Second Deposit LDP

Search representations

Results for Pegasus Group search

New search New search

Object

Second Deposit LDP

8.20

Representation ID: 5164

Received: 12/04/2023

Respondent ID: 4682

Respondent: Pegasus Group

Legally compliant? Not specified

Sound? No

Representation Summary:

Whilst we are broadly supportive of the preferred Spatial Option, we feel that it needs to be more explicit in stating that the strategy needs to align with the ambitious economic aspirations of the plan.

At present, we do not feel that this is reflected in the proposed Spatial Option and, therefore, it has not been fully justified in the context of the Council's economic growth ambitions.

We would stress that this does not require wholesale changes to the proposed Spatial Option as this could still be community led and the delivery of sustainable development should be at the heart of all Plan strategies. However, we would wish to see it reflect the Council's ambitious economic growth aspirations and acknowledge that this will influence the spatial distribution of development.


Our response:

Disagree. The development of the preferred option has emerged from the consideration of the spatial options and other considerations, including the economic needs and aspirations of the County. The option will recognise and reflect investment and economic benefits to the County and its communities through the City Deal, and other economic opportunities. It has utilised background evidence on the linkages between housing and economic development as set out within pieces of background evidence that the Council has commissioned. There is no further need to be more explicit in including the change suggested by the respondent.

Object

Second Deposit LDP

9. A New Strategy

Representation ID: 5165

Received: 12/04/2023

Respondent ID: 4682

Respondent: Pegasus Group

Legally compliant? Not specified

Sound? No

Representation Summary:

We are broadly supportive of the Plan's ambitions to deliver economic growth and an uplifted housing requirement to support this. However, the perceived reduced importance of delivering the Council's ambitious economic growth targets within the Preferred Spatial Option has manifested in what we consider to be an ineffective Plan Strategy.


Our response:

Disagree. The strategy of the revised LDP seeks to support the distribution of housing and economic growth which is of a scale and nature appropriate to the county area, and evidence presented within the Deposit LDP and Topic Paper identifies a balanced and achievable targets in meeting economic growth. The revised LDP seeks to ensure that development is appropriate to the settlement and reflective of its ability to accommodate growth and to support the serviced and facilities available.

Object

Second Deposit LDP

Strategic Policy - SP1: Strategic Growth

Representation ID: 5166

Received: 12/04/2023

Respondent ID: 4682

Respondent: Pegasus Group

Legally compliant? Not specified

Sound? No

Representation Summary:

Support is given to deliver a higher quantum of dwellings over the plan period to align with the Council's economic growth ambitions & the proposed 10% flexibility. However, we question why this has been reduced from the 15% flexibility applied in the First Deposit Revised LDP. This is particularly important in the context where one of the reserve sites under Policy SG2 has been removed.

We are not convinced the distribution of housing has been properly justified in the context of the ambition to deliver higher levels of economic growth.

The distribution strategy does not take a realistic view of the capacity of lower order settlements to deliver economic growth, relative to the Tier 1 settlements and has, accordingly, failed to allocate a sufficient level of housing in close proximity to key employment areas.

It is important for housing to be delivered in close proximity to key employment areas. Policies SP1 and SP4 (including their supporting text) need to clearly justify the overall quantum of development to be delivered at each settlement tier and then explain how it will be distributed to support the economic aspirations of the plan, alongside its sustainability and community aspirations. Its failure to do so at present is a significant deficiency with the plan that needs to be addressed.


Our response:

Disagree. 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 appropriate and deliverable housing requirement has been set within the Revised LDP.

The strategy of the revised LDP seeks to support the distribution of housing and economic growth which is of a scale and nature appropriate to its cluster. In this respect the revised LDP seeks to ensure that development is appropriate to the settlement and reflective of its ability to accommodate growth and the services and facilities available. Reference is drawn to the Growth and Spatial Distribution topic papers and the position statement relating to Housing Growth.

Object

Second Deposit LDP

Strategic Policy – SP3: Sustainable Distribution – Settlement Framework

Representation ID: 5167

Received: 12/04/2023

Respondent ID: 4682

Respondent: Pegasus Group

Legally compliant? Not specified

Sound? No

Representation Summary:

Policy SP3 sets out the settlement hierarchy and settlement clusters. We largely agree with the structure and support the Ammanford/Cross Hands area being included within the first tier – Principal Settlements.

We also agree with the assertion that growth and development will be directed to sustainable
locations in accordance with the spatial framework; however, as mentioned above, we have some reservations with how this has been implemented.

Whilst we note that the highest proportion of development is due to be delivered at the Tier 1 settlements (a principle we support), we consider that too great a proportion of growth has been allocated to lower order settlements. As stated above, the Plan is unrealistic in the way it proposes to distribute growth to deliver its economic aspirations and the allocation of housing sites to support this is also unsuitable as a result.

If the Plan is serious about delivering economic growth, sustainable development and mitigating its impacts on the environment to combat climate change, then it needs to re-think its distribution framework and allocate higher levels of development to the Tier 1 settlements.


Our response:

The policies and proposals of the Revised LDP are considered sound and deliverable emerging from a robust evidence base and having been formulated with regard to, and in a manner consistent with the Integrated Sustainability Appraisal.

The settlements concerned have been allocated sufficient housing in accordance with the spatial hierarchy and is sufficiently evidenced within background and topic papers.

Object

Second Deposit LDP

Strategic Policy – SP4: A Sustainable Approach to Providing New Homes

Representation ID: 5168

Received: 12/04/2023

Respondent ID: 4682

Respondent: Pegasus Group

Legally compliant? Not specified

Sound? No

Representation Summary:

Policies SP1 and SP4 (including their supporting text) need to clearly justify the overall quantum of development to be delivered at each settlement tier and then explain how it will be distributed to support the economic aspirations of the plan, alongside its sustainability and community aspirations. Its failure to do so at present is a significant deficiency with the plan that needs to be addressed.


Our response:

Disagree. 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-based 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 appropriate and deliverable housing requirement within the Deposit Revised LDP factors in the ability to meet the strategic objectives and policies of the Council, retains the young within the county, delivers for the needs of all our communities both urban and rural, and provides the opportunity for job creation, amongst others. The relationship between household growth and economic growth is further considered in the Growth and Spatial Distribution Part 2: Job creation and the economy.

Further consideration will be given at the examination of the Plan.

Object

Second Deposit LDP

SD1: Development Limits

Representation ID: 5169

Received: 12/04/2023

Respondent ID: 4682

Respondent: Pegasus Group

Legally compliant? Not specified

Sound? No

Representation Summary:

This policy states that development within the identified development of Tier 1-3 settlements
will be acceptable, provided that they accord with other relevant policies of the LDP. Whilst there are exceptions to this rule (for example, Policy HOM6), the policy does not set out a scenario whereby development for traditional housing can come forward beyond the development limits. This will be problematic in circumstances where the Council's housing delivery fails to keep pace with their proposed annual requirement.

Whilst we support the principle of identifying specific sites to meet the development needs of the district within the LDP to guard against excessive unplanned development, Local Plans still need to be sufficiently flexible to ensure that housing and other types of development can come forward to meet the needs of the population.

We acknowledge that the plan has attempted to plan positively for housing growth in particular and sought to incorporate measures to secure this (10% buffer to the housing requirement (albeit reduced from 15%) and the identification of reserve sites) over the plan period. However, we consider that policy SD1 should incorporate additional flexibility to allow development to come forward under certain circumstances (as specified above) in order the ensure the plan can remain as effective as possible for its duration.


Our response:

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 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 and an amendment to the policy is not necessary.

Object

Second Deposit LDP

HOM1: Housing Allocations

Representation ID: 5170

Received: 12/04/2023

Respondent ID: 4682

Respondent: Pegasus Group

Legally compliant? Not specified

Sound? No

Representation Summary:

Requests the inclusion of a new site within the Plan for inclusion within Gorslas (AS2/067/002).

We suspect that when the plan is reviewed in light of these issues, a higher proportion of growth will be identified at the Tier 1 settlements and this will require additional housing allocations to be included.

Our client's Site is available, deliverable and sustainably located. We have assessed it against the Council's ISA template and it has performed very well with few minor issues. We would, therefore, support a new policy allocating the Site for residential development in the final
version of the LDP.


Our response:

There is sufficient and more appropriate land available for residential use within the settlement to accommodate its housing need.

For instructions on how to use the system and make comments, please see our help guide.