Non Site Allocation Representations Report.pdf

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SPATIAL POLICIES, KEY DIAGRAMS AND SUPPORTING DEVELOPMENT CONTROL POLICIES Policy HOU/2 Affordable Housing for Local Need Rep No Name People Type 1755 Watkin Jones Homes (Mr Goronwy Owen) [879] 1 Support Summary We support the use of the Three Dragons Toolkit for the assessment of the provision of AHLN housing provided that this is based on the WAG Practice Guidance for Delivering Affordable Housing using S106 Agreements as issued in July 2008. 7145 Cyngor Cymuned Llansannan (Mr Eifion Jones) [2082] 1 Support Summary As a Council, we believe that there is a need for more affordable housing and private houses during this period to ensure growth and future for Llansannan. As you know, we investigated affordable housing in the parish 3 years ago and the requirements were higher than is suggested in the Plan. Also, the Parish Evaluation refers many times to the lack of affordable housing for local people. Change Sought: There is a need for more affordable housing and private houses in Llansannan. 1470 Conwy Children and Young People's Partnership (Ms Alwen Sian Williams) [1867] Summary Cheaper housing for 16 -25 year olds. 5157 Ainscough Strategic Land. (Mr Nigel McGurk) [2073] 1 Support Summary Ainscogh Johnson support the policy in its general content. Change Sought: The percentage of affordable housing should be subject to negotiation with developers as part of the development control process and shold reflect the individual need in the area as well as the site characteristics. 1399 Awdurdod Parc Cenedlaethol Eryri / Snowdonia National Park Authority (Tim Polisi a Chynlluniau Strategol Eryri Policy and Strategic Plans Team) [1663] Summary I take it that the total figure should be 1920 and not 1290. Change Sought: I take it that the total figure should be 1920 and not 1290. 5281 Goodwin Planning Services Ltd (Mr Stephen Goodwin) [1162] 1 Object Summary The Council's attempt to apply affordable housing requirements to all housing developments such that 50% is required in urban areas and 100% in rural areas except for sites for single dwellings (where a financial contribution will be required) is not founded on a robust and credible evidence base and therefore fails soundness test CE2. (For further justification, see full submission). Change Sought: Policy HOU/2 should be amended such that the words "a minimum 50% AHLN" should be amended to read:- "a target of 30% AHLN". 1178 Mr Emyr Lloyd Hughes [1235] 1 Object Summary The affordable housing needs of the County will not be realised with the level of housing allocation provided for in the Plan. See point 2 in the attachment for further information. Change Sought: Under provision of allocations in the Plan. 515 Leonard Jinks Architecural Consultants Ltd (Leonard Jinks) [789] 1 Object Summary The level of affordable housing at 50% is unsustainable and not viable. Also in part A of the policy one affordable dwelling on developments of two or more houses is unviable in today's market. There is no evidence to suggest that this percentage of affordable housing can be provided therefore the plan is unsound and fails test CE2 Change Sought: An acceptable level of affordable housing will probably be between 10 - 20% in the first five years possible rising to 30% if the market improves. Within urban windfalls one affordable out of every five should be pursued. 1746 Watkin Jones Homes (Mr Goronwy Owen) [879] Summary Exception sites for 100% AHLN dwellings should be allowed on sites adjoining all towns and villages in the county. Change Sought: Exception sites for 100% AHLN dwellings should be allowed on sites adjoining all towns and villages in the county. 658 Rossisle Ltd [833] Summary Your text supports AHLN on sites outside main villages. It is not adequate to limit this to the uncertainty of giving a first priority to brownfield sites. This gives no developer certainty. Change Sought: The policy needs to be relaxed. Outside Main Village settlement boundaries, small scale ( under 10 houses) 100% AHLN will be acceptable on both brownfield and greenfield sites lying on the edge of settlements to encourage the creation of sustainable communities in line with Policies DP/2 185 Mr John Thompson [460] 1 Object Summary We feel that although Bryn Pydew fits into the category of Minor Village it should not be considered suitable for the addition of up to 3 ADLNs. This is not appropriate in Bryn Pydew due to accessibility via roads which are already problematic. There is no public transport, and there are no local shops, and no local school. The result would be significantly more traffic on worn single lane roads with no pavements poor visibility which would be dangerous to all road users including both cars and other users. Any housing should also be in character. Change Sought: It should be declared in the Plan that although Bryn Pydew is a minor village, it is not suitable for any ADLN development due to inadequate infrastructure to support this. 1254 Anwyl Construction Ltd (Mr Mike Pender) [1514] 1 Object Summary Objection to evidence base on which policy HOU/2 applies. It is incomplete/not up to date and does not support or justify the policies and proposals. See attachment. Change Sought: To make the Plan sound there needs to be an up to date evidence base to support realistic policies - especially on the overall housing requirement , the reasonable allowance for commitments etc, site capacity, the residual need for new allocations, 50% requirement for affordable housing , open space requirement , green wedges, landscape areas , renewable energy and planning obligations. 1774 Mostyn Estates Limited (Mr Peter Caldwell) [717] 1 Object Summary Policy HOU/2 Affordable Housing for Local Needs (Page 184) The requirement in HOU/2 for a minimum of 50% of all new dwellings to be Affordable Housing for Local Need (AHLN) is very high and will not be achievable through private development. The introduction of Community Infrastructure Levy and increased requirements under S106 Planning Agreements may mean developments will not be viable and private sector house building will stall. 1 1 1 1 Support The Court of Appeal in Blyth Valley Borough Council v Persimmon Homes (North East) Ltd 2008 quashed their 30% Affordable Housing target in the Local Plan because "the Planning Authority had not made an informed assessment of the economic viability of any thresholds and proportions of affordable housing proposed". The policy as drawn does not have proper regard to the economic viability of residential development particularly in a depressed economy. There are reports that AHLN is difficult to sell at the lower prices because purchasers are unable to obtain mortgages and the dwellings remain vacant because of the Planning conditions. This policy may reduce the supply of development land on to the market. Proposal The policy for 50% AHLN has not been based on robust and credible evidence and is not sustainable and the required number of houses will not be delivered in accordance with the Plan's targets Change Sought: The policy for 50% AHLN has not been based on robust and credible evidence and is not sustainable and the required number of houses will not be delivered in accordance with the Plan's targets. Object Object Object 106
SPATIAL POLICIES, KEY DIAGRAMS AND SUPPORTING DEVELOPMENT CONTROL POLICIES Policy HOU/2 Affordable Housing for Local Need Rep No Name People Type 1257 Anwyl Construction Ltd (Mr Mike Pender) [1514] 1 Object Summary This objection is mainly in relation to the site appraisals referred to in Policy HOU/2 and set out in Background Paper No 9. But it also refers to HOU/1 being the overall housing requirement as this will have an impact on the delivery of planning obligations especially affordable housing. This objection relates to validity of the site developer appraisals and the extent to which they assert that developer contributions - especially affordable housing- have been assessed and demonstrate that 50% affordable housing on site with scope for other developer contributions are economically viable. Change Sought: It is submitted that the development appraisals are flawed and the 50% affordable housing requirement cannot be achieved and so the policies are unsound. Rather than start with a fixed % and then negotiate at site specific level is it not better to simply say that the % affordable will be based on an indicative but lower target of say 20% and each site appraisal started from that point. 1747 Watkin Jones Homes (Mr Goronwy Owen) [879] 1 Object Summary We do not see why there is a requirement for tier 1 and tier 2 villages. Change Sought: We propose that AHLN be provided at 30% on all development sites in the plan and with 100% being provided on all council and publicly owned sites. 822 Campaign for the Protection of Rural Wales (Mr Richard Waters) [985] 1 Object Summary The need for high level of affordable housing is acknowledged and supported, the figure of a minimum of 50% would appear to be unrealistically high, particularly in view of all of the other financial or other contributions with which developers are likely to be faced. Whilst it is acknowledged that the selected sites have been subjected to the Three Dragons Appraisal Toolkit, the site appraisals in Background Paper 9 would seem to indicate that many of the rural sites would have a very low residual percentage value (3-4%) that would question the likelihood of a developer taking on the site. Change Sought: The Plan should be amended to ensure that it proposes a more realistic and defensible requirement for the provision of affordable dwellings. 1174 Gordon Kenyon (Kenyon & Company) (Mr Gordon Kenyon) [1188] 1 Object Summary The requirement of Policy HOU/2 for allocated residential sites to provide 50% affordable housing provision is wholly unreasonable and unrealistic. See attachment for further information. Change Sought: Redraft policy HOU/2 to take account of the low level of finance and public subsidy likely to be available and to provide appropriate site thresholds and site specific targets based on a realistic and credible assessment of viability. See attachment for further information. 186 dr caren thompson [463] 1 Object Summary I object to Bryn Pydew, which is classed as a minor village, being deemed suitable for development of up to 3 ADLN. I feel the provisions available in the village are inadequate to support so many new homes. There is no local shop, school or public transport link. All the roads to access the village are narrow, single lane, have poor visibility and are in poor condition already. The burden of more traffic from these possible homes would be dangerous for residents and leisure users. Change Sought: I would like Bryn Pydew to be exempt from the possible development of 3 ADLN as stated in the policy for Minor Villages (Policy numbers 5.1 and 5.2) on the grounds of poor infrastructure. 1745 Watkin Jones Homes (Mr Goronwy Owen) [879] 1 Object Summary How can you negotiate a percentage when the statement includes the term "a minimum of 50% AHLN" - does that mean that the negotiations start at 100% and work their way down to 50%? What is meant by "It is expected that AHLN will be provided without subsidy" - these will be sibsidised by the developers unless the council are to cover the cost of the development of these dwellings so that they are not subsidised by the developers? Change Sought: You should consider re-wording this policy otherwise this will impact dramatically on residential development in the county as developers look for easier and more profitable developments elsewhere in other local authority areas. 555 CDN Planning (Mr Rhys Davies BA (Hons) MRTPI) [131] 1 Object Summary The requirement to provide 50% of housing on new housing sited is likely to be unviable. This policy requirement is not supported by any evidence to indicate that the provision of 50% affordable housing on new housing sites is viable. As such the LDP housing strategy which has its roots in the need to deliver significant levels of affordable housing during the plan period will prove to be fundamentally flawed. One of the main objectives of the LDP will not be delivered if a requirment for a minimum of 50% affordable housing is required on new housing sites. Change Sought: Revision of the 50% affordable housing requirement and its replacement with a target of 30% affordable housing on greenfield housing sites and a more flexible approach to the provision of affordable housing on previously developed land. 7234 Welsh Assembly Government (Mr Mark Newey) [2176] 1 Object Summary There is a figure of 331 dwellings/year in paragraph 4.56, but then 1908 people needing AH is referred to - 50% reduction not explained. Plan looks to nonmarket delivery- no endorsement from relevant industry stating whether it's realistic. Unclear if 50% AH target is viable on small/windfall sites creating deliverability difficulties. High yields could result in lack of robustness reducing plan flexibility to market changes. Higher levels of housing provision analysis and their ability to deliver more AH appears flawed and misleading. Focus on 'local need' for AH could stifle the labour movement in urban areas which NPP says should be accessible for all. Change Sought: Explain 50% reduction in AH need. Need endorsement/proof from relevant industry to state whether non-market delivery is possible. Clarify if 50% AH on small/windfall sites is viable. Reanalyse higher levels of housing provision and their ability to deliver AH. Remove focus on 'local need' for AH if low housing provision used. 7188 Redrow (Mr Robin Buckley) [1996] Summary Redrow object to Policy HOU/2 - Affordable Housing for Local Need for the following reasons:- 1. The proposed affordable housing minimum requirement reflects an over-concentration within the Plan on existing housing commitments (which will deliver very few affordable homes) and an overall housing requirement which has been set far too low. 2. No consideration has been given to the ability of the Registered Social Landlords which operate in Conwy to purchase the implied number of new homes. Change Sought: 3. A 50% affordable housing requirement will not result in the creation of mixed and well balanced communities. A lower affordable housing target should be set (e.g. 30%) following a thorough reassessment of the deliverability of the existing housing land supply, a new housing requirement figure of at least 9300 net additions to the dwelling stock and realistic viability testing. 7250 Welsh Assembly Government (Mr Mark Newey) [2176] 1 Object Summary Poor drafting, policy HOU/2 appears to state that market housing will be provided on rural exception sites in Tier 1 'main villages'. This would be contrary to national policy which states that such sites are only for AHLN. Change Sought: redraft HOU/2 1777 Jones and Fishwick Ltd [2003] Summary Minafon Farm, Betwys Yn Rhos be allocated for general purpose housing with 50% affordable housing. Change Sought: The Minafon Farm site should be allocated for open market housing with a realistic proportion of affordable housing rather than 100% affordable. 1553 Countryside Council for Wales (Mr Richard Ninnes) [1948] Summary The policy is not consistent in its wording to mean that "only AHLN units will be permitted on exception sites". Criterion (a)ii should be further amended by clarifying that small scale 100% AHLN sites outside Main Village settlement boundaries will be acceptable subjec to meeting criteria against which a housing development would be judged (MIPPS 01/2006 Housing, para. 9.2.22), including a search sequence. Change Sought: Revise the wording of Policy HOU/2 1 1 1 Object Object Object 107
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CYNLLUN DATBLYGU LLEOL CONWY I’W
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Policy CTH/3 Buildings and Structur
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LDP - Deposit Plan INTRODUCTION 1.2
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INTRODUCTION 1.5 Rep No Name 1434 L
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INTRODUCTION 1.19 Tests of Soundnes
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INTRODUCTION 1.24 Policy Framework
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INTRODUCTION 1.26 Plan Area context
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INTRODUCTION 1.32 Rep No Name Peopl
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VISION AND OBJECTIVES 2.1 A Vision
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VISION AND OBJECTIVES 2.8 Rep No Na
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THE SPATIAL STRATEGY AND KEY DIAGRA
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IMPLEMENTATION AND MONITORING FRAME
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SECTION ONE - INTRODUCTION 1.2 The
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SECTION TWO - VISION AND OBJECTIVES
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SECTION FOUR - SPATIAL POLICIES, KE
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SECTION FIVE - IMPLEMENTATION AND M
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