 4779

Received: 11/04/2023

Respondent ID: 2558

Respondent: The Home Builders Federation

Legally compliant? Yes

Sound? Yes

The Policy introduces requirements that are over and above National Policy, PPW11 and Future Wales, all of which only reference green infrastructure. Therefore they should not be included in the plan.

The policy requires a Green Infrastructure Statement to demonstrate Green and Blue Infrastructure this requires clarification.

The requirement for the policy to apply to all major developments is considered onerous and will be overly onerous on smaller developments.

Consider that many of the requirements of this policy are replicated in other policies such as Strategic Policy – SP 14

Disagree. The policy requires that all planning applications for major developments will be required to submit a Green Infrastructure Statement to demonstrate how GBI design solutions have been considered and accommodated as part of the proposed development. GBI focuses on the natural environment and how by creating a strong, well considered networks of green and blue corridors and spaces we can support adaption and resilience to climate change, conserve and improve biodiversity and contribute to the health and wellbeing of our communities. Green and Blue Infrastructure elements often go hand in hand, and the requirement to submit a Green Infrastructure Statement is the most appropriate method to incorporate all elements.

Object

Representation ID: 4783

Received: 11/04/2023

Respondent ID: 2558

Respondent: The Home Builders Federation

Legally compliant? Yes

Sound? Yes

Policy wording confusing and inconsistent with other policies in the plan.

Wording repeats other policies.

Disagree. The policies and proposals of the LDP are considered sound and deliverable emerging from a robust evidence base and having been formulated with regard to national planning policy.

Object

Representation ID: 4785

Received: 11/04/2023

Respondent ID: 2558

Respondent: The Home Builders Federation

Legally compliant? Yes

Sound? Yes

The requirements for new development to be served by high speed broad band are unnecessary as this is covered by Building Regulations, so is repeating other existing policy requirements.

Disagree, PPW Edition 12 para 5.2.23 specifically states "Planning authorities in urban and rural areas should include policies in their development plans to address the need for broadband infrastructure and its improvement or replacement."

Object

Representation ID: 4786

Received: 11/04/2023

Respondent ID: 2558

Respondent: The Home Builders Federation

Legally compliant? Yes

Sound? Yes

The suggestion that a HIA be triggered by the 'major development' threshold is considered unreasonable . It is considered far too low and will put an additional burden on small developers, creating additional cost and delay in bringing forward development. Further the supporting text talks within the HIA Sequential Checklist about deciding on the type of assessment, although no clarification is provided on the different types.

The major development threshold decided by the Council in respect of Health Impact Assessments, and included within Policy INF2, is considered sound and robust. Matter to be further considered at examination.

Object

Representation ID: 4787

Received: 11/04/2023

Respondent ID: 2558

Respondent: The Home Builders Federation

Legally compliant? No

Sound? No

It is considered that the wording does not explain how the windfall figure used in the trajectory has been calculated.

Topic Papers have been prepared that accompany the LDP which set out the calculations behind the housing figures, including the windfall provision.

Object

Representation ID: 4788

Received: 11/04/2023

Respondent ID: 2558

Respondent: The Home Builders Federation

Legally compliant? Yes

Sound? Yes

HBF consider having both an Infrastructure and S106 policy is confusing and is unnecessary duplication.

The wording of the policy should be amended to say - the applicant will be required to meet the 'reasonable' costs.

The additional text supporting Policy SP9 Infrastructure signposts the reader to Policy INF1 Planning Obligations and so it is considered clear that the two policies are related. However, given that planning obligations will not always be relevant to matters relating to infrastructure there is merit in maintaining two distinct policies for clarity.
The inclusion of the word 'reasonable' within the policy can be further discussed at examination.

Object

Representation ID: 4789

Received: 11/04/2023

Respondent ID: 2558

Respondent: The Home Builders Federation

Legally compliant? Yes

Sound? Yes

The HBF are not clear on what is meant by 'Residential development of 5 or more dwellings on allocated or windfall sites that do not address evidence of need and demand for housing recorded in a Housing Market Assessment or other relevant local sources of evidence'. In particular how would a site which is allocated in the plan not address evidence of need and demand for housing? Further windfall sites are generally within the settlement

All windfall sites are unanticipated by their very nature and what is the size threshold for 'large scale housing development'.

The production of SPG will provide additional clarity and guidance, however, further consideration can be given to he matter during the examination.

Object

Representation ID: 4790

Received: 11/04/2023

Respondent ID: 2558

Respondent: The Home Builders Federation

Legally compliant? Yes

Sound? No

Plan lacks aspiration only providing a minor increase in annual housing delivery figures over and above past trends.

The Plan misses the opportunity to capitalise on the City Deal and Regional Growth status of the National Plan.

The housing provision within the LDP is based on robust evidence as set out within the Topic Papers on Growth and Spatial Distribution and Population and Household Projections. In addition to the identified housing need an additional amount of land is allocated to allow flexibility in supply. It is considered that sufficient land has been made available to meet the identified housing need..

Object

Representation ID: 4791

Received: 11/04/2023

Respondent ID: 2558

Respondent: The Home Builders Federation

Legally compliant? Yes

Sound? No

The HBF objects to the suggested strategy as it considers it will make it much harder to deliver the appropriate/recognised level of growth. It is also less likely to deliver sustainable development and will not allow the plan to take full advantage of the areas Swansea Bay City Deal status.

The housing provision and the spatial distribution within the LDP is based on robust evidence as set out within the Topic Papers on Spatial Options, Growth and Spatial Distribution, and Population and Household Projection. In addition to the identified housing need an additional amount of land is allocated to allow flexibility in supply. It is considered that sufficient land has been made available to meet the identified housing need with the focus of growth given to the higher level settlements within the settlement hierarchy.