Non Site Allocation Representations Report.pdf
Non Site Allocation Representations Report.pdf
Non Site Allocation Representations Report.pdf
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SPATIAL POLICIES, KEY DIAGRAMS AND SUPPORTING DEVELOPMENT CONTROL POLICIES<br />
Policy HOU/2 Affordable Housing for Local Need<br />
Rep No Name<br />
People Type<br />
1257 Anwyl Construction Ltd (Mr Mike Pender) [1514]<br />
1 Object<br />
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<br />
the overall housing requirement as this will have an impact on the delivery of planning obligations especially affordable housing. This objection relates to<br />
validity of the site developer appraisals and the extent to which they assert that developer contributions - especially affordable housing- have been assessed<br />
and demonstrate that 50% affordable housing on site with scope for other developer contributions are economically viable.<br />
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.<br />
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<br />
lower target of say 20% and each site appraisal started from that point.<br />
1747 Watkin Jones Homes (Mr Goronwy Owen) [879]<br />
1 Object<br />
Summary We do not see why there is a requirement for tier 1 and tier 2 villages.<br />
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.<br />
822 Campaign for the Protection of Rural Wales (Mr Richard Waters) [985]<br />
1 Object<br />
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,<br />
particularly in view of all of the other financial or other contributions with which developers are likely to be faced.<br />
Whilst it is acknowledged that the selected sites have been subjected to the Three Dragons Appraisal Toolkit, the site appraisals in Background Paper 9<br />
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<br />
taking on the site.<br />
Change Sought: The Plan should be amended to ensure that it proposes a more realistic and defensible requirement for the provision of affordable dwellings.<br />
1174 Gordon Kenyon (Kenyon & Company) (Mr Gordon Kenyon) [1188]<br />
1 Object<br />
Summary The requirement of Policy HOU/2 for allocated residential sites to provide 50% affordable housing provision is wholly unreasonable and unrealistic. See<br />
attachment for further information.<br />
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<br />
specific targets based on a realistic and credible assessment of viability. See attachment for further information.<br />
186 dr caren thompson [463]<br />
1 Object<br />
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<br />
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,<br />
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<br />
leisure users.<br />
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<br />
grounds of poor infrastructure.<br />
1745 Watkin Jones Homes (Mr Goronwy Owen) [879]<br />
1 Object<br />
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%<br />
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<br />
unless the council are to cover the cost of the development of these dwellings so that they are not subsidised by the developers?<br />
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<br />
more profitable developments elsewhere in other local authority areas.<br />
555 CDN Planning (Mr Rhys Davies BA (Hons) MRTPI) [131]<br />
1 Object<br />
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<br />
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<br />
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<br />
delivered if a requirment for a minimum of 50% affordable housing is required on new housing sites.<br />
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<br />
flexible approach to the provision of affordable housing on previously developed land.<br />
7234 Welsh Assembly Government (Mr Mark Newey) [2176]<br />
1 Object<br />
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<br />
delivery- no endorsement from relevant industry stating whether it's realistic. Unclear if 50% AH target is viable on small/windfall sites creating<br />
deliverability difficulties. High yields could result in lack of robustness reducing plan flexibility to market changes. Higher levels of housing provision analysis<br />
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<br />
says should be accessible for all.<br />
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<br />
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<br />
provision used.<br />
7188 Redrow (Mr Robin Buckley) [1996]<br />
Summary Redrow object to Policy HOU/2 - Affordable Housing for Local Need for the following reasons:-<br />
1. The proposed affordable housing minimum requirement reflects an over-concentration within the Plan on existing housing commitments (which will deliver<br />
very few affordable homes) and an overall housing requirement which has been set far too low.<br />
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.<br />
Change Sought:<br />
3. A 50% affordable housing requirement will not result in the creation of mixed and well balanced communities.<br />
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<br />
housing requirement figure of at least 9300 net additions to the dwelling stock and realistic viability testing.<br />
7250 Welsh Assembly Government (Mr Mark Newey) [2176]<br />
1 Object<br />
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<br />
national policy which states that such sites are only for AHLN.<br />
Change Sought: redraft HOU/2<br />
1777 Jones and Fishwick Ltd [2003]<br />
Summary Minafon Farm, Betwys Yn Rhos be allocated for general purpose housing with 50% affordable housing.<br />
Change Sought: The Minafon Farm site should be allocated for open market housing with a realistic proportion of affordable housing rather than 100% affordable.<br />
1553 Countryside Council for Wales (Mr Richard Ninnes) [1948]<br />
Summary The policy is not consistent in its wording to mean that "only AHLN units will be permitted on exception sites".<br />
Criterion (a)ii should be further amended by clarifying that small scale 100% AHLN sites outside Main Village settlement boundaries will be acceptable subjec<br />
to meeting criteria against which a housing development would be judged (MIPPS 01/2006 Housing, para. 9.2.22), including a search sequence.<br />
Change Sought: Revise the wording of Policy HOU/2<br />
1<br />
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Object<br />
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