swansea ldp examination statement of swansea council · 2018-02-13 · 1 | p a g e swansea ldp...

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Swansea LDP Examination

Statement of

Swansea Council

Non-strategic (H1) and

‘Exception Site’ (H5) Allocations

in East, Central, West, Gower

Fringe and Gower Zones

Hearing Session 8A: 27 February 2018

Published: 12 February 2018

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Contents Contents ..................................................................................................................... 2

1.0 Introduction ........................................................................................................ 4

2.0 Procedural Matters ............................................................................................ 4

3.0 Are the site allocations appropriate? .................................................................. 5

Central SHPZ .......................................................................................................... 5

Site H1.1 - Former Vetch Field, Glamorgan Street, Swansea ............................. 5

Site H1.2 – Llwyn Y Bryn Campus ....................................................................... 9

Site H1.3 – Townhill Campus, Townhill Road, Townhill ..................................... 10

East SHPZ ............................................................................................................ 13

Site H1.4 – Land between Bog Road and Cefn Hengoed Road, Llansamlet ..... 13

Site H1.5 – Land at Upper Bank, Nantong Way, Landore ................................. 17

Site H1.6 – Land at Jersey Road opposite numbers 16-38, Pentrechwyth ........ 21

Site H1.7 – Land at rear of 17-93 Carmel Road, Winch Wen ............................ 24

Site H1.8 – Land at Ty Draw Road and Llanerch Road, Bonymaen .................. 28

Site H1.9 – Land at Graigola Road, Glais .......................................................... 32

Site H1.10 – Land at Tanycoed Road, Clydach ................................................. 36

Site H1.11 – Land at Ramsey Road, Clydach ................................................... 40

Site H1.12 – Former Teachers Centre, Gellionen Road, Clydach ..................... 44

Site H1.13 – Talycoppa farm, Llansamlet .......................................................... 45

Site H1.14 – Land adjacent to Heol Las, Birchgrove ......................................... 48

Site H1.15 – Land at Midland Place, Llansamlet ............................................... 50

Site H1.16 – Heol Ddu Farm, Llansamlet .......................................................... 54

Site H1.17 – Gwernllwynchwyth House, Llansamlet .......................................... 57

Site H1.18 – Land at Fredrick Place, Llansamlet ............................................... 61

Site H1.19 – Former Four Seasons Club, Trallwn ............................................. 65

Site H1.20 – Land at David Williams Terrace, Port Tennant .............................. 66

West SHPZ ........................................................................................................... 70

Site H1.51 – Former Eastmoor Nursery, Chestnut Avenue, West Cross ........... 70

LDP Policy H 5 Sites ............................................................................................. 71

Site H5.1 – Land at Monksland Road, Scurlage ................................................ 71

Site H5.2 – Land to the east of Gowerton Road ................................................ 76

Site H5.3 – Land adjoining Tirmynydd Road, Three Crosses ............................ 80

Site H5.4 – Land adjoining Pennard Drive, Pennard ......................................... 84

Site H5.5 – Land at Summerland Lane, Newton ................................................ 88

Site H5.6 – Land at Higher Lane, Langland ....................................................... 92

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4 0 Monitoring Framework ..................................................................................... 95

5.0 Proposed Matters Arising Changes (MACs) .................................................... 96

Appendix 1: More Homes Strategy ........................................................................ 102

Appendix: Candidate Site Report Stage 3A and 3B forms (see separate document)

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Swansea Local Development Plan 2010 – 2025

Examination Hearing Session 8a:

Non-strategic and Rural Exception Site Housing Allocations (Policies H 1 and

H 5) (Sites in East, Central, West, Gower Fringe and Gower Zones)

1.0 Introduction 1.1 This Statement has been produced by Swansea Council (hereafter ‘the

Council’) in order to respond fully to the detailed ‘Matters and Issues’ agendas produced by the Inspectors for the Swansea Local Development Plan (LDP) Examination.

1.2 The Statement relates to Hearing Session 8a: Non-Strategic and Rural

Exception Site Housing Allocations (Policies H 1 and H 5) in Strategic Housing Policy Zones (SHPZ) East, Central, West, Gower Fringe and Gower. The statement is set out in accordance with the headings and sub-questions provided by the Inspectors. Any relevant potential ‘Matters Arsing Changes’ are clearly highlighted at the end of the Statement.

2.0 Procedural Matters 2.1 Any relevant procedural matters to be addressed will be identified by the

Inspectors, or relevant parties in attendance, at the appropriate hearing session.

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3.0 Are the site allocations appropriate?

LDP Non-Strategic Housing Sites Central SHPZ Site H1.1 - Former Vetch Field, Glamorgan Street, Swansea

a. Would the allocation contribute to the objectives of the Plan and those of

the Sustainability Appraisal? 3.1 Yes – the site forms an integral element of the Plan’s Sustainable Housing

Strategy which is set out in Policy PS 3.

3.2 All allocations in the Plan have been appraised against both LDP objectives and Sustainability Appraisal (SA) objectives to ensure that they contribute both to the objectives underlying each of the Plan’s policies and to the objectives of achieving sustainable development.

3.3 The outcome for each individual site allocation is reported in the relevant Candidate Site (CS) Report in the Stage 3A and 3B forms1 which are presented in the Appendix. Appendix 5 of the SA report2 presents a composite table of the SA scores for all allocated sites. These assessments show that the sites

1 http://www.swansea.gov.uk/article/27770/Candidate-site-register-2016---allocated-sites 2 LDP09a SA Report Appendix 5 (June 2016)

http://www.swansea.gov.uk/article/27770/Candidate-site-register-2016---allocated-sites

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contribute to the objectives of the Plan and the SA objectives while any mitigation measures necessary are noted.

b. Is the allocation consistent with other LDP policies and designations, and

should key policy expectations be consistently identified in the ‘development principles’?

3.4 There are no conflicting policies and designations for this site. The Council

carried out a robust CS process (as reported in ED006.73) to ensure that all allocations in the Plan were capable of complying with LDP policy requirements and designations. The CS Stage 1 filtering process ensured that sites with fundamental constraints to their delivery were removed at an early stage in the process. There are therefore no allocations which are fundamentally in conflict with LDP policies and designations. Sites which then progressed to Stage 2 of the process were subjected to the more detailed site assessment process (as set out in the CS Assessment Reports). The process identified infrastructure and mitigation measures which would be required on or off-site, or through financial contributions. The comprehensive and iterative nature of assessments undertaken by the Council on proposed sites has ensured that all the allocations in the Plan, with the exception of those identified in this statement as being affected by updated evidence, are compliant with LDP policy.

3.5 The key constraints and resulting policy expectations are highlighted in the CS

reports and SA conclusions and reflect the information available at the time of the allocation. However, the Plan does not specifically identify all key policy expectations relating to each site in the “development principles” column of the H1 table. Whilst, the information which informed the site allocation process is considered to be robust and is sufficient to provide the Council with confidence that the sites are viable and deliverable in the Plan period, the inclusion of this level of detail in the Plan is not considered to be appropriate, as the exact nature of key policy requirements for H1 sites will be determined at the planning application stage, having regard to the most up to date surveys and assessments (as required by the relevant LDP policies). The purpose of the column in the Deposit Plan was to present additional information identified as necessary to make the allocation acceptable and/or key issues in respect of the site identified during discussions between the Council and site promoter. For this site it was noted that development must accord with the SPG.

c. Is the quantum and density of dwellings on the site realistic and

appropriate? 3.6 Yes – the site quantum and density reflects the adopted SPG4 and Masterplan

for the site. This SPG will be re-adopted to align with the LDP.

3 ED006.7 SC Additional Info CS Process and Methodology 2017 4 Vetch Field Masterplan SPG 2015.

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d. Are there any significant constraints or barriers to the site’s

development? 3.7 No - the viability and deliverability of sites was an inherent part of the CS

assessment process. The Stage 1 filtering process ensured that sites with fundamental constraints to their delivery were removed at an early stage in the process. The detailed Stage 2 CS Assessment process was informed by desk based survey data, technical study information, and consultation with both internal Council departments and external stakeholder organisations (such as NRW, DCWW). The Council engaged in dialogue with site promoters to ensure that they were aware from an early stage of the infrastructure provision and mitigation measures required. There are therefore no significant constraints or barriers to development on H1 sites, and where constraints or issues have been identified through the CS process, the Council have confirmed that mitigation measures can be implemented in accordance with Plan policies. The Flood Risk evidence5 confirms there are no flooding issues with this site.

e. Is the expected timescale for delivery realistic, having regard to

infrastructure requirements? 3.8 Yes – there are no major infrastructure requirements for the site. The land will

be developed in accordance with the adopted SPG and masterplan which has been subject to extensive consultation and research. The site is being developed in two phases and the LDP allocation refers to the future second phase. The first phase, located on the land off Madoc Place, is currently under construction by Pobl for 30 sheltered housing single bed apartments under planning application reference 2015/1731. The future phase of 40 units is scheduled to be provided by the same RSL in the Affordable Housing Programme Delivery Plan (PDP), to start construction in 2019/20 and with completion forecasted in 2020/21.

f. Has a financial viability assessment been carried out? If so, what are its

conclusions? 3.9 The future phase of 40 units is to be provided by the same RSL and the project

is listed in the Affordable Housing PDP, confirming that funding is secured for the development.

3.10 The issue of financial viability of H1 sites is addressed in detail at Section 7 of

ED006.76 which clarifies that the non-strategic sites were not subject to specific financial viability appraisal, as at the time of allocation it was considered to be overly onerous on smaller scale site promoters to require this. E006.7 states that the CS assessment process was considered to give sufficient reassurance that sites allocated in the Plan were deliverable and viable. The document highlights that SDA sites (which make up 76% of allocations) have been subject to Independent Financial Viability Appraisals. The Council is therefore able to provide very detailed, site specific evidence regarding the financial viability of

5 ED006.5 SC Additional Info Flood Risk and Mitigation 6 Dec 17 6 ED006.7 SC Additional Info CS Process and Methodology 6 Dec 17

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the majority of development in the Plan. ED006.27 provides the up to date assurances of the delivery of all allocated sites (both Strategic and Non-Strategic), including details of the financial viability assessment carried out to support such sites. At the broader, plan wide level, the Affordable Housing Viability Study 20138 and 2016 update9 provide evidence of the overarching financial viability of development across the County, by demonstrating that residual land values are sufficient to support development whilst meeting the affordable housing contributions set out in Policy H3.

g. What are the implications of the site and/or supporting infrastructure not

coming forward within the anticipated timescale? 3.11 There are no significant infrastructure requirements for the site. The Plan

housing supply incorporates flexibility to allow for some sites not coming forward at the rate expected.

h. Any other site specific matters 3.12 The Council has provided full responses to the issues raised in the LDP

Deposit consultation. See Deposit Consultation Report (Core Document LDP17). In terms of Fields in Trust (FIT) and Accessible Natural Greenspace (ANGS) standards, the Council has undertaken a quantitative, qualitative and accessibility assessment of all open space provision. Outputs from the Open Space assessment (OSA) provide an evidence base against which LDP Policies SI5 and SI6 have been formulated to protect and provide for open space. The LDP Policies seek to provide new open space on residential developments with a capacity of 10 units or more. This allocation lies within the Castle ward, which the OSA shows has a FIT deficiency. The Council would seek to address this and provide FIT provision as part of the development. This would add to the overall provision in the ward and provide north Sandfields, which is currently deficient, with access to a FIT facility within 300 metres. Importantly, the OSA classifies the land in question as ‘F2 – Community Garden’, which does not form part of the FIT or ANGS standards. As such, development of the site would not reduce the provision of public open space as defined by FIT. The Adopted Vetch Masterplan Review SPG proposes 0.7ha of public open space comprising retention of an element of the existing open space together with opportunities for new forms of open space (wild flower meadow/community orchard/informal open space/natural play) and a community centre.

7 ED006.2 SC Additional Info Phasing and Delivery 6 Dec 17 8 EB001 Affordable Housing Viability Study July 2013 9 EB002 Affordable Housing Viability Study Report May 2016

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Site H1.2 – Llwyn Y Bryn Campus

3.13 Since publication of the Deposit Plan, the College has been granted planning

permission for up to 200 residential apartments (Class C3) and signed a Section 106 under reference 2011/0184 on 15th September 201710. A MAC is proposed at the end of this document to reflect that the site is now a commitment.

10 https://property.swansea.gov.uk/online-applications/files/76135D48C633DA4B6312E39E1A4D2298/pdf/2011_0184-FINAL_DECISION_NOTICE-684154.pdf

https://property.swansea.gov.uk/online-applications/files/76135D48C633DA4B6312E39E1A4D2298/pdf/2011_0184-FINAL_DECISION_NOTICE-684154.pdf

https://property.swansea.gov.uk/online-applications/files/76135D48C633DA4B6312E39E1A4D2298/pdf/2011_0184-FINAL_DECISION_NOTICE-684154.pdf

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Site H1.3 – Townhill Campus, Townhill Road, Townhill



Strategy which is set out in Policy PS 3. All allocations in the Plan have been appraised against both LDP objectives and SA objectives to ensure that they contribute both to the objectives underlying each of the Plan’s policies and to the objectives of achieving sustainable development. The outcome for each individual site allocation is reported in the relevant CS Report in the Stage 3A and 3B forms11 presented in the Appendix. Appendix 5 of the SA report12 presents a composite table of the SA scores for all allocated sites. These assessments show that the sites contribute to the objectives of the Plan and the SA objectives while any mitigation measures necessary are noted.




carried out a robust CS process (as reported in ED006.713) to ensure that all allocations in the Plan were capable of complying with LDP policy requirements

11 http://www.swansea.gov.uk/article/27770/Candidate-site-register-2016---allocated-sites 12 LDP09a SA Report Appendix 5 (June 2016) 13 ED006.7 SC Additional Info CS Process and Methodology 2017


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and designations. The CS Stage 1 filtering process ensured that sites with fundamental constraints to their delivery were removed at an early stage in the process. There are therefore no allocations which are fundamentally in conflict with LDP policies and designations. Sites which then progressed to Stage 2 of the process were subjected to the more detailed site assessment process (as set out in the CS Assessment Reports). The process identified infrastructure and mitigation measures which would be required on or off-site, or through financial contributions. The comprehensive and iterative nature of assessments undertaken by the Council on proposed sites has ensured that all the allocations in the Plan, with the exception of those identified in this statement as being affected by updated evidence, are compliant with LDP policy.


reports and SA conclusions and reflect the information available at the time of the allocation. However, the Plan does not specifically identify all key policy expectations relating to each site in the “development principles” column of the H1 table. Whilst, the information which informed the site allocation process is considered to be robust and is sufficient to provide the Council with confidence that the sites are viable and deliverable in the Plan period, the inclusion of this level of detail in the Plan is not considered to be appropriate, as the exact nature of key policy requirements for H1 sites will be determined at the planning application stage, having regard to the most up to date surveys and assessments (as required by the relevant LDP policies). The purpose of the column in the Deposit Plan was to present additional information identified as necessary to make the allocation acceptable and/or key issues in respect of the site identified during discussions between the Council and site promoter. For this site it was noted that highway access for the development should be from Townhill Road. The main building constitutes a local land mark feature and should be retained as part of the development. Proposals will be expected to consider these principles, and integrate any development requirements that are highlighted, in the context of the particular circumstances that apply at the time of any future planning application, including financial viability. A MAC is proposed at the end of this document to clarify the purpose of the Development Principles column.


appropriate? 3.17 Yes – the site quantum (150)/density (28 dph) reflects the CS Assessment

findings regarding the requirement to retain the existing main building; and the sloping nature of much of the site, and areas of mature vegetation including TPOs which limit the developable area.



assessment process. The Stage 1 filtering process ensured that sites with fundamental constraints to their delivery were removed at an early stage in the process. The detailed Stage 2 CS Assessment process was informed by desk

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based survey data, technical study information, and consultation with both internal Council departments and external stakeholder organisations (such as NRW, DCWW). The Council engaged in dialogue with site promoters to ensure that they were aware from an early stage of the infrastructure provision and mitigation measures required. There are therefore no significant constraints or barriers to development on H1 sites, and where constraints or issues have been identified through the CS process, the Council have confirmed that mitigation measures can be implemented in accordance with Plan policies.


infrastructure requirements? 3.19 Yes – there are no major infrastructure requirements for the site. UWTSD and

a developer have agreed Heads of Terms for the purchase of the site and are proceeding to an exchange of legal contracts. They expect a planning application to be submitted in Quarter 3 2018 and pre-application discussions have commenced with the Council. Site assessments have been undertaken to inform the forthcoming planning application and initial discussions have also taken place with Welsh Water representatives and the Council’s Highways Department. The developer has provided a timeline for development as set out in the site schedule in ED006.2, with units beginning to be completed in 2019/20.


conclusions?

3.20 The site promoter has agreed Heads of Terms for the sale of the site to a

developer and are proceeding to an exchange of legal contracts ahead of the submission of a formal planning application. Ongoing site assessments are now taking place in order to inform the forthcoming planning application submission.


ED006.714 which clarifies that the non-strategic sites were not subject to specific financial viability appraisal, as at the time of allocation it was considered to be overly onerous on smaller scale site promoters to require this. E006.7 states that the CS assessment process was considered to give sufficient reassurance that sites allocated in the Plan were deliverable and viable. The document highlights that SDA sites (which make up 76% of allocations) have been subject to Independent Financial Viability Appraisals. The Council is therefore able to provide very detailed, site specific evidence regarding the financial viability of the majority of development in the Plan. ED006.215 provides the up to date assurances of the delivery of all allocated sites (both Strategic and Non-Strategic), including details of the financial viability assessment carried out to support such sites.

14 ED006.7 SC Additional Info CS Process and Methodology 6 Dec 17 15 ED006.2 SC Additional Info Phasing and Delivery 6 Dec 17

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3.22 At the broader, plan wide level, the Affordable Housing Viability Study 201316 and 2016 update17 provide evidence of the overarching financial viability of development across the County, by demonstrating that residual land values are sufficient to support development whilst meeting the affordable housing contributions set out in Policy H3.





Deposit consultation. See Deposit Consultation Report (Core Document LDP1718).

East SHPZ Site H1.4 – Land between Bog Road and Cefn Hengoed Road, Llansamlet

16 EB001 Affordable Housing Viability Study July 2013 17 EB002 Affordable Housing Viability Study Report May 2016 18 LDP17 Deposit LDP Consultation Report - July 2017

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Strategy which is set out in Policy PS 3. All allocations in the Plan have been appraised against both LDP objectives and SA objectives to ensure that they contribute both to the objectives underlying each of the Plan’s policies and to the objectives of achieving sustainable development. The outcome for each individual site allocation is reported in the relevant CS Report in the Stage 3A

and 3B forms19 presented in the Appendix. Appendix 5 of the SA report20 presents a composite table of the SA scores for all allocated sites. These assessments show that the sites contribute to the objectives of the Plan and the SA objectives while any mitigation measures necessary are noted






reports and SA conclusions and reflect the information available at the time of the allocation. However, the Plan does not specifically identify all key policy expectations relating to each site in the “development principles” column of the H1 table. Whilst, the information which informed the site allocation process is considered to be robust and is sufficient to provide the Council with confidence that the sites are viable and deliverable in the Plan period, the inclusion of this level of detail in the Plan is not considered to be appropriate, as the exact nature of key policy requirements for H1 sites will be determined at the planning application stage, having regard to the most up to date surveys and assessments (as required by the relevant LDP policies). The purpose of the column in the Deposit Plan was to present additional information identified as necessary to make the allocation acceptable.



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appropriate? 3.28 The planning agent has advised that they are under instruction to submit an

outline planning application in 2018 that will consist of a proposed layout to provide a retirement village consisting of bungalows and assisted living flats with a small spa and doctor's surgery. On the basis of their latest site planning, the agent suggests that the appropriate capacity could potentially be greater than 70 units, but the allocated quantum (70) / density (17 dph) is considered to be a realistic and appropriate density based on the CS report findings which highlighted that the site is crossed by a water main for which protection measures, whether in the form of an easement and/ or diversion may be required, potential requirement to provide open space, ecological interest, and ground condition issues regarding mining legacy.


development? 3.29 No - The viability and deliverability of sites was an inherent part of the CS

assessment process. The Stage 1 filtering process ensured that sites with fundamental constraints to their delivery were removed at an early stage in the process. The detailed Stage 2 CS Assessment process was informed by desk based survey data, technical study information, and consultation with both internal Council departments and external stakeholder organisations (such as NRW, DCWW). The Council engaged in dialogue with site promoters to ensure that they were aware from an early stage of the infrastructure provision and mitigation measures required. There are therefore no significant constraints or barriers to development on H1 sites, and where constraints or issues have been identified through the CS process, the Council have confirmed that mitigation measures can be implemented in accordance with Plan policies.


infrastructure requirements? 3.30 Yes – there are no major infrastructure requirements for the site. The agent is

currently working on submitting a planning application in 2018 with a view to developing once planning permission is achieved. Completions have therefore been forecasted to start coming forward in 2019/20 to allow sufficient time for Reserved Matters consent at an annual rate of around 20-25 per annum.


conclusions? 3.31 The agent has confirmed that funding has been secured for the first phase

subject to planning consent being achieved and the landowner intends to develop the site themselves (having developed the adjacent substantial Hengoed Court development).

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3.32 The issue of financial viability of H1 sites is addressed in detail at Section 7 of ED006.722 which clarifies that the non-strategic sites were not subject to specific financial viability appraisal, as at the time of allocation it was considered to be overly onerous on smaller scale site promoters to require this. E006.7 states that the CS assessment process was considered to give sufficient reassurance that sites allocated in the Plan were deliverable and viable. The document highlights that SDA sites (which make up 76% of allocations) have been subject to Independent Financial Viability Appraisals. The Council is therefore able to provide very detailed, site specific evidence regarding the financial viability of the majority of development in the Plan. ED006.223 provides the up to date assurances of the delivery of all allocated sites (both Strategic and Non-Strategic), including details of the financial viability assessment carried out to support such sites.

3.33 At the broader, plan wide level, the Affordable Housing Viability Study 201324

and 2016 update25 provide evidence of the overarching financial viability of development across the County, by demonstrating that residual land values are sufficient to support development whilst meeting the affordable housing contributions set out in Policy H3.

g. What are the implications of the site and/or supporting infrastructure not coming forward within the anticipated timescale?

3.34 There are no significant infrastructure requirements for the site. The Plan




22 ED006.7 SC Additional Info CS Process and Methodology 6 Dec 17 23 ED006.2 SC Additional Info Phasing and Delivery 6 Dec 17 24 EB001 Affordable Housing Viability Study July 2013 25 EB002 Affordable Housing Viability Study Report May 2016 26 LDP17 Deposit LDP Consultation Report - July 2017

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Site H1.5 – Land at Upper Bank, Nantong Way, Landore




and 3B forms27 presented in the Appendix. Appendix 5 of the SA report28 presents a composite table of the SA scores for all allocated sites. These assessments show that the sites contribute to the objectives of the Plan and the SA objectives while any mitigation measures necessary are noted. The wider site is already making a positive contribution to the housing land supply.





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3.37 There are no conflicting policies and designations for this site. The Council carried out a robust CS process (as reported in ED006.729) to ensure that all allocations in the Plan were capable of complying with LDP policy requirements and designations. The CS Stage 1 filtering process ensured that sites with fundamental constraints to their delivery were removed at an early stage in the process. There are therefore no allocations which are fundamentally in conflict with LDP policies and designations. Sites which then progressed to Stage 2 of the process were subjected to the more detailed site assessment process (as set out in the CS Assessment Reports). The process identified infrastructure and mitigation measures which would be required on or off-site, or through financial contributions. The comprehensive and iterative nature of assessments undertaken by the Council on proposed sites has ensured that all the allocations in the Plan, with the exception of those identified in this statement as being affected by updated evidence, are compliant with LDP policy.


reports and SA conclusions and reflect the information available at the time of the allocation. However, the Plan does not specifically identify all key policy expectations relating to each site in the “development principles” column of the H1 table. Whilst, the information which informed the site allocation process is considered to be robust and is sufficient to provide the Council with confidence that the sites are viable and deliverable in the Plan period, the inclusion of this level of detail in the Plan is not considered to be appropriate, as the exact nature of key policy requirements for H1 sites will be determined at the planning application stage, having regard to the most up to date surveys and assessments (as required by the relevant LDP policies). The purpose of the column in the Deposit Plan was to present additional information identified as necessary to make the allocation acceptable and/or key issues in respect of the site identified during discussions between the Council and site promoter. For this site it was noted that development should retain former rail line as cycle path and positively integrate with the green space area. Proposals will be expected to consider these principles, and integrate any development requirements that are highlighted, in the context of the particular circumstances that apply at the time of any future planning application, including financial viability. A MAC is proposed at the end of this document to clarify the purpose of the Development Principles column


appropriate? 3.39 The site is allocated for 180 units in the Plan. It should be noted that part of the

allocated area has outline planning permission (Ref:2006/1902). This area of the site was allocated in the UDP for 218 units based on the capacity used in the Transport Assessment. The site is allocated in the LDP covering a larger area going beyond the land with outline planning consent. However, in the absence of detailed evidence on the capacity of the additional land the site was conservatively allocated with the same capacity as the UDP allocation (218) but minus the total capacity of the areas of the site which at that time had achieved

29 ED006.7 SC Additional Info CS Process and Methodology 2017

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detailed Reserved Matters planning consent. As recorded in the annual JHLAS, construction has been ongoing at the site for 3 years and some of the earlier phases are occupied. As reported in ED006.2, 106 units now have detailed Reserved Matters planning permission (as of 10th November 2017 – see table below) and can be considered as commitments. A MAC is proposed to reflect the updated position on the planning status of the site.

3.40 It should be noted that the LDP allocated land has significant potential to

exceed the 218 capacity assumed for the land in the Deposit. Pre-application (2017/1881/PRE) correspondence has taken place with Hygrove Homes indicating that the site capacity of the land with outline planning consent could increase overall to 250 units subject to planning permission. As noted, there is further (Council owned) land within the LDP allocation boundary that is not included in the Hygrove masterplan which could yield further development. An initial feasibility layout plan has been prepared with a suggested capacity for an additional 100 residential units on top of the LDP allocation as part of a mixed use development including a family pub restaurant and a hotel.


development? 3.41 No - construction has been ongoing at the site for 3 years and some of the

earlier phases are occupied. The viability and deliverability of sites was an inherent part of the CS assessment process. The Stage 1 filtering process ensured that sites with fundamental constraints to their delivery were removed at an early stage in the process. The detailed Stage 2 CS Assessment process was informed by desk based survey data, technical study information, and consultation with both internal Council departments and external stakeholder organisations (such as NRW, DCWW). The Council engaged in dialogue with site promoters to ensure that they were aware from an early stage of the infrastructure provision and mitigation measures required. There are therefore no significant constraints or barriers to development on H1 sites, and where constraints or issues have been identified through the CS process, the Council have confirmed that mitigation measures can be implemented in accordance with Plan policies.


infrastructure requirements? 3.42 Yes – there are no major infrastructure requirements for the site. As recorded

in the annual JHLAS, construction has been ongoing at the site for 3 years and some of the earlier phases are occupied. Forecasts have therefore been set at a rate of 30 completions per annum based on rates achieved to date.


conclusions?

3.43 As recorded in the annual JHLAS, construction has been ongoing at the site for 3 years and some of the earlier phases are occupied demonstrating that the

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site is viable. A planning application for the next phase is currently under determination by the Council (2017/2441/RES).

3.44 The issue of financial viability of H1 sites is addressed in detail at Section 7 of ED006.730 which clarifies that the non-strategic sites were not subject to specific financial viability appraisal, as at the time of allocation it was considered to be overly onerous on smaller scale site promoters to require this. E006.7 states that the CS assessment process was considered to give sufficient reassurance that sites allocated in the Plan were deliverable and viable. The document highlights that SDA sites (which make up 76% of allocations) have been subject to Independent Financial Viability Appraisals. The Council is therefore able to provide very detailed, site specific evidence regarding the financial viability of the majority of development in the Plan. ED006.231 provides the up to date assurances of the delivery of all allocated sites (both Strategic and Non-Strategic), including details of the financial viability assessment carried out to support such sites.






h. Any other site specific matters 3.47 No objections received in the LDP Deposit consultation.

30 ED006.7 SC Additional Info CS Process and Methodology 6 Dec 17 31 ED006.2 SC Additional Info Phasing and Delivery 6 Dec 17 32 EB001 Affordable Housing Viability Study July 2013 33 EB002 Affordable Housing Viability Study Report May 2016

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Site H1.6 – Land at Jersey Road opposite numbers 16-38, Pentrechwyth




and 3B forms34 presented in the Appendix. Appendix 5 of the SA report35 presents a composite table of the SA scores for all allocated sites. These assessments show that the sites contribute to the objectives of the Plan and the SA objectives while any mitigation measures necessary are noted.







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appropriate? 3.51 Yes the site quantum (20) and density (28 units per hectare) and reflects the

CS assessment findings and considered to be realistic and appropriate. d. Are there any significant constraints or barriers to the site’s



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infrastructure requirements? 3.53 Yes – there are no major infrastructure requirements for the site. The site is

Council owned and considered by the Estates Department in their market assessments that the site would be ideally suited for affordable housing provision. Initial exploratory work has been undertaken in respect of design and layout and no major technical constraints have been identified that would constrain development of the site. In their planning of asset disposal, this site is expected to come forward in the medium term. The Estates Department expect a planning application to be submitted in 2021 and forecast that the 20 units would be completed in 2022/23.


conclusions? 3.54 Further to answer e, the issue of financial viability of H1 sites is addressed in

detail at Section 7 of ED006.737 which clarifies that the non-strategic sites were not subject to specific financial viability appraisal, as at the time of allocation it was considered to be overly onerous on smaller scale site promoters to require this. E006.7 states that the CS assessment process was considered to give sufficient reassurance that sites allocated in the Plan were deliverable and viable. The document highlights that SDA sites (which make up 76% of allocations) have been subject to Independent Financial Viability Appraisals. The Council is therefore able to provide very detailed, site specific evidence regarding the financial viability of the majority of development in the Plan. ED006.238 provides the up to date assurances of the delivery of all allocated sites (both Strategic and Non-Strategic), including details of the financial viability assessment carried out to support such sites. At the broader, plan wide level, the Affordable Housing Viability Study 201339 and 2016 update40 provide evidence of the overarching financial viability of development across the County, by demonstrating that residual land values are sufficient to support development whilst meeting the affordable housing contributions set out in Policy H3.

3.55 No formal financial viability appraisal has been carried out due to the need to

undertake a range of detailed site surveys coupled with cost analysis in order to properly inform any robust viability appraisal. Notwithstanding this formal position, each site has been appraised by a Chartered Surveyor working within the Council’s Strategic Estates Dept which deals directly with all the Council’s property asset disposals; this department has been bringing forward on an annual basis several million pounds of assets for sale / development, therefore the Strategic Estates team are very much in tune with the requirements of developers and the local property market in Swansea. Moreover, the Council’s More Homes Strategy illustrates the Council’s ability to bring forward


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development on its own sites and the importance of the Strategy for delivering Corporate Priorities on tacking poverty (see Appendix 1). Consequently a ‘desk top assessment’ for each site has been undertaken by Chartered Surveyors with the benefit of any identified physical site constraints and local market knowledge to form a realistic informed judgment as to likely developer demand. It should be noted the Council are probably by far the largest transactional landowner in Swansea with a database of land sales second to none. Therefore the Strategic Estates Department are well placed to undertake a desk top assessment and make an informed judgement on a site by site basis armed with experience, local knowledge and expertise.




h. Any other site specific matters 3.57 No objections received in the LDP Deposit consultation. Site H1.7 – Land at rear of 17-93 Carmel Road, Winch Wen

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a. Would the allocation contribute to the objectives of the Plan and those of the Sustainability Appraisal?

3.58 Yes – the site forms an integral element of the Plan’s Sustainable Housing











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3.61 The site does contain a SINC. As far as is viable SINC areas will be protected and where loss of SINC habitat is unavoidable mitigation will be put in place in-line with Policy ER 6.


appropriate? 3.62 Yes - the site density is quite low at 19 units per hectare but this reflects the CS

assessment findings including the need for SINC mitigation, potential requirement to incorporate open space, and that a public sewer crosses the site which requires protection.






allocated for 65 units. It is Council owned. The Estates Department expect a planning application to be submitted in 2021 and forecast that the units would be delivered at approximately 20 per annum from 2022/23 onwards. Initial exploratory work has been undertaken. This has identified that vacant possession will be required but the garage tenancies concerned can be terminated by service of notice.


conclusions?

3.65 The issue of financial viability of H1 sites is addressed in detail at Section 7 of ED006.744 which clarifies that the non-strategic sites were not subject to specific financial viability appraisal, as at the time of allocation it was considered to be overly onerous on smaller scale site promoters to require this. E006.7 states that the CS assessment process was considered to give sufficient reassurance that sites allocated in the Plan were deliverable and

44 ED006.7 SC Additional Info CS Process and Methodology 6 Dec 17

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viable. The document highlights that SDA sites (which make up 76% of allocations) have been subject to Independent Financial Viability Appraisals. The Council is therefore able to provide very detailed, site specific evidence regarding the financial viability of the majority of development in the Plan. ED006.245 provides the up to date assurances of the delivery of all allocated sites (both Strategic and Non-Strategic), including details of the financial viability assessment carried out to support such sites.




undertake a range of detailed site surveys coupled with cost analysis in order to properly inform any robust viability appraisal. Notwithstanding this formal position, each site has been appraised by a Chartered Surveyor working within the Council’s Strategic Estates Dept which deals directly with all the Council’s property asset disposals; this department has been bringing forward on an annual basis several million pounds of assets for sale / development, therefore the Strategic Estates team are very much in tune with the requirements of developers and the local property market in Swansea. Moreover, the Council’s More Homes Strategy illustrates the Council’s ability to bring forward development on its own sites and the importance of the Strategy for delivering Corporate Priorities on tacking poverty (see Appendix 1). Consequently a ‘desk top assessment’ for each site has been undertaken by Chartered Surveyors with the benefit of any identified physical site constraints and local market knowledge to form a realistic informed judgment as to likely developer demand. It should be noted the Council are probably by far the largest transactional landowner in Swansea with a database of land sales second to none. Therefore the Strategic Estates Department are well placed to undertake a desk top assessment and make an informed judgement on a site by site basis armed with experience, local knowledge and expertise.







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Site H1.8 – Land at Ty Draw Road and Llanerch Road, Bonymaen









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3.71 There are no conflicting policies and designations for this site. The Council carried out a robust CS process (as reported in ED006.750) to ensure that all allocations in the Plan were capable of complying with LDP policy requirements and designations. The CS Stage 1 filtering process ensured that sites with fundamental constraints to their delivery were removed at an early stage in the process. There are therefore no allocations which are fundamentally in conflict with LDP policies and designations. Sites which then progressed to Stage 2 of the process were subjected to the more detailed site assessment process (as set out in the CS Assessment Reports). The process identified infrastructure and mitigation measures which would be required on or off-site, or through financial contributions. The comprehensive and iterative nature of assessments undertaken by the Council on proposed sites has ensured that all the allocations in the Plan, with the exception of those identified in this statement as being affected by updated evidence, are compliant with LDP policy.




appropriate? 3.73 Yes the site density is 30 units per hectare and reflects the CS assessment

findings, including that the site is crossed by public sewers that will need to be protected and potential requirement to include open space.



assessment process. The Stage 1 filtering process ensured that sites with fundamental constraints to their delivery were removed at an early stage in the process. The detailed Stage 2 CS Assessment process was informed by desk based survey data, technical study information, and consultation with both internal Council departments and external stakeholder organisations (such as NRW, DCWW). The Council engaged in dialogue with site promoters to ensure that they were aware from an early stage of the infrastructure provision and mitigation measures required. There are therefore no significant constraints or


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barriers to development on H1 sites, and where constraints or issues have been identified through the CS process, the Council have confirmed that mitigation measures can be implemented in accordance with Plan policies.



allocated for 55 units. It is Council owned land in the Housing Department’s portfolio of land. A consultant has been commissioned to assess all of the Council's Housing Department land to inform a strategic plan for future development. The Plan will identify sites suitable for smaller scale Council self build in the short term and other larger sites with potential for mixed tenure development beyond 2020 when the Council will have greater borrowing powers and expects to procure a partner developer to build such larger sites. Initial consideration suggests that this site has potential for a larger mixed use scheme beyond 2020. Further details on timeline will become available following the consultants’ work, but estimated forecasts are provided based on the current information available with development expected to come forward by 2022/23.


conclusions? 3.76 The issue of financial viability of H1 sites is addressed in detail at Section 7 of





undertake a range of detailed site surveys coupled with cost analysis in order to


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properly inform any robust viability appraisal. Notwithstanding this formal position, each site has been appraised by a Chartered Surveyor working within the Council’s Strategic Estates Dept which deals directly with all the Council’s property asset disposals; this department has been bringing forward on an annual basis several million pounds of assets for sale / development, therefore the Strategic Estates team are very much in tune with the requirements of developers and the local property market in Swansea. Moreover, the Council’s More Homes Strategy illustrates the Council’s ability to bring forward development on its own sites and the importance of the Strategy for delivering Corporate Priorities on tacking poverty (see Appendix 1). Consequently a ‘desk top assessment’ for each site has been undertaken by Chartered Surveyors with the benefit of any identified physical site constraints and local market knowledge to form a realistic informed judgment as to likely developer demand. It should be noted the Council are probably by far the largest transactional landowner in Swansea with a database of land sales second to none. Therefore the Strategic Estates Department are well placed to undertake a desk top assessment and make an informed judgement on a site by site basis armed with experience, local knowledge and expertise.





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Site H1.9 – Land at Graigola Road, Glais








carried out a robust CS process (as reported in ED006.757) to ensure that all



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allocations in the Plan were capable of complying with LDP policy requirements and designations. The CS Stage 1 filtering process ensured that sites with fundamental constraints to their delivery were removed at an early stage in the process. There are therefore no allocations which are fundamentally in conflict with LDP policies and designations. Sites which then progressed to Stage 2 of the process were subjected to the more detailed site assessment process (as set out in the CS Assessment Reports). The process identified infrastructure and mitigation measures which would be required on or off-site, or through financial contributions. The comprehensive and iterative nature of assessments undertaken by the Council on proposed sites has ensured that all the allocations in the Plan, with the exception of those identified in this statement as being affected by updated evidence, are compliant with LDP policy.



3.84 The site does contain a SINC. As far as is viable SINC areas will be protected

and where loss of SINC habitat is unavoidable mitigation will be put in place in-line with Policy ER 6.

3.85 For all housing sites (of 10 or more) that are located within the Welsh Language

Sensitive Area (WLSA) any planning application will need to be accompanied by a Language Action Plan which sets out the measures to be taken to protect, promote and enhance the Welsh language e.g. mitigation measures such as promotion of the Welsh language as an intrinsic design element, provision of affordable housing for local needs, contributions to welsh medium school or support for language and cultural awareness initiatives.


appropriate? 3.86 Yes the site density is low at 11 units per hectare but reflects the CS

assessment findings including highway safety comments, the need to mitigate SINC impacts, potential need to provide informal accessible open space within site or adjoining site to address local deficiency, and potential requirement to provide garages for adjoining occupiers.

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allocated for 25 units. It is Council owned and considered by the Estates Department in their market assessments that there is high demand for such in-fill plots in this area. Environmental reports and other background studies are currently being undertaken with a view to marketing the site quickly after adoption of the LDP and expected sale of the land in 2019/20. A planning application is expected to be submitted in Quarter 3 2020. Development has therefore been forecasted for 2021/22.





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60 EB001 Affordable Housing Viability Study July 2013 61 EB002 Affordable Housing Viability Study Report May 2016

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Site H1.10 – Land at Tanycoed Road, Clydach




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3.97 The site does contain a SINC. As far as is viable SINC areas will be protected

and where loss of SINC habitat is unavoidable mitigation will be put in place in-line with Policy ER 6.

3.98 For all housing sites (of 10 or more) that are located within the WLSA any

planning application will need to be accompanied by a Language Action Plan which sets out the measures to be taken to protect, promote and enhance the Welsh language, e.g. mitigation measures such as promotion of the Welsh language as an intrinsic design element, provision of affordable housing for



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local needs, contributions to welsh medium school or support for language and cultural awareness initiatives.



findings including SINC mitigation and need to maintain hedgerows. d. Are there any significant constraints or barriers to the site’s





allocated for 20 units. It is Council owned and the Council Estates Department see this as a long-term development opportunity likely to come forward in the second half of the remaining Plan period. Completions have therefore been forecast for the latter part of the Plan period.



ED006.765 which clarifies that the non-strategic sites were not subject to specific financial viability appraisal, as at the time of allocation it was considered to be overly onerous on smaller scale site promoters to require this. E006.7 states that the CS assessment process was considered to give sufficient reassurance that sites allocated in the Plan were deliverable and viable. The document highlights that SDA sites (which make up 76% of allocations) have been subject to Independent Financial Viability Appraisals. The Council is therefore able to provide very detailed, site specific evidence regarding the financial viability of the majority of development in the Plan. ED006.266 provides the up to date assurances of the delivery of all allocated


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sites (both Strategic and Non-Strategic), including details of the financial viability assessment carried out to support such sites.









Deposit consultation. In response to local concerns regarding drainage, the Council responded that the site assessment process and stakeholder consultations did not highlight any specific issues with surface water flooding on the site and the site is not within an area of identified flood risk in TAN 15. However, the issues raised by the respondent relating to the culvert at Tanycoed Road are noted. Controls will be imposed at the Planning application stage to restrict the maximum rate of run off to a level no greater than greenfield run off or existing discharge rates where appropriate. If necessary


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opportunities to deliver improvements to local surface water flooding should be explored. Plan Policy RP 3 requires that sustainable drainage systems must be implemented wherever they would be effective and practicable. Development will also be encouraged to consider the provision of green infrastructure within the site as a measure to reduce surface water run-off. The Council therefore considers the site to be viable and deliverable and to accord with the Strategy of the Plan

Site H1.11 – Land at Ramsey Road, Clydach




and 3B forms69 presented in the Appendix. Appendix 5 of the SA report70 presents a composite table of the SA scores for all allocated sites. These



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assessments show that the sites contribute to the objectives of the Plan and the SA objectives while any mitigation measures necessary are noted.





3.109 The key constraints and resulting policy expectations are highlighted in the

CS reports and SA conclusions and reflect the information available at the time of the allocation. However, the Plan does not specifically identify all key policy expectations relating to each site in the “development principles” column of the H1 table. Whilst, the information which informed the site allocation process is considered to be robust and is sufficient to provide the Council with confidence that the sites are viable and deliverable in the Plan period, the inclusion of this level of detail in the Plan is not considered to be appropriate, as the exact nature of key policy requirements for H1 sites will be determined at the planning application stage, having regard to the most up to date surveys and assessments (as required by the relevant LDP policies). The purpose of the column in the Deposit Plan was to present additional information identified as necessary to make the allocation acceptable.

3.110 The site does contain a SINC. As far as is viable SINC areas will be

protected and where loss of SINC habitat is unavoidable mitigation will be put in place in-line with Policy ER 6.

3.111 For all housing sites (of 10 or more) that are located within the WLSA any

planning application will need to be accompanied by a Language Action Plan which sets out the measures to be taken to protect, promote and enhance the Welsh language e.g. mitigation measures such as promotion of the Welsh language as an intrinsic design element, provision of affordable housing for local needs, contributions to welsh medium school or support for language and cultural awareness initiatives


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assessment findings, including the need for SINC mitigation and some historic mine workings.


development? 3.113 The viability and deliverability of sites was an inherent part of the CS

assessment process including SINC designation. The Stage 1 filtering process ensured that sites with fundamental constraints to their delivery were removed at an early stage in the process. The detailed Stage 2 CS Assessment process was informed by desk based survey data, technical study information, and consultation with both internal Council departments and external stakeholder organisations (such as NRW, DCWW). The Council engaged in dialogue with site promoters to ensure that they were aware from an early stage of the infrastructure provision and mitigation measures required. There are therefore no significant constraints or barriers to development on H1 sites, and where constraints or issues have been identified through the CS process, the Council have confirmed that mitigation measures can be implemented in accordance with Plan policies.



allocated for 60 units. The two landowners have advised that they are in discussions with a major house builder to develop the site in a strategic manner. Discussions are at an early stage but represent a significant step forward and an intent to develop, therefore completions have been forecasted for 2020/21 onwards to allow time for sale of the land and planning consent to be achieved.



ED006.772 which clarifies that the non-strategic sites were not subject to specific financial viability appraisal, as at the time of allocation it was considered to be overly onerous on smaller scale site promoters to require this. E006.7 states that the CS assessment process was considered to give sufficient reassurance that sites allocated in the Plan were deliverable and viable. The document highlights that SDA sites (which make up 76% of allocations) have been subject to Independent Financial Viability Appraisals. The Council is therefore able to provide very detailed, site specific evidence

72 ED006.7 SC Additional Info CS Process and Methodology 6 Dec 17

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regarding the financial viability of the majority of development in the Plan. ED006.273 provides the up to date assurances of the delivery of all allocated sites (both Strategic and Non-Strategic), including details of the financial viability assessment carried out to support such sites.



3.117 Part of the site is an undeveloped UDP allocation but the site has been

expanded into adjoining land to increase the viability of the site in the LDP. The two landowners have advised that they are in discussions with a major house builder to develop the site in a strategic manner. The house builder is known to have explored the viability of the site. Discussions are at an early stage but represent a significant step forward and an intent to develop.







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Site H1.12 – Former Teachers Centre, Gellionen Road, Clydach

3.120 The site was allocated for 10 units in the Plan but has since been granted

planning permission under ref. 2016/1217 on 9th December 2016 for 15 units76 and the development is well under construction. A MAC is proposed to reflect that this site is now a commitment.

76 https://property.swansea.gov.uk/online-applications/files/81AA1509094C0EE0F0C99EB4959CB679/pdf/2016_1217-VERSION_4_FINAL_DECISION_NOTICE-651553.pdf

https://property.swansea.gov.uk/online-applications/files/81AA1509094C0EE0F0C99EB4959CB679/pdf/2016_1217-VERSION_4_FINAL_DECISION_NOTICE-651553.pdf

https://property.swansea.gov.uk/online-applications/files/81AA1509094C0EE0F0C99EB4959CB679/pdf/2016_1217-VERSION_4_FINAL_DECISION_NOTICE-651553.pdf

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Site H1.13 – Talycoppa farm, Llansamlet





b. Is the allocation consistent with other LDP policies and designations, and should key policy expectations be consistently identified in the ‘development principles’?





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CS reports and SA conclusions and reflect the information available at the time of the allocation. However, the Plan does not specifically identify all key policy expectations relating to each site in the “development principles” column of the H1 table. Whilst, the information which informed the site allocation process is considered to be robust and is sufficient to provide the Council with confidence that the sites are viable and deliverable in the Plan period, the inclusion of this level of detail in the Plan is not considered to be appropriate, as the exact nature of key policy requirements for H1 sites will be determined at the planning application stage, having regard to the most up to date surveys and assessments (as required by the relevant LDP policies). The purpose of the column in the Deposit Plan was to present additional information identified as necessary to make the allocation acceptable and/or key issues in respect of the site identified during discussions between the Council and site promoter. For this site it was noted for the development to maximise connections to existing community – Highways access from Maes-Yr-Haf, Maes-Lan, Tegfan and Delfan. Maintain and enhance existing hedgerow boundaries within the public realm. Outward looking development to south and east. Proposals will be expected to consider these principles, and integrate any development requirements that are highlighted, in the context of the particular circumstances that apply at the time of any future planning application, including financial viability. A MAC is proposed at the end of this document to clarify the purpose of the Development Principles column





findings.

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infrastructure requirements? 3.127 Yes – there are no major infrastructure requirements for the site. Site is

allocated for 150 units. The land owner has advised that the site is currently being marketed by Savills and several offers have been made. The landowner is in detailed negotiations with a major housebuilder and anticipates that a planning application will be made in Quarter 3 2018 following exchange of contracts and pre-application discussions. Therefore some completions have been attributed to 2019/20 in the likelihood that construction would start mid way through the year, with increased annual rates in subsequent years.





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h. Any other site specific matters 3.131 No objections received in the LDP Deposit consultation. Site H1.14 – Land adjacent to Heol Las, Birchgrove


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the Sustainability Appraisal? 3.132 At the time the Plan was published the site formed an integral element of the

Plan’s Sustainable Housing Strategy which is set out in Policy PS 3. At the Deposit stage the site was partly within Flood Zone C1 and all representations received during the statutory 6 week public consultation period on the Deposit LDP reflected this. NRW’s ‘Change Map’ highlighted that the part C1 Zone would become C2 but it did not inform the Council that the entire site would become C2 as in the latest version of the DAM. In light of the new C2 Zone on the whole of the site, in-line with National Planning Policy, it is proposed that if the site promoter is unable to demonstrate at the relevant hearing session or provide information via a statement to justify why the allocation should proceed in respect of the C2 designation then the site should not now be allocated for residential development in the Plan. No units are currently attributed to this site in the housing delivery trajectory. ED006.784 recommends that the site is reviewed and sets out the extent of the C2 flood risk which covers virtually the entire site.


3.133 See answer a). c. Is the quantum and density of dwellings on the site realistic and

appropriate? 3.134 See answer a). d. Are there any significant constraints or barriers to the site’s

development? 3.135 See answer a). e. Is the expected timescale for delivery realistic, having regard to

infrastructure requirements? 3.136 See answer a). f. Has a financial viability assessment been carried out? If so, what are its

conclusions? 3.137 See answer a).

84 ED006.5 SC Additional Info Flood Risk and Mitigation 6 Dec 17

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coming forward within the anticipated timescale? 3.138 The Plan housing supply incorporates flexibility to allow for some sites not

coming forward at the rate expected. h. Any other site specific matters. 3.139 The Council has provided full responses to the issues raised in the LDP


Site H1.15 – Land at Midland Place, Llansamlet




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assessment findings reflecting the need for SINC mitigation, water main



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crossing site requiring protection, proximity to the railway, mining legacy ground condition issues, and potential requirement to provide open space.


development? 3.145 No, the viability and deliverability of sites was an inherent part of the CS




allocated for 30 units. It is Council owned and has recently been marketed by the Estates Department who have advised that they have received substantial interest from RSLs. However, the site is also one of several that they have now earmarked for the potential to direct develop in-house following adoption of the LDP, building on the Council’s recent successful development project at Penplas. On the basis of the strong likelihood of developing in-house, the Estates Department expect a planning application to be submitted in mid 2019 and forecast that the 30 units would begin to be completed in 2020/21.





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Site H1.16 – Heol Ddu Farm, Llansamlet


the Sustainability Appraisal?

3.152 Yes – the site forms an integral element of the Plan’s Sustainable Housing Strategy which is set out in Policy PS 3. All allocations in the Plan have been appraised against both LDP objectives and SA objectives to ensure that they contribute both to the objectives underlying each of the Plan’s policies and to the objectives of achieving sustainable development. The outcome for each individual site allocation is reported in the relevant CS Report in the Stage 3A




3.153 There are no conflicting policies and designations for this site. The Council carried out a robust CS process (as reported in ED006.794) to ensure that all allocations in the Plan were capable of complying with LDP policy requirements



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3.154 The key constraints and resulting policy expectations are highlighted in the CS reports and SA conclusions and reflect the information available at the time of the allocation. However, the Plan does not specifically identify all key policy expectations relating to each site in the “development principles” column of the H1 table. Whilst, the information which informed the site allocation process is considered to be robust and is sufficient to provide the Council with confidence that the sites are viable and deliverable in the Plan period, the inclusion of this level of detail in the Plan is not considered to be appropriate, as the exact nature of key policy requirements for H1 sites will be determined at the planning application stage, having regard to the most up to date surveys and assessments (as required by the relevant LDP policies). The purpose of the column in the Deposit Plan was to present additional information identified as necessary to make the allocation acceptable.

3.155 The site is located in a Noise Action Planning Priority Area (NAPPA) and proposals will need to conform to LDP Policy RP 2.

c. Is the quantum and density of dwellings on the site realistic and appropriate?

3.156 Yes the allocated site density is low at 12 units per hectare but reflects the CS assessment findings including the NAPPA covering some of the site. The Council has undertaken positive pre-application discussions with a developer and RSL for a mixed use scheme which includes a proposal for more units than allocated in the Plan (23 units) for which a planning application has now been submitted.

d. Are there any significant constraints or barriers to the site’s development?

3.157 The viability and deliverability of sites was an inherent part of the CS assessment process. The Stage 1 filtering process ensured that sites with fundamental constraints to their delivery were removed at an early stage in the process. The detailed Stage 2 CS Assessment process was informed by desk based survey data, technical study information, and consultation with both internal Council departments and external stakeholder organisations (such as NRW, DCWW). The Council engaged in dialogue with site promoters to ensure that they were aware from an early stage of the infrastructure provision and

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mitigation measures required. There are therefore no significant constraints or barriers to development on H1 sites, and where constraints or issues have been identified through the CS process, the Council have confirmed that mitigation measures can be implemented in accordance with Plan policies.

e. Is the expected timescale for delivery realistic, having regard to infrastructure requirements?

3.158 Yes – there are no major infrastructure requirements for the site. The site is

allocated for 10 units. The Council has undertaken positive pre-application discussions with a developer and RSL for a mixed use scheme which includes a proposal for more units than allocated in the Plan. Site investigations have been undertaken and a planning application has been submitted since the publication of ED006.2 under reference 2017/2677/FUL.


conclusions? 3.159 The site is an undeveloped UDP allocation but there are clear intentions to

develop the site in the short-term so the site has been brought into the 5 year land supply and forecasted for completion in 2019/20. The site promoter has confirmed that the land and construction price are viable and within the Welsh Government’s acceptable cost guidance. The development is already included in the latest Affordable Housing (PDP) meaning that funding for the site is confirmed. The site promoter has confirmed their investigations have shown a high level of demand for homes in the Birchgrove area. Site investigations have been undertaken and a planning application has been submitted.




and 2016 update98 provide evidence of the overarching financial viability of development across the County, by demonstrating that residual land values are


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sufficient to support development whilst meeting the affordable housing contributions set out in Policy H3.





Site H1.17 – Gwernllwynchwyth House, Llansamlet




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CS reports and SA conclusions and reflect the information available at the time of the allocation. However, the Plan does not specifically identify all key policy expectations relating to each site in the “development principles” column of the H1 table. Whilst, the information which informed the site allocation process is considered to be robust and is sufficient to provide the Council with confidence that the sites are viable and deliverable in the Plan period, the inclusion of this level of detail in the Plan is not considered to be appropriate, as the exact nature of key policy requirements for H1 sites will be determined at the planning application stage, having regard to the most up to date surveys and assessments (as required by the relevant LDP policies). The purpose of the column in the Deposit Plan was to present additional information identified as necessary to make the allocation acceptable and/or key issues in respect of the site identified during discussions between the Council and site promoter. For this site it was noted that development should preserve the setting of the adjacent scheduled ancient monument. Proposals will be expected to consider these principles, and integrate any development requirements that are highlighted, in the context of the particular circumstances that apply at the time of any future planning application, including financial viability. A MAC is proposed at the end of this document to clarify the purpose of the Development Principles column



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3.167 The site does contain a SINC. As far as is viable SINC areas will be protected and where loss of SINC habitat is unavoidable mitigation will be put in place in-line with Policy ER 6.

3.168 The site is located in a Noise Action Planning Priority Area (NAPPA) and

proposals will need to conform to LDP Policy RP 2. c. Is the quantum and density of dwellings on the site realistic and


findings, including the need for SINC and NAPPA mitigation, and need to incorporate shared use path and preserve the setting of the adjacent scheduled ancient monument.






allocated for 50 units. The landowner is in detailed discussions with a local developer and anticipates bringing the site forward for development in the short term with a planning application expected to be submitted in early 2018. A scheme and layout has been drawn up for a mix of 2, 3, 4 and 5 bedroom units with due regard for the ancient monument. Work is underway on a comprehensive drainage strategy for the site, while tree and ecology surveys have been undertaken. On the basis of the developer intentions, the development has been forecasted to start on site in late 2018/19 with an anticipated delivery of 15 units per annum. Site investigations are currently being undertaken and a planning application is expected to be submitted imminently. The site is an undeveloped UDP allocation but there are clear intentions to develop the site in the short-term so the site has been brought into the 5 year land supply and forecasted for completion in 2019/20.

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f. Has a financial viability assessment been carried out? If so, what are its conclusions?





3.174 The landowner is in detailed discussions with a local developer and

anticipates bringing the site forward for development in the short term. g. What are the implications of the site and/or supporting infrastructure not






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Site H1.18 – Land at Fredrick Place, Llansamlet





106 http://www.swansea.gov.uk/article/27770/Candidate-site-register-2016---allocated-

sites 107 LDP09a SA Report Appendix 5 (June 2016)



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appropriate? 3.181 Yes the site density is very low at just 6 units per hectare but reflects the CS

assessment findings to reflect the need for SINC mitigation, potential provision of ANGS, ground conditions including mining legacy, and proximity to the tunnel.


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allocated for 20 units. It is Council owned land and the Estates Department have advised that technical studies (mining and environmental) have been completed and they expect to sell the site as one of their priority asset disposals. A private developer scheme has already been drafted and initial consultations held with national land sales agents, but no agent has been appointed yet as further investigation works are required prior to marketing which are ongoing. Site is expected to attract interest from small/ medium developers, possibly local. To allow time for the sale of the land, a planning application would be expected by Quarter 1 2020 and completions forecasted for 2021/22.





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Deposit consultation. Please see the Deposit Consultation Report (Core Document LDP17) for the Council’s responses to the concerns raised regarding potential traffic, flood risk, school and health care facility capacity, and ecology impacts.


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Site H1.19 – Former Four Seasons Club, Trallwn

3.189 The site is allocated for 30 units but has since been granted planning

permission for 41 units under reference 2016/1510 on 14th June 2017113. A MAC is proposed at the end of this document to reflect that the site is now a commitment.

113 https://property.swansea.gov.uk/online-applications/files/BC9D16F241A8718F8A0C4295759010E3/pdf/2016_1510-FINAL_DECISION_NOTICE_V3-699722.pdf

https://property.swansea.gov.uk/online-applications/files/BC9D16F241A8718F8A0C4295759010E3/pdf/2016_1510-FINAL_DECISION_NOTICE_V3-699722.pdf

https://property.swansea.gov.uk/online-applications/files/BC9D16F241A8718F8A0C4295759010E3/pdf/2016_1510-FINAL_DECISION_NOTICE_V3-699722.pdf

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Site H1.20 – Land at David Williams Terrace, Port Tennant


the Sustainability Appraisal? 3.190Yes – the site forms an integral element of the Plan’s Sustainable Housing








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appropriate? 3.194 Yes the site density is fairly low at 19 units per hectare but reflects the CS

assessment findings in terms of the need for SINC mitigation, sloping nature of the site and need to incorporate the existing access track diagonally crossing the site and protection measures for the water main crossing the site.



assessment process. The Stage 1 filtering process ensured that sites with fundamental constraints to their delivery were removed at an early stage in the process. The detailed Stage 2 CS Assessment process was informed by desk based survey data, technical study information, and consultation with both internal Council departments and external stakeholder organisations (such as NRW, DCWW). The Council engaged in dialogue with site promoters to ensure that they were aware from an early stage of the infrastructure provision and mitigation measures required. There are therefore no significant constraints or

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barriers to development on H1 sites, and where constraints or issues have been identified through the CS process, the Council have confirmed that mitigation measures can be implemented in accordance with Plan policies.


infrastructure requirements? 3.196 Yes – there are no major infrastructure requirements for the site. Site is

allocated in the Plan for 15 units. It is Council owned land in the Housing Department’s portfolio of land. A consultant has been commissioned to assess all of the Council's Housing Department land to inform a strategic plan for future development. The Plan will identify sites suitable for smaller scale Council self build in the short term and other larger sites with potential for mixed tenure development beyond 2020. This site has potential for a small scale Council self build scheme and is expected to come forward at the later end of the Plan period. Further details on timeline will become available following the consultants’ work, but estimated forecasts are provided based on the current information available with completions forecasted in 2024/25.







undertake a range of detailed site surveys coupled with cost analysis in order to properly inform any robust viability appraisal. Notwithstanding this formal position, each site has been appraised by a Chartered Surveyor working within


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the Council’s Strategic Estates Dept which deals directly with all the Council’s property asset disposals; this department has been bringing forward on an annual basis several million pounds of assets for sale / development, therefore the Strategic Estates team are very much in tune with the requirements of developers and the local property market in Swansea. Moreover, the Council’s More Homes Strategy illustrates the Council’s ability to bring forward development on its own sites and the importance of the Strategy for delivering Corporate Priorities on tacking poverty (see Appendix 1). Consequently a ‘desk top assessment’ for each site has been undertaken by Chartered Surveyors with the benefit of any identified physical site constraints and local market knowledge to form a realistic informed judgment as to likely developer demand. It should be noted the Council are probably by far the largest transactional landowner in Swansea with a database of land sales second to none. Therefore the Strategic Estates Department are well placed to undertake a desk top assessment and make an informed judgement on a site by site basis armed with experience, local knowledge and expertise.






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West SHPZ Site H1.51 – Former Eastmoor Nursery, Chestnut Avenue, West Cross

3.202 The land is allocated in the Plan for 20 units. Since the Deposit, outline

planning permission has been granted for 5 units on the entire site under reference 2015/2334 on 19th July 2016, and a full planning application is being determined for 5 units under reference 2017/2550/FUL.

3.203 Therefore no contribution from the site has been attributed in the ED006.2

large site schedule since the 5 units would be counted in the forecasts for small site build, and a MAC change is proposed to amend the H1 site schedule to remove this site from the Plan.

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LDP Policy H 5 Sites H5.1 – Land at Monksland Road, Scurlage


the Sustainability Appraisal? 3.204 Yes – the allocation of the site, forms an integral element of the Plan’s

Sustainable Housing Strategy which is set out in Policy PS 3. Arising from Action Points from Examination Hearing Sessions 3 and 4, the Council are working to submit a statement to clarify that H5 sites are allocated to provide housing to meet specific local housing needs for market housing, in accordance with PPW para 9.2.4. As a consequence, the Council consider that it is more appropriate that the site is included within the settlement boundary of Scurlage. The Council’s statement in response to the Action Points will be submitted to the examination by 5th March and will be discussed at a further Hearing Session on 20th March.

3.205 All allocations in the Plan have been appraised against both LDP objectives and SA objectives to ensure that they contribute both to the objectives underlying each of the Plan’s policies and to the objectives of achieving sustainable development. The outcome for each individual site allocation is

reported in the relevant CS Report in the Stage 3A and 3B forms121 presented

121 http://www.swansea.gov.uk/article/27770/Candidate-site-register-2016---allocated-sites


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in the Appendix. Appendix 5 of the SA report122 presents a composite table of the SA scores for all allocated sites. These assessments show that the sites contribute to the objectives of the Plan and the SA objectives while any mitigation measures necessary are noted.

3.206 Deposit Representations highlighted that the Plan contains a draughting error in relation to the boundary of H5:1. The Deposit Plan allocates the candidate site as originally submitted and consulted upon. However, an amended site allocation area was presented to Planning Committee on the 11th June 2015 which excluded part of field parcel 1973 (to reflect the fact that the development permitted in field parcel 3074 to the north west of the candidate site has not removed the possibility of a through road to link the two sites, as originally envisaged). A Matters Arising Change is therefore proposed to amend Inset Map 16 as set out in NSA 116 to clarify the correct boundary of H5.1 is the boundary publicised prior to the Deposit and agreed by Council in September 2015 (which ensures the site follows logical, established field boundaries and excludes the triangle of land from field parcel 1973). The map above shows both the Deposit and proposed amended site boundary.






CS reports and SA conclusions and reflect the information available at the time of the allocation. However, the “development principles” column in Policy H1 is not replicated in the table of allocations in Policy H5 and the Plan does not specifically identify all key policy expectations relating to each H1 site in the “development principles” column of the H1 table. Whilst, the information which informed the site allocation process is considered to be robust and is sufficient to provide the Council with confidence that the sites are viable and deliverable

122 LDP09a SA Report Appendix 5 (June 2016) 123 ED006.7 SC Additional Info CS Process and Methodology 2017

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in the Plan period, the inclusion of this level of detail in the Plan is not considered to be appropriate, as the exact nature of key policy requirements for H5 sites will be determined at the planning application stage, having regard to the most up to date surveys and assessments (as required by the relevant LDP policies).

3.209 Policy H5 allocations pursue an innovative policy approach which seeks to

allocate sites for market housing for local needs, in accordance with PPW para 9.2.4. The Policy requirements relating to the local occupancy restrictions are proposed for inclusion new Appendix 7 to clearly set out the local occupancy criteria to be applied (see MAC proposed in Hearing Statement 4).

3.210 The site is located within the Gower AONB, and whilst the AONB designation

does not preclude development, the design of the development must be in accordance with Gower AONB Design Guide (SPG003) and Policy HC1 with regard to the protection of Historic Landscapes.


appropriate? 3.211 Yes, the site density is fairly low at 15 dwellings per hectare, but this reflects

the location within the Gower AONB, and the candidate site assessment which highlights that the site is crossed by a water main and an easement or diversion will therefore be required.





infrastructure requirements? 3.213 There are no major infrastructure requirements for the site which would affect

current estimated delivery forecasts. It is Council owned in the Housing Department’s portfolio of land. A consultant has been commissioned to assess all of the Council's Housing Department land to inform a strategic plan for future development. The Plan will identify sites suitable for smaller scale Council self-build in the short term and other larger sites with potential for mixed tenure

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development beyond 2020 when the Council will have greater borrowing powers and expects to procure a partner developer to build such larger sites.

3.214 Initial consideration suggests that this site has potential for a small scale

Council self-build scheme and is expected to come forward as one of the first priority development sites. Further details on timeline will become available following the consultants’ work, but estimated forecasts are provided based on the current information available with development expected to come forward by 2020/21.


conclusions? 3.215 ED006.2 relating to Phasing and Delivery provides the up to date assurances

of the delivery of all allocated sites (both Strategic and Non-Strategic). This is supported by ED006.7 which explains that the CS assessment process is considered to give sufficient reassurance that specific sites allocated in the plan are deliverable and viable. At the broader, plan wide level, the Affordable Housing Viability Study 2016 update (Core document EB002124) specifically tested the viability of the H5 Policy requirement to provide a minimum of 51% affordable housing for local needs, and 49% market housing for local needs. The study concludes that in the sub-market areas where the H5 sites are located, the residual values are sufficiently to support the percentage of affordable housing and local needs market housing proposed by the Policy.

3.216 No formal financial viability appraisal has been carried out due to the need to undertake a range of detailed site surveys coupled with cost analysis in order to properly inform any robust viability appraisal. Notwithstanding this formal position, each site has been appraised by a Chartered Surveyor working within the Council’s Strategic Estates Dept which deals directly with all the Council’s property asset disposals; this department has been bringing forward on an annual basis several million pounds of assets for sale / development, therefore the Strategic Estates team are very much in tune with the requirements of developers and the local property market in Swansea. Moreover, the Council’s More Homes Strategy illustrates the Council’s ability to bring forward development on its own sites and the importance of the Strategy for delivering Corporate Priorities on tacking poverty (see Appendix 1). Consequently a ‘desk top assessment’ for each site has been undertaken by Chartered Surveyors with the benefit of any identified physical site constraints and local market knowledge to form a realistic informed judgment as to likely developer demand. It should be noted the Council are probably by far the largest transactional landowner in Swansea with a database of land sales second to none. Therefore the Strategic Estates Department are well placed to undertake a desk top assessment and make an informed judgement on a site by site basis armed with experience, local knowledge and expertise.

124 EB002 Affordable Housing Viability Study Report May 2016 (PDF, 1MB)

https://www.swansea.gov.uk/media/17637/Affordable-Housing-Viability-Study-Report-May-2016/pdf/Affordable_Housing_Viability_Study_Report_May_2016.pdf

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housing supply incorporates flexibility to allow for some sites not coming forward at the rate expected

h. Would each H5 allocation address an identified need?

3.218 The Council consider that the H5 allocation will meet both an identified need for Affordable Housing for Local Need and also for Market Housing to address local social and economic needs. As a result of Action Points arising from discussion at Examination Hearing Sessions 3 and 4, the Council are currently working with ORS (the consultants responsible for the Council’s Local Housing Market Assessment) and will produce further evidence of the social and economic needs of the local population to support the allocation of housing to meet local needs within the Gower, Gower Fringe and West Strategic Housing Policy Zones. This further evidence will be submitted by 5th March and will be discussed at further Hearing Session to be held on 20th March.

i. Any other site-specific matters. 3.219 The Council has provided full responses to the issues raised in the LDP


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Site H5.2 – Land to the east of Gowerton Road



Sustainable Housing Strategy which is set out in Policy PS 3. Arising from Action Points from Examination Hearing Sessions 3 and 4, the Council are working to submit a statement to clarify that H5 sites are allocated to provide housing to meet specific local housing needs for market housing, in accordance with PPW para 9.2.4. As a consequence, the Council consider that it is more appropriate that the site is included within the settlement boundary of Three Crosses. The Council’s statement in response to the Action Points will be submitted to the examination by 5th March and will be discussed at a further Hearing Session on 20th March.

3.221 A Matters Arising Change is proposed to amend Inset Map 18 as set out in NSA117 to correct draughting error raised by Deposit Representations, which highlighted that the boundary of H5:2, as shown on the Deposit Plan Proposals Map indicated a larger site for allocation than was approved for inclusion in the Deposit by the Council on the 24th September 2015. An amendment to the site boundary is therefore recommended to clarify the correct and originally intended boundary of the allocation (as shown on the map above). The Site Promoter has confirmed support for the proposed MAC.

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reported in the relevant CS Report in the Stage 3A and 3B forms125 presented in the Appendix. Appendix 5 of the SA report126 presents a composite table of the SA scores for all allocated sites. These assessments show that the sites contribute to the objectives of the Plan and the SA objectives while any mitigation measures necessary are noted.






CS reports and SA conclusions and reflect the information available at the time of the allocation. However, the “development principles” column in Policy H1 is not replicated in the table of allocations in Policy H5 and the Plan does not specifically identify all key policy expectations relating to each H1 site in the “development principles” column of the H1 table. Whilst, the information which informed the site allocation process is considered to be robust and is sufficient to provide the Council with confidence that the sites are viable and deliverable in the Plan period, the inclusion of this level of detail in the Plan is not considered to be appropriate, as the exact nature of key policy requirements for H5 sites will be determined at the planning application stage, having regard to the most up to date surveys and assessments (as required by the relevant LDP policies).


allocate sites for market housing for local needs, in accordance with PPW para 9.2.4. The Policy requirements relating to the local occupancy restrictions are



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proposed for inclusion new Appendix 7 to clearly set out the local occupancy criteria to be applied (see MAC proposed in Hearing Statement 4).


appropriate? 3.226 Yes, the site density is fairly low at 13 dwellings per hectare, but this reflects

the candidate site assessment which highlights that the site is crossed by a water main and an easement or diversion will therefore be required.





infrastructure requirements? 3.228 There is a developer/RSL partnership involved with this site. The site

appraisal is being concluded with a view to resolving a deal for the land with the vendor. Detailed discussions are currently ongoing with the developer with regard to progressing towards the preparation and submission of a planning application in late 2018 following adoption of the Plan. The site has therefore been forecasted for development in mid to late 2019/20. There are no major infrastructure requirements for the site which would affect current estimated delivery forecasts.


conclusions?

3.229 ED006.2 relating to Phasing and Delivery provides the up to date assurances of the delivery of all allocated sites (both Strategic and Non-Strategic). This is supported by ED006.7 which explains that the CS assessment process is considered to give sufficient reassurance that specific sites allocated in the plan are deliverable and viable. At the broader, plan wide level, the Affordable Housing Viability Study 2016 update (Core document EB002128) specifically tested the viability of the H5 Policy requirement to provide a minimum of 51%



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affordable housing for local needs, and 49% market housing for local needs. The study concludes that in the sub-market areas where the H5 sites are located, the residual values are sufficiently to support the percentage of affordable housing and local needs market housing proposed by the Policy.

3.230 The site promoter has undertaken ecological, transport and historic mining

assessments which all conclude that the development is deliverable g. What are the implications of the site and/or supporting infrastructure not





i. Any other site-specific matter 3.233 The Council has provided full responses to the issues raised in the LDP


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Site H5.3 – Land adjoining Tirmynydd Road, Three Crosses



Sustainable Housing Strategy which is set out in Policy PS 3. Arising from Action Points from Examination Hearing Sessions 3 and 4, the Council are working to submit a statement to clarify that H5 sites are allocated to provide housing to meet specific local housing needs for market housing, in accordance with PPW para 9.2.4. As a consequence, the Council consider that it is more appropriate that the site is included within the settlement boundary of Three Crosses. Such a change would not affect the boundary of the allocation or the extent of the land included within the plan for development. The Council’s statement in response to the Action Points will be submitted to the examination by 5th March and will be discussed at a further Hearing Session on 20th March.





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c. Is the quantum and density of dwellings on the site realistic and appropriate?

3.239 Yes, the site density is fairly low at 14 dwellings per hectare, but this reflects

candidate site assessment which highlights that the site is crossed by a public sewer and an easement or diversion will therefore be required, and that a PROW crosses the southern section of the site which would need to be accommodated into the layout of the development. There is also a mining legacy on the site which, subject to further assessments may also need to be accommodated in the layout.





infrastructure requirements? 3.241 A developer has the benefit of an option to purchase the land that is outside of

their ownership. A preliminary viability study has been carried out which incorporated the 51% affordable requirement. Under the terms of the option the developer has to submit an application within 12 months of the LDP adoption. Allowing 12 months for a planning decision they have advised that they would expect to complete the scheme within a further 18 months so the completions have been forecasted for 2021/22.



of the delivery of all allocated sites (both Strategic and Non-Strategic). This is supported by ED006.7 which explains that the CS assessment process is considered to give sufficient reassurance that specific sites allocated in the plan are deliverable and viable. At the broader, plan wide level, the Affordable Housing Viability Study 2016 update (Core document EB002132) specifically tested the viability of the H5 Policy requirement to provide a minimum of 51%



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affordable housing for local needs, and 49% market housing for local needs. The study concludes that in the sub-market areas where the H5 sites are located, the residual values are sufficiently to support the percentage of affordable housing and local needs market housing proposed by the Policy.

3.243 ED006.2 Phasing & Delivery indicates that the site promoter has also carried

out a preliminary viability study to test the viability of Policy H5 affordable housing and local needs requirements.








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Site H5.4 – Land adjoining Pennard Drive, Pennard



Sustainable Housing Strategy which is set out in Policy PS 3. Arising from Action Points from Examination Hearing Sessions 3 and 4, the Council are working to submit a statement to clarify that H5 sites are allocated to provide housing to meet specific local housing needs for market housing, in accordance with PPW para 9.2.4. As a consequence, the Council consider that it is more appropriate that the site is included within the settlement boundary of Pennard. Such a change would not affect the boundary of the allocation boundary or the extent of the land included within the plan for development. The Council’s statement in response to the Action Points will be submitted to the examination by 5th March and will be discussed at a further Hearing Session on 20th March.





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does not preclude development, the design of the development must be in accordance with Gower AONB Design Guide (SPG003) and Policy HC1 with regard to the protection of Historic Landscapes.


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appropriate? 3.253 Yes, the site 2.2ha and is considered to have a capacity of 60 units (in

ED006.2 Phasing and Delivery document) which would be a density of 27 d.p.ha. Access to PROW network would need to be retained.






current estimated delivery forecasts. Coastal Housing have submitted a pre-application for a scheme for 73 dwellings which is fully compliant with the requirements of Policy H5. See 2018/0112/PRE Land North Of Pennard Road And East Of Pennard Drive. The site layout plan and extracts of the planning statement are attached as an Appendix to Hearing Statement 4.

3.256 ED006.2 Phasing and Delivery document indicates that the planning agents

for the site promoter have stated that a planning application will be submitted soon after adoption of the LDP and expected in Quarter 3 2018. On this basis completions have been forecasted to come forward from late 2019/20.



of the delivery of all allocated sites (both Strategic and Non-Strategic). This is supported by ED006.7 which explains that the CS assessment process is considered to give sufficient reassurance that specific sites allocated in the plan are deliverable and viable. At the broader, plan wide level, the Affordable Housing Viability Study 2016 update (Core document EB002136) specifically



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tested the viability of the H5 Policy requirement to provide a minimum of 51% affordable housing for local needs, and 49% market housing for local needs. The study concludes that in the sub-market areas where the H5 sites are located, the residual values are sufficiently to support the percentage of affordable housing and local needs market housing proposed by the Policy.

3.258 ED006.2 Phasing and Delivery indicates that, as part of the land acquisition

process, development costs have been established via a full suite of feasibility works which formed the basis for negotiations. In addition, market research has been done to establish values and saleability for the market elements.








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Site H5.5 – Land at Summerland Lane, Newton



Sustainable Housing Strategy which is set out in Policy PS 3. Arising from Action Points from Examination Hearing Sessions 3 and 4, the Council are working to submit a statement to clarify that H5 sites are allocated to provide housing to meet specific local housing needs for market housing, in accordance with PPW para 9.2.4. As a consequence, the Council consider that it is more appropriate that the site is included within the settlement boundary of Newton. Such a change would not affect the boundary of the allocation boundary or the extent of the land included within the plan for development. The Council’s statement in response to the Action Points will be submitted to the Examination by 5th March and will be discussed at a further Hearing Session on 20th March





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3.266 The Council consider that the H5 allocation will meet both an identified need for Affordable Housing for Local Need and also for Market Housing to address local social and economic needs. As a result of Action Points arising from discussion at Examination Hearing Sessions 3 and 4, the Council are currently working with ORS (the consultants responsible for the Council’s Local Housing Market Assessment) and will produce further evidence of the social and economic needs of the local population to support the allocation of housing to meet local needs within the Gower, Gower Fringe and West Strategic Housing Policy Zones. This further evidence will be submitted by


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5th March and will be discussed at further Hearing Session to be held on 20th March.


appropriate? 3.267 The site is 2.6 ha and is considered to have a capacity of 60 units (in ED006.2

Phasing and Delivery document), which is a density of 23 d.p.ha. 3.268 Developer, Westacres in partnership with RSL, Pobl, submitted a full planning

application (2017/1948/FUL) (Full Application) on the site for 61 dwellings, which was fully compliant with the requirements of Policy H5 comprising of 31 Affordable Local Needs dwellings and 30 market local needs dwellings.

3.269 The Council resolved to approve the application, subject to s106, at Planning

Committee on 9th January 2018. All documents associated with the application can be viewed on the Council’s planning application search web pages. Planning Committee Minutes can be viewed on the Council’s main webpage. A decision notice will be issued once the S106 has been signed. The site layout plan has been submitted as an Appendix to Hearing Statement 4 for information.




3.271 Application 2017/1947/FUL has been approved subject to the signing of s106

Agreement and will deliver a package of measures to address identified constraints and provide any mitigation required.



current estimated delivery forecasts. ED006.2 indicates that, pending the signing of the s106 and issuing of the decision notice being achieved in early 2018, the development is expected to be completed in late 2019/20.

https://property.swansea.gov.uk/online-applications/applicationDetails.do?activeTab=documents&keyVal=OVLZ9SEVL8G00

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f. Has a financial viability assessment been carried out? If so, what are its conclusions?

3.273 ED006.2 relating to Phasing and Delivery provides the up to date assurances

of the delivery of all allocated sites (both Strategic and Non-Strategic). This is supported by ED006.7 which explains that the CS assessment process is considered to give sufficient reassurance that specific sites allocated in the plan are deliverable and viable. At the broader, plan wide level, the Affordable Housing Viability Study 2016 update (Core document EB002140) specifically tested the viability of the H5 Policy requirement to provide a minimum of 51% affordable housing for local needs, and 49% market housing for local needs. The study concludes that in the sub-market areas where the H5 sites are located, the residual values are sufficiently to support the percentage of affordable housing and local needs market housing proposed by the Policy.

3.274 Application 2017/1947/FUL has been approved subject to the signing of s106

Agreement which will deliver a package of requirements which are fully compliant with policy requirements.






i. Any other site-specific matters 3.277 The Council has provided full responses to the issues raised in the LDP




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Site H5.6 – Land at Higher Lane, Langland



Sustainable Housing Strategy which is set out in Policy PS 3. Arising from Action Points from Examination Hearing Sessions 3 and 4, the Council are working to submit a statement to clarify that H5 sites are allocated to provide housing to meet specific local housing needs for market housing, in accordance with PPW para 9.2.4. As a consequence, the Council consider that it is more appropriate that the site is included within the settlement boundary of Langland. Such a change would not affect the boundary of the allocation boundary or the extent of the land included within the plan for development. The Council’s statement in response to the Action Points will be submitted to the examination by 5th March and will be discussed at a further Hearing Session on 20th March.


reported in the relevant CS Report in the Stage 3A and 3B forms141 presented in the Appendix. Appendix 5 of the SA report142 presents a composite table of



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the SA scores for all allocated sites. These assessments show that the sites contribute to the objectives of the Plan and the SA objectives while any mitigation measures necessary are noted.










does not preclude development, the design of the development must be in accordance with Gower AONB Design Guide (SPG003) and Policy HC1 with regard to the protection of Historic Landscapes. The Candidate Site Report highlights that the development would need to retain the mature boundary


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treatment and rural lane along the western boundary to minimise landscape impact.


appropriate? 3.284 The site is 1.2 ha and is considered to have a capacity of 30 units (in ED006.2

Phasing and Delivery document) which would achieve a density of 25 d.p.ha. Retain PROW access through site





infrastructure requirements? 3.286 Developer, Edenstone Homes have submitted a pre-application

(2017/2628/PRE) for 47 which is fully compliant with the policy requirements of Policy H5, comprising of 24 Affordable Local Needs dwellings, 23 Market Local Needs dwellings. The pre-application is currently being considered by the Council and can be viewed on the Council’s website via the planning application search function. Information relating to the Pre-Application submission has also been submitted to the examination on behalf of Edenstone Homes. The Planning Agent for the site has indicated in that subject to the progression of the pre-application, that a planning application would come forward promptly, and subject to planning consent, that the site would be built by mid 2019/20.



of the delivery of all allocated sites (both Strategic and Non-Strategic). This is supported by ED006.7 which explains that the CS assessment process is considered to give sufficient reassurance that specific sites allocated in the plan are deliverable and viable. At the broader, plan wide level, the Affordable

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Housing Viability Study 2016 update (Core document EB002144) specifically tested the viability of the H5 Policy requirement to provide a minimum of 51% affordable housing for local needs, and 49% market housing for local needs. The study concludes that in the sub-market areas where the H5 sites are located, the residual values are sufficiently to support the percentage of affordable housing and local needs market housing proposed by the Policy.

3.288 ED006.2 indicates that Initial reports dealing with ecology, visual impact and

transportation have all been undertaken, with each concluding that the scheme is deliverable in an appropriate and acceptable manner.





3.290 The Council consider that the H5 allocation will meet both an identified need for Affordable Housing for Local Need and also for Market Housing to address local social and economic needs. As a result of Action Points arising from discussion at Examination Hearing Sessions 3 and 4, the Council are currently working with ORS (the consultants responsible for the Local Council’s Housing Market Assessment) and will produce further evidence of the social and economic needs of the local population to support the allocation of housing to meet local needs within the Gower, Gower Fringe and West Strategic Housing Policy Zones. This further evidence will be submitted by 5th March and will be discussed at further Hearing Session to be held on 20th March.

i. Any other site-specific matters 3.291 The Council has provided full responses to the issues raised in the LDP


4 0 Monitoring Framework

a. Does the monitoring framework include clear targets/milestones for the delivery of housing and necessary infrastructure for the H 1 and H 5 site allocations?

4.1 The monitoring framework is set out in Section 4.2 of the Deposit and in-line

with the Local Development Plan Regulation 37, the following indicator has been included and a trigger point identified where action may be required:



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- The number of net additional affordable and general market dwellings built in the Plan area (TAN 2).

4.2 The Deposit acknowledges that effective policy implementation will be a key

factor in determining how successful the Plan will be in achieving the Strategic Objectives. In relation to new housing development, where delivery will need to occur throughout the Plan period, it is highlighted that it will be important to ensure that delivery remains on track to achieve the Policy aims throughout the Plan period. In this case, the monitoring framework sets out that missing one target would represent an opportunity to assess the Policy to establish the causes of the lower than anticipated level of performance. However, missing a further target would significantly impact on the ability of the Plan to achieve its stated aims and objectives and require a review of that particular Policy.

4.3 This monitoring indicator will be supplemented by the related indicator on

housing land supply. 4.4 The Deposit proposes that an Annual Monitoring Report (AMR) will be

prepared. This will identify any Policy that is not being implemented in the anticipated manner. It will outline steps that will be taken to address the issues identified and any required revisions to the Plan to replace or amend the Policy. The AMR will provide an assessment of whether the underlying Plan Strategy remains sound, the impact of Policies at the local and wider level and whether Policies and related targets have been met or progress is being made towards meeting them.

b. If the sites and necessary infrastructure do not come forward as

anticipated, is the framework clear about what action should be taken, such as an expedited plan revision, if necessary?

4.5 The Council will work with Welsh Government to identify a comprehensive set

of monitoring indicators in line with the actions arising out of hearing sessions. 5.0 Proposed Matters Arising Changes (MACs) 5.1 The Council’s schedule of ‘Non-substantive amendments’145 to the Deposit

Plan included changes that relate to matters addressed in this response (specifically in relation to NSA 42, 116 and 117). The Council considers that these amendments should be considered at the appropriate hearing session, and therefore these amendments are included within the table of ‘Proposed Matters Arising Changes (MACs)’ below.

5.2 Non-substantive amendments have been proposed to the Inset Maps to correct

draughting errors relating to Inset Map 16 Scurlage [NSA116], and Inset Map 18 Three Crosses [NSA117].

145 LDP20 Schedule of Non-Substantive Amendments to Swansea Deposit LDP 2017

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5.3 In addition to the following proposed MACs, the Council recognises that further issues may arise from the hearing sessions, for example, further informatives to be included in the H 1 Table Development Principles column.

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Hearing Statement Question

Deposit LDP Section

Deposit Rep Ref

Proposed MAC Reason/Justification Origin of MAC

3 Table H1 NA Note that the following sites now have planning permission: H1. 2 H1. 5 H1. 12 H1. 19 H1. 51

To update the planning status of sites

NSA 42 (and updated)

3b Para 2.5.1 after policy H1

44821 Propose adding the following at end of paragraph 2.5.1 after policy H1 that states: ‘The policy highlights Development Principles that are relevant to certain sites, which are intended to make developers and site promoters aware of some of the key issues that proposals will need to address. Proposals will be expected to consider these principles, and integrate any development requirements that are highlighted, in the context of the particular circumstances that apply at the time of any future planning application, including financial viability.’

It is considered useful to include additional supporting text to the policy to refer to the Development Principles and their intended purpose

This statement

Inset Map 16: Scurlage

43890, 43892, 43896, 45062

Amend Inset Map 16 to clarify the correct boundary of the allocation at Site H5.1 Land at Monksland Road, Scurlage as agreed by Council [as illustrated below]:

To correct a draughting error and accurately reflect the boundary of the allocation, as per the original submission by the site proposer and as publicised prior to the Deposit and agreed by Council in 2015.

NSA117

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Hearing Statement Question

Deposit LDP Section

Deposit Rep Ref Proposed MAC Reason/Justification Origin of MAC

Inset Map 18: Three Crosses

45492, 45940, 45938, 45936, 45934, 45932, 45930, 45928, 45925, 44159, 45941, 45939, 45937, 45935, 45933, 45931, 45929, 45927, 44225

Amend Inset Map 18 with regards the boundary of Rural Exception Site H5.2 Land to the east of Gowerton Road, Three Crosses to accurately reflect the delineation of the site boundary as illustrated below.

To correct a draughting error and accurately reflect the boundary of the allocation, as per the original submission by the site proposer and as publicised prior to the Deposit and agreed by Council in 2015.

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Appendix 1: More Homes Strategy Following national changes to the Housing Revenue Account Subsidy System (HRAS), which allow Councils to retain the full value of their housing stock rental income therefore providing more financial resources, the Council is developing a strategy for delivering more Council homes. This is known as the More Homes Strategy. A pilot scheme of 18 units has already been delivered at Milford Way, Penplas in 2017/18; while a further scheme at Parc Yr Helig, off Ffordd y Bryn, Birchgrove has planning permission for 16 units and is expected to be delivered over the next 2 years. The progress achieved to date illustrates that the Council is in a position to bring forward development on its own sites, and the More Homes Strategy forms an integral element of the Council’s Corporate Priority and well-being objective to tackle poverty. Source:

Swansea Local Housing Strategy 2015 – 2020

Delivering a Successful & Sustainable Swansea. The City and County of Swansea’s Corporate Plan 2017/22

swansea ldp examination statement of swansea council · 2018-02-13 · 1 | p a g e swansea ldp...

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