Second Deposit LDP

Consider rewording this section or be be more ambitious by planning for greater growth.

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 pervious 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.

Instead of 'necessary' it should say 'where required as a direct result of the development'. This is an important point as S106's cannot be used to ask developers to pay to resolve existing issues just those directly created by the new development.

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

Provide greater clarity on the break down of the housing supply.

It is not clear if this list of allocations are all new proposed site, or rollover sites from previous plan or sites with planning permission. It's normal practice to break down the supply into new allocation, landbank sites (those that planning permission), windfalls and small sites. The list of sites do not need to be included in the policy they could be an Appendix instead.

Presuming they do include sites with planning or rolled over sites, does it include all the site or has an assessment been made or a percentage reduction applied to allow for sites which are less likely to come forward, as suggested in the WG DM3.

There is no explanation as to how the period in which the units will be delivered has been arrived at, what allowance has been made for the time it takes to gain planning permission.

The supporting text should refer top the trajectory in the Appendices.

Change the wording removing ' a minimum' replacing with 'a target'.

Reference policy AHOM1: Provision of Affordable Homes or combine as one policy.

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.

Policy wording should be changed to 'To achieve this new development shall aim to:

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.

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

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.