Review Report

Comment

Representation ID: 27224

Received: 22/12/2017

Respondent: Beech Developments (NW) Ltd

Agent: P L Planning

The developers note the Written Statement of the Cabinet Secretary of 14 December 2017 inviting Conwy and Denbighshire to submit proposals to prepare a Joint LDP. The developers agree with the Cabinet Secretary that the cost and time taken to prepare LDP's to date is excessive and that resources should be used efficiently.
However, the Statement of 14 December 2017 is likely to lead to additional delay and uncertainty in the immediate future and a lengthened Development Planning process yet again.

Noted: CCBC agree with statements made. A response has been provided to the Minister expressing concerns with regards to timing and housing land supply.

Object

Representation ID: 27225

Received: 22/12/2017

Respondent: Beech Developments (NW) Ltd

Agent: P L Planning

Rather than the Review Report using language which suggests a need to reduce the housing supply the Council should be taking positive and continuing steps to enable delivery of housing, including in a replacement LDP.
Additional, suitable, viable land attractive to the market in sustainable places where people want to live is available and capable of contributing to housing delivery.

Noted. Housing requirements and supply levels will be re-assessed as part of the Review process.

Object

Representation ID: 27226

Received: 22/12/2017

Respondent: Beech Developments (NW) Ltd

Agent: P L Planning

Failure to deliver the envisaged number of windfalls: The windfall allowance was calculated by using a 5 year past trend and doubling it. As the Inspector reported (para 5.35) "simply doubling this figure by way of extrapolation to 2022 introduces a greater degree of uncertainty...". The Plan also relies on a high percentage of windfalls (29%) coming forward. The risk of failure from windfall not being achieved was therefore reasonably predictable.

Noted. All housing requirements and sources of supply will be re-assessed as part of the LDP Review process.

Object

Representation ID: 27227

Received: 22/12/2017

Respondent: Beech Developments (NW) Ltd

Agent: P L Planning

The LDP housing target was not unrealistic. It was evidence based, consulted upon at Deposit, Examined and found to be Sound. This should be explicitly acknowledged.

Accepted in part. Whilst we acknowledge that the housing target was found sound at Examination, subsequent WG projections have indicated far lower housing requirements. The Inspector did not take into account the reduced level of delivery since 2008, although CCBC argued to reduce the requirement for this reason.

Object

Representation ID: 27228

Received: 22/12/2017

Respondent: Beech Developments (NW) Ltd

Agent: P L Planning

The revision to TAN1 (2015) has not exacerbated the housing land supply position. It provided a standardised method of calculating housing land supply. The consequence is that Local Authorities cannot not use alternative methods of calculation (such as previous build rates) to rely on past performance a measure of success nor to continue to set aside their responsibilities to plan for the delivery of housing in accordance with National Planning Policy.

Noted. It is acknowledged that the residual method has always been the primary method of calculating land supply for authorities with adopted plans, however the past build rates method provided a 'sense-check' of the residual requirement which may indicate 'land shortages or surpluses, which do not exist in practice' (TAN1 2006 7.5.2)

Object

Representation ID: 27229

Received: 22/12/2017

Respondent: Beech Developments (NW) Ltd

Agent: P L Planning

PPW para 9.2 does not state that Local Authorities should reduce the emphasis given to WG household projections when determining LDP housing requirements. In fact para 9.2 states they must work in collaboration with housing authorities, registered social landlords, house builders, developers, land owners and the community and must take account of...the Welsh Governments later household projections. The must also take account of a number of other sources including local housing needs and demands, the needs of the local and national economy and social considerations (including unmet need).

Accepted in part. PPW does now change the emphasis to be given to WG household projections when calculating LDP household requirements than was the case PPW prior to Edition 8. This will be clarified.

Object

Representation ID: 27230

Received: 22/12/2017

Respondent: Beech Developments (NW) Ltd

Agent: P L Planning

There is no mention of the suitability of sites allocated for housing in the plan or indeed their potential to become available. For example there has been subsequent research on the need to look at deliverability and viability far more closely than in previously LDPs (WG study 'Longitudinal Viability Study of the Planning Process').
Furthermore case studies (including in Conwy) suggest permissions not being released as a result of delays in signing S106 agreements.

Accepted. As part of the LDP review, candidate sites will be required to demonstrate viability and deliverability before being allocated. The conclusion will be expanded to reflect this.

Object

Representation ID: 27231

Received: 22/12/2017

Respondent: Beech Developments (NW) Ltd

Agent: P L Planning

The Review should reflect on the requirement for General Conformity with the emerging National Development Framework for Wales, the potential for a North Wales Strategic Development Plan and take full account of the vision of the North Wales Economic Ambition Board. The latter aspiration for 120000 new job opportunities in north Wales to 2035, associated Growth Bid activities. Regional Growth aspiration clearly points towards a requirement for significant additional housing to support employment and job creation. The Conwy Economic Strategy 2017-2027 seek to deliver 3500 new jobs to the County - a significantly higher number than the current LDP.

Accepted in principle. This section already makes reference to NWEAB and the A55 corridor plan (SDP). However this will be clarified further.

Comment

Representation ID: 27232

Received: 22/12/2017

Respondent: Beech Developments (NW) Ltd

Agent: P L Planning

A further review of CIL has now been announced by central government. CIL powers will be devolved to Wales in April 2018.

Noted. Changes in means to secure infrastructure requirements may be required. This will be considered as part of LDP Review.

Object

Representation ID: 27233

Received: 22/12/2017

Respondent: Beech Developments (NW) Ltd

Agent: P L Planning

The build rate is not 'extremely ambitious'. The evidence at Examination supported it including capacity in the housebuilding industry along with housing need. The current LHMA (2016-2021) shows a need for at least 199 affordable housing units per year.

Not accepted. The point of this paragraph is that in comparison with recent build rates the Council maintain that building 435 per year is extremely ambitious. The housing requirement will be reviewed using the latest evidence as part of the LDP review process.