Second Deposit LDP
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Second Deposit LDP
PSD5: Development and the Circular Economy
Representation ID: 4777
Received: 11/04/2023
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.
Rewording of and or clarification over what the policy requires in terms of formal documentation. However, HBF consider all of the identified asks could be included in the planning or the sustainability / placemaking statement, thus avoiding the need for another separate document.
The HBF question the requirement for a 'natural materials management plan' a document which we have not come across before in a Development Plan in Wales or one which is supported by National Policy. Further we note that the dictionary definition of a material Management plan is as follows - A materials management plan (MMP) is a mechanism by which those who are developing a site can comply with Environment Agency regulations for excavated ground materials, this appears to be something very different to what the policy is looking to capture around the circular economy.
Again like other policy requirements in the plan this will unduly impact on smaller house builders, creating more up front work prior to planning.
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
Second Deposit LDP
PSD3: Green and Blue Infrastructure Network
Representation ID: 4779
Received: 11/04/2023
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
Policy wording should be amended to split the green and blue infrastructure requirements and clarify what is required to be covered in any statement.
Suggest a threshold of 30 units for the requirement for a specific Statement to be submitted.
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
Second Deposit LDP
PSD1: Effective Design Solutions: Sustainability and Placemaking
Representation ID: 4783
Received: 11/04/2023
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.
Wording should be amended to be consistent and less confusing.
Replace the phrase 'clearly demonstrate' with 'consider the following requirements'
The wording of the policy is considered confusing covering a wide range of issues many of which are covered in separate more specific policies.
The policy says 'shall demonstrate' in the first sentence and in the second sentence 'clearly demonstrate'.
The phrase 'sustainability objectives' is used but what are these? Strategic Policy – SP4: talks about 'principles' are these the same thing?
The word 'shall ' is considered too prescriptive as not all developments will either be able to meet all of the requirements.
It is not clear how this policy relates to the previous policy Strategic Policy – SP 12 as it appears to repeat things but uses different wording.
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
Second Deposit LDP
INF3: Broadband and Telecommunications
Representation ID: 4785
Received: 11/04/2023
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.
Remove unnecessary wording from the policy.
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
Second Deposit LDP
INF2: Healthy Communities
Representation ID: 4786
Received: 11/04/2023
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 requirement for a HIA should be trigged by developments of 50 units or more.
Clarification should be provided on the different types of assessments.
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
Second Deposit LDP
11.83
Representation ID: 4787
Received: 11/04/2023
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.
Re word to provide clarity.
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
Second Deposit LDP
INF1: Planning Obligations
Representation ID: 4788
Received: 11/04/2023
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 two policies should be combined into one policy.
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
Second Deposit LDP
WL1: Welsh Language and New Developments
Representation ID: 4789
Received: 11/04/2023
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'.
Amended wording of the policy to make requirement clearer.
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 site are generally within the settlement
All windfall site 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
Second Deposit LDP
8.7
Representation ID: 4790
Received: 11/04/2023
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.
Consider a growth strategy that falls between the current the ten year trend and the higher employment led scenario.
In view of the economic aspirations of the plan and Carmarthen's role as a Regional Growth area as identified by the National Plan, further consideration should be given to Baseline employment-led scenario. Trend based scenarios result in repeating what has happened in the past rather than planning for the future and looking to be more aspirational.
The chosen level of growth would also only be 87 units per annum above the annual average of 501 dwellings per annum achieved during the current plan period, since 2007, or 61 units per annum over the past five years average. It is considered that this small annual increase is not considered aspirational and will not fully support other growth policies within the plan and National Policy requirements. The base line employment led scenario is considered particularly relevant due to the projects being promoted by the City Deal.
Within the summary of the Baseline employment-led scenario it sates that it 'would provide a positive outlook for housing growth and job creation' but then considers an increase in the annual homes requirement of 23.3% to be 'slightly in excess of the Plan's housing growth potential', again an example of the plan lacking aspiration.
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
Second Deposit LDP
8.20
Representation ID: 4791
Received: 11/04/2023
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 plans spatial option should be a combination of Option 2 and 5. Although the issue of the community being more involved/ having greater influence should be embed in to the plan it should not be the leading factor for the spatial distribution of growth in the plan.
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.
