Swansea Local Development Plan 1 | L D P I n i t i a l C o ... · Penrice Community Council * As long as it does not sterilise the existing system (planning blight). The Unitary Development

1 | L D P I n i t i a l C o n s u l t a t i o n R e p o r t ( J u l y 2 0 1 6 )

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ansea Local Developm

ent Plan

Appendices to the City & County of Swansea Local Development Plan Initial Consultation Report


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Appendix 1

Delivery Agreement Consultation Details

The questionnaire consisted of a number of specific questions relating to the DA Timetable and Community Involvement Scheme (CIS). Out of 402 consultations sent 32 responses were received by the end of the consultation period. Of these 25 were questionnaires with the remainder formal letters. Details of the representations received together with the Council’s response and proposed action points are presented in the Table below:

Question 1 Is the explanation of the various featur es and stages of the LDP preparation process set ou t in Sections 1.0 to 8.0 and Appendix 7 of the Draft DA sufficien tly clear?

Consultee Name Comment Response

Swansea University

Swansea University (SU) is pleased to see the Council's commitment to "participation" from the outset of the LDP process and the specific focus on stakeholder and community engagement.

SU understands the Council's intention to reuse stakeholder responses from the various strategies as identified on page 5. However, this should not preclude the opportunity for stakeholders to make further representations if considered appropriate for the specific strategy in question. The situation may arise where although issues overlap, a specific more detailed response is necessary.

Although the Delivery Agreement refers to the sharing of consultation resources and exercise, this is in order to improve consistency and avoid duplication. It is not intended to substitute consultation at any stage of the LDP preparation process.


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Question 2 Do you consider the timetable for LDP pr eparation as set out in Section 10.0 and Appendices 1 and 2 of the Draft DA to be realistic and deliverable?


Bishopston Community Council

More time required in which to make informed observations/comments.

The LDP preparation is a four year process and therefore the timetable for preparation is very tight. The DA aims to pre-warn all stakeholders in advance about when various consultations will take place and at which stage of the LDP process. It is expected that stakeholders vary meeting cycles accordingly to accommodate the LDP framework.

Gower Society Challenging but possible. Comment noted. Llangyfelach Community Council

Yes, but do not consider 6 weeks sufficient to alter or make further representations on the Deposit Plan. It is noted that provision is made in the DA timetable for the cycle of Council meetings. It is required that similar provision is made for Community Council consultation i.e. during July (dependant on when the monthly meeting is held) and August (when all Community Councils are in recess until September). Therefore documents sent for consultation must allow sufficient time for Community Council Members to see and obtain a Council resolution.

Six weeks is the statutory period required for consultation. All stakeholders will be notified in advance of the consultation period in order for sufficient arrangements to be made for co-ordinating a response. Due to the already tight timescale of LDP production and the number of proposed consultations involved, it is not possible to extend the length of this consultation. It is expected that groups and Councils vary their meeting cycles accordingly.

Mumbles Community Council

1. a) Preparation of strategic options

b) Assess options through SA*1

c) Preparation of pre-deposit proposals

The time scale for the LDP is much shorter than the preparation times for previous development plans. The purpose of the DA and more specifically the timetable is to ensure that everything is taken in to account and that each


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'The above had bracket around them and pointed to following' Time scale very tight and liable to slippage which will have a knock on effect.

2. Assess Options - approximately 2 months allowed, including Christmas and new year. Has account been taken of this?

stage of the plan preparation process is allocated enough time. It is expected that groups and Councils vary their meeting cycles accordingly.

The timetable for the LDP plan preparation is being reviewed as part of this consultation process and will take in to account periods which run over the Christmas break and Council summer recess.

Penrice Community Council

* As long as it does not sterilise the existing system (planning blight).

The Unitary Development Plan (UDP) for Swansea was adopted in November 2008. The UDP covers the period from 2001 – 2016 and will remain in place for guiding development across the County until the LDP is adopted. The preparation of the LDP will not have a negative effect on the existing planning system. At no point will the County be without an adopted development plan.

The African Friendship Association

Please try to review submission LDP to WAG date if possible before 2013, by 2012.

Swansea’s Unitary Development Plan was adopted in November 2008 and will cover the period of plan preparation until the LDP is in place. The timescale for the preparation of the LDP is already shorter than the preparation times for previous development plans, on average 4 – 5 years, and it would be unrealistic to bring the submission date forward to 2012.


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Question 3 Do you consider the resources/funding co mmitted to this project, as set out in Section 11. 0 of the Draft DA to be adequate?



Full time dedicated staff should be used. The LDP will be delivered by staff in the Planning Policy Team, some of whom work part-time, as indicated in the DA. The LDP will be the team’s priority over the next 5 years but there will also be other areas of work which also require the team’s input and this has been accounted for.

Glamorgan-Gwent Archaeological Trust

There does not appear to be a clear assessment of the cost of the SEA/SA process, it is unlikely that this can be achieved to the appropriate level along with evidence gathering and plan preparation as part of the £60,000 per annum budget for 2010 to 2013. It is suggested that realistic costs for doing the SEA/SA work in house should be found out from Caerphilly CBC who have recently completed SEA/SA for their LDP in-house.

The SA was completed in-house for the UDP and staff have been trained in the process. Therefore we anticipate that staff will be able to provide a positive contribution towards the SA/SEA process. The budget included in the DA does not include staff-time; this has been covered and accounted for.

Gower Society I have no way to judge this. Presumably the officer time is not included in this figure? Nor the accommodation overheads etc.? The LPA are already hard-pressed-it is not easy to see how an officer will allocate part of his/her time to the LDP if/when urgent planning problems demand priority.

The LDP will be delivered by staff in the Planning Policy Team, some of whom work part-time, as indicated in the DA. The LDP will be the team’s priority over the next 5 years but there will also be other areas of work which also require the team’s input and this has been accounted for.


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Mumbles Community Council

Number and approximate costs of external consultants not indicated.

Past experience indicates that this is likely to be more expensive than allowed for in the budget.

At this stage of the LDP process the number of consultants needed for the process or indeed at which stages in unknown. However, where ever possible the work will be done in-house. Where consultants are engaged throughout the process staff will also be trained and skilled up themselves. Resources have been allocated for evidence gathering and consultancy fees.


* As long as the existing system does not suffer. The Unitary Development Plan (UDP) for Swansea was adopted in November 2008. The UDP covers the period from 2001 – 2016 and will remain in place for guiding development across the County until the LDP is adopted. The preparation of the LDP will not have a negative effect on the existing planning system. At no point will the County be without an adopted development plan.

Question 4 Are there additional risks to the delive ry of the LDP besides those set out in Section 12.0 of the Draft DA?


Dwr Cymru/Welsh Water

Where engagement with key stakeholders is necessary to obtain relevant information then a reasonable time needs to be allowed

The mitigation section highlights a need to improve consultation. The Council appreciates the demands on key stakeholders who are often contributing to a number of service areas. We are looking to improve our working relationship


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with stakeholders through ensuring early and advanced notice of when input is required throughout the preparation process.

Gower Society Not as far as we can see. Comment noted.

Swansea University

Table 4 sets out the Risks, Impact and potential mitigation measures in relation to delivering the LDP timetable. Risk 4 related to late objections or information from stakeholders. In this respect SU welcome the Council's proposed mitigation measures which seek to improve liaison procedures with key stakeholders. Early liaison and engagement with key stakeholders, like SU, is vital to the successful delivery of the LDP and it is therefore imperative that this is recognised through the Delivery Agreement (DA), any delay in such consultation would clearly result in additional risks to the preparation of the LDP.

The University are a key stakeholder and will be fully involved in the LDP process from the outset. Point 4 in Table 4 identifies that this scenario has been considered and that appropriate mitigation measures have been identified.

The Environment Centre/Swansea Environmental Forum

Time is not the most important element - important everyone is consulted and the plan is not rushed.

Comments noted.

Question 5 Are the objectives and opportunities for community involvement at the key stages of LDP preparation as set out in Sections 15.0 to 17.0 and Appendix 3 of the Draft DA clear and appropriate?



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We would remind your authority that water & sewerage undertakers are classed as 'specific consultation bodies' and not as general consultation body [sic] as identified within this Delivery Agreement. Water and sewerage infrastructure is an essential component of modern day living and is a fundamental pre-requisite of a development occurring. As the statutory water and sewerage undertaker of your Local Authority area we are keen to play a pro-active role in the delivery of your LDP.

The Council welcomes this commitment to providing a pro-active role in the development of the LDP and recognise the importance of water and sewerage infrastructure. The Council can also confirm that you are classed as a ‘specific consultation body and the DA will be amended accordingly.

Environment Agency

We welcome the opportunity for an early and proactive involvement at each key stage of the LDP process. We would ask for sufficient notification of dates for meetings.

As a statutory consultee you will be continually involved and sufficient notification dates will be provided.

Llangyfelach Community Council

Yes, but note that The Community Council request that in respect of Table 6 (5) ‘Transparency’ that the Community Council is consulted in respect of all proposals in the Llangyfelach area and areas adjacent to the Llangyfelach ward.

Throughout the LDP process there will be opportunities for the Community Council to raise and consider local issues and proposals. However, the LDP is a strategic document, and any proposals within the Llangyfelach area must be considered in a County-wide context.

Llwchwr Town Council

Section 16.6 refers to consultation bodies including "and appropriate community/town councils". The implication in this statement is that not all will be consulted only those "deemed" appropriate. The section as it stands has the potential to exclude community interest, by deeming them "not appropriate". Why not just delete the words "and

The reference to appropriate refers to Community and Town Councils outside of the County. For clarification, the word ‘appropriate’ will be removed from section 16.6.


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appropriate" and rely on the integrity of appendix 6.

Swansea University

SU agree that community involvement from the outset of the LDP process will be beneficial to both the council and local community. The benefits highlighted at Table 5 are welcomed.

The objectives for community involvement set out at table 6 are also fully welcomed by SU.

From Appendix 3 it is apparent that, although general consultation bodies are involved throughout the preparation of the LDP, the associated Strategic Environmental Assessment (SEA), is to be undertaken with little or no involvement from the general consultation bodies. SU consider this approach to be inappropriate and would wish this to be amended to enable consultation on the SEA with all the stakeholders.

The consultation process follows the regulations set within the legislative framework. Stage 1 of the LDP and SA/SEA involves statutory bodies for plan preparation and evidence gathering and subsequent stages involve more widespread consultation with all interested parties.

Question 6 Are the proposed methods of community in volvement and consultation as set out in Sections 2 0.0 to 22.0 of the Draft DA clear and appropriate?



Need to include intention to make a formal response to all consulted.

The Council will acknowledge all representations received. Findings will be reported to Council and will be available from the Civic Centre and on the website. Consultees


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are advised to refer to the website throughout the Plan preparation process. This will help to avoid the duplication of responses, timetable slippage and will assist with progressing the LDP.

Environment Agency

Stakeholder meetings/groups at the early stages of the LDP process would be a useful exercise.

The timetable, illustrated in Appendix 1, includes ‘Early Participation and Involvement’ at the start of Stage 2, Early Participation and Consultation.

Gower Society It will continue, nonetheless, to be difficult to engage all groups, however positive the intention.

It is a difficult to engage all groups. However, it is our intention to ensure various groups are invited to get involved and to raise awareness of the opportunities that are available. Throughout the process we are hoping to encourage consultees to come forward and inform us of appropriate and preferred methods of consultation.


Although section 20.1 sets out a wide range of methods to involve the community. Does the authority know which methods are the best for the individual communities or will all methods be used at the same time. [sic]

Is the Better Swansea Partnership representative of the community? My Council has not had any involvement with this organisation for some considerable time and it is not clear how it is

The Council are working with stakeholders to identify their preferred methods, these will be revisited and revised throughout the process.


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functioning or representing the community.


* Articles in free newspaper are more likely to be read than public notices.

Public notices are a statutory requirement throughout the LDP. These will be supplemented by press releases and other forms of publicity.

Swansea University

The proposed methods of community involvement set out in section 20 are considered appropriate.

Comment noted.


I do not believe the general public are very aware of the community plan - so the use of the same process may not reach the majority. Attendance at community events and information in plain English making it obvious why this is of importance will be key to the success of this element.

Methods will be revised as we are informed throughout the process, we are seeking to engage the hard to reach groups and will not necessarily be using the same processes as the Community Strategy.

Question 7 Do you consid er the proposed scrutiny arrangements and expected stakeholder contributions as set out in Sections 18.0 and 19.0 of the Draft DA adequate and acceptable?


Environment Agency

Timescales for required responses should be clearly highlighted on any enquires and consultations.

Comment noted.

Llangyfelach No, if a cross party Advisory Panel of City Councillors Terms of reference for the Advisory Panel are


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Community Council

is established will the public be able to attend (i.e. a representative from the Community Council) to listen to & obtain copies of any reports presented by officers to the Panel? Llangyfelach CC would send an observer to such meetings, especially if it affected the Llangyfelach area.

currently being considered and will be published on the LDP website once agreed. It is expected that the Panel will be a non decision making internal steering group of officers and Members dealing with administrative procedures and processes relating to improving plan preparation. Issues of policy relating to specific areas would be dealt with through public workshops, exhibitions, etc at which Community Councils would be expected to play a lead role. It should be noted that for some local planning authorities the Community Councils have taken the lead role on LDP consultation within their area. This is an issue to be explored with Community Council representatives in due course.


If the plan has to be reported to 8 Overview and Scrutiny Boards it will take too long too make any progress. An Advisory Panel to cover the interests of all boards is essential if any progress is to be made.

In relation to the Stakeholder contributions the Council will need to have regard to, Town and Community Council Committee cycles in determining response times. In addition most councils do not meet in August of any year.

Terms of reference are currently being established and will be published on the website and available from the Civic Centre in due course.

Penrice Community

* As long as councils includes community and town councils.

Community and Town Councils have an integral part to play throughout the LDP process and


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Council have been identified within Appendix 6 List of Consultees.


Important not just council employees and big developers involved. Community involvement needed here too.

The Community Involvement Scheme set out in Part Three of the Delivery Agreement clearly outlines how community involvement will be considered and planned for throughout the preparation, alteration and review stages of the LDP. Government regulations prescribe minimum consultation standards that the Council must meet, including specific bodies that must be consulted. The aim of the Delivery Agreement is to exceed these standards wherever possible, so as to reach more people and organisations than have previously been involved in plan making. It is recognised that different sectors of the community have different values and needs and this will influence the way in which Council seeks to reach all those who need and want to be involved, including those who are the hardest to reach.

Question 8 Can you identify any additional statutor y, specifi c and general consultation bodies to those listed i n Appendix 6?


Bishopston Community

Nothing ticked. MEP's ANOB [sic]. There is no specific AONB group available but various groups are represented in the list of key


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Council stakeholders.


Please ensure that DCWW are classed as a specific consultation body.

Comment noted, DA updated.

Gower Heritage Centre

Barham Centre, Community Centre, Mill Buildings, Swansea SA3 2EH.


Gower Society The Civic Trust for Wales (a national/regional body) Comment noted, DA updated.


Yes. Add: The Society of Local Council Clerks.

N.B. Appendix 6 is incorrect Community Councils are Statutory Consultees under the Land Compensation Act 2004.

Addition noted and DA updated accordingly.

In accordance with Local Development Plan Wales 2005 and the Town and Country Planning (Local Development Plan) (Wales) Regulations 2005 the consultees for LDPs are defined as specific and general consultation bodies. Appendix 6 has been amended to take this into account by deleting the reference to statutory consultees and defining Community Councils as specific consultation bodies.


The Council has identified a number of sports and recreation clubs which have an interest in land use such as the Ramblers and other walking clubs but have not had regard to any other uses such as those which are water based i.e. Mumbles Yacht Club, Loughor Boating Club, Mumbles Rowing Club. There are likely to be others. Similarly Langland Bay Developments Ltd may have interest not currently

Comments noted, DA updated.


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covered by either individual organisations or special interest groups.

National Grid National Grid Supports the Delivery Agreement Identification of National Grid as a specific consultation body within Appendix 6.


Penllergare Trust Penllergare Trust (See 1st Page)

Welsh Historic Gardens Trust



Duke of Beaufort Estate

Penrice Estate


Swansea University

SU is pleased to be listed in Appendix 6 as a consultation body. However, it should be recognised that SU is a significant and important stakeholder and has specific interest in the future development within the City of Swansea. SU is one of the three largest employers in the City and has a profile that extends outside the City on a national/international scale. In order for the University to retain its current premier status and in order to consolidate co-ordinated future growth, it is vitally important that a clear and flexible land use policy framework is established through the LDP, which can best assist the University in these terms.

SU wish to be accorded a highlighted and strategic consultee position in the plan process, that its

Comment noted.


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significant stakeholder role would reflect.


Swansea Environmental (al - underlined) Forum – pls [sic] correct this, Swansea Waste Forum, Swansea Environmental Education Forum.


Tourism Swansea Bay

Gower Future Farmers, T Beynon, Nicholaston Farm, Nicholaston, Gower



Welsh Historic Garden Trust. Comment noted, DA updated.

Question 9 Are there any other representations you wish to make about the Draft DA or issues you would particularly wish to become involved with during th e preparation of the LDP?



To be consulted and to request services, in attendance at an agreed Community Council meetings of a planner.

Community and Town Councils will be consulted throughout the LDP process. Given the already tight timescales identified within the Delivery Agreement it may not necessarily be feasible to attend individual meetings given the need for consultees to be grouped. In order to make efficient use of resources the consultation process requires a more streamlined organisation which avoids the duplication of information. In order to ensure an effective use of resources the Council will arrange


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consultation and training events at appropriate stages of the LDP preparation process. Section 19.0 of the DA outlines Stakeholder contributions in more detail.

Defence Estates This application is outside of any MoD safeguarding and will not be of concern. However, we would like to continue to be consulted.

Comments noted.

Environment Agency

No further comment on draft DA. However, we would welcome the opportunity to become involved in any projects undertaken to help inform the LDP, for example the preparation of any strategic flood consequence assessments (SFCAs).

Comments welcomed. The Environment Agency will be involved throughout the LDP preparation process.


GGAT as the archaeological advisors to the City and County of Swansea are able to assist in the preparation of the LDP, especially in regard to the implications of proposals that will have an impact on the Historic Environment. We have considerable experience in assisting LPAs with the production of LDPs currently working on 11 such documents and in particular we can assist you with the SEA/SA process.

Comments welcomed.

Gorseinon Town Council

Gorseinon Town Council is particularly interested in the preparation of a Town plan as an input into LDP.

Comment noted as an issue for consideration during the LDP preparation process.

Gower Heritage Centre

Tourism Issues.

P [sic]

Comment noted.


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Gower Society No other representations and while we would take an interest in the whole process, the particular concerns will be with the rural areas and the AONB.

Comment noted.


(1) The Community Council wish to be involved in all matters relating to the Llangyfelach area (in respect of any matters) of all adjoining areas which might have an effect on the Llangyfelach area.

(2) The Community Council request that a representative of the Planning Department address the next Council meeting, to be held on 2nd July 2009, in respect of the Draft Delivery Plan.

Throughout the LDP process there will be opportunities for groups to raise local issues. However, the LDP is a strategic document, therefore it is important that more generic county-wide issues are not overlooked. Given the already tight timescales identified within the Delivery Agreement it may not necessarily be feasible to attend individual meetings. In order to ensure an effective use of resources the Council will arrange consultation and training events at appropriate stages of the LDP preparation process.


My town Council is very keen to ensure it is involved in all stages of the development of the LDP.

Community and Town Councils have an integral part to play throughout the LDP process and have been identified within Appendix 6 List of Consultees. Involvement will be considered and planned for throughout the preparation, alteration and review stages of the LDP.

National Grid National Grid request that they are adequately consulted, and that the assets/operating procedures and practices of National Grid are considered, during the formational of all planning policies. Please see covering letter for more information.

The National Grid will be consulted throughout the LDP preparation.

The African To raise awareness of black and minority community Comment noted as an issue for consideration


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Friendship Association

group. throughout the LDP preparation process. We welcome suggestions for how this can be received.

Tourism Swansea Bay

Business Development.

Tourism.

Comment noted.


The Welsh Historic Gardens Trust would particularly wish to be become involved in issues concerning the protection, conservation and enhancement of the historic landscape.

Comment noted.

Action Points from letters received:

Consultee Point Response

Countryside Council for Wales

2.1 (e) Policy Context. We recommend that reference is also made in this section to the cross boundary work that is undertaken by authorities and the LDPs’ of adjacent authorities that will need to be taken into consideration during the preparation of the Swansea LDP.

To be added

3.0 Key Stages of the LDP Process. Stage 1 Delivery Agreement (CIS and Timetable). Whilst we note the summary of the scope of the DA is based on an extract from the WAG LDP Manual, the publication of which preceded the legislative requirement to undertake

To be added


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Habitat Regulations Assessment (HRA), the extract should be updated to include a reference to HRA and the management of that process.

Figure 1: Local Development Plan Preparation Process Diagram. The central box of the diagram also needs to make reference to the HRA process.

To be added

5.0 Habitats Regulations Assessment. Please note there may also be European Sites outside he Swansea area that are linked indirectly e.g. river SAC’s [sic] through water supply issues.

To be added

Page 10 Fig. 2 Relationship between the various LDP preparation processes. A link is required between the Figure 2: HRA process ‘Assess preferred strategic options and candidate sites against HRA criteria for potential impacts on Natura 2000 sites’ and the LDP process ‘Identify and test strategic options’.

To be added

Page 10 Fig. 2 With regards to stage 6 in the LDP process, the Inspector’s Report, it is CCW’s understanding that as the Inspector’s report will be binding on the authority, that HRA will need to have been taken for all options and sites under consideration before the Examination of the plan. There should not therefore be a requirement to undertake HRA in the light of the Inspector’s Report as indicated in the flow diagram.

To be added


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Welsh Assembly Government

Preface: About this document

It is suggested in this opening section that you make reference to the availability of the Welsh Assembly Government’s LDP Guidance - Planning Your Community: A guide to LDPs.

To be added

2.0 The LDP Process

Section 2(e) considers the policy context, identifying the national policy context. Suggest mentioning that there is no need to repeat national policy, but local discretion is possible where supported by robust evidence.

To be added

6.0 The Candidate Site Process

Suggest that you provide a timescale for the submission of candidate sites. It is also suggested that you specify that the candidate sites process does not represent a commitment on the part of the Council to take sites forward into the LDP.

To be added

7.0 Supplementary Planning Guidance (SPG)

Suggest further comment is made on consultation processes for SPG, and that you check that the community involvement scheme (CIS) protocols are applicable to SPG production. If not, insert any necessary stages or procedures, as paragraph 5.3 of LDP Wales makes it clear that SPG should be

To be added


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prepared in accordance with the authority's CIS. I would encourage you to consider what SPG is likely to be needed and when.

8.0 Independent examination

This section clearly outlines the driver behind the LDP system is soundness and the tests for soundness. Suggest that reference to soundness source documents, namely PINS Guide to the Examination of Local Development Plans, & the Assembly’s LDPWales.

To be added

10.0 Timetable

It is assumed that you will be contacting the Planning Inspectorate to check your indicative timetable

To be added

The scheduled start date for work to commence on the LDP is August 2010, which is 15 months in the future. The reasons for this delay in commencing work on the LDP should be provided.

To be added

The statutory consultation periods need to be set out clearly for the consultees and members of the public to understand. It is suggested that Table 2 should identify the months during which consultation is planned to take place.

To be added

16.7 Hard to Reach Groups, page 20. To be added


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It is encouraging to see the planned engagement with sectors of the community who have traditionally found it difficult to engage with the planning process. There is no specific reference made in 16.7 to engaging with Gypsies and Travellers which are traditionally a hard to reach group, although I note Appendix 6 lists the Gypsy and Traveller Law Reform Coalition and The Gypsy Council as general consultation bodies.

Petitions

No mention is made of how the LPA will deal with petitions.

To be added

Appendix 2 LDP Key Stages and Actions

Clarify why is there a reference to ‘Update and produce new SPGs’ under stage 1 Delivery Agreement.

To be added

Appendix 6 List of Statutory, Specific and General Consultation Bodies

Local Development Plans Wales 2005 and The Town and Country Planning (Local Development Plan) (Wales) Regulations 2005 define the consultees for LDPs as Specific and General Consultation Bodies. It is suggested that Appendix 6 is amended to follow this convention by deleting reference to Statutory Consultees and ensure all the relevant consultees are listed under the appropriate heading. Amendments will

To be added


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also need to be made to section 16.

Consultation Report

A consultation report will need to be prepared based on this consultation exercise to be included or cross referred to in the final Delivery Agreement.

To be added

No DA self-assessment has been provided – this is required at DA submission (LDP Manual 4.6.1 & Annex B)

To be added

Theatres Trust As a statutory consulteee for planning applications concerning theatres we are disappointed not to be included in the list of Consultation Bodies in Appendix 6 but support your Delivery Agreement.

To be added

We suggest that contact details for any person or group wanting to join the consultation database be added within Part 3 Community Involvement as a separate paragraph along the lines of :

LDP consultation database

The City and County of Swansea has a database of individuals and organisations that wish to be involved including local businesses, residents’ associations, voluntary groups, government bodies and individuals. If you would like to join the LDP consultation database and be kept up-to-date on the new development plans for Swansea please contact us

To be added


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using the details below. Please also contact us if you are already on the LDP consultation database and want to change your details or be removed.


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Appendix 2

Candidate Site Consultation Details

Consultation Methods:

o Councillor Involvement

• Endorsed by Planning Committee 2nd September 2010.

• Councillors were sent an email 17th September 2010 regarding Local Development Plan – Candidate Site Process.

o Publicity

Online

• The LDP web page provided coverage and a link to dedicated Candidate Site pages

• The LDP pages were featured on the Council front page (www.swansea.gov.uk)

• Dedicated pages for the Candidate Sites consultation on the Planning Policy Pages of the Council website www.swansea.gov.uk/ldpcandidatesites

• The JDi e-consultation website was used http://swansea.jdi-consult.net/ldp/

• The consultation was signposted on the Swansea Consultation Partnership Database: http://www.swanseaconsultationpartnership.org.uk/

• Press release:

� Consultation due on city’s draft guidebook for planning (09/07/12) http://www.swansea.gov.uk/index.cfm?articleid=49991

In print

• These press releases generated 1 article (post 9thnov2010) in the local newspaper the Evening Post from date to date NB may be outside consultation period

• Details of the consultation and the LDP process were featured in a article in the Swansea Leader.

• LDP Newsletters Summer 2011 and Spring 2012.

• Network 50+ newsletter included LDP article Spring 2011.


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• Community Regeneration Unit Newsletter Issue 2 hosted an LDP article Spring 2011 – 29th March 2011.

At Council venues

• Consultation appeared on the TV screens in the Contact Centre.

• Bilingual full display in the Civic Centre reception September 2010 – March 2011.

• Posters and feedback forms sent out to the County’s 17 Libraries.

• Posters sent out to community session venues.

Direct contact with Consultees

• Emails and letters to consultees on the LDP e-consultation service.

• Presentation on LDP and Candidate Sites for Community Councillors was held 2nd December 2010.

• Notifications sent to Councillors (dated 21st December 2010).

• 3 Community Sessions took place between 17th January and 24th January 2011.

• Email to all community regeneration contacts (also forwarded to environmental contacts by Swansea Environment Centre) – 1st February 2011

• Email reminder to all consultees and Councillors 7th March 2011.

Results of Consultation

Document

Respondents

Objectors

Support

Object

Comment

Representations

CS Register

10372 9835 3902

37438

370 41723

CS Assessment Methodology

10 6 1 12 10 23

Totals 10380 9840 3903

(9.4%)

37450

(89.7%)

380

(0.9%)

41746


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Summary of Representations

Within each Candidate Site Assessment form are summaries of representations made during this consultation period and each subsequent period. The candidate site assessment forms can be found via: www.swansea.gov.uk/LDPPA


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Appendix 3

Vision, Objectives & Strategic Options Consultation Details



• Presented to the LDP Member Advisory Group 2nd July, 2012.

• Endorsed by Planning Committee 12th July, 2012.

• Councillors were sent an email & letter (dated 23rd July, 2012) regarding the consultation and community involvement sessions.

o Publicity

Online

• The LDP web page provided coverage and a link to dedicated VOSO pages


• Dedicated pages for the VOSO consultation on the Planning Policy Pages of the Council website (www.swansea.gov.uk/ldpvoso .

• The JDi e-consultation website was used http://swansea.jdi-consult.net/ldp/ and during the consultation period (23/07/12 – 2/10/12) the site registered 2,834 unique visitors.

• The consultation was signposted on the Swansea Consultation Partnership Database: http://www.swanseaconsultationpartnership.org.uk/

• PR team press releases:

� Consultation due on city’s draft guidebook for planning (09/07/12) http://www.swansea.gov.uk/index.cfm?articleid=49991

� Communities give up their secrets for the Local Development Plan (24/07/12) http://www.swansea.gov.uk/index.cfm?articleid=50229

� Residents have their say on LDP at community events next month (30/08/12) http://www.swansea.gov.uk/index.cfm?articleid=50795

� Residents have their say on LDP at community events this month (06/09/12) http://www.swansea.gov.uk/index.cfm?articleid=50965


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� Local Development Plan gets more scrutiny this week (19/09/12) http://www.swansea.gov.uk/index.cfm?articleid=51189

� Last call for views on latest stage of plan (27/09/12) http://www.swansea.gov.uk/index.cfm?articleid=51351

� Last chance to have your say on latest round of LDP consultation (04/10/12) http://www.swansea.gov.uk/index.cfm?articleid=51507

In print

• These press releases generated 14 articles in the local newspaper the Evening Post from 07/07/12 to 11/10/12.

• Details of the consultation and the LDP process were featured in a half page article in the September 2012 edition of the Swansea Leader.

• Bilingual full display in the Civic Centre reception.

• LDP Newsletter.

• At Council venues Consultation appeared on the TV screens in the Contact Centre.





• Notifications sent to Councillors and Community Councils via email/letter (dated 23rd July, 2012).

• 8 Community Sessions 10th September to 27th September 2012.

Community Sessions

The Planning Policy Team arranged 8 sessions across the County to enable members of the public to speak to Officers about the VOSO. Copies of the VOSO documents were made available to view.

Materials were also provided for members of the public to take away that included:

• LDP Newsletter 5

• Info Sheet 2.

• Consultation Forms.


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• The Delivery Agreement.

• LDP Ward Profiles summaries.

• LDP process leaflets.

• Welsh Government LDP guide booklets.

Results of Consultation:

Document

Respondents

Objectors

Support

Object

Comment

Representations

Vision and Objectives

102 0 10 0 103 113

Strategic Options

159 5 2 5 166 172

Total 166 5 12 5 269 286

Assessment Outputs

Sustainability Appraisal/Strategic Environmental Assessment

The Sustainability Appraisal (SA) of the draft vision and draft objectives of the Swansea LDP was undertaken in December 2011 and January 2012. The process involved testing the draft vision and objectives against the SA framework to determine whether the principles of sustainable development had been fully embedded in this initial stage in the LDP preparation. A crucial part of the process involved recommending appropriate changes leading to increased promotion of sustainable development.

Overall, subject to suggested amendments, it was considered that the draft vision and objectives would promote sustainable development. An amended version of the draft Vision and draft Objectives, which took into account suggested amendments as a result of the SA, were subjected to public consultation from the 23rd July 2012 to the 12th October 2012. Any further amendments to the Vision and Objectives, if they result in a significant effect on the environment, will need to be subject to further SA.

The full report is available via: http://www.swansea.gov.uk/media/pdf/g/4/SA_Report_Visionobjectives_(2)_(3).pdf

Habitats Regulations Assessment

The deposit LDP will be subject to a full Habitats Regulations Assessment (HRA) in accordance with the regulations. It is good practice to ensure that the requirements of the regulations, and the potential effects on


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European Sites, are considered as an iterative process from the earliest stages of the plan making process. For this reason a preliminary screening of the LDP draft Vision and Objectives and the Strategic Growth Options has been carried out.

For the Vision and Objectives no negative effect is anticipated mainly because no development could occur through the policy itself, the development being implemented through later policy or the policy relates to design or other qualitative criteria or the policy is intended to protect natural environment.

For the Strategic Growth Options eight potential effects have been identified and these have been used to assess the potential areas for growth. The assessment identified several high risk areas, all of which have been identified because of issues surrounding the discharge of waste water, for which possible mitigation measures are potentially available.

Information on the HRA can be found via: http://www.swansea.gov.uk/ldphra

Summary of Representations and Actions arising

Are available within the LDP VOSO Consultation Report via: www.swansea.gov.uk/ldpvoso extract overleaf details comments and responses.


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Comments Received

Vision and Objectives

Action/Theme Representation Proposer and Ref ID

Introduction

Clarify what is the introduction. Clarify what is the introduction. If the introduction is the LDP update then this isn't made clear. chris humphreys 41463

...'over the Plan Period 2010-2015'.

In the 2nd paragraph, we suggest adding ...'over the Plan Period 2010-2015'. The introduction perhaps should also

refer to the period which the Plan covers. Asbri Planning 41564

Introduction - I am against development in the area of outstanding natural beauty - and coastal path, the Langland

Cliffs and Thistleboon. Judy Rees 41371

Introduction-The doucments emphasise the non-negotiable nature of the population growth assumptionn. My

comments have therefore been made in the context of such acceptance but I am noting in this introduction the

obvious dangers of basing such important strategies and policy on possibly false or limited assumptions - Objection

Mrs Bridget Stein 41509

Vision

"Capitalises upon its regional city role; its Waterfront city

location and the Gower

Peninsula."

2nd line of the vision "Capitalises upon its regional city role; its Waterfront city location and the Gower Peninsula." A

glaring omission appears to be a lack of any reference to The Gower area/Gower AONB - the jewel in the crown for

the Swansea area. This statement will then encapsulate the major and defining features of the City of Swansea area.

Environment Agency

Wales 41578

To protect our natural environment and open spaces

when expanding small villages

Vision (line 4 - protects and enhances its natural environment) Odette Rice 41365

Vision (line 4) Protects and enhances its natural, built and cultural environment - I expect the vision to protect our

natural environment, its open spaces and its AONB and to be mindful when expanding small villages for development - Support

mrs jill burgess 41335

Mr Russell Thomas 41360

Corinne Thomas 41361

To protect our natural environment and open spaces when expanding small villages

Vision (line 4 - protects and enhances its natural environment) David Rice 41368

Vision (Line 4 - protects and enhances its natural, built and cultural environment) - Line 4 should be a core pillar of the

vision and an imperative for protecting and conserving the AONB and surrounding 'green fields'. Steven Herrieven 41376


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We agree with the vision statements indicated in lines 4; 5; 6; 7 & 9 which reflect our remit and concerns for the

successful development of the Swansea area in environmental terms over the next 13 years. Environment Agency

Wales 41578

"Effectively uses its natural resources"

Re-word 6th bullet point RWE npower renewables

41300

“Ensures sustainable use of its

natural resources.” Bullet Point 6: We suggest that this is amended to read: Ensures sustainable use of its natural resources. Countryside Council for

Wales 41559

"Delivers on sustainability and

equality in everything it does" 8th bullet point: re-write RWE npower renewables

41300

“Encourages and promotes

good health and wellbeing.” Bullet Point 8: We suggest this is amended to read: Encourages and promotes good health and wellbeing. Countryside Council for

Wales 41559

"provides a sufficient range and choise of housing opportunities to enable necessary growth of the City and its communities."

the Vision should include a bullet point which states "..provides a sufficient range and choise of housing opportunities

to enable necessary growth of the City and its communities." As housing is a key element along with economy and

transport (which are referred to)

Asbri Planning 41564

"Is accessible with a sustainable, integrated public and private transport system"

The following vision: "Is accessible with a sustainable, integrated transport system" to read "Is accessible with a

sustainable, integrated public and private transport system" - General Comment Nigel Bowen-Morris 41550

"Encourages and supports the

Welsh language in its

communities".

No clear provision for the Welsh language which is one of the "distinctive" elements of Swansea and should be separately included in the "vision". Information on Welsh language is provided in the baseline Ward data but is not clearly articulated or structurally included in the vision. Suggest the vision includes a line as follows: "Encourages and supports the Welsh language in its communities".

Nigel Bowen-Morris 41550

Additional bullet point “...that ensures everyone has access to

good quality housing that is

affordable and meets the needs

of them and their families;”

We are perplexed by the lack of reference to housing within the Vision. We would understand if the vision were based on these or principles, however the vision clearly singles out certain areas to be prioritised e.g. infrastructure, education, transport, but provides absolutely no reference to the need to ensure the people of Swansea have access to appropriate housing. Access to good quality housing is a basic human right and arguably one of the most important aspects and duties of the LDP. The need for more and better homes is a national priority, which is clearly demonstrated by the recent Housing White Paper. In light of this, we believe the need to ensure access to good quality, affordable and appropriate housing should be reflected in the vision. In this respect, we would suggest that an additional bullet point be included as follows:- ...that ensures everyone has access to good quality housing that is affordable and meets the needs of them and their families;

Home Builders Federation

41537

Vision General Comments

Soc

ial

Com

men

ts

It is not clear whether the word "cultural" refers to the built environment or both. Nigel Bowen-Morris 41550

Vision-LHB supports draft vision, in particular, parts that encourage and promte good health and delivery of the best possible services/facilities. WYG 41472 for LHB

Vision - Good ideals but not specific enough. No emphasis on the move neglected areas which are looking shabby and run down. chris Humphreys 41463


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Vision - This area (Langland Cliffs and Thistleboon) is congested and over populated. Judy Rees 41371

Eco

nom

ic/D

evel

opm

ent

Com

men

ts

Vision - The vision and objectives need to ensure there is more emphasis placed on the protection of amenity sites and focus on brownfield

development where possible. If greenfield development is unavoidable this should be large scale, noe piecemeal Dr Simon Brooks 41328

(i) The City Centre. Plaid notes that the Draft Vision Objectives include reference to "Reinforcement and improvement" of the City Centre as a key

regional focal point for the City and County. However there is no reference in the Vision to outlying areas such as the old Lliw Valley area, which

has a distinct identity of its own, or smaller shopping districts within this amalgamated region, such as Gorseinon and Pontarddulais. Plaid

believes that our smaller towns are a key part of the fabric of the City and County, and as such it is important that they have an explicit place in the

strategic land use planning framework going forward.

Jim Dunckley 41556

Overall we consider that the Vision needs some amendment as it is appears somewhat generic in approach and is not particularly site specific. There is limited direct reference to areas within the City and County of Swansea area e.g. Waterfront city location. An unique feature of Swansea is

that it is also considered a beach side city which is very rare in Europe with other examples including Barcelona and Valencia. Surely this must offer

an opportunity for exploitation in future planning policy terms.

Environment Agency

Wales 41578

Vision-Particularly welcome the Vision of the LDP that the plan will enable a competitive and prosperous economy. This suggests that the plan

and the Council will be proactive in overcoming identified deficiencies in addressing inter alia the beneficial use of existing brownfield vacant sites-Support

Ms Philippa Cole 41511

If existing housing stock currently used as HMOs is returned to family housing, and student relocated to purpose-built accommodation, this would

free up a considerable proportion of future housing requirements and benefits (outlined in the VISION) of living in the centre of our waterfront city

can be enjoyed by Swansea residents, instead of by the current mainly transient occupiers. Also if we wish to build on tourism to help promote

economic growth it is important that the central areas of the city have the welcoming and cared-for appearance that strong communities can help

to promote

F Ferguson 41553

The vision proposed is broadly supported as it refers to the opportunity to capitalise on Swansea's regional role and Waterfront City location. We

do think it could be sharper and stronger with a firmer sptial dimension that supports the Bay area - and with priority given to recycling land and

buildings.

Tim Gent 41523

Vision - Swansea projection of possible building just 730 new homes yearly compared with WAGs 1300 is interesting. Are there plans to bring

neglected or long left empty homes on stream? Miss E Harry 41459

Vision - The option for new villages is a good idea - protecting small rural villages. Carol Jones 41440

Vision - Support the fact that the vision includes intentions to capitalise of Swansea's waterfront location and enable a competitive and

prosperous economy. In particular, ABP would like reiterate the ability of Swansea Docks to significantly contribute towards the vision -

Support/General Comment

RPS Planning &

Development 41471

The vision proposed is broadly supported as it refers to the opportunity to capitalise on Swansea's regional role and Waterfront City location. The

draft objectives also appear to be robust and the focus on deliverability (through the planning system) is supported. Paul Williams 41522

nmen

tal

com

men

ts (ii) Greenbelt Protection. Plaid strongly support that the Draft Vision and Objectives make explicit reference to the protection of "accessible

green-space" and the "interplay of town and country". However, we note with some dismay that this stands in flat contradiction to the "Strategic

Options" section of the consultation which outlines a major policy shift in the direction of development on green-belt land. It is quite clear that that this shift is driven directly by the Welsh Government itself and contradicts the current emphasis in Swansea's UDP on development on Brownfield

Jim Dunckley 41556


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sites. Plaid are opposed to the removal of green-belt land for further development, and believe that much of this shift is driven by the need to

accommodate the excessive housing targets set by the Statistical Directorate of the Welsh Government. We support the democratic right of local communities to determine for themselves the level of housing development that is appropriate to their needs.

Vision makes efficient use of its natural resources - I trust this doesn't relate to 'fraking' which has been mentioned on a number of occassions. if this is the case, then the LA is surely in conflict with their 'Quality Environment Objectives' - Comment/Objection

Brian Burgess 41339

Vision - Protect and enhance its natural environment, particularly in areas of outstanding natural beauty e.g. cliffpata, closeness and fields. Claudia Herrieven 41356

Vision makes efficient use of its nature resources - We expect that Swansea's natural environment will be protected - Support Mr&Mrs MaCartney 41332

and A Davies 41340

Vision (make efficient use of natural resources) - I expect the vision to protect the natural environment W Clarke 41367

Vision makes efficient use of its natural resources - It states that the vision will protect and enhance its natural environment - Support Mike Macartney 41336

Vision - Protect and enhance its natural, built and cultural environment. This alone will stop Swansea's decline - it is lack of this that has done the

most harm - The most important point. All else will follow. Mrs Jan Probert 41464

Gen

eral

wor

ding

/gui

danc

e re

late

d

com

men

ts

Vision is up to date and has wide spatial relevance. These two paragraphs need to be written in simpler language. If documents are for public

comment plain English please. It sounds clear but it is full of jargon e.g. "spatial development" to me this just means developing space. It's like

"forward planning" you can't plan any other way!

Mrs A Capp 41317

Although the Wales Spatial Plan is one of the considerations the Planning Act 2004 requires Local Authorities to have regard to in the preparation

of their LDPs, it is not clear why so much emphasis is placed on it in identifying the Vision of the LDP, particularly when Local Development Plans

Wales identifies that LDP visions should normally be based on the objectives and priorities of the Community Strategy. Although supportive of the

Draft Vision, the Countryside Council for Wales (CCW) considers that it would benefit from a couple of tweaks (included in Vision comments

above)

Countryside Council for

Wales 41559

The Group suggested that the words ‘accessible and inclusive’ be added to the introduction alongside ‘vibrant and distinctive’ – rather than featuring alongside transport. Alternatively a bullet point focused solely on accessibility and inclusivity could be added to avoid misinterpretation

Disability Liaison Group

The vision is well-developed and broad, and should do all it can to meet the criteria extracted from Local Development Plan Manual (2006) as it is

actually applied to planning and policy in the County. The motivation of making Swansea the sort of plan it wants to become is paramount, and

this must reflect ambitious ideas for Swansea at different scale: not merely the city centre, but the wider urban area and emerging city region, as

well as a county full of urban and rural communities. All these are places in their own right, and their own, scaled economic, environmental and

social needs must be met - Support

Mr Alfie Stroud 41549

Gen

eral

stat

emen

ts Vision - The vision sets out a range of aspects of life of Swansea residents. Importantly the document is integrated with other overarching

strategies providing the necessary framework. Positive that natural assets are utilised and that it strives to make Swansea 'distinctive' - Support Jonathan Hughes 41327

Vision - What's not to agree with...? - Support Peter May 41353

The Vision for Swansea is strong and all encompassing. Mrs Yvonne Burgis 41430


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Vision - Your vision is for a desirable place to live - now when you have to daily suffer the problems I have stated in the next section - Object mr david powell 41460

Q1. The Countryside Council for Wales (CCW) generally agree with the draft vision. CCW 41558

Vision - The vision is acceptable - Support Eleri Walters 41377

Vision - Probably the same as every other Welsh Council. Comprehensive and the areas required - Support Mr J Waygood 41540

The Vision is wide and comprehensive, but so generalised (this is the nature of visions) that it becomes almost meaningless without clear and

measurable objectives. While most of the bullet points of the Vision deal with one aspect of life in Swansea (or one cohesive group of aspects), bullet point 9 comprises two distinct and unrelated areas. The wording might express the vision more clearly were it divided into two: Promotes

sustainability and Promotes equality. Bullet points 10 and 11, on the other hand, appear to overlap and could be amalgamated into one: Facilitates and supports the provision and delivery of the best possible services and facilities, including an excellent education infrastructure.

The Gower Society 41594

Economic Prosperity & Lifelong Learning Objectives

"Direct new housing to

economically developable sites

close to supporting employment, retail, leisure, education and

other community facilities"

"Direct new housing to economically developable sites close to supporting employment, retail, leisure, education and

other community facilities and taking into account sustainability and environmental factors". Nigel Bowen-Morris 41550

"Ensure that communities have

sufficient housing to meet their

needs and that this is of good

quality, designed to a high

standard, respects distinctive

local and vernacular character

and achieves the highest energy

efficiency rating possible"

Objectives - The Objective "Direct new housing to economically developable sites close to supporting employment, retail, leisure, education and other community facilities" to rear "Direct new housing to economically developable sites

close to supporting employment, retail, leisure, education and other community facilities and taking into account sustainability and environmental factors".


The draft objectives also appear to be basically sound, although the third bullet under the Economic Prosperity and

Lifelong Learning heading does need changing. This should follow the established sequence that directs housing to

previously development land. This does not mean that plans should allocate no undevelopmed land, but it does mean

that first priority should be given to recycling well located and accessible urban land before further greenfields are

released. This is one of the cleareat planning objectives and should be reflected in the LDP.

Tim Gent 41523

Promote and enhance a

sustainable rural economy

including farm diversification."

Draft Objectives, for Economic Prosperity & Lifelong Learning, re-phrase the 5th bullet point to “Promote and enhance

a sustainable rural economy including farm diversification." RWE npower renewables

41300

Move 4th and 5th

bullet to

Community and Social Provision.

Move other objectives in

We support objectives under 'Economic Prosperity and Lifelong Learning', particularly the 4th bullet point which aims

to direct new housing to economically developable sites and the 5th point which seeks to ensure that communities

have sufficient good quality housing to meet their needs. It may be, however, that these objectives are more

appropriate to the Community & Social Provision objectives, whilst objectives in that section which relate to renewable

Asbri Planning 41564


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Community and Social Provision

to Quality Environment Section. energy, minerals and waste are more relevant to the Quality Environment Section.

Objectives - All of the objectives listed under Economic Prosperity and Lifelong Learning are supported but it should

be recognised that the Local Authority needs to allocate sufficient housing land to meet its own economic objectives. Often Local Authorities fail to reconcile their aspirations for job growth and teh resultant housing requirement.

Zoe Abberley 41602

Housing often acts as the driver for the provision of other facilities and surely the objective should seek an overall sustainable approach to the provision of housing and employment; retail; leisure; education and other community

facilities.

Environment Agency

Wales 41578

Objectives - 1. What are economically developable sites? Are these greenfield sites in sought after areas? 2. Stop any

further 'out of town' retail development to prevent further drain from the city centre. chris Humphreys 41463

The draft 'Economic Prosperity & Lifelong Learning' objectives seek to direct new housing to 'economically

developable' sites close to facilities. This general approach is supported as this will ensure that future housing is

accessible and helps to support the future viability of existing facilities. However, the inclusion of the phrase

'economically developable' is confusing and we recommend is replaced by 'viable and deliverable' to improve clarity. The reference to the draft 'Economic Prosperity & Lifelong Learning' list of objectives which relates to ensuring that communities have sufficient, good quality housing to meet needs is welcomed although we feel the synergy between

the provision of employment opportunities and provision of housing needs to be achieved through the inclusion of a

separate objective which seeks to ensure the plan achieves an alignment between housing and jobs.

Mr Jenkins 41546

Objectives - The draft 'Economic Prosperity & Lifelong Learning' objectives seek to direct new housing to

'economically developable' sites close to supporting facilities. This general approach is supported as this will ensure

that future housing is accessible and helps to support the future viability of existing facilities. However, the inclusion of the phrase 'economically devlelopable' is confusing and we recommend is replaced by 'viable and deliverable' to

improve clarity. The reference to the draft 'Economic Prosperity & Lifelong Learning' list of objectives which relates to

ensuring that communities have sufficient, good quality housing to meet needs is welcomed although we feel the

synergy between the provision of employment opportunities and provision of housing needs to be achieved through

the inclusion of a separate objective which seeks to ensure the plan achieves an alignment between housing and

jobs.

Ms O'Neill 41545

Economic Prosperity and Lifelong Learning 2.5 We agree with the objective of supporting the development of Swansea as an economically competitive place and a regional economic driver. This is consistent with the Wales

Spatial Plan (WSP) (2008) and must be reflected through the policies and allocations of the LDP as a whole. 2.6 To

achieve this objective it is fundamental that the LDP delivers sufficient residential development to support this role. As

such, we strongly support the objective of ensuring that communities have sufficient, good quality housing to meet their needs. In doing so, it is important to recognise that sufficient housing must be provided to support the needs of both the existing and future populations. This is essential if Swansea is to maintain, and build on, its position as key

regional economic driver. 2.7 We also strongly agree with the objectives of directing new housing development to

economically developable sites. This is essential if sufficient housing is to be delivered over the plan period in support of the wider objectives and vision of the LDP. We also support the objective of delivering this housing on sites that are

close to supporting employment, retail, leisure, education and other community facilities. This should be reflected

through the spatial approach adopted by the LDP. 2.8 We support the importance of providing for the development of

Stephen Pilliner 41536 on

behalf of our clients, Redrow

Homes


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accessible, high quality education, training and employment infrastructure and facilities. The delivery of such

infrastructure and facilities will be closely linked to the provision of sufficient new residential development across the

County. Residential development of a significant scale will help to drive forward this infrastructure and facilities.

Our client is concerned that the omission of a direct reference to the provision of new homes within this objective is a

significant omission and fails to recognise the importance of ensuring the future residents of Swansea enjoys access

to a home. Swansea suffers from a significant back-log of affordable housing need and also according to paragraph

1.11 of the Strategic Options the Council is seeking to provide a housing level which is below that indicated in the

latest WG projections. Together, this is likely to result in further pressure on existing housing provision in Swansea

and therefore we fee it is very important that reference is made to providing new homes for the residents of Swansea

within this objective - Support subject to suggested amendments.

Mr Jenkins 41546

Quality Environment Objectives

'High Quality Environment' Rephrase Objective title to read 'High Quality Environment' Penllergare Trust 41467

'and respects environmental limits and assets.

Quality Environment Bullet Point 1. The last part of the bullet point should be reworded thus 'and respects

environmental limits and assets.'. It is not clear what is meant by constraints. Countryside Council for

Wales 41559

Bullet Point 1. We welcome the objective to promote development that avoids significant adverse impacts. However

it is not clear what is meant by constraints. As the environment of the area is a considerable asset to the national and

local economy, and to the health and well being of the county's citizens, we consider the last part of the bullet point should be reworded to read 'and respects environmental limits and assets.'


Wales 41558

"Promote development which

does not produce irreversible

harmful environmental effects

and respects constraints".

We support the principles of the various objectives within this section but consider that they require some substantial amendment in content to enable this section to be considered sound in theory and practice.

Statement 1 should be amended to reflect Planning Policy Wales (Para 4.4.2) The original objective states "avoids

significant adverse environmental impacts" which gives us the impression that your authority will permit or favour

proposed developments which may be considered to cause adverse environmental impacts of a lower nature.

Environment Agency

Wales 41578

'Promote sustainable

development that enhances

environmental assets and

respects constraints'

Amend 1st objective Penllergare Trust 41467

'Protect and enhance the

network of accessible green

space'

Amend 2nd objective Penllergare Trust 41467

"Support the adaptation and

mitigation measures to minimise

the causes and consequences

of climate change"

Statement 3 "Support the adaptation and mitigation measures to minimise the causes and consequences of climate

change" In accordance with PPW (Section 4). Environment Agency

Wales 41578

"Reduce climate change and For Quality Environment, rephrase the 3rd bullet point RWE npower renewables


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support adaptation and

mitigation measures." 41300

Should you add "sea & pr water"

to the statement as Swansea

has a significant level of interaction with the

Sea/Waterways.

Statement 4 Should you add "sea & pr water" to the statement as Swansea has a significant level of interaction with

the Sea/Waterways. The statement (4) "Protect the interplay of town and country". What does this mean? Environment Agency

Wales 41578

'Promote the interaction of town

and country to mutual benefit'. Amend 4th objective Penllergare 41467

'Preserve and enhance the

natural, cultural and historic

environments'.

Amend 5th objective Penllergare Trust 41467

'Preserve and enhance.....' Quality Environment Bullet Point 5. 'Preserve and enhance.....' Countryside Council for

Wales 41559

Bullet Point 5. Although the objective to 'preserve or enhance' the quality of the environment will be acceptable in

many instances, this does not satisfy the authority's duty in respect of Sites of Special Scientific Interest (SSSIs). Section 28G of the Wildlife and Countryside Act places a duty on the authority to take reasonable steps, consistent with the proper exercise of the authority's functions, to further the conservation and enhancement of the flora, fauna or

geological or physiographical features by reason of which the site is of special scientific interest. Additionally, TAN 5

Nature Conservation and Planning sets out how the land use planning system should contribute to protecting and

enhancing biodiversity and geological conservation. To meet both legal and policy requirements, we therefore

recommend that the objective is amended to read 'Preserve and enhance.....'


Wales 41558

Objectives (line 5) Preserve or enhance quality of the natural, cultural, historic - Our heritage of the oldest AONB must be protected. Our historic buildings, those that still remain must have money set aside to preserve them i.e. museum

and Dylan Thomas Centre - Support

mrs jill burgess 41335

Objectives (Line 5 - Preserve or enhance quality of natural, cultural, historic) - Our heritage of the oldest AONB must be protected - Support

Mr R Thomas 41360 C

Thomas 41361

Objectives (improve and expand diversity) - We should be concentrating on smaller issues and protecting what is

already in place. W Clarke 41367

Ensures sustainable use of its

natural resources. Quality Environment Bullet Point Bullet Point 6: We suggest that this is amended to read: Ensures sustainable use of its natural resources.


Wales 41559

"Reduce; prevent or manage the

adverse effects of environmental pollution from

development".

Statement 7 "Reduce; prevent or manage the adverse effects of environmental pollution from development". This

objective will then be in accordance with PPW (Para 13.1.2). Environment Agency

Wales 41578


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Encourages and promotes good

health and wellbeing. Quality Environment Bullet Point Bullet Point 8: We suggest this is amended to read: Encourages and promotes good

health and wellbeing.


Wales 41559

Dark skies on Gower and in

other rural areas would be a

worthwhile objective to add

Objectives Bridget Stein 41509

“Support, sustain and develop

the Welsh language in local communities in order to maintain

and strengthen their bilingual character"

The following new Objective is added: Support, sustain and develop the Welsh language in local communities in order

to maintain and strengthen their bilingual character" - General Comment Nigel Bowen-Morris 41550

Objectives - AONB to protected - Support Mr& Mrs MaCartney 41332

Objectives - Protect and enhance the system of accessible green space - Support Mike Macartney 41336

Quality Environment 2.9 We agree with the objective of protecting and enhancing the system of accessible

greenspace. It is important to recognise that there are opportunities for new development delivered through the LDP

to enhance public accessibility to greenspace. 2.10 We agree with the objective of reducing the effects of environmental pollution from development. In doing so, it should be recognised that development on, and adjacent to, existing sites can help to reduce the overall effects of environmental pollution.



Homes


We support the principles of objectives 1-5 which fall within our interests/remit. Env Agency Wales 41578

"Maximise the sustainable development of renewable energy resources and energy infrastructure."

Community & Social Provision, 2nd bullet point re-phrase RWE npower renewables

41300

We suggest the seventh and

eighth objectives of community

and social provision be merged

as they mean the same thing

Community and social provision. Objective 7 & 8 The Theatres Trust 41451

"Support the development of modern healthcare facilities".

Add objective under Community & Social Provision WYG 41472

In terms of the draft 'Community & Social Provision' objectives, we question the omission of housing from the objective

which relates to promoting equality of access to health, community, leisure and recreation facilities. Ensuring access

to housing is an essential component of any cohesive community and therefore should be specifically referenced in

this objective.

Mr Jenkins 41546


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which relates to promoting equality of access to health, community, leisure and recreation facilities. Ensuring access

to housing is an essential component of any cohesive community and therefore should be specifically referenced in

this objective.

Ms O'Neill 41545

Community and Social Provision 2.11 We support the objective of promoting an integrated and sustainable transport system. To achieve this objective it is important that development allocated through the LDP is directed to sustainable

sites and locations that are close to supporting employment, retail, leisure, education and other community facilities.



Homes

The Coal Authority supports the inclusion of an Objective to secure the "Efficient Use of Minerals and Safeguard

Existing Resources", in line with paragraphs 13 and 15 of Minerals Planning Policy Wales, the surface coal resource

will form part of the defined Mineral Safeguarding Area (MSA) through the Swansea LDP. The Coal Authority has

provided this information to the City and County of Swansea Council in GIS format and expects that, in line with

paragraphs 13 and 15 of Minerals Planning Policy Wales, the surface coal resource will form part of the defined

Mineral Safeguarding Area (MSA) through the Swansea LDP. The Coal Authority also expects that the Swansea LDP

will seek to encourage and promote the prior extraction of surface coal resources where non-mineral development is

to take place within the defined MSA.

The Coal Authority [1328]

41563

Objectives-Under "Community & Social Provision" the final objective promotes equality of access to health, community, leisure and recreation facilities. Acknowledge this is an important objective but notes it is not the only

relevant objective. LHB has future programme of improvement for services, central to which is the development of modern healthcare facilities. Request additional objective "Support the development of modern healthcare facilities". LPA's frequently use planning obligations to support new facilities and services. Request that consideration be to

support healthcare provision. - Objection

WYG (Paul Vining) [2857]

41472

Objectives General Comments

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Objectives - It is clear that sufficient good quality housing is essential for a community to work well. Providing a good quality home is the basis for

good health and wellbeing as well as children being able to perform well in education. This ensures that the economy in an area is sustainable and

the area is an attractive place to work and live - Support (Penderry)

Various

Outlined below are Gower Plaid's comments in respect of (1) The "Vision and Objectives" component of the consultation 1. Vision and Objectives.

(i) The City Centre. Plaid notes that the Draft Vision Objectives include reference to "Reinforcement and improvement" of the City Centre as a key

regional focal point for the City and County. However there is no reference in the Vision to outlying areas such as the old Lliw Valley area, which has

a distinct identity of its own, or smaller shopping districts within this amalgamated region, such as Gorseinon and Pontarddulais. Plaid believes that our smaller towns are a key part of the fabric of the City and County, and as such it is important that they have an explicit place in the strategic land

use planning framework going forward.

Mr Jim Dunckley 41557

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focus on dealing with and providing the basic requirements in enhancing our bays attraction (well lit, safe walking envionment) rather than rely on

the larger tourism proposals – Comment Protect and enhance the sytem of accessible green space - Our surrounding coastal AONB is the oldest and unique area and must be protected at all cost - Comment

Brian Burgess 41339

Objectives-Particularly welcome the support for Swansea as an economically competitive place, the recognition within the aims that new housing

should be directed towards economically developable sites and that there is a need for accessible, high quality employment infrastructure and

Ms Philippa Cole 41511


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facilities-Support

The Ferry facility still exists within Swansea Dock and could form an integral part of the transport strategy for the City. EAW 41578

Objectives address all aspects of physical, social and economic factors. Housing, however, is the key to achievement of all objectives and I would

suggest needs greater prominence and also needs to reflect diversity and housing tensure e.g. affordable housing - Support Jonathan Hughes 41327

Objectives - We need affordable and/or social and eco hosuing not an estate of "executive housing". Judy Rees 41371

Objectives - The present transport system, schools, health centres, and waste systems canot support the present population in Loughor so how will it support the increase - Object

mr david powell 41460

Objectives - Careful development of inner urban areas with high density and some mixed-use quality urban development, might make significant contributions to resolving long-term challenges like reviving the city centre and would redouble the sustainability of ambitious and prestigious

developments such as SA1 Waterfront and those based around the Hafod works which will depend for success on city connectivity and on local staff and users. And, with these sorts of strategic objectives in mind, we should aim to grow and attract new citizens - across the city region. -

General Comment

Mr Alfie Stroud 41549

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Objectives (improve and expand diversity) - We should be concentrating on smaller issues and protecting what is already in place. W Clarke 41367

(ii) Greenbelt Protection. Plaid strongly support that the Draft Vision and Objectives make explicit reference to the protection of "accessible green-space" and the "interplay of town and country". However, we note with some dismay that this stands in flat contradiction to the "Strategic Options"

section of the consultation which outlines a major policy shift in the direction of development on green-belt land. It is quite clear that that this shift is

driven directly by the Welsh Government itself and contradicts the current emphasis in Swansea's UDP on development on Brownfield sites. Plaid

are opposed to the removal of green-belt land for further development, and believe that much of this shift is driven by the need to accommodate the

excessive housing targets set by the Statistical Directorate of the Welsh Government. We support the democratic right of local communities to

determine for themselves the level of housing development that is appropriate to their needs.

Mr Jim Dunckley 41557

The environment is not well served by building extensively on greenfield sites. This would only exacerbate our traffic problems and cause more

pollution. There would be more journeys across the city to work, school, leisure pursuits etc. Socially and economically the occupiants of out-of-town properties can suffer, as transport costs rise.

F Ferguson 41553

Objectives - I'm concerned about preserving village greens, allotments, play areas and urban green spaces. I believe the Council should lead the

way with regard to renewable energy - Council properties could have solar (photo voltar) cells fitted - General Comment Peter May 41353

Objectives - In order to support the vision we must protect our village greens, playing fields, parks, allotments and whats left of the character of villages in and around Swansea so there is less of continuous urban sprawl. Also protect garden spaces and limit house building in gardens -

General Comment & Objection

Eleri Walters [41377

Objectives - It's important to preserve urban green spaces, play areas, playing fields, allotments, village greens. Don't squeeze existing amenities -

Heneral Comment Margaret Walters 41381

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As stated above the WSP is only one of many considerations that the Local Authority has to have regard to in the preparation of the LDP. Therefore

it is not clear why so much emphasis is placed upon it in identifying the objectives for the plan. We welcome the recognition that some of the

objective themes are interlinked and that some may be appropriately placed under a combination of subject headings, and that sustainability issues

have been identified through data collected to inform the Strategic Environmental assessment and Sustainability Appraisal.


Wales 41559


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Although generally supportive of the draft objectives, currently they fail to demonstrate the linkages between various objectives, particularly the

importance of the environment to the economy and the community. We recommend that is brought out more fully in the Draft LDP. Unless it is

clearly stated that individual objectives should be compatible with other objectives and policies of the Plan, a number of objectives under Economic

Prosperity and Lifelong Learning have the potential to be in conflict with other Plan objectives. There should therefore be a clear statement within

the Plan to states that objectives will be compatible with other objectives of the Plan, or where there is conflict, that they will be prioritised in the

Plan.


Wales 41559

(i) Population Projections. Plaid notes that much of the projected housing demand for Swansea over the LDP period (2014 - 2026) is based on

"Welsh Government Local Authority Housing Projections" compiled by the Welsh Government's "Statistical Directorate". As such, Gower Plaid

considers that these figures are top-down figures that have not been compiled in consultation with local communities. We further note that Swansea Council considers these projections to be "unprecedented" and "unrealistically high", an analysis with which Gower Plaid would concur. It is worth putting the Swansea figures into the wider context, where the Welsh Government is proposing an increase in the Welsh population by an

additional 395,000 people by 2033. Effectively, this equates to the biggest shift in our population since the last wave of industrialization in Wales at the start of the 20th century. In Swansea, Gower Plaid understands that this will equate to an additional 29,000 households in Swansea by 2033 -

an increase of nearly a third. The impact of such a massive increase on the nature and character of our communities needs to be carefully

considered going forward. In light of these dramatic figures, Gower Plaid wishes to strongly object to the proposed figures, and the way in which the

Welsh Government have chosen to impose these arbitrary targets on Local Authority areas. Such a massive increase in the population of Swansea

over the plan period, in an era of service cut-backs, is likely to place unprecedented strain on local communities and community services across a

whole range of indicators, from traffic to provision of decent schooling to protection of our environment.

(ii) Proposed "Growth Areas".

Based on these figures, Swansea Council proposes to accommodate this massive increase in population around a number of "growth areas"

across the City and County of Swansea. Given that much of the City is already heavily developed, and the Gower peninsula is rightly protected as

an Area of Outstanding Natural Beauty (AONB), it is the considered opinion of Plaid that much of this increase will likely be accommodated across

the old Lliw Valley Borough Council area. As such, it is likely to lead to an unprecedented transformation in the character of Lliw Valley

communities, and place considerable strain on key services, particularly as budget cuts continue going forward. We also note that much of this

development is likely to be concentrated around the Burry Inlet SAC/SPA area. Councillors and officers will be well aware of the status of the Inlet as a European protected site. As such it falls under the remit of European Directives such as the Water Framework Directive, Habitats Directive and

Birds Directive. We note that the European Commission is already taking the Welsh Government to court over potential breaches to some of these

Directives. Gower Plaid considers that the tremendous amount of additional development posed in the LDP is likely to exacerbate an already over-loaded sewage system around the Burry Inlet, and that while extra investment has been proposed to upgrade sewage capacity in the area

(particularly the Llannant Water Treatment Works) whether these upgrades will be enough to accommodate all the additional land allocation

proposed in the LDP. We note also that while the Stage 1 Strategic Flood Consequences Assessment places considerable emphasis on fluvial flood impacts as outlined by Environment Agency criteria, additional consideration needs to be given to pluvial flooding caused by culverting of streams and springs as housing development is extended towards towards the Burry Inlet SAC/SPA.

Jim Dunckley 41556

We support the Council's challenge of Welsh Governments estimation of future demand for housing in Swansea which we feel to be totally

excessive and unrealistic mike ford 41350

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Q2. CCW generally agree with the draft objectives. CCW 41558

Categories of objectives are good. Some objectives are clear and give direction eg. Facilitate the sustainable management of waste. Others are

more aspirations than objectives eg promote equality of access to health, community, leisure and recreational facilities. Given the economic

climate many of these facilities are under threat of budget reductions or closure. Some communities have little by way of facilities that they can

Mrs Yvonne Burgis

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access locally. People will be interested in timescales and estimated costs for the work on these objectives and the order of priority that is to be given to them.

Need a link road from Tesco to Heol Pentre Eifion Davies 41439

- Support Objectives - AONB to be protected - Support Gareth Davies 41343

Consultation. Gower Plaid would like to congratulate the officers in the LDP Unit of Swansea Council for their hard work in compiling the Plan, gathering the evidence and their willingess to engage with the public and answer queries. This is laudable. However, questions must be raised

about the value of the consultation exercise undertaken when the likelihood is that locally agreed housing targets set by the Authority are likely to be

over-ridden by unelected Planning Inspectors appointed by the Welsh Government. In this respect, other authorities such as Wrexham and Cardiff offer a salutary lesson in the willingess of the Welsh Government to over-ride local democracy in favour of statistical targets that bear no relation to

real community need, or the condition of the housing market as it stands today.

Jim Dunckley 41556

"The creation of a waterway for navigation, recreation and leisure linking the River Tawe with the Swansea Canal and Tennant Canal would provide

a resource for the City, visitors and local communities. It would be of regional significance. It would enable the creation of a 35 mile waterway

network linking with the Neath and Tennant Canals, helping to link with the wider Swansea Bay area and bring economic, social and environmental benefits. It would help forge a new vitality and identity for the 'east side' communities that deserve a vibrant vision for the City as it emerges from the current economic difficulties. It would provide a linear green park and lung and the potential for waterside regeneration and revitalisation for communities

including Port Tennant, St. Thomas, the Hafod, Llansamlet, Morriston, Ynystawe and Ynysforgan and Clydach. The UDP protects the line of the

waterway through the City. Now is the time to shape the future of the area and the LDP should embrace and promote the waterway as an unifying

strategy for the City and east-side. The completion of the project is likely to extend beyond the life of the current version of the LDP, but very

significant progress delivering lengths of waterway, benefits and unlocking waterside development potential is very achievable within the plan

period. The Swansea Canal Society is progressing work both in Swansea and Neath Port Talbot and welcomes the opportunity to work with the City

and Council of Swansa to bring this vision to fruition."

Meryl Hunt 41595

All your objectives are great but please remember that most of them require a certain percentage of the community to be permanent rather than

transient, therefore in areas where this is a high transent percentage the objectives are going to be extremely difficult to achieve and therefore

those areas either need special attention or need to have their mix of transient permaent reduced

Sandy Johns 41592

These consultations are very expensive and I hope that local peoples opinions are being noted. Carol Jones 41440

page 25 of the Vision and Strategic Objectives confirms that the Better Swansea Partnership developed a Community Strategy and that this

approach ensures that the aspirations of all interested parties are taken ino account.The membership of the Better Swansea Partnership does not include any housing developers whose views were therefore not taken into account in the process

Liberty 41427

Given that the Gower Peninsula, part of the National Nature of Wales, nature at its best, with farm and villages, is at risk of being destroyed; a vision

of the future must be placed in the minds of those who would destroy nature for capital gain, under false claims, that fields in villages need to be

turned into housing estates, that would destroy village life of local country peoples, and turn a small peninsula into suburbia expansion, as if earth is

expendable. A warning from history, to blurry minds that, within a warning from history of towns peoples, depended on farm fields to grow foods, or

they all would have died from the lack of food. Not such a small thing, as it takes mass land to grow, only wheat for bread, and potatoes, not to

mention vegetables, or mass grass land for cows and sheep etc. Towns people are fools, but the rulers of towns are bigger fools; if you all think

within verisimilitude, that within World Ward Three, shops like Tesco would remain open to suit towns people, or that what was fields now housing

estates, can grow foods, to keep, millions of towns people alive, when all things go wrong, "as it will". Officialese, is that that do's not know, what the

Mr. Geoffrey Allan Morris

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Home Guard is, and without foods, all the children are dead. Let me enlighten you all, that rile if, you have the means to understand; Syria, Iraq, Iran, Afghanistan, Pakistan, Lebanon, Israel etc. etc. is about to explode, "mixeing", with the situation going out of control in Greece, Spain etc. etc. that may well start World Ward Three. OK, or are you blind. Given that a World War starts; most of the police, would go with the army, navy, airforce, and ALL 16 year olds to 60 year olds; all going to War, the other side of the world (a bit like World War Two); that leaves children, women, the ill, and the old left within the British towns, millions all depending on foods, from fields in villages. But if it is up to you who rule, you get rich now, and the mass peoples die then. What you do today is the continuation of yesterday that determines the end of lives. To look in the childrens eyes is

to tell them lies, if land development turns fields into means of unableness to feed them life. Who then has the only gain, to turn fields into housing

estates; oh yes, the rich. Now is the time, that the police, army, navy, airforce, and home guard speak out loud, to say, no to land developments on

fields that grow our childrens foods. Furthermore to the blind who can not see, "or" no not wish to see. "See" Russia Today News on Freeview 085. This new shows the true situation how World War Three is near. It do's not lie, like the BBC. "Your" childrens lives depend on "you" looking at Russia today news freeview 085 (each day passing). Moreover; how soon you all forget that, the hole in the ozone layer, greenhouse effect, as

icecaps melt to sea level rise, as the weather systems change for the worst, all is a danger to earths magnetic field, that can lead to quaqua-illiquation-inglobatation, if the wise do not wake up. As that, Israel being trapped within the Middle East wars etc., would press a nuclear button, to

defend itself, being fools. What a future the children have; but I see what is going wrong, why must it start with you. This letter must be put on the

database all have a right to read it. If you fail to do so you fail all children. I Mr G A Morris born in the village in Gower, now age 64 ¾. "Facts" hurt so

do's dieing.

The aspirations set out in the Vision document are what we would all like to see developed in Swansea. A firm commitment is required from the

current and future administrations to drive these forward and demonstrably achieve them. Swansea Civic Society

41514

The Objectives elaborate the Vision in a useful way, but are still at a high level of abstraction. We have no quarrel with the Objectives as outlined, but the real questions are a. What practical steps are to be taken to achieve these Objectives? And b. How are problems to be resolved, or priorities

identified, when the practical application of an Objective in one domain (e.g. Economic prosperity) conflicts with an Objective from another domain

(e.g. Quality Environment)? In general terms, The Gower Society is supportive of the Vision and Objectives, while recognising that it is in the

implementation of these aims - rather than the aims themselves - that the problems will arise.

The Gower Society

41594

Review of Comments Received

Representation Response/Action taken

Introduction

Clarify what is the introduction. If the introduction is the LDP update then this isn't made clear. Noted

In the 2nd paragraph, we suggest adding ...'over the Plan Period 2010-2015'. The introduction perhaps should also refer

to the period which the Plan covers. Agreed

Introduction - I am against development in the area of outstanding natural beauty - and coastal path, the Langland Cliffs Objection noted


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and Thistleboon.

Introduction-The doucments emphasise the non-negotiable nature of the population growth assumption. My comments

have therefore been made in the context of such acceptance but I am noting in this introduction the obvious dangers of basing such important strategies and policy on possibly false or limited assumptions- Objection

Noted

Vision

2nd line of the vision "Capitalises upon its regional city role; its Waterfront city location and the Gower Peninsula." A glaring

omission appears to be a lack of any reference to The Gower area/Gower AONB - the jewel in the crown for the Swansea

area. This statement will then encapsulate the major and defining features of the City of Swansea area.

Noted, vision will reference unique natural heritage of Swansea.

Vision (line 4) Protects and enhances its natural, built and cultural environment - I expect the vision to protect our natural environment, its open spaces and its AONB and to be mindful when expanding small villages for development - Support

Noted, support is welcomed.

Vision (Line 4 - protects and enhances its natural, built and cultural environment) - Line 4 should be a core pillar of the

vision and an imperative for protecting and conserving the AONB and surrounding 'green fields'. Noted

We agree with the vision statements indicated in lines 4; 5; 6; 7 & 9 which reflect our remit and concerns for the successful development of the Swansea area in environmental terms over the next 13 years.

Noted, support is welcomed.

Bullet Point 6: We suggest that this is amended to read: Ensures sustainable use of its natural resources. Noted, amended to conserves its unique heritage and cultural and historic environments.

Bullet Point 8: We suggest this is amended to read: Encourages and promotes good health and wellbeing. Included within various objectives.

The Vision should include a bullet point which states "..provides a sufficient range and choise of housing opportunities to

enable necessary growth of the City and its communities." As housing is a key element along with economy and transport (which are referred to)

Included within objectives on Enhancing Communities, Facilities and Infrastructure.

The following vision: "Is accessible with a sustainable, integrated transport system" to read "Is accessible with a

sustainable, integrated public and private transport system" - General Comment Objective contains sustainable transport system.

No clear provision for the Welsh language which is one of the "distinctive" elements of Swansea and should be separately included in the "vision". Information on Welsh language is provided in the baseline Ward data but is not clearly articulated or structurally included in the vision. Suggest the vision includes a line as follows: "Encourages and supports the Welsh language in its communities".

Cultural environments included in vision which includes Welsh Language concerns.

We are perplexed by the lack of reference to housing within the Vision. We would understand if the vision were based on these or principles, however the vision clearly singles out certain areas to be prioritised e.g. infrastructure, education, transport, but provides absolutely no reference to the need to ensure the people of Swansea have access to appropriate housing. Access to good quality housing is a basic human right and arguably one of the most important aspects and duties of the LDP. The need for more and better homes is a national priority, which is clearly demonstrated by the recent Housing White Paper. In light of this, we believe the need to ensure access to good quality, affordable and appropriate housing should be reflected in the vision. In this respect, we would suggest that an additional bullet point be included as follows:- ...that ensures everyone has access to good quality housing that is affordable and meets the needs of them and their families;

The Vision is overarching and highlights “sufficient, good quality accommodation”. Objective 14. states “ensure that communities have a sufficient range and choice of good quality housing to meet a variety of needs and support economic growth”


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It is not clear whether the word "cultural" refers to the built environment or both. Cultural refers to both the built environment and social fabric.

Vision-LHB supports draft vision, in particular, parts that encourage and promte good health and delivery of the best possible services/facilities.

Health is now explicitly promoted in Objective 24. Create environments that encourage and support good health, well-being and equality. And access to facilities in Objective 3.

Vision - Good ideals but not specific enough. No emphasis on the move neglected areas which are looking shabby

and run down. Noted, LDP will seek to regenerate areas however some improvements may not be achieved via the planning process.

Vision - This area (Langland Cliffs and Thistleboon) is congested and over populated. Site specific comment noted.

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Vision - The vision and objectives need to ensure there is more emphasis placed on the protection of amenity sites

and focus on brownfield development where possible. If greenfield development is unavoidable this should be large

scale, noe piecemeal

The strategy will further detail the preference for brownfield sites.

(i) The City Centre. Plaid notes that the Draft Vision Objectives include reference to "Reinforcement and

improvement" of the City Centre as a key regional focal point for the City and County. However there is no reference

in the Vision to outlying areas such as the old Lliw Valley area, which has a distinct identity of its own, or smaller

shopping districts within this amalgamated region, such as Gorseinon and Pontarddulais. Plaid believes that our

smaller towns are a key part of the fabric of the City and County, and as such it is important that they have an explicit place in the strategic land use planning framework going forward.

Comment noted. Local facilities included in Enhancing Communities, Facilities & Infrastructure objectives.

Overall we consider that the Vision needs some amendment as it is appears somewhat generic in approach and is not

particularly site specific. There is limited direct reference to areas within the City and County of Swansea area e.g.

Waterfront city location. An unique feature of Swansea is that it is also considered a beach side city which is very rare

in Europe with other examples including Barcelona and Valencia. Surely this must offer an opportunity for exploitation

in future planning policy terms.

Vision is overarching, included references to Swansea Bay City Region.

Vision-Particularly welcome the Vision of the LDP that the plan will enable a competitive and prosperous economy. This suggests that the plan and the Council will be proactive in overcoming identified deficiencies in addressing inter

alia the beneficial use of existing brownfield vacant sites-Support

Support noted.

If existing housing stock currently used as HMOs is returned to family housing, and student relocated to purpose-built accommodation, this would free up a considerable proportion of future housing requirements and benefits

(outlined in the VISION) of living in the centre of our waterfront city can be enjoyed by Swansea residents, instead of by the current mainly transient occupiers. Also if we wish to build on tourism to help promote economic growth it is

important that the central areas of the city have the welcoming and cared-for appearance that strong communities

can help to promote

Noted, policies relating to HMOs will feature in the LDP.

The vision proposed is broadly supported as it refers to the opportunity to capitalise on Swansea's regional role and

Waterfront City location. We do think it could be sharper and stronger with a firmer sptial dimension that supports the

Commented noted, included reference to Swansea Bay region.


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Bay area - and with priority given to recycling land and buildings.

Vision - Swansea projection of possible building just 730 new homes yearly compared with WAGs 1300 is

interesting. Are there plans to bring neglected or long left empty homes on stream? Not via the land use planning system.

Vision - The option for new villages is a good idea - protecting small rural villages. Noted.

Vision - Support the fact that the vision includes intentions to capitalise of Swansea's waterfront location and enable

a competitive and prosperous economy. In particular, ABP would like reiterate the ability of Swansea Docks to

significantly contribute towards the vision - Support/General Comment

Noted. The LDP will contain a Ports Policy.

The vision proposed is broadly supported as it refers to the opportunity to capitalise on Swansea's regional role and

Waterfront City location. The draft objectives also appear to be robust and the focus on deliverability (through the

planning system) is supported.

Comments noted.

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(ii) Greenbelt Protection. Plaid strongly support that the Draft Vision and Objectives make explicit reference to the

protection of "accessible green-space" and the "interplay of town and country". However, we note with some dismay

that this stands in flat contradiction to the "Strategic Options" section of the consultation which outlines a major policy

shift in the direction of development on green-belt land. It is quite clear that that this shift is driven directly by the

Welsh Government itself and contradicts the current emphasis in Swansea's UDP on development on Brownfield

sites. Plaid are opposed to the removal of green-belt land for further development, and believe that much of this shift is driven by the need to accommodate the excessive housing targets set by the Statistical Directorate of the Welsh

Government. We support the democratic right of local communities to determine for themselves the level of housing

development that is appropriate to their needs.

Objective 17 states ‘Promote a sustainable development strategy that prioritises the re-use of appropriate previously developed land, avoids significant adverse environmental impacts and respects environmental assets.’

Vision makes efficient use of its natural resources - I trust this doesn't relate to 'fraking' which has been mentioned on

a number of occasions. if this is the case, then the LA is surely in conflict with their 'Quality Environment Objectives' -

Comment/Objection

Comment noted.

Vision - Protect and enhance its natural environment, particularly in areas of outstanding natural beauty e.g. cliffpata, closeness and fields.

Noted.

Vision makes efficient use of its nature resources - We expect that Swansea's natural environment will be protected -

Support Noted.

Vision (make efficient use of natural resources) - I expect the vision to protect the natural environment Comment noted.

Vision makes efficient use of its natural resources - It states that the vision will protect and enhance its natural environment - Support

Noted, the plan must protect and enhance as well as ensure resources are used efficiently.

Vision - Protect and enhance its natural, built and cultural environment. This alone will stop Swansea's decline - it is

lack of this that has done the most harm - The most important point. All else will follow. Noted.

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Vision is up to date and has wide spatial relevance. These two paragraphs need to be written in simpler language. If documents are for public comment plain English please. It sounds clear but it is full of jargon e.g. "spatial development" to me this just means developing space. It's like "forward planning" you can't plan any other way!

Noted.


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Although the Wales Spatial Plan is one of the considerations the Planning Act 2004 requires Local Authorities to

have regard to in the preparation of their LDPs, it is not clear why so much emphasis is placed on it in identifying the

Vision of the LDP, particularly when Local Development Plans Wales identifies that LDP visions should normally be

based on the objectives and priorities of the Community Strategy. Although supportive of the Draft Vision, the

Countryside Council for Wales (CCW) considers that it would benefit from a couple of tweaks (included in Vision

comments above)

Noted, the community strategy has been utilised in forming the Vision and Objectives.

The vision is well-developed and broad, and should do all it can to meet the criteria extracted from Local Development Plan Manual (2006) as it is actually applied to planning and policy in the County. The motivation of making Swansea the sort of plan it wants to become is paramount, and this must reflect ambitious ideas for Swansea

at different scale: not merely the city centre, but the wider urban area and emerging city region, as well as a county

full of urban and rural communities. All these are places in their own right, and their own, scaled economic, environmental and social needs must be met - Support

Support noted.

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Vision - The vision sets out a range of aspects of life of Swansea residents. Importantly the document is integrated

with other overarching strategies providing the necessary framework. Positive that natural assets are utilised and

that it strives to make Swansea 'distinctive' - Support

Support noted.

Vision - What's not to agree with...? - Support Support noted.

The Vision for Swansea is strong and all encompassing. Comment noted.

Vision - Your vision is for a desirable place to live - now when you have to daily suffer the problems I have stated in

the next section - Object Noted.

Q1. The Countryside Council for Wales (CCW) generally agree with the draft vision. Support noted.

Vision - The vision is acceptable - Support Support noted.

Vision - Probably the same as every other Welsh Council. Comprehensive and the areas required - Support Support noted.

The Vision is wide and comprehensive, but so generalised (this is the nature of visions) that it becomes almost meaningless without clear and measurable objectives. While most of the bullet points of the Vision deal with one

aspect of life in Swansea (or one cohesive group of aspects), bullet point 9 comprises two distinct and unrelated

areas. The wording might express the vision more clearly were it divided into two: Promotes sustainability and

Promotes equality. Bullet points 10 and 11, on the other hand, appear to overlap and could be amalgamated into

one: Facilitates and supports the provision and delivery of the best possible services and facilities, including an

excellent education infrastructure.

Noted.

Economic Prosperity & Lifelong Learning Objectives

Objectives - The Objective "Direct new housing to economically developable sites close to supporting employment, retail, leisure, education and other community facilities" to rear "Direct new housing to economically developable sites close to

supporting employment, retail, leisure, education and other community facilities and taking into account sustainability and

environmental factors".

Noted, sustainable locations imply that developments are near to supporting uses, in addition to taking into account of environmental factors.

The draft objectives also appear to be basically sound, although the third bullet under the Economic Prosperity and Noted, objective 9. Highlights “Direct new housing to


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Lifelong Learning heading does need changing. This should follow the established sequence that directs housing to

previously development land. This does not mean that plans should allocate no undeveloped land, but it does mean that first priority should be given to recycling well located and accessible urban land before further greenfields are released. This is one of the clearest planning objectives and should be reflected in the LDP.

economically viable and deliverable sites at sustainable locations”, this ensure that delivery occurs at sites assessed and regarded to be sustainable.

Draft Objectives, for Economic Prosperity & Lifelong Learning, re-phrase the 5th bullet point to “Promote and enhance a

sustainable rural economy including farm diversification." Farm diversification would be too specific in the objective. LDP subject policies will cover specific themes.

We support objectives under 'Economic Prosperity and Lifelong Learning', particularly the 4th bullet point which aims to

direct new housing to economically developable sites and the 5th point which seeks to ensure that communities have

sufficient good quality housing to meet their needs. It may be, however, that these objectives are more appropriate to the

Community & Social Provision objectives, whilst objectives in that section which relate to renewable energy, minerals and

waste are more relevant to the Quality Environment Section.

Supported noted.

Objectives - All of the objectives listed under Economic Prosperity and Lifelong Learning are supported but it should be

recognised that the Local Authority needs to allocate sufficient housing land to meet its own economic objectives. Often

Local Authorities fail to reconcile their aspirations for job growth and teh resultant housing requirement.

Support and comments noted. The LDP will collate evidence with regards to Housing and the Economy to ensure the plan is underpinned by a robust evidence base.

Housing often acts as the driver for the provision of other facilities and surely the objective should seek an overall sustainable approach to the provision of housing and employment; retail; leisure; education and other community

facilities.

The plan objectives aim to deliver homes with supporting social infrastructure.

Objectives - 1. What are economically developable sites? Are these greenfield sites in sought after areas? 2. Stop any

further 'out of town' retail development to prevent further drain from the city centre. 1. Economically developable sites, are sites that are viable to be developed. The LDP will be underpinned by a viability assessment. 2. A retail assessment will be undertaken to help inform the LDP retail policy.

The draft 'Economic Prosperity & Lifelong Learning' objectives seek to direct new housing to 'economically developable' sites close to facilities. This general approach is supported as this will ensure that future housing is accessible and helps to

support the future viability of existing facilities. However, the inclusion of the phrase 'economically developable' is

confusing and we recommend is replaced by 'viable and deliverable' to improve clarity.

Amended objective 9 to ‘direct new housing to economically viable and deliverable sites at sustainable locations.’

The reference to the draft 'Economic Prosperity & Lifelong Learning' list of objectives which relates to ensuring that communities have sufficient, good quality housing to meet needs is welcomed although we feel the synergy between the provision of employment opportunities and provision of housing needs to be achieved through the inclusion of a separate objective which seeks to ensure the plan achieves an alignment between housing and jobs.

Comment noted.

We agree with the objective of supporting the development of Swansea as an economically competitive place and a

regional economic driver. This is consistent with the Wales Spatial Plan (WSP) (2008) and must be reflected through the

policies and allocations of the LDP as a whole. To achieve this objective it is fundamental that the LDP delivers sufficient residential development to support this role. As such, we strongly support the objective of ensuring that communities have

sufficient, good quality housing to meet their needs. In doing so, it is important to recognise that sufficient housing must be

provided to support the needs of both the existing and future populations. This is essential if Swansea is to maintain, and

Comment noted, this will continue to be an objective of the LDP.


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build on, its position as key regional economic driver.

We also strongly agree with the objectives of directing new housing development to economically developable sites. This

is essential if sufficient housing is to be delivered over the plan period in support of the wider objectives and vision of the

LDP. We also support the objective of delivering this housing on sites that are close to supporting employment, retail, leisure, education and other community facilities. This should be reflected through the spatial approach adopted by the

LDP.

Comment noted, both will continue to be an objective of the LDP. Amended to state economically viable and deliverable sites, plus objective 1 states the aspirations with regards to social infrastructure and community services.

We support the importance of providing for the development of accessible, high quality education, training and

employment infrastructure and facilities. The delivery of such infrastructure and facilities will be closely linked to the

provision of sufficient new residential development across the County. Residential development of a significant scale will help to drive forward this infrastructure and facilities.

Support noted.

Our client is concerned that the omission of a direct reference to the provision of new homes within this objective is a

significant omission and fails to recognise the importance of ensuring the future residents of Swansea enjoys access to a

home. Swansea suffers from a significant back-log of affordable housing need and also according to paragraph 1.11 of the

Strategic Options the Council is seeking to provide a housing level which is below that indicated in the latest WG

projections. Together, this is likely to result in further pressure on existing housing provision in Swansea and therefore we

fee it is very important that reference is made to providing new homes for the residents of Swansea within this objective -

Support subject to suggested amendments.

Noted. The evidence base will contain assessments based on affordable housing and the housing market, the LDP will be informed by these studies.

Quality Environment Objectives

Rephrase Objective title to read 'High Quality Environment' Objective subheading amended to read ‘Fostering a High Quality Environment’.

Quality Environment Bullet Point 1. The last part of the bullet point should be reworded thus 'and respects environmental limits and assets.' It is not clear what is meant by constraints.

Constraints will be detailed on the constraints map as part of the Deposit LDP. This will include any constraints that development will be subject

Statement 1 should be amended to reflect Planning Policy Wales (Para 4.4.2) The original objective states "avoids

significant adverse environmental impacts" which gives us the impression that your authority will permit or favour

proposed developments which may be considered to cause adverse environmental impacts of a lower nature.

Noted, objective will be in line with National Planning Policy and Guidance.

Statement 4 Should you add "sea & pr water" to the statement as Swansea has a significant level of interaction with the

Sea/Waterways. The statement (4) "Protect the interplay of town and country". What does this mean? The seascape is contained within the vision in the statement “Celebrates and conserves its unique natural heritage and cultural and historic environments” Reference to interplay removed in final document. Interplay defines how the rural and urban environments are different and relate to each other.

Bullet Point 5. Although the objective to 'preserve or enhance' the quality of the environment will be acceptable in many

instances, this does not satisfy the authority's duty in respect of Sites of Special Scientific Interest (SSSIs). Section 28G of the Wildlife and Countryside Act places a duty on the authority to take reasonable steps, consistent with the proper

Amended to read conserve and enhance the County’s natural heritage.


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exercise of the authority's functions, to further the conservation and enhancement of the flora, fauna or geological or

physiographical features by reason of which the site is of special scientific interest. Additionally, TAN 5 Nature

Conservation and Planning sets out how the land use planning system should contribute to protecting and enhancing

biodiversity and geological conservation. To meet both legal and policy requirements, we therefore recommend that the

objective is amended to read 'Preserve and enhance.....'

Objectives (line 5) Preserve or enhance quality of the natural, cultural, historic - Our heritage of the oldest AONB must be

protected. Our historic buildings, those that still remain must have money set aside to preserve them i.e. museum and

Dylan Thomas Centre - Support

Support noted

Objectives (Line 5 - Preserve or enhance quality of natural, cultural, historic) - Our heritage of the oldest AONB must be

protected - Support Support noted

Quality Environment Bullet Point Bullet Point 6: We suggest that this is amended to read: Ensures sustainable use of its

natural resources. Amended to read 7. Support the safeguarding and sustainable use of natural resources where appropriate and 17. Promote a sustainable development strategy that prioritises the re-use of appropriate previously developed land, avoids significant adverse environmental impacts and respects environmental assets.

Statement 7 "Reduce; prevent or manage the adverse effects of environmental pollution from development". This

objective will then be in accordance with PPW (Para 13.1.2). Noted, objective removed and replaced with “24. Create environments that encourage and support good health, well-being and equality”

Quality Environment Bullet Point Bullet Point 8: We suggest this is amended to read: Encourages and promotes good

health and wellbeing. Comment noted, objective now reads “24. Create environments that encourage and support good health, well-being and equality”

The following new Objective is added: Support, sustain and develop the Welsh language in local communities in order to maintain and strengthen their bilingual character" - General Comment

Comment noted, objective now reads “18. Preserve and enhance the County’s high quality cultural and historic environments” Welsh language is included within culture.

Objectives - AONB to protected - Support Support noted

Objectives - Protect and enhance the system of accessible green space - Support Support noted

Quality Environment 2.9 We agree with the objective of protecting and enhancing the system of accessible greenspace. It is important to recognise that there are opportunities for new development delivered through the LDP to enhance public

accessibility to greenspace. 2.10 We agree with the objective of reducing the effects of environmental pollution from

development. In doing so, it should be recognised that development on, and adjacent to, existing sites can help to reduce

the overall effects of environmental pollution.

Support and comments noted



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We support the principles of objectives 1-5 which fall within our interests/remit. Support noted


which relates to promoting equality of access to health, community, leisure and recreation facilities. Ensuring access to

housing is an essential component of any cohesive community and therefore should be specifically referenced in this

objective.

Housing will be delivered however it is vital that it be delivered at locations with ample accessibility to community facilities. Objective to remain as “3. Improve access to healthcare, lifelong learning, leisure, recreation, and other community facilities”

Community and Social Provision 2.11 We support the objective of promoting an integrated and sustainable transport system. To achieve this objective it is important that development allocated through the LDP is directed to sustainable

sites and locations that are close to supporting employment, retail, leisure, education and other community facilities.

Support noted. Objective 4. states “Create environments that support and promote walking, cycling and public transport as integral elements of a sustainable transport system”.

The Coal Authority supports the inclusion of an Objective to secure the "Efficient Use of Minerals and Safeguard Existing

Resources", in line with paragraphs 13 and 15 of Minerals Planning Policy Wales, the surface coal resource will form part of the defined Mineral Safeguarding Area (MSA) through the Swansea LDP. The Coal Authority has provided this

information to the City and County of Swansea Council in GIS format and expects that, in line with paragraphs 13 and 15 of Minerals Planning Policy Wales, the surface coal resource will form part of the defined Mineral Safeguarding Area (MSA)

through the Swansea LDP. The Coal Authority also expects that the Swansea LDP will seek to encourage and promote

the prior extraction of surface coal resources where non-mineral development is to take place within the defined MSA.

Noted. Objective 7 reads “Support the safeguarding and sustainable use of natural resources where appropriate”.

Objectives-Under "Community & Social Provision" the final objective promotes equality of access to health, community, leisure and recreation facilities. Acknowledge this is an important objective but notes it is not the only relevant objective. LHB has future programme of improvement for services, central to which is the development of modern healthcare

facilities. Request additional objective "Support the development of modern healthcare facilities". LPA's frequently use

planning obligations to support new facilities and services. Request that consideration be to support healthcare provision. - Objection

Objection noted.

Objectives General Comments

Soc

ial

Com

men

ts

Objectives - It is clear that sufficient good quality housing is essential for a community to work well. Providing a good

quality home is the basis for good health and wellbeing as well as children being able to perform well in education. This ensures that the economy in an area is sustainable and the area is an attractive place to work and live - Support (Penderry)

Support noted.

Outlined below are Gower Plaid's comments in respect of (1) The "Vision and Objectives" component of the

consultation 1. Vision and Objectives.

(i) The City Centre. Plaid notes that the Draft Vision Objectives include reference to "Reinforcement and

improvement" of the City Centre as a key regional focal point for the City and County. However there is no reference

in the Vision to outlying areas such as the old Lliw Valley area, which has a distinct identity of its own, or smaller

shopping districts within this amalgamated region, such as Gorseinon and Pontarddulais. Plaid believes that our

smaller towns are a key part of the fabric of the City and County, and as such it is important that they have an explicit place in the strategic land use planning framework going forward.

Comments noted. Detailed policies will be outlined for local and district centres in Deposit LDP.

l o p Objectives improve, expand and diversity aoropriate sustainable tourism facilities and infrastructure - There should The requirements mentioned are part of a community


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be a greater emphasis and focus on dealing with and providing the basic requirements in enhancing our bays

attraction (well lit, safe walking envionment) rather than rely on the larger tourism proposals – Comment Protect and

enhance the sytem of accessible green space - Our surrounding coastal AONB is the oldest and unique area and

must be protected at all cost - Comment

safety SPG and would be imbedded in design policies for the LDP. Specific policies will cover AONB, objectives do refer to natural environment.

Objectives-Particularly welcome the support for Swansea as an economically competitive place, the recognition

within the aims that new housing should be directed towards economically developable sites and that there is a need

for accessible, high quality employment infrastructure and facilities-Support

Support welcomed.

The Ferry facility still exists within Swansea Dock and could form an integral part of the transport strategy for the City. Comment noted.

Objectives address all aspects of physical, social and economic factors. Housing, however, is the key to

achievement of all objectives and I would suggest needs greater prominence and also needs to reflect diversity and

housing tensure e.g. affordable housing - Support

Support noted.

Objectives - We need affordable and/or social and eco housing not an estate of "executive housing". Comment noted. The LDP will be informed by an Affordable Housing study and various Housing Studies which provide a robust evidence base on the local housing market and housing need.

Objectives - The present transport system, schools, health centres, and waste systems canot support the present population in Loughor so how will it support the increase - Object

Objection noted, the LDP is informed by education, waste and health colleagues.

Objectives - Careful development of inner urban areas with high density and some mixed-use quality urban

development, might make significant contributions to resolving long-term challenges like reviving the city centre and

would redouble the sustainability of ambitious and prestigious developments such as SA1 Waterfront and those

based around the Hafod works which will depend for success on city connectivity and on local staff and users. And, with these sorts of strategic objectives in mind, we should aim to grow and attract new citizens - across the city

region. - General Comment

Env

ironm

enta

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omm

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Objectives (improve and expand diversity) - We should be concentrating on smaller issues and protecting what is

already in place.

(ii) Greenbelt Protection. Plaid strongly support that the Draft Vision and Objectives make explicit reference to the

protection of "accessible green-space" and the "interplay of town and country". However, we note with some dismay

that this stands in flat contradiction to the "Strategic Options" section of the consultation which outlines a major policy

shift in the direction of development on green-belt land. It is quite clear that that this shift is driven directly by the

Welsh Government itself and contradicts the current emphasis in Swansea's UDP on development on Brownfield

sites. Plaid are opposed to the removal of green-belt land for further development, and believe that much of this shift is driven by the need to accommodate the excessive housing targets set by the Statistical Directorate of the Welsh

Government. We support the democratic right of local communities to determine for themselves the level of housing

development that is appropriate to their needs.

Objective 17 highlights the concept of reusing brownfield sites, stating; ‘Promote a sustainable development strategy that prioritises the re-use of appropriate previously developed land, avoids significant adverse environmental impacts and respects environmental assets’.

The environment is not well served by building extensively on greenfield sites. This would only exacerbate our traffic

problems and cause more pollution. There would be more journeys across the city to work, school, leisure pursuits


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etc. Socially and economically the occupiants of out-of-town properties can suffer, as transport costs rise.

Objectives - I'm concerned about preserving village greens, allotments, play areas and urban green spaces. I believe the Council should lead the way with regard to renewable energy - Council properties could have solar

(photo voltar) cells fitted - General Comment

Objectives - In order to support the vision we must protect our village greens, playing fields, parks, allotments and

whats left of the character of villages in and around Swansea so there is less of continuous urban sprawl. Also

protect garden spaces and limit house building in gardens - General Comment & Objection

Objectives - It's important to preserve urban green spaces, play areas, playing fields, allotments, village greens. Don't squeeze existing amenities - General Comment

Comments noted. The forthcoming Open Space Assessment will help inform the LDP in this regard.

Although generally supportive of the draft objectives, currently they fail to demonstrate the linkages between various

objectives, particularly the importance of the environment to the economy and the community. We recommend that is brought out more fully in the Draft LDP. Unless it is clearly stated that individual objectives should be compatible

with other objectives and policies of the Plan, a number of objectives under Economic Prosperity and Lifelong

Learning have the potential to be in conflict with other Plan objectives. There should therefore be a clear statement within the Plan to states that objectives will be compatible with other objectives of the Plan, or where there is conflict, that they will be prioritised in the Plan.

(i) Population Projections. Plaid notes that much of the projected housing demand for Swansea over the LDP period

(2014 - 2026) is based on "Welsh Government Local Authority Housing Projections" compiled by the Welsh

Government's "Statistical Directorate". As such, Gower Plaid considers that these figures are top-down figures that have not been compiled in consultation with local communities. We further note that Swansea Council considers

these projections to be "unprecedented" and "unrealistically high", an analysis with which Gower Plaid would concur. It is worth putting the Swansea figures into the wider context, where the Welsh Government is proposing an increase

in the Welsh population by an additional 395,000 people by 2033. Effectively, this equates to the biggest shift in our

population since the last wave of industrialization in Wales at the start of the 20th century. In Swansea, Gower Plaid

understands that this will equate to an additional 29,000 households in Swansea by 2033 - an increase of nearly a

third. The impact of such a massive increase on the nature and character of our communities needs to be carefully

considered going forward. In light of these dramatic figures, Gower Plaid wishes to strongly object to the proposed

figures, and the way in which the Welsh Government have chosen to impose these arbitrary targets on Local Authority areas. Such a massive increase in the population of Swansea over the plan period, in an era of service cut-backs, is likely to place unprecedented strain on local communities and community services across a whole range of indicators, from traffic to provision of decent schooling to protection of our environment.

(ii) Proposed "Growth Areas". Based on these figures, Swansea Council proposes to accommodate this massive

increase in population around a number of "growth areas" across the City and County of Swansea. Given that much

of the City is already heavily developed, and the Gower peninsula is rightly protected as an Area of Outstanding

Natural Beauty (AONB), it is the considered opinion of Plaid that much of this increase will likely be accommodated

across the old Lliw Valley Borough Council area. As such, it is likely to lead to an unprecedented transformation in

the character of Lliw Valley communities, and place considerable strain on key services, particularly as budget cuts

continue going forward. We also note that much of this development is likely to be concentrated around the Burry

Inlet SAC/SPA area. Councillors and officers will be well aware of the status of the Inlet as a European protected site.

Support and comments noted.


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As such it falls under the remit of European Directives such as the Water Framework Directive, Habitats Directive

and Birds Directive. We note that the European Commission is already taking the Welsh Government to court over

potential breaches to some of these Directives. Gower Plaid considers that the tremendous amount of additional development posed in the LDP is likely to exacerbate an already over-loaded sewage system around the Burry Inlet, and that while extra investment has been proposed to upgrade sewage capacity in the area (particularly the Llannant Water Treatment Works) whether these upgrades will be enough to accommodate all the additional land allocation

proposed in the LDP. We note also that while the Stage 1 Strategic Flood Consequences Assessment places

considerable emphasis on fluvial flood impacts as outlined by Environment Agency criteria, additional consideration

needs to be given to pluvial flooding caused by culverting of streams and springs as housing development is

extended towards towards the Burry Inlet SAC/SPA.

We support the Council's challenge of Welsh Governments estimation of future demand for housing in Swansea

which we feel to be totally excessive and unrealistic Support noted.

Gen

eral

sta

tem

ents

CCW generally agree with the draft objectives. Support noted.

Categories of objectives are good. Some objectives are clear and give direction eg. Facilitate the sustainable

management of waste. Others are more aspirations than objectives eg promote equality of access to health, community, leisure and recreational facilities. Given the economic climate many of these facilities are under threat of budget reductions or closure. Some communities have little by way of facilities that they can access locally. People will be interested in timescales and estimated costs for the work on these objectives and the order of priority

that is to be given to them.

Need a link road from Tesco to Heol Pentre

- Support Objectives - AONB to be protected - Support Support noted.

Consultation. Gower Plaid would like to congratulate the officers in the LDP Unit of Swansea Council for their hard

work in compiling the Plan, gathering the evidence and their willingess to engage with the public and answer queries. This is laudable. However, questions must be raised about the value of the consultation exercise undertaken when

the likelihood is that locally agreed housing targets set by the Authority are likely to be over-ridden by unelected

Planning Inspectors appointed by the Welsh Government. In this respect, other authorities such as Wrexham and

Cardiff offer a salutary lesson in the willingess of the Welsh Government to over-ride local democracy in favour of statistical targets that bear no relation to real community need, or the condition of the housing market as it stands

today.

"The creation of a waterway for navigation, recreation and leisure linking the River Tawe with the Swansea Canal and Tennant Canal would provide a resource for the City, visitors and local communities. It would be of regional significance. It would enable the creation of a 35 mile waterway network linking with the Neath and Tennant Canals, helping to link with the wider Swansea Bay area and bring economic, social and environmental benefits. It would help forge a new vitality and identity for the 'east side' communities that deserve a vibrant vision for the City

as it emerges from the current economic difficulties. It would provide a linear green park and lung and the potential for waterside regeneration and revitalisation for communities including Port Tennant, St. Thomas, the Hafod, Llansamlet, Morriston, Ynystawe and Ynysforgan and Clydach. The UDP protects the line of the waterway through

the City. Now is the time to shape the future of the area and the LDP should embrace and promote the waterway as


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an unifying strategy for the City and east-side. The completion of the project is likely to extend beyond the life of the

current version of the LDP, but very significant progress delivering lengths of waterway, benefits and unlocking

waterside development potential is very achievable within the plan period. The Swansea Canal Society is

progressing work both in Swansea and Neath Port Talbot and welcomes the opportunity to work with the City and

Council of Swansa to bring this vision to fruition."

All your objectives are great but please remember that most of them require a certain percentage of the community

to be permanent rather than transient, therefore in areas where this is a high transent percentage the objectives are

going to be extremely difficult to achieve and therefore those areas either need special attention or need to have their

mix of transient permaent reduced

Noted.

These consultations are very expensive and I hope that local peoples opinions are being noted. Agreed, the Planning Policy Team has ensured that cost effective consultation methods have been exploited in order to ensure all have the opportunity to comment and get engaged with the LDP process. Representations are used by Officers to develop the next stage of the LDP production process.

Page 25 of the Vision and Strategic Objectives confirms that the Better Swansea Partnership developed a

Community Strategy and that this approach ensures that the aspirations of all interested parties are taken into

account. The membership of the Better Swansea Partnership does not include any housing developers whose

views were therefore not taken into account in the process

Noted, the Community Strategy is one influence on the LDP. Housing developers are consulted throughout the LDP process.

Given that the Gower Peninsula, part of the National Nature of Wales, nature at its best, with farm and villages, is at risk of being destroyed; a vision of the future must be placed in the minds of those who would destroy nature for

capital gain, under false claims, that fields in villages need to be turned into housing estates, that would destroy

village life of local country peoples, and turn a small peninsula into suburbia expansion, as if earth is expendable. A

warning from history, to blurry minds that, within a warning from history of towns peoples, depended on farm fields to

grow foods, or they all would have died from the lack of food. Not such a small thing, as it takes mass land to grow, only wheat for bread, and potatoes, not to mention vegetables, or mass grass land for cows and sheep etc. Towns

people are fools, but the rulers of towns are bigger fools; if you all think within verisimilitude, that within World Ward

Three, shops like Tesco would remain open to suit towns people, or that what was fields now housing estates, can

grow foods, to keep, millions of towns people alive, when all things go wrong, "as it will". Officialese, is that that do's

not know, what the Home Guard is, and without foods, all the children are dead. Let me enlighten you all, that rile if, you have the means to understand; Syria, Iraq, Iran, Afghanistan, Pakistan, Lebanon, Israel etc. etc. is about to

explode, "mixeing", with the situation going out of control in Greece, Spain etc. etc. that may well start World Ward

Three. OK, or are you blind. Given that a World War starts; most of the police, would go with the army, navy, airforce, and ALL 16 year olds to 60 year olds; all going to War, the other side of the world (a bit like World War Two); that leaves children, women, the ill, and the old left within the British towns, millions all depending on foods, from fields in

villages. But if it is up to you who rule, you get rich now, and the mass peoples die then. What you do today is the

continuation of yesterday that determines the end of lives. To look in the childrens eyes is to tell them lies, if land

development turns fields into means of unableness to feed them life. Who then has the only gain, to turn fields into

housing estates; oh yes, the rich. Now is the time, that the police, army, navy, airforce, and home guard speak out loud, to say, no to land developments on fields that grow our childrens foods. Furthermore to the blind who can not

Comments noted.


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see, "or" no not wish to see. "See" Russia Today News on Freeview 085. This new shows the true situation how

World War Three is near. It do's not lie, like the BBC. "Your" childrens lives depend on "you" looking at Russia today

news freeview 085 (each day passing). Moreover; how soon you all forget that, the hole in the ozone layer, greenhouse effect, as icecaps melt to sea level rise, as the weather systems change for the worst, all is a danger to

earths magnetic field, that can lead to quaqua-illiquation-inglobatation, if the wise do not wake up. As that, Israel being trapped within the Middle East wars etc., would press a nuclear button, to defend itself, being fools. What a

future the children have; but I see what is going wrong, why must it start with you. This letter must be put on the

database all have a right to read it. If you fail to do so you fail all children. I Mr G A Morris born in the village in Gower, now age 64 ¾. "Facts" hurt so do's dieing.

The aspirations set out in the Vision document are what we would all like to see developed in Swansea. A firm

commitment is required from the current and future administrations to drive these forward and demonstrably achieve

them.

Comments noted.

The Objectives elaborate the Vision in a useful way, but are still at a high level of abstraction. We have no quarrel with the Objectives as outlined, but the real questions are a. What practical steps are to be taken to achieve these

Objectives? And b. How are problems to be resolved, or priorities identified, when the practical application of an

Objective in one domain (e.g. Economic prosperity) conflicts with an Objective from another domain (e.g. Quality

Environment)? In general terms, The Gower Society is supportive of the Vision and Objectives, while recognising

that it is in the implementation of these aims - rather than the aims themselves - that the problems will arise.

Noted. Policies will be written in line with the Objectives which will ensure deliverability of the Objectives.


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Strategic Options

Action/Theme

Representation Proposer & Ref ID

Introduction

Could not find an introduction - Objection C Humphreys 41462

Estimated timescales for the production of the Preferred Strategy and Deposit Plan would be useful if included in this section - General Comment Asbri Planning 41565 41569

Section 1

Pro

ject

ion

Fig

ures

The background document: "Population and Household Projections" provides statistical information on Swansea's recent population growth and shows numerical data which evidences trends in population but without attempting to explain why these trends are occurring. For example, why is there a net in-migration into

Swansea in the last decade? It seems unrealistic to base major policy decisions on trends without understanding to the trends are generated and why. There

seems to be an over-reliance on WG data and projections without any detailed local analysis. Research into the causes which are generating changes in

population locally should be made - is net in-migration due to workers relocating to a growing economy, an increase in retirees, an increase in students, etc? Is the

growth sustainable and what is its nature? This information is needed to inform the projection scenarios. In addition, there appears to be no policy in relation to how

population change is to be managed, or if there are is any vision about what Swansea wants to be. In other words, this is a passive or reactive plan. There are

"Issues Papers" but these are not integrated into the planning strategy in a way that gives an overall vision, they are 2 page sheets with some notes on particular

themes. For examples, the Tourism Key Issue paper mentions that the "prime natural tourism resource is the landscape, in particular Gower's countryside and

beaches, the upland countryside areas and around Swansea Bay" but this is not articulated into a unified vision, nor are the impacts of some of the spatial options

addressing this - General Comment


Alternative growth scenarios. The council has provided a number of alternative growth scenarios, which they believe might provide a more robust basis for the housing

requirement that the WG's household projections. In this respect, we are concerned with the assumptions used to justify the various alternative scenarios. Home

Builders Fed

41538

We believe the Council should adopt the level of growth set out within 2008 Welsh Government Household Projections as a minimum. We do not believe robust evidence has been provided to deviate from the household projections. The council states that a preferred option has not been chosen as yet, however the WG

projection has clearly been discounted, given that is has described it as "unrealistically high" (parap 1.14 of the consultation document refers). In this respect, we

do not believe sufficient evidence has been provided to conclude that the WG projection is "unrealistically high". We common on this as follows:- The need for

affordable housing. In terms of the use of the projections to identify housing requirements within LDPs, paragraph 9.2.2 of PPW states the following - "Where local planning authorities seek to deviate from the Assembly Government projections, they must justify their own preferred policy-based projections by explaining the

rationale behind them in terms of the issues listed at paragraph 9.2.1 above." Paragraph 9.2.2 also states specifically that local planning authorities should

consider the appropriateness of the latest WG projections for their area, based upon all sources of local evidence, including the need for affordable housing

identified by their Local Housing Market Assessment. In this respect, the extent to which the need for affordable housing has been taken into account when

deciding whether or not to adopt the WG household projections have been completely omitted from the evidence base. This is a clear contradiction to national guidance and therefore, must be addressed before any deviation from the household projections is proposed. This matter must also be addressed before any

'preferred strategy' for housing growth is chosen, as clearly without this important evidence, neither the Council nor stakeholders can make an informed decision

Home

Builders

Federation

41538


Sw


ent Plan

as to the level of housing growth that would be appropriate for the LDP.

Net migration and population change The council suggests that net internal migration in recent years is lower than that which was experienced in earlier part of the

decade. However, merely focussing on net internal migration, without considering the other components, fail to recognise the overall increase in net migration, and population change, experienced in the area in recent years. For example, the Table 2 below shows population change and net migration in Swansea over the

period 1991 - 2010. Table 2 - Population and migration change 1991-2010 (Refer to file for details). As you can see from the table above, both natural change and

net migration have been increasing in recent years, which highlights a marked change when compared to the levels of growth experienced in earlier years. This, we believe, justifies the consideration of a relatively short time period in history in order to draw conclusions on how migration and population change might pan out in the future. Particularly, given that considering longer term trends would include levels of population decline and out-migration, which one assumes, the council would not want to actively plan for in the future. However, further investigation of the table also shows that the period used to inform the 2008 house projections

(2003-2008) might itself portray a rather pessimistic view of how population change might occur in the future, which implies that the 2008 projections should be

considered the minimum level of growth for the LDP. For example, net migration over the period 2003-2008 is very similar to that which has occurred in most recent 5 year period (2005-2010). However, the figures for natural change are clearly more positive over recent years, when compared to the 2008 projection

period, which means overall population change has been more positive in recent years when compared to the 2008 household projection period of 2003-2008. The overall figures also support this view, given that overall population change between 2003 and 2008 was 3700 people, but for the period 2005-2010 it was

recoded as 4800 people. In light of the above, we do not believe the Council's assertion that the 2008 projections have been 'overstated' because population

change has now slowed compared to the period 2003-2008. Clearly population change has increased in more recent years, which demonstrates that the 2008

projections should not only be considered sound, but should be considered the minimum level of development the LDP should plan for, to ensure the authority

does not experience any unnecessary future decline.

Home

Builders

Federation

(Richard

Price) 41538

University and HE Issues The council cites potential issues with the sustainability of current levels of student enrolment at Higher Education (HE) institutions, which may or may not have implications to Swansea. However, there is absolutely no evidence to make a direct correlation between these concerns and the level of development proposed by the household projections. These are high level issues, which cannot possibly be used to justify deviation from the household projections.

Home

Builders

Federation

41538

I think that, on the face of it, it is reasonable to use 2004-2009 migration figures rather than 2003-2008. However, is Swansea wants to be a vibrant City & County, it must have sufficient housing available at a range of prices to support an influx of people wishing to live here. Restricting housing allocation at this time is more

likely to push up housing costs which works against inward migration. I don't think using a longer-term (10 year) view of fertility and mortality is better. Using more

recent trends is more likely to be more accurate - especially with increasing life expectancy. I think the alternative projections are likely to underestimate the

housing requirement - especially alternative projection 3 - Objection

A W G Stone

41330

There is no evidence within the document or background documents to conclude that the Wales Government Projections i.e. the Baseline Scenario are

'unrealistically high'. Robust evidence to deviate from these projections is required. The options for growth set out do not provide robust evidence to consider any

alternative but the Wales Government Projection. - Object

Ms Philippa

Cole 41512

PPW states that "the latest Assembly Government local authority level Household Projects for Wales should form the starting point for assessing housing requirements"

and PPW only allows for deviation from these figures where appropriate justification is given in relation to a range of defined reasons relating to e.g. social considerations, the needs of the local and national economy, environmental implications etc (see PPW paragraph 9.2.1 for details). Bearing in mind the provisions in PPW, we are

concerned that the justifcation in paragraph 1.13 and the background documents is lacking and does not fully justify the proposed deviation from the latest projections. In

the absence of any appropriate justification, and in light of the Plan's aspirational vision which aims for economic growth, the figures set out in the WG projections should

form the basis for the housing requirement in the forthcoming Plan. These figures represent the most up-to-date population and household data for Swansea and will therefore ensure that the Plan delivers the necessary housing, in line with emerging requirements for both open market and affordable housing. Furthermore, it is important to highlight that none of the alternative scenarios put forward in the plan relate to an employment-led scenario (they are all demographic led). This approach fails to

consider the alignment between employment and housing. Swansea as with Wales generally has an aging population. It will therefore be essential that appropriate levels

of net in-migration are achieved to ensure an adequate workforce is available. The Council should not be seeking to constrain future housing on the basis of past levels of

41547, 41544


Sw


ent Plan

delivery. The reasons for lower build rates will relate to a number of factors including the nature of supply as well as economic conditions. Instead the level of growth should

start with the policy neutral WG household projections which should then be assessed against labour force requirements with additional consideration given to evidence of backlog to unmet need for affordable housing. - Objection

Planning for Population and Housing Growth 3.3 We strongly support the Council's recognition that the calculation of the number of new homes required to meet population growth is critical to the successful delivery of the LDP. Effectively planning for future population and housing growth will be fundamental to the delivery

of the vision and objectives set out in the Vision and Objectives Consultation Draft. 3.4 We also strongly support the Council's acceptance that there is a direct relationship between planning for housing growth and economic growth and new job opportunities for Swansea. This link is essential if the objectives relating to

Economic Prosperity and Lifelong Learning are to be realised. 3.5 It is noted that the Council's study into likely scenarios for economic growth and employment land provision over the LDP period (as referred to in Paragraph 1.2) has not been available during the consultation period. Similarly, the appraisal of community

facilities, urban capacity ad infrastructure provision is not currently available. As recognised in the Strategic Options Consultation Draft, these issues will influence

the scale of land required to facilitate development and the selection of the most appropriate locations for new land use allocations. Our comments are therefore

based on the information currently available. 3.6 We support the Council's recognition that it must take account of the latest Welsh Government (WG) Local Authority Household Projections for estimating future housing growth requirements. It is therefore appropriate that the Council draw on the latest WG figures as

the 'baseline' scenario for planning for population and housing growth. 3.7 It is noted that the Council has also considered alternative scenarios to this 'baseline' position. Recent correspondence from the WG and the Planning Inspectorate relating to the soundness of LDPs has clearly stated that Council's must take

account of the latest WG Local Authority Household Projections when planning for population and housing growth, unless there is compelling and robust evidence

to suggest otherwise. The Council must therefore carefully consider the projections and assumptions used in order to ensure that the plan is sound. 3.8 We

strongly support the Council's recognition that a zero growth scenario is considered unviable and would be fundamentally 'unsound'. Such an approach would

clearly fail to deliver the draft 'Vision' and 'Objectives' set out by the Council. Welsh Government Projection (Baseline Scenario) 3.9 Of the four potential scenarios

presented in the Consultation Draft document, we strongly support the use of the Welsh Government Projection (Baseline Scenario). Whilst recognising the

concerns raised by the Council, the Welsh Governmen projections should not be considered 'unrealistically high' without further testing and assessment. 3.10 To

deliver the vision and objectives of the LDP it is essential that the document plans for sufficient levels of housing growth over the plan period. An under provision of housing growth would undermine the key objective of developing Swansea as a regional economic driver and ensuring that the existing, and future, populations

have access to good quality housing. By underplaying the levels of growth on the basis of recent economic trends, there is a risk that the plan will fail to plan

positively for future growth across the LDP period. It is therefore essential that the LDP deviates from the latest WG projections only if robust evidence can be

presented.

Stephen

Pilliner 41535

2. Strategic Options. (i) Population Projections. Plaid notes that much of the projected housing demand for Swansea over the LDP period (2014 - 2026) is based

on "Welsh Government Local Authority Housing Projections" compiled by the Welsh Government's "Statistical Directorate". As such, Gower Plaid considers that these figures are top-down figures that have not been compiled in consultation with local communities. We further note that Swansea Council considers these

projections to be "unprecedented" and "unrealistically high", an analysis with which Gower Plaid would concur. It is worth putting the Swansea figures into the

wider context, where the Welsh Government is proposing an increase in the Welsh population by an additional 395,000 people by 2033. Effectively, this equates

to the biggest shift in our population since the last wave of industrialization in Wales at the start of the 20th century. In Swansea, Gower Plaid understands that this

will equate to an additional 29,000 households in Swansea by 2033 - an increase of nearly a third. The impact of such a massive increase on the nature and

character of our communities needs to be carefully considered going forward. In light of these dramatic figures, Gower Plaid wishes to strongly object to the

proposed figures, and the way in which the Welsh Government have chosen to impose these arbitrary targets on Local Authority areas. Such a massive increase

in the population of Swansea over the plan period, in an era of service cut-backs, is likely to place unprecedented strain on local communities and community

services across a whole range of indicators, from traffic to provision of decent schooling to protection of our environment.

Mr Jim

Dunckley

41557

In terms of Section1, regarding Planning for Population and Housing Growth, we support the projections based on the Welsh Government household projections (2008-based). It is our view, the city of Swansea is a sustainable location, playing host to a diverse range of retail, services, community facilities and employment provision. As

such, and to accommodate the growing requirements of the city, Swansea should accommodate growth in preference to its less sustainable hinterland and countryside

locations. Furthermore, departing from the Welsh Government projections is likely to draw criticism and, in other Local Authority areas, has contributed to LDPs being

Peter Waldren

41571


Sw


ent Plan

found 'unsound' at Examination. If Swansea's regeneration aspirations are to be fulfilled, investor confidence must be supported and certainly must be provided. Accordingly, adopting a growth strategy which materially departs from the Welsh Government projections should be avoided. Furthermore, taking into account the slow-down in house building as a justification for departing from the Welsh Government projections, is not a sound basis upon which to proceed. The slow down in building rates

is principally due to the limited availability of credit temporarily suppressing demand. Demand for housing is likely to increase and return to its former level (or greater) as

the current economic recession passes. Given the requirement for the LDPs to take a long term view, it is not considered appropriate to take account of this factor. - The

proposed level of growth needs to be based on sensible built out rates and population data. If the proposed level of growth deviates from the latest Welsh Government Household Projections the plan needs to contain a rgorous and sound analysis to support its position. The examples of the Cardiff and Wrexham LDP's should be at the

forefront of considerations on the level of growth to be adooted. In these cases the lack of robust evidence to deviate from the WG growth ffigures led to the withdrawal plans, signifcant delays in the production of an LDP and a planning policy void. In the case of Cardiff this has led to a damaging impact upon housing land supply and the

local economy. Any deviation from the WG must therefore be robust and subject to rigorous testing. - Whilst support from the Welsh Government (WH) is important, the

level of growth proposed needs to be appropriate for the Local Authority. Whilst the WG figures are a helpful baseline and starting point, it is recognised that they do need to

be subject to a series of 'sensitivity' tests and adjustments in light of more recent data and changes (notably more recent WG projections due to be published 2013 a2011

Census data), migration rates, past build rates and projected economic growth. - The preferred level of housing growth requires practical and commercial support to the

strategy and its level of ambition. This ambition needs to be reflected in the deliverability of the plan, otherwise there runs the risk of under performance. - The preferred

level of growth ought to be sufficient to deliver land which can provide for a range of choice for housing. Moreover, Planning Policy Wales (2011) states that LPAs must ensure that sufficient land is genuinely available or will become available to provide a 5 years supply of land for housing. Such sites must be free, or readily freed, from

planning, physical and ownership constraints, and economically feasible for development. There must be sufficient sites suitable for the full range of house types.

Alte

rnat

ive

Pro

ject

ion

1

Alternative Scenario 1 (2004-2009 Migration Rates) 3.11 It is recognised that the Council has introduced Alternative Scenario 1 on the basis that it uses average rates for the 2004 to 2009 period for internal and international migration. In doing so, it is argued that the scenario takes account of the onset of the current economic crisis, and to

some extent, would include any emerging resultant effects on demographic change. 3.12 The LDP period, however, covers the period to 2025 and as such must plan for the

long term growth of Swansea. The Consultation Draft document itself notes that fundamentally the LDP aims to facilitate sustainable growth over the next decade and

beyond. It is important that this long terms growth is not unduly restricted by emerging trends resulting from the economic crisis. Instead the scenario should enable the

LDP to plan for sufficient growth to support its subsequent recovery. 3.13 We would therefore only support the growth levels set out in Alternative Scenario 1 if a robust case

could be put forward by the Council to justify the move away from the latest WG figures. Equally, should the Council decide to proceed with Alternative Scenario 1, this

figure should be considered to be a minimum level of growth - rather than a maximum target.

Stephen

Pilliner 41535

Alte

rnat

ive

Pro

ject

ion

2

Alternative Scenario 2 (1998-08 fertility, mortality and internal migration rates) and Alternative Scenario 3 (2006-09 internal migration rates) 3.14 Both Alternative

Scenario 2 and 3 mark a substantial departure from the levels of population and housing growth required by the latest WG projections. We strongly object to the

use of either scenario and consider that this approach would undermine the vision and objectives presented in the Consultation Draft. 3.15 Providing such low

levels of growth over the plan period would seriously constrain growth and undermine the Council's objective of successfully positioning Swansea as a regional economic driver. The levels of growth set out in Alternative Scenario 2 and 3 are not sufficiently ambitious and as a result will limit access to good quality housing, and fail to support the economic growth required over the LDP period. Sufficient evidence has not been provided to support such a significant divergence from the

latest WG projections.

Stephen

Pilliner 41535

CCW considers that Alternative Projection 2 provides the most realistic projection for growth for the period of the LDP. CCW 41558

Alte

rnat

ive

Pro

ject

ion

3 Alternative 3 different time frames are used for forecasting the different components of population growth. This clearly does not represent a consistent and robust

approach to forecasting the future requirement. It is considered that the housing requirement identified in the LDP should be at least 18,600 dwellings which

equates to an annual requirement of 1,330 units per annum in line with the Welsh Household Projections (2008-2033). The three alternatives put forward are not acceptable. In this regard the proposed level of housing will not deliver the Objectives of the LDP, particularly the objective to 'Ensure that communities have

sufficient, good quality housing to meet their needs'. When the results of the economic growth assessment are available the Council must ensure that they identify

sufficient housing to support the economic growth aspirations of the authority - Objection

Zoe Abberley

41406

P r oj eTo summarised, it is our view that the alternative projections 1, 2 and 3 for housing underprovide as opposed to overprovide (as other Authorities are doing) for

housing growth - an approach which is inconsistent as a result with the drive to restimulate the housing market. Accordingly, it is considered that the WG

Penllergaer Estates Ltd c/o


Sw


ent Plan

projections should be adopted, with an additional contingency provided to allow for flexibility over the Plan period. Please refer to the accompanying cover letter

and annex for our detailed case (refer to file for documents) - Object to alternative projects 1, 2 and 3. Geraint John Planning 41469

It is evident that due to the economic difficulties facing Swansea at present, it like other parts of Wales is unlikely to meet its UDP housing delivery targets, which in

turn results in a deficit of provision. This does not appear to have been factored in to any of the population projection options and proposed housing provision

targers referred to in Section 1. In order that the LDP is to be prepared on a sound basis, this should be explored and taken into consideration.

Jason Evans Planning 41445, 41506, 41505

Housing Growth Scenarios - We note that, although there is a lot of information on projections and rates, the representation form does not ask for views on the

proposed levels of housing growth (we doubt this is the purpose of question 7 given its significance). This is worrying because a decision on which level to pursue

will in many ways drive the selection of the strategic spatial options. Our view is that great care needs to be taken in this respect as whilst we understand the

pressure that Welsh Government is placing on authorities to follow its projections, the LDP exercise is meant to produce a realistic and deliverable forward plan. We expect that further consultation on sensible (and not just statistical) levels of growth will follow and these may be guided by appropriate sensitivity testing and

more recent data and charges.

Tim Gent

41524

Gen

eral

Com

men

ts

As previously stated, multi-generation housing mau have to become the norm, so larger homes may be required in addition to improved existing stock of the older

housing in central areas of the city - Comment F Ferguson

41552

Household growth etc. needs to address housing tenure types through Housing Market Assessments - General Comment J Hughes

41326

Following the proposal by the Welsh Government that 18,000 new dwellings will be required in Swansea up until 2025, I would comment as follows:

The object is to produce an LDP which reflect the local distinctive needs of its communities with sustainable development without comprising future generations to

meet their own needs. Surely the long term protection of sites that have no reasonable prospect of being used for that purposes should be regularly reviewed; applications for alternative uses of the land or buildings should be treated on their merits. The LPA should identify and bring back into residential use of empty

housing and buildings in line with local housing and empty homes strategies. The LPA should normally approved planning applications for change to residential use and any associated development from commercial buildings (currently Class B) where this is an identified need for additional housing in the area, provided

that there are not strong economic reasons why such development would be inappropriate.

Welsh

Assembly

Government

(Byron Davies

AM) 41519

The projection that 18,000 new dwellings will be needed - most of this will have to be affordable/housing association - not the luxury end of the market. C Humphreys 41462

If its given that some 18,000 new dwellings are requested by 2025 then this must happen without compromising existing urban green spaces, allotments, village

greens, parks and play areas. It's the lesser of two evils that less accessible space is used for new development. It's important not to squeeze the space out of existing urban areas.

Peter May

41354

Section 1 - There is always an assumption that the only way of coping with population growth is by new-build. Why is there no mention of regeneration of existing

older housing stock, particularly 2 storey terraced houses that have become HMO's? These could be reconverted to family homes when they come on the market, with incentives for young families to move in. Also discouraging development of more HMO's. Encouragement to universities to provide their own accommodation

on campuses - Objection Comment

Sandy Johns

41591

We object on the basis that the Welsh Government Option should be considered as one of the Alternative Growth Scenario's, rather that being dismissed as

unrealistic. Whilst the scale of growth would be unprecedented, as is stated all Councils are required to have regard to these projections (the accompanying

supporting submission elaborates on this) - Objection

Asbri

Planning

41565, 41569


Sw


ent Plan

The Council dismiss the Welsh Household Projection's requirement, stated that they over state population growth in Swansea between 2008 and 2033 for a

number of factors. However, the rationale and robustness of the reasons are considered to be questionable. Whilst due to changing economic conditions and

indicators house building rates may have fallen in recent years, this does not remove the need for new housing to be provided to meet the needs of the local community. It is widely recognised that Britain is facing its worst housing criticise since World War 1, with housing completion rates continuing to fall. Identifying a

reduced housing requirement on the basis of recent trends does not comply with the Welsh Governments objectives as set out in the Homes for Wales - A White

Paper for Better Lives and Communities which aims to increase the supply of housing in Wales to ensure everyone gets a decent home. To state in paragraph 1.14

that: 'Fundamentally the Welsh Government projections are considered unrealistically high and would require a level of development unprecedented in recent years.' Does not provide a robust justification for deviating away from the Household projections in accordance with the requirements of PPW (paragraph 9.2.2). The three alternative scenarios put forward simply do not provide enough housing to meet the housing needs of the authority of Swansea and ensure that everyone gets a decent housing in accordance with the Housing White Paper and paragraph 9.1.1 of PPW. Data published by the ONS in February 2012 confirms

that internal and international migration rates have not declined and remain at record high levels. Therefore Alternative 1 is not considered to offer a robust alternative to the Household Projections. Alternative 2, five year periods are recognised as and are considered to be a robust basis on which to base forecasts.

Zoe Abberley

41406

How can there be a need for so many new homes when so many existing homes are left empty. All that will happen if you build more is the existing homes will remain empty - Object

Mr David

Powell 41461

At preset the documentation does not set out within the population growth data a split between family homes, flats, student accommodation, affordable homes or

up-market developments. While reliant upon the property market to make schemes viable, it would be appropriate to identify a broad based strategy. Swansea

Civic Society

41513

The Strategic Options paper deals with one specific aspect of projected population growth: housing. Other related topics such as the provision of infrastructure, facilities and employment are not considered. We are not in a position to comment on the four projections for population and housing growth, but note the very

large margin of difference between the highest and the lowest projections. It is difficult to see how a firm spatial plan for housing can be built on such imprecise

figures.

The Gower

Society 41593

We cannot find any mention in the Strategic Options document of your existing infrastructure. Growth has to have a starting point and your existing community

infrastructure should be assessed before proposals are put forward to provide new services for an increased population. The Theatres

Trust 41452

It is important to maintain the balance of Welsh speakers in the wards. No extra cost burden should be placed on the electorate. Developers should pay the full cost of any infrastructure changes or requirements. I favour a population growth option in line with comments in 1.24 and therefore favour Option 3 - General Comment

J Waygood

41539

Q7. Section 1 Planning for Population Growth Given that it is more in line with Swansea's mid year estimates for the last 10 years, CCW considers that Alternative

Projection 2 provides the most realistic projection for growth for the period of the LDP. Section 1 The Spatial Options for Growth CCW welcome the recognition that new development areas must be served, or be capable of being served by appropriate infrastructure. This should include appropriate levels of green

infrastructure to enable connectivity (important for both biodiversity and the landscape and character of the area) between the green reservoirs and corridors

within the urban area and the wider countryside, and to provide satisfactory levels of open space for recreation and well being purposes. We also welcome the

recognition that the impacts of development on environmentally sensitive areas will be an important consideration in considering the suitability of future land

allocations.

Countryside

Council for

Wales 41558

(ii) Proposed "Growth Areas". Based on these figures, Swansea Council proposes to accommodate this massive increase in population around a number of "growth areas" across the City and County of Swansea. Given that much of the City is already heavily developed, and the Gower peninsula is rightly protected as

an Area of Outstanding Natural Beauty (AONB), it is the considered opinion of Plaid that much of this increase will likely be accommodated across the old Lliw

Valley Borough Council area. As such, it is likely to lead to an unprecedented transformation in the character of Lliw Valley communities, and place considerable

strain on key services, particularly as budget cuts continue going forward. We also note that much of this development is likely to be concentrated around the Burry

Mr Jim

Dunckley

41557


Sw


ent Plan

Inlet SAC/SPA area. Councillors and officers will be well aware of the status of the Inlet as a European protected site. As such it falls under the remit of European

Directives such as the Water Framework Directive, Habitats Directive and Birds Directive. We note that the European Commission is already taking the Welsh

Government to court over potential breaches to some of these Directives. Gower Plaid considers that the tremendous amount of additional development posed in

the LDP is likely to exacerbate an already over-loaded sewage system around the Burry Inlet, and that while extra investment has been proposed to upgrade

sewage capacity in the area (particularly the Llannant Water Treatment Works) whether these upgrades will be enough to accommodate all the additional land

allocation proposed in the LDP. We note also that while the Stage 1 Strategic Flood Consequences Assessment places considerable emphasis on fluvial flood

impacts as outlined by Environment Agency criteria, additional consideration needs to be given to pluvial flooding caused by culverting of streams and springs as

housing development is extended towards towards the Burry Inlet SAC/SPA.

3. Strategic Options 3.1 Section 1. Planning for population and housing growth3.1.1 We have no comments regarding the proposed population and housing

figures or projections for the plan period. EAW 41579

Section 2

Gen

eral

Com

men

ts

We note in para. 2.3 that a strategy will be proposed for the regeneration of the city centre and we hope and expect that the Preferred Strategy document will contain a section devoted to this topic. Continuing on the theme of city centre infrastructure, especially for community facilities, so that future requirements can

be determined in harmony with your existing cultural and community assets.

The Theatres

Trust 41452

We note at Section 2.4 that the document states that "In advance of the LDP coming forward sites allocated in the UDP will continue to be considered suitable in

principle of development.". This is an extremely dangerous assumption, as during the UDP preparation process national planning policy did not require LPA's to

ensure that allocations were deliverable. PPW Edition 4 now specifically requires this to be the case and so all UDP allocations must be shown to be deliverable

if they are to form any part of the LDP process. - Object

Jason Evans

Planning

41445, 41506, 41505

The Spatial Options for Growth 3.16 We support the recognition in Paragraph 2.5 that new development areas must be served, or capable of being served, by

appropriate infrastructure. We also agree with the links drawn between the delivery of this infrastructure and economic viability and financing of development. Economic viability must be considered as an integral part of the assessment process when determining the Council's preferred strategy. Failure to take account of this will lead to insufficient new development and supporting infrastructure coming forward over the plan period. 3.17 We agree that potential areas of constraint must be taken into account when considering the spatial options for growth. These constraints must, however, be carefully considered and balanced

against the ability to mitigate for any impact and the wider benefits of development. The suitability of future allocations should therefore be carefully considered, ad not necessarily ruled out without considering the potential for migration. This is evident when considering the potential impacts of future allocations on the

Burry Inlet and Loughor Estuary drainage area. 3.18 Whilst the overall aim of maximising appropriate brownfield land is supported, it is essential that that LDP

achieves a suitable balance with suitable greenfield allocations. We strongly support the Council's recognition that a 'brownfield only' strategy is not deliverable

and would be 'unsound'. As referred to above, economic viability and financing the delivery of development must be an integral part of determining spatial options for growth. In doing so, it will be necessary to direct a significant proportion of new development to greenfield sites. 3.19 Having reviewed the four broad

strategic options presented in the Consultation Draft, we are of the view that an alternative strategy should be brought forward through the Preferred Strategy. This strategy would combine elements of the different options presented by the Council to deliver the vision and objectives presented in the Consultation Draft.

Stephen

Pilliner 41535

There needs to be a more detailed analysis of how each approach will impact on the overall geography of the Swansea as a region. The Strategic Options

Concept Plan uses symbols to indicate options without provided more detailed analysis. For example, will urbanisation along the neck of Gower cut off the rural areas of the peninsula from north Gower? The "Mixed Use Major Development Area Options" of Llangyfelach, Felindre, Garden Village and Fforestfach indicate

that this could occur. What are the negative implications for tourism and the rural economy on the spatial plan objectives? If the Gower AONB was to be

extended into north Gower, this may have tourism and economic benefits. How will the urban expansion across the neck of Gower affect this potential? -

General Comment


I can see the attraction of large-scale development-a new town or settlement - as it could be designed to provide sustainable, low impact homes with associated A W G Stone


Sw


ent Plan

facilities. However, this should not be at the expense of brownfield sites not sustainable expansion of existing communities. With people living healthier, longer

lives and prefering to stay in their existing homes which hold so many memories, the supply of housing to young families in our small towns and villages reduces. If no new houses are built, these young families are forced to move away which has a detrimental effect on the balance within the community-affecting the local primary school, village hall, shops etc

41330

Section 2 - As in section 1. This would result in less need to develop outwards with all the implications of new infrastructure etc – Comment S Johns 41591

Care must be taken to keep the 'urban form' so that communities do not get too big and lose their local identities - General Comment J Waygood

41539

Overall, we take a relatively neutral view in respect of the spatial options set out at Sections 2 and 3 of the Strategic Options document. However, our client supports the use of Brownfield and previously development land to ensure sustainable use of the built and natural environment. Furthermore, allocations and

extensions to existing settlements should be dealt with in a sustainable manner, taking account of the need for appropriate retail uses as part of any mixed-use

allocation in order to meet sustainability objectives and reduce the need to travel. We would be grateful if Swansea City and County Council continue to consider

SSL as a key consultee within any further consultation of the LDP process.

Peter Waldren

41571

Dev

elop

men

t/Eco

nom

ic

Rural semi-rural extension are best wherever they can enhance communities' sustainability - particularly with regard to poverty reduction and to their ability to

support local work and shopping hubs, and to make sustainable integrated (bus) transport routes, as emphasised in the initial Wales City Regions task-and-finish group report, more viable. Tircoed, Morriston South, Blaenymaes etc. Where the main aim of these extensions is to find easy ways to meet housing need

targets by pinning some extra homes to a desirable area, they should be resisted - above all where they would expand into truly rural areas of the Gower or north

Swansea which are necessarily more isolated than spots closer to the sustainable urban core - General Comment

Mr Alfie Stroud

41548

It is considered that a spread approach is required, which would seek to ensure that the housing needs for all areas across the County are provided for, whilst also ensuring that the ships, services and facilities within settlements are supported and sustained. A mixture of brownfield and greenfield sites, in a variety of sixes and locations are also required in order to ensure that a robust, viable, and deliverable strategy is provided to meet the vision and objectives of the Plan. Please refer to the accompanying cover letter and annex for our detailed case. (Refer to file for documents). - Support spread approach.

Penllergaer Estates Ltd c/o Geraint John Planning 41469

It is agreed that the issue of economic viability and financing the delivery of development should be an integral element of the assessment process (see

paragraph 2.5). Ensuring allocated sites are deliverable and viable is vital in order to ensure the plan is deliverable but also flexible enough to deal with changing

circumstances (in line with the LDP soundness tests). As outlined above, we consider that this can be best achieved through the pursuance of the 'Option 1

Spread Approach large and small edge of settlement allocations strategic options' which allows for a range and choice of sites. We are concerned that the

existing UDP contains a large number of allocations that have failed to come forward over successive plan periods. These sites should not be removed and

replaced with deliverable allocations. It is also agreed that a 'brownfield only' strategy (see paragraph 2.12) is not a viable or sound strategy for the plan. We

therefore welcome the recognition that both brownfield and greenfield sites will need to be developed in order to meet Swansea's future needs and the Plan's

vision. - Support - Option 1 Spread Approach

41547, 41544

When there are brownfield sites left undeveloped it seems crazy to look at development greenfield sites - Object D Powell 41461

Concern has been expressed that the current and future highways department schemes do not come under effective and integrated planning controls. How is

this to be addressed within the Strategy, Policy and Proposals? Swansea Civic

Society 41513

Economic Indicators There is nothing within the background evidence to provide a casual link between the 'economic indicators' mentioned by the council and

the level of growth stated by the household projections. As such, there is absolutely no way to ascertain whether or not these 'economic indicators' would mean a

higher or lower level of growth that that which is provided by the household projections, or indeed by any of the alternative scenarios put forward by the council in

the background paper. In addition to this, to base the LDP housing requirement on anecdotal pessimism with respect to the future of Swansea's economy, we

believe would be counterproductive and is likely to result in a self fulfilling strategy which would risk the area experiencing decline. We believe the LDP should

Home Builders

Federation

(Richard Price)

41538


Sw


ent Plan

adopt a progressive and forward thinking strategy and should endeavour to create the right conditions for regeneration and investment, in order to ensure

Swansea (and indeed Wales a whole) make a full and swift recovery from the recession. House building levels We are aware of the effect the recession has had

on the housing market in Wales, however, we do not believe this should be an excuse for the LDP to adopt a negative strategy that actively plans for lower levels

of growth. As we have mentioned above, the LDP strategy should set the right conditions for development and should ensure that a range and choice of housing

sites is made available to support house building levels, irrespective of the prevailing economic conditions. Further to this, if previous development rates in

Swansea are considered (see Table 1 below), there is a noticeable rise in house building levels over the recessionary period, akin to the levels proposed by the

household projections. This not only supports the adopted of the projections, but should also serve as a warning sign to the adoption of a pessimistic or negative

house building strategy, given the potential for the authority to delivery housing despite the challenging market. Table 1 - Previous development rates in

Swansea (Refer to file for details).

Links between Job Growth and Housing We believe the link between job growth and housing will also be an important component to consider when identifying a

suitable housing requirement. The council suggests that more work will be undertaken in this regard, which we are keen to view. However, as with the need to

consider affordable housing above, we believe this issue must be addressed before any preferred strategy for housing growth is chosen, and stakeholders must be given the opportunity to view this evidence before a preferred strategy for housing growth is chosen. Housing growth conclusions In light of our evidence

above, we do not believe the Council has provided sufficient evidence to warrant deviating from the 2008 Welsh Government household projections and

therefore, we believe the level of housing growth stated within the projections should be the minimum level of growth for the LDP housing strategy. Notwithstanding the above, there are clearly some significant omissions from the council's evidence i.e. the need for affordable housing and the level of employment growth. In light of this, and given the importance of these issues, we do not believe it would be appropriate for the council to choose a preferred

strategy based on the current evidence. In addition to this, we also believe it is inappropriate for the Council to expect stakeholders to come to a view on a

preferred strategy, given the omission of such critical pieces of information. In light of the above, we believe the Council should reconsider the evidence base and

re-consult with stakeholders, in order to ensure everyone has the necessary information with which to decide upon an appropriate 'preferred strategy' for the

LDP.

Home Builders

Federation

(Richard Price)

41538

Option 1

Gen

eral

Com

men

ts

Supported. We need to keep greenfield. Transport - High Street needs upgrading and roads in Centre of Swansea need vast overhaul. Need better bus service. Should never have removed Mumbles Train. Need to look at trams.

J Bowen 41322

Supported. This option provides a more sustainable approach and does not include limited rural/semi-rural allocations. N B-Morris

41551

Supported. Our green land is why we love Swansea. Use the land already spoilt by development. Do not encroach unnecessarily on unspoilt lane. S R Duenas

41318

Supported. Brownfield areas must be targeted first. Big housing estates have caused social problems in the past, smaller areas of incomers are more easily

absorbed into local communities, will put less strain on services, such as schools, transport, doctors surgeries, and prevent ghettos forming. Patricia Anne

Jenkins 41351

Supported. Less greenfield developed. P S H Stott

41312

We wish to highlight that once the spatial option has been decided upon the rationale behind these choices needs to be explained fully. This will be vital in order

for the plan to meet the relevant soundness tests and be both robust and transparent. As outlined above, we consider that the best option available relates is

Option 1 'Spread approach: large and small edge of settlement allocations'. - General Comment

41547, 41544

Supported. No further details provided 2 repssubmitted


Sw


ent Plan

A

rea

Spe

cific

Scurlage/Uplands - Scurlage: There is no basis on sustainability grounds for having a Settlement Extension Option at this location: it is located in the AONB, is

not supported by local population needs, or local job supply and would contribute to the conversion of Gower into a dormitory suburb of Swansea. Nigel Bowen-Morris 41551

Uplands Recreation and Cricket Ground: This is a valuable open space resource and should not be built on, it gives a psychological impression of Swansea as a

green city. The cricket ground should be developed to complement Swansea's tourist role: eg as a beach sports arena, beach volleyball etc. Nigel Bowen-Morris 41551

Option 1/Alternative Option – Supported. Option 1 allows for existing communities to be expanded and maximum use to be made of current infrastructure. I would add that central areas such as Mount Pleasant, Uplands, St Thomas and Sandfields could be improved, offering as they do the older housing which is of a

size suitable for families who must possible in years to come accommodate several generations of one family as young people will have to stay at home for

longer, and elderly parents may have to be looked after also. Extensive development of greenfield sites means more journeys across the city to work, school, leisure and for the cultural pursuits of the occupants of these sites, and more isolation for them. Developments at rural/village locations would tend to distort the

village environment, and additionally the required infrastructure e.g. post offices, doctors' surgeries, shops etc. may be non-existent.

F Ferguson

41552

Option 2

Gen

Com

s Supported. To allow small scale development in he hamlets and villages not presently included in the UDP. D Gwynn 41323

Supported. Diversity/choice of site being made available geographically and size Reflective of rural housing needs Large scale extensions may sterilise land for

undue periods of time whilst values are generated Jonathan

Hughes 41326

Supported, No further details provided 2 reps submitted

Are

a S

peci

fic

2. In Section Two of the Consultation Paper it is noted that four broad options are put forward for discussion. The most appropriate option for BIshopston is

Option 2, called the Spread Approach encompassing large and small edge of settlement allocations, including limited rural/semi-rural extensions. In Section

Three Bishopston is included as an example of "large villages, rural and semi-rural locations".

Environmental

Planning 41584

2. In Section Two of Consultation Paper four broad options are presented. Port Eynon appears to fall within two of these categories: Option 1 - Spread

Approach: Large and small edge of settlement allocations; Option 2 - Spread Approach: Large and small edge of settlement allocations, including limited

rural/semi-rural extensions. However it is noted that the Consultation Paper excludes from Option 1 any allocations within semi-rural areas note included in the

Concept Plan. Candidate site GW0002 therefore clearly falls within the definition of Option 2, its boundary being contiguous with the built-up area of the village of Port Eynon, bring a limited semi-rural extension. Full details of the site were submitted as part of the Candidate site process.

Environmental

Planning (Mr

Graham King)

41588

2. In Section Two of the Consultation Paper four broad options are presented. Bishopston appears to falls within two of these categories: Option 1 - Spread

Approach: Large and small edge of settlement allocations; Option 2 - Spread Approach: Large and small edge of settlement allocations, including limited

rural/semi-rural extensions. However the Consultation Paper excludes from Option 1 any allocations within semi-rural areas not included in the Concept Plan. Candidate site B10011 therefore clearly falls within the definition of Option 2, being 1.56 ha in extent and its boundary contiguous with the built-up area of the

village of Bishopston. 3. Criteria for Option 2 emphasises the potential for expansion particularly where this would allow for a wide range of housing types to meet need and demand across the county over the plan period, provided this is possible without detrimental environmental impact. This statement is welcome and

realistic as villages like Bishopston, with a strong core of community facilities and social infrastructure, have proved attractive to builders and house buyers for

many years, albeit having an imposed cap on development under the policies of the UDP. Consideration of future options within the current LDP process is most timely therefore to help alleviate national concern over house building rates by allocating suitable sites such as B10011 within the village of Bishopston.

Environmental

Planning (Mr

Graham King)

41589

Option 3

al

C o m

Option 3 maximises the potential for well-integrated new developments that actually contribute to the sustainable prosperity of the urban settlements to which

they are most closely linked. This option should observe parts of the approaches of option 1 and option 4, in that it should focus on integration with existing

Mr Alfie Stroud


Sw


ent Plan

patterns of settlement across the county, but should also aim to be living mixed-use developments - well-connected, integrated and dense enough not to be

dormitory suburbs. Mixed-use development is good practice at any scale, and high density development surely not only increased the potential sustainability of any redeveloped area by making transport connections, local jobs and businesses more viable. Even 'sub-strategic' areas of redevelopment must take this into

account, and the good design of residential developments must depend on consideration of the lifestyles they make possible - and in this must be realistic about the city they will make up part of. The newer Marina/Maritime Quarter developments are, in parts, quite a distance from city centre amenities, and seem to be

becoming isolated buy-to-rent or two-cars-in-the-drive housing estates, rather than city centre extensions.

41548

Supported, No further details provided 2 reps submitted

3.23 We do not support Option 3. It is not appropriate to rely solely on previously developed sites and a limited number of strategic allocations. There remains a

need to allow for some smaller non-strategic allocations within the County. 3.24 We support the general principle of identifying strategic allocations over the plan

period, in particular to provide the scale of development required to drive forward the delivery of the necessary infrastructure over the plan period. Given the lead in

time associated with large strategic developments, however, it is important that the plan also provides for some non-strategic allocations. Such allocations are less

reliant on the delivery of supporting infrastructure, and as such are more likely to be delivered earlier in the plan period. 3.25 We do support the Council's

recognition that should strategic sites be brought forward they must be at sustainable locations, that benefit from complimentary land uses, services and facilities.

Stephen

Pilliner 41535

Option 3 - over-reliance on sites in north west of Swansea that have environmental issues associated with Burry Inlet. J Hughes 41326

3.2.3 Option 3 - This options by definition is one aimed at sustainable solution to the issues associated with growth. However questions relating to infrastructure

provision and environmental harm must be addressed for a satisfactory and sound growth strategy. EAW 41579

Option 4

Gen

eral

Com

men

ts

Mumbles Community Council supports Strategic Development Option 4, Mixed Use Major Development Areas, with the provisos that there is no breaching of the

MCC established green wedge boundary as currently defined in the UPD. The Community Council welcomes the opportunity to consider and respond to such an

important strategic document which could have significant implications on the way the City develops in the future. The core purpose of the document is to

influence and direct the Preferred Strategy and future detailed policies. As such the "macro" questions being asked at this stage are fundamental to the land use, transportation and future amenity/sustainability of the area. The Community Council have carefully considered the varied options having regard to the Mumbles

Community Plan (August 2010), current UDP and the implications of the different Strategic Options on our area and the wider city.

Mumbles

Community

Council (Mr

Steve Heydon)

41561

Option 4 - Timescales for delivery may be prohibitive and are in locations that are already experiencing stressed infrastructure - General Comment J Hughes 41326

Supported. In principle the allocation of one or possibly two mixed use major development areas is supported, although this must be shown to have direct benefits to existing brownfield sites or established areas and not merely be a greenfield land release that accommodates further development. The release of one or two mixed use major development areas should not therefore just result in the release of greenfield sites but additionally bring about major infrastructure

improvements to major brownfield sites, which are currently underutilised or redundant, as well we benefitting established part of the city which have suffered

from lack of infrastructure and other investment in recent times. In some cases this is badly needed investment which will not otherwise be achieved. None of the

other options will be capable of addressing the needs of its residents without placing additional pressure on existing resources. The release of mixed use major

development areas will accommodate the needs for transport (public and highways infrastructure), community, health and education facilities, employment and

affordable housing through a means that is economically viable, subject to this being in an area in which people want to live and employees want to locate. This

will fully accord with the Draft Visions and Objectives.

Ms Philippa

Cole 41512

Support. This option will provide for the most economic opportunity of all concerned in achieving economies of scale in all aspects and elements of the

development process. 41334, 41338


Sw


ent Plan

Supported. A new village would have to be given their own surgery, schools etc... rather than adding on to villages and stretching their services. A Capp 41316

Supported. Brownfield sites are more advantageous for less disruption than greenfield sites. Environment is important. 41387, 41348, 41346, 41347, 41389, 41403, 41402, 41401, 41386, 41396, 41404, 41388, 41384, 41398, 41400, 41344, 41345,

41395, 41385, 41394, 41397, 41399,

Supported. Alternative Option - I would rather as greenfield sites were ignored and left. To ignore the villages that exist. Only improve them. As all schools etc. are full to capacity. Give us needed facilities.

Christine

Griffiths 41311

Supported. Because it is unoccupied sites Mr&Mrs Hallett 41390

Supported. Green and brown sites should be easier for development W G Lewis

41412

Growth scenario 4 will not provide for a range and choice of housing. The provision of new community facilities to service new settlements is uneconomic when

there are under utilised facilities throughout the area that will be in danger of closing if future development is not spread across Swansea Liberty 41383

Supported. If its given that some 18,000 new dwellings are requested by 2025 then this must happen without compromising existing urban green spaces, allotments, village greens, parks and play areas. It's the lesser of two evils that less accessible space is used for new development. It's important not to squeeze

the space out of existing urban areas.

Peter May

41354

Supported. Best value for money, more jobs in areas, better infrastructure at mixed use major sites. J Rice 41358

Supported. Option 4 hopefully preserves existing urban green spaces. M Walters

41380

Supported. We think that bigger sites would cater for more affordable houses. D D & V Tong 41406

Supported. There are green and brownfield sites that are empty and ready for building on, our site is occupied and bringing in revenue. Mr&Mrs

Treweekes

41423

Supported, No further details provided 20 reps

submitted

Option 4 – Supported. Alternative Option - Identify the many brownfield sites in and around the Swansea area and build mixed housing.

This will meet a broader demand and improve much neglected areas where people will want to live.

C Humphreys

41462

Option 4 Supported. Alternative Option-Genuine brownfield sites 1st, 2nd & 3rd then any only then greenfield sites and then for affordable housing of mixed type

think Coed Darcy/ Poundsberry. This would improve the provision of housing and improve the area with parks, shops and work places for start up business etc. schools, good local transport.

Mrs Jan

Probert 41465

3.2.4 Option 4 - This option advocates an approach which may have severe potential implications for the LDP area in environmental terms. It is evitable that vast areas of currently Greenfield land would be developed and the biodiversity of these areas could be irreversibly harmed. 3.2.5 Additionally such a large scale

development approach would dictate that there is potential for a vast basic infrastructure provision to satisfy the requirements of this strategy consequently any

failure to provide the relevant facilities would mean the soundness of the LDP plan could be questionable as delays in progressing sites could be a possibility.

Environment

Agency Wales

41579


Sw


ent Plan

Section 3 - We object to the Authority pursuing Option 4, particularly in view of the areas highlighted on the Strategic Options Concept Plan. The areas indicated

are either at unsustainable locations, commercially undeliverable or both. To pursue this avenue of growth would risk repeating historic mistakes such as the

Tircoed development, irrespective of land ownership factors. - Object

Jason Evans

Planning

41445, 41506, 41505

Option 4 3.26 Again, we do not support Option 4 on the basis that the LDP cannot plan solely for brownfield development and one, or maybe two, major mixed-use developments. Given the complexities and lead in times associated with such development, it is important that the Council plan for non-strategic and smaller

strategic allocations to meet development requirements across the plan period. 3.27 We do, however, support the general principle of bringing forward at least one major mixed use development. In doing so, we support the Council's recognition that any mixed use major development area must be complimented by

appropriate new supporting services, facilities and infrastructure. This is fundamental if an allocation of this scale is to be considered sustainable, and

deliverable, within the plan period. 3.28 It should also be recognised that there are considerable benefits of locating development of this scale in areas that already benefit from access to existing supporting services, facilities and infrastructure - rather than solely relying on new services, facilities and infrastructure. This is likely to result in a more sustainable and deliverable scheme, that is more closely aligned to the existing settlement function. It should also be recognised

that major mixed use developments provide an opportunity to deliver significant improvements to existing infrastructure and services, to the wider benefit of both

existing and future uses.

Stephen

Pilliner 41535

Are

a S

peci

fic

Supported. An ideal area is a brownfield site which allowed planned infrastructure - close to M4. 41341, 41342, 41333

Supported. The site is suitable and deliverable. It has the potential to make an important contribution to meeting the area's future need for new homes (5% to

10% according to which forecast is adopted), new jobs and new enterprises, and to do so in a way that is both environmentally attractive and sustainable. Allocation of the site for an urban village would assist in meeting the Council's vision for Swansea in 2025 and in meeting its LDP objectives. Please refer to the

supporting documentation which explains in detail the rationale for this option and the proposed development at Felindre.

Flexible

Support for

Business (Paul

Evans) 41572

Supported. I think that extending the boundaries of Swansea City to create an even larger conubation is not a good idea. Mixed use should means jobs as well as homes. Mrs B Hansford 41325

Supported. Close to motorway/public transport and shopping facilities, doesn't interfere with natural environment like "areas of outstanding natural beauty". C Herrieven 41355

Supported. This option would support the overall objectives of the LDP. The proposed sites __ neatly planned growth strategy, provide the suitable

infrastructure requirements, facilitate traffic and mobility issues whilst protecting AONB enviroment both visually and naturistically. Steven

Herrieven

41375

Supported. Pontarddulais is already over developed - the language is being eroded. Schools, health centres are full. C Jones 41441

Supported. I agree we need to manage our growth and the local area. Felindre ______ brownfield site, easy access to M4 for commute to work. Other

developments would not manage this change. Chriss Mort

41363

Supported. I agree we need to manage growth and brownfield being the ideal site with easy access to the M4. O Rice 41366

Supported. This option is ideal for all concerned with easy access to the M4 David Rice

41369

Supported. To maximise the road access to the M4 corridor. A Vaughan

41449


Sw


ent Plan

Supported. We need to protect whats left of our green spaces in and around Swansea. Brown spaces could be landscaped. If we have to build use the M4

corridor rather than continue to over develop and spoil our communities. Eleri Walters

41378

Supported. A new village would have their own facilities i.e. school, surgery etc. It would take pressure off Pontarddulais. G Watkins

41310

Supported. I agree we need to manage our growth and the ideal area is the brownfield site at Felindre - easy access to M4 for commute to work. Other

developments would not manage this so easily. Mr Thomas

41359

Supported. Looking at the plan for example Felindre which is lying idle, would create a new village in its size Mr&Mrs S Thomas 41405

Supported. To make maximum utilisation of M4 corridor. Road access within and without of Swansea. DP Vaughan 41447

Alternative Options

Alternative Options 3.29 On the basis of the above, we would support an alternative option that combines elements of each of the above options. Whilst we

recognise the need to maximise brownfield development opportunities, this must be set in the context of economic viability and deliverability. There is not value

in identifying sites or development options on brownfield sites that will not be brought forward over the plan period. Any option for growth must therefore start with a careful and realistic understanding of how much brownfield land is likely to come forward. This assessment will need to be supported by the Council's

emerging evidence base. It must also be recognised that not all brownfield sites are suitable for future development. 3.30 Development of previously used land

must be supported by non-strategic allocations on greenfield land in sustainable locations. Such allocations are generally subject to less onerous upfront infrastructure costs and are capable of being delivered earlier in the plan period. This is essential to ensure that there is continuity of development throughout the

plan period, whilst more complex brownfield and strategic greenfield sites are progressed. This will ensure that sufficient new housing is provided to meet the

needs of existing and future populations throughout the plan period. 3.31 The Council should also plan for a limited number of strategic greenfield allocations and

at least one major mixed use development. As recognised in the Consultation Draft, it is essential that such developments are located in sustainable locations

that are capable of drawing on existing infrastructure, services and facilities, albeit with the recognition that improvements will need to be made. It would not be

sustainable to direct developments of this scale to locations that are not well related to the existing urban area and do not benefit from existing supporting

infrastructure, facilities and services.This approach will support the development of sustainable developments that build on close links between residential and

employment uses. 3.32 The provision of residential led strategic greenfield allocations and major mixed use development will also drive the delivery of necessary

infrastructure over the plan period. Without delivering development of this scale it is unlikely that such infrastructure will be realised. As such, the allocation is

sustainable strategic extensions and major mixed use allocations will play an important role in development Swansea as an economically competitive place and

a regional economic driver. 3.33 By pursuing a spatial option that allows for viable and deliverable brownfield non-strategic and strategic development, including

that of a major scale, it is more likely that the vision and objectives of the LDP will be met. Importantly, such a strategy will enable the delivery of these visions and

objectives across the plan period as a while. Without such an approach there is a danger that insufficient levels of growth will be delivered, or insufficient supporting infrastructure and development will be provided.

Stephen

Pilliner 41535

Alternative Option supported - no details provided. 3 reps received

Alternative Option supported - Empty homes in Dec 2011 are over 3000 (Channel 4 TV - Empties) and increased from 1881 (Shelter 2008). Development on

major 'brownfield' sites (Felindre, Swansea Vale etc). Undeveloped sites from the UDP. Any shortfall to be as Option 2 above. I favour this option as it keeps

development in already prescribed areas and the 'brownfield' sites - particularly Felindre - allows for a complete package (infrastructure etc) to be achieved

without extra impact on the local communities.

James

Waygood

41539


Sw


ent Plan

Option Combinations

Opt

ions

1 &

2

Blend of Options 1 and 2 supported. To support existing communities and have new facilities in existing communities, to support the local businesses that are

already within the area by increasing the number of residents close to them. 41485, 41494, 41507, 41501, 41497, 41489, 41481, 41477, 41474, 41482, 41486, 41498, 41490, 41493, 41432, 41478

Option 1 3.20 Option 1 is not supported, given that we do not believe that the vision and objectives of the LDP can be delivered solely through brownfield

development and non-strategic greenfield allocations. Whilst we support the need for non-strategic greenfield allocations over the plan period, such

development will not be sufficient to deliver the economically and socially sustainable levels of growth required over the plan period. 3.21 Brownfield and non-strategic greenfield allocations alone will not enable the delivery of sufficient good quality housing to meet existing and future needs. This option would also fail to

support the scale of development required to provide for required accessible, high quality education, training and employment infrastructure. Option2 3.22 This

option is not supported for the same reasons set out above in relation to Option 1.

Stephen

Pilliner 41535

3.2.2 We would have concerns regarding Options 1 & 2 for several reasons. They are: - Are these options likely to achieve the strategic economic agenda that the LDP requires - Development in rural villages may pose problems or have impacts in relation to infrastructure or biodiversity matters.

EAW 41579

Opt

ions

1 &

3

A combination of options 1 & 3 supported. The Council should seek to allocate both strategic and non-strategic urban extensions as this will allow for a flexibility

to respond to the different opportunities and needs within the CCS area. Limiting development to Strategic Options will prevent the development of logical round

off opportunities that could provide necessary local housing and potentially deliver environmental improvements. A combination of options 1 & 3 will also allow for

a range and choice in the nature of sites allocated within the plan. A spread approach across the County of strategic and non-strategic urban extensions as

suggested in Option 1 and Option 3 is supported. This provides an approach which is a)sustainable, b)offers a range of sites and c)helps to fulfil housing needs of a variety of communities around Swansea rather than just a few geographic areas. a)In terms of sustainability, this option allows for the development of both

brownfield and (suitable and accessible) greenfield sites. This will help to ensure best use is made of the existing land resource, whilst also ensuring that future

development continues to be located in accessible locations close to existing services and facilities. This will help to minimise the need to travel and support existing facilities and services. Paragraph 2.12 of the plan recognises that a brownfield only strategy is not deliverable and we concur with this ascertain. It is

clear that in order to ensure the developments needs of Swansea are met, the allocation of both brownfield and (appropriate) greenfield sites is necessary and

this Option provides the basis for this. b)This option also will help to ensure the Plan offers a full range and choice of development sites, without the Plan needing

to rely solely on the delivery of one or two large-scale (more than 15ha) urban extensions in order to meet Swansea's development needs up to 2025. These

strategic sites often entail significant up-front investment in infrastructure and require considerable lead-in periods prior to development. It is important therefore

that there are alternative sites that can be developed in parallel access the city. This 'spread option' allows for wider range of sites to be allocated and will therefore help to ensure the Plan is deliverable and flexible enough to deal with any unforeseen circumstances. c) This 'spread approach' also allows for a wider

geographic spread of development, which will ensure that development can be located in (sustainable) location, where the development is needed. This

approach will therefore help to achieve an alignment between development demand and development supply, unlike other options which rely on a smaller

number and range of sites.

41547, 41544

Alternative Option – Supported. In terms of spatial options, a combination of option 1 spread approach: 'large and small edge of settlement allocations' and

option 3 'sustainable urban extensions' is supported. Option 1 is considered to be appropriate because it allows for logical settlement boundary alterations

whether small or large to be made, with the LDP process offering the appropriate mechanism for this. A combination of options 1 and 3 is considered the most robust option for delivering the sustainable growth of Swansea over the LDP period in accordance with the Vision and Objectives identified for the LDP. The

combination of the options will allow for large scale extensions that will be required to achieve the housing requirement for Swansea over the LDP period and

logical alterations including small scale sustainable extensions. Areas not currently shown - Appropriate locations for small to medium sized boundary

amendments.

Zoe Abberley

41406

Ops

1&4 Mix of 1 and 4 with brownfield development on small sites. Dr S Brooks

41329


Sw


ent Plan

O

ptio

n 1

&

Alte

rnat

ive

Alternative Option –Supported. Blend of 1 and regeneration of older housng stock in city centre and immediate surrounds, discouraging further HMO's in 2 storey

traditional family homes. Incentives to young familities to move into central areas and convert HMO's that come onto market back into family homes. Encouragement to universities to build their own student accommodation on campuses. This is more sustainable, less need to create new infrastructure, better

pre-existing transport links and amenities. Easier for low income families to get around. Revitalises city centre and surrounding communities. Less need for new

build and using greenfield, again more sustainable and ecologically and culturally sound. Also helps keep small local shopping centres alive. Also less likely to

have sprawl of Swansea into countryside therefore protecting economically essential tourism.

Sandy Johns

41591 O

ptio

ns 2

& 3

A blend of options 2 & 3 would be supported. It is considered that a mix of option 2 and option 3 would represent the most sustainable and deliverable of the

options presented in terms of being capable of meeting the needs of all members of the population of Swansea, irrespective of economic or geographic position. J Evans 41444, 41505, 41506, 41446

We support the aim of the LDP to facilitate a sustainable growth strategy and the weight the Council place on ensuring new development areas must be served or

be capable of being served by appropriate infrastructure. Therefore the suitability (and inherent sustainability) of individual sites should be the key consideration

and this should not be lost in a pre-occupation with a narrow spatial strategy. On this basis, it is considered that a blend of Option 2 and Option 3 is the most appropriate strategic option to take forward. A spread-approach is generally needed to be able to focus development on the most suitable, sustainable and

viable sites - which incorporate brownfield sites, large and small edge of settlement allocations and a limited number of rural/semi-rural extensions. This

approach ensures the flexibility to deliver housing in appropriate parts of the County to meet demand (but controlled by the planning system). However, in order

to ensure delivery and to meet housing needs, it is expected that some sustainable urban extensions will be required, and therefore option 2, with a blend of option 3, to include a suitable number of strategic sites is the preferred option. However, the potential sustainable urban extension candidate sites ought to be

carefully considered and assessed with regard to their deliverability and sustainability. Option 4, mixed-use, major development areas, is considered to be the

least favourable and sustainable option.

Paul Williams

41521

Opt

ions

2 &

4

Alternative Option supported. A blend of options 2 & 4 would be most appropriate for the Swansea LDP due to varying nature of the County. Brownfield/ abandoned/ previously developed sites should be identified and utilised initially for new development/transformation. Where previous industries have

contaminated land - this should be rectified where possible, no matter the cost than leave the ground/site undeveloped and serving no purpose. These sites

should be a priority for cleaning up and developing. Option 2 - Spread Approach B: Some small scale development at rural/village locations should be permitted

though carefully considered so that there are benefits to the communities such as new community facilities where no/little provision exists and new/increased

businesses. The capacity/quality of road network to these locations should be weighted in such decisions. As in option 1, agree with development spread across

the County at the edge of existing urban elements but on a small-medium scale utilising previously development land/brownfield sites, subject to local conditions

(suitable infrastructure etc.) as a priority (but avoiding green field development). Option 3 - Sustainable Urban Extensions is not appropriate for parts of the

County where town/village identity and community spirit is lost through the merging of communities through large scale 'infill' developments where the network/ infrastructure is not capable of coping with the added volume of people and vehicles etc. Option 4 - Mixed Use Major Development Areas have a role to play in

specific locations in the County, targeting previously developed/brownfield sites - Felindre is a prime example of a large waste of space and land that could be

transformed with residential housing, retail outlets, has excellent road links with the opportunity of having Countryside/recreational facilities on the doorstep.

Miss Kelly

Shefford 41422

My preferred options would be: Option 2 - Spread approach B. Distribute growth across Swansea, candidate sites to be considered at a later stage. And Option 4

- one or two larger sites. Byron Davies

AM 41519

Opt

ion

3

& A

lt

Option 3 / Alternative Option – Supported Option 3 would allow for comprehensive, phased forms of development where, at greenfield locations, deliverable

schemes supported by housebuilders, could provide for housing needs at early stages of the Plan Period. The site at Bryn Rhos Farm would meet this

description. Option 4 could also apply in Penllergaer where separate releases may contribute collectively to strategic development. Consequently a 'hybrid' option which applies to both Options 3 and 4 may also be appropriate. Option 4 sites should however be reduced in scale to 50 hectares rather than 100.

Asbri Planning

41569

io n s 3 Options 3 & 4 – Supported. Alternative Option – Supported. Option 3 would allow for comprehensive, phased forms of development where, at greenfield

locations, deliverable schemes supported by housebuilders, could provide for housing needs at early stages of the Plan Period, with subsequent phased

Asbri Planning


Sw


ent Plan

development contributing to latter stages with associated infrastructure improvements. In order to further sustainability aims appropriate areas would be

identified for community and other uses. In this context Option 4 could also apply is extended to adjacent land to the south. Consequently a 'hybrid' option which

applies to both Options 3 and 4 would be appropriate as there is a high degree of overlap between the two options. Option 4 developments should, however, be

reduced in scale to 50 hectares and more.

41565

Options 3 & 4 – Supported. Alternative Option – Supported Option 3 would allow for comprehensive, phased forms of development where, at greenfield

locations, deliverable schemes supported by housebuilders, could provide for housing needs at early stages of the Plan Period, with subsequent phased

development contributing to latter stages with associated infrastructure improvements. In order to further sustainability aims appropriate areas would be

identified for community and other uses. In this context Option 4 could also apply. Consequently a 'hybrid' option which apples to both Options 3 and 4 would be

appropriate as there is a high degree of overland between the two options.

Asbri Planning

41566

Whilst generally favouring Option 3, due to the degree of overlap between Options 3 and 4 - a hybrid option of the two should be referred to as being a potential Preferred Option - General Comment

Asbri Planning

41569

Option 4 – Supported. Alternative Option - 3 & 4. Opportunity to create a really radical sustainable developm,ent in model of Coed Darcy rather than graft uneasily on to existing settlements.

Miss E Harry

41458

Due to the degree of overlap between Options 3 and 4 - a hybrid option of the two should be referred to as being a potential Preferred Option. This may be

dependent ultimately on the level of non residential uses proposed and where boundaries are drawn in relation to existing land uses - General Comment Asbri Planning

41565

All

Alternative Option supported - A mixed approach using all 4 options is probably the most practicable. The principles expresed in 2.1-2.7 need to then be applied. Enlightened visions of the future should be the basis of decision making: energy-efficiency, good transport infrastructure, well-constructed and self-sufficient communities a that have their needs close at hand - shops, greenspace, school, community centre.

Mrs Bridget

Stein 41510

Option 1 - The acknowledgement that a spread approach is unlikely to deliver the levels of growth required is welcomed – Comment Option 2 - The

acknowledgement that such an approach is likely to deliver the strategic economic agenda is welcomed – Comment Option 3 - Developments of this scale are

likely to be single use lead, rather than true mixed development and of insufficient size to help realise other plan objectives, in terms of infrastructure and

community, health and education facilities. Rather, this option will impact on already stretched existing resources - Comment/Object Option 4 - Generally agree

with the summary of this option which reflects the balanced approach of greenfield releases directly benefitting and addressing the needs of brownfield sites

which would not otherwise be viable development options. This balance is supported. This description is not reflected or made clear in this form which refers

only to greenfield releases. The balance/link with brownfield land releases/designations should have been emphasised more clearly in this form which only

refers to greenfield land releases in Question 4a above. The concept olan reinforces that the definition of Mixed Use Major Development Area Options could

involve brownfield and greenfield sites. Fforestfach and Felindre both include significant areas of brownfield land within their Candidate Site Submissions and

the descriptions afforded to the proposals within Section 3 of the document confirm this - Comment

Ms Philippa

Cole 41512

In considering the four key Strategic Options together with the fifth option of a mix of all of them, only a few locations such as Velindre or SA1 have the capacity of large scale schemes. The Society takes the view that a well conceived and balanced mix would be the preferred way forward. This will provide the flexibility to

promote the best schemes that enhance the City without being restricted by a rigid LDP Strategy document. The areas outside the current main development of Swansea are prime areas for mixed development and will not impair or affect the current development plan.

Swansea Civic

Society 41513

Options – General Comments

Gen

era

l

3.2 Section 2. The spatial options for growth 3.2.1 We note that your authority has 4 different spatial options for growth within the County Borough for the LDP

plan period. It is essential that your authority advocate a growth strategy which falls in line with current Welsh Government Planning advice. It is not within our

remit to recommend any particular preferable option but we do offer various comments for your perusal.

Environment

Agency Wales

41579


Sw


ent Plan

The options for growth set out do not provide robust evidence to consider any alternative but the Wales Government Projection. - Object P Cole 41512

Spatial Options - In this context commenting on spatial options is difficult although like the Council we suspect that some a combination of the choices presented

is likely to be chosen. Our view at this stage - and putting to one side the level of growth - is that to be sustainable and deliverable, and to reflect a refined spatial vision (as set out above) is that option 1 should be the starting point, with the scope for some (suitably controlled) movement into option 2 and (if necessary)

option 3. This would properly sequence the most suitable, sustainable and viable sites - and target brownfield sites, some edge of settlement allocations and a

limited number of rural/semi-rural extensions. This approach ensures the flexibility to deliver housing in appropriate parts of the County to meet demand (but in a

guided and controlled manner). Unless excessive levels of growth are imposed, option 4 does not fit with planning policy guidance, will not be sustainable, will not be needed and should be dismissed.

Tim Gent 41524

Response: Of the 4 Strategic Options presented within the Swansea Local Development Plan-Vision & Objectives Consultation Draft July 2012 the Community

Council have concluded that the approach as outlined under Option 4-Mixed-Use Major Development Areas provided the City with the most comprehensive and

deliverable solution with the maximum potential infrastructure, community, educational, employment and environmental benefits. Mumbles Community Council supports Strategic Development Option 4, Mixed Use Major Development Areas.The Community Council would wish to see the current Green Wedges as

identified in the UDP maintained. Justification:The location of the Mixed-Use Major Development Areas at Fforestfach, Penllergaer, Llangyfelach and Felindre

are well placed on the regional transportation network and minimise the implications on over congested areas of the City such as West Swansea/Mumbles. The

scales of these developments can provide benefits in economic terms through the capacity to provide associated employment opportunities. Indeed the

historic/current developments along this M4 corridor are in many ways already beginning to deliver this strategic vision by default. Formalising this as a core

Strategic approach in the LDP would being additional status, commitment and coordinated planning to areas which have considerable potential to improve the

economic vitality of the City. Edwina Hart recently announced a "New sustainable urban village proposed for Felindre - Minister approves feasibility study". This

study considers proposals for a new sustainable urban village on a 100 hectare greenfield site owned by the Welsh Government at Felindre, Swansea. The

proposed new village could provide a mix of affordable and private sector housing - with associated community facilities including schools and playing fields and

also provide employment opportunities. Business Minister Edwina Hart has approved funding for the study which will be formally submitted as part of the

consultation process on the City and County of Swansea's Local Development Plan (LDP). There is in our opinion "economies of scale" at play with such larger

development areas, with greater scope for financial contributions towards community requirements and enhanced environmental standards. The other smaller

scale widely dispersed Strategic Options (Option 1-3) presented within the Swansea LDP - Vision and Objectives Consultation Draft July 2012 are unlikely to

deliver the Strategic Vision or a step change in the perception of the northern area of the City. In terms of Option 1 this is acknowledged in the text, "There is some

question as the extent to which an approach might limit how the LDP is able to deliver economically and socially sustainable levels of growth, particularly in terms

of realising a strategic economic agenda that might potentially demand significant land releases". Similar concerns are also expressed in term of Option 2

"...there is some question whether this scenario would be able to deliver a strategic economic agenda in a sustainable manner, should there be a lack of sufficiently larger sites for employment generating development as well as housing". This option also has serious implications on certain environmentally

sensitive areas such as the AONB and settlements such as Bishopston, Pennard/Southgate, Upper Killay, Three Crosses and Scurlage. Turning to Option3

(Sustainable Urban Extensions) this involves much larger potential allocations in areas (particularly West Swansea/ Mumbles) which historically because of insatiable housing pressures have been subject to restraint policies for many decades. Given the need to protect the AONB, Green Wedges and the prevention

of the coalescing of settlement the Community Council do not consider that the approach could be supported at this stage with the present suggested major

housing allocations in Thistleboon, Mumbles and/or West Cross, Newton for the following reasons: The Economic Prosperity and Life section of the Strategy

Objective Point 3 states that: "New housing should be close to employment, retail, leisure education and other community facilities." Also, the Quality

Environment document Point 3 aims to: "Protect and enhance the system of access to green spaces."

Mumbles

Community

Council (Mr

Steve Heydon)

41561

Section 3

“…Para 4: in penultimate sentence, delete 'sustainability' and insert, 'quality

environment and community provision'” Para 4: in penultimate sentence, delete 'sustainability' and insert, 'quality environment and community provision'. - Object

Penllergare

Trust 41466


Sw


ent Plan

“…Llangyfelach - Para 2: add at end of 2nd sentence 'and an historic park and

garden undergoing high quality restoration'.” Llangyfelach - Para 2: add at end of 2nd sentence 'and an historic park and garden

undergoing high quality restoration'. Penllergare

Trust 41466

“Para 3:add new sentence, 'As an historic park and garden of national importance Penllergare Valley Woods would contribute significantly to the

quality and attractiveness of the proposed strategic development, both as a

large, diverse and well-managed recreational greenspace- connected to

Penllergaer Forest by its M4/A48 underbridge-as well as promoted visitor

destination. In return the new development would be expected to contribute to

the sustainable upkeep of Valley Woods and its facilities'”

Para 3: add new sentence, 'As an historic park and garden of national importance

Penllergare Valley Woods would contribute significantly to the quality and

attractiveness of the proposed strategic development, both as a large, diverse and

well-managed recreational greenspace - connected to Penllergaer Forest by its

M4/A48 underbridge - as well as promoted visitor destination. In return the new

development would be expected to contribute to the sustainable upkeep of Valley

Woods and its facilities'. - Object

Penllergare

Trust 41466

Gen

eral

Areas for Consideration 3.34 Comments on selected 'areas for consideration' are set out below. Our comments take account of the suitability of each area to

accommodate the spatial options for growth addressed above. We have also referred to broad areas of growth where possible, rather than being site specific. As such, our comments should be read in relation to our previous candidate site submissions.

Stephen

Pilliner 41535

Q4a Strategic Options - Spatial Spread We consider that each of the options will result in a number of difficult decisions and consequential environmental impacts, with the potential for the coalescence of a number of traditionally freestanding settlements. We advise that each of the options is therefore carefully

considered through the Strategic Environmental Assessment (SEA)/Sustainability Assessment (SA) processes to ensure that environmental impacts are

minimised. Where a particular approach is likely to result in environmental impacts, clear justification should be provided why such an approach is to be followed, with details of the mitigation and compensation measures that will be provided to offset such impacts.

Countryside

Council for

Wales 41558

Important that areas for consideration offer diversity of opportunity, both spatially and in scale of site - General Comment J Hughes 41326

There should be a strategy for the Welsh language, previous urbanisation of Swansea has obliterated Welsh speaking communities in northern areas. Settlement Extension Options include Three Crosses, and Penclawdd, part of Welsh Gower, which are under threat of losing their distinctiveness. There needs

to be a deeper analysis of the dynamics of individual area and how the spatial allocation of housing will impact on this. For example, some areas like Mawr and

Pontarddulais give northern areas a distinctive Welsh identity, how will the Welsh identity be managed in the context of the planning policy? Is there an overall education policy to match? The data at Ward level is cellular and does not develop a unified theme - General Comment


Section 3 - Areas in the north and west of the County would be challenging to successfully develop, being often greenfield and adjacent to existing communities

with very particular needs, as described above. Meanwhile there seem to remain large amounts of brownfield land available for development - including at 'strategic level' in Swansea Vale as indicated in the Strategic Options document - which is spatially potentially highly supportive of efforts to regenerate Swansea

on a broader scale. These underdeveloped zones along Fabian Way, the Lower Swansea Valley and Morfa, if redeveloped with high density and some mixed-use quality urban development, might make significant contributions to resolving long-term challenges like reviving the city centre and would redouble the

sustainability of ambitious and prestigious developments such as SA1 Waterfront and those based around the Hafod works which will depend for success on city

connectivity and on local staff and users - General Comment

Mr Alfie Stroud

41548

If any extension to Pontarddulais is considered, this must include changes to traffic flow which is terrible - especially since the new Tesco store has opened. If the

suggested development next to Felindre steelworks site goes ahead, it is even more important to allow some new housing in the village of Felindre. The Welsh

Language primary schools in Felindre takes a significant number of pupils from other areas of Swansea which would go to a new school within this development. Without these pupils, the viability of the school in Felindre would be questionable - Comment

A W G Stone

41330

Section 3 - Any areas which have become neglected in nned of an injection of new life to include landscaping, community facilities and small retail outlets. Also

including small units for 'start up businesses'. C Humphreys

41462


Sw


ent Plan

Section 3 - See previous comment on Q5 regarding Fabian Way Corridor - General Comment/Support RPS 41470

Infrastructure should be a key consideration, whether the areas for consideration can even cope with such developments. The capacity and facilities/scope for

improvement in the area should be carefully and fully reviewed before decisions made to include them further in the process. - General Comment Miss Kelly

Shefford 41422

Section 3 - Maintain as many greenfield sites, also AONB (Gower etc.). DP Vaughan 41447

Section 3 - Maintain as many greenfield sites as possible, also AONB (Gower etc.). A Vaughan

41449

Care must be taken to keep the 'urban form' so that communities do not get too big and lose their local identities - General Comment J Waygood

41539

Section 3 - Unoccupied properties and brownfield sites - Object D Powell 41461

Section 3-The broad areas for consideration are supported. The text as it refers to Penllergaer is discussed in the accompanying submission document Support Asbri P 41565

Burry Inlet We note that your Authority will be carrying our further assessment in relation to the Gowerton sewerage catchment issues where relevant Strategic

Options as part of the SEA/HRA of the LDP. We will comment fully on that in due course. Please note the following comments/observations are made on the

basis of the descriptions provided in Section 3 (Areas for Consideration) of the Strategic Options Consultation Draft July 2012. CCW has not carried out any

appraisal of actual Candidate Site boundaries.

Countryside

Council for

Wales 41558

4. Section 3. Areas for consideration 4.1 Generic overview 4.1.1 In relation to the details provided in this section we would remind your authority that you in

possession of our comments/information for candidate sites/potential development sites. You will conscious that we have responsibility for environmental protection including; - flood risk; - groundwater and land contamination; - waterbody protection and quality; - air quality - certain industrial activities - biodiversity -

waste management. If you unsure of whether certain sites advocated within this document have not been assessed by us would you please forward their details

at the earliest opportunity?

Environment

Agency Wales

41579

Spatial Growth Options Without knowing exactly how the missing evidence mentioned above might impact on the level of housing and economic growth required

for the area, we believe it would be difficult to provide a full and detailed response with respect to the Spatial Options put forward. Notwithstanding the above, we

would comment as follows based on the evidence we have to hand:- We do not believe option 1 is a credible option, as it provides little flexibility to allow for

growth and investment, and would constrain the LDP in terms of meeting its aims and objectives. In terms of a suitable way forward, we believe options 2, 3 and

4, all have certain merits and therefore, we believe the preferred strategy should be flexible enough to embrace the positive elements from each option. In this

respect, we believe the preferred strategy should enable the regeneration of previously developed and non-developed land. The preferred strategy should also

enable the potential for extensions to towns and villages to be created, (both small and large), and should also be flexible enough to enable the creation of strategic sites that can provide as focus for growth and investment. In addition to the above, we believe the preferred strategy should enable those areas that are

already successful in attracting investment and growth to flourish and continue to grow. This will help the authority regenerate less attractive areas by ensuring

the benefits radiate out into those area. However, the strategy must also be sufficiently flexible to provide viable options for growth in less attractive areas, in

order to capitalise on any investment opportunities that might arise. Crucially, however, we do not believe the strategy should try and force development into

areas that have historically had difficulty in attracting inward investment.This will only serve to limit development opportunities in the area and could potentially

drive investment out of Swansea and into other areas of Wales, which will clearly have a detrimental impact on the ability of the LDP to achieve its aspirations. We believe the key to a successful strategy is to provide sufficient focus on the areas that are 'magnets' for investment and to provide options for growth in other

areas. Flexibility in the strategy will be essential to ensure regeneration is facilitated in the areas that need it most, and a strategy that recognises the importance

of housing development to society, and to the economy of the area, will be essential to ensure success. In addition to the above, we believe the spatial option

should provide a range and choice of housing sites across the authority, in order to ensure sufficient flexibility exists to deliver the right amount of housing growth

for the area. Again, we believe vital information to inform this part of the spatial strategy has been omitted from the consultation (i.e. the need for affordable

Home Builders

Federation

(Richard Price)

41538


Sw


ent Plan

housing and employment growth) and therefore, it would be impossible to provide any clear idea of how much growth is needed or where it should be focussed. The spatial strategies provided also do not provide a coherent schematic for how the proposed options for growth would work on a strategic scale, however, we

believe following the principles of our comments above would provide an appropriate starting point to ensure the 'preferred strategy' works efficiently and

effectively.

Spatial Options Conclusions We believe there is sufficient evidence within the consultation to provide any meaningful suggestions on a workable preferred

spatial option. However, various part of options 2, 3 and 4 all have merit and therefore we believe a hybrid option might be a suitable way forward. Nonetheless, we believe the principles of a workable spatial option, as we have described above, should also be considered, and any chosen preferred strategy should be

focused on attracting investment and growth, with the flexibility to ensure it takes hold. As we have described above, some key pieces of evidence are lacking

from the background papers which makes it extremely difficult to understand what is required from a preferred spatial option. As such, we are unclear how the

council can chose a spatial option based on the information available at present, or how stakeholders are expected to come to a view on a suitable preferred

strategy, given the circumstances. In light of the above, we believe the council should consider these omitted (yet vital) pieces of evidence and how they might influence the creation of an appropriate spatial option, and re-consult with stakeholders so we all have the necessary information with which to decide upon an

appropriate 'preferred strategy' for the LDP.

Home Builders

Federation

(Richard Price)

41538

Areas for Consideration - The summary of areas within the County to consider regarding their suitability to accommodate the growth scenarios (and therefore

new allocations) is a useful exercise. It is stated in paragraph 3.5 of the document, the suitability of these areas to accommodate some degree of development will depend not only on site specific issues and constraints, but on which spatial option is considered most suitable to deliver Swansea's overarching aims. As

identified above, there lies a risk that a preoccupation with an overly focused spatial strategy will prevent good, sustainable and deliverable sites coming forward

for development. For example, an over-reliance on major strategic allocations will not achieve short term requirements to deliver new housing. Notably, it is

considered that proposals for a major mixed use development at Felindre would be an unsustainable solution to meeting housing development needs in

Swansea.

Paul Williams

41521

Pon

tard

dula

is N

orth

Pontarddulais North - The road system would not support large scale development – Object D Gwynn 41323

Pontarddulais North - Problems with flooding – Objection A Capp 41316

Pontarddulais North - Problems with flooding - Objection G Watkins

41310

Pontarddulais North - The identification of 'Pontarddulais North' as an identified area of consideration is supported and it is considered to represent a suitable and

sustainable location for strategic development, which is close to the existing district centre of Pontarddiulais. Unlike some of the other options available, North

Pontarddulais is well-linked to Pontarddulais centre and benefits from excellent transport routes to Swansea City via rail, the M4 and bus. The North

Pontarddulais proposal represents a logical area for development, being located on the fringe of the existing settlement, with existing residential and

employment areas located to the west, east, south and partly to the north. The existing built environment therefore leads itself to future development, without resulting in significant landscape impact. The sustainability credentials of North Pontarddulais are recognised in paragraph 3.4 of the Plan, although we wish to

highlight that only some areas in Pontarddulais North area have flood risk constraints and therefore the statement in the plan should be amended to reflect this. Notably, our client’s site (candidate site ref. PT0011) forms part of the wider North Pontarddulais area and is not constrained by flood risk. Furthermore our

client’s site is readily available and deliverable during the plan period, and forms an integral part of the Pontardulais North area by providing a potential access

pojnt onto Glanffrwd Rpad. It is also noted that our client’s site is identified as having the potential to accommodate a new road in the Hyder Transportation and

Development Study for Pontarddulais (see option 3). The conclusions of this study are yet to be published, however we wish to highlight that this new road will provide improved access arrangements for the existing industrial estate in Pontarddulais as well as the Macmillans estate to the north. Development of our

clients sites (PT0011) as part of a wider comprehensive scheme for residential development offers up an enabling opportunity which could potentially help fund

the development of this road. Without beneficial development that creates a significant value the Council’s proposed link road could not be funded given the

shortage of government funding. Development in this location would therefore bring significant benefits in terms of: - Provision of necessary housing, -

41547, 41544


Sw


ent Plan

Infrastructure improvements that could not otherwise be delivered, - Wider regeneration benefits for Pontarddulais, Even if the Pontarddulais North option were

not to come forward, as set out in the Council’s option or Hyder studies, the potential exists for modest residential development at Glanffrwd Road to assist in

meeting local housing demand.

4.2 Pontardulais North & South Flood risk is an issue within the Pontardulais North area. EAW 41579

1. Pontarddulais North Land East of Ty'n y Bonau Road - The area appears to consist mainly of agriculturally improved land with some thick hedgerows and two

small blocks of woodland - Agricultural buildings at present - these may need to be surveyed for suitability for bats Land East of Glyn Hir Road - Graig Fawr SSSI lies approx 600m to the north of the site -CCWs Phase 1 Habitat survey (dated 1987) records some marshy grassland and semi improved modified marshy

grassland fields in this area - We refer you to Environment Agency regarding this area for any land drainage issues/flood risk areas.

Countryside

Council for

Wales 41558

2. The Strategic Options Consultation Paper puts forward four broad options to help develop a preferred strategy for development across the county of which two

are relevant to Pontarddulais North. Option 1- the Spread Approach - proposed consideration of both large and small edge of settlement allocations primarily for

housing or employment, generally less than 15ha, with the possibility of integrating undeveloped green space alongside residential allocations. Option 3 focuses

on areas of development of more strategic significance, generally more than 15ha, especially on the fringes of existing settlement boundaries in sustainable

locations close to local services and facilities. Possible sites are shown on the Concept Plan, one of which is Pontarddulais North. Collectively the sites are

around 15ha in extent. Both Options 1 and 2 therefore appear relevant to development in this area.

Environmental

Planning (Mr

Graham King)

41576

3. In Section 3 of the consultation report, Areas for Consideration, Pontarddulais North is described as an extension of the existing settlement of the north of the

town into areas currently designated as open countryside. Greenfield areas, it states, could be brought forward in conjunction with redevelopment of brownfield

land. The report then continues "a number of Candidate Sites have been submitted for land east of Tyn-y-Bonau Road, and land east and west of Glynhir Road". It describes this option as "a potential opportunity to provide new housing in a relatively sustainable location, and to deliver enhancements to the facilities and

infrastructure" of the town. It also notes potential flood risks. This in effect rules out land east of Glanhir Road and the southern part (only) of site PT0009. The

important new factor of course is the new road proposed in the Hyder study which can serve and open up for development the three candidate sites PT0007, PT0008 and PT0009 (northern part). A fourth site (PT0011) of Glanffrwd Road lying between the latter two, could also be available.

Environmental

Planning (Mr

Graham King)

41576

4. The local of these sites is shown in the accompanying plan together with the notional route of the Hyder study road. This confirms that site PT00078 could take

the opportunity presented by the road to be enlarged. Taken collectively the development value of these sites would enable a contribution be made to the cost of the road. If this is achieved the new road would serve to open up a brownfield site, provide access to a major housing expansion, and also serve the industrial estate. The residual green space could be integrated by way of a master plan for the development of the area.

Environmental

Planning (Mr

Graham King)

41576

I enclose a copy of a joint response to your consultation on behalf of the owners of the above candidate sites in North Pontarddulais, who have expressed an

interest in the development of their sites for development in connection with the proposed road. All parties would be happy to negotiate a satisfactory scheme

generally acceptable. We look forward to hearing from you. SWANSEA LOCAL DEVELOPMENT PLAN CONSULTATION ON STRATEGIC OPTIONS

RESPONSE ON BEHALF OF CANDIDATE SITES IN NORTH PONTARDDULAIS PT007, PT0008, PT0009. 1. This response is on behalf of the three candidate

sites listed above located in North Pontarddulais. PT0007 and PT0008 are both accessed from Tyn-y-bonau Road, and PT0009 from the direction of Glanhir

Road. All three sites are affected by the line of the proposed new road in the Hyder Traffic Study which affords an opportunity to provide both improved access to

the Industrial Estate (Macmillans) and the release of these sites for residential development including potential for part funding of the proposed road.

Environmental

Planning (Mr

Graham King)

41576

5. As the consultation report notes, the general location of these sites is relatively sustainable, and would be well served by public transport, close to schools, and

other facilities. Should the road be adopted in the plan, the landowners and their agents would be happy to discuss further feasibility studies with a view to

Pontarddulais being designated as a strategic development in the plan. There is developer interest. Key to Plan (refer to file for plan) - Site A on Plan - PT0007 -

off Ty'n y Bonau Road, owned by J & E Roberts Site B on Plan - PT0008 - part Ty'n y Bonau Farm, owned by Keith Griffiths Site C on Plan - PT0009 - off Glanffwrd Road, owned by H Davies

Environmental

Planning (Mr

Graham King)

41576


Sw


ent Plan

P

onta

rddu

lais

Sou

th

Pontarddulais South-If this option was advanced it would allow for the possibility of an inner by pass from Bolgoed Road to the Tesco development-Support D Gwynn 41323

Pontarddulais South - Anymore new builds would further stretch infrastructure - objection A Capp 41316

Pontarddulais South - Cannot cope with more housing - Objection G Watkins

41310

2. Pontarddulais South - The habitat in this area appears more diverse than Pontarddulais North with good coverage of woodland, mature hedgerows, scrub, wet marshy areas and semi approved fields. - The area of the south of Bolgoed Road and the A48 is mainly made up of improved fields however there is an area

mapped as a spoil tip under our Phase 1 habitat survey data. Although we do not hold current habitat information for this area, it may be of nature conservation

interest and further survey work may be needed. We would refer you to your Local Authority Ecologist for any available information.

Countryside

Council for

Wales 41558

Pontardulais - It is considered that the site GO0001 would be suitable as a Strategic Urban Extension Area for up to 120 new dwellings - Support GO0001 as a

Strategic Urban Extension Boyer Planning

41532

Pontardulais - It is considered that the site would be entirely appropriate as a Strategic Urban Extension - Support the inclusion of the site as a Strategic Urban

Extension. Boyer P 41533

Section 3 Pontarddulais North & South - Pontarddulais has has significant housing development over the last 15 years and the infrastructure cannot cope with

additional development. The schools are full as is the surgery and the existin transport network will not manage further development. Pontarddulais has a

Welshness only matched within the City and County of Swansea by the community of Mawr. To continue to introduce new housing development will dilute that Welshness and make Pontarddulais a culturally poorer place.

Pontarddulais

Town Council

41503

This representation is provided on behalf of Llanedi Community Council and is based upon both the observations of local councillors but also the results of a

Community Consultation exercise which was completed over last few months. This representation is specific to the options being considered for the spatial options for growth in particular in relation to the Pontarddulais area. The Council notes the comments contained in the following section of the document: "2.5 It is critical that new development areas must be served, or be capable of being served, by appropriate infrastructure. This includes appropriate transport routes and services, education provision, community facilities, utilities and drainage infrastructure." The Council has serious concerns in relation to the infrastructure of Pontarddulais especially as there has been significant both commercial and residential development in recent years. In particular, the main concerns relate to the

transport infrastructure serving the community. There are particular problems at the entrance roads to the community where there are sub-standard bridges, including Pentre Road, Bolgoed Road and bridges within the town centre together with narrow restrictive roads accessing the Town from the East. The net effect of these problems would be the intensifying of traffic crossing over the river Loughor to access the M4 motorway through Hendy. This would cause a serious

problem as there are currently significant traffic issues which have been identified in the Hendy area and there are no immediate highway solutions identified

which could remedy this problem. Based upon the above factors, Llanedi CC are of the opinion that there should not be any significant further development considered in the Pontarddulais area until such time as existing transport infrastructure is significantly improved to the South and East of the community

including where appropriate a new junction to the M4 motorway to serve the community. The Council are also of the opinion that any future development in the

area should have a balance of residential and employment opportunities in order to ensure that there is scope for employment provision for local people thus

creating a more sustainable community.

Llanedi

Community

Council (Mr

David Davies)

41392

Mor

risto

n

Sou

th &

Nor

th

Morriston South - We support development at this location as a number of parcels and blocks of land in the area in question are free from many constraints, including flood risk and nature conservation interest. The area also represents a location for future sustainable growth on the basis of its excellent public

transport infrastructure, community facilities and local services, together with a range of nearby employment opportunities, particularly the large increase in job

opportunities in the nearby DVLA offices - Support

J Evans 41444

3. Morriston South The area contains mature hedgerows and is quite wooded with marshy areas. CCW 41558


Sw


ent Plan

Morriston South - An area of greenfield land, within a UDP green wedge has been identified on land opposite the DVLA. Whilst this area provides good

accessibility, the Council will be required to give careful consideration of the loss of the existing green wedge allocation and large areas of greenfield land (and its

agricultural quality). As such, a sequential approach to the allocation of new sites should prioritise sites already located within the settlement boundary. Sites put forward by Edenstone Homes close to the Morriston South site identified in the Strategic Options report are considered to respresent a more sustainable and

suitable option for growth in this part of the city given that they lie within the settlement boundary and are not subject to any green wedge or other protective

designations in the UDP. The Enfield Close sites (as referred to above) have a cumulative site area of 3.8 hectares - and therefore residential development of this

site has the potential to make an important contribution to housing growth in the emerging LDP period (circa 100-120 houses). The site credentials are set out in

detail in the candidate site submissions. However, in summary, the site is adjacent to an established residential area and is clearly suitable for infill residential development. The site does not lie within any landscape designation (as defined by the current UDP). Indeed, the site is currently underused and does not form

any significant landscape function or provide any visual amenity to the neighbouring residential estate. It is also relevant to note that land to the south of this land, the former Cwmrhydyceirw Quarry, is also likely to become available for development within the plan period. The Quarry site is currently subject to proposals for

infilling. However, there is clear potential for a joint development of the quarry site and the two candidate sites in the future. This could take place in either a

phased approach, bringing forward the greenfield elements in advance of the quarry infilling and settling period or, as a single phase by reclaiming the existing

land and creating a development plateau. Each option is viable within the plan period up to 2025. The combined sites could feasibly deliver over 250 dwellings

within the plan period, on partially brownfield land within the settlement boundary and without any landscape or heritage constraints. Of the sites set out in

Section 3: Areas for Consideration, the vast majority are either constrained by green wedge or countryside designations. Of the few that would not result in

extensions into the exsiting countryside or green wedge, the large sites are either existing strategic employmet sites or would be affected by flood risk/drainage

constraints. The strategy and subsequent allocations within the LDP should seek to maximise the potential of existing unconstrained and sustainable sites such

as those promoted by Edenstone in Morriston as this will reduce the need to allocate sites outside of the existing settlement boundary. The sites tehrefore

represent a more sustainable and suitable alternative to the Morriston South site identified within the Strategic Options Concept Plan. The sites promoted as

candidate sites by Edenstone, either independently or along with the Cwmrhydyceirw Quarry site are capable of being developed within the plan period. They are

in a sustainable location and would not require intrusion onto the countryside as many of the other sites being considered would do. As such, it is recommended

that sites such as the Edenstone sites should be prioritised over the allocation of both the identified site at Morriston South and, the other new sites being

promoted outside of existing settlement limits. Importantly, regardless of the strategy adopted for the LDP, the Edenstone sites should feature as an allocation

given the suitability set out above.

Paul Williams

41521

Morriston North - We support health related development at this location as its close proximity to Morriston Hospital represents a sustainable opportunity to

further enhance the medical offer of the County to its residents - Support Jason Evans

Planning 41506

Morriston North - The LHB welcomes the reference, under this heading, to proposed new healthcare provision on land north of Mynydd Gelliwastad Road, which

the LHB has submitted as a candidate site. Although greenfield, the site is not subject to any constraints on the LDP Constraints Map and comprises lower grade

agricultural land which appears to be used mainly for horse grazing. The site is not subject to any statutory designations or fundamental environmental constrains and is free of flood risk. The site lies adjacent to the Morriston Hospital campus, which is currently undergoing a phased programme of redevelopment to improve clinical services and patient facilties. This land represents the best opportunity for future expansion of Morriston Hospital, which is one of a small number of major specialist hospitals in South Wales - Support

WYG (Paul

Vining) 41473

4. Morriston North There appear to be less improved grasslands than Morriston South. Hedgerows provide connectivity with wooded areas and semi-improved

grasslands. CCW 41558

4.3 Morriston North & South There appears to be constraints related to Flood risk & green wedge/buffer zones protection which will have implications for potential development proposals.

EAW 41579

Morriston North - There is an opportunity to deliver a small infill scheme on the edge of settlement limits on land off Mynydd Gelliwastad Road - as referred to

above. The site is adjoined by existing residential development and has the potential to provide housing in order to meet existing demand from the nearby major

Paul Williams

41521


Sw


ent Plan

employer of the hospital or in association with the possible expansion of the NHS Hospital Campus and private medical facility. As recognised in Option 2, it wil be important in the emerging plan to include the potential for some small-scale expansion in semi-rural areas, particularly where this would serve to meet identified housing need to meet the range and housing of housing opportunities. The site has been put forward as a candidate site (see attached plan - refer to

file). Importantly whilst the site is with a green wedge, development would not result in any further intrusion into the countryside, given that it is already bordered

by residential development.

Fab

ian

Way

Cor

ridor

Fabian Way Corridor - ABP supports the recognition in the document that Swansea Docks make an important contribution to the economic infrastructure of the

County. ABP generally supports the inclusion of the Fabian Way Corridor as a strategic urban extension and the potential inclusion of land around Queens Dock

in this allocation. It is considered important, however, that the allocation does not impinge on the docks port - related activities both existing and future. In this

regard ABP welcomes the fact that the document recognises that decisions relating to the future use of the docks are key to the future of the Fabian Way

Corridor. Clearly, therefore, there will be a need to ensure that the wording of subsequent policies on this matter allows for sufficient flexibility in relation to the

future uses of land at Swansea Docks and, in particular, of land around Queens Dock - General Comment/Support

RPS Planning &

Development

41470

Fabian Way, M4 Corridor, Swansea Valley (Morfa etc.) - Increased housing should be near infrastructure, public transport, employment and social opportunity

etc. Principle of brownfield site use is good. Hence these areas seem most appropriate for development. - Support Mrs Bridget

Stein 41510

Areas for Consideration With respect to areas for consideration, it is a little premature to consider these until some firmer guidance is provided on levels of growth

and the Council's vision is given a spatial dimension (and sequence). However it is clear that whatever option is chosen, and at this stage conclusions can be

made on two areas - Fabian Way and Felindre. Fabian Way Corridor - A candidate site submission was made in March 2011 for Land West of Transite Site, Fabian Way - which has since been supplemented by a Technical Note relating to flood risk (Atkins, reference 5077145-TRA-OUT-0078). The site has been put forward as a candidate site for inclusion within the emerging LDP for mixed use employment, residential, commercial, civic and environmental. The site also lies

within the Swansea Bay (Waterfront and Western Valleys) Area, which is identified as an area for growth within the Wales Spatial Plan (WSP). The site is

previously developed and available. It is also extremely well located and next to the main arterial highway (A483) which provides direct access into the city

centre of Swansea. It sits next to the Bay Science and Innovation Campus for Swansea University which is regionally significant project. The site shows why the

'Fabian Way Corridor' area will be a sustainable location for growth whichever option or level of growth is selected. As identified by the Council, the area

represents one of the largest brownfield sites in the County - and its redevelopment is one of the plan's key responsibilities. The Council also recognises the

significance of the new Campus and the Transit Site is a key opportunity (that can both support the University and enjoy the improved public transport linkages

that it will trigger). Few other areas of consideration can perform as well as the Fabian Way Corridor and the area should be a priority for development in the LDP.

Tim Gent 41524

5. Fabian Way Corridor - Brownfield land noted and prepared for development - We advise that any mixed use proposals that would contribute even potentially

small emissions to air and thereby potential effects on air quality should be considered in the HRA (Habitats Regulations Assessment) process for possible effect on Crynmlyn Bog SAC which lies in close proximity to this area. - We have previously highlighted the hydrological link between the Tenant Canal (which forms

part of Crymlyn Bog SAC) and the Prince of Wales Dock through an underground culvert. Where relevant this should be taken account of through HRA when

considering LDP allocations. - Derelict areas may need to be surveyed for the presence nesting birds if works are to be carried out during the breeding season

(March-August inclusive). - Development in this area has opportunity to incorporate open green space and explore further connections with nearby recreational assets including Kilvey Hill, the Wales Coastal Path, cycle routes and the Crymlyn Bog National Nature Reserve and Reserve Centre.

Countryside

Council for

Wales 41558

4.4 Fabian Way Corridor This is a key strategic site for development within the LDP cycle and proposed future presence of Swansea University at this location

may act as a catalyst for other associated developments. Allied to this proposal the main gateway into the City offers opportunities for exciting proposals within

the SA1 quarter/Docks area. Our concerns would relate to possible existing land contamination and flood risk to new schemes.

Environment

Agency Wales

41579

Sw

anse

a

Val

e 6. Swansea Vale - For advice on any constraints to this area due to flood risk we refer tyou to the EA - The impact of development on otters and bats, both

European Protected Species, should be considered due to the proximity of the site to the River Tawe - We refer you to your Nature Conservation Team/Local Authority ecologist for further comments on this area including the nearby Swansea Vale Nature Reserve and any potential SINC sites.

Countryside

Council for

Wales 41558


Sw


ent Plan

4.5 Swansea Vale We have actively involved with your authority & Welsh Government in schemes for the improvement of flood protection infrastructure in this

location to ensure the protection of existing development. EAW 41579

Mor

fa

Morfa - This area is around the important Copperopolis site and would be better developed for tourism and heritage etc. and education - Objection Sandy Johns

41591

7. Morfa (Land either side of Nantong Way) - CCW holds bryophyte (lower plant) data from two surveys conducted in the Atlantic Close and Pluck Lake area from

2001 and 2007 concluding that Atlantic Close, Pluck Land and Six Pits Branch is of significant local/regional importance for its metallophyte moss and liverwort assemblage. Any development in this area should consider its impacts on the bryophyte assemblage further and update surveys and CCW can provide copies

of the report on request - The area is extensively wooded - In addition, Pluck Lake has been know to support good records of dragonfly species, we advise further

information should be obtained from your Local Authority Ecologist re the biodiversity value of this area and how this can be incorporated and positvely managed

within any future master planning proposals for the area.

Countryside

Council for

Wales 41558

4.6 Morfa We have are actively involved with your authority & developers in discussing current flood risk; contamination and water quality issues in this area. Environment

Agency Wales

41579

Bon

ymae

n

The option for a sustainable urban extension at Bonymaen is supported. Development of the existing green wedge at this location can be achieved in a sensitive

manner, enabling the urban form to continue to be managed in the area and it will also not lead to the coalescence of any settlements - General Zoe Abberley

41406

8. Bonymaen - The area is made up of semi improved land with marshy areas - This site is situated very close to Crymlyn Bog Special Area of Conservation

(SAC) and Ramsar site, which is of concern to CCW because of potential impacts on the SAC. There are surface water seepages and streams in the fields

adjacent to the site which will flow towards the SAC. Any development within the Crymlyn Bog catchment area should therefore be assessed in details for its

impact on the quantity and quality of surface run-off drainage to Crymlyn Bog to ensure there are no significant impacts on the integrity of the features of the SAC. - The land south of Crymlyn Road appears to be in very close proximity to Crymlyn Bog SAC/Ramsar site. Development of this site has the potential to result in

adverse impacts on the SAC. See comments re assessment above. - This area is currently within the Green Wedge in the UDP, which seeks to prevent the

coalescence of Bonymaen/Winch Wen/Port Tenant and the administrative area of Neath Port Talbot. Given that planning permission exists for the

redevelopment of the former Llandarcy refinery site (Coed Darcy), consideration should also be given to those proposals when considering the review of the

green wedge boundaries and any allocations in this area. Sites should be looked at in-combination with emerging sites in Neath Port Talbot's candidate site

process in order for the impacts of development in the upper catchments of Crymlyn Bog to be fully assessed through SEA/HRA.

Countryside

Council for

Wales 41558

4.7 Bonymaen No adverse comments but need to protect green wedges/buffer zones. EAW 41579

Birc

hgro

ve

9. Birchgrove - We hold little information on this area, aerial photographs indicate scattered scrub and urban fringe sites that we well accessed perhaps by

footpaths? Countryside

Council for

Wales 41558

4.8 Birchgrove No adverse comments but need to protect green wedges/buffer zones. EAW 41579

Cly

dach

10. Clydach Land north of Tan y Coed - Extensively wooded and with wet areas - Target noted on CCWs Phase 1 Habitat survey as marshy grassland

Land north of Gellionen Road (SN 692 025) - Part of the land to the north of Gellionen Road is mapped as Open Access Land under the CRoW Act (2005), where

the public have a right of access on foot. This should be taken into consideration when allocating development sites. Land south of Gellionen Road - Semi improved grassland areas, no detailed information held.

Countryside

Council for

Wales 41558

4.9 Clydach No adverse comments but need to protect green wedges/buffer zones. EAW 41579


Sw


ent Plan

T

ycoc

h

Tycoch - The LHB welcomes the reference, under this heading, to future residential development at Cefn Coed Hospital, which the LHB has submitted as a

candidate site. The site comprises previously development land, free of flood risk, lying within the urban area and sustainably located in relation to services and

public transport. It is not subject to any statutory designations or fundamental environmental constraints and is already allocated in the adopted development plan for a mix of healthcare and residential uses. The provision of new healthcare uses at the site has been completed recently and a small part of the site has

received planning permission for residential development. The LHB now seeks the support of the Council in bringing forward a large part of the remainder of the

site for phased residential development. Studies undertaken by the LHB indicate that the site is capable of satisfactorily accommodaing 500 dwellings within the

plan period - Support

WYG (Paul

Vining) 41473

11.Tycoch -The large undeveloped area to the west of Cockett and Tycoch, north of Killay and south of Waunarlwydd is a very elevated, prominent ridge, highly

visible in the landscape. The Landscape and Visual Impacts of any development proposed on this ridge should we consider, be fully assessed for its effects on

landscape as advised on page1-The area is within the green wedge on UDP, as it is been recognised as a prominent area in Swansea's landscape where it is

important to avoid the coalescence of Tycoch/Cockett and Waunarlwydd. Clear justification should be provided if the green wedge boundaries in this area are to

be revised, leading to the coalescence of these settlements and the erosion of the landscape on this prominent ridge.-Area has wooded areas, with scrub areas

on the slopes-For advice on land drainage we refer you to the Env Agency-The wider area is known to be important for bats commuting through Clyne to Dunvant therefore any development should consider its effects on bat species. Given the density of houses nearby, this land provides an opportunity to facilitate urban

green space provision and green links for wildlife through to the Cockett Valley.

Countryside

Council for

Wales 41558

4.10 Tycoch No adverse comments but need to protect green wedges/buffer zones. EAW41579

Thi

stle

boon

, M

umbl

es

Thistleboon - This proposal forms a fundamental part of the AONB and has been set aside to form a green buffer zone between the coast and residential and thus

its continued format must be retained 41334, 41338

Thistleboon - Any plan that does not fully protect the AONB (as per the vision) is flawed on environmental, natural and sustainability grounds and should not be

considered - Objection Steven

Herrieven

41375

Langland & Thistleboon - Must be conserved as an area of natural beauty Judy Rees

41370

Langland Cliffs & Thistleboon - Should not be developed. They should remain an area of natural beauty. R Rees 41373

Thistleboon - Area planned is area of outstanding natural beauty, coastal area J Rice 41358

I object to the fields at Thistleboon or any of the Gower Coastal Path proposed developments. It's shocked me that you can even consider building on such a

beautiful landscape. I live in Swansea and when I go to the Cliffs and fields in the Gower I don't want to see any more houses or buildings. P Mayf 41393

Whilst understanding the difficult position the planning dept is in with regard to identifying potential sites for development, I was nonetheless staggered to see

that the Site at Thistledown is being considered. Of all the different options available this should be dismissed immediately. Some sites deserve to be protected

with all the force the council has. Development of this area is a real mistake, and the council needs to take its responsibilities of guardianship seriously. We are

blessed in Swansea with some of the most beautiful coastlines in the country, appreciated and cherished by both residents and visitors. Ruining this and building

bland housing would be a gross mistake. I object strongly to the thistleboon site's inclusion in this proposal.

Mr Boyd Erlam

41304

12. Thistleboon, Mumbles - This area is located within the nationally designated Gower Area of Outstanding Natural Beauty (AONB), where the primary objective

for designation is the conservation and enhancement of its natural beauty. Development plan policies affecting AONBs should therefore favour conservation of the area's natural beauty, and give great weight to conserving and enhancing the natural beauty, wildlife and cultural heritage of these areas.

- For any development within the Gower Area of Outstanding Natural Beauty (AONB), or that is likely to affect the area, we remind you of your Council's duty

Countryside

Council for

Wales 41558


Sw


ent Plan

under Section 85 of the countryside and Rights of Way Act 2000, which requires Local Authorities to have regard to the purposes of conserving and enhancing

the natural beauty of the AONB. The statutory purposes of Areas of Outstanding Natural Beauty are conservation and enhancement of natural beauty. As you

are aware, your authority's AONB team have recently overseen the production of a Design Guidance for Gower, with input from CCW. The design guide should

be used to inform the above considerations for any proposal in the AONB

- Langland Bay (Rotherslade) geological Site of Special Scientific Interest (SSSI) lies close by to the South West of the site.

4.11 Thistleboon Environmentally sensitive area. EAW 41579

The Mumbles Community Council Area With respect to the suggested allocations, the Community Council's more detailed observation relating to Thistleboon, Mumbles and Newton/West Cross, Mumbles are below:

Thistleboon, Oystermouth Ward, Mumbles:

Thistleboon would not be a suitable site for development under the criteria outlined in Strategy 4 of the following reasons:

- The site is within the Gower AONB and it therefore forms a vital buffer between existing developments and the coastal pathway and it is a rich source of biodiversity.

- Gower Area of Outstanding Natural Beauty

* Gower, including the proposed site at Thistleboon and the cliffs in front of this site, was the first AONB in the British Isles in 1956. The AONB is subject to Policy

EN26 of the Unitary Development Plan, a policy fully supported by MCC, which states:

"Development which would have a material adverse effect on the natural beauty, wildlife and cultural heritage of the AONB will not be permitted."

- There are only two access routes to the site. Both are residential and too narrow.

* The present local highway infrastructure, consisting of narrow lanes with infrequent passing places, (specifically between Beaufort Avenue and Worcester

Drive section of Higher Lane and Plunch Lane). These narrow stretches provide an important buffer to help discourage high volumes of holiday and tripper

traffic, as well as vans and lorries, using these roads as a short cut to and from Mumbles or the beaches.

- Primary schools in the area are near capacity.

- Sewage and drainage systems in the Mumbles area have already exceeding their intended capacity.

* it is believed that the discharge from any development here would eventually join the sewer running under Newton Road. This would not be acceptable due to

lack of sewer capacity.

- There is a risk of subsidence or other damage to houses and infrastructure as the site is on limestone, honeycombed with many sink holes and with old mine

adits running underneath it.

- The site is outside of the existing settlement boundary defined in the Swansea UDP: Policy EV20/21 Development in the Countryside. This policy is supported

by MCC.

- Previously, this site has been recognised as being located outside the settlement boundary in Swansea UDP and it forms a vital green buffer between the

existing development and the well-used coastal pathway, part of the All Wales Coast Path.

* Development would almost certainly have a detrimental effect on these protected areas.

Mumbles

Community

Council (Mr

Steve Heydon)

41561


Sw


ent Plan

- By retaining the fields in question as agricultural grazing land, due to close proximity to both Bracelet Bay SSSI and Mumbles Hill Nature Reserve, it will help

safeguard the biodiversity of the local wildlife in the fields, cliffs and the Mumbles headlands.

- There are no additional employment opportunities in the MCC area.

* Development would lead to daily migration to a workplace in Swansea or elsewhere.

* The additional residents would work and shop outside of the MCC area and this would make any housing development on this site akin to any deserted second

homes site in Wales.

- The Mumbles Road is already one of the busiest roads in Wales and cannot sustain any higher levels of commuter traffic.

* Parts of this road are now designated as being within an EA level 2 flood risk zone and there is an increasing risk of flooding causing temporary closure as

storms increase and sea levels rise.

Thistleboon - We are sceptical that development of a strategic urban extension can be achieved at Thistleboon without significant harm to the Gower AONB -

Objection National Trust 41542

Thistleboon - This is, as you state, an environmentally sensitive area and merits protection. It is, in our view, particularly important to protect the vulnerable edge

of the AONB where it interfaces with urban Swansea. This is a very desirable area for developers to 'cherry pick' for expensive (and profitable) development, but pressure for any such development must be resisted. The infrastructure here (particularly the road system) is already under great pressure.

The Gower

Society 41593

New

ton

4.12 Newton No adverse comments but need to protect green wedges/buffer zones. EAW 41579

13. Newton - This area is made up of improved agricultural land and is located in close proximity to the to the Gower AONB boundary - Woodland areas and

hedgerows - some tall and overgrown, others managed - Any development of this area should consider its effects on protected species e.g. bats and dormice

due to the presence of potential suitable habitat - Pwll du Head and Bishopston Valley SSSI lies to the South West of the site (within 1km) - The area is within the

green wedge on UDP, as it is being recognised as a prominent area in Swansea landscape where it is important to avoid the coalescence of West Cross/Newton/Bishopston, and manage the urban form of the area. Clear justification should be provided if the green wedge boundaries in this area are to be

revised, leading to the loss of openness of the area, reduction in connectivity between the urban green corridors and the open countryside, and the likely

coalescence of the aforementioned settlements and the resulting loss of distinctiveness that would occur.

Countryside

Council for

Wales 41558

Dun

vant

Dunvant - We support development at this location as a number of parcels and blocks of land in the area in question are free from constraints, including flood risk, traffic congestions and nature conservation interest. The area also represents a location for future sustainable growth on the basis of its excellent public

transport infrastructure, range of community facilities and local services, together with a range of nearby employment opportunities. - Support

J Evans 41505

4.13 Dunvant No adverse comments but need to protect green wedges/buffer zones. EAW 41579

15. Dunvant - Very wooded areas with some agricultural fields - Currently designated in the UDP as a green wedge, where it is considered important to retain the

openness and character of the area between Dunvant, Three Crosses and Gowerton, and the Cockett and Hendrefoilan Ridges and manage the urban form of the area. Because of the prominence of many of these areas, particularly when viewed from the AONB, clear justification should be provided if the green wedge

boundaries are to be revised, leading to the erosion of the openness of the area, coalescence and loss of character and distinctiveness. - Some semi improved

grassland and scrub areas - Any development of this area should consider its effects on bats and dormice in the area due to the presence of potential suitable

habitat

Countryside

Council for

Wales 41558

DV0002 Land at Killan Fach Dunvant - We have concerns about what might be included in the term 'mixed use'. If residential housing is included then we think

the current road system would not cope with the associated increase in volume of traffic. The area is adjacent to a site of special scientific interest (SSSI) and a

Colin & Hilary

Fielder 41515


Sw


ent Plan

residental area so we would want assurances that whatever is included in the term mixed use would not create elevated levels of noise pollution. Again, depending on what is proposed by the term mixed use, since the area is adjacent to a SSSI we would suggest that restrictions are considered for the large scale

use of herbicides and pesticides which could be harmful to local bees and other insect - Comment

Gow

erto

n

Gowerton - Support is given for the recognition that Gowerton is an area where development is considered to be appropriate. Notwithstanding this, it is noted that the Strategic Options document only refers to, and presumably by association, seeks to focus development to the south of Gowerton. It is considered that this

strategy is flawed in that there are viable, suitable and appropriate sites available for development to the north of Gowerton. Accordingly, an extension to the

settlement boundary to the north of Gowerton is considered appropriate, and would ensure that a range of appropriate development sites are provided for within

this sustainable location. - Support & Object Areas Not Currently Shown - Land to the north of Gowerton, and in particular land to the east of Fairwood Terrace

(Candidate Site Reference No. GT0006) is considered suitable to provide for residential development. Please refer to the accompanying cover letter and annex

for our detailed case (refer to file for documents). Section 3- Support is given for the recognition that Gowerton is an area where development is considered to be

appropriate. But, areas to the north of Gowerton, in particular land to the east of Fairwood Terrace (candidate site ref. no. GT0006) is considered to be a suitable, sustainable and appropriate site for residential development. Please refer to the accompanying cover letter and annex for our detailed case. (Refer to file for

documents). - Support & Object

Penllergaer

Estates Ltd c/o

Geraint John

Planning Ltd

41469

16. Gowerton - Currently designated in the UDP as a green wedge, where it is considered important to retain the openness and character of the area between

Dunvant, Three Crosses and Gowerton, and the Cockett and Hendrefoilan Ridges, and manage the urban form of the area. Clear justification should be

provided if the green wedge boundaries are to be revised, leading to the erosion of the openness of the area, coalescence and loss of character and

distinctiveness.

Countryside

Council for

Wales 41558

Equally the continued pressure on the Gowerton waste water treatment works and its effect on the Burry Inlet Special Area of Conservation needs to be

addressed before any further consideration to the continued urbanisation of the ward. Mr William

Meredith 41428

Loug

hor

Upper Loughor - In the ward profile document maps you show the land adjacent to Tre Uchaf School as 'leisure'. You should be away that this is not what the

authority is saying, as this land has been closed and shut off from the community since the previous administration decided to put forward the disposal of school land to help finance the developments elsewhere - General comment.

James

Waygood

41539

Loughor - Loughor should NOT be included for Strategic Urban Extension or any other medium-large scale development, the infrastructure just can not cope with

the existing population. Highway safety issues have been raised continuously as the road system can not cope now. Loughor Road is already a very busy road

and becomes gridlocked daily around school start of day and end of day. It turns into a one way street when the college buses depart on mass at 4.55pm and

roads blocked should buses meet lorries or other buses coming in the opposite direction. Cars are damaged frequently and I have witnessed too many near-miss incidents to count on that road alone in the 5 years I've lived in the area. The traffic generation from any new developments in this area would be absolutely

horrendous in terms of further noise, pollution and road blockages due to traffic colume and no alternative access. There would also be serious implications for

any Energency Services trying to negotiate the highways already in poor condition as well as being blocked with traffic for example. Due to the inadequate road

system alone, Loughor should clearly be excluded from this process. Schools, doctors, dentists etc. are already over-subscribed in the area, it can take up to 3

weeks for a Doctors appointment and unable to register with a local dentist for example. There is not the capacity in the area to cope with additional developments. This would clearly be gross over development of the area if allowed to progress, there is already inadequate drainage and flooding/surface water

issues on the local roads and visible in the fields-come-rivers, surrounding current developments, which with further developments would be exacerbated. The

stench from Gowerton Sewerage works that reaches Loughor would indicate the sewerage system can not cope either. There would be significant adverse effect on Burry Inlet (SPA & RAMSAR site). The close proximity to the sensitive environmental areas for protection and safeguarding will be put at risk. There is also a

need to protect green wedge/field/green areas set in place in the current UDP to retain the openess of the areas, preserve and enhance the linkes between urban

areas and the countryside, to help preserve wildlife corridors/habitat and the landscape. Green wedges constitute an additional presumption against development, over and above those normally applied and should be kept of not increased in the new LDP - not decreased and developed. There is a need to

prevent coalescence of settlements - to prevent merging communities together (loughor and Kingsbridge) through over development. Conflict with the character

Miss Kelly

Shefford 41422


Sw


ent Plan

of the area, loss of visual amenity, spoiling natural/existing contours, potentially threatining public rights of way and insufficient amenity land locally in the area at present would all apply here with any new developments proposed. There will also be an increasing imbalance between jobs and homes in the area. There are

better alternative sites suggested/available. Therefore Loughor SHOULD NOT be included as an 'area for consideration'. - Object

17. Loughor - CCWs Phase 1 habitat survey maps areas of species-poor semi improved grassland to the south of Glebe Road, large overgrown hedgerows and

some areas of scrub woodland. - The Afon Lliw, a tributary of the Burry Inlet flows to the east of the site and any impacts on flow or water quality would be a

consideration in relation to the SAC. - Please refer to the Environment Agency for advice on flood/drainage considerations - Parts of the area are currently

designated in the UDP as a residential use with the remainder designated as green wedge to retain the urban form and openness of the land between Gowerton, Loughor and Kingsbridge and avoid the coalescence of those settlements. Clear justification should be provided if the green wedge boundaries are to be

revised, leading to the erosion of the openness of the area, coalescence and loss of character and distinctiveness. - Areas to the south of the B4620 - very similar

habitat to the above site but generally has more agriculturally improved areas.

Countryside

Council for

Wales 41558

I have read the strategic options consultation draft and I want to register my interest in land at Loughor, which I consider should be included in future housing

development. I appreciate that I am too late for the land to be considered as a "candidate site". I enclose a plan showing the land I own included in the current UDP edged red and hatched. I also own the other land edged red on the plan. Persimmon intend to develop the land to the North of my land as shown on the

plan. I submit that some of my land adjacent to the Persimmon development should be included in future residential development. I have shown this land on the

plan. The remainder of this land, although potentially on the flood plan, could be used for leisure and green space. (* refer to consultation file for map).

Anonymous

41580

Gar

den

Vill

age

18. Garden Village -Mainly agriculturally improved areas with some semi improved grassland to the very north of this area.

- Scrub and wooded areas to the north of the area with hedgerows throughout

- Land to the east of Llys Aneurin and Ffordd Talfan is mapped by CCWs Phase 1 habitat survey as mixture of some semi-improved and improved fields with

some marshy grassland further to the east

- Mynydd Garn Goch lies to the east, which is of higher habitat value (CCW Phase 1)

Countryside

Council for

Wales 41558

Gor

sein

on W

est &

Eas

t

Gorseinon West - Referring to Whitley Fach. This is in the Upprt Loughor Ward and is not part of Gorseinon. Any development of this size will blur the urban form

and put very significant pressures on the already creaking infrastructure. The proximity of the Loughor SSI is a major concern. - Objection but also a general comment

James

Waygood

41539

19. Gorseinon West - Whitley Fach Farm - the Burry Inlet and Loughor Estuary SSSI/SAC/Ramsar/SPA lies immediately adjacent to this site. There are also

streams on site which drain into the Loughor Estuary. Full consideration should be made for any development's effect on the drainage in this area and water

quality and any physical disturbance issues should be addressed as part of the Habitats Regulations Assessments (HRA) of the LDP, and of specific project level HRAs for any development applications at the site. - Please refer to the Environment Agency for advice on flood and drainage issues - Mainly agricultural land

with some mature hedgerows - Clear justification should be provided if the green wedge boundaries are to be revised, leading to the erosion of the openness of the area, potential coalescence of Gorseinon and Penyrheol, and loss of character and distinctiveness of the area

Countryside

Council for

Wales 41558

20. Gorseinon East - Land east of Heol y Mynydd consists mainly of agricultural fields, with some semi-improved grassland areas - Clear justification should be

provided if the green wedge boundaries are to be revised, leading to the erosion of the openness of the area, potential coalescence of Grovesend and Gorseinon

and loss of character and distinctiveness of the area.

Countryside

Council for

Wales 41558

Ffo

res

tfach

Fforestfach - The major mixed use development in this area is supported because it will deliver new infrastructure (with highway capacity benefits) without reliance on public funding. This will benefit not only the Westfield Industrial Park (Former Alcoa) and land already identified as a potential extension to Swansea

West Business Park, which are significantly restrained in their potential to offer employment generating development by the absence of such improvements, but the existing occupiers, particularly Timet and those located at the Fforestfach Industrial Estate and Waunarlwydd. The proposed residential sites that form part of

Ms Philippa

Cole 41512


Sw


ent Plan

this proposal are closely related to the existing settlement and well aligned to complimentary uses such as retail, employment, recreation and community

facilities. Rather than place pressure on the existing facilities, there is potential to deliver economically on site, those facilities (schools, health, retail and

affordable housing) which cannot reasonably be accommodated by existing facilities or where existing facilities are under resourced and do not meet the draft visions and objectives (e.g. providing first class education facilities). This is in contrast to other proposals which are remove or of insufficient scale to either

demand or fund such facilities.-Support

Fforestfach 3.42 The principle of major mixed-use development at Fforestfach is supported by our clients. The area is closely related to the existing settlement and is well aligned to existing complimentary uses, such as retail, employment, recreation and community facilities. The location is sustainable and represents

an economically viable option for a development of this scale on both brownfield and greenfield land. 3.43 As noted in the Consultation Draft, land at Fforestfach

is already identified for employment development within the adopted UDP. It is, however, acknowledged in the adopted UDP that this development was unlikely

to come forward without associated improvements to access, including a new access road. The identification of this area as a major mixed use allocation would

resolve this issue and help to unlock future development in the area. 3.44 The provision of a significant proportion of residential development to the north of the

Afon Llan and south of the A484 would drive the delivery of infrastructure improvements in this area. It would help facilitate the delivery of improved road access

in the area and associated infrastructure improvements, which would benefit both existing and new employment land to the south of the Afon Llan. The provision

of a new road from A484 (running south to Titanium Road) would ensure significant benefits to the locality. These benefits include diverting heavy commercial traffic from Carmarthen Road and providing improved access to existing occupiers of the former Waunarlwydd Works. The infrastructure improvements would

also improve the marketability of the Westfield Business Park and help to unlock the development of future employment provision. The mixed use scheme would

also allow economically viable improvements to the infrastructure on Westfield Business Park, providing services employment sites to the market, which will not be possible without enabling development. 3.45 The allocation of a major mixed use development in this area would also deliver significant improvements to the

existing green infrastructure and accessibility to open space in the area. The development would deliver a new publicly accessible riverside park, which would

greatly improve the existing landscape setting, and access to it. 3.46 As set above, land at Fforestfach is capable of accommodating a major missed use

development over the plan period. Should the Council decide to not progress a spatial option for growth that includes development of this scale, land at Fforestfach (north of the Afon Llan and south of the A484) should still be brought forward as a residential led strategic allocation over the plan period. Such a

development would represent a sustainable location for residential growth and would be capable of delivering the vision and key objectives of the LDP. It would

be well related to existing complimentary uses, and would deliver significant benefits to the wider area. Technical work undertaken to date demonstrated that land in this area can be brought forward with appropriate mitigation. 3.47 In conclusion, land at Fforestfach is considered to be well related to the existing

settlement and complimentary uses, which is a distinct advantage over other sites identified in the Consultation Draft. Lane in this area also offers the potential to

support the vision and objectives of the LDP through the delivery of a major mixed use development, or a strategic extension. Development in this area would

also help drive forward infrastructure improvements to the benefit of existing and new employment land.

Stephen

Pilliner 41535

21. Fforestfach - This area is currently allocated as a green wedge in the UDP to retain the urban form of the area and avoid the coalescence of Waunarlwydd and

Fforestfach. Clear justification should be provided if the green wedge boundaries are to be revised, leading to the erosion of the openness of the area, loss of connectivity, the potential coalescence of the settlements and loss of character and distinctiveness of the area - Possible SINC - please check fill details of available survey information with your Local Authority Ecologist - Need to determine whether there is any encroachment on the boundaries of Stafford Common -

Close to the Afon Llan, a tributary of the Burry Inlet, any impacts on flow or water quality would be a consideration in relation to the SAC and should be addressed

in the HRA of the LDP, and through project level HRAs where relevant to accompany any future development applications. Please refer to the Environment Agency for advice on flood and drainage issues. - Any development of this area should consider its effects on protected species e.g. otters and dormice due to

the presence of potential suitable habitat.- CCW Phase 1 survey holds a target note for the area to the west of the factory stating that there is marshy grassland

interest.

Countryside

Council for

Wales 41558

4.16 Fforestfach Various developments have been proposed for this area and there are flood risk; environmental sensitive areas and also in part the foul/surface

water drains to Gowerton STW/Burry Inlet and as such mush be subject to careful foul and surface water drainage provision/assessment. EAW 41579

l i n d Felindre 3.48 Land at Felindre is not supported as a major mixed use allocation. It is not a sustainable or logical location for significant housing growth. The area Stephen


Sw


ent Plan

does not benefit from access to complimentary uses, services, facilities and infrastructure, or access to public transport, in the same way that would be delivered

at locations such as Fforestfach. We would also question the economic viability of the site and whether there is demand for either employment or residential development at this scale in this location. 3.49 The Consultation Draft itself recognises that the area is relatively remove from the main built up areas of Swansea, which raises issues about the sustainability of a major residential development at this location. The area would not represent a logical or sustainable major mixed

use extension to Swansea, and would not be effectively linked to the rest of the Swansea urban area. When considered against other sites of this scale, such as

Fforestfach, it is not considered to be sustainable or appropriate.

Pilliner 41535

North of M4 (e.g. Felindre) - I would suggest development here would not be a good idea as it increases the areas for ambulances, police, fire service etc. to over

and puts people at distance from most other services - e.g. schools. Crossing the M4 may be subject to delays which are difficult to avoid. It also eats into "green"

areas which are increasingly essential to all as areas for leisure, exercise etc. - General Comment.

Patricia Anne

Jenkins 41351

The community of Felindre would benefit from a small extension. Young people and their families have not settled in the village because of the lack of housing. This has adversely affected the community - especially the shop, the pub and the primary school.

A W G Stone

41330

Felindre - Concern that a new settlement at Felindre is remote from the main built up areas of Swansea for such a potentially extensive allocation. This

remoteness brings into question whether this is somewhere residents will want to live, whether it would successfully address the future housing needs of the city

during the plan period and whether it is a sustainable and viable location in line with the draft Vision and Objectives. In addition, the site has failed to attract employment occupiers in the past despite being identified for employment use in the West Glamorgan Structure Plan Review No. 2 adopted in February 1996. The ability of this site to contribute significantly to the employment land needs of the city is therefore questionable - Object

Ms Philippa

Cole 41512

Felindre - I'm in favour of the brownfield Felindre site as this needs an upgrade and its proximity to the M4 will make it an attractive proposition. - With minimum

encroachment into greenfield. C Humphreys

41462

Felindre & Fforestfach - Any large developments within infrastructure will meet a large quantity of housing needed without spoiling smaller villages. J Probert 41465

Felindre - We would question the consideration of this area for any form of development, especially that of a strategic nature. Its isolated and poorly connected

location from public transport nodes and any community faciltiies or local services raises serious questions with regard to its sustainability level. - Object Jason Evans

Planning 41445

Felindre - A great opportunity for mixed development on a large scale, utilising waste ground/space with existing good road links. Area such as this and old

factory sites left empty/derelict should be targeted and developed first as a priority and where the infrastructure exists/can easily be improved to cope with such

developments.

Miss Kelly

Shefford 41422

Felindre - We would support the use of this land for the creation of a new fully serviced community. Ideal location - large site - access to infrastructure and utilities -

adjacent M4 Mr M Ford

41349

Felindre - Just as Fabian Way will feature in the plan regardless of the strategy and growth level that is selected, the Felindre site shows why that strategy needs

careful consideration and management. The Council recognises its significant deficiencies in the papers presented and there is no need for it at this time. If current exercises into the site announced and sponsored by WG and the Council show any potential on this greenfield site, then this should be reserved for future

plan periods, so that efforts and resources are properly focused on completing existing sustainable projects and initiatives, rather than starting new ones (no

matter how well intentioned this might be). In this context, Felindre is the polar opposite of Fabian Way and it is difficult to see how or why it should be pursued as

part of any option in the LDP - no matter what growth strategy or rate is chosen.

Tim Gent 41524

Felindre - This area is close to M4 and has limited impact on smaller communities - General Comment D Powell 41461

Felindre site. Mixed use development with a better authority control than that seen at Tir Coed. I wonder also if there is already ample provision and space

allocation for industrial units elsewhere in the authority area. James

Waygood


Sw


ent Plan

41539

Felindre - Most suitable location - Support Mr C

Taylor 41597

The city centre is particularly the focus for the area's evening economy and will contain the city's main leisure and entertainment facilities/ We therefore suggest that the LDP Preferred Strategy contains a policy that will protect your existing community and leisure facilities in the city centre by resisting their loss or change

of use unless replacement facilities are provided on site or within the vicinity which meets the need of the local population, or necessary services can be delivered

from other facilities without leading to, or increasing, any shortfall in provision, and it has been demonstrated that there is no demand for another similar use on

site.

The Theatres

Trust 41452

22. Felindre - CCW holds Grassland survey dated from 1987/1989 centred on grid reference SN 638 004 for a number of fields of moderate to high conservation

interest of stands of fen-meadow, associated with a range of marshy grassland, flush and heath communities - Any development in this area would require

updated ecological survey and should consider Marsh Fritillary butterflies. Additional surveys are also likely for otters, bats, badgers and dormice. Please refer

to your Local Authority ecologist for any recent records and the previous Environmental Statement ecological surveys and habitat management reports for the

Felindre Strategic development site. - Given its remoteness from the main built up areas of Swansea, CCW has concerns about the sustainability of development at this location. Should the UDP allocation be taken forward into the LDP and any further land allocated, emphasis should be placed on the sustainable

development of the site, including provision of an integrated transport strategy for the area that focuses primarily on access to the site via public transport

Countryside

Council for

Wales 41558

4.15 Felindre This is a strategic site within the Swansea area and has been the subject of much advice from us in terms of flood risk and land contamination. It also drains to the Gowerton STW/Burry Inlet and as such much be subject to careful foul and surface water drainage provision/assessment.

EAW 41579

In terms of spatial growth options our client supports a strategic urban extension based upon Felindre alongside other strategic and non strategic allocations

around the City and County of Swansea (Options 1 & 3). It might be that the potential exists for a mixed use major development area centred at Felindre (Option

4) but this is likely to extend beyond the plan period so account needs to be given to allocation of a range of sites that can come forward in parallel with such a

large scale proposal. As you will be aware, our client owns a site immediately to the south of this area. The site is currently allocated in the UDP for B1, B2 and B8

uses and our clients has had discussions with the Council on the details of a planning application. Some constraints were identified, namely drainage, and our

client has been working to overcome these constraints with the Welsh Government and City and County of Swansea as landowners of the allocated strategic

business park to the north of the site. These are now resolved. Planning permission for some development at the strategic business park has been granted. We

agree that the site should be identified for strategic development but it is necessary to consider how the site relates to the adjacent available and allocated sites to

ensure that there is an integrated and complimentary strategy to ensure that the overall vision is not piecemeal. A joined up strategy should be taken forward in

the LDP particularly where parties are willing to work together to achieve this. Finally it is recognised in the strategic options consultation paper that the Felindre

area of growth is remote from main built-up areas of Swansea. Rather than dismissing further development of this site for this reason the integrated strategy

should include a focus on how the Felindre growth area can be better connected to the adjacent settlements. This would be more than just a transport strategy

suggested in the consultation paper. It would include a means of creating functional links between the settlements which will allow the Felindre growth area to

integrate into the nearby built-up area. We welcome the opportunity to discuss our client's site with you further and work with the Council to pursue the

development of this site.

Nathaniel

Lichfield and

Partners (Helen

Ridgeway)

41543

It is important that existing communities are allowed to expand sustainably. For example, the community of Felindre suffers from the lack of new houses which

means that young families must move away, affecting the village shop, pub, school and village hall. A W G Stone

41330

Pen

ller

gae

r

Penllergaer - Could this present unacceptable impact on Penllergare Gardens – Objection Uplands - Tis is not indicated since Hendrefoilan Student Village is to

be sole off could this provide one of options for 3 - sustainable urban extensions? - General Comment Miss E Harry

41458

Penllergaer - Concern that an extensive residential lead land release will further impact on traffic congestion along Carmarthen Road - particularly at Fforestfach Ms Philippa


Sw


ent Plan

- to the detriment of existing employment and other uses at Fforestfach Industrial Estate and Waunarlwydd. Published council studies regarding the potential to

relieve conjestion along this corridor have acknowledged that there is no on route solution i.e. that the changes to existing highway and that major new highway

infrastructure is necessary. The congestion in this area is a barrier to re-use and redevelopment of large brownfield sites and of detriment to the operation of existing businesses. - Object

Cole 41512

Penllergaer - We support the identification of Penllergaer as a Mixed Use Major Development Area Option on the Strategic Options Concept Plan, subject to the

comments above that the development of land at Parc Mawr could also be described as a Sustainable Urban Extension. Proposals associated with the

candidate site submision - Ref PG - 2 - Land at Parc Mawr Farm, Penllergaer would contribute to early phases of a larger form of development. (See

accompanying submission supporting document).

Asbri Planning

41565

Penllergaer - We support the identification of Fforestfach as a Mixed Use Major Development Area Option on the Strategic Options Concept Plan, subject to the

comments above that it could also be described as a Sustainable Urban Extension. Proposals associated with the Candidate Site submissions KB0001 - Land at Llwyn Cadwgan, Fforestfach and PD0001 - Pentregethin Road, would contribute to early phases of a larger form of development. (See accompanying

Submission Supporting document).

Asbri Planning

41566

Penllergaer - We support the identification of Penllergaer as a Mixed Use Major Development Area Option on the Strategic Options Concept Plan, subjec to the

comments above that proposals associated with the Candidate Site submission - Ref PG0003 - Land at Bryn Rhos Farm, Penllergaer would be more

appropriately considered as a Sustainable Urban Extension unless linked in combination with other releases, particularly Parc Mawr Farm, which is also

promoted by Bellway Homes. (See accompanying Submission Supporting document).

Asbri Planning

41569

Penllergaer - It is considered that site PG0005 would be suitable either as a standalone Strategic Urban Extension Area or as part of a wider Mixed Use Major

Development Area - Support the inclusion of the site either as a standalone Urban Extension or as part of a larger MUMDA. Boyer Planning

41529

Section 3-The broad areas for consideration are supported. The text as it refers to Penllergaer is discussed in the accompanying Submission document-Support Asbri 41569

4.17 Penllergaer Various developments have been proposed for this area and there are flood risk; environmental sensitive areas and also in part the foul/surface

water drains to Gowerton STW/Burry Inlet and as such must be subject to careful foul and surface water drainage provision/assessment. EAW 41579

23. Penllergaer - Area to the south of Gorseinon Road is mainly improved grassland - Need to determine whether there is any encroachment on adjacent commonland? - Land to east of A483 is close to Penllergaer Valley Woods, landscape impacts need to be considered in line with guidance on the Register of Landscapes Parks and Gardens of Special Historic Interest in Wales Grade II. We refer to your Cadw in this regard. - Developments should consider impacts on

drainage to the valley of the Afon Llan a tributary of the Burry Inlet and Loughor Estuary, and should be addressed in the HRA of the LDP and through project level HRAs to accompany any further development applications at the allocated sites. - This are is currently allocated as a green wedge in the UDP form of the

area and avoid the coalescence of Penllergaer, Pontlliw and Gorseinon. Clear justification should be provided if the green wedge boundaries are to be revised, leading to the erosion of the openness of the area, loss of connectivity, the potential coalescence of the settlements and loss of character and distinctiveness of the area.

Countryside

Council for

Wales 41558

On behalf of Penllergaer Community Council, I wish to object to the continued urbanisation and development of Penllergaer for the following reasons: Penllergaer has seen staggering population growth in recent years, with almost a 20% increase in population from the Census of 2001 (2,434) to the mid-2010

Census returns (2,900). This compares to population growth of approximately 4% for Swansea as a whole.Any further development in Penllergaer under any of the four proposals within the 'Strategic Options' document would therefore be unsustainable in the context outlined. Since the 2001 Census, Penllergaer has

absorbed the housing estate at Parc Penllergaer and further developments on the adjacent side of the A483. A further Bellway development is well underway at Parc Penderri and a Taylor Wimpey development is gaining planning approval for Llewellyn road. Penllergaer already has the prospect of supporting the

infrastructure requirements of up to an additional 400 homes within the ward, all of which are to be built on Greenfield sites. Potentially the resident population of the ward could double in the space of 12years.

Mr William

Meredith 41428


Sw


ent Plan

The growth of Penllergaer in the last decade has damaged the sense of community and identity of the village. Penllergaer has a 'high proportion of Welsh

speakers' at 18.4% at the last Census; however in the 2001 census at least 30% of the population had some knowledge of the Welsh language. It would seem

the influx of population is having a direct effect on the propensity of Welsh speakers within the ward. Penllergaer has the existing infrastructure of a village, supporting the resident population of a small town. Penllergaer's continued development has placed enormous pressure on local facilities. Roads are heavily

congested at peak times and the local school is over-subscribed to the point that local children can no longer be assured of a place; we already have the prospect of parents having to drive past their local school to find places in neighbouring wards. This has caused considerable anxiety and concern to residents. The village

school is expanding to meet the demands of the latest Bellway estate through the construction of additional classroom spaces - further residential expansion

would exasperate capacity issues and prolong a period of flux for the school with obvious detriment. The expansion of the primary school makes no provision for

Planning Obligations (as defined under section 3.3.2 of the 'Supplementary Planning Guidance' regarding the wider implications for transport, highways, walking

routes and increases in traffic outside the school. The school entrance is already dangerously congested and whilst Parc Penderri will have independent access

to the school the Llewellyn Road development will significantly add to this congestion. Any further development adding to this congestion would be grossly

irresponsible.

Mr William

Meredith 41428

The remaining available land in Penllergaer is predominantly Greenfield and 'Green Wedge' and further urbanisation of these sites to meet the wider housing

needs of the County is untenable and in our view contrary to planning guidance - leading to coalescence with neighbouring wards and spread of urban sprawl to

the loss of good, productive agricultural land, habitats, erosion of visual and sensory qualities and detriment to historic settings.

Mr William

Meredith 41428

We welcome the opportunity to discuss the future of the 3M site and to secure continued skilled employment within the ward; however this should not be seen as

an opportunity to squeeze further residential development into Penllergaer under a 'Mixed Use Major Development'. The existing and planned new-build

developments are in danger of becoming dormitory communities, with a high propensity of residents commuting outside of Swansea for work thanks to our

proximity to the M4. Even based on the 2001 census, a high propensity of the resident population of Penllergaer are of working age and almost 20% commuting

at least 10km for work. The land which 3M currently occupies should be seen as an opportunity to create a sustainable community for the existing influx of residents, a place where people, live, work and socialise - contributing to the local economy and creating a sustainable community. Something successive

planning decisions have failed to recognise. Penllergaer should be afforded the opportunity within the LDP to assimilate the existing developments. Any of the

options outlined within the Strategic Options Consultation would be unsustainable within Penllergaer - creating a sprawl of homogenous, car-dependent, dormitory housing developments with little sense of community and perpetuating an unsustainable level of growth within the ward.

Mr William

Meredith 41428

Llan

gyfe

lach

Llangyfelach 3.50 As noted in the Consultation Draft, Llangyfelach is subject to ' highly significant' environmental and biodiversity issues. The potential impacts

of a development of this scale on the environment and biodiversity are more significant that other alternative sites available for major mixed use development, such as Fforestfach. The areas would also rely solely on major greenfield releases, without offering wider benefits of delivering infrastructure improvements that could unlock further brownfield redevelopment.

Stephen

Pilliner 41535

Llangyfelach - Existing areas in the surrounding areas should be boosted in the current economic climate - Objection41485, 41494, 41507, 41501, 41497, 41489, 41481, 41477, 41474, 41482,

41486, 41498, 41490, 41493, 41432, 41478

Llangyfelach - The site is subject to highly signficant environmental issues as identified in the draft settlement. It would additionally, rely solely on major

greenfield releases without offering the benefit of infrastructure improvements that could unlock further brownfield development or benefit of existing businesses

or established areas. The potential impact on traffic congestion along Carmarthen Road would further blight the potential redevelopment or reuse of brownfield

sites at Waunarlwydd, the reuse of existing buildings at Fforestfach Industrial Estate and the efficiency of existing business - Object.

Ms Philippa

Cole 41512

Y Llwyni, Llangyfelach - This land must be left as local amenity. It is the only surviving piece of green land suitable for play and general use. The application for

village green status should be approved - Objection Dr Simon

Brooks 41329

Llangyfelach - This area is somewhat detached and isolated form the existing urban area of Swansea or its outlying settlements. It would appear that any further

development would be focussed around the Royal Fern development, which would then further compound the lack of sustainability that this development has. Jason Evans


Sw


ent Plan

No further development should be permitted to take lace at this location to rectify the poor decision taken to permit the Royal Ferm development to take place. -

Object. Planning 41445

24. Llangyfelach - Large area of open countryside, central/south is Penplas Grasslands SSSI, a low lying area with marshy grassland and wet heath. Development in this area should demonstrate how any significant adverse effects on the SSSI will be avoided. - CCW holds Grasslands survey (1988) centred

on grid reference: SS 642 988 recording 14 ha of grassland communities. Further and updated habitat surveys would be required in this area, including Marsh

fritillary butterfly surveys - Close to Historic Park and Gardens/Landscape at Penllergaer Valley Woods. We refer you to Cadw in this regard. - Land is made up

of marshy grassland, semi improved grassland, scrub and woodland - Any development should consider effects on Marsh Fritillary butterfly - Developments

should consider impacts on drainage to the valley of the Afon Llan a tributary of the Burry Inlet and Loughor Estuary and should be addressed in the HRA of the

LDP and where relevant through project level HRAs to accompany any future development applications at the allocated sites

Countryside

Council for

Wales 41558

4.18 Llangyfelach Various developments have been proposed for this area and there are flood risk; environmental sensitive areas and also in part the

foul/surface water drains to Gowerton STW/Burry Inlet and as such must be subject to careful foul and surface water drainage provision/assessment. EA W 41579

Larg

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rura

l an

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loca

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Large villages, rural and semi-rural locations esp. Scurlage - Rhossili is most affected by proposals for candidate sites in Scurlage. As highlighted in our

response to you last year, in our Area of Outstanding Natural Beauty it is vital to recognise the value of sensitive development while treasuring the history, land, character and tranquillity of Gower. Tourism is a major contributor to the prosperity of both Swansea and Gower. Sensitive development at Scurlage is important as it is the gateway to popular tourist areas within Gower namely the villages of Port Eynon, Horton, Overton and Rhossili. Each year about half a million tourists

visit Rhossili for its iconic cliff views and beaches and, to do this, they must pass through Scurlage. Our opinion is that some development of Scurlage could be

acceptable and have a positive impact on the area. It is desirable for our young people and families growing up on Gower to continue to live here: some

affordable housing encourages and helps them to stay. We consider that the area would benefit from a mix of housing if any of the Scurlage candidate sites are

developed. It is also essential that local primary schools at Knelston and Llanrhidian continue to serve the community; this remains viable while there is a

buoyant intake of children from the area. Gower rural living requires employment opportunities within reach, including Swansea, the M4 corridor and locally to

sustain agriculture and tourism industries especially at the coast. Good infrastructure and communications - roads, public transport, broadband etc. - must support the locality and keep environmental pressures in check. Therefore companion employment and economic strategies are essential to successful implementation of the LDP. In so saying, whilst Rhossili Community Council recognises that a small amount of development may be beneficial at Scurlage, it would be entirely unacceptable for all the proposed candidate sites to be developed. This would overwhelm and urbanise the area, creating a big settlement out of proportion with its locality and to the detriment of Gower, its inhabitants and visitors.

Rhossili

Community

Council 41433

Gower & Swansea Villages - Protect this area of natural outstanding beauty and the villages that border it. No further development - General comment and

objection E Walters

41378

Mumbles and Gower - No further development as is major asset for Swansea tourism. Oystermouth Road can't take any more traffic - Objection M Walters

41380

Pontlliw - It is considered highly appropriate that the candidate site LF0002 is allocated as a small scale settlement extensions for up to 50 new dwellings -

Support the allocation of LF0002 as a small scale extension Boyer Planning 41525

Pontlliw - It is considered highly appropriate that the candidate site LF0005 is allocated as an extension - Support the allocation of LF0005 as an urban extension. Boyer P 41528

Upper Killay - Insufficient existing community amenities in this area e.g. poor public transport, nearest GP and chemist and major foodstores etc. in Killay. Would

necessitate too much reliance on car for basics, including getting to work. Walking to Killay difficult because of 2 very steep and long hills. Sandy Johns

41591

25. Large Village/Rural/Semi-Rural Villages - For any development within the Gower Area of Outstanding Natural Beauty (AONB), we remind you of your

Council's duty under Section 85 of the Countryside and Rights of Way Act 2000, which requires Local Authorities to have regard to the purposes of Areas of Outstanding Natural Beauty and conservation and enhancement of natural beauty, and any proposed allocations within the AONB should be considered in this

Countryside

Council for


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ent Plan

context. As you are aware, your authority's AONB team have recently overseen the production of a Design Guidance for Gower, with input from CCW. The

design guide should be used to inform the above considerations for any proposal in the AONB - We consider that Policies EV16 Small Villages and EV17 Large

Villages in the UDP provide a solid base against which development in small and large villages should be considered, and advise that a similar format and criteria

is used in the LDP.

Wales 41558

4.19 Rural Villages There may be various issues with respective villages but the question of infrastructure provision/capacity and environmental protection are

key issues which need addressing. We hope the above is useful for your purposes and if you have any enquiries please do not hesitate to contact me. EAW 41579

I enclose a copy of a joint response to your consultation on behalf of Mr Layton Jones (landowner) and Coastal Housing who have expressed an interest in the

development of the site for affordable housing linked to community benefit. Both parties would be happy to negotiate a satisfactory scheme acceptable to all parties. A potential layout has already been submitted to you with the original candidate site proposal. I look forward to hearing from you. 1. Candidate site B1002

lies within the village of Bishopston to the rear of the Spar store. Just under one hectare, it was registered as a candidate site, being considered ideal for

affordable housing development. The owner Mr Layton Jones is therefore interest in the options put forward for consultation in the Strategic Options paper. He

is joined in this by Coastal Housing, both parties believing the site to be ideal for affordable homes in this up market community. It is noted that the Strategic

Options Concept plan highlights Bishopston as a Semi-rural Settlement Option.

Environmental

Planning (Mr

Graham King)

41584

3. Importantly for Candidate site B10002, the report states that development of sites within or on the edge of settlements in the west of the County such as

Bishopston have potential to contribute to affordable housing provision at a location where there is an established need for such provision and available sites are

lacking. The report also suggests that development of such sites can bring wider benefit for established communities, especially if they have no detrimental impact on the wider environment. In the case of site B10002 the offer is made to greatly improve access to the local schools as illustrated in the submitted plans.

Environmental

Planning (Mr

Graham King)

41584

4. Candidate site B10002 is the perfect site to provide betterment in the village of Bishopston. As the initial submission stated, the site has a number of unique

advantages: (i) the local demand for affordable homes has been confirmed by Coastal Housing; the site is regarded as eminently suitable; (ii) the site is highly

sustainable, being located at the heart of the village, near schools and all local facilities, plus public transport; (iii) the revised school access proposed will alleviate the chronic congestion that occurs at school opening and closing times; (iv) adjoining the school sites on the north and east the site has a defensible

boundary against further development; (v) the site does not lie within Gower AONB, and its discrete location would not harm the green wedge; (vi) currently used

for grazing, the site has no significant ecological value; (vii) all main services are available; (viii) release of this site for affordable housing would help achieve a

balance of housing stock in the area; (ix) the owner is willing to sell and, with Coastal Housing, negotiate an improved access for the school.

Environmental

Planning (Mr

Graham King)

41584

Further to my letter and enclosure of 12 September, at the request of the clients I now enclose a plan of the proposed layout in this particular site for your records. As you will note, the scheme makes a modest contribution to meeting the need for high quality homes in this strategic location of Bishopston. * See consultation

file for map

Environmental

Planning 41585

4. Bishopston, as a large village, is also included as an Area for Consideration in Section 3 of the Consultation document. While encouraging appropriate

development, this section places significant emphasis on the protection and enhancement of the environmental assets of such areas, especially landscape

quality. In this respect site B10011 is modest in size and unobtrusively located within Bishopston rather than an extension into open countryside. It also has the

following advantages: (i) it immediately abuts the settlement boundary; (ii) it is within walking distance of all social facilities and bus routes; (iii) it represents a

logical rounding off of the existing urban area, with defensible boundaries; (iv) there are no ecological constraints; hedgerows will be protected; (v) release of this

land for good quality housing would meet an established demand for up to five dwellings; (vi) the land is available for immediate development; (vii) all main

services are already in position.

Environmental

Planning (Mr

Graham King)

41589

Gower - No further development. Protect this asset. Oystermouth Road cannot take any more traffic - General Comment & Objection Peter May

41354

1. Candidate Site B 10011 lies within the village of Bishopston to the rear of Ridley Way with access from a short cul-de-sac called Vensland. This response Environmental


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assesses the LDP consultation on Strategic Options for the County, with particular interest in the vision for Bishopston and the need for additional housing sites in

the west of the county. It is noted that the Strategic Options Concept Plan highlights Bishopston as a Semi Rural Settlement Option. Planning 41589

5. Site B1001 is a useful test case for the impact of Option 2 as it bears upon the village of Bishopston. It shows that an appropriate site is available. This in turn

supports the inclusion of Bishopston within Option 2 as a viable part of the LDP Preferred Strategy. As the Consultation document states "the approach has

potential to provide for a wide range of housing types to meet need and demand across the County over the Plan period". This approach is therefore supported.

Environmental

Planning 41589

Large villages, rural and semi-rural locations - The communities listed under this heading differ substantially in size, nature and location. Some are in the AONB

and others are outside, but on the very edge of it and impact on it. Since the AONB's designation, housing in and near to the designated area has increased far

more rapidly, in proportion to its 1956 population, than in the rest of the City and County. Developers favour this area because it is more profitable to them; a

strategy, however, should be built on need rather than greed. This is not to argue that there should be no new housing in rural areas or in the AONB, but that development should be proportionate and sensitive to the locations. Rural Swansea - like many other rural areas in the UK - lacks both employment opportunities

and social facilities. Building in such areas can lead to a commuting population with an environmentally negative impact. Housing, where there are few or no

jobs, is not sustainable development. Public transport in many of the rural areas is poor and dependant on subsidies (which may, or may not continue). Facilities, particularly for families, are fewer and further away and more expensive to maintain. "Affordable" housing is laudable, but is difficult to retain in a free market. Housing, however, is only one side of affordability. The other is having a reasonably paid job and having reasonably priced facilities within easy reach. We

particularly refer to the possible extension of Scurlage, which is already blighted by insensitive development. It is ill-suited for commuting employees or for low-cost housing for local and younger people, since they have difficulty in finding employment locally. In the heart of the AONB and seen by all visitors travelling

west, it is important to improve the visual impact of this village. Sewerage treatment and flooding is also an issue here. In short we could not support any sort of comprehensive development within the actual AONB or directly adjacent too it. In addition to the need to safeguard protected areas, housing should be provided

where there are good transport links, employment opportunities, adequate facilities and sufficient services.

The Gower

Society 41593

1. Candidate site GW0002 lies on the edge of Port Eynon next to Boarlands and is owned by Mr Jeffries of Bay View Farm. His response on his behalf assesses

the LPA consultation on Strategic Options for the County, with particular interest in the vision for Gower and the need for additional housing sites in the west of the county. It is noted that the Strategic Options Concept Plan highlights Scurlage as a Semi Rural Settlement Option rather than Port Eynon. It is this which he

wishes to questions.

Environmental

Planning 41588

Oth

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Com

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Newton, Thistleboon, Dunvant, Gowerton - Not to be development areas - Objection P S H Stott

41312

Loughor/Gorseinon 3.35 We strongly support the identification of Loughor/Gorseinon as an area capable of accommodating future growth over the LDP period. The area benefits from a range of complimentary facilities and community services and is highly accessible by road and public transport. It is within close

proximity of the rail stations at Gowerton and Bynea. The area is also highly desirable for homebuyers, which will aid deliverability. 3.36 In terms of the spatial options for growth, the settlement is considered capable of accommodating non-strategic growth (defined by the Council as being less than 15 hectares). Land

Is available with Loughor/Gorseinon that is sustainable, economically viable and capable of delivering the vision and objectives contained in the LDP. This area

should therefore be taken forward as part of the preparation of the Preferred Strategy. 3.37 As referred to above, it is important that the LDP provides for a range

of sites capable of being delivered across the plan period. By directing development to Loughor/Gorseinon it would be possible to deliver development early in

the plan period, ahead of the lead in times for larger strategic development. Such development would also support the existing services and facilities, together

with being the driver for improvements to the benefit of existing and future populations. 3.38 The Consultation Draft refers to development at Loughor, Gorseinon

West and East. Of the identified areas we strongly support the idenfication of what is referred to as a westward extension of Gorseinon West, specifically land

around Whitley Farm Farm (to the north of Borough Road and to the east of Gwynfe Road). 3.39 Technical work undertaken on behalf of our clients

demonstrates that land in this area is: - bound by the existing settlement of the southern, eastern and part of its western and northern boundaries. - capable of drawing on, and helping to support and improve, existing services and facilities - easily accessible by various modes of transport - capable of delivering

significant areas of green infrastructure and public open space, which will improve access to the Loughor Foreshore Park - not subject to risk of flooding -

Stephen

Pilliner 41535


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ent Plan

economically viable and is not subject to significant infrastructure requirements that could constrain delivery - not subject to any significant landscape or

biodiversity constraints that cannot be overcome with mitigation (including any potential impact on the areas around the Bury Estuary). 3.40 It is recognised that land in this location is currently designated as part of a Green Wedge. Representations have previously been made on behalf of our clients through the

Candidate Site process (not repeated here) that demonstrate that this land is not required as part of the Green Wedge. It is entirely appropriate for such

designations to be reviewed as part of the LDP process. 3.41 We therefore strongly support the identification of land at Whitely Fach Farm (to the north of Borough Road and the east of Gwynfe Road) as a non-strategic allocation capable of accommodating future growth in a sustainable manner. The area is

capable of delivering development early in the plan period and is not dependent in significant up front infrastructure requirements.

Leos Site Milford Way, Penplas - Penderry Ward - Housing, mixed community use. This community is a deprived are and needs a boost not any further drains on

the area. It cannot absorb any more. 41485, 41494, 41507, 41501, 41497, 41489, 41481, 41477, 41474, 41482, 41486, 41498, 41490, 41493, 41432, 41478

Section 3 - Penplas-Penderry - This is an area that should be included for strategic urban extension options, to boost economic activity in the area. This would

attract people who are working and boost the economy in the area. The area is well placed for this as there are good transport links, close to the M4 and City

Centre. For existing residents it would give a boost to community facilities. There would also be the opportunity to provide affordable accommodation for first time buyers - Support to include Penplas 41485, 41494, 41507, 41501, 41497, 41489,

41481, 41477, 41474, 41482, 41486, 41498, 41490, 41493, 41432, 41478

M4 Corridor - Better location for large development - General comment and support E Walters

41378

M4 Corridor - Seems ripe for development - as infrastructure is in place - Support M Walters

41380

M4 Corridor - Ideal location for large development requiring less new infrastructure costs - General Comment & Support Peter May

41354

Gower - Development on Gower and particularly in western and more rural parts of Gower seems counter to the visions and objectives stated. Increased

housing should be near infrastructure, public transport, employment and social opportunity etc. Development of more housing detracts from the unique

character of Gower and leads to increased motorised traffic on inadequate roads. Bus services to remote parts do not work effectively - they don't seem to be

economically viable at present, and in practice people living in places like Scurlage will try to have their own cars to get to places of work, do their shopping etc. The alternative is then to improve the infrastructure in the remote area, which would be further undermine its unique character. Extending small villages on

Gower is even less desirable than e.g. development of larger settlements like Scurlage. It runs counter to many of the aims expressed in the vision document and should therefore be totally obviously bad policy. For example, the requirement for housing to be close to economic infrastructure and accessible education

etc. is not met; the tourist and farming industry that already exists and needs to be encouraged, is jeopardised by increased population, busier roads etc.; the

need for integrated sustainable transport with new development, it not met; the unique character of a beautiful place is threatened.

Mrs Bridget

Stein 41510

14. Gwernfadog - Currently designated as green wedge within the UDP, where it is considered important to retain the openness and character of the area around

Pant Lasau, Morriston and Clydach, and manage the urban form of the area. As with other green wedges identified as potential strategic allocations, clear

justification should be provided if their boundaries in the area are to be revised, leading to the erosion of the openness and character of the area and likely

coalescence of settlements. - Significant areas of woodland on western and southern edge of site with mature hedgerows.

Countryside

Council for

Wales 41558

4.14 Gowerton/Loughor/Garden Village/Gorseinon East & West. These areas are considered potential areas which will have implications for the Burry Inlet as

they all drain via the Gowerton STW. Appropriate foul and surface water drainage provision/assessments needs to be addressed at potential development sites

in these areas.

EAW 41579

3. Criteria for Option 2 emphasise the potential for settlement expansion particularly where this would allow for a wide range of housing types to meet need and Environmental


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ent Plan

demand across the county over the plan period, provided this is possible without detrimental environmental impact. This statement is welcome and realistic as

villages like Port Eynon, with a strong core of community facilities and social infrastructure, have proved attractive to builder and house buyers for many years, albeit having an imposed cap on developments under the policies of the UDP. Consideration of such options within the current LDP process is most timely

therefore to help alleviate national concern over house building rates in rural areas by allocating suitable sites such as GW0002.

4. However Port Eynon, as a Gower village, is not included as an Area for Consideration in Section 3 of the Consultation document, areas where appropriate

development might be encouraged as long as no significant harm is done to areas of important landscape value. In respect of Mr Jeffries' site this omission is

contested for a number of reasons as Scurlage has been included, presumable seen as a hub for the wider area. This however overlooks the unique history and

development of Port Eynon as a truly living and developing community over several centuries. Rather than concentrate all future development in the western

end of Gower at a single hub, it is preferable that allocations for housing land should be made throughout all the small villages such as Port Eynon.

5. Moreover the Port Eynon site has a number of unique advantages: (i) it immediately abuts the settlement boundary with a direct footpath link to the village; (ii)

it is close to all social facilities and bus services to Swansea; (iii) it represents a logical rounding off of the existing village with defensible boundaries; (iv) there

are no significant ecological constraints; hedgerows can be retained; agriculture ceased a long time ago; (v) release of this land for good quality housing would

meet an established demand; (vi) it is close to all main services.

Planning (Mr

Graham King)

41588

West Cross Ward, Mumbles Using the criteria set for recommending Strategy 4, Newton and West Cross would not be a suitable site for development for the

following reasons: - A development of some 15 hectare in this area comprises a large development and to propose a site that size outside of the Newton/West Cross Green Wedge would place great pressure on the environment of those areas.

- There are no shops, pubs, health clinics or other facilities within easy walking distance of this site and the site itself would not be large enough for the

establishment of any of these facilities.

- There is insufficient primary school capacity in the area.

- The width of the track leading N.W. from Highpool Lane to the proposed area, including the track itself, is all common land and many of the trees along it are

protected by TPOs. Note: The first section of the track is in Newton. The remainder is in West Cross. The Green Wedge edge of the settlement boundary follows

the eastern line of this track.

- The farm land to the west of this track, comprising of a number of fields, is in West Cross ward. Any proposals for development on this land would breach the

Green Wedge at this point, this was established, and defined in the UDP, to ensure the separation of the built areas of the communities of Bishopston and

Mumbles.

- The fields in West Cross Ward adjoining Newton Ward, bar one, are marshy and have springs rising in them. The water eventually feeds into one of the prime

Blue Flag Beaches in the county, Caswell Bay. The common land behind these fields rises gently to the north and is bisected by the Mayals/Bishopston road, which is also the ward boundary.

* Most of this area is marshy with numerous springs rising. The water from most of these springs eventually feeds into Caswell Bay. Any pollution during or after

development could impact on this famous bathing beach and affect its Blue Flag status.

- There are extensive below ground Welsh Water storage tanks and pumping facilities and an above ground electricity sub-station in this area.

- Sewage and storm water drainage systems in the Mumbles area have already exceeding their intended capacity.

- There is insufficient sewerage and storm water drainage capacity in the proposed area.

* The current development site at Moorlands Road already has drainage problems.

Mumbles

Community

Council (Mr

Steve Heydon)

41561


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ent Plan

* At the eastern end of the common there is already a known problem of spring water runoff putting some houses in West Cross at risk of flooding after heavy

rainfall.

* It is believed that the discharge from any development here would eventually join the sewer running under Newton Road. This would not be acceptable due to

lack of sewer capacity.

- There an archaeological feature within the proposed area. An earthwork, currently recorded as a post-medieval Cockpit.

- There are no additional employment opportunities in the MCC area. Development would lead to daily migration to a workplace in Swansea or elsewhere.

- The additional residents would work and shop outside of the MCC area and this would make any housing development on this site akin to any deserted second

homes site in Wales.

- The Mumbles Road is already one of the busiest roads in Wales and cannot sustain any higher levels of commuter traffic.

* Parts of this road are now designated as being within an EA level 2 flood risk zone and there is an increasing risk of flooding causing temporary closure as

storms increase and sea levels rise.

Newton Ward, Mumbles In addition to the above any development in this area specifically proposed for Newton Ward would be in the fields alongside Murton

Lane, from Espalone Farm to Lady Housty Avenue. - Development here would lead to ribbon development along Murton Lane. This would effectively merge the

two communities of Mumbles and Bishopston as the Green Wedge between Newton and Mansfield, only some 100m side at this point, would disappear. -

Increased traffic connected with a major development here would also necessitate widening of this road. - There are no additional employment opportunities in

the MCC area. Development would lead to daily migration to a workplace in Swansea or elsewhere. - The additional residents would work and shop outside of the MCC area and this would make any housing development on this site akin to any deserted second homes site in Wales. - The Mumbles Road is already one

of the busiest roads in Wales and cannot sustain any higher levels of commuter traffic. * Parts of this road are now designated as being within an EA level 2 flood

risk zone and there is an increasing risk of flooding causing temporary closure as storms increase and sea levels rise. - MCC's policy is to defend the Green

Wedge edge of its settlement line along this boundary.

Mumbles

Community

Council (Mr

Steve Heydon)

41561

Brynmill, Uplands. Not new build be regeneration of traditional 2 storey houses - traditionally these were affordable family homes. Return HMO's to family

homes when they come up on the market by giving incentives to young families to move in and reconvert be it by purchase or rental. Discourage further HMO's. Encourage universities to build sufficient purpose built residential accommodation on their campuses. All this would revitalise central city areas and their

immediate surrounds, would be more sustainable, would require less new build and less new infrastructure and ease transport problems of low income families. It would also help local small businesses, and many of the other problems of waste management, antisocial behaviour etc in these areas.

Sandy Johns

41591

Land behind Borough Road - We are trying to sell out family home and already we have had potential buyers pull out of viewing our home due to the possible

building of houses behind Borough Road - Objection Mrs Alexandra

Hill 41319

Llangyfelach, Dunvant, Rural Extension Options in Gower - A major development area at Llangyfelach has the potential to impact on the Penllergare historic park

and garden. Adverse impacts should be avoided and the potential for beneficial impacts, for example through linking development to enhancement of the

historic park and garden should be explored. We are concerned at the potential for development at Dunvant to impact on the Gower AONB and the Gower

Commons SAC. While recognising that there may be capacity for modest growth in larger villages of Gower, the successful integration of new development with

the natural beauty of the AONB and the environmental sensitivities of neighbouring land must be a major influence on the scale and design of the proposals-

General Comment

The National

Trust 41542

General Comments


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ent Plan

Section 3 - Again this is all about new build, why not sites for regeneration? - Objection & Comment S Johns 41591

Areas that should be considered for future development - If brownfield. P S H Stott

41312

Areas for Consideration - Refer to supporting information Flexible Support

for Business 41572

I agree mainly with what is being said. C Griffiths

41311

Areas Not Currently Shown - Overall I found this feedback form ambiguous and wide open to misinterpretation. There isn't enough emphasis on the use of brownfield sites to improve neglected areas.

C Humphreys

41462

The Community Council resolved, at its October Council Meeting, that the only comments it wished to make in respect of the above are:- They have no observations to make in respect of the questions listed under "Vision & Objectives" nor in respect of the 4 options stated in the "Strategic Options" part of the Feedback Form. The only comments the Community Council wished to make is "they object to any further development in the Ward, other than those areas which have an existing planning permission". Also the Council Members stated that in the above documents and in the City and County of Swansea's planning policies that, where any residential development of any size was being

contemplated, the City and County of Swansea ensured or would ensure that play areas/public open spaces were to be provided - completely contrary to your proposals for the

Land at Y Llwyni (Candidate Site LF013) which is the only play area/open space in the village of Llangyfelach and which is widely used by the local residents.

Llangyfelach

Community

Council 41516

Future Residential - All housing provide "work from home" facilities e.g. fast broadband links – General Road Capacity - Road capacity to Swansea and Mumbles totally inadequate - Objection.

A Vaughan

41449 DP

Vaughan 41447

Areas not currently shown - To maximise all "brownfield" sites. A Vaughan

41449

The plans to encroach on what has been designated an Area of Outstanding Natural Beauty is unacceptable in terms of the potential for long-term damage to our natural heritage for future generations. The bio-diversity in this area is priceless and the drive to produce affordable housing is no excuse to destroy green field sites for short-term gain especially when there are sufficient brown field sites available due to Swansea's industrial past. We have a duty to keep Gower green and not nibble away at the edges! The development of luxury building projects in Upper Killay against the wishes of the Community Council are generally financially inaccessible to local young families and benefit neither the local school nor our local commerce. Experience has shown that in this area new houses rapidly become inaccessible to young people with a school-age family There would inevitably be increased traffic on inadequate road systems and pressure on the local services causing great difficulty for the local community.

Upoer Killay

Community

Council 41302

Areas not currently shown- To maximise all "brownfield" sites. DP Vaughan 41447

Also very small childrens play area, very busy main road. Also all houses expensive, if developer forced to do affordable then would be expensive place for low income families to live–Objection

S Johns 41591

We recommend that priority should be given to large brownfield sites where new communities can be established. Smaller brownfield sites and infill development should come next. Green field, green wedge and green belt should only be considered when brownfield sites have been exhaustive and excess demand still exists. Because none of the four options above properly address the need to use previously developed land first.

Mr Mike Ford

41349

"The creation of a waterway for navigation, recreation and leisure linking the River Tawe with the Swansea Canal and Tennant Canal would provide a resource for the City, visitors and local communities. It would be of regional significance. It would enable the creation of a 35 mile waterway network linking with the Neath and Tennant Canals,

Meryl Hunt

41596


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ent Plan

helping to link with the wider Swansea Bay area and bring economic, social and environmental benefits. It would help forge a new vitality and identity for the 'east side' communities that deserve a vibrant vision for the City as it emerges from the current economic difficulties. It would provide a linear green park and lung and the potential for waterside regeneration and revitalisation for communities including Port Tennant, St. Thomas, the Hafod, Llansamlet, Morriston, Ynystawe and Ynysforgan and Clydach. The UDP protects the line of the waterway through the City. Now is the time to shape the future of the area and the LDP should embrace and promote the waterway as an unifying strategy for the City and east-side. The completion of the project is likely to extend beyond the life of the current version of the LDP, but very significant progress delivering lengths of waterway, benefits and unlocking waterside development potential is very achievable within the plan period. The Swansea Canal Society is progressing work both in Swansea and Neath Port Talbot and welcomes the opportunity to work with the City and Council of Swansea to bring this vision to fruition."

The South Wales Branch of the Inland Waterways Association wholeheartedly supports the creation of a waterway linking the River Tawe with the Swansea and Tennant Canals. Canal development and restoration has a proven record of bringing many benefits to the communities affected. These include job creation, a linear park for walking and other recreational activities promoting well being, the development of tourism and a greater awareness of the area's heritage. The Inland Waterways Association (IWA) is a registered charity, which advocates the conservation, use, maintenance, restoration and development of the inland waterways for the public benefit. IWA has around 17,000 members whose interests include boating, towpath wallking, industrial archaeology, nature conservation and many other activities associated with inland waterways. This forms the Association's response to the Consultation and is written by its South Wales Branch of its Trustees.

Inland

Waterways

Association

41517

Fill the unoccupied homes in Swansea first which are 3000+ and then develop brownfield sites such as Felindre. It is ridiculous to build new homes when we have so many unoccupied properties in Swansea. Use brownfield sites to retain our green areas which are a valuable asset in every area. Areas not currently shown - Felindre

Mr David

Powell 41461

We do not intend to comment on each of the Areas for Consideration outlined in Section 3 of the paper, though in general we would argue that it is easier to accommodate increased building in existing urban areas than to expand smaller communities. We are concerned at the lack of detail (perhaps necessary at this stage) relating to the rural/semi-rural sites shown on the plan, but only briefly referred to in the text. We are also concerned at proposals within the AONB, since this is a nationally recognised designation and any development must have due regard to its special nature and the protection of its landscape value.

The Gower

Society 41593

Hendrefoilan Student Village - housing (approx 250 plus being quoted). J Waygood

41539

Q5 Areas for Consideration Landscape. The following observations do not incorporate comments on landscape impact. However, CCW advises that all areas identified in the strategic options should be assessed using the authority's LANDMAP study to ascertain likely landscape and visual impacts. LANDMAP is an all-Wales GIS based landscape resource where landscape characteristics, qualities and influences on the landscape and recorded and evaluated into anationally consistent data set. LANDMAP comprises five spatially related datasets known as Evaluated Aspects; the five layers are the Geological Landscape, Landscape Habitats, Visual & Sensory, Historic Landscape and Cultural Landscape. All information is managed through a Geographical Information System and associated Collector database.

Countryside

Council for

Wales 41558

Protected Species Whilst we appreciate that individual sites are not being consulted on at present, you should bear in mind that should any buildings be required to be demolished

or converted for development to continue at the identified strategic sites if they are allocated in the Deposit LDP, a bat survey may be needed to assess the use of the building by

bats and to ensure that any development at the site does not result in any detriment to the favourable conservation status of the species. We recommend that it is highlighted in the

LDP that this information will be required to assess any subsequent development application at the site. Additionally, all of the identified sites contain areas of woodland, scrub

and/or hedgerows which we advise are retained as they may be used by numerous protected species (including but not limited to bats, dormice, otters, birds and badgers) for resting, foraging and commuting purposes and provide habitat connectivity to nearby wooded areas and watercourses. However, if woodland, scrub or hedgerows are proposed to

be cleared for development, future applicants/developers of such sites should be advised to consult your planning Ecologist as to the proposed species surveys requirements of the sites. For further advice on biodiversity considerations and most recent protected species records applicants should be referred to your Local Authority Ecologist and the South

West Wales Local Records Centre (SEWBREC). We recommend that such detail is included as an annex to the LDP detailing requirements/constraints of individual site

allocations.

NERC duty/BAP Habitats and Species. Consideration should be made of possible effects of allocations on the habitats and species listed under section 42 of the Natural Environment and Rural Communities (NERC) Act 2006, or on your Local Biodiversity Action Plan and other local interests. To comply with your authority's duty under section 40 of the NERC act, to have regard to conserving biodiversity, any development at allocated sites should take account of possible adverse effects on such interests. The habitat information we hold is derived from our Phase I survey data, dated 1987. Therefore this data may be out of date. Further habitat survey work may be required on the allocated sites

Countryside

Council for

Wales 41558


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prior to any development commencing, to protect any section 42 habitat. We recommend that you seek further advice from your authority's internal ecological adviser and the

Wales Biodiversity Partnership's web site has guidance for assessing proposals that have implications for Section 42 habitats (www.biodiversitywales.org.uk). Our comments on

habitats under the "Areas for Consideration are based on observations largely from Phase I and aerial photographs and are therefore limited. Where woodland is implicated for example this should be considered in relation to the new Ancient Woodland Inventory as launched in July 2012. Marshy grassland for example, may equate to the priority habitat "purpose moor grass and rush pasture" and such habitat can support other priority species of conservation concern including the marsh fritillary butterfly. Areas of semi-improved

grassland, scrub and wetlands can all add to the wildlife value of an area and potentially support significant species interests. The significance of habitats in the Areas for Consideration should therefore be assessed with your Local Authority Ecologist who can also advise on the presence or otherwise of candidate SINC sites.

Consultation. Finally, Gower Plaid would like to congratulate the officers in the LDP Unit of Swansea Council for their hard work in compiling the Plan, gathering the evidence and their willingness to engage with the public and answer queries. This is laudable. However, questions must be raised about the value of the consultation exercise undertaken when the likelihood is that locally agreed housing targets set by the Authority are likely to be over-ridden by unelected Planning Inspectors appointed by the Welsh Government. In this respect, other authorities such as Wrexham and Cardiff offer a salutary lesson in the willingness of the Welsh Government to over-ride local democracy in favour of statistical targets that bear no relation to real community need, or the condition of the housing market as it stands today.

Mr Jim

Dunckley

41557

On behalf of our client, Aringdale Developments, we respond to the Council's consultation on the emerging LDP. Our client broadly supports the Vision and Objectives set out in the consultation draft. In terms of the Strategic Options our client considers that the alternative growth projections are too low and that the starting point for assessing the LDP housing requirement figure should be the latest Welsh Government Housing Projections. These projections indicate a higher demand for housing that the Council is currently proposing to meet. NLP anticipate that once economic growth aspiration are also factored in alongside demographic trends that the housjng requirement figure will be well in excess of the options set out in the Strategic Option paper. For these reasons we do not consider that the options are founded upon a robust evidence base.

Nathaniel

Lichfield and

Partners (Helen

Ridgeway)

41543

Network Rail has been consulted by Swansea Council on the Local Development Plan - Vision, Objection & Strategic Options. Thank you for providing us with this opportunity to comment on this Planning Policy document. Network Rail is a statutory undertaker responsible for maintaining and operating the country's railway infrastructure and associated estate. Network Rail owns, operates, maintains and develops the main rail network. This includes the railway tracks, stations, signalling systems, bridges, tunnels, level crossings and viaducts. The preparation of development plan policy is important in relation to the protection and enhancement of Network Rail's infrastructure. In this regard, please find our comments below.

Level Crossings: Development proposals' affecting the safety of level crossings is an extremely important consideration for emerging planning policy to address. The impact from development can result in a significant increase in the vehicular and/or pedestrian traffic utilising a crossing which in turn impacts upon safety and service provision.

As a result of increased patronage, Network Rail could be forced to reduce train line speed in direct correlation to the increase in vehicular and pedestrian traffic using a crossing. This would have severe consequences for the timetabling of trains and would also effectively frustrate any future train service improvements. This would be in direct conflict with strategic and government aims of improving rail services. In this regard, we would request that the potential impacts from development affecting Network Rail's level crossings, is specifically addressed through planning policy as there have been instances whereby Network Rail has not been consulted as statutory undertaker where a proposal has impacted on a level crossing. As such, we strongly believe that the importance of Level Crossing safety warrants a specific Policy included in the Supplementary Planning Guidance Document which will help to elevate the importance of Level Crossings within the development management and planning process. We request that a policy is provided confirming that:The Council have a statutory responsibility under planning legislation to consult the statutory rail undertaker where a proposal for development is likely to result in a material increase in the volume or a material change in the character of traffic using a level crossing over a railway: Schedule 4 (d)(ii) of the Town & Country Planning (Development Management Procedure) (Wales) order, 2012 requires that... "Where any proposed development is likely to result in a material increase in volume or a material change in the character of traffic using a level crossing over a railway (public footpath, public or private road) the Planning Authority's Highway Engineer must submit details to both The Welsh Ministers and Network Rail for separate approval". As a first principle, Network Rail would seek to close Level Crossings where possible. Any planning application which may increase the level of pedestrian and/or vehicular usage at a level crossing should be supported by a full Transport Assessment assessing such impact: and The developer is required to fund any required qualitative improvements to the level crossing as a direct result of the development proposed.

Network Rail

(Barbara

Morgan) 41520

Developer Contributions: The Local Development Plan should set a strategic context requiring developer contributions towards rail infrastructure where growth areas or significant housing allocations are identified close to existing rail infrastructure. Many stations and routes are already operating close to capacity and a significant increase in patronage may create the need for upgrades to the existing infrastructure including improved signalling, passing loops, car parking, improved access arrangements or platform

Network Rail

(Barbara


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extensions. As Network Rail is a publicly funded organisation with a regulated remit it would not be reasonable to require Network Rail to fund rail improvements necessitated by commercial development. It is therefore appropriate to require developer contributions to fund such improvements. Specifically, we request that a Policy is included within the document which requires developers to fund any qualitative improvements required in relation to existing facilities and infrastructure as a direct result of increased patronage resulting from new development. The likely impact and level of improvements required will be specific to each station and each development meaning standard charges and formulae may not be appropriate. Therefore in order to fully assess the potential impacts, and the level of developer contribution required, it is essential that where a Transport Assessment is submitted in support of a planning application that this quantifies in detail the likely impact on the rail network. To ensure that developer contributions can delivery appropriate improvements to the rail network we would recommend that Developer Contributions should include provisions for rail and should include the following: - A requirement for development contributions to deliver improvements to the rail network where appropriate. - A requirement for Transport Assessments to take cognisance of impacts to existing rail infrastructure to allow any necessary developer contributions towards rail to be calculated. - A commitment to consult Network Rail where development may impact on the rail network and may require rail infrastructure improvements. In order to be reasonable these improvements would be restricted to a local level and would be necessary to make the development acceptable. We would not seek contributions towards major enhancement projects which are already programmed as part of Network Rail's remit.

Morgan) 41520

Planning Applications We would appreciate the Council providing Network Rail with an opportunity to comment on any future planning applications should they be submitted for sites adjoining the railway, or within close proximity to the railway as we may have more specific comments to make (further to those above).

Network Rail

41520

Notwithstanding the above, I enclose a link to Network Rail's website; http://www.networkrail.co.uk/browseDirectory.aspx?dir=\RUS%20Documents\Route%20Utilisation%20Strategies\Wales&pageid=2895&root= This link provides access to Network Rail's Wales Route Utilisation Strategy (November 2008) of which sets out the strategic vision for the future of the railway in this vital part of the railway network. It is hoped that this will be of use to the Council to keep you up to date with future aspirations for railway development in Swansea. We trust these comments will be considered in your preparation of the forthcoming policy document.

Network Rail

41520

WYG Planning and Environment represent Sainsbury's Supermarkets Ltd (SSL) and the following responses are submitted on their behalf. SSL would like to indicate their interest to the City and County of Swansea in the production of the Swansea Local Development Plan (LDP). Sainsbury's are seeking to expand and improve their port-folio of supermarkets in and around Swansea in addition to their existing stores at Quay Parade, Gorseinon, Uplands Crescent and Gower Road. Sainsbury's anticipate that growth over the LDP period will support the operation of other key stores within the county area. Focus of Representation We note the early stage of the Swansea LDP however, wish to make comments on the recently published Strategic Options (consultation draft) July 2012. Firstly, we would like to note our position and interest in terms of retail provision in the City and County. As such, we would like to be considered a key consultee in discussions regarding the planned retail provision.

Peter Waldren

41571

As you will be aware, Hammerson UK plc (Hammerson) is the Council's development partner in respect of the retail led city centre regeneration which relates to land at both the (now demolished) St David's Centre and Parc Tawe. As with such complex projects around the UK, there is a significant lead in period to delivery. During such time it is important that the investment and development potential is appropriate protected. Hammerson is very supportive of the Council's preparation of new City and County wide planning policy being prepared. The Vision and related objectives set out within the Consultation Draft, which amongst other issues seeks to "reinforce and improve the city centre as regional focus for business, administration, shopping, culture and leisure". Hammerson is supportive of ambitious residential and economic growth set out in the Section 1 of the Strategic Options document given the regional importance of Swansea in South Wales. In respect of the spatial planning options set out in Section 2 of the same document which respect to anticipated levels of growth, we have a strong preference for the focus of new homes and jobs to be closely associated with the existing urban area of Swansea, and therefore well related to the shops and services of the city centre. This is in accordance with Planning Policy Wales (PPW), Edition 4 (February 2011) Chapter 10 (Planning for Retail and Town Centres). In addition to the City Centre offer, there are a number of other retailing locations within the City & County Borough servicing a range of functions and services. The last retail study prepared on beheld of the Council demonstrated that there are a number of out of town locations which already have a significant share of comparison goods expenditure for example. The following is an extract are from the Council's own Retail Capacity and Policy Advisory Study (2005): "the low market share of Swansea city centre has been influenced by the large quantity of out-of-centre development that has taken place in recent decades, which has drawn shoppers away from the city centre. The strength of the Enterprise Park (with 7.5% of the total comparison expenditure across a wide Survey Area) and Parc Fforestfach (4.5%) illustrates this" (Para 6.12) "the draft retail policies, although supportive of enhancing city centre viability, will need to be strengthened in order to strictly control further out-of-centre development. Any further out-of-centre development will simply put back the day when a major city centre development can be achieved" (Para 6.36). Hammerson is mindful that the emerging LDF should not promote either new retailing locations, or the enhancement of existing retail locations (whether as an identified centre, or an out of town location), in an unsustainable manner. Hammerson is concerned that there are a number of promoted sites and land, set out in Section 3, which will either be dependent upon, or will at least seek to strongly promote commercial/retail uses, that would compete with the City Centre's existing and anticipated offer. Therefore,

G L Hearn

41575


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any subsequent LDF policy document should be quite clear about this retained focus for the established retail hierarchy as this related to homes and jobs growth spatial planning. This comprehensive planning strategy should also be based on robust and up to date retail evidence base as it is likely that the City Centre's performance has worsened over recent years. Hammerson requests that the Council's policies ensure that any significant growth areas are clearly focussed on delivering new homes, and where appropriate include small scale retailing provision to meet local convenience needs. Further significant scale competing retail/leisure offers will be counterproductive to sustainable planning at its widest level. Hammerson would be willing to contribute to any discussions that the Council's planning department on the above related matters in advance of the next stage of LDP drafting. Please contact Ben Wrighton using the above contact details should you require any clarification on the above.

Given that the Gower Peninsula, part of the National Nature of Wales, nature at its best, with farm and villages, is at risk of being destroyed; a vision of the future must be placed in the minds of those who would destroy nature for capital gain, under false claims, that fields in villages need to be turned into housing estates, that would destroy village life of local country peoples, and turn a small peninsula into suburbia expansion, as if earth is expendable. A warning from history, to blurry minds that, within a warning from history of towns peoples, depended on farm fields to grow foods, or they all would have died from the lack of food. Not such a small thing, as it takes mass land to grow, only wheat for bread, and potatoes, not to mention vegetables, or mass grass land for cows and sheep etc. Towns people are fools, but the rulers of towns are bigger fools; if you all think within verisimilitude, that within World Ward Three, shops like Tesco would remain open to suit towns people, or that what was fields now housing estates, can grow foods, to keep, millions of towns people alive, when all things go wrong, "as it will". Officialese, is that that do's not know, what the Home Guard is, and without foods, all the children are dead. Let me enlighten you all, that rile if, you have the means to understand; Syria, Iraq, Iran, Afghanistan, Pakistan, Lebanon, Israel etc. etc. is about to explode, "mixeing", with the situation going out of control in Greece, Spain etc. etc. that may well start World Ward Three. OK, or are you blind. Given that a World War starts; most of the police, would go with the army, navy, airforce, and ALL 16 year olds to 60 year olds; all going to War, the other side of the world (a bit like World War Two); that leaves children, women, the ill, and the old left within the British towns, millions all depending on foods, from fields in villages. But if it is up to you who rule, you get rich now, and the mass peoples die then. What you do today is the continuation of yesterday that determines the end of lives. To look in the childrens eyes is to tell them lies, if land development turns fields into means of unableness to feed them life. Who then has the only gain, to turn fields into housing estates; oh yes, the rich. Now is the time, that the police, army, navy, airforce, and home guard speak out loud, to say, no to land developments on fields that grow our childrens foods. Furthermore to the blind who can not see, "or" no not wish to see. "See" Russia Today News on Freeview 085. This new shows the true situation how World War Three is near. It do's not lie, like the BBC."Your" childrens lives depend on "you" looking at Russia today news freeview 085 (each day passing). Moreover; how soon you all forget that, the hole in the ozone layer, greenhouse effect, as icecaps melt to sea level rise, as the weather systems change for the worst, all is a danger to earths magnetic field, that can lead to quaqua-illiquation-inglobatation, if the wise do not wake up. As that, Israel being trapped within the Middle East wars etc., would press a nuclear button, to defend itself, being fools. What a future the children have; but I see what is going wrong, why must it start with you. This letter must be put on the database all have a right to read it. If you fail to do so you fail all children. I Mr G A Morris born in the village in Gower, now age 64 ¾. "Facts" hurt so do's dieing.

Mr Geoffrey

Allan Morris

41581

We act as planning consultants for Barclays Bank plc ("the Bank") in respect of the Development Plan for Swansea and have previously made representations on the LDP Issues consultation in September 2011. We have had no feedback on those representations but trust that the Council will give them serious attention as the LDP evolves.As a long-established business, the Bank has made a substantial contribution to the vitality and viability of Swansea over the years that it has traded as a significant stakeholder within the Council's area it is therefore concerned that development plan policies should not fetter the important contribution that it makes to the vitality and viability of city and town centres. Through high attraction of footfall, financial services retailers generally, (and the Bank in particular) play a key role in promoting town centre health and as a result, the provision of financial services should be encouraged to improve and evolve alongside improvements to shopping provision. It is likely that the Bank's representation in Swansea will continue to evolve over the life of the plan and such investment should be welcomed and facilitated by planning policy. In our previous representations we commented that the commencement of the preparation of the Local Development Plan (LDP) is an opportunity for the Council to recognise the key role played by financial service retailers such as banks and building societies and to plan accordingly. As an intended replacement for the current UDP and the Council states that the LDP "Vision and Objectives represents a key stage of the LDP process" and that the role of the Vision within that process "is to clarify the core purpose of the Plan and provide a framework for developing the Preferred Strategy and future detailed policies". It is therefore of concern to the Bank that the Vision, the Objectives document and the Strategic Objectives document provide a review of only a very limited number of matters which will need to be addressed in the evolving plan. The 'Strategic Options' document seems to suggest that the next stage will be the publication of a 'Preferred Strategy' however if this is the case the Bank's concern about the lack of analysis of other matters and the dearth of evidence is increased. The Council's 'Draft Objectives' to - "Support the development of Swansea as an economically competitive place and a regional economic driver, - Reinforce and improve the City Centre as a vibrant regional focus for business and administration, shopping, culture and leisure" are laudable aims but the LDP will require much more detailed analysis and evidence in order to produce the "future detailed policies" that can help to achieve them. The Bank's response to the consultation last year on

the Issues paper (particularly on the Retail paper) contained detailed representations and evidence to show how its presence has a beneficial effect on the vitality and viability of primary shopping frontages in town centres. Those representations concluded by noting that the 'Issue' suggested in the Retailing paper about controlling "proliferation of non-

Shire

Consulting

(Michael Fearn)

41600


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retail uses within shopping centres" is actually an erroneous conclusion rather than an issues, and is not based upon any supporting evidence. We commented that the Council should recognise the evidence provided by the Bank showing the important contribution to vitality and viability made by financial service retailers such as banks and building

societies in both bringing investment and acting as attractors for investment by others. We trust that before any publication of a 'Preferred Strategy' for the LDP the Council will address the matters that are not covered in this limited consultation and base its draft land use policies on robust evidence such as that provided by the Bank. The Bank confirms its

interest in the forward planning process and we shall be grateful if the Council will continue to notify us of the progress of this and other planning documents.

Conclusion-These representations have been submitted on behalf of Edenstone Homes in order to provide views of the Vision, Objectives and Strategic Options consultation for the Swansea LDP. Edenstone Homes are promoting housing development in two locations. The candidate sites surrounding Cwmrhydyceirw Quarry are suitable for development early within the plan period. Technical studies have shown that the future development or infilling of the quarry does not post a constraint to the development of these sites. They

could deliver circa 120 houses on circa 4 Ha of land. Given that the sites lie within a existing settlement boundary and are not subject to any green wedge or flooding constraints, they should be prioritised for housing allocations whichever option is taken forward for the LDP, given that this would relive pressure on allocation of existing land in green wedges

or the countryside. The potential to develop the sites alongside a development of the quarry site could deliver circa 250 houses within the plan period. The site promoted within the

Morriston North Area can deliver housing to serve the existing employment centre of the hospital without incursion into the countryside, whether it is developed independently or as

part of a wider allocation to serve plans for an expanded hospital. Therefore it can feature as an allocation whichever option is taken forward. I trust the above assists in providing

you with an insight into the potential offered by each site. We would welcome the opportunity of a meeting so that the proposals can be discussed in further detail. If there is

anything further you require to process the representations please do not hesitate to contact me. (Refer to file for full letter).

Paul Williams

41521

Review of Comments Received

Introduction

Section 1

Projection Figures

Alternative Projection 1




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Alternative Projections All

General Comments

Section 2

General Comments

Development/Economic

Option 1

General Comments

Area Specific

Option 2

General Comments

Area Specific

Option 3

General Comments

Option 4


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General Comments

Area Specific

Alternative Options

Option Combinations

Options 1 & 2

Options 1 & 3

Options 1 & 4

Options 1 & Alternative

Options 2 & 3

Options 2 & 4

Options 3 & Alternative

Options 3 & 4


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All

Option – General Comments

Section 3

General

Pontarddulais North

Pontarddulais South

Morriston South & North

Fabian Way Corridor

Swansea Vale

Morfa

Bonymaen

Birchgrove


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Clydach

Tycoch

Thistleboon, Mumbles

Newton

Dunvant

Gowerton

Loughor

Garden Village

Gorseinon West & East

Fforestfach

Felindre


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Penllergaer

Llangyfelach

Large villages, rural and semi -rural locations

Other/Combinations


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Appendix 4

Preferred Strategy Consultation Details


Various mechanisms were employed in order to raise awareness of the Preferred Strategy consultation. They included the following:


• Presented to the LDP Member Advisory Group 24th June 2013 and Cabinet - 23rd July 2013.

• Councillors sent an email & letter regarding the consultation and community involvement sessions (17/06/13).

• Councillors invited to drop in sessions in the Planning Policy Team Offices (17th, 18th, 19th and 22nd July 2013).

• Reported to Development Management and Control Committee 1st August 2013.

o Publicity

Online

• The LDP web page provided coverage and a link to dedicated Preferred Strategy dedicated web pages.


• Dedicated pages for the Preferred Strategy consultation on the Planning Policy Pages of the Council website (www.swansea.gov.uk/ldpps).

• The JDi e-consultation website was used http://swansea.jdi-consult.net/ldp/ and during the consultation period (12/08/13 – 31/10/13) the site registered 3211 visitors.

• The consultation was signposted on the Swansea Consultation Partnership Database: http://www.swanseaconsultationpartnership.org.uk/ (see appendix 2 for screen cap)

• All information from the community information sessions were posted on a dedicated webpage via: http://www.swansea.gov.uk/cis2013

• Press releases:

� Public to have their say on long-term development plans in Swansea (30/08/13) http://www.swansea.gov.uk/index.cfm?articleid=55713


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� Grand plan for city moves forward (22/07/13) http://www.swansea.gov.uk/index.cfm?articleid=55204

� Public to get chance to have say on development plans for Swansea (31/05/13) http://www.swansea.gov.uk/index.cfm?articleid=54649

� Roadshow takes Local Development Plan to Swansea communities (23/09/13) http://www.swansea.gov.uk/index.cfm?articleid=56027

� Views sought on Swansea's long-term development plans (30/10/13) http://www.swansea.gov.uk/index.cfm?articleid=56420

In print

• These press releases generated 10 articles in the local newspaper the Evening Post from 31/05/13 to 07/10/13.

• Details of the consultation and the LDP process were featured in an article in the July 2013 edition of the Swansea Leader (http://www.swansea.gov.uk/media/pdf/8/p/swansea_leader_july_2013.pdf)

• A post consultation write up featured in the November 2013 edition (http://www.swansea.gov.uk/media/pdf/e/r/swansea_leader_november_2013.pdf.

• Bilingual posters displayed in the Civic Centre reception.

• LDP Newsletter.

At Council venues

• Consultation appeared on the TV screens in the Contact Centre and Central Library.





• Notifications sent to Councillors and Community Councils via email/letter (dated 8th August 2013).

• 9 Community Sessions held across the County from 1st October to 11th October 2013.


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• Statutory Consultees and Key Stakeholders were invited to a “Preferred Strategy Meeting of Key Statutory Consultees” on 27/09/13, whereas Stakeholders were invited to a meeting on 30/09/13.

Community Sessions

The Planning Policy Team arranged 9 sessions across the County to enable members of the public to speak to Officers about the Preferred Strategy. Copies of the various LDP documents were made available to view.

Materials were also provided for members of the public to take away that included:

• LDP Newsletter 6

• Info Sheet 3.

• Consultation Forms.

• The Delivery Agreement.

• LDP Ward Profiles summaries.

• Copies of the accompanying assessments, studies, papers and Ward Profiles 2013.

• LDP process leaflets.

• Welsh Government LDP guide booklets.


Document

Respondents

Objectors

Support

Object

Comment

Representations

Supporting Documents

33 12 10 13 25 49

Preferred Strategy

195 171 235 416 5 658

Total 212 178 245 (34.8%)

429 (60.9%)

30 (4.3%)

707

All consultation responses can be found via: http://swansea.jdi-consult.net/ldp/

A Preferred Strategy Comments Report has also been produced, which summaries all the comments, key issues and actions taken. Included overleaf.


Responses to representations on

Draft Preferred Strategy July 2014

Executive Summary

Representation Ref Representor

42284 South West Wales Integrated Transport Consortium (SWWITCH) [1686]

42175 RPS Planning & Development for Associated British Ports [1878]

41805, 41807, 41803 RPS Planning & Development for Swansea University

42066 Nathaniel Lichfield and Partners for Peter Jenkins

41891 Dwr Cymru/Welsh Water (DCWW)

42000 Barton Wilmore On behalf of Baybrook Ltd

41677 CDN Planning (Wales) Ltd

41945 RPS Planning & Development

41951 Coastal Housing Group

42277 Natural Resources Wales (NRW)

ISSUES

Enhancing Communities, Facilities and Infrastructur e

a) Support from Swansea University for identification of Hendrefoilan Student Village as Strategic Development Area.

b) Support from Swansea University for plan’s recognition that a third of housing requirement will need to be on greenfield sites.

c) Support for plan’s approach to sustainable growth as set out on Page iv. Concern that ratio of two thirds brownfield is too restrictive. Suggest that the following sentence be reworded to allow more flexible approach to recognise that use of previously developed land (pdl) is not necessarily sustainable when proximity to services is taken into account. “Approximately two thirds of the housing requirement will be provided on previously developed ‘Brownfield’ land and one third on ‘Greenfield’ sites. The most sustainable option for distributing this growth is proposed to be:…”

d) Support for Plan’s approach to allowing delivering part of the housing requirement through infill and rounding off.


e) Plan’s approach should also allow appropriate infill development in urban fringe/semi rural locations (e.g. in Pontlassau).

f) Dwr Cymru Welsh Water (DCWW) offer their involvement in masterplanning of strategic sites to ensure that developments are supported by the necessary water and sewerage infrastructure and that deficiencies are addressed through regulatory investment programme.

g) Natural Resources Wales (NRW) make the following specific flood comments on strategic sites:

i. All MMUDA’s drain to Gowerton WWTW catchment, suffering from hydraulic capacity issues. Sound infrastructure provision will be a key element in securing the future development of these areas.

ii. Tawe Riverside and Swansea Vale are constrained by flood risk.

iii. Flood Consequence Assessment (FCA) for SA1 may need to be revisited.

h) NRW suggest bullet point “Creating high quality sustainable design and layouts” be amended to include reference to 'enhancing/protecting' the environment and incorporating 'sustainable technologies/features'

i) Re bullet point “master planning/place making’’ – NRW welcomes any opportunity to offer appropriate advice regarding MMUDA sites, to help ensure that the layout and design of development does not have potential impacts on the environment and maximises green infrastructure opportunities.

j) NRW supports bullet point re physical and social infrastructure.

Fostering a Quality Environment

k) NRW supports sentiments and ethos of the theme “Fostering a Quality Environment” which advocates a sustainable approach to conservation of the built environment.

l) NRW supports the approach to providing multifunctional green infrastructure network.

Delivering Economic Growth and Prosperity

m) Support from Associated British Ports (ABP) and Swansea University for the Plan’s approach to Delivering Economic Growth and Prosperity. Land surplus to ABP requirements adjacent to Bay Campus should be considered in Fabian Way Strategic Site Masterplanning. Significant potential to contribute to Plan’s economic growth through mix of uses including residential.

n) Swansea University support reference to the need to improve connectivity between the City Centre and Waterfront and suggest inclusion of a reference to the City Region to emphasise importance of creating connections between


the City Centre, Major Developments and key settlements across the City Region.

o) Amend this section to place stronger emphasis on the role of leisure and tourism industries in creating jobs. Also, that jobs could be created throughout the county, including the AONB, not just in the City Centre and Waterfront. Section needs to recognise that sustainable development in rural areas encompasses meeting economic as well as environmental and social objectives.

p) Support from Coastal Housing Group for the Plan’s approach to improving City Centre Vitality and the focus of new retail and office development in the city centre. Plan should consider redevelopment of longstanding vacant out of town retail units for housing.

RESPONSES a)b) Support is noted. The Preferred Strategy identifies Hendrefoilan Student

Village as an Urban Area Housing Site.

c) Reference to the ratio of brownfield and greenfield sites is not expressed in this paragraph in terms of a quota. It is an approximate indication based on the evidence of the supply of appropriate brownfield land contained in the Previously Developed Land (PDL) Capacity Study. The Preferred Strategy has recognised that the development of greenfield sites supported by the appropriate social and physical infrastructure will make an important contribution to delivering the required level of growth in the County. This is expressed in para (ii) on page iv which refers to the strategy of allocating Major Mixed Use Development Areas and Strategic Development Areas. The sites referred to in this paragraph relate to a mixture of PDL and greenfield sites. Agree that paragraph (ii) could be amended to clarify that the Preferred Strategy does include the development of major greenfield sites. Add a new second sentence that states ‘This will involve the development of major greenfield sites.’

d)e) Comments noted. Small scale infill and rounding off forms an important part of the Plan’s strategy and allows incremental and organic level of growth, particularly in rural areas, which can support the sustainability of the local community.

f) The Council welcomes the support of DCWW and will continue to work in partnership with them throughout the detailed candidate sites assessment process and the drafting of the Deposit Plan.

g) The Council welcomes the comments and support from National Resources Wales (NRW).

i. With regard to strategic development in the Gowerton Treatment Works catchment area, DCWW have recently made significant improvements and investment the Works. They have invested in a new


hydraulic model for the Gowerton catchment. The findings of which have indicated solutions throughout the catchment and these would have to be delivered prior to development occurring. As part of their interaction with the Memorandum of Understanding (MoU)they are undertaking surface water removal within the Gowerton catchment as part of the existing Asset Management Plan (2010-2015) and will continue with further work in their next Asset Management Plan (2015-2020). This work will help alleviate flooding in the catchment as well as reducing the number of spills to estuarial waters. Furthermore, The Local Development Plan (LDP) will encourage developments to utilise sustainable principles in the design of buildings, promote sustainable drainage systems where ground conditions allow the minimising surface water run-off and flooding, and provide positive contributions to tackling climate change.

ii. The residential elements of Tawe Riverside and Swansea Vale can be located away from specific flood risk areas.

iii. A FCA has recently been undertaken as part of the latest Swansea Vale Development Brief and the FCA for SA1 will be resisted as part of the ongoing masterplanning work for the Fabian Way corridor.

h) With regard to the first bullet point on page (iv) relating to sustainable design and layouts. A reference to sustainable technologies would be appropriate and the paragraph will be amended by adding the following new bullet “Incorporating sustainable technologies and features into the design process”.

i) The Council will continue to work closely with NRW to ensure that the most up to date environmental information is used when masterplanning strategic sites and working up the detailed allocations for the Deposit Plan to ensure that the design and layout of strategic sites takes appropriate account of the potential impacts of development on the environment.

j) Support welcomed for the physical and social infrastructure bullet point.

k) Support welcomed for the Council’s sustainable approach to the conservation of the built environment which recognises that conservation must be balanced against the need to facilitate sustainable growth.

l) With regard to maximising Green Infrastructure opportunities, the Council will continue to work with NRW to progress work on the ongoing joint Study in relation to natural resource planning

m) The Council welcomes the support from ABP and Swansea University for the principle of a strategic site at Fabian Way. The Preferred Strategy will be amended to identify the Fabian Way corridor as a strategic development area and work is ongoing to discuss the masterplanning of the area with the various interested parties and landowners.


n) Support from Swansea University for the 5th paragraph is welcomed and agree to add reference to the benefits for the City Region from enhancing connectivity and improving linkages to key settlements.

o) Tourism has a key role in the County’s economy and a new paragraph will be added to the “Enhancing Communities” section.

p) Coastal Housing Group’s support for the Plan’s approach to City Centre vitality is welcomed. Chapter 7 contains a specific policy on city centre and retailing and specific issues such as out-of-town retailing will be dealt with in the Deposit Plan.

Chapter 1 : Introduction

General Comments


42042 Abertawe Bro Morgannwg University (ABMU) Health Board [14437]

42035 Alex Welby

42150 Alison Bowden

42230, 42231, 42233 Boyer Planning for Persimmon

42256 Clive Reed


41995 David Ramsay

41999 Denis Dodd

41993 Dr Gareth W Hughes

41648 E & C V Jones

41666 Environmental Planning for site owners CS BI001

41628 Geraint Brown

41633 Gordon Gibson

42262 Gower Society

41994 H. Martin Smith

41759 Hazel Rosser

41973 Inland Waterways Association

41672 Jane Livingston

42034 Jane Hennell


41654 Martyn Jones

41675 Mobile Operators Association

41619 Mr & Mrs L Evans

41620 Mr David Bines

41643 Mr Graham Lewis

41694 Mr Haydn Morgan

42028 Mr Howard Jones

41676 Mr Peter Browne

41626 Mr T B Miles

41777 Mrs Bridget Stein

41636 Ms S P Talbot

41681 National Grid

41972 Natural Resources Wales (NRW)

41685 Network Rail

41622 P Hart

41629 P Lewis

41659 RSPCA Llys Nini

41673 Ruth Mureph


41828 Swansea Canal Society

41939 Swansea Community Boat Trust

41639 Sylvia Hughes

41885 Tim Gent, Savills, for St Modwen Developments Ltd

42036 Welsh Government

Habitat Regulations Assessment Recommendation

ISSUES a) General support for the Preferred Strategy. b) National Grid have provided information about HV Electricity overhead

transmission lines/underground cables, substations and pipelines within the Swansea area to be taken into account during preparation of LDP.

c) Mobile Operators Association suggests that a clear and flexible telecommunications policy be introduced in the LDP. This should be


introduced by a short paragraph outlining the development pressures and the Councils policy aims.

d) ABMU Health Board Swansea support work on Health Impact Assessment Methodology. Request further discussions regarding primary care provision capacity issues. Particularly regarding strategic developments in Felindre and Penllergaer where no primary care facilities are currently located. The proposed strategic site in Waunarlwydd is likely to impact on surrounding practices.

e) Support from SWWITCH for Preferred Strategy, in particular references to Regional Transport Plan (RTP) as basis for strategic transport development and the RTP funding as a potential source for future transport improvements. Suggest that more references to Swansea Bay City Region would be beneficial in terms of likely funding sources for future improvements.

f) Network Rail request the inclusion of a policy which requires developers to fund any qualitative improvements required in relation to existing facilities and infrastructure as a direct result of increased patronage resulting from new development.

g) Suggestion that the LDP should be more flexible to build in contingency for economic contraction. Concern that the LDP will stifle growth through inflexibility.

h) Suggest that scale of housing at Felindre MMUDA be reduced to address concerns about impact on welsh language. Ensure that scheme addresses need for Welsh medium education.

i) Consider that Preferred Strategy contains insufficient detail to enable comment.

j) Concern regarding the amount of greenfield land proposed for development. Suggest that all brownfield opportunities and vacant properties be used before developing greenfield sites.

k) The plan should ensure that new developments provide sufficient open/greenspaces and preserve existing spaces. The plan should recognise the important role of greenspaces as wildlife/green corridors, local amenity spaces, and the contribution they make to local landscape character.

l) Support for scale of development proposed, subject to proper provision of infrastructure and sufficient community consultation.

m) The plan should ensure that a mix of house sizes is provided to enable first time buyers to enter the market.

n) Objection to Preferred Strategy, mass housebuilding for 16,000 new homes does not relate to needs of local people and is not supported by local jobs.

o) Comment noted. The agricultural land classification of Greenfield sites is covered as part of the individual site assessments.

p) The Habitat Regulations Assessment (HRA) Screening Report concludes that chapter 1 is screened out for further assessment because it is comprised of contextual information and will not lead to any change that could affect a European Site.

RESPONSES


a) Support for Preferred Strategy is welcomed. b) Information from National Grid is noted and will be taken into account when

preparing the LDP. c) The comments of the Mobile Operators Association suggesting a detailed

telecoms policy will be taken into account when drafting detailed policies for the Deposit Plan.

d) ABMU Health Board’s support of the HIA methodology is noted. The Council have requested evidence from ABMU about the capacity of primary care provision, particularly in relation to the impact of strategic allocations and are reliant on ABMU as the responsible Health Board to provide sufficient information in order to ensure that development allocations will be supported by the appropriate level of health care infrastructure.

e) Support from SWWITCH is welcomed. Agree that the additional references to the City Region would enhance the Plan strategy context and will be incorporated as appropriate.

f) The Deposit Plan will contain a policy to ensure that improvements will be sought where developments are found to have an impact on rail infrastructure and facilities.

g) The Preferred Strategy emphasises that the number of jobs proposed is based on the ‘upper end’ forecast for employment growth, as per the findings of the Economic Assessment and Employment Land review undertaken for the Council by independent consultants Peter Brett Associates. There is therefore an implicit flexibility within this approach since it is an aspiration based on future growth across key sectors. The Plan needs to support allocations that will facilitate these growth aspirations in the interests of driving forward the regional economy, however inevitably if certain sectors do not generate the levels of investment anticipated the overall number of jobs created may be lower. The Deposit Plan will address the issue of redevelopment of land allocated for business uses, and set out the criteria that will inform a flexible approach to considering other land uses on established ‘employment land’.

h) The revised Technical Advice Note 20 (Planning and the Welsh Language) states clearly that the Welsh language should be considered during the production of LDPs, as part of the Sustainability Appraisal (SA) process, where local planning authorities have identified the Welsh language as being of importance. This process ensures that the Welsh language can be embedded into the LDP ensuring that all subsequent policies, proposals and eventual site allocations will have considered the impacts on the Welsh language. From a Swansea perspective, SA Objective 6 tests whether the Plan encourages an inclusive society and promotes equality (incorporating the Welsh language) whilst the specific LDP Objectives established seek to reduce the impacts of new development on communities where the Welsh language forms part of the social fabric. This means that the LDP must provide for sustainable development by protecting, and where possible enhancing, the cultural environment whilst facilitating sustainable economic growth and ensuring that all new development is supported by appropriate


physical and social infrastructure. Furthermore, the Spatial Options Assessment Topic Paper concluded that whilst the scale of growth proposed had the potential to put pressure on the capacity of social infrastructure, including the Welsh language, the opportunity to masterplan sites would bring positive benefits by ensuring that the Council is able to achieve the objectives of planning for sustainable, distinct communities. An updated assessment of the importance of the language within a Swansea context along with the consideration of the potential effect of developments upon the language is currently underway and will inform the production of the Pre Deposit Plan. This will be undertaken in the full knowledge of further practical guidance developed for local planning authorities to assist them with assessing the potential impacts of the LDP proposals on the Welsh language (via the SA) recently published by the Welsh Government, the provisions of which will be fully taken into account. The requirement for the additional provision of Welsh medium education will be considered as part of the in combination full assessment of all suitable Candidate Site submissions.

i) Concerns noted, however the Preferred Strategy is a high level strategic document. The detailed proposals will be set out in the Deposit LDP.

j) Comment noted. However there is insufficient previously developed (Brownfield) land remaining to meet the future population increases indicated by Welsh Government projections up to 2025, which necessitates the release of some Greenfield sites for development. The Preferred Strategy aims to maximise the use of previously developed ‘Brownfield’ land by accommodating approximately two thirds of the housing requirement on brownfield land and one third on ‘Greenfield’ sites.

k) The importance of maintaining and enhancing green infrastructure networks is recognised by the Plan’s Objectives and also through Strategic Policy 5: Green Infrastructure.

l) The Plan contains a number of strategic objectives and policies which seek to ensure that new development is supported by the appropriate community facilities and transport and utilities infrastructure.

m) The evidence upon which the strategy is based enables the plan to determine the number of new homes required and the tenure and type of housing. However, the plan can only encourage the development of a specific type of house size. This will be a matter for detailed supplementary planning guidance. The Council has published guidance in the form of the Residential Design Guide which encourages an appropriate mix of house sizes.

n) The Housing Requirement takes into account the robust evidence contained in the Strategic Housing Market Assessment, (which analyses the number and size of homes required for each of the County’s local strategic housing policy zones) and the Economic Growth and Employment Assessment (which sets out the evidence to establish the most sustainable approach to economic growth for the County). Based on this evidence, the Preferred Strategy seeks to set a deliverable and viable level of development which takes into account the County’s aspirations for economic growth and the level of housing that would be required to support this growth.


o) Comments noted. Chapter 2 : Context and Key Issues

General Comments

Representation Ref Representor 42177 RPS Planning for Associated British Ports 42320 Nathaniel Lichfield and Partners for Peter Jenkins (Glanffrwd Road CS Ref: PT011) 41878 Sustrans Cymru Habitat Regulations Assessment Recommendation

ISSUES

a) Support the recognition of significant opportunities for renewable energy generation and infrastructure. Detailed masterplanning for Port/Fabian Way area should consider the potential for these to be provided on land within ABP ownership.

b) Sustrans request that Page 14 Bullet 6 be amended to read 'Appropriate siting and design of development will significantly help to minimise use of the car and achieve increased rates of non motorised travel, particularly walking for journeys of less than 3km and cycling for journeys less than 3km 8km' This reflects the fact that 8km/5miles is a journey time of approx 30 minutes by bike.

c) The HRA Screening Report concludes that chapter 2 is screened out for further assessment because it is comprised of contextual information and will not lead to any change that could affect a European Site.

RESPONSES

a) Since the publication of the Draft Preferred Strategy the Authority has maintained a dialogue with key landowners at the Eastern Gateway strategic site (comprising the area between the Docks/Langdon Road and the new University Campus south of Fabian Way), with an emphasis on co-ordinating development proposals and bringing forward a concept plan. This work is taking place within the wider context of the masterplanning of the Fabian Way Corridor with Neath Port Talbot Council. It is for these detailed appraisals to consider the mix of land uses and key infrastructure, and whether energy projects should comprise a constituent part of this.

b) Agree that the proposed change would reflect aspirations for encouraging sustainable travel. Amend accordingly.

c) Comments noted.


Para 2.4 to 2.9 - Regional Context

Representation Ref Representor 41892, 42298 Dwr Cymru/Welsh Water (DCWW) 42299, 42300, 42301, Natural Resources Wales (NRW)) 42302, 42278, 42279, 42280, 42281 42282, 42283, 42052 Nigel Bowen-Morris

ISSUES

a) DCWW recognises the importance of the Swansea Bay City Region in driving the Welsh economy. Support for sustainable economic development. Prerequisite of delivering development is the prevalence or ability to provide utilities infrastructure. DCWW will continue to work with local authorities realise the City Region vision.

b) NRW supports collaboration with adjoining local authorities on partnership arrangements on delivering cross border development. Consider whether para 2.6 could be supported by evidence - examples of cross boundary working or successful collaboration with other non local authority bodies e.g. Swansea University - Fabian Way.

c) Support for reference in para 2.9 to reinforcement of cross border cooperation and environment protection plus enhancement.

d) Para 2.7 could be integrated with the vision for city centre regeneration. There is an opportunity to create strong grass roots retail development, for example, by harnessing the creative potential of graduates leaving local colleges with start up business incentives. Retail lower floors could be used for business and upper floors to create over-the-shop residential.

RESPONSES a)b)c) Support is welcomed and DCWW’s commitment to joint working on City

Regions is acknowledged. In-line with National Planning Guidance, the Wales Spatial Plan and City Region context, the Council has jointly with Neath Port Talbot County Borough Council undertaken a Sub-regional Strategic Housing Market Assessment and an Economic Growth and Employment Land Assessment in recognition of the identified sub-regional geographical extent of the local housing and employment markets.

d) The Preferred Strategy is a high level strategic document which is not able to contain this level of detailed proposal. Suggestions are noted for consideration in drafting the Deposit Plan.

Para 2.10 to 2.19 - Local Context


Representation Ref Representor 42176 RPS Planning & Development for Associated British Ports (ABP) [1878]

41952, 41953, 41954 Coastal Housing Group

42053 Nigel Bowen-Morris

42239 Robin Campbell

41913, 41914 RWE Npower Renewables (RWE NRL)

ISSUES

a) ABP suggest a flexible approach be taken to potential land uses within the docks and Fabian Way area to support economic aims.

b) Coastal Housing generally supports the approach and suggests a number of ways in which the High Street public transport interchange could be improved.

c) Suggest a number of actions to ensure that the city’s cultural assets continue to make a contribution to the economic well being and protect the unique sense of place.

d) Coastal Housing suggest an over cautionary approach to flood risk may restrict the Council’s ability to meet housing targets.

e) Support from RWE NRL for context set out in paras 2.18 and 2.19.

RESPONSES

a) A reference to the land at and around the operational port being a key strategic employment area would be beneficial in section ‘Local Context’, Add to paragraph 2.13 after M4 J46 “and land south of Fabian Way”.

b) Support noted. These are details which can be considered in the drafting of the Deposit Plan polices and proposals relating to the City Centre, which will include a focus on High Street as a key complementary area to the retail and leisure core.

c) Comments noted however several of the suggestions relate to actions that are outside of the control of the development plan.

d) The restriction of housing development on designated flood risk areas is controlled by National Planning Policy Guidance (TAN15). Amend final sentence of para 2.17 to make clearer that the constraints are imposed at a national level and change “respects floodplains” to “respects designated flood risk areas”.

e) Support welcomed.


Para 2.20 – Key Issues and Drivers

Representation Ref Representor 41778 Mrs Bridget Stein 42054 Nigel Bowen-Morris 42285 South West Wales Integrated Transport Consortium (SWWITCH) [1686] 41996 Byron Davies AM ISSUES

a) Diversification of economy should look more widely than just the knowledge and higher salary sectors, particularly considering the rural nature and natural diversity of the county.

b) “Social Bullet Points” There is a potential for Swansea to capitalise on its City Region status and Welsh language hinterland.

c) “Environment Bullet Points”: i. Biodiversity: There is an opportunity to establish an urban biodiversity

policy with relevant stakeholders, to ensure that biodiversity is not lost.

ii. Transport: Consideration should be given to a regional light rail network and planning should make a presumption against development on track beds which may be needed in the future.

iii. Sewage: Consideration should be given to reed bed filtration systems in conjunction with local area reed beds which may also enhance biodiversity.

d) SWWITCH support key issues identified relating to access and transport and request that a bullet point be added to refer to the role of Travel Planning, specifically - working with public and private sector bodies to encourage the development and adoption of travel plans which will support sustainable transport options for work journeys.

e) Byron Davies AM considers that development in rural areas/Gower Fringe should be restricted to local needs only. Ensure that no holiday homes are built.

RESPONSES

a)b)c) Comments are noted. These are details which can be considered in the drafting of the Deposit Plan. The plan does not need to diversify to consider rural economy, it is already supported under current policy and will continue to be supported in the LDP. There is a bullet point to this effect. City Region is dealt with under ‘Economy’. The safeguarding of Welsh Speaking communities is a bullet point. The bullet points highlight issues, not policies. Biodiversity, transportation and sewage matters will be covered by the Deposit Plan policies.


d) Support noted and agree that the proposed change would reflect aspirations for encouraging the use of travel planning. Amend accordingly. Under Environment add bullet point ‘Public and private sector bodies have an important role to play in the development and adoption of travel plans, which have significant potential to deliver sustainable transport options for work journeys in particular”.

e) The Strategic Housing Assessments have identified that there is little need for market housing on Gower and the Gower fringe and in order to provide for local householders any additional housing should be affordable. There is a query over the viability of 100% affordable housing and therefore in order to provide for the need and support economic growth a small percentage of market housing may be required. The increasing number of dwellings being used as holiday homes on Gower is an issue for the LDP and should be added to the list of key issues in paragraph 2.20. Control over the use of local need affordable homes as holiday homes can only be achieved through the employment of registered social landlords (RSLs) and through planning conditions and planning obligations.

Chapter 3 : Vision and Objectives

General Comments

Representation Ref Representor 42234 Boyer Planning for Persimmon Homes West Wales 41864 Asbri Planning for N Jones & Siblings (Site owner BI007 & BI009) [2113] 41765 Hazel Rosser 42321 Nathaniel Lichfield and Partners for Peter Jenkins 41893 Dwr Cymru/Welsh Water DCWW 41817, 41818, 41819 White Young Green for Sainsburys 41883 Sustrans Cymru 41646 Mr Peter Walters 42219, 41873 Asbri Planning for Persimmon Homes West Wales (CS PG002) [2113] 42243, 42240 Robin Campbell Habitat Regulations Assessment Recommendation

ISSUES a) Asbri on behalf of site owner is generally supportive of Vision and Objectives. b) Nathaniel Lichfield and Partners on behalf of site owner supports directing

new housing to viable and deliverable sites. c) DCWW support the acknowledgement of the importance of infrastructure

provision.


d) Sainsbury’s support Objective 12 and the need to reinforce and improve the city centre as a regional focus.

e) Persimmon Homes Wales generally supportive of the Vision and Objectives but suggest there is a need for further allocations to match the aspirations for economic growth.

f) Persimmon Homes Wales suggest amendment to Vision to recognise economic importance of housing delivery by adding a bullet that states: Is a thriving City Region that offers a range and choice of housing provision to meet the needs and aspirations of its community, as well as facilitating the creation of a prosperous economy. Also suggest a specific objective to relate to the provision of housing to meet community needs and bring social benefits.

g) Sainsbury’s consider that the proposed Objectives should give greater consideration to the allocation of retail sites. Objective 3 should specifically mention retail given that such facilities are equally as important as healthcare, lifelong learning, leisure and recreation. It should include wording to indicate how the Council intends to ensure the existing and future population will be provided with appropriate access to a range and choice of convenient and sustainably located facilities.

h) Sustrans consider that in light of the Active Travel Bill Objective 4 should be strengthened and amended to 'Create environments that support and promote walking, cycling and public transport as integral elements of a sustainable transport system’.

i) Development should avoid making the sea and the bay less visible. j) Persimmon Homes Wales consider the proposals for Penllergaer accord with

the Vision and Objectives. k) Persimmon Homes Wales believe that future residential development at

Gwernfadog would accord with the Vision and Objectives. l) The objectives do not mention the Welsh language despite the issuing of

TAN20 which contains guidelines on how the planning system can help safeguard the Welsh language.

m) Amend para 3.9 – bullets re “enhancing communities” to include reference to TAN20 Welsh Language.

n) Swansea is a City of Culture that throws away its heritage. o) The HRA concludes that the vision is screened out of further assessment

under category A as being a general statement and the strategic objectives are screened out under categories A as being a general statement, B as being a policy listing general criteria for testing the acceptability/sustainability of proposals and D as an environment policy/site safeguarding policy.

RESPONSES a)b)c) Support welcomed. d) Noted e) The Preferred Strategy makes clear the location of the proposed major

development areas that will allow for sufficient allocations in the forthcoming Deposit Plan. It is important that the LDP does not over designate land


significantly above and beyond that required to accommodate the scale of growth forecasted, otherwise this risks undermining deliverability of key regeneration areas and could affect the soundness of the Plan. The quantum of housing has increased to reflect WG requirements.

f) Precise wording of suggested amendments replicates other parts of the Vision, however agree that objectives 1 and 14 be amended as follows: Objective 1: “Ensure that communities have a mix of uses and facilities to create sustainable, inclusive neighbourhoods that help to bring about wider social benefits and allow community life to flourish Objective 14: “Ensure that communities have a sufficient range and choice of good quality housing to meet a variety of needs and support economic growth.

g) Disagree that access to retail provision specifically is a goal that can be placed on an equal footing with the more overarching requirements of good health, education provision and recreation, which are inherently associated with human wellbeing.

h) Agree that proposed change would be in line with provisions of the Active Travel Bill. Add “Create environments that support and…” at beginning of bullet point 4.

i) Comments noted however this point of detail in respect of design matters is not appropriately made in the overarching Vision and Objectives chapter. Detailed policies and guidance relating to development around at the waterfront and city centre will be set out in the Deposit Plan and associated supplementary planning guidance.

j)k) Comments noted. l) The importance of the Welsh Language to notions of cultural identity is

highlighted in the preamble to Strategic Policy 13 ‘Natural Heritage and the Cultural and Historic Environment’. The issue is also raised more broadly elsewhere in the document. Chapter 2 emphasises the Wards of Mawr and Pontarddulais as being language sensitive areas with the highest numbers of Welsh speakers (approximately 38% and 31% respectively), where the impact of development will be most closely considered in this regard. The revised Technical Advice Note 20 (Planning and the Welsh Language) states clearly that the Welsh language should be considered during the production of LDPs, as part of the Sustainability Appraisal (SA) process, where local planning authorities have identified the language as being of importance. This process ensures that the Welsh language can be embedded into the LDP ensuring that all subsequent policies, proposals and eventual site allocations will have considered the impacts on the Welsh language. From a Swansea perspective, SA Objective 6 tests whether the Plan encourages an inclusive society and promotes equality (incorporating the Welsh language), whilst the specific LDP Objectives established seek to reduce the impacts of new development on communities where the Welsh language forms part of the social fabric. This means that the LDP must provide for sustainable development by protecting, and where possible enhancing, the cultural environment whilst facilitating sustainable economic growth and ensuring that


all new development is supported by appropriate physical and social infrastructure. Furthermore, the Spatial Options Assessment Topic Paper concluded that whilst the scale of growth proposed had the potential to put pressure on the capacity of social infrastructure, including the Welsh language, the opportunity to masterplan sites would bring positive benefits by ensuring that the Council is able to achieve the objectives of planning for sustainable, distinct communities. An updated assessment of the importance of the language within a Swansea context along with the consideration of the potential effect of developments upon the language is currently underway and will inform the production of the Pre Deposit Plan. This will be undertaken in the full knowledge of further practical guidance developed for local planning authorities to assist them with assessing the potential impacts of the LDP proposals on the Welsh language (via the SA) recently published by the Welsh Government, the provisions of which will be fully taken into account. Amend preamble to Strategic Policy 13 to refer explicitly to following the guidance set out in revised TAN 20 and the role of the SA.

m) Agree to amend paragraph 3.9 – bullets re “enhancing communities” to include reference to TAN20.

n) The LDP will seek to set out a planning framework that avoids precisely this scenario through a set of strategic and detailed policies that build upon the stated objective of preserving and enhancing the County’s valued heritage.

o) Comments noted.

Chapter 4 : Strategic Growth Options

General Comments

Representation Ref Representor 42097 Home Builders Federation (HBF)

41865, 42220 Asbri Planning for N. Jones & Siblings (Site owners BI007 & BI009) [2113]

41761 Hazel Rosser


41886 Savills for St Modwen Developments Ltd

42151, 42158 Redrow Homes

42197, 42194, 42195, Harmers Limited for Redrow Homes

42196


41833-41858 Urban Style Land

42091, 42092 Penllergaer Estates Ltd c/o Geraint John Planning Ltd

41814, 41815 White Young Green for Sainsburys




ISSUES

a) Asbri Planning (for site owner) support the housing target but reserve the right comment further at the Deposit stage on any future amendments.

b) Support for the current housing target.

c) Redrow Supports additional growth at selected rural settlements commensurate with the scale and function of the settlement.

d) HBF consider the housing requirement is underestimated and deviation from the WG household projections has not been justified.

e) Nathaniel Lichfield and Partners (for site owner) consider there is insufficient evidence for the deviation downwards from the WG projection.

f) Harmers Ltd for Redrow consider that there is insufficient justification for the deviation from the WG projection.

g) Asbri Planning (for site owner) consider that the Preferred Strategy growth option is not appropriate as the deviation from WG projection has not been justified.

h) Harmers agree that it is advisable to wait for publication of the WG 2011 projections and reserve the right to comment further at the Deposit Plan stage when more up to date projections will be available.

i) Sainsbury supports the intention to use 2011 base set of population and household projections.

j) Urban Style Land welcome the recognition that the projected housing figures could change.

k) Nathaniel Lichfield (for site owner) perceive that there is no evidence that the social impacts of undersupply (particularly in relation to affordable housing) have been considered.

l) Savills for St Modwen Development Ltd consider the level of housing growth is much too high.

m) WG and HBF state that allocations should include a 10% flexibility allowance.

n) Nathaniel Lichfield (for site owner) consider the housing requirement is too low and inconsistent with the strategic objectives of the Plan for economic growth.

o) Nathaniel Lichfield (for site owner perceives) there is not a robust alignment between the housing and employment assessments.


p) Nathaniel Lichfield (for site owner) perceive that there has been limited consideration of regional issues.

q) Urban Style Land consider the growth projections and subsequent strategy adopted will not provide sufficient economies of scale to meet infrastructure costs.

r) St Modwen Development Ltd are critical that the Plan forecasts the number of jobs that might be created and then works backwards to a number of homes needed to accommodate this growth.

s) HBF state that Table 7.9 in the Economic Growth Assessment is out of date.

t) Perceives that the Viability Study does not consider cumulative impacts on developers e.g. affordable housing and other planning obligations.

u) Perceives that the housing requirement within SHPZs is based on past build rates.

v) Redrow supports Candidate Site PN001, and an extension to the settlement of Pennard.

w) Query whether the reduction of empty homes has been taken into account in determining how many additional homes are required over the Plan period.

x) Harmers Ltd for Redrow are concerned about the deliverability of the Major mixed use development areas.

y) There is concern about the data used and the conclusions drawn from option 3.

z) Penllergaer Estates consider that option 2 provides a more appropriate level of growth than option 3.

aa) WG consider that the level of housing proposed to be delivered by the LDP is 4,200-4,400 short of what is required and does not reflect the economic objectives of the Plan.

ab) WG state that the Council needs to consider the implications of the 2011 Based WG Household Projections and whether it is appropriate to base future growth projections on trends covering a period of low economic performance.

ac) WG consider that the Strategic Options have inconsistent base populations.

ad) WG queries whether the assumptions used in the Council’s preferred option have been tested sufficiently.

ae) WG raise queries regarding Table 7.9 of the Economic Growth Assessment Study in terms of base population figures, household size, vacancy churn rate, and ratio of jobs to new homes required.

af) WG consider that the Plan will not provide sufficient housing numbers and that there has not been sufficient assessment of how this could impact on economic growth.


ag) The HRA Screening Report concludes that chapter 3 is screened out for further assessment because it is comprised of contextual information and will not lead to any change that could affect a European Site.

RESPONSES

a)b)c) Support welcomed.

d)e)f) Since publication of the LDP Draft Preferred Strategy, WG has released its 2011 based household projections for

g)h)i) Local Authorities in Wales. Initial analysis appears to show that the projection advocated by the Council for the City &

j)k)l) County of Swansea in the Draft Preferred Strategy is in-line with the new 2011 based WG projection (plus a 10% flexibility allowance) for the LDP period 2010-25.

m) The Council has undertaken an assessment of the WG 2011 based household projections and their implications for housing growth in the City & County of Swansea in terms of the principal projection and higher variants. The Council’s proposed strategic growth options will include the Welsh Government’s requested 10% flexibility allowance to allow for uncertainty regarding the delivery of sites and unforeseen issues.

n)o) The Plan’s economic and housing strategies are very much aligned. The Economic Growth and Employment Land Assessment has forecasted employment growth for the City & County of Swansea over the Plan period, based on an aspirational higher growth scenario, and the number of homes required to support this growth has been assessed as part of this analysis. The dwelling requirement finding from this economic growth analysis was very closely aligned with the dwelling requirement derived from the Council’s household projection advocated in the Draft Preferred Strategy.

p) In-line with National Planning Guidance, the Wales Spatial Plan and City Region context, the Council has jointly with Neath Port Talbot County Borough Council undertaken a Sub-regional Strategic Housing Market Assessment and an Economic Growth and Employment Land Assessment in recognition of the identified sub-regional geographical extent of the local housing and employment markets.

q) Assessment of the viability and deliverability of sites along with the associated requirements for essential supporting infrastructure will continue to be undertaken to inform the Deposit Plan. The strategy adopted will maximise the economies of scale that may be achieved.

r) The projection advocated for the City & County of Swansea in the Council’s Draft Preferred Strategy is based on the WG (2008 based) household projection but includes migration data for a more up to date period (2004-09),


removing the peak of internal (UK) migration observed in 2003-04 and including the on-set of the economic crisis in 2008-09. This was then validated against the PBA Economic Growth and Employment Land Assessment, in terms of the number of homes required to support forecasted economic growth, and the findings were in very close alignment.

s) 2010 data has been used in Table 7.9 to indicate the baseline year for the LDP period of 2010-25.

t) Not accepted. The Affordable Housing Viability Study follows the adopted Wales Development Appraisal Toolkit and its parameters were agreed in advance with stakeholders including the development industry. The methodology clearly shows that when assessing residual site value (the difference between scheme revenue and scheme costs including provision for a reasonable developer profit), allowance is made for Section 106 and Community Infrastructure Levy contributions as well as affordable housing provision in order to determine whether a site is likely to be brought forward for housing. The cumulative impact of costs for specific development proposals and of developments within the wider area, are taken into consideration within the Study.

u) The housing requirement has been determined by a Strategic Housing Market Assessment (SHMA) undertaken by an independent consultant, Opinion Research Services. The SHMA has combined evidence from both recent house building trends and also likely future land availability to apportion housing requirements to the sub-areas of the City & County.

v) The assessment of Candidate Sites is ongoing to inform the Deposit Plan, as is the examination of settlement capacity to accommodate further sustainable and appropriate growth.

w) The Preferred Strategy has sought to identify the number of dwellings required to accommodate the projected number of new households. However, in setting out how the Preferred Strategy’s identified requirement will be met, the Deposit Plan will include an anticipated contribution from the reduction of voids as has been the case in the adopted UDP. The PDL Capacity Study includes an estimate of the number of homes expected to be brought back into occupation by Council/other initiatives per annum over the Plan Period.

x) Assessment of the viability and deliverability of sites along with the associated requirements for essential supporting infrastructure will continue to be undertaken to inform the Deposit Plan.

y)z) The Option proposed in the Draft Preferred Strategy was assessed to be the most robust, up to date and sustainable for the City & County. It was based on the WG (2008 based) household projection but included more up to date migration data and the on-set of the economic crisis in 2008-09. It was validated against, and in-line with, the findings of the Economic Growth Assessment Study regarding the number of homes required to support the


forecasted higher policy based scenario for jobs growth over the Plan period (which reflected the economic objectives of the LDP and Swansea’s City Region role). The Option was also tested against the economic, environmental and social objectives of the LDP and through a Sustainability Appraisal

aa) The Option proposed in the Draft Preferred Strategy was assessed to be the most robust, up to date and sustainable for the City & County. It was validated against, and in-line with, the findings of the Economic Growth Assessment Study regarding the number of homes required to support the forecasted higher policy based scenario for jobs growth over the Plan period (which reflected the economic objectives of the LDP and Swansea’s City Region role).

Since publication of the LDP Draft Preferred Strategy, WG has released its 2011 based household projections for Local Authorities in Wales. Initial analysis appears to show that the projection advocated by the Council for the City & County of Swansea in the Draft Preferred Strategy is in-line with the new 2011 based WG projection, plus a 10% flexibility allowance, for the LDP period 2010-25.

ab) The Council is fully aware of the WG 2011 based household projections and has undertaken an assessment of their implications for housing growth in the City & County of Swansea in terms of the principal projection and higher variants.

ac) The small difference in the base figures for both the population and household projections in Table 3 is caused by the base year in the projections being 2008, which was the base year of the Welsh Government projections used for the growth options at that time. Therefore, it is only figures for 2008 that would be the same across all the growth options. By 2010 (the LDP base year) the different assumptions have created a small divergence (which will increase over the LDP period).

ad) The Option proposed in the Draft Preferred Strategy was assessed to be the most robust, up to date and sustainable for the City & County. It was based on the WG (2008 based) household projection but included more up to date migration data and the on-set of the economic crisis in 2008-09. It was validated against, and in-line with, the findings of the Economic Growth Assessment Study regarding the number of homes required to support the forecasted higher policy based scenario for jobs growth over the Plan period (which reflected the economic objectives of the LDP and Swansea’s City Region role). The Option was also tested against the economic, environmental and social objectives of the LDP and through a Sustainability Appraisal.

ae) Comments noted. The supporting evidence has been reviewed and an in-house update of the Economic Growth Assessment Study has been undertaken using consistent data and assumptions.


af) The Option proposed in the Draft Preferred Strategy was assessed to be the most robust, up to date and sustainable for the City & County. It was based on the WG (2008 based) household projection but included more up to date migration data and the on-set of the economic crisis in 2008-09. It was validated against, and in-line with, the findings of the Economic Growth Assessment Study regarding the number of homes required to support the forecasted higher policy based scenario for jobs growth over the Plan period (which reflected the economic objectives of the LDP and Swansea’s City Region role). The Option was also tested against the economic, environmental and social objectives of the LDP and through a Sustainability Appraisal.

ag) Comments noted.


Chapter 5 : Spatial Options

General Comments

Representation Ref Representor 41760 Hazel Rosser 41866 Asbri Planning for N. Jones & Siblings (Site owners BI007 & BI009) [2113] 42235 Boyer Planning for Persimmon Homes 42261 Miss E Harry 42323 Nathaniel Lichfield and Partners for Peter Jenkins 42152 Redrow Homes 41887 Savills for St Modwen Developments Ltd 42197- 42216 Harmers Limited for Redrow Homes 41912 Llanrhidian Lower Community Council 41955 Coastal Housing Group 42221, 42222, 41874 Asbri Planning for Persimmon Homes West Wales 41894 - 41898 Dwr Cymru/Welsh Water DCWW 42122 - 42130 & Barton Wilmore on behalf of Baybrook Ltd 42001 - 42009 42036 Welsh Government Habitat Regulations Assessment Recommendation

ISSUES

a) Garden Village has prolific wildlife and is good quality grazing land.

b) Persimmon Homes support the draft Spatial Strategy. Should be a comprehensive drainage strategy and policy context for CIL particularly in respect of the Gowerton Waste Water Works Catchment.

c) Larger sites may not deliver over the Plan period due to perceived long lead in times/reliance on provision of supporting infrastructure.

d) Redrow support the Preferred Strategy but more evidence is required to demonstrate that the MUMDA sites are deliverable within the LDP period.

e) Support Options 1 and 2.

f) Persimmon Homes consider that options 3 and 4 will not achieve LDP objectives relating to meeting local needs.

g) UDP protection policies should be strengthened in the LDP.

h) Assessment of the viability and deliverability of sites will be essential.

i) Llanrhidian Community Council wish to see a Policy context in the AONB that will ensure there is a presumption in favour of granting planning permission to the children of farmers who submit appropriate and acceptable building plans.


j) Private sector involvement will be key to the identified major regeneration schemes.

k) DCWW have noted the Council’s proposed Spatial Strategy and will continue to engage in the LDP process on proposed site locations, boundaries, uses and sizes in respect of water supply/drainage and strategic infrastructure passing through sites.

l) Baybrook Wilmore advocate Option 2 as the most sustainable.

m) WG require further evidence to demonstrate how the Council’s ‘hybrid’ spatial option incorporates the PPW principles of sustainable development. All aspects of sustainable development should be taken into account when determining the scale and location of development and be supported by a Sustainability Appraisal/SEA, based on robust evidence. WG highlight that the Deposit Plan will need to demonstrate that an open and transparent process has been followed, clearly stating any assumptions and there relationship to the strategy/objectives in the plan.

n) WG state that the Council will need to demonstrate that all housing allocations and commitments are financially viable and deliverable within the Plan period.

o) WG state that the Plan will need to incorporate a detailed review of settlement capacity to support the proposed levels of growth.

p) WG state that commitments and allocations should be set out clearly and differentiated in the Plan.

q) The Habitat Regulations Assessment (HRA) Screening Report concludes that chapter 5 is screened out for further assessment because it is comprised of contextual information and will not lead to any change that could affect a European Site.

RESPONSES

a) Candidate Site assessments are ongoing and biodiversity considerations and the quality of agricultural land are covered in these assessments.

b) Support for the draft Preferred Strategy spatial distribution of development is welcomed. Detailed evidence on all sites’ deliverability and cumulative impacts will continue to be gathered to inform the Deposit LDP. The Council will maintain close consultation with DCWW and work with them to identify the infrastructure improvements and phasing required to support the sustainable development of sites. This will feed into an infrastructure plan which will serve as part of the LDP’s evidence base and support the Council’s work on introducing a CIL.

c) The Council has indicated it proposes to follow a hybrid approach (combination of Options 2, 3, and 4) which, as assessed in the Spatial Options Topic Paper, would best meet the LDP and SA objectives. The Preferred Strategy is a strategic level document which only identifies specific options for the larger scale developments (Options 3 and 4) assessed to be


required to help Swansea meet its growth requirements. Smaller scale sites in sustainable locations throughout the City & County are also required (Option 2) in addition to the larger sites to, for example, help meet local needs and maintain a 5 year housing land supply. These will be identified in the more fine-grained Deposit Plan following the assessment of Candidate Sites against the final Preferred Strategy.

d) Support for the draft Preferred Strategy spatial distribution of development is welcomed. Detailed evidence on these sites’ deliverability and viability will continue to be gathered to inform the Deposit LDP.

e)f) The Council has set out in the Preferred Strategy and supporting Spatial Options Topic Paper that following detailed assessment of the Options, a hybrid approach of Options 2, 3 and 4 was felt to be the most sustainable and would best meet the LDP SA objectives. Pursuing Options 1 or 2 in isolation would not sustainably deliver the quantum of new housing required in the City & County over the Plan period.

g) The adopted UDP Policies will be reviewed and analysis of their effectiveness will be used to inform the LDP’s policies.

h) The Council agrees that assessment of the viability and deliverability of sites will be essential and this will continue to be undertaken to inform the Deposit Plan.

i) Policies for the LDP are being drafted for inclusion in the Deposit Plan. This work will partly be based on a review of the adopted UDP Policies and National Policy context and will consider local needs housing and succession farming requirements.

j) The Council will continue to engage with the private sector in bringing forward major regeneration schemes.

k) The Council will continue to work with DCWW to identify proposed development sites as the Candidate Site assessments progress so service requirements can be incorporated into future utility planning as early as possible and to ensure strategic infrastructure is not compromised.

l) The Council recognises the benefits of Option 2 but has assessed that this Option, alone, would not provide the scale of housing growth required in a sustainable manner (e.g. it would lead to pressure on existing infrastructure). Larger scale releases are required to provide sustainable urban extensions with supporting infrastructure.

m) The Spatial Options were individually assessed against both the LDP objectives (see the Spatial Options Topic Paper) and the SA objectives. Both assessments concluded that the hybrid approach was the most sustainable. The hybrid option proposed in the Final Preferred Strategy has now been subject to a further SA. Further evidence will be gathered relating to the assessment of settlements, and further SA assessments will be carried out to


ensure that the detailed allocation of sites for the Deposit Plan achieves the most sustainable form of development.

n) Comment noted. The Council’s site assessments of viability and deliverability are ongoing and will inform the Deposit Plan allocations.

o) Settlement capacity will be reviewed to inform the Deposit Plan.

p) Comment noted. The Council is aware that commitments and allocations should be set out clearly and differentiated in the Deposit Plan.

q) Comments noted.

Chapter 6 : Preferred Strategy

6.1 to 6.7 - Overview

Representation Ref Representor 42084 Stephen Williams

42094 Penllergaer Estates Ltd c/o Geraint John Planning Ltd

41651 Councillor Uta Clay, Llansamlet Ward

41635 Gareth & Fiona Roberts

41627 Mr & Mrs R J Smith

41662 Mrs Angela Bridges

42324, 42325, 42326 Nathaniel Lichfield and Partners for Peter Jenkins

41766 Community Land Advisory Service Wales (CLAS Cymru)

42236 Boyer Planning for Persimmon Homes

41779, 41780, 41781, Mrs Bridget Stein

41782, 41783, 41784,

41790, 41792, 41798

42131, 42132, 42133, Barton Wilmore on behalf of Baybrook Ltd

42134, 42135, 42136,

42137

41996 Mr Byron Davies AM

41888 Savills for St Modwen Developments Ltd

ISSUES

a) Barton Wilmore (on behalf of Baybrook Ltd) believe the housing requirement should be 17956 to reflect WG projections.


b) Nathaniel Lichfield and Partners (on behalf of land owner) object to housing requirement for the following reasons:

i. Requirement should be amended to at least 17,956 homes, to take account of Welsh Government (WG) household projections.

ii. Object to expression of requirement as an upper limit of a range rather than an absolute target. Consider this approach is contrary to recent MIPPS.

iii. Object to lack of flexibility allowance. Suggest at least the standard 10% allowance. Consider whether higher % is appropriate for Swansea.

iv. Concern that housing need within SHPZ’s is partly based on past build rates and may not reflect future demand accurately. WG policy encourages step change to achieve higher build rates than past completions.

c) Penllergaer estates support recognition that housing requirement cannot be met on brownfield sites only.

d) Nathaniel Lichfield and Partners support recognition that housing requirements cannot be met on brownfield only sites but consider that this has not been reflected in the spatial options for growth. Consider that more greenfield allocations will be needed in order to meet the perceived housing shortfall and provide a mix of viable and deliverable sites.

e) Persimmon homes promote the following greenfield sites to meet perceived housing shortfall: Coedwig Hywell, Penllergaer; Cwrt y Carne, Gorseinon; Bryntirion Road, Pontlliw; Glynhir Road, Pontarddulais.

f) Concern that the Plan will not provide a sufficient mix of house sizes to meet needs and further consideration to transport and accessibility required.

g) Object to a strategy which is based on the requirement for continual growth. The plan should clearly state that brownfield sites will be brought forward before greenfield sites.

h) Councillor Uta Clay considers that the Preferred Strategy should include strategic planning for the long term need for Gypsy/Traveller sites beyond the current need to find a site for 20 pitches.

i) WG state that where there is unmet need for pitches (residential and transit use), LPAs must allocate sufficient sites in their Plan to ensure these can be met.

j) Concern that there needs to be an improvement in the frequency and coverage of public transport to support development. Object to para 14 relating to provision of good public transport links. Public transport needs to be reformed to link homes with jobs that are located outside the city. Employers should be encouraged to relocate to central areas.


k) Preferred Strategy contains insufficient detail on the drainage strategy and policy context for CIL to support the level of development proposed for the Gowerton Treatment Works Catchment area.

l) Penllergaer Estates concerned that the Council’s spatial options do not accurately reflect the extent of greenfield sites that will be required to deliver the Plan’s strategy.

m) CLAS Wales support the Plan’s approach to provision of accessible natural greenspace and highlight that green space provision could be in the form of community growing spaces. Suggest that concept of community growing spaces is incorporated into the Plan’s settlement strategy for smaller settlements and into the masterplanning of growth areas.

n) Query whether Clyne Valley has been identified as a green area.

o) Byron Davies AM supports the principle of having fewer larger scale developments, but concern that Gowerton/Waunarlwydd areas will need vast improvements to sewerage system before any further housing is built.

p) Byron Davies AM has concern over the impact on infrastructure of the proposal to develop 4770 homes in the Greater North West SHPZ. Query whether there will be planning gains other than the new school planned for Pontarddulais.

q) St Modwen Developments Ltd has concern that plan proposes unrealistic levels of housing growth. Council has no choice but to proposed growth in nearly every part of the City and County. The Preferred Strategy does not establish a sequence for the release of sites and will inflate the housing land supply requirement which could result in additional unplanned releases beyond those identified.

r) Concern over pressure on junction 47.

RESPONSES

a) Since publication of the LDP Draft Preferred Strategy, WG has released its 2011 based household projections for Local Authorities in Wales. Initial analysis appears to show that the projection advocated by the Council for the City & County of Swansea in the Draft Preferred Strategy is in-line with the new 2011 based WG projection for the LDP period 2010-25. The Council is currently updating the LDP evidence base supporting studies with the new projections

b) Objections to the Housing Requirement

i. Since publication of the LDP Draft Preferred Strategy, WG has released its 2011 based household projections for Local Authorities in Wales. Initial analysis appears to show that the projection advocated by the Council for the City & County of Swansea in the Draft Preferred Strategy is in-line with the new 2011 based WG projection for the LDP


period 2010-25. The Council is currently updating the LDP evidence base supporting studies with the new projections.

ii. As above.

iii. The Council is currently updating the LDP evidence base supporting studies with the new WG 2011 based household projections and is proposing to build a 10% flexibility allowance into the amended projections.

iv. The Strategic Housing Market Assessment has combined evidence from both recent house building trends and also likely future land availability to apportion housing requirements to the sub-areas of the City & County.

c)d) Support noted. Further details about the amount of greenfield and brownfield land that will be identified in the Plan will continue to emerge as the Candidate Site Assessment Process progresses. Discussion of the merits of individual candidate sites is not a matter for this report. Each site will be assessed accordingly through the candidate site assessment process.

e) Promotion of release of ad hoc greenfield sites in advance of adoption of the LDP on the basis that developers have options with landowners is not a coherent or sustainable approach to meeting the County’s future growth needs. It has the potential to significantly undermine the Council’s Preferred Strategy and could prejudice due consideration of the sites concerned.

f) Matters of detail such as the need for a range and mix of house sizes and types is a matter for detailed policy in the Deposit Plan. It is however already promoted through policy set out in the adopted UDP and supplementary planning guidance - ‘Places to Live: Residential Design Guide’. This guidance is not proposed to be changed through the LDP process.

g) The concept of not planning for the projected level of growth is not sustainable as it does not enable the council to plan development to support the economic and social needs of both the existing and future population. This option was not included in the Council’s assessment of strategic development options. Delivery of brownfield sites before Greenfield is favoured but cannot be a requirement as this is too inflexible.

h) Meeting the long term needs for Gypsy and Traveller sites is a matter for the Deposit Plan and should cover the period to 2025.

i) It is acknowledged that there is a deficiency in appropriate Gypsy and Traveller site provision within the County. The ongoing site search undertaken by a Member led Task and Finish Group is currently being reviewed by Scrutiny Committee the outcomes of which will inform the second part of the search focusing on privately owned land. It is anticipated that site provision can be identified through this process via the provisions of Policy HC9 (Gypsy and Traveller Caravan Sites) of the Unitary Development Plan which will cater for the immediate identified need along with the anticipated


future needs of the LDP. Should this approach prove unsuccessful, then alternative measures will have to be put in place to deliver adequate site provision.

j) The Plan’s strategy seeks to ensure that major development does not take place unless there is sufficient infrastructure to support it. With regard to the location of employment, Strategic Policies 10 and 11 seek to ensure that retail and leisure uses are focussed within the City Centre or district centres. However, some employment uses are best located out of the city centre on existing employment land. Policy 8 supports accessing employment by more sustainable transport models.

k) As part of the candidate site assessment process, the Council will continue to work together with DCWW to determine both the site specific and the cumulative impact of proposed development sites and ensure that the appropriate measures are put in place to enable development.

l) Acknowledge that the spatial options did not contain specific details of the scale and location of greenfield sites. However, this is considered to be entirely appropriate for the Preferred Strategy which is an early stage of the Plan making process. The Spatial Options are high level strategic concepts which were devised to assess the most appropriate and sustainable distribution of growth. The assessment of options was based on the evidence of development potential of brownfield sites set out in the Previously Developed Land Capacity Study. The Deposit Plan will contain more detail about the scale and location of specific allocations as this emerges through the candidate site assessment process.

m) Comments are noted and will be taken into account when drafting the detail of the Deposit Plan.

n) Clyne Valley is currently part of the Green Wedge area in the UDP. The green wedges will be subject to review and the updated boundaries will be published in the Deposit Plan.

o) With regard to strategic development the Gowerton Treatment works catchment area, DCWW have recently made significant improvements and investment at Gowerton Treatment Works, and have invested in a new hydraulic model for the Gowerton catchment. The findings of which have indicated solutions throughout the catchment and these would have to be delivered prior to development occurring. As part of their interaction with the Memorandum of Understanding they are undertaking surface water removal within the Gowerton catchment within the existing Asset Management Plan (2010-2015) and will continue with further work in their next Asset Management Plan (2015-2020). This work will help alleviate flooding in the catchment as well as reducing the number of spills to estuarial waters. Furthermore, The LDP will ensure that developments will be encouraged to utilise sustainable principles in the design of buildings, promote sustainable drainage systems where ground conditions allow minimising


surface water run-off and flooding, and provide positive contributions to tackling climate change.

p) Chapter 5 of the Preferred Strategy sets out how the Council assessed the strategic options for the distribution of development. The impact of development on both social and physical infrastructure was a key part of this assessment. As a result the Plan contains a number of strategic objectives and policies which seek to ensure that all new development will be supported by the community facilities, utilities and transport necessary to enable sustainable, inclusive neighbourhoods. The impact of development on infrastructure and the collection of data about local capacities is a key part of the candidate site assessment methodology. This process is ongoing and will inform the selection of allocations for the Deposit Plan. Where development is proposed on a Strategic scale, the LPA will work with developers and landowners to draw up a detailed masterplan. This will include consideration of the contributions required towards the necessary infrastructure and facilities.

q) The levels of housing growth identified are considered to be sound and are supported by the Welsh Government, independent assessments and the Council’s own population, household and economic growth projections. Housing growth is proposed in every part of County. Phasing of release of housing sites could potentially unnecessarily restrict supply. Whilst this is a matter of detail for Deposit Stage, release of any site is likely to be dependent upon securing sufficient infrastructure capacity to meet current and future needs arising from the development. The Preferred Strategy does not identify all proposed housing sites. Further sites will be identified in the Deposit Plan to meet future needs and this provision will include the Welsh Government’s requested 10% flexibility allowance to allow for uncertainty regarding the delivery of sites and unforeseen issues.

r) The Strategic Transport Assessment will assess the impact of the LDP strategic sites on the transport network. It will include detailed junction analysis that will determine the likely impact on junction 47 and consider potential mitigation measures where necessary.

Paragraphs 6.8 to 6.13 - Housing Supply


41956, 41958 Coastal Housing Group

42225, 42226, 42227, Asbri Planning on behalf of Persimmon Homes West Wales [2113]

42228, 42223, 42224 (Site promoters MR001)

42138, 42139, 42140, Barton Wilmore on behalf of Baybrook Ltd


42141, 42142, 42143


ISSUES

a) Barton Wilmore on behalf of Baybrook Ltd consider that the paragraphs do not set out how the housing supply and amount of development on greenfield land has been calculated.

b) Coastal Housing Group consider that the sites with planning permission but which have not been built should be made known to RSL’s to try to take forward with the site applicants.

c) Coastal housing Group has stated that dwelling sizes need to be flexible to respond to changing government policies such as bedroom tax.

d) Asbri Planning consider that there is no guarantee that the 1915 units that are proposed to be delivered through the LDP from long standing commitments/constrained sites that have failed to be delivered through the current UDP will emerge through the LDP process. More sites should be allocated where there is more demand.

e) WG state that the Council will need to demonstrate a five year housing land supply from adoption of the Plan.

RESPONSES

a) Para 6.8 states that details of how figures have been calculated are set out in supporting background documents and assessments. Such level of detail is inappropriate for inclusion in the Preferred Strategy which only contains the headline figures. Similar principles will apply to the eventual LDP document with the detailed background evidence to explain relevant facts and figures set out in supporting documents and clearly cross-referenced.

b) Details of all sites with planning permission and undeveloped allocated UDP sites are included in the annual Joint Housing Land Availability Study (JHLAS) Site Schedule. All RSL’s are members of the JHLAS Group and the Study findings are published online.

c) The need for a range and mix of house sizes and types is a matter for detailed policy in the Deposit Plan. It is however already promoted through policy set out in the adopted UDP and supplementary planning guidance - ‘Places to Live: Residential Design Guide’. This guidance is not proposed to be changed through the LDP process.

d) The Previously Developed Land Capacity Study informed by the Candidate Site Assessment process has re-considered the viability and deliverability of all long standing housing site commitments and this has seen the number of such sites reduce by 50%. There are no constraints to the deliverability of


those proposed for inclusion in the LDP. There is demand for housing in all areas and sites have been identified for release in all areas. The larger releases are in areas where demand is greatest.

e) Comment noted. The Council is aware of its responsibility in-line with national planning guidance. Assessments of site deliverability will inform the Deposit Plan.

6.14 to 6.22 - Sustainable Growth Strategy Representation Ref Representor 41899 Dwr Cymru/Welsh Water DCWW 41959, 41957 Coastal Housing Group 41785, 41786, 41787 Mrs Bridget Stein ISSUES a) Support from DCWW for the Plan’s emphasis at Para 6.16.on ensuring that developments are supported by the appropriate physical infrastructure.

b) Concern as to whether the provision of infrastructure will have an impact on the existing character of an area, particularly where remoteness or lack of street lighting etc forms part of the character.

c) Coastal Housing Group has concern that introduction of CIL as referred to in para 6.17 will place too many costs on developers and result in making schemes unviable.

d) Coastal Housing Group considers that the detail regarding housing size at para 6.19 does not specify what proportion of the two bedroom units are to be houses.

RESPONSES

a) Support is welcomed.

b) Paragraph 6.16 is intended to convey the Plan’s commitment to ensuring that all new development does not have a detrimental impact on local communities by providing new or improved infrastructure. It is not the Plan’s intention to provide infrastructure which would have a detrimental impact on the character of a local area.

c) The purpose of CIL is to set a charge which is founded on robust evidence of viability. As part of the process of setting the charge, the Council will need to gather evidence about all other likely sources of development costs and requirements for financial contributions and set the levy at a viable level.


d) Table 6.1 is derived from the Swansea Bay Local Housing Market Assessment. The study did not provide this level of detail about house type and is a level of detail which it is unnecessary to specify in the LDP.

Paragraphs 6.23 to 6.32 - Greater North West Swanse a

General Comments

Representation Representor Reference 41946 RPS Planning & Development 41881 Sustrans Cymru 41623 S Hudson 41652 Mrs R Nicholas 41621 Mrs K Hudson ISSUES

a) RPS Planning & Development support the proposal for settlement growth in the Greater North West Swansea Zone.

b) Sustrans Cymru suggest the following text is added to 6.28 to 'Opportunities for sustainable travel, including safe, accessible and attractive walking and cycling routes must be considered as part of this assessment'.

c) The green at Llangyfelach should be retained for play use.

d) Waunarlwydd Road should be preserved. It is always possible to develop green areas but it is virtually impossible to make changes once development has taken place.

e) Are there sufficient facilities to meet the needs of all the population? Object to the consideration of Candidate Site LF0013 (y Llwyni, Llangyfelach).

RESPONSES

a) Support welcomed.

b) Agree proposed amendment would improve the clarity of the document. At end of penultimate sentence of 6.28 add “including safe, accessible and attractive walking and cycling routes”.

c) The assessment of the Candidate Sites is an ongoing exercise and detailed objections relating to individual sites will be considered as part of the appraisal to ascertain whether an allocation in the Deposit Plan is appropriate. A decision on whether to allocate sites that currently provide areas of open space or amenity for communities will have full regard to the requirements of TAN16 and other LDP policies that will set a standard for open space provision and seek to improve access to green infrastructure more broadly.


d) Sites with development potential and sites other than Candidate Site submissions (inclusive of settlement refinements) are in the process of being considered and will inform the Pre Deposit Plan which is due to be published during the latter part of 2014.

e) In defining land for development within the LDP full regard must be given to the Open Space Assessment that provides a full account of whether there is a surplus or deficiency in Fields in Trust (formal) provision or Accessible Natural Greenspace. In areas of limited open space, it is important that the creation of new open spaces is encouraged within developments and that existing spaces are retained and improved where possible. Valuable existing facilities should be protected whilst the provision of new and improved open spaces should be facilitated. In addition, where there are examples of deficiencies within wards opportunities may exist in improving the quality and accessibility of provision which may include investment in drainage or social infrastructure.

Felindre

Representation Representor Reference 41658 Philip Ronald Crayford 41653 Gareth Watson 41960, 41961 Coastal Housing Group 42051, 42292 D Brown 41900 Dwr Cymru/Welsh Water (DCWW) 42171 Llangyfelach Community Council (LCC) Habitat Regulations Assessment Recommendation

ISSUES

a) LCC has no objection to the proposed residential site as Felindre.

b) LCC state that the identified site known as Felindre sits in the community of Llangyfelach and should be renamed accordingly.

c) The site known as Felindre should be renamed.

d) LCC require substantial screening of any new development.

e) LCC consider that access to the site by public transport is poor and will have to be delivered as part of the development, as well as cycle paths & footpaths.

f) LCC consider that substantial investment would be needed at the site to support new development, and provide facilities that could also be used by existing residents of Llangyfelach.

g) Approach roads to the site are busy with hospital emergency access DVLA etc. and around 1500 more cars would put too much pressure.


h) Passenger rail improvements should be considered.

i) LCC consider that the sewerage capacity issues need to be addressed.

j) The Sewerage Pumping Station on the Felindre site has a restriction of accommodating foul flows of no more than 39 l/s, which DCWW believe would be sufficient to accommodate 1,000 new homes and associated facilities.

k) Coastal Housing Group consider that regard must be had to the impact on the Welsh language in Felindre.

l) The Felindre proposal is an example of expansionism as opposed to the regeneration that is proffered, which would be at detrimental cost to the environment.

m) The HRA concludes that provided the recommended amendments to Policy 12 Tourism are implemented the likely significant effect relates to waste water only.

RESPONSES a) Support welcomed.

b)c) Accept that the site lies outside the established community of Felindre and that it should be promoted with a fresh identity to distinguish itself as a new place and distinctive neighbourhood within Swansea. Amend all references to refer to land north of J46 of the M4 at Llangyfelach.

d) Screening will be considered as part of the master planning of the site.

e) Agree that the site by its very nature as an undeveloped area beyond the settlement limit lacks any established networks for public transport provision and walking and cycling routes. The masterplanning process will need to address this as a fundamental ingredient of creating a sustainable place.

f) Agree that the investment required to deliver the site is very significant and that new facilities to be created can be for the benefit of existing communities within Llangyfelach, which will be subject to detailed appraisals of need and deficiencies.

g) The proposals will be subject to a localised transport assessment to consider the impact of proposals upon the road network, which will clarify the extent of any mitigation measures required to ameliorate any adverse impact. In addition the Council intends to carry out a strategic transport study to consider the in combination effects of all significant development proposals set out in the Preferred Strategy.

h) The prospects for delivering a new rail station and opening up the existing freight line for passenger travel will need to be fully assessed by the site proposer to demonstrate that this option has been seriously investigated for its viability, including an appraisal of all potential investment mechanisms available to fund such significant physical infrastructure works.


i)j) Comments with regard to Felindre pumping station are noted.

k) The revised Technical Advice Note 20 (Planning and the Welsh Language) states clearly that the Welsh language should be considered during the production of LDPs, as part of the Sustainability Appraisal (SA) process, where local planning authorities have identified the language as being of importance. This process ensures that the Welsh language can be embedded into the LDP ensuring that all subsequent policies, proposals and eventual site allocations will have considered the impacts on the Welsh language. From a Swansea perspective, SA Objective 6 tests whether the Plan encourages an inclusive society and promotes equality (incorporating the Welsh language) whilst the specific LDP Objectives established seek to reduce the impacts of new development on communities where the Welsh language forms part of the social fabric. This means that the LDP must provide for sustainable development by protecting, and where possible enhancing, the cultural environment whilst facilitating sustainable economic growth and ensuring that all new development is supported by appropriate physical and social infrastructure. Furthermore, the Spatial Options Assessment Topic Paper concluded that whilst the scale of growth proposed had the potential to put pressure on the capacity of social infrastructure, including the Welsh language, the opportunity to masterplan sites would bring positive benefits by ensuring that the Council is able to achieve the objectives of planning for sustainable, distinct communities. An updated assessment of the importance of the language within a Swansea context along with the consideration of the potential effect of developments upon the language is currently underway and will inform the production of the Pre Deposit Plan. This will be undertaken in the full knowledge of further practical guidance developed for local planning authorities to assist them with assessing the potential impacts of the LDP proposals on the Welsh language (via the SA) recently published by the Welsh Government, the provisions of which will be fully taken into account.

l) Disagree. The proposal offers an excellent opportunity to deliver an exemplar development that creates a new quality neighbourhood that will complement the employment land proposed at the former steelworks site. In regeneration terms it can play an important role in the economic growth strategy for not only Swansea but the wider City Region.

m) Comments noted and will be taken into consideration in the preparation of the final Preferred Strategy and Deposit Plan.

Garden Village

Representation Ref Representor 41762, 4163 Hazel Rosser 42255 William McCulloch & Sheila Humphries 41739 Amanda Evans


42032, 41755, 42031, Mrs Janelle Bentley 41754, 42030, 41753 41743 Alan Acott 41696 Hugh Harris 41736 J P & M D Jarrett 41725 J Silvitore 42257 Jan & Cliff Williams 41742 June Acott 41722 K A Tribbeck 41721 Kathleen Freeman 42025 Keith Morgans 41718 Kelly Williams 41746 Kerry Lewis Thomas 41709 Lauren Hassett 41729 Lillian Truelove 41712 Maria Matti 41744 Maureen Susan Evans 41726 Michael Williams 41719 Moira Williams 41730 Mr & Mrs Gordon Thomas 41715 Mr David Evans 41734 Mr Glyn Williams 41708 Mr Kieran Hassett 41710 Mr Michael Hassett 41970 Mr Owain Morgans 41705 Mr Thomas Vaughan Evans 41735 Mr W B Lewis 41693 Mr Wilf Smith 41706 Mr Williams Lloyd Francis 41728 Mrs H Hammond 41704 Mrs Alma Evans 41727 Mrs C Delve 41707 Mrs Eileen Hassett 41731 Mrs Esme Maureen Davies 41716 Mrs Lilian Herbert 41741 Mrs Patricia Evans 41732 Mrs T S Camm 41717 Mrs Wendy Evans 42023 Ms Karen Morgans 42067 Nia Morgans 41745 Nicola J Evans 41711 Paula Kelly 41720 Richard Delve 41947 RPS Planning & Development (Emma Fortune) 41713 Salam Matti 41724 Stanley Towell


42251 Susan & Frederick Walters 41714 Thomas Matti 41756 William Gethin Evans 41723 William McCulloch & Sheila Humphries 41733 Christopher Evans 41737 D Williams 41738 David Evans 41740 David Royston Davies 41757 Doreen Evans 42024 Ffion Morgans 42233 Boyer Planning for Persimmon Homes Habitat Regulations Assessment Recommendation

ISSUES

a) Boyer Planning support the Sustainable Urban Extension north of Garden Village, which could either be a small to medium scale extension or larger phased comprehensive sustainable settlement extension.

b) Garden Village should not become an extension of Blaenymaes.

c) Present traffic levels are high and it is dangerous exiting current properties. Road infrastructure could not cope with additional demand.

d) There is no school in Garden Village - children would have to walk to Kingsbridge School which is full to capacity.

e) Area is below the water table and further erosion of natural drainage will have an extremely detrimental effect on properties. The current system is old and cannot cope with heavy rain. There is already flooding to properties.

f) Urbanisation of the open countryside, destruction of green wedge and result in coalescence of communities.

g) Accept the major mixed use development proposed for the land between the A4240 and A484, but not the need to extend to Garden Village.

h) Serious concerns regarding sewerage capacity at Gowerton Sewerage Works and protection of water quality at Loughor Estuary.

i) Hospitals, health centres and surgeries are full. There are no doctors surgeries in the Kingsbridge ward nearest located in centre of Gorseinon.

j) Cumulative impact: new housing developments are currently taking place at Kingsbridge and Upper Loughor where there are approximately 300 houses being built. Furthermore there is a possible 100 houses to be built at Cae Duke.

k) Use brownfield instead of Greenfield.


l) It is understood that there is a previous legal agreement to prevent the coalescence of Garden Village and Gorseinon.

m) Garden Village has no facilities: - shops, pubs etc.

n) The loss of farmland surrounding the village would result in loss of village character.

o) Protect the environment, wildlife, hedgerows and preserve the existing open landscape, character and appearance of the countryside. It is a recognised wildlife corridor.

p) RPS Planning provide general support to paragraph 6.31 which recognises where development could occur in other settlements in the Greater North West Swansea Zone and that such development could contribute towards creating more sustainable communities.

q) The HRA findings indicate that proposed development at Garden Village may need to provide adequate mitigation measures to avoid cancel or reduce:

i. effects on the aquatic environment

ii. effects on mobile species

iii. effects from recreation

RESPONSES

a) Support noted. The assessment of the Candidate Sites is an ongoing exercise.

b) Comment noted.

c) The assessment of the Candidate Sites is an ongoing exercise which includes examining the impact on highways of any proposed development. Where the existing infrastructure is sub standard new development may provide an opportunity to improve provision and in bringing sites forward for consideration, site proposers will be expected to prove the deliverability of their proposals.

d) The assessment of the Candidate Sites is an ongoing exercise which includes examining the capacity of schools as a result of any proposed development, and whether new schools are required.

e) The assessment of the Candidate Sites is an ongoing exercise which includes examining the drainage and sewerage infrastructure of any proposed development and the capacity of existing infrastructure.

f) The assessment of the Candidate Sites is an ongoing exercise which includes an examination of existing open space provision. Any deficiencies would have to be addressed by new developments. Where the existing infrastructure is sub standard new development may provide an opportunity to improve provision.


g) Sufficient additional development land is required to meet the future population increases indicated by Welsh Government projections up to 2025.

h) The issues surrounding foul and surface water discharges from new development in the Gowerton catchment is well documented as it impacts on local shellfish waters and the Carmarthen Bay and Estuaries European Marine Sites. Key stakeholders, through a Memorandum of Understanding, are committed to working together to investigate and undertake essential improvements for safeguarding the environmental quality. Developers too, can play their part in adhering to specific policies of this Plan, in particular the removal of surface water from the public sewerage system and through the promotion of sustainable practices for their development sites. DCWW has already invested in providing ultra violet improvement at their Northumberland Sewerage Pumping Station and installed Local Authority funded phosphorous facilities at Llannant WwTW in order to facilitate existing development plans on both sides of the estuary. However, more work will be needed to limit combined sewer overflow spills and maintain an acceptable level of phosphorous discharged to the environment. Although additional phosphorous removal is planned before 31st March 2015 at Parcysplott WwTW (Carmarthen), Pontyberem WwTW, Llanelli WwTW and Gowerton WwTW in order to comply with the European Habitats Directive these improvements are not designed to provide further development capacity. The proposed level of development will necessitate phosphorous removal at additional waste water treatment works in the area in order to complete with environmental legislation. DCWW has also invested in a new hydraulic model for the Gowerton catchment. The findings of which have indicated solutions throughout the catchment and these would have to be delivered prior to development occurring. As part of DCWW interaction with the Memorandum of Understanding they are undertaking surface water removal within the Gowerton catchment within the existing Asset Management Plan (2010-2015) and will continue with further work in their next Asset Management Plan (2015-2020). This work will help alleviate flooding in the catchment as well as reducing the number of spills to estuarial waters.

i) Comment noted. The impact of multiple proposals within an area on existing social/healthcare infrastructure will be assessed during the Candidate Sites assessment. Where the existing social/healthcare infrastructure is deemed to be sub standard new development may provide an opportunity to improve provision.

j) The cumulative impact of multiple proposals within an area on existing infrastructure will be assessment during the Candidate Sites assessment. Where the existing infrastructure is deemed to be sub standard new development may provide an opportunity to improve provision and in bringing sites forward for consideration, site proposers will be expected to prove the deliverability of their proposals.

k) There is insufficient previously developed (Brownfield) land remaining to meet the future population increases indicated by Welsh Government projections


up to 2025, which necessitates the release of some Greenfield sites for development. The Preferred Strategy aims to maximise the use of previously developed ‘Brownfield’ land by accommodate approximately two thirds of the housing requirement on brownfield land and one third on ‘Greenfield’ sites.

l) The Council is unaware of a legal agreement but would welcome any further information which the Representor is able to submit.

m) The impact of proposals on existing infrastructure such as shops will be assessed during the Candidate Sites assessment. Where the existing infrastructure is deemed to be sub standard new development may provide an opportunity to improve provision in order to improve the sustainability of settlements.

n) The assessment of the Candidate Sites is an ongoing exercise which includes an examination of the impact on settlement character.

o) The candidate Site assessment process includes an examination of the ecology, ecological connectivity and green infrastructure within the area to ensure that ecological and habitat issues are considered during any assessment.

p) Support welcomed.

q) Agree to amend paragraph to refer to the requirements of the Habitats Directive in this area.

Gorseinon

Representation Ref Representor 41982, 41983, 41986, Knight Frank for Somerset Trust 41988, 41989 Habitat Regulations Assessment Recommendation

ISSUES

a) Somerset Trust propose that land at Bryn Dafydd (South of Gorseinon) should be considered further. This land was not presented as a Candidate Site submission but supportive information has been provided.

b) Somerset Trust support for Candidate Site KB005 Land at Bryn Dafydd (Hospital Road) that failed Stage 1 given that it is positioned within an area of 100% protected habitat. Further studies undertaken suggest that the land is suitable for development.

c) Somerset Trust support for Candidate Site KB008 (Stafford Common) that failed Stage 1 given that it is positioned within an area of 100% protected habitat. further studies undertaken suggest that the land is suitable for development.


d) Somerset Trust support for Candidate Site PG0012 (Mynydd Garngoch) that failed Stage 1 of the assessment. The further studies suggest that the land is suitable for development.

e) Somerset trust suggest that land to the South and West of Bryn Terrace should be considered further. This land was not presented as a Candidate Site submission but supportive information has been provided.

f) Somerset Trust support Candidate Site GO001 (Cwrt y Carne, Gorseinon). Further studies undertaken suggest that the land is suitable for development.

g) The HRA findings indicate that proposed development at Gorseinon may need to provide adequate mitigation measures to avoid cancel or reduce:




iv. effects associated with dust and particulates

v. effects from disturbance noise and lighting

RESPONSES

a)b)c) Comments noted. The assessment of Candidate Sites is currently ongoing and all representations previously made

d)e)f) have been taken into account. The Stage 1 filtering of sites was published during March 2012 whilst the outputs of the Stage 2 filtering form part of this report. Sites with development potential and sites other than Candidate Site submissions (inclusive of settlement refinements) are also in the process of being considered and will inform the Pre Deposit Plan which is due to be published during the latter part of 2014.

g) Agree to amend paragraph to refer to the requirements of the Habitats Directive in this area.

Grovesend

Representation Ref Representor 41985 Knight Frank for Somerset Trust

ISSUES

a) Somerset Trust suggests that land at Station Road, Grovesend should be considered further even though it was not presented as a Candidate Site submission.


RESPONSES a. Comments noted. Sites with development potential and sites other than Candidate Site submissions (inclusive of settlement refinements) are also in the process of being considered and will inform the Pre Deposit Plan which is due to be published during the latter part of 2014.

Gowerton/Waunarlwydd

Representation Ref Representor 41694 Mr Haydn Morgan 41987 Knight Frank for Somerset Trust 42095 Penllergaer Estates Ltd c/o Geraint John Planning Ltd 41859, 41860, 41861, Urban Style Land 41862 41829, 41830, 41831, Ms Philippa Cole for Alcoa 41832 41667 Mr John Evans 41671 Mr Mike Jones Habitat Regulations Assessment Conclusions

ISSUES

a) Promotion of land for allocation at Cefn Gorwydd Farm, off Cecil Road, Gowerton which was not submitted as a candidate site.

b) Penllergaer Estates Ltd and Urban Style Land support the identification of Gowerton as an area for growth. The later.

c) Somerset Trust promotes CO009, Mynyddd Bach-y-Glo. Additional evidence submitted to address issues relating to failure of site at Stage 1.

d) Alcoa and Urban Style Land promote Westfield park/Alcoa.

e) Promotion of GT006 for residential development.

f) Concern about the capacity of Gowerton’s transport, sewerage and social infrastructure to accommodate proposed scale of development, particularly in light of the impact of past developments.

g) The HRA findings indicate that proposed development at Gowerton/Waunarlwydd may need to provide adequate mitigation measures to avoid cancel or reduce:





iv. effects from disturbance, noise and lighting

h) The further development of Gowerton will exacerbate the infrastructure issues present.

RESPONSES a) Comments noted. The assessment of alternative development options other than those submitted as candidate sites, forms part of the Candidate Site Assessment Methodology. The Candidate Site Assessment process is currently ongoing.

b) Support welcomed.

c)d)e) The assessment of the Candidate Sites is an ongoing exercise which will take account of any additional evidence and comments submitted.

f) Concerns are noted. However, the candidate site assessment process will take into account the capacity of the social and physical infrastructure to accommodate new development and also the opportunities for development to contribute to the provision of new infrastructure and facilities including improvements to Gowerton WWTW.

g) Agree to amend paragraph to refer to the requirements of the Habitats Directive in this area.

h) The impact of proposals on existing infrastructure is pat of the Candidate Sites Assessment process. Where the existing infrastructure is deemed to be sub standard new development provides an opportunity to improve provision in order to improve the sustainability of settlements.

Loughor

Representation Ref Representor 41664 Llwchwr Town Council (42217, 42184, 42185, Harmers Limited 42186, 42187, 42188, 42189, 42190, 42191, 42192, 42193)

ISSUES

a) Llwchwr town Council object to the potential allocation of Candidate Site UL008 – Land off Borough Road.

b) Harmers limited (on behalf of land owner) support Candidate Site UL008 – Land off Borough Road.

c) Land adjoining Candidate Site KB010 should be included as an extension to KB010.


RESPONSES

a)b)c) Comments noted. The assessment of Candidate Sites is currently ongoing and all representations previously made have been taken into account. The Stage 1 filtering of sites was published during March 2012 whilst the outputs of the Stage 2 filtering form part of this report. Sites with development potential and sites other than Candidate Site submissions (inclusive of settlement refinements) are also in the process of being considered and will inform the Pre Deposit Plan which is due to be published during the latter part of 2014.

Penllergaer


42026 Mr Grant Poiner

42041 Penllergaer Community Council


41813 Gareth Wyn Jones

41875 Asbri Planning for Bellway Homes

42056 Mr Andrew Bevan for Mr Layth Jabar

42183 Mr Paul Baker

ISSUES

a) Land at Parc Mawr Farm, Penllergaer was originally proposed as a site of only 12 ha and now it is identified for 1000 houses. How has this risen so significantly?

b) The land has previously been rejected during formation of the UDP (and the Interim Housing Policy Statement) which allocated the area as green wedge.

c) Penllergaer Community Council believe that the proposed 1000 new homes can be successfully and more appropriately accommodated elsewhere. Propose Felindre as more suitable site for large sustainable village. Extended to accommodate 2,000 homes to ensure fully sustainable new community able to fund and support community facilities. And/or expand land adjacent to Tircoed to improve sustainability of existing development.

d) Penllergaer Community Council believe that the LDP has an unrealistic and over optimistic economic growth scenario and thus the need for 16,700 homes is overstated.


e) Penllergaer Community Council are concerned that the proposal will cause problems for local sewerage site – there is a lack of capacity at Gowerton Treatment works.

f) Penllegaer Community Council have existing concerns regarding current volume of traffic in Penllergaer which would be made worse through impact of large scale housing development and they remain unconvinced that a new road link would be a realistic outcome. There are already traffic pressures at M4 Junction 47 and the A4240.

g) Development would lead to the loss of important agricultural land. Parc Mawr farm is Grade 3A Agricultural land, which was a reason for refusal of a planning appeal for development in 1981, and is a well maintained busy farm.

h) Penllergaer Community Council believe the proposals would lead to significant loss of biodiversity, ecology and green infrastructure.

i) Pollution (noise & vehicle emissions) would increase in the area.

j) Penllergaer Community Council believe that the green wedge between communities would be diminished.

k) Penllergaer Community Council believe the proposals would cause problems for an already oversubscribed school.

l) Penllergaer Community Council questions whether new large primary school is desirable or appropriate and what provision will be made for secondary places?

m) Any new school in Penllergaer should be a Welsh School in order to fulfil Welsh Government aims of creating a bilingual Wales. The existing Welsh schools are already full.

n) Instances of crime likely to escalate.

o) Within the context of Penllergaer being a high ranking sustainable development area it is desirable to include small parcels of potential 'windfall' housing development via the amendment of existing settlement boundary designations such as Candidate Site PG010, Land at Keepers Lodge.

p) Penllergare Valley Woods is important as Green Infrastructure for surrounding communities and meets all criteria and objectives set out in the Preferred Strategy. Proposed future developments within Llangyfelach and Penllergaer should make provision for improved access and management of The Penllergare Valley Woods.

q) Bellway support the identification of the Penllergaer Major Mixed Use Development Area.

RESPONSES

a) A number of Candidate Sites were submitted for the Penllergaer area, which included land south of Gorseinon Road (Site Ref PG002) at 31Ha.


Subsequent analysis of the area during the formation of the Preferred Strategy highlighted the opportunity presented by the availability of further land at this location under the same ownership. This opportunity rests on the ability to deliver new infrastructure, a range of new community services and facilities, and create a high quality residential environment, all of which can be brought forward in a planned and co-ordinated manner for the benefit of existing, as well as proposed new, Penllergaer residents.

b) Acknowledge that the land has been promoted through previous development plans and adopted interim policy but was not favoured at that time. The land has been re-appraised however in the context of the most up to date evidence available regarding population growth forecasts for the County, and also having regard to the LDP Spatial Strategy that promotes the allocation of mixed use major development areas at locations offering the greatest opportunities for sustainable placemaking.

c) The proposed mixed use development areas at Felindre and Penllergaer are not considered either/or options. Both proposals are integral to the Plan strategy, in the interests of delivering development that enhances opportunities and choices for both existing and future residents at a range of destinations, at locations that will benefit from supporting facilities and infrastructure.

d) The economic growth forecasts are considered sound. Peter Brett Associates have undertaken a thorough assessment based on industry standard methodologies in order to arrive at the findings and recommendations. The consequences of failing to plan for the forecasted economic growth in line with aspirations is a failure to realise the opportunities for new jobs and investment which is vital to improve life chances for future generations.

e) The issues surrounding foul and surface water discharges from new development in the Gowerton catchment is well documented as it impacts on local shellfish waters and the Carmarthen Bay and Estuaries European Marine Sites. Key stakeholders, through a Memorandum of Understanding, are committed to working together to investigate and undertake essential improvements for safeguarding the environmental quality. Developers too, can play their part in adhering to specific policies of this Plan, in particular the removal of surface water from the public sewerage system and through the promotion of sustainable practices for their development sites. DCWW has already invested in providing ultra violet improvement at their Northumberland Sewerage Pumping Station and installed Local Authority funded phosphorous facilities at Llannant WwTW in order to facilitate existing development plans on both sides of the estuary. However, more work will be needed to limit combined sewer overflow spills and maintain an acceptable level of phosphorous discharged to the environment. Although additional phosphorous removal is planned before 31st March 2015 at Parcysplott WwTW (Carmarthen), Pontyberem WwTW, Llanelli WwTW and Gowerton WwTW in order to comply with the European Habitats Directive these improvements are not designed to provide further development capacity. The


proposed level of development will necessitate phosphorous removal at additional waste water treatment works in the area in order to complete with environmental legislation. DCWW has also invested in a new hydraulic model for the Gowerton catchment. The findings of which have indicated solutions throughout the catchment and these would have to be delivered prior to development occurring. As part of DCWW interaction with the Memorandum of Understanding they are undertaking surface water removal within the Gowerton catchment within the existing Asset Management Plan (2010-2015) and will continue with further work in their next Asset Management Plan (2015-2020). This work will help alleviate flooding in the catchment as well as reducing the number of spills to estuarial waters.

f) In order for the proposed site to be allocated in the Deposit Plan the impact of the proposals upon the highway network and levels of traffic congestion will need to be quantified, and any necessary mitigation measures identified. This will need to be addressed both within the immediate locality and also by assessing the in-combination effect of development across the wider strategic area. In addition, the transport appraisals will need to identify the means by which the site will facilitate sustainable travel choices for future residents. The Council intends to commission the strategic transport assessment, which will test the impact of the proposed new highway link from Gorseinon Road to the Llanelli Link Road. If this confirms the highway link as appropriate new infrastructure, the delivery of the road will be an unambiguous requirement for a developer to fund in association with delivering the new homes and facilities proposed.

g) The loss of the best and most versatile high grade agricultural land is an important consideration in determining land allocations across the County. Initial appraisal of the significance of the land classification has found that, having regard to the quality and supply across the wider area, this is not an overriding fundamental constraint that would preclude the designation of the site. Further detailed and up to date investigations of the quality of agricultural grade at parcels across the proposed development area are currently ongoing by the site proposer. The findings will be used to produce an assessment report on the viability/importance of land at this location for future agricultural use and the impact of the development proposals upon the sector more broadly.

h) Any significant development activity has an impact on biodiversity and ecology, however such impacts can be mitigated and moreover translated into an overall net benefit with appropriate environmental strategies and management. Whilst the proposals would lead to a reduction in the amount of undeveloped green land at this location, integral to the proposals is a green infrastructure network that would serve to increase the amount of accessible open space within the vicinity.

i) The LDP Preferred Strategy features a clear policy that states development will not be permitted where there is found to be an unacceptable adverse effect on air, noise or light pollution (Strategic Policy 14). This high level


principle will inform decisions on development proposals. Whilst it is clearly an unreasonable proposition to suggest all environmental pollution can be eliminated as this is an inherent by product of construction and development activity, however all reasonable mitigation measures would be sought through the relevant planning and legal processes to ensure such impact are kept to reasonable levels.

j) The Llan Valley green wedge forms an important role in distinguishing Penllergaer from the communities of Fforestfach and Waunarlwydd. The principle of preserving community identity will be maintained in the LDP and the new settlement boundaries will be drawn in the Deposit Plan on the basis of a thorough appraisal of the landscape character, urban limits, and defensible edges.

k) The proposals include the provision of a new primary school building within the site to replace the existing constrained facility, which would serve the existing community as well as new residents.

l) The proposed new primary school has been discussed with the Council’s education department who have confirmed that the expansion of the exiting school, or provision of a new facility, is necessary to accommodate the proposed growth in population.

m) The Council’s education department continually appraises the requirements for both English and Welsh medium education, and the most up to date data closer to the time of adoption of the LDP. This will be used to decide the medium of any new schools to support significant development areas. In the case of Penllergaer the proposed new school is to replace an existing English medium facility.

n) There is no evidence to suggest a likely causal relationship between the proposed development and an increased crime rate.

o) The proposed major mixed use development area is focused on an area of undeveloped land west of the A483 Swansea Road. There is significant physical severance between this proposed development area and land to the east of the A483 (including land subject of Candidate Site PG010, Land at Keepers Lodge), which is as a result of the road, distances and lack of linkages. As such candidate site PG010 has been assessed for its suitability on its own merits and as a further extension of the settlement boundary at Parc Penllergaer, rather than as forming part of the proposed major mixed use development area south of Gorseinon Road.

p) Penllergare Valley Woods is considered a high quality recreational and amenity resource for not only the communities of Penllergaer and Llangyfelach but for residents and visitors across the County and wider afield. Its value is recognised in the LDP Topic Paper Natural heritage and Countryside. Agree that opportunities to deliver improvements to the accessibility of this resource, as well as its management and overall enhancement should be facilitated through the development process.


q) Support noted.

Penyrheol

Representation Ref Representor 41703 Gorseinon Town Council

ISSUES

a) Gorseinon Town Council consider that Candidate Site PY004 – Gower View Road allocation should include reference to requirement for s106 agreement to upgrade existing and provide new community facilities, particularly need for community hall.

b) Gorseinon Town Council consider that the site north of Garden Village should specify whether it will be an extension of Garden Village, or site linked via a new access to Gorseinon. Concern new linkage would create "rat run".

c) Gorseinon town Council request a meeting with officers to discuss new shopping centre boundary for Gorseinon.

d) Gorseinon Town Council has major concerns about the state of the waterlogged cemetery extension at Kingsbridge. Strongly recommended that the allocated new site at Penyrheol (adj Toyoda Goshei) utilised asap as replacement cemetery.

e) Gorseinon Town Council offers tentative support for concept of link road from Gorseinon Road Penllergaer to the Llanelli link road.

f) Gorseinon Town Council requests details of how significant drainage information in NW Swansea is to be funded.

g) Gorseinon Town Council consider that the tourism and leisure potential for Loughor estuary is not acknowledged.

RESPONSES

a)b) Comments noted. The assessment of Candidate Sites is currently ongoing and all representations previously made have been taken into account. The Stage 1 filtering of sites was published during March 2012 whilst the outputs of the Stage 2 filtering form part of this report. Sites with development potential and sites other than Candidate Site submissions (inclusive of settlement refinements) are also in the process of being considered and will inform the Pre Deposit Plan which is due to be published during the latter part of 2014. The requirement for new facilities will emerge from master planning work which will enable the delivery of new infrastructure, new community facilities and create a high quality residential environment.


c) Comments noted. The assessment of the Candidate Sites is an ongoing exercise. The Council would welcome further dialogue regarding a new shopping centre boundary for Gorseinon. Such detail will be explored during the preparation of the Deposit Draft Plan.

d) Kingsbridge still has cemetery provision available given that there remains to be unused space in sections that can be offered as new graves (although the current section (M) is now approaching capacity). Whilst it is acknowledged that Kingsbridge has poor drainage and suffers from some surface water issues during periods of heavy rain, this is common for most cemeteries the Council is responsible for. Additional drainage has been installed in Kingsbridge and further plans are in place to complete the bottom corner which should help enormously. This will also bring another section of graves into being thereby prolonging the existence of this vital community asset. The allocated Cemetery site at Penyrheol along with the Candidate Site submission for the land adjoining Morriston Crematorium are currently being assessed for their suitability to be included within the Pre Deposit Plan.

e) Comment noted. The construction of a link road is essential for the delivery of the proposals.

f) Comments noted. The issues surrounding foul and surface water discharges from new development in the Gowerton catchment is well documented as it impacts on local shellfish waters and the Carmarthen Bay and Estuaries European Marine Sites. Key stakeholders, through a Memorandum of Understanding, are committed to working together to investigate and undertake essential improvements for safeguarding the environmental quality. Developers too, can play their part in adhering to specific policies of this Plan, in particular the removal of surface water from the public sewerage system and through the promotion of sustainable practices for their development sites. DCWW has already invested in providing ultra violet improvement at their Northumberland Sewerage Pumping Station and installed Local Authority funded phosphorous facilities at Llannant WwTW in order to facilitate existing development plans on both sides of the estuary. However, more work will be needed to limit combined sewer overflow spills and maintain an acceptable level of phosphorous discharged to the environment. Although additional phosphorous removal is planned before 31st March 2015 at Parcysplott WwTW (Carmarthen), Pontyberem WwTW, Llanelli WwTW and Gowerton WwTW in order to comply with the European Habitats Directive these improvements are not designed to provide further development capacity. The proposed level of development will necessitate phosphorous removal at additional waste water treatment works in the area in order to complete with environmental legislation. DCWW has also invested in a new hydraulic model for the Gowerton catchment. The findings of which have indicated solutions throughout the catchment and these would have to be delivered prior to development occurring. As part of DCWW interaction with the Memorandum of Understanding they are undertaking surface water removal within the Gowerton catchment within the existing Asset Management Plan (2010-2015)


and will continue with further work in their next Asset Management Plan (2015-2020). This work will help alleviate flooding in the catchment as well as reducing the number of spills to estuarial waters.

g) Such level of detail is not required within the Preferred Strategy document given that it does not aim to provide a detailed account of all possible provision. In order to be consistent, to make the highlighted inclusion into the text would also require the naming of other individual areas with tourism and leisure potential which would make the sentence unwieldy. No changes are therefore proposed to the text.

Pontarddulais

Representation Ref Representor 42276 Mr Byron Davies (AM) 42327 Nathaniel Lichfield and Partners for Peter Jenkins 42033 Pontarddulais Town Council 42248 Environmental Planning 42229, 42246, 42247 Boyer Planning for Persimmon Homes 41638 Mrs Gwenda Miles Habitat Regulations Assessment Recommendation

ISSUES

a) Request the inclusion of land to the rear of Highland Terrace into the LDP.

b) Nathaniel Lichfield and Partners (on behalf of the land owner) support the further development of Pontarddulais in particular Candidate Site PT011 – Glanffrwd Road.

c) Persimmon Homes support the allocation of PT012 – Glynhir Road in the Deposit Plan.

d) Environmental Planning supports the development of Pontarddulais North in particular Candidate Sites PT007 – Land off Ty’n y Bonau Road, PT008 – Land adjacent to Ty’n y Bonau Road, PT009 – Land off west side of Glynhir Road and PT011 – Land off Glanffrwd Road.

e) Byron Davies (AM) objects to the further development of Pontarddulais given that there are still unimplemented planning consents and to the fact that the further development of the town could have an adverse effect on the Welsh Language.

f) Pontarddulais town Council consider that any proposed large scale housing development in the area should have regard to the existing infrastructure which would require upgrading and enhancing whilst any future housing


development needs to have a mix of housing types to include bungalows and affordable housing.

g) The HRA concludes that there will be no likely significant effects providing Llanant Treatment works are utilised and the recommended changes to Policy 12 Tourism are implemented.

RESPONSES


d) have been taken into account. The Stage 1 filtering of sites was published during March 2012 whilst the outputs of the Stage 2 filtering form part of this report. Sites with development potential and sites other than Candidate Site submissions (inclusive of settlement refinements) are also in the process of being considered and will inform the Pre Deposit Plan which is due to be published during the latter part of 2014.

e) Whilst it is acknowledged that there are some unimplemented planning consents and indeed allocations within Pontarddulais it remains a fact that sufficient additional development land is required to meet the future population increases indicated by Welsh Government projections up to 2025. The revised Technical Advice Note 20 (Planning and the Welsh Language) states clearly that the Welsh language should be considered during the production of LDPs, as part of the Sustainability Appraisal (SA) process, where local planning authorities have identified the language as being of importance. This process ensures that the Welsh language can be embedded into the LDP ensuring that all subsequent policies, proposals and eventual site allocations will have considered the impacts on the Welsh language. From a Swansea perspective, SA Objective 6 tests whether the Plan encourages an inclusive society and promotes equality (incorporating the Welsh language) whilst the specific LDP Objectives established seek to reduce the impacts of new development on communities where the Welsh language forms part of the social fabric. This means that the LDP must provide for sustainable development by protecting, and where possible enhancing, the cultural environment whilst facilitating sustainable economic growth and ensuring that all new development is supported by appropriate physical and social infrastructure. Furthermore, the Spatial Options Assessment Topic Paper concluded that whilst the scale of growth proposed had the potential to put pressure on the capacity of social infrastructure, including the Welsh language, the opportunity to masterplan sites would bring positive benefits by ensuring that the Council is able to achieve the objectives of planning for sustainable, distinct communities. An updated assessment of the importance of the language within a Swansea context along with the consideration of the potential effect of developments upon the language is currently underway and will inform the production of the Pre Deposit Plan. This will be undertaken in the full knowledge of further practical guidance


developed for local planning authorities to assist them with assessing the potential impacts of the LDP proposals on the Welsh language (via the SA) recently published by the Welsh Government, the provisions of which will be fully taken into account.

f) In identifying land for development within the Plan, the Planning Policy Team will test the deliverability of such proposals (inclusive of infrastructure provision). Where the existing infrastructure is sub standard new development may provide an opportunity to improve provision and in bringing sites forward for consideration, site proposers will be expected to prove the delivery of their proposals.

g) Comments noted and will be taken into consideration in the Final Preferred Strategy and Deposit Plan.

Pontlliw

Representation Ref Representor 42232 Boyer Planning for Persimmon Homes 41947 RPS Planning & Development

ISSUES

a) Persimmon Homes support the inclusion of Candidate Site LF002 – Land at Bryn Tirion Road, Pontlliw.

b) General support is given by RPS Planning to paragraph 6.31 which recognises where development could occur in other settlements in the Greater North West Swansea Zone and that such development could contribute towards creating more sustainable communities. However, consider that Pontlliw should be referred to in this context with residential development of the Poplars site not extending the physical built up settlement boundaries further south but instead rounding off the village in this location.

RESPONSES

a) Comments noted. The assessment of Candidate Sites is currently ongoing and all representations previously made have been taken into account. The Stage 1 filtering of sites was published during March 2012 whilst the outputs of the Stage 2 filtering form part of this report. Sites with development potential and sites other than Candidate Site submissions (inclusive of settlement refinements) are also in the process of being considered and will inform the Pre Deposit Plan which is due to be published during the latter part of 2014.

b) Support noted. Amend Paragraph 6.32 to clarify that, small scale allocations at settlement edges (rounding off and/or fulfilment of suitable UDP sites) will also contribute to the overall housing figures.


Paragraphs 6.33 to 6.36 - North Swansea

General Comments

Representation Ref Representor 41882 Sustrans Cymru

ISSUES

a) Sustrans suggest an addition to the text to end of Paragraph 6.34 to read "Providing safe, accessible and attractive walking and cycling linkages and facilities at these destinations will ensure these facilities offer genuine sustainable travel options."

RESPONSES

a) Agree that proposed change would improve the clarity of the document. Amend to add suggested text to the end of the paragraph.

Morriston

Representation Ref Representor 42218 Asbri Planning for Persimmon West Wales 41683 White Young Green for ABMU Health Board 41691, 41686 Jason Evans Planning 41678 CDN Planning (Wales) Ltd 41645, 41663 Mrs Theresa Lane 41644 U Lane Habitat Regulations Assessment Recommendation

ISSUES

a) Jason Evans Planning supports Candidate Site MB005 (Land off Clasemont Road) as a Sustainable Urban Extension for residential development.

b) Persimmon Homes promote Candidate Site MR001 (land at Gwernfadog) and consider that it should be allocated in accordance with the proposal to promote development in the Cwmrhydyceirw area.

c) ABMU Health Board, Jason Evans Planning, and CDN Planning support the proposals for development at Pantlassau on land adjacent to Morriston Hospital, in particular residential uses and additional healthcare provision.


d) Objection to development along Pantlassau Road. Development would generate an increase in traffic on Pontlassau Road which is already very congested tailbacks at peak times that causes a bottleneck at Clasemont Road, and exacerbate problems with surface water resulting in flooding for these houses. It would also lead to a loss of agricultural land and adversely impact on biodiversity.

e) Allocations should be restricted to brownfield sites and the redevelopment of vacant properties.

f) The HRA concludes that providing the recommended changes are made to Policy 12 Tourism there will be no likely significant effects.

RESPONSES

a)b) Comments noted. The assessment of Candidate Sites is currently ongoing and all representations previously made have been taken into account. The Stage 1 filtering of sites was published during March 2012 whilst the outputs of the Stage 2 filtering form part of this report. Sites with development potential and sites other than Candidate Site submissions (inclusive of settlement refinements) are also in the process of being considered and will inform the Pre Deposit Plan which is due to be published during the latter part of 2014.

c)d) The Preferred Strategy identifies Cwmrhydyceirw/Pantlassau as a potential area for small scale development and refers specifically to the land in the vicinity of Morriston Hospital for potential. The final Preferred Strategy will confirm this position and clarify that land will be designated for health related uses to support appropriate levels of expansion of the hospital complex. Any allocation will emphasise the requirement for development proposals to fully assess, and mitigate against, any adverse impact upon the transport network. The specific location, size and delineation of any such allocation will be based upon appraisals of site specific issues and constraints, including those relating to flood risk and biodiversity.

e) The urban capacity assessment that underpins the Preferred Strategy makes clear that there is insufficient appropriate brownfield land available to accommodate the scale of housebuilding that is required to support the forecasted level of growth. A brownfield only strategy would therefore be found unsound by the Planning Inspectorate (as it has done so elsewhere in Wales) who as a result would not permit the LDP to be adopted.

f) Comments noted and will be taken into consideration for final Preferred Strategy and the Deposit Plan.

Paragraphs 6.37 to 6.40 - East Swansea


SA1

Representation Ref Representor 42178 RPS Planning & Development for Associated British Ports (ABP) [1878] 41962 Coastal Housing Group 41618 W H & E J Beynon 41650 Hilary & Tom Jenkins Habitat Regulations Assessment Recommendation

ISSUES

a) ABP consider that the statement that the 4,350 homes required in East Swansea will include existing strategic housing schemes at SA1 is questioned. Would suggest, in terms of SA1, that the proposed housing is limited to existing commitments within that development and that there is no further encroachment of residential uses towards the operational docks. Not clear from Preferred Strategy whether all required 4,350 homes are provided for and where they will be located, however, ABP consider that a flexible masterplan for its landholding could contribute positively to help meet this housing target.

b) Coastal Housing Group consider that the Preferred Strategy should make it clear that the Morfa site be developed with a greater emphasis on sports and leisure to help shift retail back to the city centre.

c) Land at Brokesby Road West (Candidate Site BM021) should be retained as an area of open space for play.

d) A perceived inaccuracy with the naming of a couple of UDP allocations. HC1(6) should be referred to as Lon Las rather than Birchgrove whilst HC1(11) should be referred to as Peniel Green rather than Lon Las.

e) The HRA concludes that if the green field releases to the north east of Bonymaen (paragraph 6.39 refers) are accessed off Bog Road (which runs within 200m of Crymlyn Bog SAC) this could lead to likely significant effects in relation to air pollution. It is recommended that paragraph 6.39 clarifies that the site will be served by Cefn Hengoed Road and Carmel Road.

f) The HRA findings indicate that proposed development at North East Bonymaen may need to provide adequate mitigation measures to avoid cancel or reduce effects on the aquatic environment. Development for the land south of Fabian Way may need to provide adequate mitigation measures to avoid or reduce the effects of air pollution however, a precise boundary for the employment site will need to be provided in order for it to be fully assessed (refer to HRA response to Policy 9 Economic Growth and Employment).


RESPONSES

a) The Council is working with the Candidate Site submitters in the area between the Docks/Langdon Road and the new University Campus south of Fabian Way to agree a parcel plan to guide the regeneration of this area. This work is taking place within the wider context of the masterplanning of the Fabian Way Corridor with Neath Port Talbot Council.

b) Agree that clarifying the nature of retailing at this location would help to emphasise the Council’s priority focus upon the City Centre. Amend paragraph accordingly.

c) Individual sites of non-strategic scale are not defined as allocations in the Preferred Strategy. A decision on whether to allocate site BM021 in the Deposit Plan will have full regard to the characteristics of the site and its surroundings. The appraisal will consider the appropriateness of a designation as amenity space/open space. It will also consider the requirements of TAN16 and other LDP policies that will set a standard for open space provision and seek to improve access to green infrastructure more broadly.

d) The UDP is an adopted document and such the suggested amendments cannot be implemented. Should the sites proceed to the Deposit Local Development Plan then their naming can be revisited at that point.

e) Comments noted. This detail will be included in the Deposit Plan. It is not appropriate to refer explicitly to Cefn Hengoed Road and Carmel Road in isolation as sites served by other roads may be suitable for rounding off within Bonymaen/Llansamlet. An appropriate reference will be made within Chapter 6 of the document however to clarify that development proposals at Bonymaen (and other relevant locations) will need to avoid, cancel or reduce any adverse effects upon European Sites.

f) Comments noted and agree to amend paragraph to refer to the requirements of the Habitats Directive in this area.

Paragraphs 6.41 to 6.43 - Central Swansea

Representation Ref Representor 41699 Mr Keith Evans

ISSUES

a) Object to the inclusion of CA0013 in the proposed strategy as the site does not meet the stipulations of TAN16 regarding provision of open space.

b) The HRA concludes that providing the recommended amendments are made to Policy 12 there will be no likely significant effects as a result of allocations on Swansea water front.


RESPONSES

a) Individual sites of non-strategic scale are not defined as allocations in the Preferred Strategy. A decision on whether to allocate site CA013 in the Deposit Plan will have full regard to the characteristics of the site and its surroundings. The appraisal will consider the appropriateness of a designation as amenity space/open space. It will also consider the requirements of TAN16 and other LDP policies that will set a standard for open space provision and seek to improve access to green infrastructure more broadly.

b) Comments noted and will be taken into consideration in the final Preferred Strategy and Deposit Plan.

Paragraphs 6.44 to 6.47 - West Swansea

Representation Ref Representor 41687, 41688, 41689, Jason Evans Planning 41690 41611 Mrs Glenys Porter 41806, 41808 RPS Planning & Development for Swansea University 41682 WYG for Bro Abertawe Local Health Board (ABMU) 42045, 42046 Mrs Jill Burgess Habitat Regulations Assessment Recommendation

ISSUES

a) Jason Evans Planning urge caution in seeking the deliverability of the majority of new housing in this zone on two brownfield sites, given their ecological and transport constraints. Would support the allocation of Candidate site KN001 as does not infringe on AONB or Green Barrier illustrated in Fig 6.4.

b) Object to building on green fields at the Cefn Coed site (SK017) due to loss of green space, wildlife habitat and inadequate roads. Support the conversion of the existing hospital into homes. Please reword para 6.45 to "This could entail redevelopment of the existing buildings at Cefn Coed hospital and Hendrefoilan Student village but not building on the fields surroundings the existing buildings on those sites".

c) Swansea University supports the confirmation that Hendrefoilan Student village is a brownfield redevelopment opportunity and confirms that land is available to the north of Hendrefoilan Lane for development in conjunction with the Student Village.

d) ABMU supports the identification of Cefn Coed Hospital as a brownfield development opportunity.

e) Disagree that high value housing is being permitted in West Swansea purely as a cash generator for the provision of affordable housing elsewhere. In


recent years the Council has benefitted through S106 contributions of a number of small infill and redevelopment developments. Land in the Council ownership in Thistleboon has been disposed of in open market tender, rather than for first time buyers and low income households.

f) Unclear which zone Langland is in, it is not in par 6.44 (West Swansea) but referred to in para 6.50 as Gower Fringe.

g) Support sustainable urban extensions and Brownfield sites in West Swansea and suggest a reduction of housing provision for areas bounding on the AONB and Gower Fringe, which could be accommodated at those sites instead, rather than putting further pressure on social, medical, educational, transport, highway and public utility provision.

h) The HRA concludes that providing the recommended changes to Policy 12 Tourism are implemented the only likely significant effect for Killay north and Dunvant relates to waste water whereas for Sketty providing amendments are made to Policy 12 no likely significant effects are anticipated.

RESPONSES

a)b)c) Comment noted. Comments noted. The assessment of Candidate Sites is currently ongoing and all representations previously made have been taken into account. The Stage 1 filtering of sites was published during March 2012 whilst the outputs of the Stage 2 filtering form part of this report. Sites with development potential and sites other than Candidate Site submissions (inclusive of settlement refinements) are also in the process of being considered and will inform the Pre Deposit Plan which is due to be published during the latter part of 2014.

d) Support welcomed.

e) Comment noted. It is recognised that a shortfall of affordable housing across the County is a significant issue facing local residents at the present time, and the LDP has a key role to play in bringing forward sufficient land in appropriate locations to contribute towards meeting affordable housing needs. The delivery of more affordable housing is a strategic priority and a responsibility for the Council as a whole. The Swansea Bay Local Housing Market Assessment (2013) has identified a need for 7,100 additional affordable homes to be built over the LDP period, i.e. 44% of the total housing requirement. In aiming to deliver this target, the LDP shows a real commitment in providing sufficient affordable homes for local communities.

f) The existing built up settlement boundary of Langland lies within Swansea West Strategic Housing Policy Zone (SHPZs). However there is no capacity for any significant growth of this settlement without extending beyond the defined Gower AONB boundary. Therefore extension of Langland as envisaged in the strategy would be categorised as development within the Gower AONB. Any such development should only be as an exception to


provide affordable housing to meet local needs. This is largely a matter of detail that may only be addressed through the Deposit Plan, for example, SHPZs are ward based and make no allowance for the fact that a settlement such as Bishopston which is within the Gower Fringe SHPZ lies partly in the AONB and development would contribute either to the AONB requirement or the Gower Fringe requirement dependent upon location. Amendments to locality references in paras 6.44 and 6.50 will be made to avoid confusion. Delete ‘Dunvant, Killay North and Killay South’ and insert ‘Mumbles, Newton and West Cross’ in para 6.44. In paragraph 6.50 delete ‘Langland, Newton/West Cross, Dunvant’ and add new sentence after ‘Penclawdd/Crofty.’ ‘Whilst further contributions may arise from any outward expansion of settlement boundaries within Oystermouth, West Cross and Newton wards into the adjoining Gower Fringe areas.’

g) Support welcomed. The Swansea Bay Local Housing Market Assessment (2013) identifies the need for 1,600 homes in the West Swansea Strategic Housing Zone, 350 homes in the Gower Fringe zone and 200 homes in the Gower Zone. The volume of building cannot be increased in one zone to offset another.

h) Comments noted and will be taken into consideration in the final Preferred Strategy and Deposit Plan.

Paragraphs 6.48 to 6.52 - Gower and Gower Fringe

Representation Ref Representor 42262 Gower Society 41867, 41870 Asbri Planning for N Jones & Siblings (site owners BI007 & BI009) [2113] 42070,42071 Mrs Henderson 42010, 42011, 42012, Barton Wilmore on behalf of Baybrook Ltd 42013, 42014 41884 Mr Neil Reeve 41612 Mr Philip Morris 42254 Mr & Mrs Williams 42068 Rhossili Community Council 42050 Mrs Jill Burgess 41789 Mrs Bridget Stein 41637 Elizabeth Fussell Habitat Regulations Assessment Recommendation

ISSUES

a) The Gower Society considers that the boundary between the Gower and Gower Fringe SHPZs should be the AONB boundary.


b) The Gower Society advocates an official amendment to the AONB boundary rather than the creation of the Gower fringe SHPZ .

c) The Gower Society supports policies 12, 13, 14.

d) The Gower Society considers that the predicted housing requirement for Gower is too high and likely to be damaging for the AONB and cannot understand how such a large figure has been reached.

e) Objection to new development and any extension of existing village boundaries on Gower. There is not sufficient infrastructure provision to accommodate new development.

f) No new development within or close to the Gower AONB. This should be stated in the Gower and Gower fringe section.

g) The Gower Society has observed that an increasing number of planning applications are being approved for the demolition of small dwelling to be replaced by a much larger and more expensive property. This is contributing to a lack of affordable homes on Gower.

h) The Gower Society considers that in the Mumbles fringe area the cost of land/plots makes it impossible to provide affordable accommodation and such housing in the AONB would be visible from the coast.

i) The Gower Society considers that development of the North Gower Hotel site has not resulted in sufficient affordable housing.

j) The Gower Society considers that Gower does not need more large expensive housing. Small starter homes for local people are required. Concern expressed over keeping of such houses at a low price. Scurlage not considered suitable for affordable accommodation.

k) The Gower Society believes that Council houses on Gower are being occupied by people from Swansea. This suggests that there is not a proven local need.

l) The Gower Society considers that an Increasing number of holiday chalets, caravans and bungalows are being lived in full time. An audit of such properties is required in order to gain a true picture of housing provision on Gower.

m) The Gower Society has concern that more candidate sites on Gower have not been filtered out as many of the remaining sites are regarded as unacceptable.

n) The Gower Society considers there to be confusion over windfall sites and viable candidate sites.

o) Rhossili Community Council requires clarification on windfall sites.

p) The Gower Society is of the opinion that as a result of the selling off of farm land there has been a rise in the number of applications for new farm buildings and an increase in farm dwellings is predicted.


q) The Gower Society considers that more housing land should be allocated in the East and Greater North West SHPZs with the equivalent reduction in allocations for Gower. This would allow for better protection of the AONB.

r) Asbri Planning (for site owner) object to the housing requirement for Gower and Gower fringe zones. The housing land requirement for Gower fringe should be higher.

s) Asbri Planning (for site owner) consider that there should be more opportunities for boundary extensions where allocations would amount to less than 4ha and where the character of the existing village or settlement would be maintained or improved. This would apply to the sites being promoted, which, in combination could deliver approximately 60 dwellings at average densities.

t) The sites in Bishopston, promoted by Asbri, represent an ideal location for an edge of settlement release should any sites proposed in the Preferred Strategy not be accepted and taken forward.

u) Development on Gower should not be considered at sensitive coastal locations and greenfield areas as this could result in an urbanisation of sensitive countryside.

v) No reference to the importance of tourism and leisure for Gower. This should be recognised in the Preferred Strategy.

w) Support for candidate site FA007as it includes brownfield land in the form of farm buildings and rounds off the settlement of Three Crosses. It therefore is consistent with the Preferred Strategy.

x) Rhossili community Council consider that settlement/village boundaries would help understand the extent of development allowed.

y) Rhossili Community Council query how 100% affordable housing translate into LDP policy?

z) The HRA concludes that providing the recommended changes are made to Policy 12 there will be no likely significant effects as a result of development at Scurlage, Pennard, Bishopston and a likely significant effect in relation to waste water as a result of development at Three Crosses and Penclawdd/Crofty.

RESPONSES

a) Strategic Housing Policy Zones (SHPZs) are identified on the basis of the housing market. They are areas with similar characteristics in terms of housing type and price and provide a useful strategic planning tool for the identification of common issues affecting future housing development. The designation of such areas will not override the AONB designation.

b) Amendments to the AONB boundary is a matter for Natural Resources Wales (NRW) and is not the role of the LDP.


c) Support welcomed.

d)e)f) The LDP must provide sufficient land for development to meet the future population increases indicated by Welsh Government projections up to 2025. The predicted housing requirement for the entire plan area including Gower and Gower Fringe SHPZs and including the need for affordable housing is based on robust evidence in the from the Strategic Housing Assessments. These assessments have identified the need for 520 houses on Gower and Gower fringe during the lifetime of the Plan and provide a full explanation of how this figure was reached.

g) The lack of affordable housing is a major issue for the LDP (see Key Issues and Drivers section 2.20) and particularly so on Gower and Gower fringe. Comments noted with regard to replacement dwellings, this issue will be addressed during the review of existing UDP policy and specifically UDP Policy EV19 ‘Replacement Dwellings’.

h) LDP evidence for housing provision that takes into consideration the need for and viability of affordable housing has identified the requirement for significant affordable housing in Gower and Gower fringe including Mumbles. The LDP objectives aim to foster a high quality environment that is ‘sensitive to location’ and ‘respects environmental assets’ this is particularly relevant for coastal locations.

i) The North Gower Hotel application was determined against UDP policy. UDP policy is being reviewed as part of the LDP preparation process and will address the concerns raised in this issue. The LDP Preferred Strategy has identified the need for significant affordable housing provision on Gower (para. 6.52 refers) and this will be reflected in the detailed LDP policy.

j) The Strategic Housing Assessments indicate that there is no current need for market housing on Gower and a considerable need for affordable housing. Housing will remain affordable if developed by registered social landlords (RSL’s) otherwise applicants will be required to complete a section 106 agreement to ensure that the rent or prices for these homes are affordable and remain so in the future. Scurlage is an established settlement within a rural area and as such conforms to the proposed spatial strategy for the location of development in rural areas.

k) The allocation of Council housing is a matter for the Authority’s housing services section and not the LDP. LDP housing provision is based on sound evidence on the form of the Strategic Housing Assessments, the findings of which show a proven need for affordable housing on Gower and the Gower fringe.

l) Agree with the sentiments behind this and the need for such an audit. The Holiday Caravan Sites (Wales) Bill should assist in regulating permanent residential use of holiday units, if it becomes an Act.


m) Only stage 1 of the candidate site assessment process has been undertaken. This has excluded only sites that are unrealistic or have fundamental constraints.

n)o) Windfall sites are unallocated sites that for various reasons become available for development during the life time of the Plan. An allowance is made for such sites in calculating the overall housing land supply. Viable candidate sites are those that can realistically be developed within the Plan period. All candidate sites that become allocations must be viable.

p) Comments noted. Such proposals will need to comply with development plan policy.

q) The LDP needs to provide for a range and mix of house sizes and type across the Plan area. The Strategic Housing Assessments have identified the particular need for affordable housing in Gower and the Gower fringe that could not be meet through provision in the opposite side of the County. The housing requirement in one SHPZ cannot be offset by development in another SHPZ.

r) The requirement for Gower and Gower fringe is based on robust evidence in the form of the Strategic Housing Assessments. An explanation of how housing requirements are calculated can be found in the Housing Landbank and Previously Developed Land Capacity Study and summarised in Table 11. There should be no change to the housing requirement for Gower and Gower fringe.

s) Support welcomed. For Gower and Gower fringe the Preferred Strategy supports the allocation of sites of less than 4ha. The minimum size for candidate sites to be considered for LDP allocations is 0.4ha in urban areas and 0.2ha in rural areas. Appropriate boundary extensions of less than this size will be left as white land within a settlement.

t) Comments noted.

u) The LDP objectives aim to foster a high quality environment that is ‘sensitive to location’ and ‘respects environmental assets’ this is particularly relevant for coastal locations. The Preferred Strategy states that it is necessary to release greenfield sites for development in order to provide for the required amount of development. Evidence for this, including the Gower area, is provided in the Housing Landbank and Previously Developed Land Capacity Study and summarised in table 11 of this document.

v) Comments noted. This section is focussed on the sustainable growth strategy and the delivery of good quality housing to meet the needs of the predicted population growth. Tourism is referred to throughout the Preferred Strategy and has a specific strategic policy with supporting information.

w) Comments noted. The assessment of Candidate Sites is currently ongoing and all representations previously made are being taken into account. The Stage 1 filtering of sites was published during March 2012 whilst the outputs


of the Stage 2 filtering form part of this report. Sites with development potential and sites other than Candidate Site submissions (inclusive of settlement refinements) are also in the process of being considered and will inform the Pre Deposit Plan which is due to be published during the latter part of 2014.

x) Consideration will be given to the identification of village boundaries for the LDP.

y) The viability of affordable housing including for Gower and the Gower Fringe has been considered in depth in the City and County of Swansea Affordable Housing Viability Assessment with a full explanation of the findings and draft policies for the deposit LDP provided in the Affordable Housing Topic Paper.

z) Comments noted.

Bishopston

Representation Ref Representor 41863 Asbri Planning for N Jones & Siblings (site owners BI007 & BI009) [2113] 42250, 41700, 41701, Environmental Planning for site owners CS BI011. 41666 Habitat Regulations Assessment Recommendation

ISSUES

a) Asbri Planning on behalf of site owners promotes the candidate sites BI007 and BI009, Brandy Cove Lane.

b) Environmental Planning promotes BI002 – Land to the rear of 51b Bishopston Road, Bishopston and BI011 - Field at rear of Ridley Way, Bishopston.

c) Asbri Planning on behalf of site owners has raised an objection to Preferred Strategy for Gower and Gower Fringe Area and consider that provision for a further 200 new dwellings should be made in the Gower fringe in deposit plan.

d) Asbri Planning on behalf of site owners consider that the supporting documents contain conflicting statements re future affordable housing requirements.

e) Environmental Planning support for policy of small scale settlement boundary amendments in appropriate locations. Support allocation of sites for affordable housing but also small scale housing for elderly and quality housing, such as Candidate Site BI011.

f) Promotion of Bishopston as suitable location for allocation of medium sized sites.


g) The HRA concludes that providing the recommended changes to Policy 12 Tourism are implemented there will be no likely significant effects.

RESPONSES

a)b) Comments noted. The assessment of Candidate Sites is currently ongoing and all representations previously made are being taken into account. The Stage 1 filtering of sites was published during March 2012 whilst the outputs of the Stage 2 filtering form part of this report. Sites with development potential and sites other than Candidate Site submissions (inclusive of settlement refinements) are also in the process of being considered and will inform the Pre Deposit Plan which is due to be published during the latter part of 2014.

c) The requirement for Gower and Gower fringe is based on robust evidence in the form of the Strategic Housing Assessments. An explanation of how housing requirements are calculated can be found in Housing Land Bank and Previously Developed Land Capacity Study summarised in Table 11. There should be no change to the housing requirement for Gower and Gower fringe.

d) Bishopston ward lies within the Gower Fringe SHPZ, but the settlement of Bishopston itself lies partly in the Gower AONB and partly within the Gower Fringe. However, future affordable housing requirements are the same regardless of which Zone any specific site in the area falls under.

e)f) Bishopston is an established settlement within the Gower Fringe SHPZ. Based on the evidence base referenced above, the Preferred Strategy has established that the majority of sites in the Gower and Gower Fringe SHPZ’s should be developed for Affordable Housing to meet local needs. The level of need identified in the SHMA is over 500 homes. The distribution of housing to Bishopston will therefore take place in accordance with the Preferred Strategy for the SHPZ.

g) Comments noted and will be taken into consideration in the final Preferred Strategy and Deposit Plan.

Mumbles and Langland

Representation Ref Representor 42294, 42058, 42293, Ann Cooke 42295, 42296 42043, 42044, 42047, Mrs Jill Burgess 42048, 42049 42308, 41968 Ruki Sidhwa 42269, 42170, 42268, Oscar Chess 42270, 42271 41631 Alan Goss


41632 Veronica Horska 42273 CDN Planning (Wales) Ltd for Mumbles Community Council [14371] Habitat Regulations Assessment Recommendation

ISSUES

a) Object to plans to develop fields between Higher Lane, Langland and the Gower Coastal Path.

b) The mumbles Community Council object to new development in the fringes of Mumbles and Langland.

c) Questions whether a full study of the feasibility of potential development been undertaken with regards to increased population, environmental impact, biodiversity, drainage, traffic, congestion, parking, sustainability and spoilage of a rare landscape. If so where are the reports?

d) Strategy is unclear whether Langland is in the Gower or Gower Fringe.

e) If Langland is part of the Gower and the Gower Fringe zone then agree that no urban extensions of a strategic scale will be identified within this Zone.

f) Support two potential sustainable urban extensions at the Brownfield sites of Hendrefoilan Student Village and Cefn Coed Hospital within the Wet Swansea Zone. Infrastructure and public services in these areas are not at the same pressure as at Mumbles and Langland.

g) Agree with paragraph 6.48.

h) A combined area of 4ha in total for development is a significant size when applied to the Gower and Gower Fringe Zone which incorporates significant and justifiable constraints on development.

i) Policy of small scale infill developments over last ten years has been to the detriment of the built environment, where significant houses have been demolished and resulted in over development. This is not either maintaining or improving the existing settlement.

j) Would place strains on the sewage system and potentially increase the risk and likelihood of surface water flooding.

k) The evidence base does not recognise existing problems with infrastructure provision and deliverability and that further work will be done by the LPA between this stage and the Deposit Plan.

l) There does not appear to be any consideration of the effects upon other local services and facilities. Development of these sites would need to make substantial and early contributions to upgrade sewers and schools.

m) The mumbles Community Council has concerns about the impact of new development on the road network and pollution levels.


n) The LPA also need to consider in detail what planning obligations would be required in order for development in this area to be acceptable, for example physical infrastructure, road improvements, civil infrastructure, schools and other facilities. It is likely to be substantial and unrealistic amount and it is expected that by the time of the Deposit LDP the evidence base will future demonstrate that any development on or near this area will be unsound.

o) The HRA concludes that providing the recommended changes to Policy 12 Tourism are implemented there will be no likely significant effects.

RESPONSES

a)b) Comments noted. The assessment of Candidate Sites is currently ongoing and all representations previously made are being taken into account. The Stage 1 filtering of sites was published during March 2012 whilst the outputs of the Stage 2 filtering form part of this report. Sites with development potential and sites other than Candidate Site submissions (inclusive of settlement refinements) are also in the process of being considered and will inform the Pre Deposit Plan which is due to be published during the latter part of 2014.

c) The Candidate site process in an ongoing process. In identifying land for development within the Plan, the Planning Policy Team will test the deliverability of such proposals (inclusive of infrastructure provision). Where the existing infrastructure is sub standard new development may provide an opportunity to improve provision and in bringing sites forward for consideration, site proposers will be expected to prove the delivery of their proposals.

d)e) The existing built up settlement boundary of Langland lies within Swansea West Strategic Housing Policy Zone (SHPZs). However there is no capacity for any significant growth of this settlement without extending beyond the defined Gower AONB boundary. Therefore extension of Langland as envisaged in the strategy would be categorised as development within the Gower AONB. Any such development should only be as an exception to provide affordable housing to meet local needs. This is largely a matter of detail that may only be addressed through the Deposit Plan, for example, SHPZs are ward based and make no allowance for the fact that a settlement such as Bishopston which is within the Gower Fringe SHPZ lies partly in the AONB and development would contribute either to the AONB requirement or the Gower Fringe requirement dependent upon location. Amendments to locality references in paras 6.44 and 6.50 will be made to avoid confusion. Delete ‘Dunvant, Killay North and Killay South’ and insert ‘Mumbles, Newton and West Cross’ in para 6.44. In para 6.50 Delete ‘Langland, Newton/West Cross, Dunvant’ and add new sentence after ‘Penclawdd/Crofty.’ ‘Whilst further contributions may arise from any outward expansion of settlement boundaries within Oystermouth, West Cross and Newton wards into the adjoining Gower Fringe areas.’


f)g) Support welcomed.

h) Comment noted. Gower and Gower Fringe housing zones need to accommodate a combined total of 520 homes.

i) Comment noted with regard to infill development however it seems to relate more to the replacement of dwellings. This is a separate issue to infill development. Currently such proposals are considered under UDP policy. UDP policy will be reviewed as part of the preparation of the Deposit LDP and you concerns will be taken into consideration.

j)k)l) Comment noted. The assessment of the Candidate Sites is an ongoing exercise which includes examining the

m) drainage and sewerage infrastructure, general infrastructure, impact on the road network, impact on pollution levels, deliverability, school capacity and the need for new schools of any proposed development. The assessments are based on the evidence base which is continually being developed.

n) In identifying land for development within the Plan, the Planning Policy Team will test the deliverability of such proposals (inclusive of infrastructure provision). Where the existing infrastructure is sub standard new development may provide an opportunity to improve provision through planning obligations and in bringing sites forward for consideration, site proposers will be expected to prove the delivery of their proposals.

o) Comments noted and will be taken into consideration in the final Preferred Strategy and Deposit Plan.

Newton

Representation Ref Representor 41992 Mr & Mrs MaCartney Habitat Regulations Assessment Recommendation

ISSUES a) Objects to Paragraph 6.44 of the Preferred Strategy in particular the growth of the Newton area. Concerns highlighted include: Primary School capacity, road infrastructure, drainage capacity, positioned within the AONB.

b) The HRA concludes that providing the recommended changes are made to Policy 12 Tourism there will be no likely significant effects.

RESPONSES

a) Comments noted. The assessment of Candidate Sites is currently ongoing and all representations previously made have been taken into account. The Stage 1 filtering of sites was published during March 2012 whilst the outputs


of the Stage 2 filtering form part of this report. Sites with development potential and sites other than Candidate Site submissions (inclusive of settlement refinements) are also in the process of being considered and will inform the Pre Deposit Plan which is due to be published during the latter part of 2014.

b) Comments noted and will be taken into consideration in the final Preferred Strategy and Deposit Plan

Penclawdd

Representation Ref Representor 41660 Councillor Mark Thomas, Penclawdd Ward Habitat Regulations Assessment Recommendation

ISSUES

a) Councillor Mark Thomas considers that existing brownfield sites within the village of Penclawdd (Swn Y Mor, ‘The Old Colliery’ and Crofty Industrial Estate) should be utilised prior to considering greenfield sites. This would remove some eyesores within the ward plus reduce possible local resistance to development.

b) The HRA findings indicate that proposed development at Penclawdd/Crofty may need to provide adequate mitigation measures to avoid cancel or reduce:


ii. effects on the marine environment

iii. effects on the coast

iv. effects on mobile species

v. effects from disturbance, noise and lighting

RESPONSES


b) Agree to amend paragraph to refer to the requirements of the Habitats Directive in this area.


Pennard

Representation Ref Representor 41997 Councillor Lynda James, Pennard Ward 42153, 42154, 42155, Redrow Homes 42156, 42157 Habitat Regulations Assessment Recommendation

ISSUES

a) Councillor Lynda James considers that population growth is overestimated and proposed number of new dwellings is too great.

b) Councillor Lynda James considers that new development should be focused on brownfield sites.

c) Councillor Lynda James considers that the use of prime agricultural land for building is short sighted.

d) Councillor Lynda James considers that all new dwellings should count toward numbers for Gower/Gower Fringe, not just sites of 10 dwellings or over.

e) Redrow Homes support candidate site PN001 for inclusion within the Deposit Plan.

f) The HRA concludes that providing the recommended changes to Policy 12 Tourism are implemented there will be no likely significant effects.

RESPONSES

a) The LDP Preferred Strategy is based on a growth projection that has been developed using the latest data sources available. These suggest a requirement over the LDP period (2010 to 2025) in the order of 16,100 to 17,100 new dwellings and a mid-point figure has been used.

b) Comment noted. There is insufficient previously developed (brownfield) land remaining to meet the future population increases indicated by Welsh Government projections up to 2025, which necessitates the release of some Greenfield sites for development. The Preferred Strategy aims to maximise the use of previously developed ‘Brownfield’ land by accommodate approximately two thirds of the housing requirement on brownfield land and one third on ‘Greenfield’ sites.

c) Comment noted. National planning policy advises that the best and most versatile agricultural land should be maintained unless there is an overriding need for development and lower grade/previously developed land is unavailable, or available lower grade land has an environmental value


recognised by a landscape, wildlife, historic or archaeological designation which outweighs the agricultural considerations.

d) All new dwellings regardless of size do count towards numbers for the relevant SHPZ they are located within. It is only sites of 10 or more dwellings that are specifically mapped. An allowance is made within the housing supply calculations for contributions from small sites of less than 10 dwellings. The level of contribution is monitored through annual Joint Housing Land Availability Studies.

e) Support noted – The assessment of the Candidate Sites is an ongoing exercise and all representations previously made have been taken into account. The Stage 1 filtering of sites was published during March 2012 whilst the outputs of the Stage 2 filtering form part of this report. Sites with development potential and sites other than Candidate Site submissions (inclusive of settlement refinements) are also in the process of being considered and will inform the Pre Deposit Plan which is due to be published during the latter part of 2014.

f) Comments noted and will be taken into consideration in the final Preferred Strategy Deposit Plan.

Port Eynon

Representation Ref Representor 41758 Environmental Planning for Mr Jeffries (site owner CS GW002) [1852]

ISSUES

a) Environment Planning on behalf of the site owner support the preferred strategy and note recognition there are small scale opportunities for settlement boundary amendments.

b) The Preferred Strategy lists Scurlage as an opportunity location but not Port Eynon. Environment Planning on behalf of the site owner strongly recommended that Port Eynon should be included as a local centre, and candidate site GW002 be designated for residential development.

RESPONSES


b) Recommendation not accepted. As stated within the Preferred Strategy the Council is continuing to assess the suitability of locations in the Gower and Gower Fringe zones and that there are a number of sites within village boundaries that could come forward over the plan period. Scurlage is named


as it is a village which contains a significant degree of community infrastructure, benefiting a sustainable community. The candidate site process is ongoing.

Scurlage

Representation Ref Representor 42262 Gower Society Habitat Regulations Assessment Recommendation

ISSUES

a) The Gower Society question the identification of Scurlage in paragraph 6.50. How many houses and in what specific locations and what employment is available for new residents?

b) The Gower Society consider that Scurlage is unsustainable location because it is on an infrequent bus route and is 15 miles from Swansea.

c) There are very few jobs on Gower and so occupiers will be commuters or retired – this does not promote sustainability.

d) The Gower Society suggest that there is not a proven local demand/need for Council Housing in Scurlage (or Rhossili) as some are currently occupied by people re-housed from Swansea.

e) The HRA concludes that providing the recommended changes to Policy 12 Tourism are implemented there are no likely significant effects.

RESPONSES

a) Comment noted. The Swansea and Neath Port Talbot Local Housing Market Assessment, 2013, identifies the need for a combined total of 200 homes within the Gower Strategic Housing zone. The objectives and strategic polices of the LDP seek to encourage rural economic diversification and the creation of rural employment opportunities. Allocation details will be provided in the Deposit Plan.

b) Comment noted. It is acknowledged that Scurlage is some 15 miles from Swansea, but it has many community facilities which enable a well balanced community to thrive, for example, a doctor’s surgery, pharmacy, pub, post office and shop.

c) Comment noted. The Swansea and Neath Port Talbot Local Housing Market Assessment, 2013, identifies the need for a combined total of 200 homes within the Gower Strategic Housing zone.


d) Comments noted and will be taken into consideration in final Preferred Strategy and the Deposit Plan.

Thistleboon

Representation Ref Representor 42274 CDN Planning (Wales) Ltd for Mumbles Community Council [14371] 41990 Knight Frank for Somerset Trust 41872 Eleri Walters 41768 Elizabeth Melanie Walters 42083 Richard Porter 42312, 41911, 42311, Claire Lewis 42313, 42314 42055, 42265, 42264, Claudia Herrieven 42266, 42267 41974, 42303, 42304, Judy Rees 42305, 42306 41630 Jill Burgess 42252 Barbara Ward ISSUES

a) Object to the development of sites within Thistleboon/Langland.

b) Mumbles Community council object to Candidate Site submissions: OY003 (Thistleboon Caravan Park), OY0016/0017/0018 (Land at Higher Lane, Thistleboon) and OY0019 (Land at Thistleboon). Reasons for objection include: effect on AONB, the Authority should be supporting tourism ventures such as caravan parks, traffic problems, significant adverse effects on the landscape, seascape and townscape, and also visual effects on receptors such as the coast path, open land and other vantage points. Furthermore, there does not appear to be any consideration of the effects upon other local services and facilities. Development of these sites would need to make substantial and early contributions to upgrade sewers and schools.

c) Somerset Trust support Candidate Site submissions: OY0011 / OY0016 / OY0017 / OY0018 (Land at Higher Lane, Thistleboon), and OY0019 (Land at Thistleboon).

d) Consider the proposed sites not to be ‘natural infill’ or ‘rounding off’.

e) The land in question provides an essential buffer between housing and the sea which is important for surface water run off.

f) Concern about the capability of infrastructure such as utilities and schools to cope with this new development.


g) Seek assurances that the sewerage system can accommodate the additional properties.

h) Concern regarding the road infrastructure and capacity.

i) Potential negative effects on biodiversity considered to be a relevant factor.

j) Perceive that the development of residential properties will adversely affect the tourist industry.

k) Question whether the proposed sites be houses that local people can afford, or investment properties.

l) Support any strategy that uses brownfield sites as a means of satisfying housing requirements.

m) Cannot support strategy that largely seeks to build low cost housing in areas such as Gower/Gower Fringe when evidence suggests already non uptake of such provision.

RESPONSES


d)e) have been taken into account. The Stage 1 filtering of sites was published during March 2012 whilst the outputs of the Stage 2 filtering form part of this report. Sites with development potential and sites other than Candidate Site submissions (inclusive of settlement refinements) are also in the process of being considered and will inform the Pre Deposit Plan which is due to be published during the latter part of 2014.

f)g)h) Comments noted. As part of the assessment of Candidate Sites the Planning Policy Team has placed the onus on

i) the site proposers to prove the deliverability of the sites presented. This includes the provision of evidence relating to various infrastructure issues and constraints. In identifying sites within the Pre Deposit Plan, the Planning Policy Team will have to be confident that the highlighted issues can be resolved or adequately mitigated.

j) There is no evidence provided to clarify why the development of residential properties will adversely affect the tourism industry. The Plan will have to ensure a balance between the requirements of both.

k) It is recognised that a shortfall of affordable housing across the County is a significant issue facing local residents at the present time, and the LDP has a key role to play in bringing forward sufficient land in appropriate locations to contribute towards meeting affordable housing needs. The delivery of more affordable housing is a strategic priority and a responsibility for the Council as a whole. The Swansea Bay Local Housing Market Assessment (2013) has identified a need for 7,100 additional affordable homes to be built over the


LDP period, i.e. 44% of the total housing requirement. In aiming to deliver this target, the LDP shows a real commitment in providing sufficient affordable homes for local communities.

l) In spatial terms, the sustainable growth strategy that is proposed would seek to maximise the use of appropriate brownfield development opportunities across the County, where such sites are available, economically viable and capable of delivery during the Plan period. It is clear however that the amount of brownfield land that is available and appropriate for development is insufficient to meet the identified housing need. A sustainable growth strategy is not about exhausting all undeveloped land within the urban area for development schemes, since some are important green spaces that should be protected in the interests of local amenity and biodiversity. Furthermore, some brownfield sites may be fundamentally undeliverable due to constraints or commercial viability and do not therefore offer sensible options for allocations in the Plan. Indeed, they would be rejected by the Planning Inspectorate at the Plan’s Independent Examination stage if there was any attempt to allocate such sites. It is therefore necessary for some element of growth to be met by means of developing appropriate greenfield sites, where this can be delivered in a sustainable manner, by maintaining important natural landscapes and green space and where providing realistic alternatives to private car travel would be integral to development.

m) There are problems of affordability across the County, in particular for first time buyers, and in areas where supply is restricted due to environmental constraints such as in rural communities on Gower. It is recognised that a shortfall of affordable housing across the County is a significant issue facing local residents at the present time, and the LDP has a key role to play in bringing forward sufficient land in appropriate locations to contribute towards meeting affordable housing needs. The delivery of more affordable housing is a strategic priority and a responsibility for the Council as a whole. The Swansea Bay Local Housing Market Assessment (2013) undertaken by Opinion Research Services has identified a need for 7,100 additional affordable homes to be built over the LDP period, i.e. 44% of the total housing requirement. It concluded that there is a very high requirement for affordable homes within the Gower Fringe Zone, whilst virtually all of the dwellings required within the Gower Zone over the period of the LDP should be affordable homes. In aiming to deliver this target, the LDP shows a real commitment in providing sufficient affordable homes for local communities.

Three Crosses

Representation Ref Representor 42253 Mr & Mrs Williams 41692 Jason Evans Planning for site owners of FA004 and FA010 [1464]


41991 Knight Frank, for Somerset Trust Habitat Regulations Assessment Recommendation

ISSUES

a) Suggestion that candidate site FA007 be considered in conjunction with FA014 to avoid problems associated with housing next to a working farm.

b) Jason Evans Planning (for the land owners) supports for the identification of Three Crosses as a location for sustainable growth and in particular candidate sites FA004 and FA010.

c) Somerset Trust has expressed concern that FA013 failed stage 1 of assessment.

d) Somerset Trust support FA012 as a development opportunity within the existing settlement.

e) The HRA concludes that providing the recommended changes to Policy 12 Tourism are implemented the only likely significant effect relates to waste water.

RESPONSES

a)b)c) The assessment of Candidate Sites is currently ongoing and all representations previously made have been taken

d) into account. The Stage 1 filtering of sites was published during March 2012 whilst the outputs of the Stage 2 filtering form part of this report. Sites with development potential and sites other than Candidate Site submissions (inclusive of settlement refinements) are also in the process of being considered and will inform the Pre Deposit Plan which is due to be published during the latter part of 2014. FA013 failed because it is a designated SSSI.

e) Comments noted and will be taken into consideration in the final Preferred Strategy Deposit Plan.

Wernffrwd

Representation Ref Representor 41639 Sylvia Hughes 41640 Eric Hughes 41641 Mrs P E Senger 41695 Brian Williams

ISSUES


a) Objects to large scale development in Wernffrwd given that: there are not many unspoilt villages left in Gower, coalescence of villages, positioned within a green wedge and AONB, unsuitable road infrastructure, tidal Marsh Road, unsuitable sewerage infrastructure.

b) Objects to new development within the village given that: no shops, employment, and poor public transport provision, would ruin wildlife habitat and there is already a preponderance of empty properties available.

c) Objects to Candidate Site PC0010 (Land adjacent to 2 Hillside, Llanmorlais).

RESPONSES

a)b)c) Comments noted. The assessment of Candidate Sites is currently ongoing and all representations previously made have been taken into account. The Stage 1 filtering of sites was published during March 2012 whilst the outputs of the Stage 2 filtering form part of this report. Sites with development potential and sites other than Candidate Site submissions (inclusive of settlement refinements) are also in the process of being considered and will inform the Pre Deposit Plan which is due to be published during the latter part of 2014.

West Cross

Representation Ref Representor 42272 CDN Planning (Wales) Ltd for Mumbles Community Council [14371] 41984 Knight Frank for Somerset Trust Habitat Regulations Assessment Recommendation

ISSUES a) Mumbles Community Council object to development on the fringes of West Cross, specifically Candidate site WC004 and any other site that hitherto has not been promoted via the Candidate Site process.

b) Mumbles Community Council consider that WC004 covers much of Clyne Common. Common land should not be developed and further issues, such as landscape, biodiversity and the general relationship between the urban and rural areas reinforce this.

c) Mumbles Community Council note that WC004 was rejected during the Stage 1 assessment of Candidate Sites but paragraph 6.50 refers to ‘local needs housing opportunities identified at Newtown/West Cross’ and Fig 6.4 identifies a ‘limited rural fringe extension in the vicinity of West Cross’. Which sites are referred to if not WC004? The Community Council support the rejection of WC004 during Stage 1.


d) Development in this area should be resisted, due to the remoteness of the site to existing facilities, likely effects on watercourses, drainage, and sewerage and flood risk.

e) The LPA must consider in detail what planning obligations would be required in order for development in this area to be acceptable, for example physical infrastructure, road improvements, civil infrastructure, schools and other facilities. It is likely to be substantial and unrealistic amount and it is expected that by the time of the Deposit LDP the evidence base will in future demonstrate that any development on or near this area will be unsound.

f) The Transport and Access Topic Paper states that the wider road network in Mumbles is at capacity in several locations, which is supported by anecdotal evidence from the local community and Community Council. There area also vehicular pollution effects in Mumbles which would be further exacerbated by the quantum of development that the Preferred Strategy suggests is possible at West Cross.

g) Mumbles Community Council believe that any development of this area would have severe and significant adverse and irreversible effects on the sensitive landscape character and also visual effects.

h) Support candidate site WC004. Common land not necessarily constraint to development. The Somerset Trust is open to providing suitable compensatory measures and/or exchanging land. An ecological assessment has been undertaken and it shows that the site is developable, subject to mitigation/compensatory measures, which client will adhere to. The site is appropriate for allocation in the LDP. It is a sustainable location with good road and public transport links.

i) The HRA concludes that providing the recommended changes are made to Policy 12 Tourism there will be no likely significant effects.

RESPONSES

a) Objection noted. The Stage 1 filtering of sites was published during March 2012 whilst the outputs of the Stage 2 filtering form part of this report. Sites with development potential and sites other than Candidate Site submissions (inclusive of settlement refinements) are also in the process of being considered and will inform the Pre Deposit Plan which is due to be published during the latter part of 2014.

b) Comment noted. A decision on whether to allocate sites that currently provide areas of open space or amenity for communities will have full regard to the requirements of TAN16 and other LDP policies that will set a standard for open space provision and seek to improve access to green infrastructure more broadly.

c)d)e) Comments and support noted. The Candidate site process is an ongoing process. In identifying land for development within the Plan, the Planning


Policy Team will test the deliverability of such proposals (inclusive of infrastructure provision). Where the existing infrastructure is sub standard new development may provide an opportunity to improve provision and in bringing sites forward for consideration, site proposers will be expected to prove the delivery of their proposals. Some sites other than candidate site submissions are also being considered and assessed.

f) Comment noted. The Candidate site process is an ongoing process and potential impacts of proposed development on the highway infrastructure are considered as part of the assessment.

g) Comment noted. The Candidate site process is an ongoing process and the landscape and amenity impacts of development will be assessed.

h) Comment noted however it relates to a specific candidate site. The assessment of candidate sites is an ongoing process that will inform the Pre-Deposit Plan and ultimately the Deposit Plan. The public consultation of these documents will provide an opportunity to make representations on the non-allocation of sites.

i) Comments noted and will be taken into consideration in the final Preferred Strategy and Deposit Plan.

Paragraphs 6.53 to 6.56 - Regeneration Strategy

Representation Ref Representor 42085, 42086 Stephen Williams 41816 White Young Green (WYG) for Sainsburys ISSUES

a) Poor performance and low rankings for the city centre is not due to a lack of a new retail scheme but is the result of previous schemes having been poorly conceived/delivered; poor public realm; pedestrianising the city centre; and the increase of internet shopping. The proposed retail core is therefore not the right approach, since no retail scheme will claw back footfall. Rather it is people that attract shops, rather than shops attracting people, and the LDP should aim to populate the city with people working.

b) Sainsburys consider that the statement that "Further leisure and retail development in out-of-centre locations will impact negatively on the future performance of the City Centre and will not be supported" pre-judges the affect of future development proposals and contradicts the retail tests set out in national planning policy. Such statements should not be included in the Preferred Strategy and certainly should not be repeated in forthcoming stages of the LDP as to do so would run counter to soundness test C2.

RESPONSES


a) Agree that a retail only strategy would not be an appropriate approach for regenerating Swansea city centre. The strategy is instead explicitly a mixed use approach that will be focused on delivering new homes, business and leisure development, as well as retailing. This mixed use approach is concerned with delivering a true destination that will appeal to residents, workers and visitors alike. This approach will be key to delivering enhanced overall vibrancy and attractiveness of the City Centre, and creating a thriving day and night time economy. In terms of business investment in particular, the Preferred Strategy contains a strategic policy that clearly states the city centre will be the preferred location for new office uses (Policy 11). These high level objectives, as described in the Preferred Strategy, will be further augmented in the Deposit Draft and supporting supplementary guidance, which will feature details policies and proposals on key development areas.

b) The LDP will provide clarity regarding the retail hierarchy and resisting out of centre development that would undermine regeneration prospects for the city centre, which is well founded in evidence and a policy aim supported by national guidance. Grammatical error in paragraph. Amend 6.57 to read ‘Further leisure and retail development in out-of-centre locations that will impact negatively on the future performance of the City Centre and will not be supported.’

Paragraphs 6.58 to 6.63 - Economic Growth and Emplo yment

Representation Ref Representor 42017, 42015, 42016, Barton Wilmore on behalf of Baybrook Ltd 42018, 42019, 42020 42179 RPS Planning & Development for Associated British Ports [1878] 41804 RPS Planning & Development for Swansea University

ISSUES

a) Barton Wilmore on behalf of Baybrook Ltd consider that there is no specific reference made to the importance of jobs in the tourism and leisure sectors to the economy. For example, the proposed redevelopment of Fairwood Park Golf Club will create some 60 jobs year round which will generate approximately £6.2 million of additional visitor expenditure.

b) Paragraph relates to Fabian Way Strategic Employment Site and it refers to land at Swansea Port being safeguarded for storage/distribution uses where necessary and need to review potential linkages with new Swansea Bay Campus to support spin-out businesses in future. ABP considers, that a more flexible approach to land uses would be more appropriate.

c) Swansea University consider that there should be a specific recognition in the LDP that land to the west of the Bay Campus should be allocated to


accommodate potential development that will support and complement the transformational development underway at the Bay Campus, rather than reviewing this in the future as stated in the document.

RESPONSES

a) Agree that a reference to tourism and leisure uses would be helpful to further illustrate the depth of the economy and opportunities for growth. Amend paragraphs accordingly.

b)c) Since the publication of the Draft Preferred Strategy the Authority has maintained a dialogue with key landowners at the Fabian Way Eastern Gateway with an emphasis on co-ordinating development proposals and bringing forward a concept masterplan for the strategic area. It is not considered appropriate for the Preferred Strategy however to refer to specific allocations of constituent parts of the wider area, particularly in view of the continuing work to develop the masterplan. Amend paragraphs to refer to the role of a concept masterplan for this strategic area.

Paragraphs 6.65 to 6.69 - Transport

Representation Ref Representor 41963 Coastal Housing Group 42087 Stephen Williams 41793, 41794, 41795, Mrs Bridget Stein 41791 42286 South West Wales Integrated Transport Consortium (SWWITCH) [1686]

ISSUES

a) SWWITCH consider that this section could be strengthened in terms of the regional and national context by reference to: the Swansea Bay City region; Electrification of the SW Mainline to Swansea; The Active Travel Bill; and the importance of Travel Planning and the benefits which sustainable access can have on access to employment by deprived communities.

b) Coastal Housing Group is involved with an initiative to bring a cycle hub to the centre of Swansea. Improved cycle infrastructure is imperative to encouraging people to leave their cars at home.

c) Public transport needs to become a more viable option in order to improve modal split and reduce congestion. With all public transport leading to the city centre, and virtually all jobs outside the city centre, Public transport is not an option for most. More bus lanes will not attract more people to use public transport since if the buses are not going to the right place the speed of the bus is irrelevant.


d) The principle of integrating sustainable travel infrastructure as part of new development, and in advance of occupation, is supported.

e) As well as local travel, transport links to the outside world need to be improved for Swansea to become more economically viable. A proper express train (electrified) needs to be established, with no stops between Swansea and Cardiff, and high speed links from there to London and the north and elsewhere. Slow trains can pick up passengers between the express trains.

f) Felindre seems a far better site for an airport than the current location, considering its road and potential rail links

RESPONSES

a) Agree that the proposed additional references to national and regional measures would improve the document. Amend accordingly.

b) Comments noted. Strategic and detailed policies will aim to facilitate enhanced infrastructure through the development process. Agree that such infrastructure is integral to providing realistic and attractive alternatives to car travel, particularly for short journeys.

c) Investment in dedicated bus routes and other infrastructure aimed at improving journey times/reliability can play a key role in enhancing the appeal of public transport as a genuine alternative travel choice to the private car. Routes into the city centre are vital in this respect as they converge on what is the commercial and entertainment hub for the whole City Region, however this does not preclude such measures from being implemented on other routes across the County. The LDP will, where appropriate, provide a framework to facilitate the implementation of bus priority measures to/from strategic development areas to improve connectivity and provide enhanced sustainable travel opportunities across the County.

d) Support welcomed.

e) The section will be amended to include an additional reference to the opportunity provided by electrification of the mainline (see above), however the suggested changes to frequencies and station stops outside the County boundary are measures beyond the scope of the LDP.

f) Comments noted, however a Mixed Use Major Development Area is considered a more suitable development option for the Felindre area in order to complement the strategic employment site and deliver an exemplar sustainable village and a high quality residential environment. An airport at this location would preclude this and moreover the Planning Authority is not aware of any formal proposals from either public or private sector to deliver such a scheme, or even undertake feasibility assessments for what would clearly require huge levels of investment notwithstanding issues of environmental impact.


Paragraphs 6.70 to 6.72 - Utilities

Representation Ref Representor 41796 Mrs Bridget Stein 41901 Dwr Cymru/Welsh Water (DCWW) ISSUES

a) Requests the improvement of broadband provision.

b) DCWW confirm that potable water supplies can be provided.

RESPONSES

a) Comments noted. The Council supports the introduction of new and improved infrastructure provision throughout the County and will actively encourage providers to deliver schemes. The Council made a bid for funding to address some of the broadband deficiencies in urban Swansea to the Super Connected City initiative run by UK Government. This bid was unsuccessful but the Council, as part of a programme of projects called Swansea Bay Wireless, is planning to attract significant capital investment to provide a private access network for the public sector across the Swansea Bay region. The Planning Policy Team has been involved in the initial design considerations and planning of such a network and their continued involvement on the project will be important to ensure the evolving LDP and potential network are integrated.

b) Comments noted. The Council welcomes the fact that such supplies can be provided.

Paragraphs 6.73 to 6.75 - Drainage

Representation Ref Representor 41823, 41824 Carmarthenshire County Council. 41902, 41903, 41904 Dwr Cymru/Welsh Water (DCWW) 41647 Mr David Miller Habitat Regulations Assessment Recommendation

ISSUES

a) Carmarthenshire County Council recognises ongoing cross boundary collaborative consultation in particular with respect to CBEEMS and the associated Multi Agency Memorandum of Understanding (MoU).


b) DCWW recommends that all signatories of the MoU should collaboratively review and inform the issue of drainage within the Preferred Strategy specifically in relation to matters regarding the Loughor Estuary in order to avoid unintentional conflict.

c) DCWW supports Paragraph 6.75 and the Preferred Strategy's aim to control and manage surface water discharge from new developments and prevent new connections of surface water drainage to the sewerage network.

d) Highlights the fact that the lack of capacity of the Gowerton Waste Water Treatment Works is unacceptable and considers that unused land surrounding the works should be utilised in the investment of additional facilities.

e) The HRA screening report highlights the potential issues surrounding the discharge of waste water as a challenging issue for the Swansea LDP. A successful resolution to the ongoing discussions and renegotiation of the MOU will be important to enable likely significant effects to be screened out in the formal HRA. Support for paragraph. 6.74 that states that the ongoing review of the MOU is identified as a potential way forward between all relevant bodies to ensure there is sufficient capacity to accommodate proposed LDP allocations.

RESPONSES

a) Comments noted. The Council welcomes continuous dialogue and consultation with adjoining Authorities covering a whole range of issues. This is critical for ensuring both the compatibility of respective development plans and for highlighting best practice.

b) There is a firm commitment by all signatories to implementing the provisions of the MoU) and its requirements in practice. This multi agency commitment to the MoU remains with cross border collaboration and discussions between the City and County of Swansea and Carmarthenshire ongoing. The MoU Technical Officer Group oversees the revision of the MoU (every six months) and a draft revised version is currently being finalised. Once finalised, the MoU will inform the production of the Pre Deposit Plan and additional revisions in the future will inform further stages of Plan preparation.

c) Support welcomed. The LDP will ensure that developments will be encouraged to utilise sustainable principles in the design of buildings, promote sustainable drainage systems where ground conditions allow minimising surface water run-off and flooding, and provide positive contributions to tackling climate change.

d) Significant improvement and investment have recently been ongoing at Gowerton Treatment Works. DCWW has recently invested in a new hydraulic model for the Gowerton catchment. The findings of which have indicated solutions throughout the catchment and these would have to be delivered prior to development occurring. As part of their interaction with the


Memorandum of Understanding they are undertaking surface water removal within the Gowerton catchment within the existing Asset Management Plan (2010-2015) and will continue with further work in their next Asset Management Plan (2015-2020). This work will help alleviate flooding in the catchment as well as reducing the number of spills to estuarial waters.

e) Comments noted and support welcome.

Paragraphs 6.77 to 6.80 - Environmental Capital and Constraints


41610 Mr Philip Morris


42021 Barton Wilmore on behalf of Baybrook Ltd

ISSUES

a) No specific mention of the AONB in the environmental capital section.

b) No clarification of the Preferred Strategy for development on or close to the AONB.

c) Paragraph 6.77 contains well made points that are central to achieving a good plan.

d) Barton Wilmore on behalf of Baybrook Ltd consider that the Preferred Strategy should recognise that there needs to be investment in existing tourism facilities for the tourism industry to remain competitive.

RESPONSES

a) The term natural heritage covers statutory designated sites including the AONB. As defined in National Planning Guidance ‘Natural heritage refers to geology, land forms, biodiversity, natural beauty and amenity ….. It includes statutorily designated sites, urban areas, the countryside, the coast and open water features.’

b) The Preferred Strategy for Gower and Gower fringe is outlined in chapter 6 paragraph 6.48 – 6.52.

c) Support welcomed.

d) This is reflected in LDP objective 16’ Improve, expand and diversify appropriate sustainable tourism facilities and infrastructure’.


Fig 6.4 - Strategic Diagram

Representation Ref Representor 41949 RPS Planning & Development for site owners LF0011 41879 Sustrans Cymru 42144 Barton Wilmore on behalf of Baybrook Ltd ISSUES

a) RPS Planning and Development for site owner support content of key diagram.

b) RPS Planning and Development for site owner expressed concern about the lack of detail in the Preferred Strategy relating to specific locations for development outside of the defined strategic areas.

c) The Key Diagram currently only shows the road and rail network. Sustrans consider that the diagram should include strategic cycling and walking routes as defined by the National Cycle Network and Wales Coastal Path. See the requirements of Active Travel Bill.

d) RPS Planning and Development for site owner consider that land at Fabian Way should be identified on the Key Diagram as a key component of the Plan’s Strategy.

e) The key diagram shows “Green Barriers”. Baybrook Ltd is concerned that the Plan does not confirm the purpose of these areas. Specifically, objection is raised to the identification of the area north of Birchgrove as “green barrier” and the implications of this for candidate site LS012 – Land at Heol Las.

RESPONSES

a) Support is welcomed.

b) The Preferred Strategy is a conceptual document by its nature and is not the appropriate stage of the Plan making process to set out the detail of all sites being considered for allocation. The level of detail requested will be set out in the Deposit Plan.

c) Agree that the Key Diagram should be amended to show key strategic cycle routes. Amend diagram to illustrate National Cycle Network. However, do not agree that the Wales Coastal Path has the same strategic development planning significance to show this on the key diagram.

d) The Key Diagram identifies land at Fabian Way as a strategic housing and employment location. It will be given greater emphasis in the full version of the Preferred Strategy.

e) The purpose of “green barriers” on the key diagram is to show at a very strategic and conceptual level, the key locations where it will be necessary to ensure that proposed development maintains the important green areas which


define the natural edge of settlements and/or serve as areas of open space that separates distinct communities. Accept that the definition of “green barriers” could be made clearer in the plan. Amend Chapter 6 to include a paragraph that introduces the Key Diagram. With regard to the specific comment relating to Birchgrove, the relationship of a specific site to the settlement edge and its impact on coalescence is a matter for detailed analysis through the ongoing candidate site assessment process.

Chapter 7 : Strategic Policies

General Comments


42287, 42289 South West Wales Integrated Transport Consortium (SWWITCH) [1686]



ISSUES

a) SWWITCH Request that the objective stated after a number of policies which refers to the promotion of a sustainable transport system should be strengthened to refer to the role of travel planning.

b) Support strategic policies, which could promote a better future for our region and deliver quality places.

c) Strategic policies do not mention the Welsh language, and therefore risks the references to Welsh sensitive areas being seen as tokenism. The language should be included as a basic principle to any strategic policy, which should also refer to the Welsh Government produced TAN20.

RESPONSES

a) The objectives stated after policies are cross references to the Strategic Policies. A reference to travel planning is too detailed for inclusion in the strategic objectives. Agree however, that the supporting text to Policy 8 ‘Sustainable Travel and Accessibility’ could be amended to highlight the importance of travel planning. Suggest the addition of the following text “The Deposit Plan will also set out the role of Travel Planning as a driver for modal shift and facilitating sustainable travel choices.”

b) Support welcomed.


c) The importance of the Welsh Language to notions of cultural identity is highlighted in the preamble to Strategic Policy 13 ‘Natural Heritage and the Cultural and Historic Environment’. The issue is also raised more broadly elsewhere in the document. Chapter 2 emphasises the Wards of Mawr and Pontarddulais as being language sensitive areas with the highest numbers of Welsh speakers (approximately 38% and 31% respectively), where the impact of development will be most closely considered in this regard. The revised Technical Advice Note 20 (Planning and the Welsh Language) states clearly that the Welsh language should be considered during the production of LDPs as part of the Sustainability Appraisal (SA) process, where local planning authorities have identified the language as being of importance. This process ensures that the Welsh language can be embedded into the LDP ensuring that all subsequent policies, proposals and eventual site allocations will have considered the impacts on the Welsh language.

From a Swansea perspective, SA Objective 6 tests whether the Plan encourages an inclusive society and promotes equality (incorporating the Welsh language) whilst the specific LDP Objectives established seek to reduce the impacts of new development on communities where the Welsh language forms part of the social fabric. This means that the LDP must provide for sustainable development by protecting, and where possible enhancing, the cultural environment whilst facilitating sustainable economic growth and ensuring that all new development is supported by appropriate physical and social infrastructure. Furthermore, the Spatial Options Assessment Topic Paper concluded that whilst the scale of growth proposed had the potential to put pressure on the capacity of social infrastructure, including the Welsh language, the opportunity to masterplan sites would bring positive benefits by ensuring that the Council is able to achieve the objectives of planning for sustainable, distinct communities. An updated assessment of the importance of the language within a Swansea context along with the consideration of the potential effect of developments upon the language is currently underway and will inform the production of the Pre Deposit Plan. This will be undertaken in the full knowledge of further practical guidance developed for local planning authorities to assist them with assessing the potential impacts of the LDP proposals on the Welsh language (via the SA) recently published by the Welsh Government, the provisions of which will be fully taken into account. Suggest that the supporting text to Strategic Policy 13 be amended to refer explicitly to following the guidance set out in revised TAN 20 and the role of the SA.

Paragraphs 7.2 to 7.5 - Policy 1: Sustainable Devel opment




41876, 41868 Asbri Planning for N Jones & Siblings (site owners BI007 & BI009) [2113]

42237 Boyer Planning for Persimmon Homes West Wales


41915 RWE npower renewables

41975, 41976 The Theatres Trust



41916, 41917, 41918 RWE npower renewables



ISSUES

a) Support for Policy 1 and a requirement for appropriate utility infrastructure to be implemented to support communities and business.

b) CLAS Cymru request inclusion of a reference to new and wide ranging types of green infrastructure at criteria (iii).

c) CLAS Cymru express strong support for Policy 1 and request reference to leisure and recreation opportunities that bring communities together at point (viii).

d) Asbri Planning on behalf of site owner, support Policy 1. However, consider that the distribution of housing requirement in Fig 7.1 should be amended as it shows relatively low housing requirement associated with Gower Fringe Area of only 320 dwellings.

e) With regard to para 7.4, Coastal Housing Group consider that sustainability measures imposed by the LA need to be kept to a minimum. Developers are already subject to regulation by the EU, the UK and the Welsh Government, so further burdens increasing costs and construction times will need to be carefully considered.

f) NLP for Peter Jenkins consider that the term “Social Infrastructure” is ambiguous and requires clarification to prevent Policy 1 from being overly onerous and causing difficulties with its implementation. The Theatres Trust highlight the term is defined in the glossary but consider that the definition is unclear whether it includes theatres, art venues and performance spaces. The Trust suggests for clarity that the plan sets out one term for all Community and Cultural Facilities with a description in the Glossary as follows: "community and cultural facilities provide for the health and wellbeing, social,


educational, spiritual, recreational, leisure and cultural needs of the community".

g) NLP for Peter Jenkins support Council’s general approach of considering the capacity of previously developed land to meet housing requirements. Support Council’s acknowledgement of importance of the 'Greater North West' area to deliver housing.

h) RWE npower Renewables support Policy 1 but consider that objective 6 "encouraging appropriate development of low carbon and renewable energy resources and energy infrastructure" should be explicitly stated as a policy criterion.

i) All new homes should meet high specifications with regard to their energy efficiency and should be "Eco-homes". Residents should be able to walk/cycle to work and local shops.

j) HRA concluded that Policy 1 is screened out of further assessment.

RESPONSES


b) Comment noted. The term ‘enhancing green infrastructure’ refers to improvements in the network as a whole which may include the creation of new green space.

c) The proposed amendment is not accepted. The strategic policy seeks to ensure that all development is delivered sustainably and that it contributes to sustainable communities. Criterion (viii) refers to leisure and recreation opportunities. It is not considered necessary to further elaborate this criterion, especially as Policy 6 also refers to social infrastructure and sustainable communities.

d) The proposed amendment is not accepted. The Strategic Housing Market Assessment provides a figure of 320 units for the Gower Fringe Strategic Housing Policy Zone, which is reflected in Fig 7.1.

e) Comment noted. The local authority does not impose any standards above those imposed nationally. All residential development is expected to meet a minimum of Code Level 3 and the principles of good, sustainable design as set out within TAN 12: Design and the Council’s adopted supplementary planning guidance ‘The Residential Design Guide’.

f) In order to improve the implementation of Strategic Policy 1, suggest that the definition of Social Infrastructure is amended to read: "community and cultural facilities provide for the health and wellbeing, social, educational, spiritual, recreational, leisure and cultural needs of the community".

g) Support welcome and noted.

h) Support welcome and noted. A Strategic Policy on renewable and low carbon energy was considered during the Sustainable Appraisal (SA) of the Preferred


Strategy. Following consideration of the results of the SA, it was concluded that Strategic Policy 15: Renewable and Low Carbon Technologies should be omitted from the Preferred Strategy, as it repeated national planning policy and did not add anything of a County specific nature. In particular, the scale of potential development proposals was considered and it was identified that small-scale renewable proposals would not require planning permission and were therefore outside the remit of the Policy. Whilst very large-scale proposals would also not require planning permission from the Council, as their consideration would fall within the remit of the Planning Inspectorate. Proposals that would potentially be subject of control by the Council would not be of a strategic nature and thus no Strategic Policy was considered necessary. Such proposals should however be subject of a detailed policy in the Pre Deposit Plan.

i) Comment noted. In Wales, all new residential development must meet the Code for Sustainable Homes (which replaced Eco Homes) Level 3 and obtain 6 credits under issue Ene1– Dwelling Emission R. The LDP aims to facilitate sustainable communities which will enable healthier standards of living.

j) Comments noted.

Paragraphs 7.6 to 7.10 - Policy 2: Sustainable Sett lement Strategy


41868 Asbri Planning for N Jones & Siblings (site owners BI007 & BI009) [2113]

41890, Savills for St Modwen Developments Ltd

42237 Boyer Planning on behalf of Persimmon Homes

42329, 42330, 42331, Nathaniel Lichfield and Partners for Peter Jenkins

42332 Glanffrwd Road (CS Ref: PT0011)



41948 RPS Planning & Development (for Landowner of CS LF011 & LF012) [14422]

41649 Peter R Stevens

41876 Asbri Planning for Persimmon Homes (CS PG002)



ISSUES


a) Asbri Planning for N Jones support Policy 2, particularly criteria (iii) re infill and rounding off.

b) NLP for Peter Jenkins support the Council’s approach of identifying a mix of brownfield and Greenfield land to meet the housing requirement. Support the Council’s acknowledgement of importance of the 'Greater North West' area to deliver housing as set out in Fig 7.1.

c) DCWW support a blend of options 3 and 4 and welcome the approach to focussing development on brownfield sites, extensions to existing urban settlements and in sustainable locations where DCWW infrastructure is prevalent.

d) General support from RPS Development for Policy 2, and in particular for the reference to the role of 'appropriate infill within existing defined settlements and villages and small-scale rounding off to defensible boundaries at locations with the benefit of good transport links'.

e) Request that supporting text to Policy 2 amended to a) * reflect issues of over-reliance on brownfield sites, windfalls and constrained sites; b) * include "large scale" edge of settlement extensions.

f) Savills, for St Modwen request a lower of housing growth. Whilst Penllergaer Estates consider that a higher level of housing growth is required to be provided within the LDP.

g) Savills, for St Modwen request that the Fabian Way corridor feature as part of a strategic policy.

h) Penllergaer Estates consider that the housing allocations should have a greater focus of small to medium sized sites adjacent to existing sustainable settlements, as well as greenfield sites, in order to ensure an appropriate balance of sites is provided.

i) RPS Development request that Policy 2 and its supporting text should include a cross reference to Pontlliw, on the grounds that it is a sustainable settlement with good transport links and therefore suited to future residential development in appropriate locations.

j) Para 7.7 refers to the concentration of development in the east and north west areas. Query whether attention has been paid to upgrading infrastructure to accommodate expansion in the east and north west areas which is already under strain.

k) Asbri Planning for Persimmon Homes query the wording of para 7.10 which they consider appears to allow for the Council to introduce a change in the stance of Preferred Strategy at a future date. Query whether there is sufficient evidence to support a change of approach.

l) Asbri Planning for Persimmon Homes highlight that work carried out in preparing the Vision for Penllergaer has considered other development options which could be put forward in a changed Preferred Strategy scenario


and that some flexibility exists in allowing a smaller scale scheme if necessary.

m) Baybrook Ltd request that the Policy needs to be amended to be in-line with the Welsh Government's household projections i.e. to increase the requirement to 17,956 homes.

n) The HRA concludes that Policy 2 is screened out for further assessment.

RESPONSES

a)b)c) d) Support welcome and noted.

e) Proposed amendments not accepted: a) The assessment of options was based on the evidence of development potential of brownfield sites set out in the Previously Developed Land Capacity Study. The Deposit Plan will contain more detail about the scale and location of specific allocations as this emerges through the candidate site assessment process. b) The sustainable settlement strategy is set out within Policy 2. However, if this is not accepted then large scale sites will need to be released at edge of settlement locations (paragraph 7.10 refers). However, it is considered that this approach would fail to deliver the vision and objectives of the Preferred Strategy.

f) The level of housing growth contained within the Preferred Strategy reflects the 2011 based WG projection for the LDP period 2010-25. To provide a lower level of housing growth which did not meet projected growth would be unsound.

g) The Preferred Strategy identifies Fabian Way as a strategically significant employment site and the Pre Deposit LDP will feature more detailed policy on employment land requirements and economic development, which will include confirmation of site allocations and the criteria that will inform the consideration of redevelopment and/or change of use proposals at existing employment locations. Detailed policy will also provide further clarification of the Council’s strategy for its strategically significant sites at Felindre, Waunarlwydd (which includes the Swansea West and Westfield Business Parks), Swansea Vale, south of Fabian Way and the City Centre.

h) The Preferred Strategy proposes a variety of scale of new housing land releases, ranging from small to large-scale releases at edge of settlement boundaries to strategic-scale Mixed Use Major Development Areas.

i) Comment noted. However, an amendment to Policy 2 is not considered necessary as the policy does not mention any specific locations and it would be inappropriate to refer to individually to Pontlliw. There is reference to Pontlliw as a rural village in the Greater North West Swansea Strategic Housing Policy Zone (paragraph 6.23). In addition the Greater North West SHPZ section is to be amended to include reference to small- scale settlement amendments.


j) Comment noted. The Candidate Site assessment process is ongoing and an assessment of infrastructure capacity is part of the assessment. Where the existing infrastructure is sub-standard new development may provide an opportunity to improve provision and in bringing sites forward for consideration, site proposers will be expected to prove the delivery of their proposals

k) The Preferred Strategy identifies a range of broad spatial options for growth which are derived from a clear understanding of the regional and local context, as well as the key issues and drivers that can be addressed through land use allocations and planning policies. Whilst the Preferred Strategy pinpoints a specific preferred growth option it also covers the implications for development of pursuing this strategy including any major sites on which the strategy depends. The formal consultation period offered an opportunity for communities, stakeholders and indeed Members to influence its production and suggest modifications or alternatives, providing that they meet the LDP’s objectives and are compatible with its vision. In taking the agreed growth option forward to the Pre Deposit Plan the Planning Policy Team will ensure that the evidence base clearly supports the approach adopted thus ensuring that the Plan can be considered sound.

l) Comment noted. The Candidate Site assessment process in ongoing.

m) Since publication of the LDP Draft Preferred Strategy, WG has released its 2011 based household projections for Local Authorities in Wales. Initial analysis appears to show that the projection advocated by the Council for the City & County of Swansea in the Draft Preferred Strategy is in-line with the new 2011 based WG projection for the LDP period 2010-25. The Council is currently updating the LDP evidence base supporting studies with the new projections.

n) Comments noted.

Paragraphs 7.11 to 7.16 - Policy 3: Affordable Hous ing


41876, 41868 Asbri Planning for N Jones & Siblings (site owners BI007 & BI009) [2113]

42249 Environmental Planning for site owners CS BI002


41668, 41669 Derek Walker





ISSUES

a) Asbri Planning for N Jones notes that Bishopston is included in the Swansea South West Viability Sub Market in the Affordable Housing Viability Study (AHVS), prepared by Dr Andrew Golland, and support the findings of the study to the effect that the affordable housing requirement will be 20-30%, as opposed to a maximum of 70% in the Gower and Mumbles sub areas. However, it is noted that in the Topic Paper on Affordable Housing issued by CCS in August 2013 Bishopston falls within Gower Fringe where a 70% policy for affordable housing is being proposed in Policy AH1. A 70% requirement would make development in Bishopston unviable as Dr Golland concludes, therefore the policy should be amended accordingly to 30% in line with the advice of the AHVS.

b) Environmental Planning note the statement at para 7.11 relating to the issue of a shortfall of affordable housing across the County.

c) Baybrook Ltd consider that the policy needs to make reference to the fact that the delivery of affordable housing needs to be balanced against wider development economics.

d) Representor highlights the WG’s commitment to the expanding the role of Co-operative housing which has the potential to play a significant role in securing affordable housing provision.

e) With regard to para 7.15, Coastal Housing suggest that as social housing can be delivered on smaller sites, the Council could dispose of sites of less than ten dwellings directly to RSLs rather then increasing the social housing requirements for private developers.

f) WG query why the LDP proposes to deliver 4,130 affordable dwellings but the Strategic Housing Market Assessment has identified a need for 7,100.

g) WG generally support the proposed split threshold for affordable housing as being reflective of local housing market circumstances.

h) WG consider that a 10% target for affordable housing in Swansea East and North is not supported by the evidence.

i) WG state that the Council should consider the inclusion of affordable housing policies for windfall sites, rural exceptions sites and the allocation of some 100% affordable housing sites.

j) WG state that viability information must be up to date and take into account all known costs, particular reference is made to consideration of the July 2013 Ministerial Statement on Part L Building Regulations.

k) WG consider that more explanation is required on whether the identified housing need for affordable housing takes account of backlog, current need and anticipated future need.


RESPONSES

a) The Affordable Housing Topic Paper clearly indicated the AHVS was received after the Draft Preferred Strategy had been approved for consultation and amendments would be incorporated into the final version of the document as appropriate. Bishopston lies in part within the Gower AONB and part within the Gower Fringe and any development within the area contributes to house build within these SHPZs. It is clearly physically separated from the West SHPZ and cannot be ‘placed’ in this zone to enable a lower affordable housing requirement. It is acknowledged that the description of localities in the independent AHVS has caused some confusion over the boundaries of the SHPZs. The SHPZs are ward based, whereas the AHVS is an analysis of house prices by sub-markets based on postcode sectors which do not correspond to ward boundaries. Whilst there are significant overlaps between the SHPZs and AHVS sectors, they are not directly comparable. The locality descriptions in the AHVS will be changed to postcode sectors or similar to avoid confusion and further clarification provided within the background documents.

b) This is stated in the Preferred Strategy and is a key issue for the LDP to address.

c) The quantum of affordable housing identified to be delivered through the LDP is actually 40% below the level needed. This takes into consideration the viability and deliverability of sites having regard to wider development economics.

d) Where co-operative housing is feasible this form of tenure would be supported in principle. Such schemes are however primarily focussed on housing management which is not an LDP function.

e) In practice private developers are usually not interested in Council sites of less than 10 dwellings, and the focus for disposal of such sites tends to be to RSLs. This approach however, combined with historically high trigger thresholds for affordable housing provision by private developers, has resulted in under provision of such housing type. The LDP seeks to reduce trigger points for private developer schemes informed by development appraisal viability assessments in order to increase the supply of affordable housing. It is acknowledged this may eat into developer’s profit margins if their purchase price failed to adequately take such provision into consideration. However the development appraisal toolkit will ensure that a profit is still maintained and is the only way of delivering the significant levels of affordable housing need identified.

f) It is recognised that a shortfall of affordable housing across the County is a significant issue facing local residents at the present time, and the LDP has a key role to play in bringing forward sufficient land in appropriate locations to contribute towards meeting affordable housing needs. The delivery of more affordable housing is a strategic priority and a responsibility for the Council as a whole. The Swansea Bay Local Housing Market Assessment (LHMA 2013)


has identified a need for 7,100 additional affordable homes to be built over the LDP period, i.e. 44% of the total housing requirement. In aiming to deliver this target, the LDP shows a real commitment in providing sufficient affordable homes for local communities. However, Section 106 Planning Agreements cannot be expected to deliver the full need for affordable housing. The affordable housing target thresholds proposed have been informed by the Viability Assessment. Other wider mechanisms will also contribute towards delivery of affordable housing and RSLs will continue to develop affordable housing on their own sites.

g) The WG’s support is welcomed.

h) The Development Appraisal Toolkit will assess the viability of schemes on a site by site basis and the levels of housing provision sought will be up to the targets identified acknowledging that it will not be possible to achieve these targets in every case. Equally however in some zones where the target is low, such as Swansea East and North, there will be pocket sites where higher levels of affordable housing provision will be viable and it will be important to ensure that housing policies do not preclude this.

i) Comment noted. The Council will formulate policies for the Deposit Plan based on the most up to date evidence base and viability assessments.

j) Comment noted. The Council will continue to maintain an up to date evidence base.

k) The housing need has been identified by the Swansea Bay Local Housing Market Assessment. The analysis has been undertaken in-line with the requirements set out in TAN 2: Planning and Affordable Housing (2006).

Paragraphs 7.17 to 7.23 - Policy 4: Quality Places and Spaces



41877 Asbri Planning for Persimmon Homes (CS PG002)



ISSUES

a) CLAS Cymru strongly support policy.

b) Persimmon Homes support the policy and the notion of concept planning/masterplanning to guide proposals at key sites, as per the approach taken at Penllergaer major mixed use development area.


c) Representor considers that whilst house design considerations are worthwhile, the policy should also insist that all new homes meet high specifications with regard to energy efficiency.

d) Baybrook Ltd consider that whilst the aspiration to encourage high quality design is supported, it must also be balanced with development viability.

RESPONSES

a)b) Support is welcomed.

c) Comments noted. All residential development is expected to meet a minimum of Code Level 3 and the principles of good, sustainable design as set out within TAN 12: Design and the Council’s adopted supplementary planning guidance ‘The Residential Design Guide’.

d) Consideration of site viability is an essential part of the development plan preparation process.

Paragraphs 7.24 to 7.26 - Policy 5: Green Infrastru cture




ISSUES

a) Strong support for Policy 5 from CLAS Cymru and for the specific reference to community gardening and allotments at Para 7.25.

b) The HRA concludes that Policy 5 is screened out for the need for further assessment.

RESPONSES

a) Support welcome.

b) Comments noted

Paragraphs 7.27 to 7.29 - Policy 6: Social Infrastr ucture




41684 White Young Green (WYG) for the Local Health Board (ABMU) [2857]

42337 Nathaniel Lichfield and Partners (NLP) for Peter Jenkins

(Re - Glanffrwd Road (CS Ref: PT0011)


ISSUES

a) Strong support for Policy 6 from CLAS Cymru.

b) CLAS Cymru request para 7.29 refers to community growing spaces as an example of essential community facilities.

c) ABMU request that healthcare provision is given consideration when requiring planning obligations to support future development.

d) NLP are concerned that this policy will become too onerous without a clear definition of ‘social infrastructure’.

e) The HRA concludes that Policy 6 is screened out.

RESPONSES


b) Agree Community growing space is a good example of an area that provides an opportunity for informal leisure, healthy lifestyles and social interaction. Add ‘community growing spaces’ to examples at the end of para. 7.29.

c) This will be determined when drawing up a Community Infrastructure Levy (CIL) schedule, appropriate legal agreements or planning conditions.

d) In order to improve the implementation of Policy 6, and also Policy 1 (see previous section of report) it is suggested that the definition of Social Infrastructure in the Glossary be amended to read: "community and cultural facilities provide for the health and wellbeing, social, educational, spiritual, recreational, leisure and cultural needs of the community".

e) Comments noted.

Paragraphs 7.30 to 7.33 - Policy 7: Physical Infras tructure


41919, 41920, 41921, RWE npower renewables

41922




42080 Mrs Henderson



ISSUES

a) DCWW fully support the Policy and highlight that as the Statutory Water and Sewerage Undertaker, DCWW always try to ensure that sufficient infrastructure exists for domestic developments. Where facilities may be deficient, DCWW will review the capital investment programme.

b) RWE Npower renewables welcome the requirement in Policy 7 that development must be supported by appropriate physical infrastructure. Request that the policy/supporting text should explicitly acknowledge that, in the case of renewable and other energy developments, connection to the electrical grid is likely to be a separate consent.

c) The third paragraph of Policy 7 requires that the mechanism of funding and delivery of appropriate physical infrastructure must be confirmed prior to the commencement of development. RWE Npower Renewables request that clarification should be provided on the level of detailed that will be sufficient in order to meet this requirement. Baybrook Ltd consider that the paragraph should be removed from the policy as appropriately worded planning conditions, s106 agreements and CIL agreements are the recognised mechanisms for dealing with infrastructure requirements.

d) The representor considers that road, drainage and utility infrastructure in many rural parts of Gower are not suitable to accommodate further development.

e) WG consider that to help evidence site viability a housing trajectory should be provided showing how sites will be delivered along with required utility, drainage, transport and other supporting infrastructure and funding streams.

f) WG state that the Council should clarify its position on CIL and consider the implications for supporting development of not being able to pool Section 106s and how this fits with any CIL preparation timetable.

g) WG considers that the Council should detail the sites that will be served by Gowerton Waste Water Treatment Works and evidence their deliverability in terms of required supporting infrastructure.

h) The HRA concludes that Policy 7 is screened out.

RESPONSES

a) Support for Policy 7 is welcomed. The Council will continue to work in partnership with DCWW to ensure that the capital investment programme takes into account developments proposed in the LDP.

b) It is acknowledged that in the case of renewables and other energy developments connections to the electrical grid are generally not treated as a


single development that can benefit from a single, comprehensive, development consent. The two components need to be consented, and therefore submitted, as necessary, for approval, separately. Such level of detail will be considered as part of the formulation of appropriate policies established within the Deposit LDP.

c) Paragraph 3 states that “The mechanism for the funding and delivery of appropriate physical infrastructure must be confirmed prior to the commencement of development”. Appropriately worded planning conditions and S106 (CIL) Agreements will ensure that this is confirmed and in place before commencement of development. The Council will review whether this paragraph is needed in the Deposit Plan.

d) Candidate Sites assessments are ongoing. The assessment of the viability and deliverability of sites, and engagement with the relevant infrastructure stakeholders, will be essential and this will continue to be undertaken to inform the Deposit Plan.

e) The Council will produce an Infrastructure Plan to evidence the deliverability of the proposed development sites in the Deposit Plan.

f) The Council is making preparations for CIL and is fully aware of the implications for pooling Section 106 contributions. The Council will produce an Infrastructure Plan to evidence the deliverability of the proposed development sites in the Deposit Plan.

g) There is a firm commitment by all signatories to implementing the provisions of the Memorandum of Understanding (MoU) and its requirements in practice. This multi agency commitment to the MoU remains with cross border collaboration and discussions between the City and County of Swansea and Carmarthenshire ongoing. The MoU Technical Officer Group oversees the revision of the MoU (every six months) and a draft revised version is currently being finalised. Once finalised, the MoU will inform the production of the Pre Deposit Plan and additional revisions in the future will inform further stages of Plan preparation. The Council will produce an Infrastructure Plan to evidence the deliverability of the proposed development sites in the Deposit Plan. With regard to strategic development in the Gowerton Treatment Works catchment area, DCWW have recently made significant improvements and investment in the Works. They have invested in a new hydraulic model for the Gowerton catchment. The findings of which have indicated solutions throughout the catchment and these would have to be delivered prior to development occurring. As part of their interaction with the Memorandum of Understanding (MoU) they are undertaking surface water removal within the Gowerton catchment as part of the existing Asset Management Plan (2010-2015) and will continue with further work in their next Asset Management Plan (2015-2020). This work will help alleviate flooding in the catchment as well as reducing the number of spills to estuarial waters. Furthermore, the LDP will encourage developments to utilise sustainable principles in the design of buildings, promote sustainable drainage systems where ground conditions allow the minimising surface water run-off and flooding, and provide positive contributions to tackling climate change.


h) Comments noted. Paragraphs 7.34 to 7.36 Policy 8: Sustainable Trave l and Accessibility



42090 Stephen Williams



ISSUES

a) Penllergaer Estates support the central objective that development should be directed towards sustainable locations, in particular consider that site GT006 is compatible with this approach.

b) SWWITCH consider that the policy/supporting text should include reference to the role of Travel Planning as a driver for modal shift.

c) SWWITCH consider that the issues set out in criteria (i) of Policy 8 should include a reference to building on the benefits from electrification of the rail line to Swansea.

d) Representor considers that a central goal of the LDP should be to centre the workforce into the city centre to maximise the opportunities and take up of public transport, walking and cycling.

e) The HRA concludes that Policy 7 should be screened out.

RESPONSES

a) Support welcomed. The merits of individual candidate sites will be considered through the candidate sites assessment process which is an ongoing process and is separate to this report.

b) Amend para 7.35 to make clear that the Deposit Plan will set out the role of Travel Planning as a driver for modal shift and facilitating sustainable travel choices.

c) Whilst this is a matter of detail not appropriate for the strategic policy, amend Chapter 6 at para 6.65 and 6.67 ‘Infrastructure and Delivery - Transport’ to state that opportunities for increasing passenger rail travel will be explored including in relation to maximising the benefits for the City Region that can be derived from the electrification of the South Wales mainline, to improve strategic connectivity.


d) The LDP will indeed prioritise the city centre as the preferred location for any new office development (see Strategic Policy 11) and will provide a planning framework that aims to regenerate the City Centre as the commercial and business core for the City Region.

e) Comments noted.

Paragraphs 7.37 to 7.39 - Policy 9: Economic Growth and Employment



42081 Mrs Henderson

41822 White Young Green (WYG) for Sainsburys

41923, 41924, 41925 RWE Npower Renewables


ISSUES

a) Strong support for Policy 9 from CLAS Cymru.

b) Representor considers that farming is integral to the creation of the AONB designation in Gower, playing a key role in the maintenance of the designation and enhancing the landscape. Agricultural land within Gower is therefore a valuable resource in terms of the rural economy.

c) Sainsburys consider that Policy 9 should be amended to specifically recognize the significant value of retailing to the economic and employment well being of Swansea and its population. The Policy should also be amended to reflect the role of ‘non-space uses’, as highlighted in Peter Brett Study.

d) RWE Npower renewables support the general context of Policy 9. In the context of energy generation, RWE refer the Council to the report 'Economic Opportunities for Wales from Future Onshore Wind Development' (Regeneris Consulting Ltd, January 2013) commissioned by Renewable UK Cymru, the Welsh Government and a group of wind farm developers, which sets out the direct, indirect, induced and community benefits associated with onshore wind farms.

e) The HRA concludes that meaningful assessment of potential mitigation measures cannot be undertaken in relation to Policy 9 until the precise location of the development to provide employment opportunities is provided within the Deposit Plan. Further assessment will therefore be required as part of the formal HRA once the precise location for the employment opportunities has been specified.


RESPONSES


b) The policy makes clear it is concerned with development across all sectors, which would include agriculture. The stated aim of enhancing the rural economy is also relevant.

c) It is not considered appropriate for the strategic policy to attempt to highlight all the individual sectors that comprise the local/regional economy or to similarly focus in on any one particular component part.

d) Comments noted.

e) Comments noted. A meaningful assessment of the employment sites will be undertaken for the Deposit Plan.

Paragraphs 7.40 to 7.48 - Policy 10: Retail and Lei sure


41821 White Young Green (WYG) for Sainsburys

42317, 41971 GL Hearn for Hammersons

41977 The Theatres Trust



ISSUES

a) Hammersons support policy aim to direct retail and leisure growth to City Centre at the top of the retail hierarchy to not support out-of-centre retail and leisure development. Agree that LDP should clearly set out the type of investment from all sectors (including retail) that it will support.

b) Sainsbury’s Policy restricts uses appropriate to city centre being permitted at out of centre locations and therefore contradicts PPW. Policy should be more flexible and reflect that assessments of appropriate locations should be based on proposal sensitive factors.

c) Representor requests that Policy should clarify what precise uses are considered "best located in city centre".

d) Sainsburys the amendment of policy to recognise contribution of Sainsbury’s site to city centre despite its edge of centre location. Proposals map should allocate Sainsbury's Quay Parade store within designated city centre or, at least edge-of-centre.

e) The Theatres Trust considers that Policy 11 does not provide sufficient guidance for the protection and enhancement of existing cultural facilities in


the city centre. Para.7.45 explains leisure and cultural uses, but doesn't include sui generis uses, i.e. theatres.

f) The HRA concludes that Policy 10 is screened out.

RESPONSES


b) The policy is concerned with providing clarity as to the retail hierarchy and resisting out of centre development where this would undermine regeneration prospects for the city centre. This is well founded in evidence and a policy aim supported by national guidance. Acknowledge that there may be occasions when an out of centre scheme is permissible in exceptional circumstances, which detailed policies in the Deposit Plan will describe. Amend Policy 10 to clarify that the policy is an overarching principle that does not imply a blanket ban of all out-of-centre development proposals and that there may be exceptional circumstances that justify a departure from this position.

c) The description of retail and leisure uses detailed in the policy is considered sufficient for a strategic level document.

d) It is not appropriate for this strategic policy to refer to individual stores or operators and their functional roles within, or outside, the city centre. Decisions regarding the precise delineation of the city centre area will be a matter for the Deposit Plan and not the Preferred Strategy.

e) Agree that reference to leisure also encompasses potential suit generic uses. Amend supporting text to clarify.

f) Comments noted.

Paragraphs 7.49 to 7.56 - Policy 11: City Centre an d Waterfront


41971, 42317 GL Hearn for Hammersons

41820, 41821 White Young Green (WYG) for Sainsburys



ISSUES

a) Hammersons consider that Policy 11 goes further than the supported aims of Policy 10 by stating all significant retail and leisure development will be directed towards the City Centre and to prioritise redevelopment of the St David's/Quadrant Site. Recognition must be given however to the important /


complementary role Parc Tawe plays in supporting City Centre. It provides for types of retail and leisure that are not suitable for a central city location.

b) Sainsburys consider that it is inappropriate for Policy 11 to state "The City Centre will be the preferred location for all significant retail, leisure and office development", since retail facilities should be located to serve their core catchment areas and certain types of retailing (e.g. convenience retailing) are particularly sensitive to this location characteristic. The policy pre judges the conclusions of any sequential site assessment and, indeed, the fundamental commercial requirements of retailers.

c) The St Davids scheme presents an opportunity to open an east-west road running through that part of Swansea and should not facilitate the creation of another empty shopping centre which will be shut at 5pm each night.

d) The HRA concludes that Policy 11 can be screened out of the need for further assessment.

RESPONSES

a) Parc Tawe is one of a number of sub areas within and on the edge of the city centre that provide complementary roles to the retail and leisure core. It is not appropriate to refer to each of these areas and give an account of their individual functions within this strategic policy. Policy guidance for these areas will be set out in the Deposit Plan.

b) It is imperative that the strategic policy makes clear the priority afforded to the city centre for significant new investment of the nature described, where this would serve more than a localised catchment area. Amend amplification to emphasise that the policy refers to significant development, which would exclude local scale development shown to serve only the local community within which it is located and that would not have any impact beyond that localised area.

c) The Deposit Plan and relevant supporting guidance for the city centre and its major development sites will set out the principles to guide future redevelopment proposals for St David’s.

d) Comments noted.

Paragraphs 7.57 to 7.59 - Policy 12: Tourism


42081, 42077, 42072, Mrs Henderson

42079, 42075, 42074,

42073, 42318

42173 P J Atherton (Surveying) Limited




42000 Barton Wilmore for Baybrook Ltd


ISSUES

a) Farming is integral to the creation of the AONB designation in Gower. Agricultural land within Gower is a valuable resource.

b) Many villages within Gower are full - no further tourist facilities are required. There is a vast variety of tourist accommodation of all standards that can offer year round accommodation. There is an over supply of underused tourist accommodation. Any further/new development for tourism is not only unjustified but will diminish landscape/environment that draws tourists here. Gower’s prime natural tourist resource is the landscape. Areas within Gower are deteriorating rapidly as a result of over visitation.

c) Tourism can have a detrimental impact on a village's identity and village life. Communities in Gower especially in the South are greatly affected by visitors. Currently, when the season is over, villagers and the environment are able to have a rest and reclaim normal village life. Local resources and the area are already degraded from frequent over use. This proposal must be weighed against longer term need of area and wider community.

d) The sea front, including the river corridor, should be developed for bars, restaurants, cafes, parks etc. Not poor quality flats and offices. SA1 has failed to develop appropriate uses – there are no cafes, restaurants, play areas or any other leisure uses that would be there in any other city.

e) Development and tourism efforts need to be aligned to make a coherent tourism strategy.

f) New large scale single operator or a new tourist site should be located on the fringe of the Gower AONB and away from the coastline. Any new development will have an impact on the landscape/environment of the AONB.

g) "Expand" should be further qualified. Small scale expansion in proportion to an existing site may be ok in justified circumstances where sites are improved. It should not provide any justification for unnecessary or mass expansion of existing sites.

h) The policy states that 'proposals for rural tourism related development that seeks to conserve and enhance the County's unique natural heritage will be supported’. Development within the Gower AONB, especially on undeveloped land, will erode this special area not enhance it.


i) I do not agree that tourist developments which aim to extend the tourist season or add to the tourist offer (which is already at capacity in South Gower, Port Eynon especially) should be encouraged.

j) The following should be added:

"Proposals which will improve the quality and/or the visual appearance of caravan and camping sites in the Gower AONB will be supported."

k) The Theatres Trust supports Policy 12 because it will support cultural facilities, although it doesn't state how this will be achieved. Suggest the plan include a definition of what is meant by 'cultural facilities'.

l) Stronger emphasis should be placed on the fact that jobs that can be created through the leisure and tourism industries throughout the County, not just in the City Centre and waterfront. The expansion and enhancement of existing businesses and facilities should be supported throughout Swansea, including within the AONB, given that sustainable development encompasses satisfying economic objectives as well as environmental and social priorities.

m) The HRA concluded that the potential for growth in tourism related development could have a likely significant effect on European sites. In order to reduce this risk, it is suggested that the following wording be incorporated into the policy itself as a mitigation measure: “In order to be in accordance with this plan, tourism related development must be of a nature and scale and in a location that would not be likely to have a significant effect on any of the following European sites, either alone or in combination with other plans or projects and also in combination with any increased recreational pressure arising from additional housing provisions. Any potential in combination effects of tourism and recreation on these and other European sites will be avoided or reduced by evidence-based site and project-specific measures in conjunction with the implementation of the Gower AONB Management Plan.”

RESPONSES

a) Comment noted. National planning policy seeks to protect high quality agricultural land.

b) Comment noted. The Preferred Strategy recognises that there is a need to ensure that tourism doesn’t have a negative impact on the very environment that attracts visitors in the first place and the development of tourism facilities to support economic growth must be balanced with the protection and enhancement of the natural environment .The Council has a duty under the Countryside and Rights of Way Act 2000 to have regard to the purposes of conserving and enhancing the natural beauty of the AONB when carry out its functions. Any new proposal for tourism development accommodation will be carefully assessed against this duty.

c) Comment noted. The Policy introduction states that new proposals will be assessed to ensure that communities are not adversely affected.


d) Comment noted. The Policy, in conjunction with Policy 11: City Centre and Waterfront and the Swansea Bay Strategy, seeks to develop the waterfront, creating sustainable places and maintaining vibrant and attractive communities. New developments will address deficiencies (such as open space) in the area.

e) The Council’s Destination Management Plan is a key corporate document which is taken into account when preparing the LDP.

f) Comment noted. The Council has a duty under the Countryside and Rights of Way Act 2000 to have regard to the purposes of conserving and enhancing the natural beauty of the AONB when carry out its functions. Any new proposal for tourism development accommodation will be carefully assessed against this duty with careful consideration of landscape and seascape visual and landscape impacts.

g) Comment noted. The Objectives set out the strategic aims of the more detailed planning policies to be published in the Deposit Plan. The tourism policies within the Deposit Plan will define what is meant by ‘expand’.

h) Comment noted. The policy seeks to ensure that any proposed development will conserve and enhance the natural heritage of the AONB.

i) Comment noted. The Preferred Strategy recognises the importance of the visitor economy to the economy of the County and is seeking to extend the tourism season in order to benefit the rural economy. This is in accordance with the corporate Destination Management Plan and national tourism strategy.

j) Comment noted. Specific policies in relation to caravan and camping will be contained within the Deposit Plan.

k) Support welcome and comment noted. The term ‘cultural facilities’ includes libraries, museums, art galleries etc. which are part of the cultural environment.

l) Agree. The supporting text will be reworded to reflect the importance of tourism to the County, particularly to the rural economy. The policy does not prevent development but seeks to ensure that any proposed development will conserve and enhance the natural heritage of the AONB.

m) Suggestion noted. The supporting text to Policy 12 Tourism is being amended to refer to ecological impact on European Designated sites. Detailed policies and text will be contained within the Pre-Deposit LDP.

Paragraphs 7.60 to 7.64 - Policy 13: Natural Herita ge and the Cultural and Historic Environment


42081, 42318, 42078 Mrs Henderson

41926, 41927, 41928 RWE Npower Renewables


42149 Barton Wilmore for Baybrook Ltd



ISSUES

a) Both RWE and Baybrook Ltd request that Policy 13 is amended to include the reference set out in the supporting text, to the fact that the conservation and enhancement of the quality of the County’s natural heritage must take place in the context of sustainable development and within the balance of environmental, economic and social needs.

b) The Theatres Trust considers that the policy and supporting text should not cover libraries, museums, galleries and theatres. These are currently included within the term “cultural environment”. The Policy is considered to rightly provide guidance for landscapes and listed buildings but is not considered relevant for community and cultural facilities. The Glossary entry for Cultural and Historic Environments should be amended accordingly.

c) There is a need to protect and conserve good quality farmland as it plays a key role in the maintenance of the Gower AONB and enhances the landscape. Make reference to this in Policy 13.

d) The HRA concludes that Policy 13 is screened out.

RESPONSES

a) An amendment to the policy is not necessary. The Preferred Strategy contains strategic Policy 1 which sets the context for sustainable development along with other subject specific strategic policies which deal with discrete aspects of sustainable development. The plan should be read as a whole and proposals should be considered on their merits against each of the appropriate policies. The balance to be struck between the objectives of each policy is to be determined on a case by case basis.

b) Accept that Museums, Galleries and Theatres primarily function as community and cultural facilities. However, many such facilities are housed in listed buildings and form part of the historic built environment. The text therefore rightly highlights the interaction between historic and cultural environment and the wider cultural context in which the conservation of the historic environment operates. Acknowledge that the policy currently deals only with the preservation or enhancement of the historic environment, despite the reference to the cultural environment in the policy. Recommend that a reference should be included in the supporting text to make clear how the plan is able to influence the cultural environment, and in particular, to place the role of the cultural environment in the context of the wider ongoing corporate work to establish Swansea as the welsh capital of culture. Suggest the following amendments to the supporting text and policy.

7.62 Amend Para 7.63 to add the following before the final sentence.


The significance of the cultural environment to social and economic well-being of the County is recognised by the Council and is reflected in the ongoing work to establish Swansea as the welsh Capital of Culture. The LDP will therefore support the development or enhancement of cultural facilities which will contribute to the preservation or enhancement of Swansea’s cultural environment.

Add the following to the end of Policy 13.

“Proposals for development that seeks to preserve or enhance Swansea’s unique cultural environment will be supported”

c) The term ‘valued countryside’ in paragraph 7.61 includes high quality agricultural land. As a strategic policy it would not be appropriate to list specific elements of the countryside to be protected. More detailed policy will be provided in the deposit Plan. National Planning Guidance requires the protection of high quality agricultural land and consideration of agricultural land quality has formed part of the candidate site assessment.

d) Comments noted.

Paragraphs 7.64 to 7.72 - Policy 14: Safeguarding t he Environment



42076 Mrs Henderson

4231, 418016 Mrs Bridget Stein

41930, 41931, 41932, RWE Npower Renewables

41934, 41935, 41937

41938, 41933

42159, 42160, 42161 The Coal Authority


ISSUES

a) The Coal Authority supports reference to land instability and subsidence in Policy 14 and its supporting text as Swansea has a significant legacy of coal mining activity which can pose a risk for new development.

b) Dwr Cymru Welsh Water supports Policy 14 as it seeks to protect both the quality and quantity of water.

c) RWE npower renewables support the test for ‘unacceptable adverse environmental effects’ in Policy 14 as some development may have


environmental effects that cannot be mitigated absolutely, but can still be acceptable.

d) Mitigation of adverse effects will be difficult to achieve in certain areas e.g. AONB and coastal areas. Development will also affect the rural/visual character of such areas. For tourism development it would be better to improve existing sites.

e) Objection to the use of the word ‘significant’ at the start of Para. 7.67. It is considered that any increase in air, noise and light pollution should be avoided in sensitive locations, particularly the AONB. Request specific policies for light and noise pollution.

f) WG state that the Council should set out clearly how national flood risk policy has been taken into account in the Plan.

g) The HRA concluded that likely significant effects were identified from the Preferred Strategy ‘’alone’’ in relation to effects on the aquatic environment, effects on the marine environment, effects on the coast, effects on mobile species, effects from recreation, effects from air pollution (dust and particulates from construction) and proximity effects (associated with disturbance, noise and light). Amending the wording of Policy 14 would facilitate these effects being screened out of further assessment as part of the formal HRA.

RESPONSES

a)b)c) Support welcome.

d) Para. 7.66 states that ‘the acceptability of adverse effects will depend on the nature of the development and the location’. It is recognised that sensitive locations such as the Gower AONB and coastal areas will be more vulnerable and in such locations the standard of acceptability will be higher. Landscape and seascape protection are considered under Policy 13 Natural Heritage and the Cultural and Historic Environment. Specific Tourism development is considered under Policy 12 and supports proposals that seek to ‘conserve and enhance the County’s unique natural heritage’.

e) In many instances it is impossible to achieve absolute mitigation of adverse environmental impacts and it would be unrealistic and unreasonable to require ‘no air, noise or light pollution’. Instead the policy aims to keep pollution levels to a minimum with acceptable levels dependant on the ‘nature of development and the location’ (para. 7.66 refers). More detailed policies will be provided in the Deposit Plan and consideration will be given to separate policies for light and noise pollution.

f) In order to satisfy the requirements of the Habitat Directive: i. add the following wording to the end of Policy 14:

’Development must not be likely to have a significant effect on any


European Sites, or adverse effects on the integrity of any European Sites either alone or in combination with other plans or projects’’.

ii. Add information relating to mitigation measures that may be required as part of proposed development to the supporting text at the relevant section of Chapter 6.

Paragraphs 7.73 to 7.76 - Policy 15: Minerals


42172 Minerals Products Association (MPA)

41825 Carmarthenshire County Council

42037, 42038, 42039, Dart Energy Ltd

42040


42333 - 42336 Nathaniel Lichfield and Partners for Peter Jenkins

42162 - 42169 The Coal Authority



ISSUES

a) The MPA highlight that the plan does not contain details of minerals to be safeguarded, methodology or locations and draws attention to BGS best practice guidance.

b) Support from MPA for intention to encourage aggregates recycling from Construction and Demolition Waste (CDW). However, consider that a detailed policy is needed to identify sites or criteria for promotion of alternative materials.

c) Include recycling reference within strategic minerals policy.

d) Carmarthenshire County Council acknowledge that discussions have been underway between Swansea, NPT and Carmarthenshire regarding crushed rock reserve held jointly between the authorities. However, highlight that agreement only exists at officer level as the matter has not been progressed politically within Carmarthenshire.

e) Dart Energy highlight that the Preferred Strategy makes no mention of either Shale Gas or Coal Bed Methane (CBM). Although no significant exploration activities have been carried out, these energy sources may be viable in future. Consider that the Preferred Strategy should consider and address exploration, appraisal and production of both Shale Gas and CBM.


f) DCWW fully supports any policy that is designed to prevent any possible derogation of water resources as a result of mineral development.

g) NLP for Peter Jenkins highlight that Mineral Planning Policy Wales confirms that the identification of a safeguarding area "does not necessarily indicate an acceptance of working". Residential development on such areas is not unacceptable in principle, but that the potential for extraction of mineral resources will need to be considered prior to other forms of development. This Policy needs to be re-worded to be consistent with national minerals policy.

h) The Coal Authority is pleased to note in paragraph 7.76 that minerals addressed include coal. Request that the Council clarifies that the coal resources to be safeguarded are those capable of extraction using surface coal mining methods rather than all coal resources.

i) The Coal Authority highlight that the Minerals Safeguarding Area will need to be illustrated on Proposals Map and consider that it is not currently clear within the Preferred Strategy how the safeguarding areas will be defined.

j) The Coal Authority note that there is no policy included in the Preferred Strategy with regard to local requirements for mineral extraction operations. If the Council has taken the decision that no locally distinctive policy is required, the LDP would be enhanced by a clear statement making plan users aware that any new proposals for mineral extraction in Swansea would be determined against.

k) The Welsh Government support the regional approach between Swansea and Carmarthenshire County Council’s with regard to minerals planning. Carmarthenshire County Council should formally agree this regional approach in order to comply with national policy in respect of landbanks.

l) The HRA concludes that Policy 15 is screened out.

RESPONSES

a) Comment noted. Detailed information regarding safeguarding areas will be contained within the Deposit Plan and will follow national planning guidance.

b) Support welcomed – detailed policies will be contained within the Deposit Plan.

c) The policy as worded references re-use and recycled materials.

d) Comment noted. The situation regarding crushed rock landbanks has been revised in light of the updated RTS for South Wales and the Preferred Strategy will be amended to reflect this.

e) Comment noted. Shale gas and Coal bed methane would be considered under a general minerals policy. There is no need for them to have separate policies within the Deposit Plan. Reference to unconventional and conventional gas will, however, be included within the introduction to the


strategic policy to clarify that any proposal to develop those resources will be considered via minerals policy.

f) Support welcomed.

g) Comment noted. The policy amplification will be amended to clarify that safeguarding does not necessarily prevent development, but that the potential for extraction of mineral resources will need to be considered prior to other forms of development.

h) Comment noted. This will be clarified within paragraph 7.76.

i) Comment noted. When preparing the Deposit Plan the mineral safeguarding area will be defined following national planning guidance.

j) Comment noted. The Deposit Plan will contain a mineral policy against which any proposals for new mineral development will be assessed against. The Strategic Policy will be amended to clarify that any new proposal for mineral extraction will be determined against policies contained within the Deposit Plan.

k) Support welcomed. Carmarthenshire County Council continue to assist with mineral planning work but the situation regarding crushed rock landbanks has been revised in light of the updated RTS and the Preferred Strategy will be amended to reflect this.

l) Comments noted.

Paragraphs 7.77 to 7.80 - Policy 16: Waste


41670 Chartered Institution of Wastes Management (CIWM) Cymru [1834]


ISSUES

a) CIWM Cymru Wales is satisfied with the current parts of the document referring to waste (page 75 and 76) - which show that Swansea LDP has picked up on the requirements upcoming of the revised TAN21 - and we approve Swansea LDP's waste policies.

b) The HRA concludes that Policy 16 is screened out.

RESPONSES


b) Comments noted.


Chapter 8: Progress and Future Stages


41950 RPS Planning & Development for site owner CS LF011 & LF012 [14422]


ISSUES

a) RPS Planning for site owner supports Candidate Site submissions LF0011 (The Poplars and its surrounding curtilage); LF012 (Land East of the Poplars, also known as Land at Christopher Rise).

b) The HRA concludes that chapter 8 is screened out for further assessment because it is comprised of contextual information and will not lead to any change that could affect a European Site.

RESPONSES


b) Comments noted.

Appendix 1: National Policy and Legislation


41880 Sustrans Cymru

ISSUES

a) The Active Travel Bill (Wales) should be included in legislative framework for Local Development Plan and it duties reflected in policies set out in Preferred Strategy.

RESPONSES


a) All appropriate guidance and legislation will inform the production of detailed policies as part of the Pre Deposit Plan. As such, the provisions of the Active Travel Bill (Wales) will be taken into account.

Topic Papers

Affordable Housing Topic Paper


41871 Asbri Planning for N Jones & Siblings (site owners BI007 & BI009) [2113]

42059, 42060 Nathaniel Lichfield and Partners for Peter Jenkins –

Glanffrwd Road (CS Ref: PT0011)

ISSUES

a) Support location of Bishopston in South West Viability Sub-market with 20-30% affordable housing requirement. Object to placement of Bishopston in Gower Fringe and 70% requirement in Topic Paper.

b) The Affordable Housing Viability Study acknowledges there will be sites where affordable housing targets will not be achievable and this needs to be translated into housing policy.

RESPONSES

a) Bishopston lies in part within the Gower AONB and part within the Gower Fringe and any development within the area contributes to house build within these SHPZs. It is clearly physically separated from the West SHPZ and cannot be ‘placed’ in this zone to enable a lower affordable housing requirement. Development within the Gower AONB/Fringe should be focussed on meeting local housing needs not adding to the supply of market housing. Acknowledgement of the fact that targets will not be achievable on every site is reflected in the affordable housing target which is 40% below that identified as being needed. The Development Appraisal Toolkit will assess the viability of schemes on a site by site basis and the levels of housing provision sought will be up to the targets identified acknowledging that it will not be possible to achieve these targets in every case. Equally however in some zones where the target is low, such as Swansea East and North, there will be pocket sites where higher levels of affordable housing provision will be viable and it will be important to ensure that housing policies do not preclude this. The Council will ensure that the Affordable Housing Topic Paper is amended at para 7.11 which specifies minimum target levels


Culture and Heritage Topic Paper

Issues relating to Canals and Rivers

Representation Ref Representor 41828 Swansea Canal Society 41943, 41939 Swansea Community Boat Trust 41973 Inland Waterways Association 42034 Jane Hennell 41812 Paul Jones 41969 Mr C J L Yewlett 41993 Dr Gareth W Hughes 41994 H. Martin Smith 41995 David Ramsay 41999 Denis Dodd 42027 Stephen Hayes 42029 Susan Goodyear 42035 Alex Welby 42256 Clive Reed 42258 Rosemary Phillips 42036 Welsh Government

ISSUES

Comments on the Cultural Heritage Topic Paper

a) Concern that there are no proposals relating to the development of the Tawe River navigation for sustainable water transport. Topic paper should give consideration to the findings of the Tawe Riverside Corridor Study, June 2006.

b) At para 10.6 delete "The canal system today has" and insert "The Tawe river navigation, Tennant Canal and Swansea Canal have"

c) Consider that the Deposit Plan must contain detailed polices to support opportunities for the development of water based recreation facilities. Plan should recognise the role of waterways in regeneration and draw on successful examples of canal restoration & regeneration. Consider that the Council should continue the existing strong commitment to protecting the lines of the Swansea and Tennant canals. Concern that weakening this commitment could result in the permanent loss of potential tourism and leisure assets.

d) Deposit plan must contain a policy to safeguard the line of the proposed canal link in the Deposit Plan. Canal link presents important opportunity to protect


local heritage and an opportunity to attract inward investment and create a tourist/leisure amenity (walking, cycling, boating, and fishing).

e) Plan should contain policy to safeguard reserved lines of waterway connecting the Swansea Canal and the Tennant Canal to Swansea Docks, the same as for the current in-water portions of these canals. The entire route must be safeguarded as a heritage site.

f) WG consider that in the Culture and Heritage Topic Paper further analysis is needed into whether there have been any causal links between past levels of development and impacts on the Welsh language. More detailed analysis of welsh medium education data is also required. In particular, the evidence to demonstrate that growth will lead to a decline in the Welsh Language is considered to be unclear.

g) WG consider it is unclear how the Welsh language has been taken into account in the Preferred Strategy, for example in terms of influencing the scale and location of development. The Council should consider the recently published TAN 20 in formulating the Deposit Plan.

RESPONSES

a)b)c) It is clear that the reinstatement of the canal could have recreational and tourism benefits for the County and conserve.

d)e) and enhance part of the County’s heritage. A feasibility study (2002 based) has shown that reinstatement of the canal would result in economic benefits. Discussions have taken place with Swansea Community Boat Trust about their aspirations for the River Tawe and for links to Neath & Tennant Canals, and routes in Swansea via SA1 and Swansea Vale. The Council is talking to interested parties about other development and enhancement proposals which could potentially secure the long term future of viable stretches of the existing Swansea Canal but these are at very early stages and there are concerns regarding the viability and deliverability of the proposals. Development plan guidance requires the Council to demonstrate that all proposals contained in the plan are both viable and deliverable and must evidence this by reference to robust and up to date evidence. We will continue to involve the Canal Society in development proposals that affect the canal corridors which will inform the production of the Deposit Draft LDP. The potential safeguarding of the projected lines of the Swansea and Neath Valleys Waterway Network would be undertaken as part of the Deposit stage rather than being noted as part of the Preferred Strategy.

f) The Council will incorporate the requirements of national planning guidance on the Welsh Language, including the recently published TAN 20, in formulating the Deposit Plan. An updated assessment of the importance of the language within a Swansea context along with the consideration of the potential effect of developments upon the language is currently underway and will inform the production of the Pre Deposit Plan. This will be undertaken in the full knowledge of further practical guidance developed for local planning authorities to assist them with assessing the potential impacts of the LDP


proposals on the Welsh language (via the SA) has recently been published by the Welsh Government, the provisions of which will be fully taken into account.

g) The Welsh Language has been considered within the testing of the Spatial and Strategic Growth Options as part of their assessment against the LDP and SA Objectives of the Plan. The revised Technical Advice Note 20 (Planning and the Welsh Language) states clearly that the Welsh language should be considered during the production of LDPs, as part of the Sustainability Appraisal (SA) process, where local planning authorities have identified the Welsh language as being of importance. This process ensures that the Welsh language can be embedded into the LDP ensuring that all subsequent policies, proposals and eventual site allocations will have considered the impacts on the Welsh language. From a Swansea perspective, SA Objective 6 tests whether the Plan encourages an inclusive society and promotes equality (incorporating the Welsh language) whilst the specific LDP Objectives established seek to reduce the impacts of new development on communities where the Welsh language forms part of the social fabric. This means that the LDP must provide for sustainable development by protecting, and where possible enhancing, the cultural environment whilst facilitating sustainable economic growth and ensuring that all new development is supported by appropriate physical and social infrastructure. Furthermore, the Spatial Options Assessment Topic Paper concluded that whilst the scale of growth proposed had the potential to put pressure on the capacity of social infrastructure, including the Welsh language, the opportunity to masterplan sites would bring positive benefits by ensuring that the Council is able to achieve the objectives of planning for sustainable, distinct communities. An updated assessment of the importance of the language within a Swansea context along with the consideration of the potential effect of developments upon the language is currently underway and will inform the production of the Pre Deposit Plan. This will be undertaken in the full knowledge of further practical guidance developed for local planning authorities to assist them with assessing the potential impacts of the LDP proposals on the Welsh language (via the SA) has recently been published by the Welsh Government, the provisions of which will be fully taken into account.

Design Topic Paper


42263 Crime Prevention Design Advisor

ISSUES


a) South Wales Police Crime Prevention Design Advisor requests that within the Policy Framework section of the Design Topic Paper specific reference should be made to Planning Policy Wales Chapter 9, Paragraph 9.1.2, whilst Paragraph 5.17.1 and 5.17.2 of Technical Advice Note 12 (Design) should be noted. Furthermore, it is questioned whether the Council’s Community Safety Supplementary Planning Guidance should be directly referred to.

RESPONSES

a) The provisions of such guidance will inform the creation of appropriate policies and supportive text that will be established within the Deposit Plan. The policy background identified within the Design Topic Paper only provides an overarching account of the broad legislative framework and does not delve into detail on specific issues. Chapter 9, Paragraph 9.1.2 of Planning Policy Wales highlights the fact that “local planning authorities should promote greater emphasis on quality, good design and the creation of places that are safe and attractive” and this will be reflected in the Deposit Plan. Given that the Supplementary Planning Guidance in question was created to supplement the Unitary Development Plan it is unsuitable to be cross referenced as part of the Local Development Plan preparation. However, given its recent publication it is highly likely that the guidance could be easily updated to reflect appropriate policies that will be established within the Deposit Plan.

Environmental Constraints and Pollution Topic Paper


42260 Swansea Friends of the Earth

ISSUES

a) Bathing water quality of Swansea Bay is likely to continue to fail. Improve access to the relevant data.

RESPONSES

a) Comments noted. Providing information on water quality is a matter for the Council’s Pollution Control Section rather than a Planning policy issue and there is no need to amend the Topic Paper’.

Green Infrastructure (incorporating Open Space Asse ssment) Topic Paper




42291 Jane Hennell


ISSUES

a) Paragraph 4.13 should make reference to the Tawe navigation, Swansea Canal and Tennant Canal as examples of underused greenspaces.

b) Concern with the use of Green Wedges as part of the LDP.

RESPONSES

a) It is clear that the reinstatement of the canal could have recreational and tourism benefits for the County and conserve and enhance part of the County’s heritage. A feasibility study (2002 based) has shown that reinstatement of the canal would result in economic benefits. Discussions have taken place with Swansea Community Boat Trust about their aspirations for the River Tawe and for links to Neath & Tennant Canals, and routes in Swansea via SA1 and Swansea Vale. The Council is talking to interested parties about other development and enhancement proposals which could potentially secure the long term future of viable stretches of the existing Swansea Canal but these are at very early stages and there are concerns regarding the viability and deliverability of the proposals. We will continue to involve the Canal Society in development proposals that affect the canal corridors which will inform the production of the Deposit Draft LDP. The potential safeguarding of the projected lines of the Swansea and Neath Valleys Waterway Network would be undertaken as part of the Deposit stage rather than being noted as part of the Preferred Strategy.

b) It is acknowledged that there needs to be a full review of the existing Green Wedge designations as defined within the UDP. It is anticipated that Green Wedges will continue to be designated within the LDP but their scale and quantity will be far more limited. The Council will fully justify their inclusion within the Deposit Plan which will be informed by the evidence base and sound SEA/SA.

Housing Topic Paper


42238 Boyer Planning for Persimmon Homes West Wales Ltd

42297 Home Builders Federation

41809, 41810, 41811, RPS Planning & Development for Swansea University


42182, 42181, 42180

42057 Mr Andrew Bevan for Mr Layth Jabar

42061 Nathaniel Lichfield and Partners for Peter Jenkins –


42245 Sandy Johns


ISSUES

a) Perceives that the housing requirement is too low.

b) Perceives that the housing requirement is not aligned with the job growth strategy.

c) Perceives that the housing requirement is too low and will not deliver sufficient affordable housing.

d) States that the level of allocations should include a 10% flexibility allowance.

e) Reserves the right to comment on the housing requirement until more up to date evidence is available.

f) Expresses concern regarding the land supply components (e.g. reliance on windfall and JHLAS 3(i) sites).

g) Suggests that the wording of Policy 2 under bullet point iii) needs to be amended to reflect that both small and large scale edge of settlement extensions will be required.

h) Perceives that Table 7.9 in the Economic Growth Assessment is out of date.

i) Perceives that the Viability Study does not consider cumulative impacts of affordable housing and other planning obligations.

j) Site submitter supports identification of Hendrefoilan as a potential residential development opportunity but states that the capacity of the Hendrefoilan site is over estimated in the Preferred Strategy.

k) Puts forward additional land for consideration by the Council.

l) Support for hybrid spatial strategy approach.

m) Support for Council findings in terms of the amount of industrial and warehouse floorspace within the City.

n) Site submitter wishes to contribute to the development of a flexible and mixed use policy approach to regeneration and development of its land to the east of Swansea Port south of Fabian Way.

o) Site submitter is promoting their Candidate Site and its perceived merits within the identified Preferred Strategy.


p) Perceives it is not clear to what extent the regional context has been taken into account.

q) Questions whether assumptions taken in the Economic Growth and Employment Land Assessment are realistic.

r) Queries whether account has been taken of emerging housing needs from the existing population in Swansea.

s) Queries what year has been used as the base date of the economic forecasting.

t) Queries whether account has been taken of vacant or second homes.

u) States that the LDP should identify returning houses of multiple occupation to family homes as a means of providing for the identified housing requirement.

v) Queries why the Council has deviated from the migration data in the 2008 based WG projections.

RESPONSES

a) Since publication of the LDP Draft Preferred Strategy, WG has released its 2011 based household projections for Local Authorities in Wales. Initial analysis appears to show that the projection advocated by the Council for the City & County of Swansea in the Draft Preferred Strategy is in-line with the new 2011 based WG projection (plus a 10% flexibility allowance) for the LDP period 2010-25. The Council is currently updating the LDP evidence base supporting studies with the new projections.

b) The Plan’s economic and housing strategies are very much aligned. The Economic Growth and Employment Land Assessment has forecasted employment growth for the City & County of Swansea over the Plan period, based on an aspirational higher growth scenario, and the number of homes required to support this growth has been assessed as part of this analysis. The dwelling requirement finding from this economic growth analysis was very closely aligned with the dwelling requirement derived from the Council’s household projection advocated in the Draft Preferred Strategy.

c) Since publication of the LDP Draft Preferred Strategy, WG has released its 2011 based household projections for Local Authorities in Wales. Initial analysis appears to show that the projection advocated by the Council for the City & County of Swansea in the Draft Preferred Strategy is in-line with the new 2011 based WG projection (plus a 10% flexibility allowance) for the LDP period 2010-25. The Council is currently updating the LDP evidence base supporting studies with the new projections.

d) The Council is currently updating the LDP evidence base supporting studies with the new WG 2011 based household projections. This provision will include the Welsh Government’s requested 10% flexibility allowance to allow for uncertainty regarding the delivery of sites and unforeseen issues.


e) Comment noted.

f) Some allowance for windfall sites will be made as these will inevitably come forward during the Plan period, but sufficient land to provide homes to meet the identified housing requirement for the City & County will be allocated in the Deposit Plan. Assessment of the viability and deliverability of sites will continue to be undertaken to inform the Deposit Plan.

g) Larger scale settlement extensions are covered by bullet point ii.

h) 2010 data has been used in Table 7.9 to indicate the baseline year for the LDP period of 2010-25.

i) Not accepted. The Affordable Housing Viability Study follows the adopted Wales Development Appraisal Toolkit and its parameters were agreed in advance with stakeholders including the development industry. The methodology clearly shows that when assessing residual site value (the difference between scheme revenue and scheme costs including provision for a reasonable developer profit), allowance is made for Section 106 and Community Infrastructure Levy contributions as well as affordable housing provision in order to determine whether a site is likely to be brought forward for housing. The cumulative impact of costs for specific development proposals, and of developments within the wider area, is taken into consideration within the Study.

j) The assessment of Candidate Sites is ongoing to inform production of the Deposit Plan. Capacities on sites that are proposed for allocation by the Deposit Plan will be based on the most up to date evidence.

k) The assessment of sites is ongoing to inform production of the Deposit Plan.

l) Support for hybrid spatial strategy is welcomed.

m) Support for Council’s Employment Land Assessment is welcomed.

n) The Council is working with the Candidate Site submitters in the area between the Docks/Langdon Road and the new University Campus south of Fabian Way to agree a parcel plan to guide the regeneration of this area. This work is taking place within the wider context of the masterplanning of the Fabian Way Corridor with Neath Port Talbot Council.

o) The assessment of Candidate Sites is ongoing to inform production of the Deposit Plan.

p) In-line with National Planning Guidance, the Wales Spatial Plan and City Region context, the Council has jointly with Neath Port Talbot County Borough Council undertaken a Sub-regional Strategic Housing Market Assessment and an Economic Growth and Employment Land Assessment in recognition of the identified sub-regional geographical extent of the local housing and employment markets.


q) The assumptions taken in the Economic Growth and Employment Land Assessment are based on the professional judgement of independent expert consultants in this field.

r) The dwelling requirement advocated by the Council for the City & County in the Draft Preferred Strategy is based on the official 2008 based WG household projection for Swansea, the only variation being that it projects forward migration data for a more recent period (2004-09).

s) The base date of the economic forecasting in the Economic Growth and Employment Land Assessment is 2010 in-line with the LDP period of 2010-25.

t) The Council’s own projection, on which the dwelling requirement advocated in the Draft Preferred Strategy is based, does include a scaling factor to account for vacancy/second homes. An in-house update of the Economic Growth and Employment Land Assessment has recently been undertaken using the same scaling factor.

u) This is outside the remit of planning policy and is more down to market forces and landlord investment decisions.

v) The projection advocated for the City & County of Swansea in the Council’s Draft Preferred Strategy is based on the WG (2008 based) household projection but includes migration data for a more up to date period (2004-09), removing the peak of internal (UK) migration observed in 2003-04 and including the on-set of the economic crisis in 2008-09.

Minerals Topic Paper


42259 Swansea Friends of the Earth

42319 Minerals Products Association

ISSUES

a) Onshore oil and gas operations should be dealt with by an individual policy, not within the general mineral policy.

b) Reflect the apportionment allocation as set out within the 2008 RTS.

c) Identify areas of search within the LDP.

d) Suggest a new mineral supply policy (rep contains suggested wording).

RESPONSES

a) Comment noted. Following advice from the Welsh Government, it is likely that onshore oil and gas exploration policies will be contained within a single mineral policy.


b) The 2008 RTS has been superseded by the First Review RTS which was endorsed by the Council in April 2014. The Deposit Plan will reflect the recommendations contained with in the First Review document.

c) Comment noted. The council will further consider whether it is appropriate to identify areas of search for aggregates within the Deposit Plan.

d) Suggestion noted and a new policy will be drafted.

Natural Heritage and Countryside Topic Paper



ISSUES

a) Swansea Community Boat Trust Paragraph 4.17 of the Natural Heritage and Countryside Topic Paper should make specific reference to the footpath alongside Tawe river navigation, the Swansea Canal towpath and the cycle path alongside the Tennant Canal, in the context of expanding access to the countryside.

RESPONSES

a) Paragraph 4.17 is a generic, overarching statement which does not intend to provide a full account of actual provision. In order to be consistent, to make the highlighted changes to the text would also require the individual naming of commons, rivers and disused railway lines which would make the sentence unwieldy. No changes are therefore proposed to the text.

Physical Infrastructure Topic Paper



ISSUES

a) DCWW request that any references to the "Fabian Way WwTW Catchment area" within this topic paper be amended to read Swansea Bay WwTW Catchment area.

RESPONSES


a) Comments noted. All future references to the "Fabian Way WwTW Catchment area" will read Swansea Bay WwTW Catchment area. Existing published documents will be revised as and when they are reviewed.

Strategic Growth Options Assessment

Representation Representor

42062 Nathaniel Lichfield and Partners for Peter Jenkins –


ISSUES

a) Objects to the perceived low housing requirement.

b) Perceives that the extent to which other Plans in adjoining areas have been considered in determining the housing requirement is unclear.

c) Perceives that it is unclear whether the Plan’s economic and housing strategies are aligned.

d) Queries whether emerging housing needs from the existing population have been considered.

e) Queries which year has been used as the base date of the economic forecasting.

f) Queries whether vacant and second homes have been considered.

RESPONSES

a) Since publication of the LDP Draft Preferred Strategy, WG has released its 2011 based household projections for Local Authorities in Wales. Initial analysis appears to show that the projection advocated by the Council for the City & County of Swansea in the Draft Preferred Strategy is in-line with the new 2011 based WG projection (plus a 10% flexibility allowance) for the LDP period 2010-25. The Council is currently updating the LDP evidence base supporting studies with the new projections.

b) In-line with National Planning Guidance, the Wales Spatial Plan and City Region context, the Council has jointly with Neath Port Talbot County Borough Council undertaken a Sub-regional Strategic Housing Market Assessment and an Economic Growth and Employment Land Assessment in recognition of the identified sub-regional geographical extent of the local housing and employment markets.

c) The Plan’s economic and housing strategies are very much aligned. The Economic Growth and Employment Land Assessment has forecasted


employment growth for the City & County of Swansea over the Plan period, based on an aspirational higher growth scenario, and the number of homes required to support this growth has been assessed as part of this analysis. The dwelling requirement finding from this economic growth analysis was very closely aligned with the dwelling requirement derived from the Council’s household projection advocated in the Draft Preferred Strategy.

d) The dwelling requirement advocated by the Council for the City & County in the Draft Preferred Strategy is based on the official 2008 based WG household projection for Swansea, the only variation being that it projects forward migration data for a more recent period (2004-09).

e) The base date of the economic forecasting in the Economic Growth and Employment Land Assessment is 2010 in-line with the LDP period of 2010-25.

f) The Council’s own projection, on which the dwelling requirement advocated in the Draft Preferred Strategy is based, does include a scaling factor to account for vacancy/second homes. An in-house update of the Economic Growth and Employment Land Assessment has recently been undertaken using the same scaling factor.

Tourism Topic Paper


42098 Tourism Swansea Bay Ltd

42174 P J Atherton (Surveying) Limited


42082, 42069 Mrs Henderson

ISSUES

a) Accurate assessment of issues.

b) Pleased areas outside Gower are given attention.

c) Agree with current policy.

d) Treat tourism as a business/product and be less restrictive on developments.

e) Visitors are having shorter stays.

f) Allow developments which would increase wet weather tourism facilities on Gower.

g) Increase events which attract frequency of visitors to area but not necessarily increase development, such as the Folk Festival.

h) Support the notion that the AONB is a unique landscape that should be maintained, but a system that favours a presumption in favour of conservation


against development is a dangerous one and works against the Welsh Governments aim of increasing tourism by 10% by 2020.

i) The AONB suffers from a lack of serviced high quality accommodation which would attract high spending visitors in lower numbers, thereby creating less ‘footprint’.

j) Greater emphasis needs to be placed on not just the number of bed spaces in terms of the quantity but also focus on the quality and range of accommodation available to suit all visitor needs whether these be for camping or caravanning or top quality hotels.

k) Need to attract high spending visitors in lower numbers, thereby creating less ‘footprint’.

l) Need to promote/include dog walkers as part of tourism asset as walkers help counter seasonality and recognise them within the Right of Way Improvement Plan.

m) Planning policy should not add to the challenge of increasing visitor yields during difficult economic times.

n) Will the development Plan facilitate a strengthening of our competitive position and improve the performance of the tourism sector in Swansea?

o) The Council has not attached enough significance to the role Swansea will play in achieving the Welsh Government’s growth figure. We need favourable planning policy which acknowledges the contribution tourism makes to the Welsh economy and facilitates future growth rather than stifling it.

p) In order to meet the challenging targets set by the Welsh Government the Council should be seeking to promote development in order to stimulate the economy.

q) Designate certain areas within the County as 'Tourism Growth Areas' where there would be a presumption in favour of appropriate tourism related development, helping to relieve pressure on honey-pot and environmentally sensitive areas of the County. For instance areas such as the M4 corridor, Felindre, Lower Tawe Valley, former docks, specific bayside locations and so on could be suitable for such designations.

r) Produce evidence to support assertion that “many touring sites are moving towards offering 'seasonal' pitches, where touring caravans can be parked for the whole season and guarantee the operator income. This reduces number of touring pitches available and results in demand for additional pitches." Or delete comment.

s) No Caravan and Camping Topic Paper in existence.

t) Findings of the Caravan and Campsite survey 2012 not been made public.


u) The LDP needs to make reference to the emerging Sustainable Tourism Strategy.

v) Tourism can have a detrimental impact on villages.

w) No need for large scale new tourist sites. Sites should be on fringe of AONB away from coastline.

x) Farming is integral and agricultural land is a valuable resource. Diversification can lead to loss of skills.

y) Wide variety of tourist accommodation exists. Expansion or further caravan sites should be avoided.

z) The importance of the tourism sector to job creation needs to be acknowledged within the LDP.

aa) Growth is not appropriate in all locations.

RESPONSES

a)b)c) Support welcomed.

d) Comment noted. The visitor economy is viewed as a key part of the County’s economy. . The Council fully realise the importance of the visitor economy to the County’s economy and are committed to increasing tourism revenue and extend the tourism season. Proposals for appropriate tourism developments will be supported by planning policy and visitor numbers and have increased since 2007 and tourism figures in 2013 show a 4% growth in visitor revenue since the previous year. Planning polices cannot therefore be accused of restricting growth in the visitor economy.

e) Comment noted.

f) Comments noted. The lack of wet weather attractions on Gower is acknowledged within the Topic Paper. It has previously been acknowledged within the Gower Management Plan and was highlighted as an issue in the Council’s 2012 Visitor Survey. The Topic Paper acknowledges that there is scope for the development of additional tourist developments; either within the AONB or on the fringe of the AONB to provide attractions such as indoor play areas, climbing walls, bowling alleys etc which can be accommodated within barn type structures as part of farm diversification. There may also be opportunities to develop new attractions related to the heritage, culture or physical characteristics of the county. Detailed policies will be contained within the Deposit Plan.

g) Comment noted and passed onto the Tourism Section of the Council.

h) Comment noted. The Council has a statutory duty under the CRoW Act 2000 to have regard to the purposes of conserving and enhancing the natural beauty of the AONB when carry out its functions, this includes when assessing any planning application within the AONB. The planning system


must reconcile the needs of development and conservation, securing economy, efficiency and amenity in the use of land, and protecting natural resources and the historic environment in order to contribute to sustainable development. The Welsh Government’s tourism earnings growth figure of 10% between 2013 and 2020 is for the whole of Wales – it recognises that 10% growth in tourism earnings will not be achieved in some geographic areas, but will be exceeded in others. The Welsh Government’s Tourism Strategy also recognises that the natural environment is a key asset and a central reason why visitors choose to holiday in Wales and that we must take account of the characteristics of the natural environment when considering how to grow tourism sustainably. The Council is already going some way to meet the 10% growth in tourism earnings figure with the 2013 tourism figures showing a 4% growth in tourism revenue since the previous year

i)j) Comment noted. This lack of high quality serviced accommodation in Gower, together with the need to improve the quality and offer of camp sites has been recognised for a number of years – the current development plan seeks to improve the quality and choice of both serviced and un-serviced tourist accommodation and this is recognised within the Tourism Topic Paper and also within the Destination Management Plan. However, planning policies can only facilitate the development of proposals, a number of proposals with planning permission have not been implemented.

k) Comment noted. The development plan, together with the Destination Management Plan, are working to develop and promote Swansea Bay as a world class visitor destination. It is acknowledged that care must be taken not to increase pressure in many vulnerable areas and thus spoil the environment which attracts visitors.

l) Comment noted. Dog walkers can use any Right of Way. The Council produces leaflets promoting walking routes within the County and a ‘Dogs on Beaches’ leaflet which details which beaches dogs are allowed on.

m) Visitor numbers and revenue have been greater over the years of the economic downtown than experienced in 2007 and prior to that date. In 2013 a record number of visitors spent £360 million (STEAM Statistics). It is therefore unlikely that planning polices are restricting growth in the visitor economy but do have a role to play in ensuring it grows sustainably. Proposals for appropriate tourism developments will be supported by planning policy.

n) Comment noted. The Council fully realise the importance of the visitor economy to the County’s economic wellbeing and are committed to increasing tourism revenue and extending the tourism season. Proposals for appropriate tourism developments will be supported by planning policy. Detailed policies will be contained within the Deposit Plan.

The development plan, together with the Destination Management Plan, is working to further develop and promote Swansea Bay as a world class visitor destination.


o)p) Comments noted. The Council fully realise the importance of the visitor economy to the County’s economic wellbeing and tourism revenue and visitor numbers have both grown over the last 10 years. The Welsh Government’s tourism earnings growth figure of 10% between 2013 and 2020 is for the whole of Wales – it recognises that 10% tourism earnings growth will not be achieved in some geographic areas, but will be exceeded in others. The Council is already going some way to meet this figure with 2013 tourism figures showing a 4% growth in tourism revenue since the previous year. The Welsh Government’s Tourism Strategy also recognises that the natural environment is a key asset and a central reason why visitors choose to holiday in Wales and that we must take account of the characteristics of the natural environment when considering how to grow tourism sustainably. The Destination Management Plan aims to encourage the private sector and Council to work together to promote tourism in the County. Proposals for appropriate tourism developments which will enable sustainable tourism growth will be supported by planning policy. Detailed policies will be contained within the Deposit Plan.

q) Comment noted. The Swansea Bay Strategy and Unitary Development Plan (policy EC16) already promote nodes around Swansea Bay for tourism/recreation development. Furthermore, the UDP supports tourism/recreation developments in the north of the County, in order to increase the tourism offer and increase the rural economy. Paragraph 7.2 of the Topic Paper acknowledges that areas of Gower are at capacity and that the north of the County are underused as a tourism resource. LDP policies will continue to promote nodes around Swansea Bay as tourism/recreation development areas and Mawr as a tourism resource and tourism ventures which will help regenerate former industrial areas.

r) Comment noted. The evidence was gathered through discussions with site operators, many of whom would like to increase the number of seasonal pitches on offer – this can be done without planning permission and many have done so. Furthermore, it is logical that a touring caravan pitched on the same pitch all season will thus render that pitch unavailable for other users.

s) Comment noted. It was the intention to publish a Caravan and Camping Topic Paper alongside the Tourism Topic Paper. This did not happen and the Tourism Topic Paper has been amended to reflect this.

t) The findings of the 2012 Caravan and Camping Sites have not been made public, but will be contained within a Caravan and Camping Background Paper which will accompany the Deposit Plan.

u) Comment noted. The LDP will refer to the Sustainable Tourism Strategy.

v) Comment noted. It is acknowledged that tourism can have detrimental impact on villages and policies will ensure that proposals are carefully assessed to ensure that there is no significant detrimental impact on village character or amenity.


w) Comment noted. Any proposal would be carefully assessed for landscape, seascape and environmental and amenity impact and it may be possible to accommodate new developments without detriment. The development plan aims to encourage new development away from the undeveloped coastline. Detailed policies will be contained within the Deposit Plan.

x) Comment noted. Farming is acknowledged to be important to the rural economy and the means of maintaining and safeguarding the rural landscape. National planning policy seeks to protect good quality agricultural land from development.

y) Comment noted. Blanket restrictions on camping and caravanning site expansion throughout the County are not considered appropriate. The current development plan allows limited expansion of sites within the AONB and promotes development in the north of the County. The Council has published a Landscape Capacity Study for Camping and Caravan Sites within the AONB, which highlights areas where the landscape is at capacity in terms of caravan and campsites and where capacity exists for new/expansion of existing sites. This document will be used to help assess future applications for caravan and campsites within the AONB.

z) Comment noted. The Preferred Strategy and Tourism Topic Paper acknowledge that Tourism is a key sector of the County’s economy and this will be recognised within the Deposit Plan.

aa) Comment noted. The Preferred Strategy and LDP acknowledge the need to carefully balance tourism development and protection of the environment. It is agreed that growth is not suitable in all locations; some are at saturation in terms of landscape capacity.

Transport and Accessibility Topic Papers



41655 Mr & Mrs Robert & Kimberley Walker

41661 Mrs Angela Bridges


ISSUES

a) States that any proposals to alter the water level within the Prince of Wales Docks will need to be carefully assessed as there is a direct hydrological link between Crymlyn Bog SAC and the Kings and Queens Docks and Tennant Canal. Development within the Port should safeguard the canal route protection corridor.


b) Concerned that Felindre development will generate extra traffic on Swansea Road.

c) Perceives that public transport needs improvement in frequency, and coverage at Glanmor Hill, Uplands, in college holidays, evenings and Sundays.

d) Concerned that development in West Cross would exacerbate congestion and pollution issues in Mumbles.

RESPONSES

a) Comment noted. The Council is fully aware of these important considerations which it has identified in the Transport and Accessibility Topic Paper.

b) The Council intends to commission a County wide transport assessment of the key strategic development proposals to be identified in the final LDP Preferred Strategy. This assessment will be an important element in demonstrating the soundness of the LDP, particularly in respect of quantifying the impact of its strategic proposals upon the transport network and demonstrating the sustainability of identified sites.

c) Your comments have been passed on to the City & County of Swansea Transport Team, which is responsible for the provision of subsidised local bus services, including Gower Explorer & LliwLink, and works closely with private operators which run the majority of services in Swansea (e.g. First Cymru). The Council’s Passenger Transport Team can be contacted on 01792 636466 / [email protected].

d) The Council intends to commission a County wide transport assessment of the key strategic development proposals to be identified in the final LDP Preferred Strategy. This assessment will be an important element in demonstrating the soundness of the LDP, particularly in respect of quantifying the impact of its strategic proposals upon the transport network and demonstrating the sustainability of identified sites.

Socio-Economic Ward Profiles



41980, 41981 Mr John Gratrix

41657 Ruth & John Gray

41656 Ruth Gray

ISSUES


a) No mention of the Swansea Canal in the text of the Ward Profile Summary even though a photograph is displayed.

b) In response to one of the questions within Cockett Ward Profile – Believes that Cockett Valley Green Wedge and Open Countryside should be maintained.

c) Queries why Candidate Site CO017 (Land adjacent to Hillcrest, Cockett) has been referred to Stage 2 when there has been substantial local opposition and that it is currently positioned within a Green Wedge.

d) Limited open space provision and Public Rights of Way in Cockett.

e) Additional housing could be accommodated on Cockett Homes land.

f) Cefn Coed Hospital, Sketty could provide some community facilities and some parkland/walks etc.

RESPONSES

a) The Ward Profile summaries are not all encompassing documents therefore only cover certain issues. Documents such as the Natural Heritage and Countryside/Green Infrastructure Topic Papers make reference to the Canal system and further more specific references will form part of the Pre Deposit LDP.

b) Comments noted. Refinements to individual settlements and designations will inform the production of the Pre Deposit LDP due to be published late 2014.

c) Comments noted. The assessment of Candidate Sites is currently ongoing and all representations previously made have been taken into account. The Stage 1 filtering of sites was published during March 2012 whilst the outputs of the Stage 2 filtering form part of this report.

d) In defining land for development within the LDP full regard must be given to the Open Space Assessment that provides a full account of whether there is a surplus or deficiency in Fields in Trust (formal) provision or Accessible Natural Greenspace. In areas of limited open space, it is important that the creation of new open spaces is encouraged and that existing spaces are retained and improved where possible. Valuable existing facilities should be protected whilst the provision of new and improved open spaces should be facilitated. In addition, where there are examples of deficiencies with Wards opportunities may exist in improving the quality and accessibility of provision which may include investment in drainage or ensuring that previously closed education sports facilities are made more accessible to the wider community.

e) Sites with development potential and sites other than Candidate Site submissions (inclusive of settlement refinements) are also in the process of being considered and will inform the Pre Deposit Plan which is due to be published during the latter part of 2014.


f) Comments noted. Land at Cefn Coed Hospital forms part of UDP housing allocation HC1 (128). In addition Policy HC14 highlights the fact that the comprehensive redevelopment of the hospital would require the retention and enhancement of important landscape features and open spaces, natural heritage and historic environment.

SA Environmental Report



41674 Mr Andrew Walters

41665 David Owen Lewis

ISSUES

a) Carmarthenshire County Council support the document.

b) Strongly agree with Key Issues and Drivers - Economy section.

c) No order of preference between ‘brownfield’, ‘edge of settlement’ and ‘infill’ – could result in destructive infill.

d) Tidal Lagoon needs greater mention.

e) Regeneration is focused on St David’s Centre/Quadrant but doesn’t seem to know what to do with High St/Kingsway/Lower Oxford St.

f) Garden Village settlement boundaries should be maintained. Infrastructure and schools are at capacity.

RESPONSES

a)b) Support noted.

c) Comment noted. All sites will be subject to assessment to ensure that they are sustainable and do not result in loss of ecology or habitat.

d) Tidal Lagoon does not form part of the Preferred Strategy. It is a private development, which the Council has no control over. The majority of it is located below the low water mark and is therefore assessed by Central Government, not the Council. By the time the LDP is placed on Deposit the Lagoon may or may not have been granted planning permission.

e) The Deposit Plan and associated supplementary guidance will set out a range of polices and proposals relating to the city centre, which will include a focus on High Street as a key complementary area to the retail and leisure core. This will emanate from the ongoing work assessing the strategic planning


framework for the City Centre that takes a comprehensive approach to land use and delivery of future investment.

f) Comment noted – The assessment of the Candidate Sites is an ongoing exercise .

Habitat Regulations Assessment



ISSUES a) Carmarthen County Council welcome the HRA Report and to contributing to ongoing collaborative consultations between authorities.

b) Carmarthen County Council is of the opinion that the MoU and compensatory water removal model provides a key indicator of deliverability and as such there is detailed cataloguing thereof within the CCC LDP evidence base. Paragraph 7.8 - Reference to the HRA assessment of the Carmarthenshire LDP is welcomed.

RESPONSES

a)b) Support welcomed.


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Assessment Outputs

Sustainability Appraisal/Strategic Environmental Assessment

The Sustainability Appraisal (SA) of the draft Preferred Strategy of the Swansea LDP was undertaken. The process involved testing the Preferred Strategy against the SA framework to determine whether the principles of sustainable development had been fully embedded in this initial stage in the LDP preparation. A crucial part of the process involved recommending appropriate changes leading to increased promotion of sustainable development.

The full report is available via: http://www.swansea.gov.uk/ldpsasea

Habitats Regulations Assessment

The deposit LDP will be subject to a full Habitats Regulations Assessment (HRA) in accordance with the regulations. It is good practice to ensure that the requirements of the regulations, and the potential effects on European Sites, are considered as an iterative process from the earliest stages of the plan making process. For this reason a HRA screening of the LDP Preferred Strategy has been carried out.

The full report is available via: http://www.swansea.gov.uk/ldphra


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Appendix 5

Draft Proposals Map Consultation Details



• LDP Advisory Group Meeting 18th December 2014

o Publicity

Online

• The LDP web page provided coverage and a link to dedicated Draft Proposals Maps dedicated web pages.

• Dedicated pages for the Draft Proposals Maps consultation on the Planning Policy Pages of the Council website (www.swansea.gov.uk/ldpdpm).

• The JDi e-consultation website was used http://swansea.jdi-consult.net/ldp/ and during the consultation period (4th December 2014 – 16th January 2015).

• PR team press releases:

• Residents views sought on major development plan for Swansea (19/12/14) http://www.swansea.gov.uk/article/11141/Residents-

views-sought-on-major-development-plan-for-Swansea

• Closing date nears for views on major development plans for Swansea (/01/15) http://www.swansea.gov.uk/article/11369/Closing-date-nears-for-views-on-major-development-plans-for-Swansea

In Print

• These press releases generated 6 articles in the local newspaper the Evening Post from 19th December to 9th January.

• Details of the consultation and the LDP process were featured in an article in the December 2014 edition of the Swansea Leader and in the January 2015 edition.

At Council venues

• Consultation appeared on the TV screens in the Contact Centre and Central Library.

• Bilingual posters displayed in the Civic Centre reception



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• Email to all consultees RE: consultation update – 4th December 2014

• Email to all consultees RE: LDP Update 2015 – 10th March 2015


Document

Respondents

Objectors

Support

Object

Comment

Representations

Draft Proposal Maps

39 24 4 28 17 49

Totals

39 24 4 (8.2%)

28 (57.1%)

17 (34.7%)

49

Summary of Representations Overleaf


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Summary of Representations: Draft Proposals Map

Bishopston

Consultee Name Summary of response Type of representation

M Lewis Object to the exclusion of Holts Field from the settlement. Object

Castle


A. Bowden Building should be kept to the city centre, openness and natural beauty of coastal areas should be preserved and maximised, open space enhances quality of life, Civic Centre should remain with similar usage. Many comments are made about the way Swansea is currently planned: how and by whom? Land train could be put to better and more use. Alternative transport to Mumbles which could ease congestion. Road works take an unrealistic amount of time to complete. Drainage in city centre that results in flooding! No unified approach to development. Many errors are being made.

Comment

Liberty Maybe the process would be more transparent if there was some basis of calculation for the 800 units proposed, which encompasses the City entre Fringe strategic site.

Comment

Trilein Ltd We are currently conducting a Swansea Eastside Connections strategy for Natural Resources Wales, which includes the Lower Tawe, Kilvey Hill, Crymlyn

Comment


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Bog and the Tenant Canal. The work will consider connectivity of the banks of the Lower Tawe (some falling in Castle Ward) with consideration of flood alleviation measures. The work is due for completion on 31st March 2015.


Land at the west of High Street and rear and north of St Matthew’s Church, no number given in your documentation. There is a significant restraint to this as there is a known Cholera Pit in the area dating from the mid-19th Century. Any development would require a significant input to deal with the potential for a health risk and to ensure that the human remains are appropriately dealt with in accordance with Ministry of Justice Regulations regarding archaeological exhumations.

Comment

Clydach


J. Williams With regard to the proposed dwelling on the waste land opposite the junction of Bryn Road and Heol Eithrim I would have no objection.

Comment

S. & M. Bowmer We have no objections, we offer full support to the plans to pit one large dwelling in the site opposite out house, in face we welcome the site being used. Anti-social behaviours occur onsite.

Comment

J. C. Richards I would like to support the application to build a property on land on Heol Eithrim. The land is directly opposite my property. At the moment there is antisocial behaviours on site.

Comment

J. Lewis Regarding the development of the land to the left of the end of Heol Eithrim and beginning of Bryn Road. The building of a character house with sympathetic

Comment


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landscaping can only be good for the area.

M. Sykes (two representations)

Detailed site history, and current state. Mentions discussions with neighbours and positive feedback.

Comment

Cockett


P. Cole Agent for ALCOA

Alcoa Manufacturing (GB) Ltd are pleased to note that central to the Strategy is the premise that the proposed comprehensive redevelopment of this Strategic Site will enable the delivery of a new highway link from the A484 Llanelli Link Road to the north, which will in turn open up significant brownfield development opportunities at Westfield Industrial Park through the alleviation of access restrictions. The opening ip of improved links to Gowerton Rail Station as part of the comprehensive master planning approach is welcomed.

Support

JCR Planning We have been instructed to make an objection with respect to the area covered by the proposed Retail Park. While the formal recognition by the Authority of the area as a Retail Park is welcomed and supported, it is felt that the inclusion of the land edged red on the attached plan would enable the logical completion of this successful commercial area. To exclude it from the designation could create uncertainty and confusions for future investors to the Park and result in a vacant, undeveloped and underused site. It is therefore requested that the land be formally included within and designated as part of the allocation.

Object

Graham King, Environmental

You kindly met me before Christmas to assist in defining boundaries for a site off Bridge Road, Waunarlwydd that may have implications for the allocation on your pre-deposit draft plan for the area. I am forwarding you a copy of the site in

Comment


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Planning question and would like to place a holding observation suggesting the allocation of the site for residential development. I am meeting the owner on Monday 26th January. On that occasion I will inspect the site with him to consider inclusion in the residential allocation. If necessary we will consider an ecological appraisal and speak to the development promoter.

Fairwood


D & J Thomas Suggested amendment to settlement boundary. Object

Gower


Phil Baxter, Asbri Planning

I have been instructed by the landowner Mr Beynon to make representations on his behalf to object to the settlement boundary for Scurlage as proposed on the draft proposals maps. Whilst the principle of having settlement boundaries is questioned as it does not enable an assessment of village character to be assessed on a site by site basis, if the LPA were to progress on this basis it is considered, that at the very least additional land at Scurlage Farm should be incorporated, as indicated on the attached plan. This additional land corresponds with that put forward under Candidate Site GW0016, which has previously been rejected.

The agricultural buildings on this part of the farm have exceeded their lifespan

Object


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and the main agricultural activities on the farm now take place on land further to the south, away from existing residential properties, due to residential amenity sensitivities. Having said that the buildings clearly form part of the village fabric and with a natural bank immediately to their rear presents an appropriate rounding off opportunity at this location which would benefit the residential amenities of adjoining occupiers.

Atom Architecture Ltd

Scurlage : Objection to Reintroduction of Village Boundaries

The re-introduction of village boundaries to villages in Gower should be based on detailed analyses of the form and character of each village. For example the proposed village boundary submitted for Scurlage seems to ignore recent development within the village and the positive influence they have had on the character of Scurlage.

The loss of any green field site for development on Gower is an important decision and should only be considered if there is a positive benefit both visually and to the character of the village, not just to deal with a housing need.

Therefore the inclusion of village boundaries in the LDP should only be considered after detailed analysis and consultation with appropriate specialists such as the Urban Designers who prepared the Gower Design Guide to ensure that they benefit the villages

Object


Scurlage: Objection to exclusion of Candidate Site GW0017 & 18 from Village Boundary

The reasoning noted in the LDP of reintroducing village boundaries within the Gower ANOB has been stated as a way to 'help sustain community facilities and bring forward exceptional sites for affordable housing' but in the case of Scurlage

Object


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the proposed village boundary does not achieve this aim.


Scurlage : Objection to Reintroduction of Village Boundaries

The re-introduction of village boundaries to villages in Gower should be based on detailed analyses of the form and character of each village

Object

D. Gill - Boundary fails to recognise differences in character and appearance

- Fails to recognise difference in form and layout of village as a result of previous development

- Land shaded red presents ideal opportunity for a logical rounding off of village in a way that respects is current form and layout and does not change its fundamental relationship with landscape

- Views of site limited by topography

- Mature natural hedge along NW boundary provides stronger defensible boundary

- Good vehicular access with enhancement potential

- Suggested would help preserve character of village, conservation area and AONB

Object

Gower Society - Separation of Middleton to Rhossili is fuindamental to the landscape adjacent to the Conservation Area and to retain view of Rhossili Down.

- Inclusion of School Lane plot allows infill where planning permission was previously refused.

Comment


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- New plots shown for development in Reynoldston, Llanmadoc, Llangennith and Llanrhidian which were not subject to candidate site applications.

- We support larger plots identified i.e. Reynoldston, Scurlage, Port Eynon, Burry Green, Knelston and Llanrhidian provided specifically used for purposes described.

- Strongly object to inclusion into AONB at Thistleboon.

- Reservations about Port Eynon proposal - prominent location.

- Can we be assured AONB boundary is not affected?

D. Gill The drawing of the village boundaries in Gower without a reasoned justification in the form of any written statement is a retrograde step and takes the LPD back to the days of the old 'village envelopes' when there was no room for detailed judgement as to where the village ended and the countryside began. The boundaries once drawn will remove any opportunity for a more careful assessment of the form and character of the village and opportunities for rounding off. They are too rigid and inflexible and have not been justified in any way .

Object

Glamorgan Gwent Archaeological Trust

Llangennith: Land to the south of College Farm and the enclosure of St Cenydd's Church, no number given in your documentation: there are extensive Medieval remains in the immediate vicinity and the original College is believed to date from the early 6th Century as a clas relating to the Early Monastic settlement. Any development may encounter archaeological remains and potentially human remains.

Comment


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Gowerton


C. Jones The objection seeks the provision of development limits around this rural settlement referred to as Cae Mansel.

The rural settlement comprises a small group of dwellings that straddle Cae Mansel Road and Cae Mansel Lane. The larger service centre villages of Gowerton and Three Crosses are conveniently located to the north (1km) and south (1km) respectively.

The close proximity of Gowerton/Three Crosses means that the site has convenient access to a range of community facilities including schools, health care, eating establishments, convenience stores, takeaway and recreation facilities. The Gower Golf Club is situated less than 350 metres from the site.

Object

E. Guy The settlement boundary for Gowerton does not include the ownership boundary at 27 Cae Mansel Road. The outline of my property is clearly hedged and defined. I feel that the present settlement limit is incorrect; it should include my adjoining land which offers a clear, definable boundary. The field is easily and frequently accessed by our family from the front and back gardens; in essence it is part of the garden, the village and the urban form. The present exclusion of my field within the settlement boundary also has financial implications should we ever wish to sell our house.

Object

Killay North


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Blue Sky Planning

- 1,500 new homes are proposed to be located within the West Housing Policy Zone (where Hendrefoilan Road is situated). Of these 1,500 units, 400 are to be provided by existing commitments and 1,100 dwellings from allocations. Two non-strategic housing allocations are identified in this area; Hendrefoilan Campus and Cefn Coed Hospital.

- Timescale to meet need is not long and inappropriate to rely on two sites to meet such needs.

- Premature to finalise sites for housing allocation in advance to Strategic Transport Assessment.

Object

Landore


Trilien Ltd We are currently conducting a Swansea Eastside Connections strategy for Natural Resources Wales, which includes the Lower Tawe, Kilvey Hill, Crymlyn Bog and the Tenant Canal. The work will consider the banks of the Lower Tawe on both sides and issues of connectivity with the wider city as well as taking into consideration flood alleviation measures. The work is due for completion on 31st March 2015.

Comment

Glamorgan Gwent Archaeological

Sites within Archaeologically Sensitive Area of Lower Swansea Valley, discussions have taken place over years regarding mitigation. Area is important locally, nationally and internationally with regard to the metallurgical industries and their infrastructure, and many areas are SAMs. Industrial features survive

Comment


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Trust with a high degree of integrity and complexity and impact of development will require significant mitigation. Previously commented on (LA005 & LA006); as we have with LA001. LA002 is on site of dry docks and industrial features and will also require mitigation. The horizontally hatched orange area is currently within planning and as previously stated requires archaeological mitigation.

Llangyfelach



With regard to the Urban Settlement boundary on the western side of Pontlasau Road, near its junction with the roundabout leading to Morrisiton Hospital, the Council has no objection to this proposed boundary.

Support

D. Morris This 15.2 hectare site is not supported by sufficient information in order to assess its viability or deliverability. Without due justification or consideration of other options it will blight the area and its immediate surroundings.

The southernmost boundary of the proposal represents an incursion into a defined urban settlement area and also severs an existing residential property.

It is therefore proposed that the area of land, currently forming an integral part of the residential property of Cwrtnewydd, should neither be included in the MR0013 Candidate Site application nor dedicated as 'Land for Health Related Uses'.

Object

D. Morris It is noted that the Urban Settlement Boundary has been redrawn to include, rather than divide, the established residential properties in Pantlasau.

This action has gone a long way towards recognising the form, nature and

Support


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character of the settlement.

In doing so it should also allow it to flourish as a cohesive, sustainable and readily identified community.

Llansamlet


K. Jones objection to proposed settlement changes to balacalva road glais Object

J. Jones object to proposed settlement boundary changes excluding Mount Pleasant and Glendale from LDP

Object

Morriston


J. Carroll - Increase in traffic in the locality will become overwhelming for the road network

- Already a busy road, mainly due to traffic into the town centre, commuters to and from the DVLA site, and traffic accessing Morriston Crematorium, but more importantly Morriston Hospital.

- whenever there is disruption to the traffic flow on the M4, (due to an accident) a huge amount of Motorway traffic to and from the West is diverted along the A48.

- People living in the local area find it difficult to travel, carrying out simple duties

Object


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such as school runs.

Mynyddbach


JCR Planning Support the Authority's decision to allocate for residential and associated development as part of emerging LDP. However, we would like to take this opportunity to draw to the Authority's attention once again that discussions with adjoining land owner with regard to increasing extent of land available for development at this location (as indicated at page 5 of submitted Concept Plan document) are ongoing and that there may be an opportunity to increase size of Strategic Site should Authority be happy to do so. As a result, we will continue to inform Authority of progress on this matter.

Support

Newton


D. Phillips In immediate particular development of the "Dingle" left derelict and not restored to facilitate Planning application 2014/1470.

Application was rejected on 16/12/14 as represented an unjustified development.

Area referred lies to south of current extent of LDP and UDP and partially located within Gower AONB and is covered by Woodland TPO.

Object


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Likely that applicant will apply to vary boundaries to pursue application. We strongly oppose any variation to boundaries.

Creation of lower garden has impacted community and countryside nature of area.

Promotion of partly restored garden has further impacted with inreases in footfall and traffic.

Formally request integrity of boundaries is maintained and change resisted.

Asbri Planning Asbri Planning Limited has been instructed by Mrs. Tracey Glover to submit these representations to in response to the draft proposals maps that were released for consultation on the 4th December 2014. These representations relate to land north of Highpool Lane, located on the edge of West Cross, outside of the current Unitary Development Plan settlement boundary.

The Site was not promoted as a Candidate Site through the Local Development Plan (LDP) preparation process and this opportunity is welcomed to introduce the Site as suitable residential housing allocation option to be considered for inclusion in the Deposit Plan.

Object

Nathaniel Litchfield & Partners

Comments are submitted by Nathaniel Lichfield & Partners(NLP) on behalf of Redrow Homes (Redrow).

The settlement boundaries have been subject to review by the Council but NLP consider that the settlement boundaries of Newton should be amended to the west of the settlement as identified on the accompanying map (please see Appendix A), to include a well contained parcel of land.

The proposed amended settlement boundary follows a logical natural boundary

Object


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forming a sensible rounding off to the settlement of Newton. Within the existing Unitary Development Plan (UDP) the site is designated as a Green Wedge. NLP consider that this parcel of land could be included within the development boundary of Newton without detrimentally impacting on the broader openness of the green wedge designation.

G J Planning It is suggested that the Urban Settlement Boundary within the Draft LDP Proposals Maps be amended to include The Dingle, Caswell within the Urban Settlement Boundary.

Comment

Oystermouth


G J Planning We support the Draft LDP Proposals Maps which identifies the site as a 'Commitment', but object to the precise definition of this, and moreover make representations to extend (or rather retain as per the UDP) the alignment of the Urban Settlement Boundary (to encompass the entire site which benefits from planning permission).

Comment

Mumbles Hill Caravan Park Residents

The Mumbles Hill Caravan Park contains tenants relocated from Plunch Lane & Thistleboon sites to what was understood to be a permanent alternative site.

The proposal of the draft LDP could have permanently secured its current use as a Caravan Park but the change to the location of the settlement boundary offers less protection from redevelopment than the current UDP.

For this reason we propose the Mumbles Hill Caravan Park remains outside the

Object


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settlement boundary as the current UPP.

Our plan ref MHCP/01 will be forwarded to the LDP team as is required in support of this objection.

Penclawdd


R. Banks A revision to the settlement limits of Wernffrwd is sought to include part of the field frontage directly opposite established dwellings at the centre of the village.

The revision would allow for minor growth in the settlement, which at the scale proposed would not lead to a loss of landscape character or burden to local services.

The proposals to include the field frontage will also bring about highway gains through the dedication of road frontage to allow carriageway widening, benefitting all motorists.

Object

J. Devonald Firstly very disappointed to see the same residential land proposals in the Penclawdd area. I was expecting these all to be deleted from the first draft.

Secondly all queries should first be directed to the elected officials, otherwise what is the point of democracy. Officials need to remain in the background without decision-making power but to control elected representatives.

A third point is the period for consultation. This is over a xmas period and

Comment


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therefore compromises the time and attention.

Pennard


R. Vincent I would like to register my objections to the proposed housing development in Pennard, Swansea. This area has been developed enough and further development would be damaging on many levels - there would be traffic issues, environmental concerns and also it is wrong to build on an area of outstanding natural beauty.

Object

S. Rogers The infrastructure currently in place at this site is insufficient to support the housing development proposed. In particular, the single road to Pennard is narrow and single track in places. The drainage systems are inadequate. The medical centre has reduced hours due to cuts. Public transport is difficult for people expecting to get to work in Swansea. There is no public transport on Sundays despite many people working on Sundays. Access to the increased housing would put an unacceptable burden on the already busy residential roads in the estate putting playing children at risk.

Object

Pontarddulais


A. Capp I do not want any further development in Pontarddulais. We have, by your own admission, (on some document or other that I have read) had more than our fair

Object


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share already. The schools cannot cope, neither can the local health clinic. There is a notice on the wall of our surgery telling patients to complain to the council if they have to wait an unreasonable time for an appointment.

J. Nicholls Concern at building proposals in Pontarddulais overall but on land off Glynhir Road in particular.

- How will we cope with the extra traffic and parking?

- How will the schools cope with influx of large amounts of new students?

- The medical facilities here are already grossly inadequate.

- We also have no Police Station here, and very little evidence of a police presence.

- Flooding is also a problem, will lose more drainage land.

- Land immediately to rear of my property is shown for recreation, this is of concern as experience has shown these areas being abused.

Object

J. Nicholls I am protesting the proposal to build 750 dwellings in Pontarddulais. There are 4 key elements in any community. HEALTH. EDUCATION, CRIME. AND A FUNCTIONING ROAD SYSTEM. How will any cope with the planned proposals? The roads are constantly gridlocked with a one was system, No Police Station and very little evidence of a Police presence, Schools are full to bursting, and the surgery is next to useless. We have problems with flooding and yet more Green land will become concrete Can't we use more unsightly waste ground, demolish derelict buildings and save out Green land .

Object


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J. Nicholls I am protesting the proposal to build 750 dwellings in Pontarddulais. There are 4 key elements in any community. HEALTH. EDUCATION, CRIME. AND A FUNCTIONING ROAD SYSTEM. How will any cope with the planned proposals? The roads are constantly gridlocked with a one was system, No Police Station and very little evidence of a Police presence, Schools are full to bursting, and the surgery is next to useless. We have problems with flooding and yet more Green land will become concrete Can't we use more unsightly waste ground, demolish derelict buildings and save out Green land .

Object


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Appendix 6

LDP Proposed Allocations Publicity Details


• Council 31st March 2015, opportunity to present valid petitions to Planning Committee agreed. Council 24th September 2015 to endorse Planning Committee findings.

• Planning Committee 1st June 2015, 4th June 2015, 8th June 2015, 11th June, 6th July 2015 (Special Planning Committee), 14th July 2015, 11th August 2015.

o Online

• The LDP web page provided coverage and a link to dedicated Proposed Allocations web pages.

• Dedicated pages for the Proposed Allocations consultation on the Planning Policy Pages of the Council website (www.swansea.gov.uk/ldppa).

In Print

• 21 articles in the local newspaper the Evening Post from 30th May 2015 to 10th November 2015.


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COUNCIL REPORT 24 th SEPTEMBER 2015

APPENDIX 2: DETAILS OF HEARINGS PROCESS AND RECOMME NDATIONS ON PROPOSED ALLOCATIONS

- The summaries do not include observations made by members of Planning Committee during consideration of the proposed allocations.

- Sites not recommended for allocation by the Committee are highlighted grey in the schedule and the site capacity recorded as 0

Central SHPZ

Castle

Candidate Site (CS) Ref

Location Site Capacity

Hearings proces s and Recommendation

CA012 Sailbridge Site, East Burrows Rd

50 Reported : 1 June 2015 – deferred for site visit Site visit : 29 June 2015 Reported : 30 June 2015 Recommended for inclusion within the Deposit Plan subject to displaced car parking needs being addressed in the future development brief

CA013 Site 9, Trawler Road PETITION SITE

30 Reported : 1 June 2015 Mr Woolliscroft (petitioner) and Cllr Crouch spoke against the site being included. Mr North (CCS Corporate Property) addressed Committee as site promoter Recommended for inclusion within the Deposit Plan subject to greenspace being included in the development. Reconsidered at the meeting on 8 June 2015 and deferred for site


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visit. Site visit : 29 June 2015 attended by petitioners Reported : 30 June 2015 Recommended for inclusion within the Deposit Plan and that the site be subject of a development brief including retention of as much of the site as open space and limiting unit numbers to 30

CA014 Vetch Field, Glamorgan St

40 Reported : 1 June 2015 Cllr Crouch spoke against the site being included Recommended for inclusion within the Deposit Plan Reconsidered at the meeting on 8 June 2015 and deferred for site visit. Site visit : 29 June 2015 Reported : 30 June 2015 Recommended for inclusion within the Deposit Plan

CA022 [Strategic Site I]

Central Area and Waterfront (non-specific sites)

1000+ Reported : 1 June 2015 Recommended for inclusion within the Deposit Plan

Total 1120


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Landore

CS Ref Location Site Capacity

Hearings process and Recommendation

LA001 Land at 66-70 Morfa Road

50 Reported : 1 June 2015 Recommended for inclusion within the Deposit Plan

LA002 Land at former Unigate Dairy, Morfa Rd


LA005 Former Hafod Morfa Copperworks


LA007 Pipehouse Wharf Council Depot


Total 200 Uplands



UP004 Llwyn Y Bryn Campus 200 Reported : 1 June 2015 Cllr Bayliss reiterated his comments contained within the report. A submission by Cllr May was reported Recommended for inclusion within the Deposit Plan

UP005 Townhill Campus 150 Reported : 1 June 2015 Cllr Bayliss and Cllr Davies raised concerns in respect of the site. A submission by Cllr May was reported Deferred for site visit Site visit : 23 June 2015 Reported : 30 June 2015 Recommended for inclusion within the Deposit Plan, subject to the


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development brief seeking to access the site from Townhill Road and secure the non-listed retention of the original main building.

Total 350



Central Total 1670


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East SHPZ

Bonymaen



BM002 Land between Bog Rd and Cefn Hengoed Rd, Llansamlet

70 Reported : 1 June 2015 Cllr Evans raised concerns on behalf of local ward members in relation to all sites in the ward Deferred for site visit Site visit : 23 June 2015 Reported : 30 June 2015 Recommended for inclusion within the Deposit Plan

BM007 Land at Upper Bank, Nantong Way

180 Reported : 1 June 2015 Cllr Evans raised concerns on behalf of local ward members in relation to all sites in the ward Recommended for inclusion within the Deposit Plan

BM012 Land north of Cefn Hengoed School

0 Reported : 1 June 2015 Cllr Evans raised concerns on behalf of local ward members in relation to all sites in the ward Deferred for site visit Site visit : 23 June 2015 Reported : 30 June 2015 – Capacity reduced from 100 to 80 units. Deferred for further information Reported: 14 July 2015 Not recommended for inclusion, but settlement boundary to be redrawn along Cefn Hengoed Rd to include site as white land


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BM013 Land at Jersey Rd, opp no’s 16 – 38


BM017 Land at rear of 17-93 Carmel Rd, Winch Wen


BM025 Land at Ty Draw Road and Llanerch Rd

55 Reported : 1 June 2015 Cllr Evans raised concerns on behalf of local ward members in relation to all sites in the ward. Recommended for inclusion within the Deposit Plan

Total 390

Clydach



CL007 Land at Graigola Road 25 Reported : 8 June 2015 Recommended for inclusion within the Deposit Plan

CL008 Land at Tanycoed Road

20 Reported : 8 June 2015 - deferred for site visit Site visit : 23 June 2015 Reported : 30 June 2015 Recommended for inclusion within the Deposit Plan subject to omission of easternmost field and reduction of site capacity from 70 to 20 units

CL011 Land at Ramsey Road 60 Reported : 8 June 2015 Recommended for inclusion within the Deposit Plan

CL015 Former Teachers 10 Reported : 8 June 2015


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Centre, Gellionnen Rd Recommended for inclusion within the Deposit Plan Total 115 Llansamlet



LS008 Talycoppa Farm, Llansamlet


LS009 Land adj. Heol Las, Birchgrove


LS015 Land at Midland Place, Llansamlet


LS021 Heol Ddu Farm, Llansamlet

10 Reported : 11 August 2015 Recommended for inclusion within the Deposit Plan

LS022 Gwernllwynchwyth House, Llansamlet


LS023 Fredrick Place, Llansamlet PETITION SITE

20 Reported : 1 June 2015 Mr Thornton (petitioner) spoke against the site being included. Mr Bacon (CCS Corporate Property) addressed Committee as site promoter Deferred for site visit Site visit : 23 June 2015 attended by Cllr U Clay and Cllr Matthews Reported : 30 June 2015 Recommended for inclusion within the Deposit Plan

LS031 Former Four Seasons Club, Trallwn


Total 340


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St Thomas



ST006 [Strategic Site]

Fabian Way Corridor 525+ Reported : 1 June 2015 Recommended for inclusion within the Deposit Plan

ST010 Former St Thomas Station, Pentreguinea Rd


ST012 Land at David Williams Terrace


Total 650

East Total 1495


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North SHPZ

Cockett



CO003 Former Walkers Factory, Pontarddulais Rd, Cadle


CO004 Land adj. 114 Brithwen Road, Waunarlwydd


CO010 [Strategic Site]

Land north, south west and west of Titanium Road; north of Ystrad Road; north and south of Carmarthen Road and south of Swansea Road and west of Hospital Road

800+ Reported : 4 June 2015 A statement by Cllr W Evans was reported Recommended for inclusion within the Deposit Plan

CO013 Land adj Cockett Pond, Cockett PETITION SITE

50 Reported : 4 June 2015 Mrs Crossley (petitioner) spoke against the site being included. Mr Bacon (CCS Corporate Property) addressed Committee as site promoter Deferred for site visit Site visit : 23 June 2015 attended by petitioner Reported : 30 June 2015 Recommended for inclusion within the Deposit Plan


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CO018 Land off Penrhos Place, Gendros


CO027 BT Depot, Gors Avenue, Townhill


CO037 Land at Cockett House, Cockett


Total 1085

Cwmbwrla



CW004 Manselton Primary School, Manor Road


CW005 Cwmbwrla Primary School, Stepney St


Total 50 Morriston



MR011 Land at Rhyd Y Pandy Rd Pantlasau

0 Reported : 4 June 2015 - deferred for site visit Cllr Sullivan spoke against the site being included Site visit : 23 June 2015 attended by Cllr Sullivan and Cllr Jardine Reported : 30 June 2015 Not recommended (10 units) for inclusion within the Deposit Plan. Proposed settlement boundary to redrawn along Mynydd Gelliwastad


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ent Plan

Rd MR015 Land at rear of

Glyncollen Primary School, Morriston

35 Reported : 4 June 2015 - deferred for site visit Site visit : 23 June 2015 Reported : 30 June 2015 - deferred for further information Reported: 14 July 2015 Recommended for inclusion within the Deposit Plan

MR017 Land at Brayley Road, Morriston


MR019 Land at Enfield and Cwmrhydyceirw Quarry, Morriston

300 Reported : 4 June 2015 - deferred for site visit Site visit : 23 June 2015 attended by petitioners (except on site), site promoter and Cllr Evans Reported : 30 June 2015 Recommended for inclusion within the Deposit Plan

Total 350

Mynyddbach



MB005 [Strategic Site]

Land off Clasemont Road, Morriston

675 Reported : 4 June 2015 - deferred for site visit Cllr Sullivan spoke against the site being included Site visits : 23 June 2015 and 14 July 2015 Reported : 14 July 2015. Capacity reduced from 750 to 600 units Recommended for inclusion within the Deposit Plan Reported : 11 August 2015. Site expanded to the east and capacity increased by 75 units Recommended for inclusion within the Deposit Plan

MB009 Land at Mynydd Garnllwyd Rd,



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ent Plan

Morriston Total 770

Penderry



PD001 Land at Cadle, Fforestfach

50 Reported: 11 August 2015 as part of a mixed residential/commercial scheme Recommended for inclusion within the Deposit Plan

PD002 Land between Eppynt Rd and Bettws Rd, Penlan


PD024 Land north of Milford Way

40 Reported: 11 August 2015 as extension of strategic site PD039 Recommended for inclusion within the Deposit Plan

PD039 [Strategic Site]

Land north of Mynydd Newydd Road

750+ Reported : 4 June 2015 Cllr Sullivan spoke against the site being included Recommended for inclusion within the Deposit Plan Reported: 11 August 2015 with proposed increased yield of 600 units following discussions with prospective developers - increasing capacity from 750 to 1350 units Recommended for inclusion within the Deposit Plan

Total 1450

North Total 3705


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ent Plan

Greater North West SHPZ

Gorseinon



GO001 Land east of Pontarddulais Road

90 Reported : 8 June 2015 Cllr D Lewis raised concerns in relation to this site Deferred for site visit Site visit : 23 June 2015 Reported : 6 July 2015 Recommended for inclusion within the Deposit Plan

GO007 Parc Melin Mynach 0 Reported : 8 June 2015 Cllr D Lewis raised concerns in relation to this site Deferred for site visit Site visit: 23 June 2015 Reported : 6 July 2015 – reduced in capacity from 250 to 150 units and site area redrawn. Deferred for further information Reported: 14 July 2015 – deferred for further information Reported : 11 August 2015 - removal proposed given viability and deliverability concerns Not recommended for inclusion, but retained as white land within settlement boundary

GO008 Land at Parc Melin Mynach & Heol Eifion

25 Reported : 8 June 2015 Cllr D Lewis raised concerns in relation to this site Deferred for site visit Site visit : 23 June 2015 Reported : 6 July 2015


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ent Plan

Recommended for inclusion within the Deposit Plan Total 115

Gowerton



GT005 Former Cefn Gorwydd Colliery, Gorwydd Rd, Gowerton PETITION SITE

90 Reported : 4 June 2015 Mr Higgon (petitioner) and Cllr Jones spoke against the site being included. Philippa Cole (site promoter) spoke in favour of the site Deferred for site visit Site visit : 29 June 2015 attended by petitioners and Cllr Jones Reported : 30 June 2015 Recommended for inclusion within the Deposit Plan

GT006 Land to the east of Fairwood Terrace, Gowerton

35 Reported : 4 June 2015 Cllr Jones spoke against the site being included Deferred for site visit Site visit : 29 June 2015 attended by local residents and site promoter Reported: 30 June 2015 Recommended for inclusion within the Deposit Plan

Total 125

Kingsbridge



KB012 Land at Garden Village 750 Reported : 8 June 2015


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ent Plan

[Strategic Site] A statement by Cllr W Evans was reported Recommended for inclusion within the Deposit Plan

KB014 Land at West Street, Gorseinon


KB015 Land to south of Highfield, Loughor Road

60 Reported : 8 June 2015 Recommended for inclusion within the Deposit Plan Site Visit : 23 June 2015 for information Reported: 11 August 2015 to clarify amended site area. Capacity unchanged Recommended for inclusion within the Deposit Plan

Total 830 Llangyfelach



LF001 Walters Yard, off Swansea Road, Pontlliw

65 Reported : 4 June 2015 Cllr Sullivan spoke against the site being included Deferred for site visit Site visit : 23 June 2015 attended by Cllr Sullivan and site promoter Reported : 6 July 2015 Recommended for inclusion within the Deposit Plan

LF002 Land at Carmel Rd and Bryntirion Rd, Pontlliw

100 Reported : 4 June 2015 Cllr Sullivan spoke against the site being included Recommended for inclusion within the Deposit Plan

LF009 [Strategic Site]

Land adj Former Felindre Tinplate Works

850+ Reported : 4 June 2015 Cllr Sullivan spoke against the site being included Recommended for inclusion within the Deposit Plan

LF011 The Poplars, Pontlliw 15 Reported : 4 June 2015


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ent Plan

Cllr Sullivan spoke against the site being included Deferred for site visit Site visit : 23 June 2015 attended by Cllr Sullivan Reported : 6 July 2015 Recommended for inclusion within the Deposit Plan

Total 1030

Lower Loughor



LL003 Beili Glas, Glebe Road 60 Reported : 8 June 2015 Recommended for inclusion within the Deposit Plan

Total 60

Penllergaer



PG002 [Strategic Site]

Land at Parc Mawr Farm PETITION SITE

750 Reported : 4 June 2015 Mr Harris (petitioner, on behalf of Penllergaer Community Council) and Cllr Fitzgerald spoke against the site being included. Robin Williams (site promoter) spoke in favour of the site Deferred for site visit Site visit : 14 July 2015 attended by petitioners, site promoter and Cllr Fitzgerald Reported : 14 July 2015


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ent Plan

Recommended for inclusion within the Deposit Plan PG004 Land at Penllergaer

Civic Offices 80 Reported : 4 June 2015

Cllr Fitzgerald spoke against the site being included Deferred for site visit Site visit : 14 July 2015 Reported : 14 July 2015 Recommended for inclusion within the Deposit Plan

PG006 Land north of Llewellyn Road

50 Reported : 4 June 2015 Cllr Fitzgerald spoke against the site being included. Recommended for inclusion within the Deposit Plan

Total 880

Penyrheol



PY012 Land at Tyrisha Farm, Grovesend

45 Reported : 8 June 2015 - deferred for site visit Site visit : 23 June 2015 attended by site promoter and Community Councillor Reported : 6 July 2015 Recommended for inclusion within the Deposit Plan

PY013 Land at Brynafon Rd, Gower View Rd, Clos Cwrt Y Carne


Total 270


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ent Plan

Pontarddulais



PT002 [Strategic Site]

Land north of Pontarddulais PETITION SITE

720 Reported : 8 June 2015. Dr Susan Barnes (petitioner) and Suzy Davies (AM) spoke against the site being included. Pete Sulley and Chris Jenkins (site promoters) spoke in favour of the site. Cllr Downing and Cllr Harris raised concerns in respect of traffic infrastructure in the locality. Deferred for site visit Site visit : 23 June 2015 attended by petitioners, site promoters, Cllr Downing and Cllr Harris Reported : 6 July 2015 Recommended for inclusion within the Deposit Plan

PT017 Land at Bolgoed Road PETITION SITE

50 Reported : 8 June 2015 Dr Susan Barnes (petitioner) spoke against the site being included. Recommended for inclusion within the Deposit Plan

PT023 Land east of Carreg Teilo


Total 800 Upper Loughor



UL001 Land South of former Cae Duke Colliery

30 Reported; 11 August 2015 Cllr Robert Smith raised concerns in relation to the site Recommended for inclusion within the Deposit Plan

UL002 Land at Heol Pentre Bach

40 Reported : 8 June 2015 Francis Sinfield (petitioner) spoke against the site being included.


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ent Plan

PETITION SITE Robin Williams (site promoter) spoke in favour of the site Recommended for inclusion within the Deposit Plan

UL008 Land off Borough Rd, Loughor

0 Site Visit: 11August 2015 Reported: 11August 2015 Cllr Robert Smith spoke against the site being included Not recommended for inclusion within the Deposit Plan

UL015 Land south of Glebe Road


Total 170 Great North West Total

4310


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ent Plan

West SHPZ

Dunvant



DU003 Land r/o 104 Killan Rd 15 Reported : 11 June 2015 Cllr Raynor raised concerns in relation to the site. Recommended for inclusion within the Deposit Plan

Total 15

Killay South



KS001 Land off Rowan Close PETITION SITE

0 Reported : 8 June 2015 Mrs C Thomas (petitioner) and Cllr J Jones spoke against the site (10 units) being included. Deferred for a site visit Site Visit: 29 June 2015 attended by petitioner and Cllr Jones Reported: 30 June 2015 Not recommended for inclusion within the Deposit Plan

Total 0


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ent Plan

Killay North



KN004 Hendrefoilan Student Village


Total 300

Sketty



SK011 Land to north of Llwyn Mawr Road, Tycoch


SK017 Cefn Coed Hospital, Cockett PETITION SITE

500 Reported : 11 June 2015 Petitioners did not take up invite to address committee Cllr Philpott on behalf of Sketty ward members and Paul Vining ( site promoter) spoke in relation to this site Recommended for inclusion within the Deposit Plan

CS Ref Location Site

Capacity Hearings process and Recommendation

Total 525

West Cross


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ent Plan



WC004 Clyne Common off Chestnut Avenue PETITION SITE

0 Reported : 11 June 2015 Betty Ballman (petitioner) spoke against inclusion of the site. Geraint John (site promoter) and Cllr Child spoke in favour of the site (50 units) Deferred for site visit Site visit : 29 June 2015 Reported : 30 June 2015 Not recommended for inclusion within the Deposit Plan

WC009 Former Eastmoor Nursery, Chestnut Avenue


Total 20

West Total 860


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ent Plan

Gower SHPZ

Gower



GW002 Land adj Boarlands Estate, Port Eynon PETITION SITE

10 Reported : 11 June 2015 Mr Herbert (petitioner) and Mr Attwell (petitioner) spoke against the site being included. Mr King (site promoter) spoke in favour of the site Recommended for inclusion within the Deposit Plan

GW010 Land at Tyle House Farm, Burry Green

0 Reported : 11 June 2015 - deferred for site visit (10 units) Site visit : 29 June 2015 - community councillor attended Reported : 30 June 2015 Not recommended for inclusion within the Deposit Plan

GW023 Land at Monksland Road, Scurlage

25 Reported : 11 June 2015 - deferred for site visit Site visit : 29 June 2015 Reported : 30 June 2015 Recommended for inclusion within the Deposit Plan

Total 35


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ent Plan

Oystermouth*



OY003 Land at Thistleboon Caravan Park PETITION SITE

Boundary change

Reported : 11 June 2015 Mr Smith (petitioner) spoke against inclusion of the site within the settlement boundary Deferred for site visit Site visit : 29 June 2015 attended by petitioners and community councillor Reported : 30 June 2015 Recommended that the boundary change is not included within the Deposit Plan and that the existing settlement boundary remains unchanged

OY016 Land at Higher Lane, Thistleboon PETITION SITE

30 Reported : 11 June 2015 Mrs Burgess (petitioner) spoke against the inclusion of the site. Mr Geraint John (site promoter) spoke in favour of the site Deferred for site visit Site visit : 29 June 2015 attended by petitioners and community councillor Reported : 30 June 2015 Recommended for inclusion within the Deposit Plan

Total 30

* Sites located within or partly within Gower AONB


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ent Plan

Pennard


Capacity


PN001 Land adjoining Pennard Drive, Pennard

60 Reported : 11 June 2015 Cllr James submitted written representations and spoke against the site being included Recommended for inclusion within the Deposit Plan Site Visit: 29 June 2015 for information. Petitioners attended

Total 60

Gower AONB Total

125


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ent Plan

Gower Fringe SHPZ

Bishopston


Capacity


BI002 Land to the rear of 51B Bishopston Rd

0 Reported : 8 June 2015 Cllr Marsh spoke against the inclusion of the site (30 units) Deferred for a site visit Site Visit: 29 June 2015 local residents, site promoter and Cllr Marsh attended Reported: 30 June 2015 Not recommended for inclusion in the Deposit Plan

Total 0

Fairwood


Capacity


FA008 Fairwood Hospital, Gower Road, Upper Killay PETITION SITE

25 Reported : 11 June 2015 Petitioners did not take up invite to address committee Recommended for inclusion within the Deposit Plan


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ent Plan

FA010 Land to the East of Gowerton Rd, Three Crosses PETITION SITE


FA011 & FA014

Land adjoining Tirmynydd Rd, Three Crosses PETITION SITE


FA019 Northern end of Gowerton Road, Three Crosses PETITION SITE

Boundary change

Reported : 11 June 2015 Petitioners did not take up invite to address committee Recommended for inclusion within the Deposit Plan

Total 60

Newton*



NE011 Land at Summerland Lane, Caswell

60 Site Visit : 29 June 2015 Reported : 11 August 2015 Recommended for inclusion within the Deposit Plan

* Site located within Gower Fringe

Gower Fringe Total

120