Second Deposit LDP

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Object

Second Deposit LDP

9.10

Representation ID: 4792

Received: 11/04/2023

Respondent ID: 2558

Respondent: The Home Builders Federation

Legally compliant? Yes

Sound? No

Representation Summary:

The HBF does not agree that the proposed strategy can be described as 'ambitious' as in terms of housing numbers it merely plans to replicate what the previous plan achieved. The Swansea Bay City Deal and the areas status in the National plan as a Regional Growth area are the changes since the previous plan which should be a reason to be more ambitious and therefore allocated a higher housing requirement.

Our response:

The Population and Household Projection Topic Paper and the evidence contained within the Housing and Economic Growth sets out the informing considerations and the justification for the population and household projections for the County.

In assessing and identifying the housing requirement for the Plan and in accordance with Planning Policy Wales the WG local authority level projections were utilised as a starting point.

The Housing and Economic Growth Report sought to review and assess the appropriateness of the latest WG population and household projections for Carmarthenshire and sought to also provide an alternative suite of demographic and trend based evidence to consider.

The Council considers that an achievable, appropriate and deliverable housing requirement has been set within the Revised LDP.

Reference is drawn to the Growth and Spatial Distribution topic papers and the position statement relating to Housing Growth.

Object

Second Deposit LDP

9.43

Representation ID: 4793

Received: 11/04/2023

Respondent ID: 2558

Respondent: The Home Builders Federation

Legally compliant? No

Sound? No

Representation Summary:

The wording requires a minor amendment to keep it in line with the Circular on S106's.

Our response:

Disagree. The word necessary is implicit in covering the correct requirement as set out in national guidance.

Object

Second Deposit LDP

HOM1: Housing Allocations

Representation ID: 4798

Received: 11/04/2023

Respondent ID: 2558

Respondent: The Home Builders Federation

Legally compliant? No

Sound? No

Representation Summary:

Housing figures not clear.

No reference to Trajectory in the supporting text.

Our response:

A Housing Position Statement has been prepared which sets out the housing figures and calculations for clarity. These matters will be discussed at examination.

Reference to the Housing Trajectory is contained within paragraph 11.81.

Object

Second Deposit LDP

Strategic Policy – SP 5: Affordable Homes Strategy

Representation ID: 4799

Received: 11/04/2023

Respondent ID: 2558

Respondent: The Home Builders Federation

Legally compliant? No

Sound? No

Representation Summary:

The policy is a statement indicating a minimum figure of affordable homes planned to be delivered by the plan, however, it does not provide any actions for developers to meet the figure.

It is normal practise to describe the affordable housing provision as a target, as set out in the Welsh Government Development Plan Manual 3.

Our response:

Disagree. The terminology used within the policy allows for a higher proportion of affordable housing where supported by viability evidence.

Object

Second Deposit LDP

Strategic Policy – SP 12: Placemaking and Sustainable Places

Representation ID: 4800

Received: 11/04/2023

Respondent ID: 2558

Respondent: The Home Builders Federation

Legally compliant? Yes

Sound? Yes

Representation Summary:

The policy wording is too prescriptive as not all development will be able to deliver all of the listed items.

The requirement for SuDS is covered by existing separate legislation so does not need to be included in the policy requirements.

Our response:

The integration of the placemaking principles are consider to contribute to the delivery of the Plan's Vision of creating prosperous, cohesive, and sustainable communities. Strategic Policy – SP 12: Placemaking and Sustainable Places is considered sound and deliverable, emerging from a robust evidence base and having been formulated with regard to national planning policy. Matter to be further considered at examination.

Object

Second Deposit LDP

AHOM1: Provision of Affordable Homes

Representation ID: 4802

Received: 11/04/2023

Respondent ID: 2558

Respondent: The Home Builders Federation

Legally compliant? Yes

Sound? No

Representation Summary:

The requirement can't be a target and a minimum. The percentage requirement for affordable homes should not be based on the size of the site. Aggregating adjacent site will not work if sites are in different ownerships. Perpetuity should not be a policy requirement. No 'key sites' viability assessment has ben carried out. Such approach takes no account of market areas.

Change suggested by respondent:

Delete this policy and replace with a new policy based on viability testing of housing market areas also taking account of the above comments.

Full text:

This is the first time that the HBF has seen an affordable housing policy like this, in that it proposes a percentage requirement based on the size of the site rather than the viability of the area. Such an approach is not supported by the Welsh Government Development Plan Manual 3. Further such an approach takes no account of market areas which vary greatly in this area due to the geographical size and differences between the unban and rural areas, as identified by Appendix A of the viability document. These areas were used by the LHMA but have then not been used by the policy to consider viability by area. There is no explanation in the plan or the Viability evidence document as to why this different approach has been used.

CARMARTHENSHIRE HOUSE PRICE DATABASE SUMMARY as at November 2022 : APPENDIX B indicates average prices range across the borough from £164K - £284K which highlights the impact location will have on viability. Further the same table indicates that the increase in prices since 2019 has varied greatly between 13.1% and 56.9% again highlighting the difference in market areas.

No 'key sites' viability assessment has ben carried out, other recent RLP's have shown that these sites need to be considered differently to the high level viability assessment.

The wording of the policy states 'The affordable housing target percentage noted is a target to be used as a starting point for affordable housing negotiation'. This is unacceptable and contradicts its self if its a target it can't also be the starting point.

As is the normal practice there is no mention of viability within the policy and the need to consider whether it is viable for the scheme to deliver affordable housing along with many other potential S106 cost.

The idea of using the aggregate number of adjacent sites is not appropriate if the sites are being developed by different developers. Its is presumed that this wording is trying to avoid sites being subdivided to reduce affordable housing requirements, if this is the case then this is what it should say.

The requirement for perpetuity should not be contained within the policy wording and the acceptability of it should be checked with local RSL's.

Our response:

The percentage targets identified in policy AHOM1 are partly determined by site size (in terms of the number of dwellings that a site can be expected to deliver). This recognises that larger sites are likely to be able to deliver a greater proportion and absolute number of new affordable homes. The evidence provided in the Financial Viability Report supports this approach.
Work has been undertaken to assess the financial viability of a number of key sites allocated within the Plan.
The Policy seeks to ensure that the affordable dwellings remain affordable for all subsequent occupants in perpetuity. It is not clear why this should not be a policy requirements.

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