Under this heading we have identified three areas which concern us most of all. But this is not to say that there are not further areas which we very much agree need radical re-thinking by the NPA. In particular, having attended at the General Housing Policy Issues day at the Enquiry Centre (the E-Commerce Building on Cleddau Reach in Llanion East, Pembroke Dock) we whole-heartedly endorse the concerns of many other groups that the very ambitious percentage of affordable housing requirements set out by the NPA in the plan, always at least 50%, often 70% as in here in Newport, and sometimes even higher, have not be subjected to any form of external or independent ‘viability’ analysis. In particular this would involve the NPA getting together with Pembrokeshire house builders, Social Sector Landlords (e.g. Housing Associations etc.) and landowners of the sites proposed by them for housing, to “crunch the numbers”, in order to establish at the least the financial viability of their proposals. This has not been done.

In addition the following three main areas concern the Group with respect to generally the lack of policy based provision, especially as compared to the existing planning situation under the current local development plan the JUDP (Joint Unitary Development Plan 2006).

See our written submissions on each topic  here (a brief outline summary appears beneath the link).

No policy provision for replacement housing development.

Given our recent experience here in Newport with respect to the notorious replacement dwelling house at Bettws Newydd, on the Parrog, it should be obvious to all why the Group was horrified to discern that the LDP, which will replace the JUDP, proposes to set out no equivalent Policy provision on this topic to replace the existing Policy 56. Without that policy provision in the current local plan, the campaign to oppose the massively over-sized replacement dwelling at Bettws Newydd, representing the overwhelming majority view of the community, would surely have had no chance whatever of succeeding.

No policy provision for in-fill and rounding-off within settlement centres

It is simply irrational that whilst the NPA proposes to make some, albeit inadequate, re-iteration of the current JUDP policies on the development of so-called ‘in-fill’ and ’rounding-off’ sites in countryside settlments, where the settlement character or size does not warrant a so called boundary ‘centre-line’; it proposes no such re-iteration in relation to similar such developments proposed within settlements with centre-lines, where as a matter of common sense such proposals are bound to be much more frequent.

No or inadequate policy provision on buildings conversions.

The proposed re-iteration of the policy provisions, in the current JUDP, on the vexed subject of the appropriate criterion for permitting building conversions, most especially conversion of non-domestic (typically work related and business use buildings) in the countryside to residential use instead, which are volumious, is proposed for only a bare sentence or two in the new plan. In particular, the very strong requirement in the current plan, for a proposal for conversion to a residential use to come forward only after a business or employment use has been proven to be unavailable, will now be dropped in favour of a preference for residential use favouring affordable housing instead. Whilst, of course, we strongly favour a large proportion of new housing being for affordable needs, a policy of promoting affordable housing conversion in the countryside with no associate viability analysis, or related employment criterion is clearly woefully inadequate.