Strategaeth a Ffefrir

Whilst the overall PS focused on the Coastal Communities of Conwy is supported the distribution of development does not appear consistent with the principles of sustainable development. The decision to concentrate development on just five major strategic sites across the County is by its very definition unsustainable. The PS fails to adequately explain why only these sites were considered suitable for inclusion.
A more diversified strategy should have been considered that included smaller sites that could be more readily assimilated into existing development and communities. Excluding some larger settlements along the coast will frustrate their ongoing development and renewal potentially impacting on the viability of local community services and public infrastructure including schools. There is also an inherent risk that putting so many "eggs" in so few "baskets " the Council may become a hostage to fortune in how these sites are developed. This approach very much plays into the hands of larger volume housebuilders who maximise profit against other considerations of design, affordable housing and community facilities
The proposed allocation within Old Colwyn is potentially the worst example of what will be a completely unsustainable development that is incapable of being properly absorbed within the fabric of the existing settlement. The inclusion of such a large single allocation will undermine the on-going regeneration of Colwyn Bay itself. Although much progress has been made in bringing forward smaller brownfield sites within the town the inclusion of such a large site would make it more difficult to sustain progress deflecting investment away from the centre.
The need for major improvements to the public infrastructure associated with these sites and the Old Colwyn one in particular does not seem to have been fully explored within the PS. For example the scale of development envisaged in Old Colwyn will impact on the wider highway network as well as the already substandard local road system serving the site. Prior to this site being proposed a full transport and highway study should have been undertaken to fully understand the extent and potential cost of the improvements required to the area's transport network

The policies on affordable and social housing are not considered ambitious enough. Further urgent consideration must be given to finding ways of providing more social housing using existing providers with more funding coming directly from the public sector and well as "windfall " receipts from the planning system itself.
* Social housing accounts for 12% of the total housing stock in Conwy the second lowest in Wales 23% of which is sheltered.
* There were 401 social housing lets in the last year with an average waiting time of 542days.
* 18% of households rent privately the highest in Wales, Welsh average is 14%.
* There were 89 affordable homes built last year
* 233 new house completions
* 1685 homes in Conwy have been empty more than 6 months
* There are 1441 second homes in the county
* 33% increase in homelessness over the past 12 months
* £200k overspend on the use of temporary accommodation by CCBC
* 268 single people 16-24 are homeless. The main reason being family unwilling to accommodate the person further
Housing Need
Conwy CBC is facing an acute housing crisis fuelled in the main by lack of suitable affordable housing and the condition and structure of the existing housing stock:
* 891 households on the waiting list for social housing
* 1 in 10 have been waiting 3 years or more
* 50% of social housing applications require 4 or more bedrooms
* Conwy need to provide 372 new affordable homes each year
* Further 340 applications on the first steps register seeking help to buy.
* No provision of accommodation for rough sleepers
* 1200 houses in multiple occupation
* 308 housing enforcements reports last year
* Fuel poverty: 13% of homes have a EPC rating of E or G; 33% of homes have solid walls and are hard to heat, 25-35% of dwellings are off mains gas
* 9500 homes at significant risk of flooding 8900 at moderate risk.
The shortage of affordable homes to rent or buy is at crisis point right across the County in both rural and urban communities. The scale of the problem is however most acute in the larger urban areas, especially Llandudno, where competition from the tourism sector is increasingly affecting the supply of permanent residential accommodation. The rise in the phenomena of new tourism developments such as Airbnb is making an already difficult situation for local families increasingly impossible.

The policies on affordable housing fall well short of addressing the failings in the current Local Plan which have consistently missed the targets set for the last five years. More ambitious targets for the percentage of affordable homes need to be set and rigorously enforced, using existing planning powers.
If the County Council fail to fully recognise the challenge which delivering affordable housing presents then it is severe danger of repeating the mistakes of the last plan which over a five year period only delivered 277 affordable housing units in total against an annual plan target of 123 units. Developers have frequently been successful in side-stepping the system with the result that on average private developer schemes have only achieved a level of 7% affordable homes. There are numerous examples of where the policy has been flouted. A developer in Rhos claimed that his target market of upper middle class retired with £250k to spend on an apartment required a higher quality of finish which would reduce his profit and therefore instead of 3 affordable units only 1 was provided. Another developer building 9, £300k homes, had to make a financial contribution of just £20k insufficient to finance a single affordable home.
The LDP Review also recognises the issues raised by "viability" assessments:
"To address this, the policy will need to be reviewed through further viability testing, whilst the call for sites will include more rigorous assessment of viability at an early stage to reduce the possibility of planning obligations being reduced due to high land values or abnormal costs".
There is no evidence from the published strategy and its associated documents that a more rigorous assessment has actually taken place. The plan therefore runs the risk of repeating the mistakes of the previous LDP leaving the system wide open to abuse by developers flaunting their obligations to provide adequate affordable housing.

Only this April the National Assembly produced a research note in its Planning Series on Section 106 agreements. Advice in paragraph of the note recommends:
"LDPs and/or Supplementary Planning Guidance should set out the circumstances where LPAs will use planning conditions or S106 agreements to ensure that the affordable housing provided is occupied in perpetuity by people falling within particular categories of need. Onsite provision of affordable housing is preferred, but in exceptional circumstances the provision can be offsite. In some cases a financial contribution in lieu of on-site provision (a commuted sum) is preferred".
The use of section 106 powers are particularity important in the successful delivery of affordable housing policies in any plan as recognised in Circular 13/97. It is therefore extremely disappointed to note a very defeatist stance taken within the plan in paragraph 4.3.24. This paragraph implies that proper control over the delivery of affordable housing via the planning system is "outside the sphere of influence" of the Council and that its powers as LPA are "limited ".
If the County Council fail to fully recognise the challenge which delivering affordable housing presents then it is severe danger of repeating the mistakes of the last plan which over a five year period only delivered 277 affordable housing units in total against an annual plan target of 123 units. Developers have frequently been successful in side-stepping the system with the result that on average private developer schemes have only achieved a level of 7% affordable homes. There are numerous examples of where the policy has been flouted. A developer in Rhos claimed that his target market of upper middle class retired with 250k to spend on an apartment required a higher quality of finish which would reduce his profit and therefore instead of 3 affordable units only 1 was provided. Another developer building 9, 300k homes, had to make a financial contribution of just 20k insufficient to finance a single affordable home.
Assuming the County Council are serious about making a real difference to the levels of affordable housing it should apply a minimum percentage of 30% right across the County. With most experts predicting a progressively tighter housing market with increasing rents making it even more difficult for local people to secure suitable homes it is regrettable that the County Council has not taken the opportunity to increase targets for the provision of affordable homes. In fact the target of 120 per annum is less than that set within the original plan and well below that required to make meaningful impact on this growing crisis. A crisis manifested by a waiting list for social housing of 891 households and where 270 under 24 year olds classified as homeless. The PS highlights the risk of further outward migration of the county's young people. With such limited housing choices more and more may join what is fast becoming a "housing led" migration epidemic.

Given the recent Commission on Climate Change objectives for net zero emissions by 2050 the RLDP should require all new development to be Carbon Zero. This can be achieved by adopting existing technology in a away that does not impose unreasonable additional costs and will infact over the lifetime of any development deliver a positive economic return

Following the decision by Welsh Government made on 11 June 2019 to accept the Climate Change Commission's recommendations to achieve a 95% reduction in greenhouse gases by 2050 the targets outlined in the draft plan need to be revisited.
Given the disproportionate impact climate change will have on the coastal communities of the County the RLDP should go further and aspire to achieving a net zero emission target by 2050.

Although the draft plan makes passing reference to the importance of trees and hedgerows to encouraging biodiversity no reference to the need to control the increasingly widespread problems associated with the netting of trees and hedgerows is included. This practice is predominately used by developers and others to prevent birds nesting in both trees and hedgerows often prior to any planning permission being sought or granted. The RSPCA are calling on all council's to introduce policy guidelines that ensure development is not carried out during nesting periods and that the use of netting is banned or strictly controlled.

The development of a tidal lagoon will bring not only environmental benefits but has the potential to deliver employment and wider regeneration benefits to the coastal communities of Colwyn Bay, Pensarn Kinmel Bay and Towyn. It also offers the potential for involvement of the local community in its planning and longer term management.