Preferred Strategy

Comment

Representation ID: 27627

Received: 03/09/2019

Respondent: Welsh Government

Preferred Strategy:

The Preferred Strategy directly quotes BMV policy in Strategic Objective 1 (SO1), Strategic Policy 13, Managing Settlement Form. BMV policy is also considered in the sustainability appraisal.

Departmental View:

The Department offers no objection at this time based on the candidate site assessment of agricultural land quality and the commitment to produce a paper evidencing the application of BMV policy.

Noted.

Comment

Representation ID: 27644

Received: 29/08/2019

Respondent: Welsh Government

The level of growth proposed is around 2,500 dwellings above the WG 2014-based principal and 10 year migration projection. The Council has concluded that the WG projections would result in 'too low' growth levels and would compound negative demographic and economic prospects for the LPA. The level of housing growth proposed in the Preferred Strategy broadly aligns with the past 15 year build rate trend (300 p/a) and is slightly above the past 10 year past build rates (250 p/a). The housing requirement is 2,200 dwellings lower than the current adopted plan required of 6,520 dwellings.

Noted.

Object

Representation ID: 27645

Received: 29/08/2019

Respondent: Welsh Government

The LHMA (Table 38) concludes there is an annual need of 200 affordable homes per annum required over the plan period (excluding supply). The required tenure split shows a predominate need for social rented homes (85%) to intermediate (15%). However, the conclusion following the table states the LPA 'does not agree' and intends to pursue a 50/50 tenure split.

Noted: However refer to BP/11 for justification to defer from the LHMA.

Object

Representation ID: 27646

Received: 29/08/2019

Respondent: Welsh Government

The settlement hierarchy and plan policies make multiple references to the promotion of 'exception sites' to meet local needs outside of settlement boundaries, providing they include a minimum of 50% affordable housing, on sites up to 20 units.

Accepted in part. The 50% AH sites are not referred to in the PS as 'Exception Sites' however comments from the WG are noted and the AH policy will be revised for the Deposit Plan.

Comment

Representation ID: 27647

Received: 29/08/2019

Respondent: Welsh Government

The Council's GTAA only covers the period 2017-2022. To ensure compliance with legislation and planning policy, a GTAA must be prepared and agreed by Welsh Ministers in advance of Deposit stage for the whole LDP period (2018-2033) with provision made for appropriate and deliverable site allocations to meet the need identified within the required timescales, if appropriate.

A new joint DCC/CCBC GTAA will be completed for Deposit Plan.

Comment

Representation ID: 27648

Received: 29/08/2019

Respondent: Welsh Government

The Council has undertaken a Welsh Language Impact Assessment (July 2019) of the Preferred Strategy and an initial impact assessment of the five strategic sites (BP42). They acknowledge the importance of the language and the integral role it plays to community life in Conwy, highlighting the need for specific policies and mitigation measures. We note that Strategic Policy 7: Welsh Language states that language sensitive areas will be defined in the Deposit Plan, along with mitigation measures where appropriate.

Noted.

Comment

Representation ID: 27651

Received: 29/08/2019

Respondent: Welsh Government

The Council has undertaken a significant amount of work in respect of place making, delivery and infrastructure to inform the Preferred Strategy. This puts the LPA in a good position moving forward, namely:

Clear articulation and justification of the spatial distribution of housing supply and components of the housing provision (private and affordable)
Housing trajectory
Strategic sites and delivery infrastructure assessment - including constraints, site requirements and masterplan concept frameworks
Initial affordable housing viability paper
Education and transport assessments and requirements

Noted. All necessary site viability, delivery and trajectory work will be prepared to inform the Deposit Plan.

Comment

Representation ID: 27652

Received: 29/08/2019

Respondent: Welsh Government

A large proportion of the authority is within Priority Areas 3 & 15 for Solar and Wind Energy in the draft NDF. On this basis the Authority should ensure that it is in general conformity with the NDF when adopted. The LPA has prepared a Renewable Energy Assessment (REA) in line with the WG Toolkit Methodology which concludes there are no suitable wind or solar Local Search Areas (LSAs). The Council has allocated the SSA within its area, and is proposing to allocate Land at Gofer for a 4MW PV solar array.

Noted. The NDF detail wasn't available at the time of preparing the Preferred Strategy and the identified areas are not available as data as WG cannot release it in draft form. Text and designations will be amended to reflect national guidance when finalised and clarity will be added regarding the integration of the REA recommendations.

Comment

Representation ID: 27653

Received: 29/08/2019

Respondent: Welsh Government

The Council should ensure that no highly vulnerable development is allocated in C2 Flood Plain. Development is located in C1, while the principle of development may be appropriate in national policy terms, the key consideration for the LPA will be to demonstrate that allocations (where relevant) are suitable and deliverable in line with any mitigation measures that may be required in order to meet the requirements of national policy.

Noted. Areas of flood risk will be avoided in line with national guidance.

Comment

Representation ID: 27654

Received: 29/08/2019

Respondent: Welsh Government

Strategic Policy SP24 and the strong reflection of PPW 10 is welcomed.

Noted.