Second Deposit LDP

Allocate the site for housing in the Revised LDP.

Our comments on the First Deposit Plan are set out below and remain relvant. There has been some updating of the evidence base for the Plan since March 2020, this does not fundamenlty alter the case that we presented in March 2020. Then as now, the housing requirement for 2018-2033 is 8,825 which we said was too low. Of note is that the First Deposit Plan enabled 10,160 homes whereas the Seocnd Deposit Plan enables 9,704 homes. There is therefore a reduction in embedded flexibility and contingency, for a plan requirement that is already not representative a a positive socio-economic vison.

First Deposit Stage
At First Depsoit Stage we made the following comments
Section 8 of the Deposit LDP sets out the range of growth options that have been prepared to inform the Plan.
The PG 10-year scenario from the 2019 Edge Analytics Report has been selected which generates a requirement for 8,835 homes for 2018-2033 (589 per annum) and 354 jobs per year.
The general thrust of Section 8 is that the housing requirement should at least reflect the rate of housing delivery that has been experienced since 2015 (545 homes per annum).
Lower growth options are rejected for negative socio-economic impacts and non-adherence to the Plans Vision and Strategic Objectives. We agree.
Higher growth options are presented positively, notably the output for ’Population Growth Long Term (2018 Report) for 9,887 homes (659 per annum) and 353 jobs per year and 10,065 homes and 439 jobs per year (PG Long Term (2019 Addendum Report). The later now essentially forms the proposed supply figure.
The proposed housing supply of the Deposit LDP is said be capable of delivering 10,160 homes (a 15% uplift to ensure that the base requirement is met).
We conclude that the proposed requirement is far too low. At the very least it should be 10,065 homes (baseline), With a 15% uplift for flexibility generating a supply figure of 11,575 homes. This generates a need for another 1,415 homes.
A scenario of 14,090 homes and 632 jobs per year derived from pre-recession trends is said to be commensurate with the adopted LDP. This is said to be economically ambitious but ‘undeliverable’ and ‘unsustainable’. We note that the Council do not say that 632 jobs per year is unrealistic as forecast, and rightly so. The Council’s own Employment Sectoral Report (WSP, 2017) generates a forecast for 2017-2032 of 18,681 jobs (1,245 per annum,or 1,182 after ‘double-jobbing’.
We are not convinced that a baseline requirement of 14,090 homes and 632 jobs per annum is ‘undeliverable’; in terms of housing or employment growth. It is not unsustainable socio-economically. We see no evidence that it would be environmentally unsustainable to attempt to meet these figures, wholly or in part.
The spatial strategy should seek to meet these higher figures, subject to land suitbality and availability.
Policy SG1 should be amended to seek to meet as far as possible a previously achvieved set of development outputs for the area
We agree with the selection of spatial strategy Option 4 in order have a strategy in place for the 6 sub-areas (clusters) of the County that have been identified.

Second Deposit Plan
Section 8 now optioneers the First Deposit Stategy against the Welsh Governemnt’s 2018 based population projections. Both the principal projection and higher variant are rejected as a being unrepresentative of a sustainable future for the area. Instead, the Council generally prefers 10-15 year trend based population projections (which present simalar outputs) as presenting a more positive vison. They are also more in tune with the strategy and housing requirement of the First Deposit Plan.
The final two scenarios generate higher housing requirements of around 10,000 -10,500 homes. Although yet higher still than previous completion rates these are still some way below pre-recession growth rates.
We question why the final two secarios would not deliver the Vision and Strategic Objectives for the area and the confidence with which the Council states that this level of growth would tip into being undeliverable. Quoting percentages masks a realtive modest uptick in actual delivery rates. It is the not case that the higher ambition within the final two scnearios would cross a threshold in terms of thier environmental effects.
We maintain our comments, expressed at First Deposit Stage, that, at the very least the Plans housing requirement should be 10,065 homes (baseline), With a 15% uplift for flexibility. This generates a supply figure of around 11,575 homes, as opposed to the 9,700 enabled by the Plan.
The pre-recession trend scenrio no longer appears in the Second Deposit Plan, so presumably the Council no longer considers it to be a reasonble alternative?

Site Submission
Against this background additional land at Penygroes should be allocated within Settlement Cluster 3. The Plan already allocates land for 290 homes across 5 sites and these all have planning permission. Emlyn Brickworks (PrC3/MU1) (177) and land adj Pant y Blodau (PrC3/h22) (79 homes) account for 88% of proposed new homes.
Land west of Waterloo Road and south of Maesglas (previously submitted at First Deposit Stage) should be allocated for 44 homes.
A site location plan and testing layout is attached to this representation showing an indicative layout for 44 homes. The site is already contained on 3 sides, including the relatively recent development at Clos Ael-Y-Bryn to the south and Cwrt Y-Fynnon to the north east. The surrounding settlement and a strong hedgerow to the east provide a high degree of enclosure and the land is within the general envelope of the village.
We assess that the ISA of this site is identical to that prepared by the Council for the allocated site known as ‘ land adj Pant y Blodau’ (PrC3/h22) in respect of significant effects. This concludes that "This site does not utilise previously developed land, however it otherwise performs well against the sustainability framework".
We also refer the inspector to the proceedual issues rasied under section of 4 of this represertation.

That the Plan's housing requirement should be increased at the very least to 10,065, with a 15% uplift for flexibility.

Our comments on the First Deposit Plan are set out below and remain relvant. There has been some updating of the evidence base for the Plan since March 2020, this does not fundamenlty alter the case that we presented in March 2020. Then as now, the housing requirement for 2018-2033 is 8,825 which we said was too low. Of note is that the First Deposit Plan enabled 10,160 homes whereas the Seocnd Deposit Plan enables 9,704 homes. There is therefore a reduction in embedded flexibility and contingency, for a plan requirement that is already not representative a a positive socio-economic vison.

First Deposit Stage
At First Depsoit Stage we made the following comments
Section 8 of the Deposit LDP sets out the range of growth options that have been prepared to inform the Plan.
The PG 10-year scenario from the 2019 Edge Analytics Report has been selected which generates a requirement for 8,835 homes for 2018-2033 (589 per annum) and 354 jobs per year.
The general thrust of Section 8 is that the housing requirement should at least reflect the rate of housing delivery that has been experienced since 2015 (545 homes per annum).
Lower growth options are rejected for negative socio-economic impacts and non-adherence to the Plans Vision and Strategic Objectives. We agree.
Higher growth options are presented positively, notably the output for ’Population Growth Long Term (2018 Report) for 9,887 homes (659 per annum) and 353 jobs per year and 10,065 homes and 439 jobs per year (PG Long Term (2019 Addendum Report). The later now essentially forms the proposed supply figure.
The proposed housing supply of the Deposit LDP is said be capable of delivering 10,160 homes (a 15% uplift to ensure that the base requirement is met).
We conclude that the proposed requirement is far too low. At the very least it should be 10,065 homes (baseline), With a 15% uplift for flexibility generating a supply figure of 11,575 homes. This generates a need for another 1,415 homes.
A scenario of 14,090 homes and 632 jobs per year derived from pre-recession trends is said to be commensurate with the adopted LDP. This is said to be economically ambitious but ‘undeliverable’ and ‘unsustainable’. We note that the Council do not say that 632 jobs per year is unrealistic as forecast, and rightly so. The Council’s own Employment Sectoral Report (WSP, 2017) generates a forecast for 2017-2032 of 18,681 jobs (1,245 per annum,or 1,182 after ‘double-jobbing’.
We are not convinced that a baseline requirement of 14,090 homes and 632 jobs per annum is ‘undeliverable’; in terms of housing or employment growth. It is not unsustainable socio-economically. We see no evidence that it would be environmentally unsustainable to attempt to meet these figures, wholly or in part.
The spatial strategy should seek to meet these higher figures, subject to land suitbality and availability.
Policy SG1 should be amended to seek to meet as far as possible a previously achvieved set of development outputs for the area
We agree with the selection of spatial strategy Option 4 in order have a strategy in place for the 6 sub-areas (clusters) of the County that have been identified.

Second Deposit Plan
Section 8 now optioneers the First Deposit Stategy against the Welsh Governemnt’s 2018 based population projections. Both the principal projection and higher variant are rejected as a being unrepresentative of a sustainable future for the area. Instead, the Council generally prefers 10-15 year trend based population projections (which present simalar outputs) as presenting a more positive vison. They are also more in tune with the strategy and housing requirement of the First Deposit Plan.
The final two scenarios generate higher housing requirements of around 10,000 -10,500 homes. Although yet higher still than previous completion rates these are still some way below pre-recession growth rates.
We question why the final two secarios would not deliver the Vision and Strategic Objectives for the area and the confidence with which the Council states that this level of growth would tip into being undeliverable. Quoting percentages masks a realtive modest uptick in actual delivery rates. It is the not case that the higher ambition within the final two scnearios would cross a threshold in terms of thier environmental effects.
We maintain our comments, expressed at First Deposit Stage, that, at the very least the Plans housing requirement should be 10,065 homes (baseline), With a 15% uplift for flexibility. This generates a supply figure of around 11,575 homes, as opposed to the 9,700 enabled by the Plan.
The pre-recession trend scenrio no longer appears in the Second Deposit Plan, so presumably the Council no longer considers it to be a reasonble alternative?

Site Submission
Against this background additional land at Penygroes should be allocated within Settlement Cluster 3. The Plan already allocates land for 290 homes across 5 sites and these all have planning permission. Emlyn Brickworks (PrC3/MU1) (177) and land adj Pant y Blodau (PrC3/h22) (79 homes) account for 88% of proposed new homes.
Land west of Waterloo Road and south of Maesglas (previously submitted at First Deposit Stage) should be allocated for 44 homes.
A site location plan and testing layout is attached to this representation showing an indicative layout for 44 homes. The site is already contained on 3 sides, including the relatively recent development at Clos Ael-Y-Bryn to the south and Cwrt Y-Fynnon to the north east. The surrounding settlement and a strong hedgerow to the east provide a high degree of enclosure and the land is within the general envelope of the village.
We assess that the ISA of this site is identical to that prepared by the Council for the allocated site known as ‘ land adj Pant y Blodau’ (PrC3/h22) in respect of significant effects. This concludes that "This site does not utilise previously developed land, however it otherwise performs well against the sustainability framework".
We also refer the inspector to the proceedual issues rasied under section of 4 of this represertation.