Second Deposit LDP

Amend Plan

Carmarthenshire Local Development Plan 2018-2033 – Deposit Draft
Objection on behalf of Evans Banks Planning Ltd

Further to the publication of the above document, we have been asked by our Clients to
review its contents, policies and proposals and advise them of any aspects we believe would
unreasonably affect their aspirations and interests. In doing so w consider it necessary to
make a formal representation to the “soundness” of the Carmarthenshire Deposit Local
Development Plan, including in relation to the provisions of Strategic Policy SP1 (Strategic
Growth). As a result, we offer the following for the Authority’s consideration, and Inspector’s
in due course.

Policy SP1 represents the Council’s strategic position with regard to the County’s growth
during the Plan period. It sets out that within the Plan period (2018-2033) the document is
expected to deliver “9,704 new homes to meet the identified housing requirement of 8,822.”
through a range of housing supply components. The ‘new homes’ figure has been reached
through research undertaken by and on behalf of the Council, advising that it has taken into
account a range of factors and data sets in reaching that figure. However, through our own
examination and consideration, we have identified that certain factors have not been given full or any consideration during that process, which are summarised as follows.

Like most counties in Wales, Carmarthenshire has seen not one, but two of its previous development plans fail in terms of delivering sufficient housing to meet the level of housing need the very same plans have identified. In the associated Topic Papers published by the Council, it is admitted that whilst the current adopted Carmarthenshire Local Development Plan (LDP) was expected to deliver on average 1,103 dwellings per annum, it in fact delivered less than half (501 dwellings per annum), with the previous Unitary Development Plan showing a similar trend.

Since the adoption of the current LDP in December 2014, the housing market in Carmarthenshire has seen steady growth in terms of demand, for both new and existing units. However, with supply levels of new housing being far lower than the adopted Plan identified as being needed (by some 7,500+ units), this has had a significant impact on the County’s demographics.

What increase in housing stock there has been, has indeed provided a growth in population since 2011, but only of 2.2%. However, 18.9% of the County’s population is now aged 65 years and over. In contrast, the number of people aged 15 to 64 in the County has decreased by 2.5% and those aged 15 years and under has decreased 0.8%. In addition, according to the submitted Topic Papers, the average household size is expected to have now risen to a figure of 2.30, whereas previous projections had thought it would only be 2.05.

The above therefore clearly illustrates the ongoing impact of the failure of previous Plans to deliver sufficient housing to meet the needs of its native population, as well as those wishing to move to the County to assist with the Council achieving its strategic economic objectives.
As a result, it is not considered that the current housing figure being put forward by the Deposit LDP is sufficient to compensate for the historic under provision and prevent the current worrying and unsustainable demographic trends from being reversed.

We therefore respectfully request that this Representation be given careful examination, and that the housing need figure be revisited to ensure that the document passes all the relevant tests of soundness.

Amend policy

Carmarthenshire Local Development Plan 2018-2033 – Deposit Draft
Objection to Policy HOM3 on behalf of Evans Banks Planning Ltd

Further to the publication of the above document, we have been asked by our Clients to
review its contents, policies and proposals and advise them of any aspects we believe would
unreasonably affect their aspirations and interests. In doing so we consider it necessary to
make a formal representation to the “soundness” of the Carmarthenshire Deposit Local
Development Plan, including in relation to the provisions of part of Policy HOM3 (Homes in
Rural Villages). As a result, we offer the following for the Council’s consideration, and
Inspector’s in due course.

It is clear that Policy HOM3 seeks to rectify the deficiency of previous Development Plans
and their policies when it comes to addressing the housing needs and requirements of all
members of a rural community, in addition to those in direct social housing need. In order to
sustain, preserve or recover a community’s level of sustainability, it is vital that provision for
new housing is made available for all its members, irrespective of their social or economic
backgrounds. This ensures a positive balance within such communities that will secure their
sustainability for the future, as under-provision of new housing in such settlements has been
a key factor in the decline and removal of many key community facilities (e.g. schools) within
them during previous Plan periods. It is considered that Policy HOM3, by in large therefore,
now makes a significant move towards ensuring that local planning policy in
Carmarthenshire goes some way to assist in securing this objective.

Notwithstanding the above, such rural communities and the settlements they relate to or
revolve around are somewhat smaller than established satellite villages and their associated
larger towns. Growth is therefore needed, but in a controlled manner to preserve
environmental aspects of a geographic area. Again, we welcome Policy HOM3 criteria
related aspects that allow, but at the same time control, growth of the related Rural Villages.

We also welcome that such growth should be limited to take place in the following
circumstances:
 Minor infill or a small gap between the existing built form; or
 Logical extensions and/or rounding off of the development pattern that fits in with the
character of the village form and landscape; or
 Conversion or the sub-division of large dwellings.
Notwithstanding the above, we have concerns and would object to the proposed ‘cap’ on
new open market housing development. Under the provisions of the 2nd Deposit LDP the
cap on new housing development within the Plan period must not exceed “ …10% over and
above the number of existing homes, as of the base date of the Plan in the settlement will be
allowed.”. However, in the 1st Deposit LDP this figure was 20%, although no explanation of
evidence has been provided by the Council as to why this figure should be halved? This lack
of justification or clarity on the decision in itself causes the Plan to be deemed ‘unsound’.
Firstly, we would strongly argue that in order to ensure those communities identified as Rural
Villages in the Plan can become truly sustainable and recover from years of policy neglect,
this cap should be returned to 20%. 10% is far too restrictive and will go nowhere near to
meeting the pent-up demand in rural communities for new housing.

Secondly, the 10% cap and limitation to ‘existing homes’ (and so not taking into account
recent consents) is so overly restrictive and prescriptive that it will lead to potentially bad,
illogical and unnatural placemaking. For example a village of 40 homes with natural infill
opportunities for 6 units over 2 equally sized sites, would only be able to deliver 3 units, as
the part development of the second could result in an illogical form of development that does
not compliment an existing settlement pattern or meet other policy requirements in the Plan.
The construction of all 6 would do so, but under the current 10% cap would be prevented
from doing so.

The settlement patterns of Carmarthenshire’s Rural Villages are extremely varied and each
has numerous opportunities for small scale new housing that follow the three locational
criteria of Policy HOM3, which they have been prevented from doing so historically due to
continual restrictive and illogical ‘development limits’ style policies of successive plans.
However, even with the more pragmatic approach being proposed by Policy HOM3, such
rural communities will continue to be failed and prevented from declining further if the 10%
cap is retained.

In summary, we full support the principles put forward by Policy HOM3 and its overall
approach to supporting rural communities in the identified Rural Villages. However, we
object to the proposed 10% cap put forward by the 2nd Deposit LDP, as without clear
evidence for halving the figure put forward in the 1st Deposit LDP, we are unable to see how
the objective of Policy HOM3 can be achieved. This in turn puts the soundness of the Plan
into question. In addition, in order to provide clarity and a true positive impact on rural
communities in Carmarthenshire, we propose that the relevant wording of the Policy should
be amended to read as follows:
“…20% over and above the number of existing homes and those under construction, as of
the adoption date of the Plan in the settlement will be allowed.

We therefore respectfully request that this Representation be given careful examination, and
that the cap figure and associated wording included within Policy HOM3 be revisited to
ensure that the document passes all the relevant tests of soundness.