Paper 2: Strategic Growth and Spatial Distribution Options

Ended on the 25 January 2019
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The Spatial Distribution Options for Growth

6.1 Alongside deciding on the actual level of growth needed over the Plan period, the RLDP must also put forward a clear Spatial Strategy identifying where this growth should be located within the County Borough. It is therefore necessary to translate the projected level of growth into broad geographical locations. The Council has identified six broad Spatial Distribution Options for new development in the County Borough. Each option is underpinned by the aim of maximising appropriate and deliverable brownfield land. However providing for all of Conwy's development requirements over the Plan period will also require new land for development outside of existing settlement limits to be released. Conwy is also constrained when considering the flood risk areas, topography and natural and historic assets. BP02 - Spatial Distribution Options informs this section of this Paper.

It is important to note that the Spatial Distribution Options for Growth put forward are not intended to define precise boundaries, sites or land use allocations at this stage. Such detail will form part of the Preferred Strategy stage later in the process as per the timetable in the Conwy Delivery Agreement.

It is critical that new development areas must be served or are capable of being served, by appropriate infrastructure. This includes for example appropriate transport routes and services, education provision, community facilities, utilities and drainage infrastructure. The likelihood of delivering new infrastructure in association with development will depend on a number of factors, not least of which will be likely opportunities for funding the delivery of development. The consideration of funding opportunities for new infrastructure and the economic and market conditions of the area must be integral to the assessment process and will influence the Preferred Strategy. Therefore, it is important that there is an emphasis on identifying realistic options that reflect the evidence. Not all the evidence is available at present, but as it is prepared it will inform the final Preferred Strategy in summer of 2019.

As identified in Welsh Government guidance, the key objective is to identify a set of realistic spatial options. In this context it would be inappropriate and potentially confusing to Plan users to consult on too great a variety of spatial options. Instead an initial assessment of a 'longlist' of potential options was undertaken (refer to Appendix 3), which has resulted in a 'shortlist' of 5 options put forward below for further assessment.

Although comments are primarily sought on the small list of spatial options this does not preclude comments being made on any of the other spatial options in the 'longlist' or indeed, any other spatial options being suggested.

Table 3: Spatial Distribution Options - Shortlisted Options

Spatial Distribution Options

Shortlisted

Option 1: Repeating the adopted LDP (Sustainable Distribution)

YES (Option 1)

Option 2: Distributing Growth to all the urban centres along the A55 Corridor

YES (Option 2)

Option 3: Focused urban growth in line with the Wales Spatial Plan.

YES (Option 3)

Option 4: Focused urban growth in line with the Wales Spatial Plan and within Satellite Settlements

YES (Option 4)

Option 5: Regeneration Led

NO (Although not considered appropriate to be carried forward as a formal option, there are elements of this approach that would need to be built into the preferred option to ensure that some growth takes place in settlements in need of regeneration)

Option 6: Hubs and Corridors

YES (Option 5)

Option 7: Dispersal

NO

Option 8: No strategy

NO

Option 9: New Settlement/Major Extension to Existing Settlement

YES (Option 6)

The more realistic options are further assessed in more detail as well as identifying which settlements fall within a particular option. A summary of the key pros and cons of each option is also provided, along with a spatial illustration of the option in map form. Key considerations covered in the pros and cons include the following criteria, which is also provided in greater detail in BP02 - Spatial Distribution Options':

  • Consideration of the Welsh Governments Five Key Planning Principles.
  • National Sustainable Placemaking Outcomes reflecting a Sustainable Place (See Appendix 2) - will it result in sustainable places in Conwy
  • Consideration of the Well-being of Future Generations Act five 'Ways of Working'
  • Legislation & Wider Strategies - consideration of the contribution to legislation and wider strategies, such as Well-being of Future Generations Act, the North Wales Growth Deal, Conwy Economic Strategy, etc.
  • Evidence Base - such as the Employment Land Review, Property Market Assessment, Local Housing Market Assessment
  • Promoting Healthy Lifestyles, including Active Travel - will the option develop and maintain places that foster healthy, active lifestyles across all age and socio-economic groups
  • Welsh Language & Placemaking - will the option seek to ensure a broad distribution and phasing of development that takes into account the ability of the area or community to accommodate development without adversely impacting use of the Welsh language
  • Infrastructure Capacity - ensuring infrastructure capacity either exists or can be provided
  • Constraints - having regard to key physical or environmental constraints
  • Commitments - having regard to the location of and likely delivery of existing commitments (those with planning permission)
  • Candidate Sites - Acknowledging the availability and distribution of Candidate Sites (this will be further assessed in progressing the Preferred Strategy.
  • Accessibility - ensuring convenient accessibility to key services, facilities and employment as well as transport nodes and corridors
  • Services and Facilities - ensuring that services and facilities are available or can be made available through the RLDP
  • Local housing market conditions - ensuring that the strategy has regard to key characteristics of local housing market areas in the Local Housing Market Assessment
  • PPW Conformity - ensuring conformity with the principles in PPW Edition 9 and having regard to draft PPW Edition 10.
  • Flexibility - ensuring an option is sufficiently flexible to withstand unforeseen circumstances or changes in market demand
  • RLDP Vision & Objectives - will the option deliver the proposed vision and objectives of the RLDP (further work around this will be undertaken at later stages to inform the Preferred Strategy)
  • Brownfield Land & De-risking - will the option promote brownfield land and take a de-risking approach to unlocking the development potential of sites.

Option 1: Repeating the adopted LDP

Description: Continuing the adopted LDP which allows for a proportional distribution of development based on sustainability principles across three tiers of the currently adopted hierarchy of settlements (Urban Areas and Tier 1 & 2 Settlements. In the rural settlements outside of the Urban and Tier 1 & 2 Settlements, a more refined policy approach would be continued to ensure protection of the local character and delivery of local development housing.

Spatial Distribution / Settlements Affected

Urban Settlements: Abergele/Pensarn, Colwyn Bay (inclusive of Rhos-on-Sea and Old Colwyn), Conwy, Deganwy/Llanrhos, Llandudno, Llandudno Junction, Llanfairfechan, Llanrwst, Mochdre, Penmaenmawr, Penrhyn Bay/ Penrhynside and Towyn/Kinmel Bay

Rural Settlements: Llanddulas, Dwygyfylchi*, Llysfaen, Glan Conwy, Betws-yn-Rhos, Cerrigydrudion, Dolgarrog*, Eglwysbach, Llanfair Talhaiarn, Llangernyw, Llansannan, Tal-y-Bont*/Castell and Trefriw*

Related Settlement Hierarchy Option(s): The Growth distribution option should to be considered against Settlement Hierarchy Options 1 & 2. If this growth distribution option is chosen it is likely to reflect one of these settlement hierarchy options.

Key legislation - Consideration of the Welsh Governments PPW, Five Key Planning Principles and National Sustainable Placemaking Outcomes reflecting a Sustainable Place

The current LDP and supporting hierarchy of settlements is based on sustainability principles, including population and needs for affordable housing. The strategy tends to comply with the key legislation. However, development to the east of the County Borough and within the settlements has been constrained over the LDP period to date, mainly due to newly arising constraints, changing community's needs and market conditions. The Key Planning Principle 'right development in right place' is therefore questioned, which would require a reassessment of some urban and rural locations in terms of delivering growth and creating sustainable places in the future.

Wider Strategies - consideration of the North Wales Growth Deal, Conwy Economic Strategy, etc.

BP18 - Conwy Employment Land Review (2018 - 2033) takes into account the potential impact from the Regional Economic Drivers in concluding land requirements. The property market assessment also considers key locations along the A55 Corridor as the preferred location for new employment growth. As above though, the location of some employment land allocations distributed across the hierarchy are constrained in some rural areas and to the east of the County. Coupled with the fact that national guidance seeks to locate housing and employment in close proximity to assist sustainability, the current LDP strategy may not be best placed to deliver wider strategies such as the Growth Deal and Conwy Economic Strategy.

Evidence Base - such as the Employment Land Review, Property Market Assessment, Local Housing Market Assessment

As the current LDP is based on sustainability and community's needs it is placed to deliver specific land requirements for each settlement based on the evidence. However, land is constrained in rural areas and to the east, and as such a more flexibility policy approach may be more deliverable in these locations with the alternative being to focus development allocations in the more market driven locations with capacity and infrastructure to deliver growth. This would be subject to understanding the constraints evidence base further, such as BP35 - Flood Risk and Development Opportunities in the East of the County Borough.

Promoting Healthy Lifestyles, including Active Travel - will the option develop and maintain places that foster healthy, active lifestyles across all age and socio-economic groups

The majority of the LDP growth (85%) is distributed within the urban areas with 15% distributed throughout the rural settlements. Growth proposed within the urban areas will encourage healthy and active lifestyles with good access to alternative modes of transport, open spaces, etc. However, there is a need through the RLDP to assess development locations based on the new Active Travel Plans to ensure that better linkages and routes are encouraged and delivered. Some of the rural locations do lack in employment and leisure opportunities, which in turn could encourage unsustainable car usage in accessing the more sustainable locations.

Welsh Language & Placemaking - will the option seek to ensure a broad distribution and phasing of development that takes into account the ability of the area or community to accommodate development without adversely impacting use of the Welsh language

The current growth distribution may impact on Abergele and some rural communities to accommodate growth without adversely impacting on the Welsh Language. Further work will be undertaken to assess the impact on the Welsh language and potential mitigation.

Infrastructure Capacity - ensuring infrastructure capacity either exists or can be provided

By distributing development based on an informed approach to the sustainability of each settlement and the settlement hierarchy then the option should have regard to the availability and capacity of infrastructure. However, the proportional distribution gives the impression that all or most settlements will need to grow or have an allocation, and this could result in spreading growth too thinly and having a less focussed approach on sustainability. The current growth distribution is unlikely to be viable or achievable in some urban and rural locations due to infrastructure constraints and no means to overcome. Whilst greater work is underway to assess this, development to the East of the County Borough for example promotes 20% growth over the LDP period. Currently, due to traffic capacity and flood risk issues this may not developable over the new RLDP period without significant financial contributions, which in turn will impact further on the viability of schemes.

Constraints - having regard to key physical or environmental constraints

By spreading growth based on a proportional distribution, the impression is given that each settlement will experience growth or an allocation. This could result in a less focussed approach where constraints may not be fully taken into account, or in some consequences compromised. It may be a more sustainable approach to focus growth and ensure constraints and infrastructure can be overcome. Conwy is significantly constrained in most areas. Along the A55 coastal belt there are topography issues to the south and flood risk constraints to the north, leaving a belt of development opportunities along the A55. The East of the County Borough is currently at risk of flooding, which would need further investigation to determine the potential for growth distribution in the RLDP.

Commitments - having regard to the location of and likely delivery of existing commitments (those with planning permission)

The option should enable the existing commitments to be taken into account in terms of a robust assessment of their likely future delivery. Commitments will be considered over the RLDP preparation period in terms of supply and market conditions. There are potential areas at risk under the current LDP growth strategy, including Abergele and Llandudno Junction, which have delivered large developments and as such may lack further opportunity to accommodate growth without major infrastructure coming forward. This will be considered further through the candidate sites assessment.

Candidate Sites - Acknowledging the availability and distribution of Candidate Sites (this will be further assessed in progressing the Preferred Strategy.

The option should have sufficient flexibility to be able to have regard to the locations of candidate sites and whether they have passed the 'technical' assessment. However, the most sustainable settlements and sites may be overlooked in the quest to spread growth across each tier in the settlement hierarchy. At this stage in the RLDP preparation candidate sites are still being progressed and appraised and will inform the final growth option and Preferred Strategy.

Accessibility - ensuring convenient accessibility to key services, facilities and employment as well as transport nodes and corridors

This option is based on the chosen settlement categorization and has regard to the settlement audits and is therefore based on sustainability principles, which will include accessibility. If the amount of growth is generally being based on the settlement hierarchy, then it is generally those higher order settlements which have the greatest provision of services and facilities and also public transport. The majority of the LDP growth (85%) is distributed within the urban areas, where accessibility to key facilities and services is considered high. However, access to education and health will need further investigation under this option to determine the appropriate growth distribution going forward.

Local housing market conditions - ensuring that the strategy has regard to key characteristics of local housing market areas in the Local Housing Market Assessment

By distributing growth proportionally across the settlement hierarchy this option may not be able to have full regard to the strength of the local housing market in terms of implications for the type of allocation and planning obligations which could be viably delivered.

Flexibility - ensuring an option is sufficiently flexible to withstand unforeseen circumstances or changes in market demand

The option has sufficient flexibility to allow for unforeseen circumstances such as an Inspector identifying the need for further allocations at examination. The Council will consider de-allocation policies, de-risking and ranking of alternative development sites to assist delivery.

Conformity with the emerging RLDP - will the option deliver the proposed vision and objectives of the RLDP (further work around this will be undertaken at later stages to inform the Preferred Strategy)

Some of the key evidence emerging may suggest that a more holistic and focused approach to employment and housing growth is promoted where there is sufficient capacity, infrastructure and favouring market conditions. However, rather than focusing on the most sustainable settlements and sites to deliver the growth ambitions this current LDP option seeks to spread growth thinly by a planning by numbers approach, which could impact on overcoming constraints and providing the necessary infrastructure.

Brownfield Land & De-risking - will the option promote brownfield land and take a de-risking approach to unlocking the development potential of sites.

The option has the necessary mechanism in place to promote brownfield land. However, de-risking may be minimised is some areas due to high infrastructure costs and constraints.

Option 1: Summary
This option has been in place since the adoption of the current LDP in 2013 and is based on a 5 tier settlement hierarchy informed by a sustainability assessment. However, this spatial option requires some sort of numerical means by which to apportion growth to the different tiers in the settlement hierarchy. This suggests that growth will be spread thinly, where sites are chosen based on some form of numerical control rather than by focussing on which are the more sustainable settlements and sites to deliver growth. The option may also impact negatively on delivering the required infrastructure and assisting de-risking of the Plan due to economies of scale.

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Option 2: Distributing Growth to all the urban centres along the A55 Corridor

Description: Directing all development to all urban centres along the A55 Corridor with the capacity and infrastructure to accommodate development. Under this option there would no rural allocations for development. Alternatively, the rural settlements a more refined policy approach would be developed to ensure that a more flexible approach is taken to bringing about and delivering local needs housing whilst protecting local character and the open countryside.

Spatial Distribution / Settlements Affected

Abergele/Pensarn, Colwyn Bay (inclusive of Rhos-on-Sea and Old Colwyn), Conwy, Deganwy/Llanrhos, Llandudno, Llandudno Junction, Llanfairfechan, Mochdre, Penmaenmawr and Towyn/Kinmel Bay.

Related Settlement Hierarchy Options: Growth option is more suited to Settlement Hierarchy options 1, 2 & 3. Although, it can be considered against all the urban areas identified in the Settlement Hierarchy Options 1, 2, 3, 4 & 5. If this Growth distribution option is chosen it will reflect one of these settlement hierarchy options.

Key legislation - Consideration of the Welsh Governments PPW, Five Key Planning Principles and National Sustainable Placemaking Outcomes reflecting a Sustainable Place

The option tends to comply with the key legislation as long as the flexible rural policy is appropriate to create sustainable places. As with Option 1 above, development to the east of the County Borough is constrained, mainly due to existing constraints, newly arising constraints, changing community's needs and market conditions. The Key Planning Principle 'right development in right place' is therefore questioned, which would require a reassessment of some urban locations in terms of delivering growth and creating sustainable places in the future.

Wider Strategies - consideration of the North Wales Growth Deal, Conwy Economic Strategy, etc.

BP18 - Conwy Employment Land Review (2018 - 2033) takes into account the potential impact from the Regional Economic Drivers in concluding land requirements. The property market assessment also considers key locations along the A55 Corridor as the preferred location for new employment growth. The option would therefore meet with wider strategies, subject to settlement capacity and overall deliverability. As above though, the location of some employment land allocations distributed across the hierarchy are constrained. Coupled with the fact that national guidance seeks to locate housing and employment in close proximity to assist sustainability, this approach may not be best placed to deliver wider strategies such as the Growth Deal and Conwy Economic Strategy in areas such as the East of the County Borough.

Evidence Base - such as the Employment Land Review, Property Market Assessment, Local Housing Market Assessment

This option focuses growth on the urban areas only within the settlement hierarchy, which tend to be the most sustainable locations to accommodate growth and meet such evidence as the Employment Land Review. However, there are sustainable settlements lower down in the settlement hierarchy which are sustainable locations yet would be denied growth in this option. Additionally, constraints in some urban locations may be constrained, which in turn would put greater pressure on the remaining urban areas to deliver growth.

Promoting Healthy Lifestyles, including Active Travel - will the option develop and maintain places that foster healthy, active lifestyles across all age and socio-economic groups

Growth focused within the urban areas will encourage healthy and active lifestyles with good access to alternative modes of transport, open spaces, etc. However, there is a need through the RLDP to assess development locations based on the new Active Travel Plans to ensure that better linkages and routes are encouraged and delivered. Some of the rural locations do lack in employment and leisure opportunities, which in turn could encourage unsustainable car usage in accessing the more sustainable locations.

However, in focussing only on higher order settlements it fails to have regard to the fact that there will be some settlements in the lower tiers of the settlement hierarchy which are accessible and will have capacity to accommodate some growth. As above this could be managed by a refined rural policy approach to ensure that a more flexible approach is taken to bringing about and delivering growth to encourage healthy and active lifestyles.

Welsh Language & Placemaking - will the option seek to ensure a broad distribution and phasing of development that takes into account the ability of the area or community to accommodate development without adversely impacting use of the Welsh language

The current growth distribution may impact on Abergele to accommodate growth without adversely impacting on the Welsh Language. This option may also have an impact on other urban areas due to concentrating development in the remaining settlements with available capacity. Further work will be undertaken to assess the impact on the Welsh language and potential mitigation.

Infrastructure Capacity - ensuring infrastructure capacity either exists or can be provided

By focusing growth within urban areas only, this option provides less opportunity and flexibility to have regard to the availability and capacity of infrastructure. Some settlements would be under pressure to deliver development, but may have significant infrastructure capacity issues and constraints e.g. East of the County Borough due to traffic capacity and flood risk issues may not be developable over the new RLDP period without significant financial contributions, which in turn will impact further on the viability of schemes.

Constraints - having regard to key physical or environmental constraints

By focussing growth on the A55 corridor urban areas there may be difficulties in having regard to key physical or environmental constraints. Flexibility may be compromised as a result of certain constraints in some settlements which cannot be overcome and may place undue pressure on other settlements. Relatively unconstrained and sustainable settlements outside the higher order tiers of the hierarchy would be prevented from contributing some growth. It may be a more sustainable approach to focus growth and ensure constraints and infrastructure can be overcome. Conwy is significantly constrained in most areas. Along the A55 coastal belt there are topography issues to the south and flood risk constraints to the north, leaving a belt of development opportunities along the A55. The East of the County Borough is currently at risk of flooding, which would need further investigation to determine the potential for growth distribution in the RLDP.

Commitments - having regard to the location of and likely delivery of existing commitments (those with planning permission)

Although a significant proportion of recent completions and commitments are in the urban areas along the A55 Corridor, some fall outside the higher settlement tiers. This option, by focussing on a number of settlements, ignores the potential role that the sustainable Tier 1&2 settlements can play in contributing to sustainable development.

Candidate Sites - Acknowledging the availability and distribution of Candidate Sites (this will be further assessed in progressing the Preferred Strategy.

The option should have sufficient flexibility to be able to have regard to the locations of candidate sites and whether they have passed the development appraisal at the frontloading stage. However, the most sustainable settlements and sites may be overlooked in the quest to spread growth across the urban areas only, which in turn may also have a negative effect on the sustainability of some Tier 1&2 settlements. At this stage in the RLDP preparation candidate sites are still being progressed and appraised and will inform the final growth option and Preferred Strategy.

Accessibility - ensuring convenient accessibility to key services, facilities and employment as well as transport nodes and corridors

This option is based on the chosen settlement categorization and has regard to the settlement audits and is therefore based on sustainability principles, which includes accessibility. If the amount of growth is generally being based within urban areas, then it is generally those higher order settlements which have the greatest provision of services and facilities and also public transport. However, access to education and health will need further investigation to understand current capacity issues and the impact on growth and overall viability issues. A lack of development in some urban areas is likely to place pressure on the deliverable urban areas and as such the facilities and services that are required.

Local housing market conditions - ensuring that the strategy has regard to key characteristics of local housing market areas in the Local Housing Market Assessment

By distributing growth proportionally across the urban settlements this option may not be able to have full regard to the strength of the local housing market in terms of implications for the type of allocation and planning obligations which could be viably delivered. The Affordable Housing Viability Study (BP10) will further inform the growth distribution in the Preferred Strategy

Flexibility - ensuring an option is sufficiently flexible to withstand unforeseen circumstances or changes in market demand

By only looking at the urban settlements along the A55 Corridor this option may not have the flexibility to withstanding changes e.g. an Inspector seeking additional growth/sites. The Council will consider de-allocation policies, de-risking and ranking of alternative development sites to assist delivery if this option is progressed, but sites may be short in supply without consideration of the Tier 1 settlements for example.

Conformity with the emerging RLDP - will the option deliver the proposed vision and objectives of the RLDP (further work around this will be undertaken at later stages to inform the Preferred Strategy)

Focusing growth within the urban settlements sits well in terms of meeting evidence and legislation, as these settlements will have employment provision and will generally be close to main employment centres. However, the option places considerable weight on the urban need and not the need to have regard to the needs of the rural areas and the rural economy. However, as above this could be addressed via more flexible rural policy. Some of the key evidence emerging may suggest that a more holistic and focused approach to employment and housing growth is promoted where there is sufficient capacity, infrastructure and favouring market conditions. .

Brownfield Land & De-risking - will the option promote brownfield land and take a de-risking approach to unlocking the development potential of sites.

The option has the necessary mechanism in place to promote brownfield land. However, de-risking may be minimised is some areas due to high infrastructure costs and constraints.

Option 2: Summary
This option will ensure that development is focused in the most sustainable locations by focusing growth in the urban areas only within the settlement hierarchy. This option may prove diffciult to deliver when considertaion of the major constraints to the East of the County Borough are considered (e.g. flooding, highways). This option will ensure that development is focused in the most sustainable locations by focusing growth in the urban areas only within the settlement hierarchy, but there are other sustainable urban and rural settlements which would be denied growth under this option.
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Option 3: Focused urban growth in line with the Wales Spatial Plan.

Description: Development would be focused by directing all development based on a rigid definition of the growth areas embodied in the Wales Spatial Plan Primary Key Settlements and Key Settlements, with the capacity and infrastructure to accommodate development. In the remaining urban and rural settlements a more refined policy approach would be developed to assist regeneration in urban areas and ensure that a more flexible approach is taken to bringing about and delivering local needs housing in rural areas.

Spatial Distribution / Settlements Affected

This option is based on delineating a boundary in map form which is based on the growth areas in the Wales Spatial Plan. It would encompass the following settlements:

Colwyn Bay (including Rhos-on-Sea and Old Colwyn), Conwy, Llandudno (including Deganwy and Llanrhos), Llandudno Junction, Llanfairfechan & Penmaenmawr and Llanrwst

Related Settlement Hierarchy Options: More suited to Settlement Hierarchy Options 4 & 5. If this growth distribution option is chosen it will likely reflect one of these options. The majority of the Conwy Plan Area is within the North East Wales Strategy Area of the Wales Spatial Plan (2008). In addition, several settlements are either fully within the North West area such as Llanfairfechan and Penmaenmawr, or fall in the area shared between both regions (Llandudno, Conwy, Llandudno Junction, Colwyn Bay and Llanrwst). This means that these cross-boundary settlements are strategically placed for connecting the two areas of Wales and beyond; via links to England and Ireland. Llanrwst has the added distinction of linking to a third Strategy Area: Central Wales.

Key legislation - Consideration of the Welsh Governments PPW, Five Key Planning Principles and National Sustainable Placemaking Outcomes reflecting a Sustainable Place

At face value a strategy option which seeks to focus growth to within a defined growth area would appear to be sustainable, especially when having regard to accessibility to key facilities, services and transport networks. However, it may impact on the County outside of the growth area from having the opportunity to deliver sustainable development to meet the needs of those settlements, without a refined policy approach for the remaining urban and rural settlements.

Wider Strategies - consideration of the North Wales Growth Deal, Conwy Economic Strategy, etc.

BP18 - Conwy Employment Land Review (2018 - 2033) takes into account the potential impact from the Regional Economic Drivers in concluding land requirements. The commercial market analysis also considers key locations along the A55 Corridor as the preferred location for new employment growth. The option would therefore meet with wider strategies, and would concentrate development away from constrained areas in the East. This option would also maximise the potential of the growth 'hub' along the coast, in accordance with the Wales Spatial Plan.

Evidence Base - such as the Employment Land Review, Property Market Assessment, Local Housing Market Assessment

This option focuses growth on the WSP urban areas, which tend to be the most sustainable locations to accommodate growth and meet such evidence. However, there are sustainable settlements lower down in the settlement hierarchy which are sustainable locations yet would be denied growth in this option. Additionally, constraints in some urban locations may be constrained, which in turn would put greater pressure on the remaining urban areas to deliver growth.

Promoting Healthy Lifestyles, including Active Travel - will the option develop and maintain places that foster healthy, active lifestyles across all age and socio-economic groups

Growth focused within the WSP areas will encourage healthy and active lifestyles with good access to alternative modes of transport, open spaces, etc. In focussing only on higher order settlements in the WSP it fails to have regard to the fact that there will be some settlements in the lower tiers of the settlement hierarchy which are accessible and will have capacity to accommodate some growth and potential to improve overall health and activity.

Welsh Language & Placemaking - will the option seek to ensure a broad distribution and phasing of development that takes into account the ability of the area or community to accommodate development without adversely impacting use of the Welsh language

The growth distribution option may impact on the Key Settlements such as Penmaenmawr and Llanfairfechan in terms of them being able to accommodate growth without adversely impacting on the Welsh Language. Further work will be undertaken to assess the impact on the Welsh language and potential mitigation.

Infrastructure Capacity - ensuring infrastructure capacity either exists or can be provided

By focusing growth on only part of the County, this geographically focused approach may put undue pressure on infrastructure especially in those smaller key settlements. Adversely, concentrating growth will possibly assist infrastructure costs and overall deliverability.

Constraints - having regard to key physical or environmental constraints

By focusing growth on only part of the County, this option may put undue pressure on a wide range of physical and environmental constraints in and around certain settlements. Relatively unconstrained and sustainable settlements outside the higher order tiers of the WSP would be prevented from contributing some growth. It may be a more sustainable approach to focus growth wider than WSP and ensure constraints and infrastructure can be overcome.

Commitments - having regard to the location of and likely delivery of existing commitments (those with planning permission)

A good proportion of commitments fall within the higher order settlements, most of which fall within the WSP area, although some of these remain undeveloped. Also, some of the existing commitments fall outside the defined growth zone approach, such as Abergele. By focussing only on the growth area the role of other sustainable settlements outside it are overlooked. This option ignores the potential role that the sustainable rural settlements can play in contributing to sustainable development.

Candidate Sites - Acknowledging the availability and distribution of Candidate Sites (this will be further assessed in progressing the Preferred Strategy.

A number of strategic candidate sites will fall within the defined growth zone. Candidate sites in other urban sustainable settlements would be prevented from being considered under this option, although such sites fall within the more constrained areas to the East of the County Borough.

The option does not have sufficient flexibility to be able to have regard to the locations of candidate sites and whether they have passed the development appraisal at the frontloading stage. However, the most sustainable settlements and sites may be overlooked in the quest to spread growth across the urban areas only, which in turn may also have a negative on the sustainability of some rural settlements. At this stage in the RLDP preparation candidate sites are still being progressed and appraised and will inform the final growth option and Preferred Strategy.

Accessibility - ensuring convenient accessibility to key services, facilities and employment as well as transport nodes and corridors

This option is based on the WSP, which is highly accessible with the existence of strategic highways and rail, in addition to alternative sustainable modes.

Local housing market conditions - ensuring that the strategy has regard to key characteristics of local housing market areas in the Local Housing Market Assessment

The defined growth area will contain a variety of local housing market areas ranging from very strong such as Llandudno to slightly weaker areas. However, WSP growth zone does exclude the very weak market areas to the East of the County Borough. The Affordable Housing Viability Study (BP10) will further inform the growth distribution in the Preferred Strategy

Flexibility - ensuring an option is sufficiently flexible to withstand unforeseen circumstances or changes in market demand

By focussing all growth within a defined geographical area, there may be less flexibility to accommodate change (such as an Inspector identifying the need for additional allocations) as many otherwise sustainable settlements would fall outside the growth area. The National Development Framework is currently in production which will also be factored in terms of flexibility.

Conformity with the emerging RLDP - will the option deliver the proposed vision and objectives of the RLDP (further work around this will be undertaken at later stages to inform the Preferred Strategy)

The concept of focusing on a growth area at face value appears to be well related to national policy in terms of a joined up approach to employment and housing growth. By focussing all growth on such a narrow geographical area, the approach deprives the opportunity for other sustainable settlements from seeking to grow and provide for their own needs. However, adversely the remaining urban areas outside of the WSP are highly constrained. Further work is underway to the East of the County to understand flood risk and determine development opportunities. This work will further inform the preferred strategy at a later date in the RLDP stage.

Brownfield Land & De-risking - will the option promote brownfield land and take a de-risking approach to unlocking the development potential of sites.

The option has the necessary mechanism in place to promote brownfield land and potential to assist de-risking.

Option 3: Summary
This option appears to tie in strongly with the employment growth aspirations set out in the Employment Land Review (ELR) and the Property Market Assessment, by focussing development within a defined growth area along the key transport route. Whilst it reflects the Wales Spatial Plan growth areas, it does not recognise the existence of additional sustainable locations to accommodate potential growth and could place untold pressure on infrastructure if tightly focused.
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Option 4: Focused urban growth in line with the Wales Spatial Plan and Satellite Settlements

Description: Directing development in line with the Wales Spatial Plan Primary Key Settlements and Satellite Settlements, with the capacity and infrastructure to accommodate development. In the rural area outside of satellite settlements a more refined policy approach would be developed to ensure that a more flexible approach is taken to bringing about and delivering local needs housing whilst protecting local character and the open countryside.

Spatial Distribution / Settlements Affected

This option is based on delineating a boundary in map form which is based on the growth areas in the Wales Spatial Plan and settlement hierarchy options set out in Options 4 & 5.

Colwyn Bay (including Rhos-on-Sea and Old Colwyn), Conwy, Llandudno (including Deganwy and Llanrhos), Llandudno Junction, Llanfairfechan & Penmaenmawr, Dwygyfylchi, Glan Conwy and Llanddulas

Related Settlement Hierarchy Options: More suited to Settlement Hierarchy Options 4 & 5. If this growth distribution option is chosen it will likely reflect one of these settlement hierarchy options. For example, the urban areas and satellite settlements may change dependent on the chosen growth. The majority of the Conwy Plan Area is within the North East Wales Strategy Area of the Wales Spatial Plan (2008). In addition, several settlements are either fully within the North West area such as Llanfairfechan and Penmaenmawr, or fall in the area shared between both regions (Llandudno, Conwy, Llandudno Junction, Colwyn Bay and Llanrwst). This means that these cross-boundary settlements are strategically placed for connecting the two areas of Wales and beyond; via links to England and Ireland. Llanrwst has the added distinction of linking to a third Strategy Area: Central Wales.

Key legislation - Consideration of the Welsh Governments PPW, Five Key Planning Principles and National Sustainable Placemaking Outcomes reflecting a Sustainable Place

This is similar to Option 3, but also distributes an element of growth to the Satellite Settlements. This option does not distribute as far as Option 1 (current LDP) into the Tier 2 Settlements. It is therefore considered to be in-line with Wales Spatial Plan and considered to be compatible with PPW in terms of identifying the most sustainable locations for development, as it is these larger settlements which generally have infrastructure, services, facilities and potential land availability. The approach also takes into account the five key Planning Principles and mirrors the conclusions of the Employment Land Review and Property Market Assessment. Development and regeneration of settlements to the East o the County Borough would also require a defined policy approach to ensure it contributes to sustainable places. By focussing on this wider growth distribution option, it ensures the role of other sustainable settlements are not overlooked. This option does not ignore the potential role that the sustainable satellite settlements can play in contributing to sustainable development.

Wider Strategies - consideration of the North Wales Growth Deal, Conwy Economic Strategy, etc.

Again this is similar to Option 3, but it provides a wider growth area to ensure deliverability of the evidence and growth level options. The option would therefore meet with wider strategies, and would concentrate development away from constrained areas in the East. This option would also maximise the potential of the growth 'hub' along the coast, in accordance with the Wales Spatial Plan.

Evidence Base - such as the Employment Land Review, Property Market Assessment, Local Housing Market Assessment

This growth distribution option meets the current evidence base in terms of sustainable locations to accommodate community's development needs. Settlements lower down the hierarchy potentially do not have the necessary infrastructure and market conditions to assist growth.

Promoting Healthy Lifestyles, including Active Travel - will the option develop and maintain places that foster healthy, active lifestyles across all age and socio-economic groups

Growth focused within the sustainable locations identified in the WSP and Satellite Settlements will provide further opportunity to encourage active and healthy lifestyles. For example, wider growth will potentially assist in progressing the Conwy Active Travel Plan over a wider scale

Welsh Language & Placemaking - will the option seek to ensure a broad distribution and phasing of development that takes into account the ability of the area or community to accommodate development without adversely impacting use of the Welsh language

The growth distribution option may impact on the Key Settlements such as Penmaenmawr, Llanfairfechan and Satellite Settlements by potentially diluting the Welsh Language. However, new development opportunity will also encourage local Welsh speakers to remain in the area and access suitable homes and jobs, which may currently not be available. Further work will be undertaken to assess the impact on the Welsh language and potential mitigation.

Infrastructure Capacity - ensuring infrastructure capacity either exists or can be provided

By focusing growth wider within the WSP and Satellite settlements, it will likely have less impact on the capacity of infrastructure than a more focused growth distribution approach would have. A full Infrastructure Assessment is underway to inform the RLDP and will in turn inform the preferred strategy approach.

Constraints - having regard to key physical or environmental constraints

By focusing growth wider into sustainable Satellite Settlements, it is likely to put less pressure on a wide range of physical and environmental constraints in and around certain settlements. Relatively unconstrained and sustainable settlements outside of the higher order tiers of the WSP are being considered under this option and as such ensures the RLDP is better placed to overcome constraints and infrastructure issues.

Commitments - having regard to the location of and likely delivery of existing commitments (those with planning permission)

A good proportion of commitments fall within the higher order settlements identified in the LDP but less so in the satellite settlements, although some of these remain undeveloped. Also, some of the existing commitments fall outside the defined growth zone approach, such as Abergele.

Candidate Sites - Acknowledging the availability and distribution of Candidate Sites (this will be further assessed in progressing the Preferred Strategy.

The option ensures that other candidate sites can be considered, other than those that fall within the WSP growth area (i.e. Option 3). A number of strategic candidate sites submitted to date do fall within the defined growth distribution area. Again candidate sites in other urban sustainable settlements would be prevented from being considered under this option, although such sites fall within the more constrained areas to the East of the County Borough.

At this stage in the RLDP preparation candidate sites are still being progressed and appraised and will inform the final growth option and Preferred Strategy.

Accessibility - ensuring convenient accessibility to key services, facilities and employment as well as transport nodes and corridors

This option is based on the WSP and recognised tier 1 sustainable settlements, which are highly accessible with the existence of strategic highways and rail, in addition to alternative sustainable modes.

Local housing market conditions - ensuring that the strategy has regard to key characteristics of local housing market areas in the Local Housing Market Assessment

The defined growth area will contain a variety of local housing market areas ranging from very strong such as Llandudno to slightly weaker areas. However, WSP growth zone and satellite settlements do exclude the very weak market areas to the East of the County Borough. The Affordable Housing Viability Study (BP10) will further inform the growth distribution in the Preferred Strategy. The option does not propose distribution of growth to lower tier settlements, due to the fact that market conditions are more strained in delivering housing and employment.

Flexibility - ensuring an option is sufficiently flexible to withstand unforeseen circumstances or changes in market demand

By distributing growth wider than the WSP areas, it provides for greater flexibility to deliver the RLDP. It provides for greater flexibility to accommodate change (such as an Inspector identifying the need for additional allocations). The Council are further investigating the potential for development to the East of the County, which will provide greater flexibility if deemed deliverable. The National Development Framework is currently in production which will also be factored in terms of flexibility.

Conformity with the emerging RLDP - will the option deliver the proposed vision and objectives of the RLDP (further work around this will be undertaken at later stages to inform the Preferred Strategy)

The concept of distributing growth across a wider focused area is well related to national policy in terms of a joined up approach to employment and housing growth. By focussing all growth on wider approach ensures that other settlements have opportunities to grow sustainably. However, adversely the remaining urban areas outside of the WSP and satellite settlements are highly constrained. Further work is underway to the East of the County to understand flood risk and determine development opportunities. This work will further inform the preferred strategy at a later date in the RLDP stage.

Brownfield Land & De-risking - will the option promote brownfield land and take a de-risking approach to unlocking the development potential of sites.

The option has the necessary mechanism in place to promote brownfield land and potential to assist de-risking.

Option 4: Summary
This growth distribution option distributes an element of growth to the sustainable Satellite Settlements in addition to the WSP growth areas. This option does not distribute as far as Option 1 (current LDP) into the Tier 2 Settlements, which do experience sustainability constraints and difficult market conditions. It is therefore considered to be in-line with national guidance and legislation in Wales in terms of identifying the most sustainable locations for development, as it is these larger settlements which generally have infrastructure, services, facilities and potential land availability. In the rural area outside of Satellite Settlements a more refined policy approach would be developed to ensure that a more flexible approach is taken to bringing about and delivering local needs housing whilst protecting local character and the open countryside. Additionally, there is a need to further understand the development constraints to the East of the County Borough and ensure that an appropriate regeneration strategy is defined in policy.

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Option 5: Hubs and Corridors

Description: Development would be distributed based on a strict interpretation of key road and rail transport hubs and routes

Spatial Distribution / Settlements Affected

Abergele/Pensarn, Colwyn Bay (including Old Colwyn), Conwy, Deganwy, Llandudno, Llandudno Junction, Llanfairfechan, Llanrwst, Mochdre, Penmaenmawr, and Towyn/Kinmel Bay Llanddulas, Dwygyfylchi* and Glan Conwy

Related Settlement Hierarchy Options: Suited to all of the Settlement Hierarchy options. If this growth distribution option is chosen it will likely reflect one of these settlement hierarchy options.

Key legislation - Consideration of the Welsh Governments PPW, Five Key Planning Principles and National Sustainable Placemaking Outcomes reflecting a Sustainable Place

A key principle in PPW is bringing about a sustainable distribution of development, underpinned by a sustainable transport system with an emphasis on public transport and other forms of sustainable transport. The County has a strategic road network comprising the A55, Coastal Rail Line, A470, A5 and Conwy Valley Rail. These corridors may be at odds with the strategic transport function of such routes which could be compromised by encouraging local traffic and journeys.

Focusing growth on transport hubs and corridors would have mixed results. On the one hand settlements along the two railway lines would represent sustainable locations for growth provided that the railway services offered could provide a step change in service provision. Growth which was located in reasonable walking distance of bus routes and nodes e.g. town centres, would represent sustainable development, but this would be achieved through other growth options detailed above.

Wider Strategies - consideration of the North Wales Growth Deal, Conwy Economic Strategy, etc.

The option provides a wider growth area than some options which in turn would ensure deliverability of the evidence and growth level options.

Evidence Base - such as the Employment Land Review, Property Market Assessment, Local Housing Market Assessment

This growth distribution option meets the current evidence base in terms of sustainable locations to accommodate community's development needs. Settlements lower down the hierarchy potentially do not have the necessary transport infrastructure and therefore may be impacted negatively.

Promoting Healthy Lifestyles, including Active Travel - will the option develop and maintain places that foster healthy, active lifestyles across all age and socio-economic groups

Growth focused within the sustainable locations identified along good transport routes should provide further opportunity to encourage active and healthy lifestyles. However, further development along the A470 and A5 could potentially encourage greater car usage unless mixed-use employment/housing is encouraged in the RLDP.

Welsh Language & Placemaking - will the option seek to ensure a broad distribution and phasing of development that takes into account the ability of the area or community to accommodate development without adversely impacting use of the Welsh language

New development opportunity along the A470/A5/Conwy Valley Line will encourage local Welsh speakers to remain in the area and access suitable homes and jobs, although land availability is constrained in these areas. Further work will be undertaken to assess the impact on the Welsh language and potential mitigation

Infrastructure Capacity - ensuring infrastructure capacity either exists or can be provided

Considerable development pressure would be placed on those settlements along transport corridors and at strategic hubs. Such an approach would place undue pressure on existing infrastructure and there may be settlements which simply do not have the level of land, services and facilities to support growth. Conversely, there will be interchanges along the A55 which will be set within open countryside where there is no existing infrastructure on which to base new development. However, this approach could also be taken under the other 4 options above.

Constraints - having regard to key physical or environmental constraints

The North Wales Coast railway and A55 runs through areas of the County which experience a number of constraints including flood risk, contaminated brownfield sites, green barrier and proximity to international nature conservation designations. The key constraint is flooding to the East of the County Borough. However, additional evidence is underway to assess the potential for development through innovative design solutions, which will inform the final strategy approach in the RLDP. The location of development along the A55 would result in unsustainable car based development in open countryside locations.

Commitments - having regard to the location of and likely delivery of existing commitments (those with planning permission)

Some of the existing commitments fall within the settlements alongside most key transport routes. However, other commitments fall outside the hubs and corridors approach. This questions how valid such a focused approach is when it has little regard to the wider picture over the whole County.

Candidate Sites - Acknowledging the availability and distribution of Candidate Sites (this will be further assessed in progressing the Preferred Strategy.

Most but not all of the candidate sites will fall within the hubs and corridors zone. Candidate sites in other sustainable settlements would be prevented from being considered. At this stage in the RLDP preparation candidate sites are still being progressed and appraised and will inform the final growth option and Preferred Strategy.

Accessibility - ensuring convenient accessibility to key services, facilities and employment as well as transport nodes and corridors

Accessibility would obviously be good under this option. However, some routes are likely to increase car usage.

Local housing market conditions - ensuring that the strategy has regard to key characteristics of local housing market areas in the Local Housing Market Assessment

The settlements which are not only alongside the railway lines, but also having stations will feature a mix of housing market areas. By contrast, locating all development at locations along the strategic highways, particularly in open countryside locations along the A55 would be in strong market areas and attractive to the market. However, the exception is lands towards the East of the County Borough along the A55/rail corridor.

Flexibility - ensuring an option is sufficiently flexible to withstand unforeseen circumstances or changes in market demand

The option is not considered to have a sufficient level of flexibility to withstand unforeseen circumstances such as an Inspector at examination identifying the need for further allocations. Ignoring large chunks of the County as well as key settlements would not give the necessary flexibility to identify additional sites.

Conformity with the emerging RLDP - will the option deliver the proposed vision and objectives of the RLDP (further work around this will be undertaken at later stages to inform the Preferred Strategy)

Directing growth based on proximity to transport corridors and nodes, to a large extent picks on the relationship between housing and employment development given that it is in this part of the County that significant employment is found and is promoted as per the Commercial Market Analysis (BP19). However, the option is not an option for planning sustainably for rural areas and settlements and locating growth along major roads could bring about unsustainable patterns of development.

Brownfield Land & De-risking - will the option promote brownfield land and take a de-risking approach to unlocking the development potential of sites.

The option has limited mechanisms in place to promote brownfield land, although the use of further greenfield lands along the key transport routes could potentially assist de-risking.

Option 5: Summary
In some respects, elements of this option are similar to the growth area approach in the WSP in that they focus on key urban settlements along key transport routes. However, the option is not a County wide option in that it ignores large parts of the County, especially rural areas, yet perversely could allow for unsustainable growth in rural settlements or possibly at junctions along the route of key strategic roads. It is also questioned in terms of the role that the railway network could play in terms of accommodating the needs of the County for development and its ability to provide for their movement requirements. Rather than being a robust basis to justify a spatial strategy in its own right, it is perhaps more suitable as a higher level context to inform the chosen spatial strategy.
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Option 6: New Settlement/Major Extension

Description: Development would be distributed via a New Settlement or via a Major Extension (mixed-use housing and employment)

Spatial Distribution / Settlements Affected

New Settlement or Major Extension

Related Settlement Hierarchy Options: Suited to all of the Settlement Hierarchy options. If this growth distribution option is chosen it will likely reflect one of these settlement hierarchy options.

Key legislation - Consideration of the Welsh Governments PPW, Five Key Planning Principles and National Sustainable Placemaking Outcomes reflecting a Sustainable Place

A key principle in PPW is bringing about a sustainable distribution of development, underpinned by a sustainable transport system with an emphasis on public transport and other forms of sustainable transport. PPW advises that 'New settlements on greenfield sites are unlikely to be appropriate in Wales, and should only be proposed where such development would offer significant environmental, social and economic advantages over the further expansion or regeneration of existing settlements'.

Draft PPW (Edition 10) also states

Para 2.61 Due to their strategic nature new settlements or major urban extensions of 1,000 or more dwellings, which will have significance beyond a single local authority, should only be proposed as part of a joint LDP, SDP or the NDF.

Papa 2.62 New settlements should only be proposed where such development would offer significant environmental, social, cultural and economic advantages over the further expansion or regeneration of existing settlements and the potential delivery of a large number of homes is supported by all the facilities, jobs and services that people need in order to create a Sustainable Place. They need to be self-contained and not dormitory towns for overspill from larger urban areas.

Despite the above there could be an opportunity to deliver a major extension to an existing urban settlement or join settlements where the necessary infrastructure is available. The option also allows for potential growth in higher market areas.

Wider Strategies - consideration of the North Wales Growth Deal, Conwy Economic Strategy, etc.

The option would ensure growth is proposed in areas of high accessibility to deliver economic growth.

Evidence Base - such as the Employment Land Review, Property Market Assessment, Local Housing Market Assessment

This growth distribution option meets the current evidence base in terms of sustainable locations to accommodate the community's development needs. Settlements lower down the hierarchy may be ignored and therefore may be impacted negatively.

Promoting Healthy Lifestyles, including Active Travel - will the option develop and maintain places that foster healthy, active lifestyles across all age and socio-economic groups

Growth focused within one location along good transport routes should provide further opportunity to encourage active and healthy lifestyles.

Welsh Language & Placemaking - will the option seek to ensure a broad distribution and phasing of development that takes into account the ability of the area or community to accommodate development without adversely impacting use of the Welsh language

New development opportunity in one location could encourage local Welsh speakers to leave other settlements where growth would not be proposed. Further work will be undertaken to assess the impact on the Welsh language and potential mitigation.

Infrastructure Capacity - ensuring infrastructure capacity either exists or can be provided

Considerable development pressure would be placed on the chosen area and as such new infrastructure would be required, which in turn could impact on planning obligations such as affordable housing.

Constraints - having regard to key physical or environmental constraints

Options for a new settlement are only likely to be delivered via the take-up of existing green wedges, which in turn could impact on natural and historic landscapes.

Commitments - having regard to the location, and likely delivery, of existing commitments (those with planning permission)

Some of the existing commitments may fall in the proposed area.

Candidate Sites - Acknowledging the availability and distribution of Candidate Sites (this will be further assessed in progressing the Preferred Strategy).

At this stage in the RLDP preparation candidate sites are still being progressed and appraised and will inform the final growth option and Preferred Strategy.

Accessibility - ensuring convenient accessibility to key services, facilities and employment as well as transport nodes and corridors

Accessibility would obviously be good under this option dependent on the appropriate extension. A new settlement would also need to factor in good rail/road accessibility. However, some routes are likely to increase car usage.

Local housing market conditions - ensuring that the strategy has regard to key characteristics of local housing market areas in the Local Housing Market Assessment

Potential to locate the option within higher market areas which in turn would increase planning obligations such as affordable housing.

Flexibility - ensuring an option is sufficiently flexible to withstand unforeseen circumstances or changes in market demand

The option is not considered to have a sufficient level of flexibility to withstand unforeseen circumstances such as an Inspector at examination identifying the need for further allocations. Ignoring large chunks of the County as well as key settlements would not give the necessary flexibility to identify additional sites.

Conformity with the emerging RLDP - will the option deliver the proposed vision and objectives of the RLDP (further work around this will be undertaken at later stages to inform the Preferred Strategy)

Directing growth to a new settlement/major extension would ignore other key regeneration areas and settlements.

Brownfield Land & De-risking - will the option promote brownfield land and take a de-risking approach to unlocking the development potential of sites.

The option has limited mechanisms in place to promote brownfield land, although the use of further greenfield lands to assist a new settlement/major extension could potentially assist de-risking.

Option 6: Summary
In some respects, elements of this option could focus specifically on the WSP and in higher market value areas, which in turn would increase viability. However, the option is not a County wide option in that it ignores large parts of the County. The option would also increase traffic usage in one area significantly. The option would need further consideration following the call for sites and options for focused growth to a new settlement or major extension.

No map provided.
New Settlement/Major settlement extensions will be considered following the call for sites.

The final LDP approach may be a combination of more than one option, so we need to know your views on each one. Please explain which option, or parts of option, you feel are the best choice and the reasons for this view. Please say whether you think the options are realistic and achievable and which one is your preferred option and why. This will help us shape the Preferred Strategy.

(3) Question 11: What is your preferred spatial growth option as detailed in the options above?

(3) Option 1

(4) Option 2

(3) Option 3

(3) Option 4

(3) Option 5

(3) Option 6

(2) Question 12: Are there any other options we should include?

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