In writing the Local Development Plan, PCNPA identified sites that were assessed to be suitable to be “housing allocations” (HAs)
In Newport, a Landscape Capacity Study commissioned by PCNPA concluded that there was only one suitable site for this purpose which was numbered 220 – Caravan Park Parrog Road – and even there the Study clearly stated that the development opportunity was limited to “small scale residential only”
“Alternative sites” put forward during the development of the LDP included those suggested by Newport Town Council, including the fields either side of the main road by Richards Bros Garage and a field opposite the Memorial Hall – all of which would allow safe pedestrian access into the centre of town, but all of these were turned down
The main part of what was then numbered site 825 – Land North of Feidr Eglwys – was put forward by another party at this point
All sites were the subject of sustainability assessments. For site 825 it was decided that the density of houses would need to be restricted to ensure that it did not harm the character of the area but that the number could be increased to 12 if small affordable units were included – from 8 under normal circumstances; that additional and significant planting within the site would be necessary to contribute to the existing character of the setting of the town; that the density of vegetation would need to be increased especially on the east side to blend into woodland at the Church; that one or one and a half storey buildings could be accommodated within the context of surrounding properties.
PCC Highways responded that “Access is achievable but will require the setting back of existing hedgebank. A maximum of 20 dwellings should be developed on this site and the site opposite (ref 824)”
A supplementary comment by Dyfed Archaeological Trust that –
The site should not be allocated until there has been an assessment of the potential resource. In the first instance a site visit should be made
– appears not to have been heeded.
The conclusion of the sustainability assessment included
Plan policy to secure as much affordable housing as can be achieved and is needed, as opposed to general needs housing, will help ensure development aims to meet the needs of local communities.
When the Caravan Park owners refused for their land to be used, site 825 became the main focus of the National Park Developments team’s interest
The Deposit Plan went through an Inquiry Stage under Mr Juniper
When he wrote his report, he rejected the caravan site as a non-starter and accepted land which had been put forward by the owners of 825 (Alt 1056 and 1057) and allowed these plots to be added to and included under the “Housing Allocation” HA825. At the same time the Inspector upped the number of houses from 12 to 20 in table 7 in the LDP but forgot to alter Appendix 2 which set out reasoned justification for 12 houses
The proportion of affordable housing based on local needs’ assessment was set at 70% in LDP policy 45
The PCNPA LDP was adopted in 2010
In the following years “Annual Monitoring Reports” (AMRs) of the LDP revealed that sufficient numbers of houses were not being built within the Park to meet targets. (Newport Area Environment Group was one of a handful of non-statutory organisations that has ever commented on these AMRs and stated that the 70% proportion should not change because of our alarming demographic imbalance and proportion of second homes here)
Put simply, this was put down to the proportions of affordable housing required in the LDP making developments not worthwhile for owners.
The PCNPA solution was to reduce those percentages drastically – from 70% to 40% for Newport for instance – but instead of conducting a review of the LDP to rewrite policy 45, the Authority consulted on a revised Supplementary Planning Guidance (SPG) for Affordable Housing in draft which they had prepared in consultation with “key stakeholders”, and giving changed percentages.
Presumably Newport Town Council was consulted at each stage in that they would have been sent the relevant documents
Some Newport residents read the consultation draft of this SPG but failed to gather that this percentage change was written in to this, and felt they were falsely reassured by officers who said there was no policy change. Those residents therefore did not comment.
The Authority announced that the consultation document was to be used “for development management purposes” immediately, that is from July 2014, but the document was not adopted until November 2014.
The PCNPA announced on its website that
” work has been undertaken, with the help of key stakeholders, to provide guidance on the way in which the local planning process might be enhanced so that an increased supply of affordable housing can be achieved.
The Authority’s approach has been revised to provide: a greater return for the developer with the type of affordable housing that can be built on site; an update to date appraisal of how much affordable housing can be delivered on sites and through contributions in the current economic climate; A more streamlined application process.”
BDOG is arguing that in determining applications, PCNPA must still follow the policies in the LDP Furthermore, that the reasoned justification as set out for this site in Appendix 2 in the LDP must be heeded.
We are also arguing that the statements made in the background papers to the LDP, as detailed above, and by the LDP Inspector, which impact on this site, are material planning considerations. Harries Design seems to have taken very little notice of these indeed.
It is claimed by Harries Design that discussions with Statutory Consultees on the application have “informed development of the scheme from its inception”. Also that “Extensive pre-application (sic) has taken place …within the community…” But the first anybody realised this was happening was on receipt of the PCNPA’s letter inviting observations with 3 weeks to respond…