Policy H2.1 - Affordable Housing 14th March 2005

Cyngor Sir CEREDIGION CEREDIGION County Council

UDP – Public Local Inquiry Proof of Evidence

Proof Number: LA No. 292

H2.1 Policy: Affordable Housing

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I. Contents

I. Contents 3

II. Introduction 4

Policy 4

III. Summary of Representations 5

Deposit Objections and LPA Responses 5

Proposed Changes Objections and LPA Responses 12

Further Proposed Changes Objections and LPA Responses 13

IV. Conclusion 28

Further proposed changes 28

Appendix 1 32

List of Objections by Objectors 32

Appendix 2 40

Representations received to the UDP Deposit Version 40

Appendix 3 49

Representations received to the UDP Proposed Changes Document (February

2004) 49

Appendix 4 51

Representations received to the UDP Further Proposed Changes 1 (September

2004) 51

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II. Introduction

This is the proof of evidence of Llinos Thomas, representing Ceredigion County Council, whose details and qualifications are displayed in the Programme Office and at all Inquiry venues.

This introduction explains how to use this document (proof). The proof covers all the objections to Housing – policy H2.1 Affordable Housing. Different objectors may have made the same or a very similar point regarding this policy, the LPA has tried to identify the issues arising out of the objections and then to address each issue, once, in this proof. Each issue is numbered and you can identify the issues which the LPA believe relate to your objection in Appendix 1. Each issue is supplemented by detailed reasons for that objection. Also, Appendix 1 lists any Proposed Change that may resolve the issues identified. A detailed summary of your objection is contained in Appendix 2 for objections to the Deposit Version and Appendix 3 for objections to the Proposed Changes documents (February 2004 and September 2004).

Any further changes proposed by the LPA are noted at the end of the proof in the Conclusion and are included in a box(s). The further proposed changes are indicated by bold italic text for any additional wording and a double strikethrough for any further deletions. Some of the further proposed changes may not directly relate to any issues identified as part of the consultation exercises. Where relevant, these amendments are being proposed to correct typographical errors or to improve the grammar and or the clarity of text or to update references where needed. These are not in any way intended to alter the sense of the document. Such changes are included along with any further changes being proposed in response to objections received in the conclusion, where the whole policy together with any further proposed changes is reproduced.

Policy

The Policy shown is the Further Proposed Change 1 version (September 2004). The removal of bold text and the reinstatement of strike through text represent the original text of the policy in the Deposit version of the UDP.

PC 550 H2.1 Affordable Housing

1. Where larger housing development (10 units in the main towns and 5

units elsewhere) is proposed (that is, residential development on a site, or part of a site that is capable of accommodating 10 units or more in the main towns and 5 units or more elsewhere), the Council will seek to negotiate the inclusion of an element of affordable housing, where there is a demonstrated need for affordable housing. Adequate planning conditions or obligations will be used to ensure that the benefits of such housing will be passed on to future occupiers.

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III. Summary of Representations

A total of 25 representations were received to Policy H2.1, of which 4 supported the

policy. A further 2 representations of objection were received to the amendment

included in the Proposed Changes document (February 2004). Subsequently 48

Objections and 6 supports were received to the policy as set out in the ‘Further

Proposed Changes 1 (September 2004)’ document (PC 550).

Deposit Objections and LPA Responses

1. Issue 1: The policy approach is criticized because:

1.a. No valid local housing needs assessment (LHNA) has been undertaken. A LHNA

should be undertaken and consulted upon.

1.a.1. Guidance permits LPAs to include policies for affordable housing within UDPs

where it is known that need for affordable housing exists (PPW, March 2002,

Para 9.2.15). In order to be able to implement such policies the need must be

defined. Such need can be demonstrated by local housing needs assessments

(LHNAs) or by other reliable and robust data sources such as housing registers

of local authorities (LAs) and registered social landlords (RSLs). At the time of

producing the Deposit Version the LPA had not undertaken a LHNA. However,

several factors clearly demonstrated that there was a need which justified the

inclusion of affordable housing policies. Therefore two policies were included

within the Deposit Version aimed at increasing the supply of affordable housing

across the County.

1.a.2. Since then a Countywide LHNA has been undertaken by the Council.

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1.a.3. The purpose of LHNAs is to provide an indication of housing needs which can

then inform LA policies, including planning and housing policy. Such

assessments provide statistically robust information regarding need and are

produced in accordance with good practice issued nationally. It would be

inappropriate to put the results of such assessments out to consultation –

because the information given within the LHNA is factual and statistical and

therefore there is nothing that can be consulted upon.

1.a.4. An up to date LHNAs will therefore aid in the effective implementation of this

Policy and hence help secure a provision of affordable housing during the plan

period. LHNAs will have an important role to play in identifying the level, tenure

and type of affordable need within the County throughout the plan period.

1.a.5. The LHNA deals with the issue of affordability and acknowledges that the needs

of those affected by that issue may be different. Neither the LHNA or the

Policies adopt a "one size fits all" approach and the question of what is an

affordable dwelling is in both documents seen in the context of the range of

needs identified.

1.a.6. Further detail regarding the consideration given to the use of specific local

needs assessments is set out in Topic Paper 3: Sustainable Communities –

Housing and Social Sustainability (Section 8).

1.b. Building enough houses to meet the demands from those moving into the

County in order to reduce house prices for local people is flawed because:

(a) It will not provide for local affordable need,

(b) It places the needs of local people secondary to those moving in to the

County; and

(c) This approach will negatively impact the Welsh language.

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1.b.1. The purpose of this policy is to ensure that sites capable of accommodating

large scale residential development (defined as 10 or more units within the main

towns and 5 or more units elsewhere) provide affordable housing as part of the

overall development. The total number of units (both open market and

affordable) capable of being accommodated within a particular settlement is

controlled by the figure set out in the Appendix to Volume 2B and the relevant

policy (H1.2 and H1.3). The approach advocated by this policy is not therefore

one of meeting the demands of those moving into the County in order to reduce

prices.

1.b.2. The emphasis of the policy is on meeting ‘local affordable need’ – therefore

occupancy restrictions will be applied to dwellings permitted in accordance with

these policies to ensure that they are occupied by those who are in need locally

of ‘affordable housing’. The LPA have proposed a number of changes to the

policy (PC 550) and to the glossary (PC 552), which supplements the policy, to

clarify this approach.

1.b.3. Providing for the housing needs of a community is seen as the best way of

sustaining the local community, which in turn will help sustain the Welsh

language. Making sure that occupancy conditions are applied to ensure that

affordable housing is directed to the needs of local people, will therefore help

sustain communities and in turn the Welsh language. The relationship between

the Welsh language and housing is explored in Topic Paper 3: Sustainable

Communities – Housing and Social Sustainability (Section 7).

1.c. Providing social housing next to private housing is problematic.

1.c.1. This statement is not supported by evidence and the LPA do not accept this

view as correct. The policy is considered to be in accordance with guidance in

seeking to ensure the promotion of social integration and to avoid ghettos as

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has occurred in the past. National guidance seeks to ensure that, in providing for

affordable housing, development incorporates a reasonable mix and balance of

housing types and size to cater for a range of housing needs (PPW, March

2002, Para 9.1.2, 9.2.14 and 9.2.15).

1.d. Forcing developers into partnership with non-governmental parties is an

infringement of a developer’s rights.

1.d.1. In line with guidance, the Policy does not prescribe who developers should work

with in order to deliver affordable housing (TAN(W)2, Para 15). The Reasons for

policy only indicate that RSL managed properties are the best means of

securing affordable housing in perpetuity (as noted in TAN(W)2 Para 19) and

that developers will, therefore, be encouraged to work with RSLs.

1.e. New housing should be for local people. The Objectors suggest alternative

policy wording, see Appendix 2, Representation numbers B/30556 and B/30558.

1.e.1. The LPA agree that ‘affordable housing provided as a result of this policy should

be for those who are in need locally of ‘affordable housing’. The LPA have

proposed a further amendment (see PC 550, 551 and 552) restricting the

occupancy of housing provided as a result of both policies H2.1 and H2.2.

1.f. The policy fails to specify that local residency conditions will be used to secure

and expand a permanent stock of housing to meet affordable local needs.

1.f.1. The Council has proposed a further amendment (see PC 550, 551 and 552) to

clarify that occupancy conditions will be applied to ensure that affordable

housing is directed to the needs of local people (TAN(W)2 Para 18).

2. Issue 2: The Policy lacks clarification regarding the delivery of affordable

housing:

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2.a. No definition has been provided for ‘local need’.

2.a.1. The LPA agree that further clarification is required regarding what constitutes

‘local affordable need’. The Council has proposed a further amendment to policy

H2.1 to clarify what criteria the occupants of ‘affordable housing’ will need to

satisfy. Within the revised definition, both ‘need’ and ‘local’ have been further

clarified (see PC 552).

2.b. Sites should be specifically allocated and protected for affordable housing

where there is a proven need. Specifically allocating such sites would reduce

the value of land and the cost of development.

2.b.1. Guidance requires that where need for affordable housing is known, that the

LPA should set indicative targets for specific sites (expressed as either numbers

of homes or a percentage of the total provision on site). The LPA however,

believe that the appropriate level will be considered at the application stage

according to the up to date information available at that time and taking into

account the circumstances of the development. It is therefore not considered

feasible to allocate sites specifically. Equally the LPA consider that it would also

be inappropriate to allocate sites specifically for affordable housing as this would

result in the creation of ghettos and does not accord with guidance which seeks

to achieve mixed communities (PPW, March 2002, Para 9.1.2, 9.2.14 and

9.2.15).

2.b.2. Where sites are allocated through the UDP then the requirement to provide

affordable units as part of the development is spelt out in appropriate cases.

However windfall sites are also expected to make their contribution to Affordable

Housing in line with policy H2.1 and H2.2.

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2.c. The phrase ‘larger housing requirements’ requires clarification within the policy

in accordance with the definition provided in the Reasons. The Objector

suggests alternative policy wording, see Appendix 2, Representation number

B/30542.

2.c.1. The Council has proposed an amendment to Policy H2.1 as requested (PC

151).

2.d. The thresholds included within the policy are ambiguous and would allow

developers to build a series of less than 10 or 5 units on the same site in order

to avoid the remit of this policy. The thresholds should apply to the capacity of

the whole site and not to the number of units bought forward in a single

application.

2.d.1. The Council has proposed an amendment to the Policy and Reasons in

accordance with this request (PC 151).

2.e. The thresholds used lack justification, aren’t based on a LHNA and go beyond

guidance (Circular 6/98 and PPG3).

2.e.1. Circular 6/98 and PPG3 relate to England only. No equivalent circular exists in

Wales, therefore the LPAs in Wales rely on guidance set out in PPW, March

2002 and PG(W) TAN(W) 2 Planning and Affordable Housing. The Council has

undertaken a local housing needs survey. It is recognised that the housing

needs survey will aid in the effective implementation of this Policy, and hence

help secure an appropriate provision of ‘affordable housing’ across the County

according to identified ‘need’ however the LHNA cannot assist in identifying the

thresholds to which policy H2.1 applies. In order to determine appropriate

thresholds, it is necessary to understand the nature and form which residential

development takes within the County; this is beyond the scope of a LHNA.

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Approximately 50% of the County’s new residential development is likely to

occur on sites of less than 5 units in total; because of the rural nature of the

County. Because of this it is considered necessary to have thresholds that are

also low if affordable housing is to be delivered as part of a general housing

scheme. Therefore based on a consideration of the pattern of development in

recent years, the threshold of 10 units in the main towns and 5 elsewhere is

considered appropriate.

2.f. The Reasons for policy should refer to other factors which will need to be taken

into account when assessing a site’s suitability for affordable housing in

accordance with Circular 6/98 (Para 10).

2.f.1. Paragraph 12 and 13 (PC 550) of the Reasons already sets out factors which

need to be considered in assessing a site’s suitability for providing for affordable

housing in accordance with PG(W) TAN(W)2, November 1996, Para 8b. Circular

6/98 applies to England only.

3. Issue 3: A balanced approach is required to ensure housing need can be fully

met.

3.a. Other solutions need to be provided to ensure affordable needs can be met.

3.a.1. The LPA agree, however this is not a land use issue. Though planning has a

role to play in the delivery of affordable housing it is but one mechanism and

does not itself provide the holistic response to tackling affordability within the

County. The Local Housing Strategy for the County and associated plans should

help address the issue of affordability more fully and refer to the UDP as one

mechanism for helping to provide for this need.

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Proposed Changes Objections and LPA Responses

The following section deals with objections received to the Proposed Changes (PC

151) set out in the document dated February 2004:

101. Issue 101: The Policy lacks clarification regarding the delivery of affordable

housing:

101.a. The use of units as thresholds is vague and subjective and should be replaced

with site areas. Based on the JHLAS, 2000 (where the average density is 18.1

houses per ha for Ceredigion) it is suggested that the threshold be changed to

‘0,6ha or more in area in the towns and 0.3ha or more in area elsewhere’.

101.a.1. The application of the suggested standard site areas as thresholds would be

arbitrary because they are based on an average density which has no meaning

in reality. In reality an average density for the County would be made up of large

number of widely differing densities across the County. This is because what is

appropriate in terms of density depends on the individual site and its location as

set out in TAN(W) Planning and Affordable Housing, Para 8b (see Topic Paper:

Settlement Strategy and Site Selection Para 5.15).

101.b. The Council alone should not decide whether it is feasible to require an element

of affordable housing as it will fail to exercise its power impartially. Decisions

should be subject to review by the WAG at the request of the public. The

Objectors suggest new wording to be included in the Reasons for policy, see

Appendix 3, representation numbers B/50843 and B/50857.

101.b.1. It is within the jurisdiction of the LPA to determine whether or not it is appropriate

to seek to negotiate an element of affordable housing as part of a proposed

development. National guidance clearly states that development proposals are

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generally best determined locally by planning authorities that know their areas

(PPW, March 2002, Para 4.12.1). The wording suggested by the Objectors is

therefore not considered to be appropriate.

Further Proposed Changes Objections and LPA Responses

The following section deals with objections received to the Further Proposed Changes

(PC 550) set out in the document dated September 2004

102. Issue 102: The level of need should be clarified

102.a. The level of need for affordable housing requires careful measurement.

102.a.1. See LPA response to Issue 1.a. above.

103. Issue 103: The role of the UDP in delivering affordable housing is questioned.

103.a. The market is best placed to provide housing. Modifying the market price could

have disadvantages in the future.

103.a.1. National guidance (PPW, March 2002, Para 9.2.15) states that local planning

authorities "should include policies for affordable housing in their UDP for the

areas where need has been identified." As set out in the LPA’s response to

Issue 1.a. above, the current LHNA, along with other information (Council

waiting lists, average house prices compared to average incomes) demonstrate

that there is a clear need for affordable housing within the County.

103.a.2. The LHNA clearly demonstrates, through the identification of backlog need in

particular, that the market has not been ensuring that all recent housing needs

within the County are met. Also the reduction in public provision with the sale of

Council housing has resulted in a reduction in the overall supply, particularly as

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Housing Associations have not been building sufficient numbers to replace this

previous stock as originally intended.

103.a.3. The LPA assumes that the objectors are referring to the cyclical nature of the

market when noting that modifying the market price will have disadvantages in

the future. In response to this point, the cyclical market is generally perceived to

be a bad thing but is something that it is not possible to control. The provision of

affordable housing may help by both depressing land prices (and so depressing

the cyclical effect) and by ensuring that when the upturn does occur that there

are properties which remain affordable rather than all housing disappearing into

the spiralling housing market. When the market is at the bottom of the cycle,

arguably everyone suffers and there is a problem with mobility and confidence in

general.

103.a.4. The importance of meeting affordable need is recognised within the Council’s

Corporate Strategy (2004-2007). As part of the Strategy, the Council is

committed to ‘Improving Housing and Healthy Living Conditions’. The Strategy

recognises that one of the ways this objective can be achieved is through

working with developers to ensure that affordable housing is realised.

103.b. Clarify that planning process doesn’t have outright responsibility for providing

affordable housing and that the ability of HA to deliver requires further

assistance from WAG.

103.b.1. The reasoned justification already sets out that the UDP is but one mechanism

which can help provide for affordable housing (PC 550, Para 16). The ability of

HA to deliver affordable housing and the need for further funding to be provided

by WAG to achieve this is outside the scope of the UDP. The Council however

do work closely with the HA and WAG and are, whenever the opportunity arises,

trying to increase the funds available to HAs through the Social Housing Grant.

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104. Issue 104: The approach to providing affordable housing proposed by these

further changes is questioned.

104.a. The plan should specify or designate sites for affordable housing. Some

objectors suggested that such sites should be on the borders of towns or larger

settlements. Allocating sites will ensure that numbers are achieved, that sites

are suitable and that land values reflect affordability.

104.a.1. See LPA response to Issue 2.b. above.

104.b. The policy should be applied to the whole of the County, not just specific

locations.

104.b.1. The policy is applicable across the County. However, the policy may not apply

to some of the smaller settlements as sites available for development will be

smaller than the 5 unit threshold. For these settlements, policy H2.2 will have an

important role to play in helping to deliver affordable housing.

104.c. The definition of an affordable dwelling/house to buy, referred to in Para 6, is

too restrictive. The definition needs be simpler and should be replaced with one

which refers to some form of shared equity scheme.

104.c.1. Shared equity schemes are already covered by Para 5. The LPA propose a

further amendment as follows to Para 5 to clarify that this first option would

include shared equity:

PC 550.001 (Para 5):

“Owned or managed by an RSL, the Local Authority or other nominated

body identified by the LA and is available for rent or purchase or any

combination thereof; or "....

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Paragraph 6 of PC 550 deals with Affordable homes for purchase. Some of the

Objectors appear to be suggeting that the ‘affordable homes for purchase’ as

defined by the LPA should be replaced by some form of shared equity scheme.

The suggestion seems to involve a scheme whereby the LPA are “gifted” a % of

the equity in the property. This is viewed as problematic in that it creates a joint

ownership with the purchaser. For instance the LPA will then need to be parties

to any mortgage of the property, will have to account for their “share” of the

equity which will appear as a capital asset and will be liable to the mortgagor in

the event that the owner defaults. The LPA are therefore not convinced of the

merits of such a scheme.

104.d. The proposed change lacks balance. The number of houses that could be built

as a result of the UDP is far greater than that which the Council envisage, so the

need for the Rural Areas Exceptions and other policies is correspondingly less.

104.d.1. The number of units which could be delivered by policy H2.1 are limited to those

sites which remain undeveloped and without an existing permission and which

meet the thresholds set out by this policy (see LPA response to Issue 105.a.

below). The overall number of units which can come forward within a settlement

are governed by the figures set out in the Appendix to Volume 2B and the

provisions set out in policies H1.2 and H1.3. For development to exceed those

figures it would have to meet the provisions of policy CER1.1. The Appendix,

along with the relevant policies, therefore help to ensure that inappropriate over

development does not occur.

104.e. The approach fails to deal with inflation (Paragraph 7). An increase in the value

of a property over time does not mean it’s affordability will be lost because

inflation will also have an upward effect on salaries. A better policy approach

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would be to tie affordable housing covenants to average house prices or

average County incomes.

104.e.1. The policy operates on the market which will respond to external economic

circumstances in exactly the same way as it does at present but with a different

balance between capital cost and income for those able to access the affordable

part of the market.

104.e.2. The LPA are not convinced that linking price to a multiplier of average earnings

would achieve the policy objectives since it would result in the policy addressing

a mythical average earner.

104.f. Paragraph 9 should set as a UDP policy that council tax should be paid at full

rate on unoccupied dwellings to encourage their letting to people in need of

affordable housing. The Objectors request for the inclusion of specific wording,

see Appendix 4, Representation numbers B/60189 and B/60195.

104.f.1. It is not within the remit of the UDP to put forward such a policy approach. This

is a matter that would need to be considered, and has already been, by the

Council outside of the UDP process.

105. Issue 105: The level of affordable housing sought, the 30% referred to in Para 9,

is considered to be inappropriate.

105.a. The application of a target figure and specifically the application of 30% was

questioned for the following reasons:

a) no justification has been provided for applying 30%;

b) 30% is too low, a figure of 75% or at least 50% should be applied baring

in mind housing in Ceredigion has been identified as being the least

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affordable. Also only 1 unit would be achieved on sites of 5 units – this

is too low;

c) Imposing high % will prevent development as sites become

uneconomical leading to fewer houses being built and inflated prices;

d) reference to providing in excess of 30% should be deleted;

e) The additional wording from “That is, 30%..” to “…may be significantly

higher” should be deleted. As written the policy removes the

responsibility for design and layout from developers/architects and it

also restricts the freedom of negotiation and is contrary to PPW.

f) clarify that 30% is a guide; sometimes it will be suitable to ask for more

other times less;

g) 30% of 5 units gives a partial result - this is not logical;

h) The plan does not contain a mechanism for determining how the % will

vary between settlements

105.a.1. In setting a target % within the UDP, the LPA were conscious that it has to

relate to a realistic need; a target was not included in the Deposit Version

because of the absence of information regarding the extent of overall level of

need. The LHNA identifies the need for additional affordable units as being 112

per annum for the next 5 years. The LPA were aware of the general findings of

the LHNA during the summer of 2004; whilst the full results of the assessment

were still being compiled. It was considered that a pragmatic target had to be

set. The LPA were keen to see the delivery of affordable housing early in the

plan period. Imposing a higher percentage would take time for delivery to take

place as landowners would hold back land due to the prospects of lower returns

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in the hope that the requirement would be abolished later in the plan period.

Whilst developers would wait until the value of land dropped sufficiently before

buying and developing. On this basis the Council decided that 30% of the

remaining potential residential development affected by this policy (sites capable

of 10 or more units in the town and 5 or more elsewhere) should be for

affordable. In reaching a decision regarding the target to be aimed for the

Council considered the indication of need as identified by the LHNA (though in

draft at that time – the results have not differed) along with the capacity to

provide for affordable housing (see Para 105.a below). By setting a target of

30%, it is considered that it will be more likely that landowners and developers

would still develop – thus improving the available stock of affordable housing

sooner rather than later.

105.a.2. The LPA acknowledge the number of units which could be achieved by this

target are lower than even the 5 years supply needed – without considering

what level of need may arise in the remaining years of the plan period. However

it has taken the view that a higher percentage at this time may prevent

development temporarily, thus exacerbating the affordability issue even further.

105.a.3. Of the total housing requirement, as at July 2003 a total of 665 units had already

been completed. Therefore only 4323 units remained to be provided for. In

addition, at July 2003, valid planning consents existed for a further 1677 units;

all of these dwellings can legitimately be built. Therefore, consents for a further

2646 units could be approved during the remainder of the plan period. As has

already been stated above (LPA response to Issue 2.e.) 50% of sites coming

forward will be less than 5 units and will not qualify. Therefore the number of

units which could fall to be considered under this policy is approx 1323, which at

30% would yield around 400 affordable units during the plan period. It should be

remembered that this is a mathematical exercise and that in reality a number of

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the consents which existed at July 2003 could fall to be considered again and

that some sites won’t be appropriate etc.

105.a.4. The Objectors misinterpreted that the 30% will be applied rigidly to all

applications. With regard to individual sites – 30% should be the starting point to

any negotiation, however, the appropriate % may vary on a site by site basis

based on other considerations. These points are already clearly set out in Para

9 of the reasoned justification to policy ENVP2.1. The policy contains adequate

flexibility and is fully compliant with TAN2 with regards to the need to consider

site characteristics (Para 12 and 13 of PC 550).

106. Issue 106: The occupancy conditions to be applied are considered either too

flexible or too rigid.

106.a. It is inappropriate that the conditions requirement will not be relaxed (Para 9).

Relaxation should be entertained if there is no longer a proven need. Various

reasons are put forward by Objectors including:

a) Mortgage companies will not support schemes with such strict

controls; and

b) This statement subverts the provisions relating to modifying or

discharging s106 and is potentially unlawful.

106.a.1. The principle that so long as there is need we should not release houses from

the scheme is entirely valid. It would be inequitable to allow owners who

purchased into the scheme to take a capital gain by selling out of it. However as

worded the policy does not allow for the theoretical possibility that the need for

the scheme may not exist for the lifetime of the property. A change is therefore

required to Para 7 as follows:

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PC 550.001:

"Given the evidence of unmet affordable need (as set out in the current

LHNA) applications for the relaxation of the conditions/requirements at the

request of by the owner will not be entertained would be contrary to policy.

For that reason applications for relaxation will not be granted unless material

considerations require a different outcome. If a property….."

106.a.2. With regard to mortgage companies not supporting these schemes due to strict

controls, the restrictions set out in the policy apply to the occupant(s). The

position regarding lenders will be addressed in detail within the s106 clauses

and it is with regard to those clauses that lenders will judge the validity of the

scheme, not against policy H2.1 itself.

106.b. Properties may not sell because there are no qualifying households, which

could lead to empty properties. Amend the text to include a cascade or

sequential test in line with guidance.

106.b.1. The policy relies on the application of occupancy conditions to control price. As

a result the use of a cascade system would create an incentive for owners to not

sell their properties to those higher up the cascade. This is because the wider

the “field” of potential purchasers the higher the price will be. The assessment of

need is on a countywide basis as is the definition of “Local” so that a scheme

which operates on a County basis is felt to be both more robust to operate and

in line with the overall approach to meeting need.

106.c. The statement ‘the price is too high not the conditions too tight’ is simplistic.

This suggests that the developer would need to keep dropping the price,

without a floor limit, until an arbitrary purchaser becomes eligible by virtue of

the low price.

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106.c.1. See LPA response to Issue 106.b above.

106.d. Unless all local affordable housing needs have been met, paragraph 9 should

apply without any exceptions. Therefore Paragraphs 12 and 13 should be

deleted.

106.d.1. Paragraph 12 and 13 (PC 550) of the Reasons set out factors which need to be

considered in assessing a site’s suitability for providing for affordable housing in

accordance with PG(W) TAN(W)2, November 1996, Para 8b. It would be

inappropriate to delete these two paragraphs.

106.e. The restrictions should apply in perpetuity.

106.e.1. Paragraph 7 already clarifies that the restrictions will apply in perpetuity (PC

550). However a further amendment has been proposed in response to Issue

106.a. above because the policy should allow for the theoretical possibility that

the need for the scheme may not exist for the lifetime of the property.

107. Issue 107: Concern has been noted regarding the ‘policing’ of affordable

housing

107.a. No detail is provided regarding the ‘policing mechanism’ referred to in Para 6

(PC 550). Specifically there is concern regarding the costs and practicalities of

the policing mechanism especially as no indication has been provided as to

how policing will be achieved.

107.a.1. It is important to make clear in the policy that the application of the policy will be

policed. It is not necessary to prescribe the mechanism in the policy and indeed

it would be counter productive to do so. If a "loophole" were to be found to the

policing mechanism then it is important to be able to change the mechanism to

close the loophole. Prescribing the mechanism in the policy would prevent this.

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107.b. The word positively’ should be replaced by ‘reasonable’.

107.b.1. The word “positively” is intended to convey an active mechanism which requires

positive confirmation of compliance rather than a passive system which leave

the LPA to discover that the conditions of the scheme have been broken. As

such its replacement with the word “reasonable” would not be appropriate.

107.c. This mechanism is unnecessary and should be deleted because the s106

agreements will ensure that the restrictions are met.

107.c.1. The existence of a legal agreement only has any significance if the party

affected by a breach is aware of the breach. The function of the policing

mechanism is to ensure that transactions do not occur without the LPA being

aware of their existence and terms and requiring positive confirmation of

compliance. The alternative would leave the LPA the task of trying to establish if

a breach had occurred. This is what is meant by “positive policing”. Reference to

the mechanism should be retained.

108. Issue 108: Some of the detailed aspects of the policy are either considered to be

in appropriate, or, lack clarification in their current form.

108.a. It is unclear which WAG document the LPA has relied upon to set the site

thresholds.

108.a.1. See LPA response to Issue 2.e. above.

108.b. The definition of ‘key worker’ is unclear following the deletion of text in

paragraph 3. Objectors have asked for the re - insertion of a definition. Some

have asked for the definition to be revised to include local craftsmen and farm

workers. Others have asked for the definition to be wider than the previous one

to allow for categories which could bring in economic or social benefit to

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Ceredigion, and have suggested specific wording (see Appendix 4,

Representation numbers B/60024, B/60030, B/0032, B/60036, B/60125, B/60130,

B/60135, B/60140, B/60145, B/60150, B/60156, B/60158, B/60166, B/60169 and

B/60174).

108.b.1. This objection is linked to the absence of a definition of Key worker. The phrase

needs definition and is in fact defined in the section 106 agreement which the

LPA is working on. The Council agree that it would be better to re-instate a

definition within the Glossary and to cross refer to this definition within the policy

as follows:

Amend policy H2.1 (550) as follows:

PC 550.001 (Para 3):

“The definition should however be broadened to include other groups such as

key workers (such as someone working in healthcare, social services, local

government, public transport or emergency services); a definition of key

workers can be seen in the Glossary under ‘occupancy restrictions’.”

Amend the Glossary (PC 552) as follows:

PC 552.001:

“Need to be in Ceredigion for employment purposes as key workers on a

full time (37 hours) permanent basis. For the purposes of the UDP, a key

worker is defined as follows:

a) a teacher in a school or in a further education establishment or sixth form

college

b) a nurse or other National Health Service staff

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c) a police officer

d) a probation service employee

e) a social worker

f) an educational psychologist

g) an occupational therapist employed by the local authority

h) a fire service employee

i) any other person whose employment fulfils an important role in the

provision of key services in Ceredigion.”

108.b.2. The concept of a key worker relates to those whose function is integral to the

running of the County’s infrastructure. Where the need can be provided through

a time limited contract or through part time working then this suggests that it’s

extent (as opposed to its nature) is not such as to make it integral to the running

of the infrastructure. While it is possible to debate the limits of the concept a high

degree of clarity around it’s core meaning is considered desirable so that those

entitled to the benefit of the policy will be aware of that entitlement without

reference to the LPA. Acknowledging however the room for debate a general

phrase is included at the end of the policy as amended to refer to others whose

employment plays an important role in the provision of key services.

108.c. Delete reference to ‘to this general definition’ (Para 3). If there is a general

shortage of housing in the Aberystwyth area this should be addressed by

releasing more land for open market housing not increasing the pool of people

who qualify for affordable housing.

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108.c.1. The LPA agree that this reference can be deleted. Para 3 should be amended

as follows:

PC 550.001:

“…In addition to this general definition, within Ceredigion there are areas where

demand for housing is high, such as Aberystwyth, where more people are likely

to face problems of affordability as house prices are pushed up in response to

demand.”…

108.d. The LA should not prescribe who developers can work with (Para 5). The phrase

‘identified by the LA’ should be deleted.

108.d.1. See LPA response to Issue 1.d. above. This is an objection based on the

wording of national guidance (TAN2). The developer can choose to provide

affordable housing units for sale directly to the public or to work with an RSL of

their choice or with the LA (should the LA be minded to go down this route) or

with any other body which might be created in the future and which the LA were

satisfied was capable of delivering affordable housing for rent.

108.d.2. The LPA would need to be satisfied that the developer was capable of delivering

affordable housing for rent – this is why the words ‘identified by the LA’ have

been included. Currently there are limited mechanisms for the delivery of

affordable housing – this may change in the future to include for example Land

Trusts.

108.e. The reference included in paragraph 14, to restricting extensions through the

removal of GPDO rights is considered to be inappropriate and unnecessary. The

use of such restrictions usually require evidence of serious affect on amenity of

the environment. This restriction could prevent occupiers from moving onto the

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next rung. Some objectors ask for the deletion of this text whilst others ask for

a mechanism to be introduced which will allow owners to improve their houses.

108.e.1. The purpose of the removal of GPDO rights is to protect the affordability of the

homes not to prevent all change. If the owner of an affordable home wants to

carry out improvements to the property then the LPA will consider such

proposals and the effect they could have on affordability. Where there is unlikely

to be such an affect then permission will be granted.

108.f. Clarification is sought with regard to how the policy will be applied to sites

which are developed over time (phased).

108.f.1. When the affordable housing element will need to be delivered will depend on

the characteristics of the scheme, however, the initial presumption must always

be pro rata.

108.g. It is unclear how the ‘sell on’ price to subsequent occupiers will be assessed.

108.g.1. The price of affordable houses will be determined by the market just like the

price of any other property. What the policy does it to alter effective demand by

restricting access to those who meet the conditions of the scheme. As a result it

affects price but it does not alter the basis position that the price is dictated by

the market.

108.h. Providing social housing next to private housing is problematic.

108.h.1. See LPA response to Issue 1.c. above.

108.i. Other factors will need to be taken into account when assessing a site’s

suitability for affordable housing and how much affordable housing can be

sought.

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108.i.1. See LPA response to Issue 2.f. above.

109. Issue 109: The validity of the further proposed changes was questioned.

109.a. Procedurally the LPA had no right to publish the Further Proposed Changes

Document (under Para 1.7 of the WAG ‘Unitary Development Plans – Guide to

Procedures’), therefore the document is not eligible for consideration as an

amendment to the UDP.

109.a.1. While acknowledging the existence of the objection the LPA do not understand

the same or feel that it has any merit.

109.b. The policy should not be used until a future date.

109.b.1. This is not a validly made objection. The weight to be given to emerging policy is

not a matter fro the UDP inquiry.

IV. Conclusion

Further proposed changes

IV.a. The LPA propose the following further amendments to policy H2.1 (PC 550):

IV.a.1. Para 3:

PC According to National Guidance, PG(W) TAN(W) 2 550.001 Planning and Affordable Housing, November 1996, affordable housing can include the provision of both low cost market and subsidised housing (irrespective of tenure, exclusive or shared ownership, or financial arrangement) which is available for people who cannot afford to occupy houses that are generally available on the open market. Such people may include, for example, first time buyers and people on low incomes. The definition should however be broadened to include other groups such as key workers (such as someone working in healthcare, social services, local government, public transport or emergency services) a definition of

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key workers can be seen in the Glossary under ‘occupancy restrictions’. In addition to this general definition, within Ceredigion there are areas where demand for housing is high, such as Aberystwyth, where more people are likely to face problems of affordability as house prices are pushed up in response to demand.

IV.a.2. Para 5:

PC 1. “Owned or managed by an RSL, the Local Authority or other 550.001 nominated body identified by the LA and is available for rent or purchase or any combination thereof; or "....

IV.a.3. Para 9:

PC The conditions and requirements not only define an 550.001 affordable dwelling but are also the mechanism through which it becomes affordable. The relaxation of the conditions/requirements would lead to an increase in the dwellings value. Given the evidence of unmet affordable need (as set out in the current LHNA) applications for the relaxation of the conditions/requirements at the request of by the owner will not be entertained would be contrary to policy. For that reason applications for relaxation will not be granted unless material considerations require a different outcome. If a property is not selling then the price is to high not the conditions to tight. The underlined expressions are further defined in the glossary (page X).

IV.a.3.1. Para 10 & 11:

PC Whether an element of affordable housing is required will be determined by the 550.001 Council and will depend on the existence of need and the feasibility of meeting the provision. Issues which may be considered when In determining affordable housing need may include the LPA will refer to the current LHNA and/or other relevant information. Such other information may include:

• Bespoke local needs housing assessments; • Local market housing prices/rents; • Local incomes; • Supply and suitability (size and type) of existing stock (rent/buy); • Nature of proposed development (type of housing proposed); • Other factors which may affect/restrict access to housing within the community for example the proportion of houses that are second homes;

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• Housing waiting list; • Community surveys, and/or local needs surveys both existing and proposed such as Llandysul and Pontweli Ymlaen Community survey 1994; • Census data; • Welsh House Condition Survey Information; • ‘Housing circumstances in Ceredigion’, report by Rural Surveys Research Unit (RSRU) Aberystwyth 1996; • Information from the housing section of the Council; • Other relevant information at the time. This change has been proposed in response to Issue 109.a. in the LPA Proof on

policy H2.2.

IV.b. The LPA also propose changes to other parts of the UDP as follows:

IV.b.1. Amend the Glossary, clause (iii) of PC 552, as follows:

PC Need to be in Ceredigion for employment purposes as 552.001 key workers on a full time (37 hours) permanent basis.

For the purposes of the UDP, a key worker is defined as

follows:

a) a teacher in a school or in a further education

establishment or sixth form college;

b) a nurse or other National Health Service staff;

c) a police officer;

d) a probation service employee;

e) a social worker;

f) an educational psychologist;

g) an occupational therapist employed by the local

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authority;

h) a fire service employee;

i) any other person whose employment fulfils an important role

in the provision of key services in Ceredigion.

IV.c. The Inspector is invited to approve for adoption policy H2.1 as amended by

proposed change PC 151, further proposed change PC 550 and further amended

by PC 550.001.

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Appendix 1

List of Objections by Objectors

Representation Numbers Names of Respondents Issues PC Number to Meet Issue

R/5081 S/60003 PC/550 Cyngor Tref Llambed/Lampeter Town Council

R/5106 B/34006 Mr Robert Arwel Jones 1.b., 1.f. PC 550, PC 551 & PC 552 & 2.a. PC 552

R/5143 B/30227 Mrs Mari Llwyd 1.b., 1.f. PC 550, PC 551 & PC 552 & 2.a. PC 552

R/5225 S/30560 Welsh Development Agency

R/5228 S/30548 Ceredigion Green Party

R/5229 S/30814 Mr Chris Simpson

R/5235 S/30559 Cyngor Tref Aberystwyth Town Council

R/5242 B/60187 PC/550 Mr Llwyd Edwards 104.a., 105.a., 108.e., 108.h. & 109.b.

R/5243 S/60018 PC/550 CCW

R/5244 B/30542 Welsh Assembly Government 2.c. PC 151

R/5245 B/30555 McCarthey and Stone (Developments) Ltd 2.e., 2.f. & 3.a.

R/5247 S/60017 PC/550 Cyngor Cymuned Dyffryn Arth Community Council

R/5249 B/33991 Dr Simon Charles Ifor Brooks ar gyfer/for Cymuned 1.b., 1.f. PC 550, PC 551 & PC 552 & 2.a. PC 552

R/5249 B/60041 PC/550 Dr Simon Charles Ifor Brooks ar gyfer/for Cymuned 105.a.

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R/5259 B/30425 Mr Simon Thomas (AS/MP) 1.a.

R/5259 B/60043 PC/550 Mr Simon Thomas (AS/MP) 105.a. & 108.f.

R/5262 B/30556 Ms S Jones Davies ar ran Plaid Cymru Cangen Goronwy 1.e. PC 550, PC 551 & PC 552

R/5263 B/30558 Ms Dilys Mary Parkin 1.e. PC 550, PC 551 & PC 552

R/5275 B/50843 PC/151 Mrs Mirja Kaarina Wynn-Williams 101.a. & 101.b.

R/5275 B/60195 PC/550 Mrs Mirja Kaarina Wynn-Williams 104.d., 104.f., 106.d. & 109.a.

R/5278 B/50857 PC/151 Mr Alun Tudor Wynn-Williams 101.a. & 101.b.

R/5278 B/60189 PC/550 Mr Alun Tudor Wynn-Williams 104.d., 104.f., 106.d. & 109.a.

R/5281 B/30557 Mr Ian Jones 1.c., 1.d. & 2.b.

R/5281 B/60095 PC/550 Mr Ian Jones 102.a., 104.e., 105.a. & 106.c.

R/5286 B/30569 Plaid Cymru: The Party of Wales Cangen Aberystwyth a Phenparcau 1.f. PC 550, PC 551 & PC 552

R/5301 B/60047 PC/550 Ms Elin Jones ( AC / AM Ceredigion ) 105.a. & 108.f.

R/5303 B/33993 Ms Menna Davies 1.b., 1.f. PC 550, PC 551 & PC 552 & 2.a. PC 552

R/5304 B/33988 Mr Elgan Philip Davies 1.b., 1.f. PC 550, PC 551 & PC 552 & 2.a. PC 552

R/5313 B/60050 PC/550 Pwyllgor Etholaeth Plaid Cymru Ceredigion 105.a. & 108.f.

R/5324 S/60039 PC/550 Mr M O James

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R/5339 B/34003 Mr Huw Roberts 1.b., 1.f. PC 550, PC 551 & PC 552 & 2.a. PC 552

R/5342 B/33992 Mr Emyr Hywel ar gyfer/for Cymuned 1.b., 1.f. PC 550, PC 551 & PC 552 & 2.a. PC 552

R/5361 B/34002 Mr Dafydd Evans 1.b., 1.f. PC 550, PC 551 & PC 552 & 2.a. PC 552

R/5396 B/60094 PC/550 Cyngor Cymuned Llanwenog Community Council 108.e. & 108.g.

R/5426 B/60049 PC/550 Cyngor Cymuned Henfynyw Community Council 108.b. PC 550.001 & PC 552.001

R/5455 S/60015 PC/550 Messrs T H J & C A Rees

R/5671 S/60009 PC/550 Mr D J Davies

R/6306 B/60122 PC/550 Jamson Estates Ltd , Tresaith 104.a., 105.a., 108.e. & 108.i.

R/6783 B/33994 Mr J E C Lumley 1.b., 1.f. PC 550, PC 551 & PC 552 & 2.a. PC 552

R/6784 B/33996 Mr David Edward Evans 1.b., 1.f. PC 550, PC 551 & PC 552 & 2.a. PC 552

R/6785 B/33998 Mr Nigel Scollan 1.b., 1.f. PC 550, PC 551 & PC 552 & 2.a. PC 552

R/6786 B/33999 Mr John Alan Lovatt 1.b., 1.f. PC 550, PC 551 & PC 552 & 2.a. PC 552

R/6787 B/34000 Ms Teresa Davies 1.b., 1.f. PC 550, PC 551 & PC 552 & 2.a. PC 552

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R/7754 B/60201 PC/550 Mr Steven Gough 105.a.

R/7774 B/35779 Mr Penri James 2.d. PC 151

R/7791 B/60069 PC/550 Mr & Mrs J V & S L Elias - Beulah 105.a., 106.a., PC 550.001 106.c., 107.a., 107.c., 108.a., 108.b., PC 550.001 & PC 552.001 108.c. PC 550.001 & 108.e.

R/7848 B/60052 PC/550 The House Builders Federation 105.a., 106.a., PC 550.001 108.b. PC 550.001 & PC 552.001 & 108.d.

R/7900 B/60024 PC/550 Mr Mike Williams 104.c., PC 550.001 105.a., 107.a., 107.b., 108.b. PC 550.001 & PC 552.001 & 108.e.

R/7901 B/60028 PC/550 Mr Martin Douglas Turnpenney 108.e.

R/7902 B/60029 PC/550 Mr Stewart Kinninmonth 105.a.

R/7903 B/60030 PC/550 Mr Robert James Mc Burnie 108.b. PC 550.001 & PC 552.001

R/7904 B/60032 PC/550 Mr Geraint Wyn Hughes 104.c., PC 550.001 105.a., 108.b. PC 550.001 & PC 552.001 & 108.e.

R/7905 B/60036 PC/550 Lawrence and Williams Ltd 104.c., PC 550.001 105.a., 107.a., 107.b., 108.b. PC 550.001 & PC 552.001 & 108.e.

R/7906 B/60045 PC/550 Cyngor Cymuned Trefeurig Community Council 102.a. & 105.a.

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R/7907 B/60054 PC/550 Ifor Jones Builders 105.a., 106.a., PC 550.001 106.c., 107.a., 107.c., 108.a., 108.b., PC 550.001 & PC 552.001 108.c. PC 550.001 & 108.e.

R/7908 B/60064 PC/550 S & R Develpoments 105.a., 106.a., PC 550.001 106.c., 107.a., 107.c., 108.a., 108.b., PC 550.001 & PC 552.001 108.c. PC 550.001 & 108.e.

R/7909 B/60074 PC/550 Sansom Develpoments 105.a., 106.a., PC 550.001 106.c., 107.a., 107.c., 108.a., 108.b., PC 550.001 & PC 552.001 108.c. PC 550.001 & 108.e.

R/7910 B/60079 PC/550 Creugiau Developments 105.a., 106.a., PC 550.001 106.c., 107.a., 107.c., 108.a., 108.b., PC 550.001 & PC 552.001 108.c. PC 550.001 & 108.e.

R/7911 B/60084 PC/550 Rheidol Developments Ltd 105.a., 106.a., PC 550.001 106.c., 107.a., 107.c., 108.a., 108.b., PC 550.001 & PC 552.001 108.c. PC 550.001 & 108.e.

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R/7912 B/60089 PC/550 J Thomas Builders 105.a., 106.a., PC 550.001 106.c., 107.a., 107.c., 108.a., 108.b., PC 550.001 & PC 552.001 108.c. PC 550.001 & 108.e.

R/7913 B/60097 PC/550 Mr Wil Lewis 103.a.

R/7914 B/60102 PC/550 Ms Joan Davies 103.a.

R/7915 B/60107 PC/550 Mr Alun Price Jones 103.a.

R/7916 B/60112 PC/550 Ms Joy Dark 103.a.

R/7917 B/60117 PC/550 Mr Morgan John Jones 108.e.

R/7918 B/60125 PC/550 Griffiths Superior Homes Ltd 104.c., PC 550.001 105.a., 107.a., 107.b., 108.b. PC 550.001 & PC 552.001 & 108.e.

R/7919 B/60130 PC/550 Mark Skitt Ltd 104.c., PC 550.001 105.a., 107.a., 107.b., 108.b. PC 550.001 & PC 552.001 & 108.e.

R/7920 B/60135 PC/550 J Thomas Property Developer & Building Contractor 104.c., PC 550.001 105.a., 107.a., 107.b., 108.b. PC 550.001 & PC 552.001 & 108.e.

R/7921 B/60140 PC/550 Mr Alan Haird 104.c., PC 550.001 105.a., 107.a., 107.b., 108.b. PC 550.001 & PC 552.001 & 108.e.

R/7922 B/60145 PC/550 SAH Developments Ltd 104.c., PC 550.001 105.a., 107.a., 107.b., 108.b. PC 550.001 & PC 552.001 & 108.e.

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R/7923 B/60150 PC/550 Mr I W M Leushon 104.c., PC 550.001 105.a., 107.a., 107.b., 108.b. PC 550.001 & PC 552.001 & 108.e.

R/7925 B/60156 PC/550 Robert Aled Ellis 105.a. & 108.b. PC 550.001 & PC 552.001

R/7926 B/60158 PC/550 Mr J E Charles Raw-Rees 104.c., PC 550.001 105.a., 107.a., 107.b., 108.b. PC 550.001 & PC 552.001 & 108.e.

R/7927 B/60163 PC/550 Mr Michael Kent 105.a.

R/7929 B/60166 PC/550 Miss Nicola Jane Vaientine 108.b. PC 550.001 & PC 552.001

R/7930 B/60167 PC/550 Mr Derek Donald Ross 105.a.

R/7931 B/60168 PC/550 Mr William Copeland 108.e.

R/7932 B/60169 PC/550 Dilwyn Roberts Architects 104.c., PC 550.001 105.a., 107.a., 107.b., 108.b. PC 550.001 & PC 552.001 & 108.e.

R/7933 B/60174 PC/550 RL Wales 104.c., PC 550.001 105.a., 107.a., 107.b., 108.b. PC 550.001 & PC 552.001 & 108.e.

R/7934 B/60186 PC/550 Mr Julian Evans 103.b., 104.b., 105.a. & 106.e.

R/7935 B/60059 PC/550 Dr D Adams 105.a., 106.a., PC 550.001 106.c., 107.a., 107.c., 108.a., 108.b., PC 550.001 & PC 552.001 108.c. PC 550.001 & 108.e.

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(R= Respondent Number, Representation Number S= Support B= Objection, PC= Proposed Change Number) (R/9999 B/99999 PC/000 A Another = Conditional Withdrawl of Objection) (R/9999 B/99999 PC/000 A Another = Unconditional Withdrawl of Objection)

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Appendix 2

Representations received to the UDP Deposit Version

Respondent Name Mr Robert Arwel Jones Respondent Number R/5106 Agent (Y or N) N Contact Name Mr R A Jones Contact Position and Company (if applicable) Contact Address Is-y-Coed, 10 Rhes Gogerddan, Aberystwyth Ceredigion SY23 2ET Admin Number D/2439 Representation Number B/34006 Summary Objection to policy H2.1 as it lacks specific reference to the use of local residency conditions (S106) in ensuring affordable housing for local people. The UDP strategy for providing affordable housing is criticised - building enough houses to meet demand from outside the County in order to reduce house prices for local people will not meet local affordable need. The approach is flawed in that: it will be detrimental to Welsh language; and the needs of local people become secondary to those moving in from outside the County.

Requests that: ‘local need’ be defined and occupancy restrictions applied; and that the policy is used to create and expand a permanent stock of houses safeguarded for local affordable needs.

Respondent Name Mrs Mari Llwyd Respondent Number R/5143 Agent (Y or N) N Contact Name Mrs M Llwyd Contact Position and Company (if applicable) Contact Address Erw Sant, 17 Trefaenor, Commins Coch, Aberystwyth Ceredigion SY23 3UB Admin Number D/355 Representation Number B/30227 Summary Objection to policy H2.1 as it lacks specific reference to the use of local residency conditions (S106) in ensuring affordable housing for local people. The UDP strategy for providing affordable housing is criticised - building enough houses to meet demand from outside the County in order to reduce house prices for local people will not meet local affordable need. The approach is flawed in that: it will be detrimental to Welsh language; and the needs of local people become secondary to those moving in from outside the County.

Requests that: ‘local need’ be defined and occupancy restrictions applied; and that the policy is used to create and expand a permanent stock of houses safeguarded for local affordable needs.

Respondent Name Welsh Development Agency Respondent Number R/5225 Agent (Y or N) N Contact Name Mr M J Hollingsworth Contact Position and Planning Director

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Company (if applicable) Contact Address Land Division, 6 th Floor, Principality House, The Friary, Caerdydd / Cardiff CF10 3FE Admin Number D/939 Representation Number S/30560 Summary Support for policy. Supports provision of affordable housing where local need is demonstrated.

Respondent Name Ceredigion Green Party Respondent Number R/5228 Agent (Y or N) N Contact Name Mr C Simpson Contact Position and Secretary Company (if applicable) Contact Address Trewylan, Ffordd Brynymor, Aberystwyth Ceredigion SY23 2HX Admin Number D/427 Representation Number S/30548 Summary Support for policy.

Respondent Name Mr Chris Simpson Respondent Number R/5229 Agent (Y or N) N Contact Name Mr C Simpson Contact Position and Company (if applicable) Contact Address Trewylan, Ffordd Brynymor, Aberystwyth Ceredigion SY23 2HX Admin Number D/426 Representation Number S/30814 Summary Support for policy.

Respondent Name Cyngor Tref Aberystwyth Town Council Respondent Number R/5235 Agent (Y or N) N Contact Name Mr J O Griffiths Contact Position and Clerc y Dref/Town Clerk Company (if applicable) Contact Address Mayor's Parlour, Town Hall, Aberystwyth Ceredigion SY23 2EB Admin Number D/916 Representation Number S/30559 Summary Support for policy, especially in terms of first time buyers.

Respondent Name Welsh Assembly Government Respondent Number R/5244 Agent (Y or N) N Contact Name Ms K Powell Contact Position and Head of Planning Company (if applicable)

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Contact Address Planning Division P3 Branch, Cathays Park, Caerdydd / Cardiff CF1 3NQ Admin Number D/1221 Representation Number B/30542 Summary Objection to policy H2.1. Include definition within the policy of 'larger housing development ('10 or more units in the main towns and 5 or more units elsewhere' as set out in reasons to policy).

Respondent Name McCarthey and Stone (Developments) Ltd Respondent Number R/5245 Agent (Y or N) Y Contact Name Mr N Pugsley Contact Position and c/o The Planning Bureau Ltd Company (if applicable) Contact Address Homelife House, 26-32 Oxford Road, Bournemouth Dorest BH8 8EZ Admin Number D/845 Representation Number B/30555 Summary Objection to policy H2.1 as it goes beyond government guidance (Circular 6/98 and PPG3) and lacks justification. Thresholds are unjustified, go beyond guidance and aren't based on a housing needs survey. The council should take a balanced approach in meeting full housing need, including consideration of other possible affordable housing solutions in meeting need. The policy should also refer to other factors which will be taken into account when assessing a site's suitability for affordable housing (para 10 Circular 6/98). Re-draft policy in accordance with guidance.

Respondent Name Dr Simon Charles Ifor Brooks ar gyfer/for Cymuned Respondent Number R/5249 Agent (Y or N) Y Contact Name Dr S C I Brooks Contact Position and Company (if applicable) Contact Address Morlais, Talybont Ceredigion SY24 5HD Admin Number D/923 Representation Number B/33991 Summary Objection to policy H2.1 as it lacks specific reference to the use of local residency conditions (S106) in ensuring affordable housing for local people. The UDP strategy for providing affordable housing is criticised - building enough houses to meet demand from outside the County in order to reduce house prices for local people will not meet local affordable need. The approach is flawed in that: it will be detrimental to Welsh language; and the needs of local people become secondary to those moving in from outside the County.

Requests that: ‘local need’ be defined and occupancy restrictions applied; and that the policy is used to create and expand a permanent stock of houses safeguarded for local affordable needs.

Respondent Name Mr Simon Thomas (AS/MP) Respondent Number R/5259 Agent (Y or N) N Contact Name Mr S Thomas Contact Position and AS / MP for Ceredigion Company (if applicable)

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Contact Address Swyddfa'r Etholaeth/Constituency Office, Ty Goronwy, 32 Heol y Wig/Pier Street, Aberystwyth Ceredigion SY23 2LN Admin Number D/934 Representation Number B/30425 Summary Objection to policy as the Council has not prepared a local needs survey. A local needs survey should be prepared and consulted upon.

Respondent Name Ms S Jones Davies ar ran Plaid Cymru Cangen Goronwy Respondent Number R/5262 Agent (Y or N) N Contact Name Ms S Jones Davies Contact Position and Company (if applicable) Contact Address Penhelig, 9 Trefor Road, Aberystwyth Ceredigion SY23 2EU Admin Number D/1899 Representation Number B/30556 Summary Objection to policy H2.1 as it does not mention that the housing will be for local people.

Amend policy as follows:

"..the Council will seek to negotiate the inclusion of an element of affordable housing for local people."

Respondent Name Ms Dilys Mary Parkin Respondent Number R/5263 Agent (Y or N) N Contact Name Ms D M Parkin Contact Position and Company (if applicable) Contact Address 4 Waun gau, Commins Coch, Aberystwyth Ceredigion SY23 3BN Admin Number D/1140 Representation Number B/30558 Summary Objection to Policy H2.1 as it does not mention that the housing will be for local people.

Amend policy as follows: "..the Council will seek to negotiate the inclusion of an element of affordable housing for local people.

Respondent Name Mr Ian Jones Respondent Number R/5281 Agent (Y or N) N Contact Name Mr I Jones Contact Position and Company (if applicable) Contact Address Tair Llyn, Cwmrheidol, Aberystwyth Ceredigion SY23 3NA Admin Number D/1689 Representation Number B/30557 Summary Objection to policy H2.1 for the following reasons: - it does not specifically allocate sites for affordable housing. Allocating specific sites

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would reduce the initial cost of the land/thus reducing the cost of providing affordable housing; - providing social housing adjacent to private dwellings is considered problematic; and -forcing developers into a business relationship with non-governmental parties is an infringement of the developers rights.

Sufficient land should be specifically designated and protected for affordable housing where there is demonstrated local need for this provision.

Respondent Name Plaid Cymru: The Party of Wales Cangen Aberystwyth a Phenparcau Respondent Number R/5286 Agent (Y or N) N Contact Name Mr L L Dafis Contact Position and Company (if applicable) Contact Address D/O Swyddfa Plaid Cymru, Heol y Wig, Aberystwyth Ceredigion SY23 Admin Number D/937 Representation Number B/30569 Summary Objection to policy H2.1. The policy should refer to the use of local occupancy conditions (S106) as a means of securing affordable housing for local people.

Respondent Name Ms Menna Davies Respondent Number R/5303 Agent (Y or N) N Contact Name Ms M Davies Contact Position and Company (if applicable) Contact Address 11 Maes Afallen, Bow Street, Aberystwyth Ceredigion SY24 5BL Admin Number D/1114 Representation Number B/33993 Summary Objection to policy H2.1 as it lacks specific reference to the use of local residency conditions (S106) in ensuring affordable housing for local people. The UDP strategy for providing affordable housing is criticised - building enough houses to meet demand from outside the County in order to reduce house prices for local people will not meet local affordable need. The approach is flawed in that: it will be detrimental to Welsh language; and the needs of local people become secondary to those moving in from outside the County.

Requests that: ‘local need’ be defined and occupancy restrictions applied; and that the policy is used to create and expand a permanent stock of houses safeguarded for local affordable needs.

Respondent Name Mr Elgan Philip Davies Respondent Number R/5304 Agent (Y or N) N Contact Name Mr E P Davies Contact Position and Company (if applicable) Contact Address 11 Maes Afallen, Bow Street, Aberystwyth Ceredigion SY24 5BL Admin Number D/906 Representation Number B/33988

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Summary Objection to policy H2.1 as it lacks specific reference to the use of local residency conditions (S106) in ensuring affordable housing for local people. The UDP strategy for providing affordable housing is criticised - building enough houses to meet demand from outside the County in order to reduce house prices for local people will not meet local affordable need. The approach is flawed in that: it will be detrimental to Welsh language; and the needs of local people become secondary to those moving in from outside the County.

Requests that: ‘local need’ be defined and occupancy restrictions applied; and that the policy is used to create and expand a permanent stock of houses safeguarded for local affordable needs.

Respondent Name Mr Huw Roberts Respondent Number R/5339 Agent (Y or N) N Contact Name Mr H Roberts Contact Position and Company (if applicable) Contact Address Llys-y-Coed, Rhodfa'r Paun, Lon Meirion, Bangor Gwynedd LL57 2BU Admin Number D/2213 Representation Number B/34003 Summary Objection to policy H2.1 as it lacks specific reference to the use of local residency conditions (S106) in ensuring affordable housing for local people. The UDP strategy for providing affordable housing is criticised - building enough houses to meet demand from outside the County in order to reduce house prices for local people will not meet local affordable need. The approach is flawed in that: it will be detrimental to Welsh language; and the needs of local people become secondary to those moving in from outside the County.

Requests that: ‘local need’ be defined and occupancy restrictions applied; and that the policy is used to create and expand a permanent stock of houses safeguarded for local affordable needs.

Respondent Name Mr Emyr Hywel ar gyfer/for Cymuned Respondent Number R/5342 Agent (Y or N) Y Contact Name Mr E Hywel Contact Position and Company (if applicable) Contact Address Cnwc yr Onnen, Blaenporth, Aberteifi/Cardigan Ceredigion SA43 2BD Admin Number D/956 Representation Number B/33992 Summary Objection to policy H2.1 as it lacks specific reference to the use of local residency conditions (S106) in ensuring affordable housing for local people. The UDP strategy for providing affordable housing is criticised - building enough houses to meet demand from outside the County in order to reduce house prices for local people will not meet local affordable need. The approach is flawed in that: it will be detrimental to Welsh language; and the needs of local people become secondary to those moving in from outside the County.

Requests that: ‘local need’ be defined and occupancy restrictions applied; and that the policy is used to create and expand a permanent stock of houses safeguarded for local affordable needs.

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Respondent Name Mr Dafydd Evans Respondent Number R/5361 Agent (Y or N) N Contact Name Mr D Evans Contact Position and Company (if applicable) Contact Address 14 Ffordd Portland, Aberystwyth Ceredigion SY23 2NL Admin Number D/2191 Representation Number B/34002 Summary Objection to policy H2.1 as it lacks specific reference to the use of local residency conditions (S106) in ensuring affordable housing for local people. The UDP strategy for providing affordable housing is criticised - building enough houses to meet demand from outside the County in order to reduce house prices for local people will not meet local affordable need. The approach is flawed in that: it will be detrimental to Welsh language; and the needs of local people become secondary to those moving in from outside the County.

Requests that: ‘local need’ be defined and occupancy restrictions applied; and that the policy is used to create and expand a permanent stock of houses safeguarded for local affordable needs.

Respondent Name Mr J E C Lumley Respondent Number R/6783 Agent (Y or N) N Contact Name Mr J E C Lumley Contact Position and Company (if applicable) Contact Address Hafan, Cilcennin, Llanbedr Pont Seffan/Lampeter Ceredigion SA48 8RH Admin Number D/1247 Representation Number B/33994 Summary Objection to policy H2.1 as it lacks specific reference to the use of local residency conditions (S106) in ensuring affordable housing for local people. The UDP strategy for providing affordable housing is criticised - building enough houses to meet demand from outside the County in order to reduce house prices for local people will not meet local affordable need. The approach is flawed in that: it will be detrimental to Welsh language; and the needs of local people become secondary to those moving in from outside the County.

Requests that: ‘local need’ be defined and occupancy restrictions applied; and that the policy is used to create and expand a permanent stock of houses safeguarded for local affordable needs.

Respondent Name Mr David Edward Evans Respondent Number R/6784 Agent (Y or N) N Contact Name Mr D E Evans Contact Position and Company (if applicable) Contact Address Llys-y-Coed, Cilcennin, Llanbedr Pont Steffan/Lampeter Ceredigion SA48 8RF Admin Number D/1276 Representation Number B/33996

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Summary Objection to policy H2.1 as it lacks specific reference to the use of local residency conditions (S106) in ensuring affordable housing for local people. The UDP strategy for providing affordable housing is criticised - building enough houses to meet demand from outside the County in order to reduce house prices for local people will not meet local affordable need. The approach is flawed in that: it will be detrimental to Welsh language; and the needs of local people become secondary to those moving in from outside the County.

Requests that: ‘local need’ be defined and occupancy restrictions applied; and that the policy is used to create and expand a permanent stock of houses safeguarded for local affordable needs.

Respondent Name Mr Nigel Scollan Respondent Number R/6785 Agent (Y or N) N Contact Name Mr N Scollan Contact Position and Company (if applicable) Contact Address Aberdeuddwr, Llangwyryfon, Aberystwyth Ceredigion SY23 4HA Admin Number D/1288 Representation Number B/33998 Summary Objection to policy H2.1 as it lacks specific reference to the use of local residency conditions (S106) in ensuring affordable housing for local people. The UDP strategy for providing affordable housing is criticised - building enough houses to meet demand from outside the County in order to reduce house prices for local people will not meet local affordable need. The approach is flawed in that: it will be detrimental to Welsh language; and the needs of local people become secondary to those moving in from outside the County.

Requests that: ‘local need’ be defined and occupancy restrictions applied; and that the policy is used to create and expand a permanent stock of houses safeguarded for local affordable needs.

Respondent Name Mr John Alan Lovatt Respondent Number R/6786 Agent (Y or N) N Contact Name Mr J A Lavatt Contact Position and Company (if applicable) Contact Address Llainlwyd, Stry Fawr, Llanon Ceredigion SY23 5HH Admin Number D/1289 Representation Number B/33999 Summary Objection to policy H2.1 as it lacks specific reference to the use of local residency conditions (S106) in ensuring affordable housing for local people. The UDP strategy for providing affordable housing is criticised - building enough houses to meet demand from outside the County in order to reduce house prices for local people will not meet local affordable need. The approach is flawed in that: it will be detrimental to Welsh language; and the needs of local people become secondary to those moving in from outside the County.

Requests that: ‘local need’ be defined and occupancy restrictions applied; and that the policy is used to create and expand a permanent stock of houses safeguarded for local affordable needs.

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Respondent Name Ms Teresa Davies Respondent Number R/6787 Agent (Y or N) N Contact Name Ms T Davies Contact Position and Company (if applicable) Contact Address Llys Teg, 4 Union St, Aberystwyth Ceredigion SY23 1NX Admin Number D/1293 Representation Number B/34000 Summary Objection to policy H2.1 as it lacks specific reference to the use of local residency conditions (S106) in ensuring affordable housing for local people. The UDP strategy for providing affordable housing is criticised - building enough houses to meet demand from outside the County in order to reduce house prices for local people will not meet local affordable need. The approach is flawed in that: it will be detrimental to Welsh language; and the needs of local people become secondary to those moving in from outside the County.

Requests that: ‘local need’ be defined and occupancy restrictions applied; and that the policy is used to create and expand a permanent stock of houses safeguarded for local affordable needs.

Respondent Name Mr Penri James Respondent Number R/7774 Agent (Y or N) N Contact Name Mr P James Contact Position and Company (if applicable) Contact Address Gwyniarth, Taigwynion, Llandre, Bow Street Ceredigion SY24 5AG Admin Number D/2449 Representation Number B/35779 Summary Objection to policy H2.1 because the wording of the policy is ambiguous. Developers would be able to build a series of less than 10 or 5 units on the same site in order to avoid the policy. The policy should refer to the total number of units on the site.

Amend to refer to 10 or 5 units on the same site and not individual applications.

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Appendix 3

Representations received to the UDP Proposed Changes Document (February

2004)

Respondent Name Mrs Mirja Kaarina Wynn-Williams Respondent Number R/5275 Agent (Y or N) N Contact Name Mrs M K Wynn-Williams Contact Position and Company (if applicable) Contact Address Bryn Elmen, Dolybont, Borth Ceredigion SY24 5LY Admin Number C/5324 Representation Number B/50843 Summary Objection to the proposed changes to Policy H2.1 because: - The criterion that a site or part of a site is capable of accommodating 10 units or more in the main towns and 5 units or more elsewhere is to too vague and subjective, and so might lead to disputes and contention. Site area would be a much better criterion as it is clearer and objective. According to the Planning Guidance (Wales) Planning Policy Joint Housing Land Availability Study for Ceredigion of 30th June 2000, the average density of housing on all housing estates in Ceredigion was then 18.1 houses per hectare. This should form the basis of the criterion, with the area rounded upwards slightly to allow for the less efficient use of land sometimes unavoidable on small sites with less suitable dimensions; and - It is inappropriate that the Council alone should decide whether the feasibility of meeting the provision would justify requiring an element of affordable housing as it is unlikely that the Council would exercise this power impartially.

In the Policy replace: 'that is capable of accommodating 10 units or more in the main towns and 5 units or more elsewhere),' with 'that is 0.6 hectares or more in area in the main towns and 0.3 hectares or more in area elsewhere),'

In the Reasons (Para 5) replace: 'Council and' with 'Council and subject to review by the Welsh Assembly at the request of any member of the public, and'

Respondent Name Mr Alun Tudor Wynn-Williams Respondent Number R/5278 Agent (Y or N) N Contact Name Mr T Wynn-Williams Contact Position and Company (if applicable) Contact Address Bryn Elmen, Dolybont, Borth Ceredigion SY24 5LY Admin Number C/5323 Representation Number B/50857 Summary Objection to the proposed changes to Policy H2.1 because: - The criterion that a site or part of a site is capable of accommodating 10 units or more in the main towns and 5 units or more elsewhere is to too vague and subjective, and so might lead to disputes and contention. Site area would be a much better criterion as it is clearer and objective. According to the Planning Guidance (Wales) Planning Policy Joint Housing Land Availability Study for Ceredigion of 30th June 2000, the average density of housing on all housing estates in Ceredigion was then 18.1 houses per hectare. This should form the basis of the criterion, with the area rounded upwards slightly to allow for the less efficient use of land sometimes unavoidable on small sites with less suitable dimensions; and - It is inappropriate that the Council alone should decide whether the feasibility of meeting the provision would justify requiring an element of affordable housing as it is

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unlikely that the Council would exercise this power impartially.

In the Policy replace: 'that is capable of accommodating 10 units or more in the main towns and 5 units or more elsewhere),' with 'that is 0.6 hectares or more in area in the main towns and 0.3 hectares or more in area elsewhere),'

In the Reasons (Para 5) replace: 'Council and' with 'Council and subject to review by the Welsh Assembly at the request of any member of the public, and'

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Appendix 4

Representations received to the UDP Further Proposed Changes 1 (September

2004)

Respondent Name Cyngor Tref Llambed/Lampeter Town Council Respondent Number R/5081 Agent (Y or N) N Contact Name Mr D I Williams Contact Position and Clerc/Clerk Company (if applicable) Contact Address Town Clerk's Office, Brynfedwen, Cellan, Llanbedr Pont Steffan/Lampeter Ceredigion SA48 8HX Admin Number C1/6383 Representation Number S/60003 Summary Support

Respondent Name Mr Llwyd Edwards Respondent Number R/5242 Agent (Y or N) N Contact Name Mr Ll Edwards Contact Position and Company (if applicable) Contact Address The Old Stables, St Mary St, Aberteifi/Cardigan Ceredigion SA43 1HA Admin Number C1/6435 Representation Number B/60187 Summary Objection to the proposed changes to policy H2.1 (550). The policy appears hastily drafted and ill-considered and hence unfair in implementation, unreasonable in terms of building economics and uncontrollable in practice because: - these new policies should be implanted at a future date rather than now; - the method of achieving affordable housing is questionable; and - the number of affordable homes’ to be achieved should not be left to the vagaries of the housing market.

Specifically: Paragraph 9: The Council should identify and designate areas that are already in the UDP as suitable for ‘affordable housing’. Such sites would probably be on the borders of towns or larger settlements. This will ensure that numbers are achieved, that sites are satisfactory (position, infrastructure services etc.) and that land values would reflect ‘affordability’.

The 30% target, if adopted, does not suit all sites - some sites will be suitable for less, some for more. The figure should be treated as a guide only.

The requirement for all smaller developments to include an element of ‘affordable housing’ will probably restrict the overall number of new houses that are built in the County.

In addition it will create unworkable housing mixes because it will be difficult to achieve true market value of say 4 freehold houses if they have one small one in the middle.

Paragraph 14: The amendments will unreasonably restrict owners of small ‘affordable houses’ from moving on to the next ‘rung’ on the housing ladder if they are unable to improve/enlarge their property. Removing GPRO rights means that such properties are only suitable for renting – thus disadvantaging those who want to buy. Introduce a mechanism which will allow owners to improve their houses.

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Respondent Name CCW Respondent Number R/5243 Agent (Y or N) N Contact Name Ms L Tomos Contact Position and Area Officer West Wales Company (if applicable) Contact Address West Area Office, Plas Gogerddan, Aberystwyth Ceredigion SY23 3EE Admin Number C1/6408 Representation Number S/60018 Summary Support

Respondent Name Cyngor Cymuned Dyffryn Arth Community Council Respondent Number R/5247 Agent (Y or N) N Contact Name Mr E D Ellis Contact Position and Clerc/Clerk Company (if applicable) Contact Address Nantgwynfynydd, Bethania, Llanon Ceredigion SY23 5NJ Admin Number C1/6404 Representation Number S/60017 Summary Support

Respondent Name Dr Simon Charles Ifor Brooks ar gyfer/for Cymuned Respondent Number R/5249 Agent (Y or N) Y Contact Name Dr S C I Brooks Contact Position and Company (if applicable) Contact Address Morlais, Talybont Ceredigion SY24 5HD Admin Number C1/6454 Representation Number B/60041 Summary Objection to the proposed amendment to policy H2.1 (PC 550) as the 30% figure is too low. The policy is supported in principle however a target figure of 75% of all housing to be affordable would be more appropriate. This suggestion is put forward baring in mind that Pembrokeshire Coast National Park are suggesting that all new housing within the park should be for local people, and the fact that housing in Ceredigion is the least affordable in Wales according to recent figures (six times higher than the average income).

Respondent Name Mr Simon Thomas (AS/MP) Respondent Number R/5259 Agent (Y or N) N Contact Name Mr S Thomas Contact Position and AS / MP for Ceredigion Company (if applicable) Contact Address Swyddfa'r Etholaeth/Constituency Office, Ty Goronwy, 32 Heol y Wig/Pier Street, Aberystwyth Ceredigion SY23 2LN Admin Number C1/6455

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Representation Number B/60043 Summary Objection to the proposed amendment to policy H2.1 (PC 550). The 30% proportion of affordable housing is too low. On sites of 5 units this would only lead to 1 affordable unit. The target should be increased to at least 50%. The policy needs to be amended clarify how affordable housing will be controlled on sites which are being developed over time.

Respondent Name Mrs Mirja Kaarina Wynn-Williams Respondent Number R/5275 Agent (Y or N) N Contact Name Mrs M K Wynn-Williams Contact Position and Company (if applicable) Contact Address Bryn Elmen, Dolybont, Borth Ceredigion SY24 5LY Admin Number C1/6477 Representation Number B/60195 Summary Objection to the proposed changes to H2.1 (PC 550) because procedurally the LPA had no right to publish this Further Proposed Changes document. The Document does not fulfil conditions set out in the WAG ‘Unitary Development Plans – A Guide to Procedures’ (Paragraph 1.17), therefore the document is not eligible for consideration as an amendment to the Ceredigion UDP. The whole document should be rejected.

However, if this proposed amendment is to be permitted, then:

The proposed change lacks balance. The number of houses that could be built as a result of the UDP is far greater than that which the Council envisage, so the need for the Rural Areas Exceptions and other policies is correspondingly less.

Paragraph 9 should be set as the main priority with no exceptions under Para 13 unless all local affordable housing needs are proven to have been met for the foreseeable future. Paragraphs 12 and 13 should therefore be deleted.

Paragraph 9 should also set as a UDP policy that council tax should be paid at full rate on unoccupied dwellings to encourage their letting to people in need of affordable housing. The following text should be added to the end of the paragraph:

“In addition, the Council will seek to increase the amount of housing available for rent by eliminating the Council Tax discount on unoccupied Class C dwellings.”

Respondent Name Mr Alun Tudor Wynn-Williams Respondent Number R/5278 Agent (Y or N) N Contact Name Mr T Wynn-Williams Contact Position and Company (if applicable) Contact Address Bryn Elmen, Dolybont, Borth Ceredigion SY24 5LY Admin Number C1/6476 Representation Number B/60189 Summary Objection to the proposed changes to H2.1 (PC 550) because procedurally the LPA had no right to publish this Further Proposed Changes document. The Document does not fulfil conditions set out in the WAG ‘Unitary Development Plans – A Guide to Procedures’ (Paragraph 1.17), therefore the document is not eligible for consideration as an amendment to the Ceredigion UDP. The whole document should be rejected.

However, if this proposed amendment is to be permitted, then:

The proposed change lacks balance. The number of houses that could be built as a result of the UDP is far greater than that which the Council envisage, so the need for the Rural Areas Exceptions and other policies is correspondingly less.

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Paragraph 9 should be set as the main priority with no exceptions under Para 13 unless all local affordable housing needs are proven to have been met for the foreseeable future. Paragraphs 12 and 13 should therefore be deleted.

Paragraph 9 should also set as a UDP policy that council tax should be paid at full rate on unoccupied dwellings to encourage their letting to people in need of affordable housing. The following text should be added to the end of the paragraph:

“In addition, the Council will seek to increase the amount of housing available for rent by eliminating the Council Tax discount on unoccupied Class C dwellings.”

Respondent Name Mr Ian Jones Respondent Number R/5281 Agent (Y or N) N Contact Name Mr I Jones Contact Position and Company (if applicable) Contact Address Tair Llyn, Cwmrheidol, Aberystwyth Ceredigion SY23 3NA Admin Number C1/6467 Representation Number B/60095 Summary Objection to the proposed change to policy H2.1 (550) as follows:

Paragraph 7: Objection to paragraph 7 because it fails to deal with inflation. The existing wording would prevent an increase in the value of an affordable house over time. This approach is contrary to TAN (W) 2. An increase in the value if a property over time does not automatically mean the loss of affordability because inflation will also have an upward effect on salaries – thus raising the ‘threshold of affordability’.

A more economically realistic approach of securing a stock of affordable housing and controlling house prices would be to develop a policy approach that clearly ties affordable housing covenants to average house prices or average County income levels over time.

The statement ‘the price is too high not the conditions too tight’ is simplistic. This suggests that the developer would need to keep dropping the price, without a floor limit, until an arbitrary purchaser becomes eligible by virtue of the low price.

Suggests that the Council’s approach should relate to ‘demonstrated need’ based on robust independent housing evidence relating to appropriate criteria of what prospective purchasers are able to pay. Suggests that if apply a percentage of open market values in determining the price of an affordable unit, then this would allow for inflation.

Paragraph 9: Objection to the inclusion of a 30% target for affordable housing (Paragraph 9) because: - no justification has been provided for this figure - no evidence has been provided that this figure is legitimate or reasonable - the only evidence of housing need that exists is contained in the LHNA which has not as yet been tested and contains a number of discrepancies.

Delete the 30% figure. The level of affordable housing appropriate for each development should be determined on a site by site basis through negotiation and should have regard to site circumstances, evidence of localised need, other site costs and against an up to date and tested wider housing needs assessment.

Respondent Name Ms Elin Jones ( AC / AM Ceredigion ) Respondent Number R/5301 Agent (Y or N) N Contact Name Ms E Jones Contact Position and Assembly Member - National Assembly For Wales Company (if applicable)

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Contact Address Swyddfa'r Etholaeth/Constituency Office, Ty Goronwy, 32 Heol y Wig/Pier Street, Aberystwyth Ceredigion SY23 2LN Admin Number C1/6410 Representation Number B/60047 Summary Objection to the proposed amendment to policy H2.1 (PC 550). The 30% proportion of affordable housing is too low. On sites of 5 units this would only lead to 1 affordable unit. The target should be increased to at least 50%. The policy needs to be amended clarify how affordable housing will be controlled on sites which are being developed over time.

Respondent Name Pwyllgor Etholaeth Plaid Cymru Ceredigion Respondent Number R/5313 Agent (Y or N) N Contact Name Miss R Evans Contact Position and Company (if applicable) Contact Address Swyddfa Plaid Cymru Ceredigion, Ty Goronwy, 32 Heol y Wig, Aberystwyth Ceredigion SY23 2LN Admin Number C1/6411 Representation Number B/60050 Summary Objection to the proposed amendment to policy H2.1 (PC 550). The 30% proportion of affordable housing is too low. On sites of 5 units this would only lead to 1 affordable unit. The target should be increased to at least 50%. The policy needs to be amended clarify how affordable housing will be controlled on sites which are being developed over time.

Respondent Name Mr M O James Respondent Number R/5324 Agent (Y or N) N Contact Name Mr M O James Contact Position and Company (if applicable) Contact Address Aberffrwd, Llanddeiniol, Llanrhystud Ceredigion SY23 5DT Admin Number C1/6436 Representation Number S/60039 Summary Support for policy H2.1 (PC 550).

Respondent Name Cyngor Cymuned Llanwenog Community Council Respondent Number R/5396 Agent (Y or N) N Contact Name Mrs A Thomas Contact Position and Clerc/Clerk Company (if applicable) Contact Address Milford House, Cwrtnewydd, Llanybydder SA40 9YH Admin Number C1/6434 Representation Number B/60094 Summary Objection to the proposed changes to policy H2.1 (550).

The restriction on modifications/additions which might increase the value of the property. The policy itself is however supported in principle.

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Reservations regarding how ‘affordable house prices’ to subsequent occupiers will be assessed – this process needs further clarification. The policy itself is however supported in principle.

Respondent Name Cyngor Cymuned Henfynyw Community Council Respondent Number R/5426 Agent (Y or N) N Contact Name Mrs E E Jones Contact Position and Clerk Company (if applicable) Contact Address Erwau Glas, Broceri, Ffosyffin, Aberaeron Ceredigion SA46 0HA Admin Number C1/6409 Representation Number B/60049 Summary Objection to the proposed amendment to policy H2.1 (PC 550) because everyone should have the right to purchase a house close to where they work rather than just those in specific types of work. The term ‘key worker’ requires further explanation.

Respondent Name Messrs T H J & C A Rees Respondent Number R/5455 Agent (Y or N) N Contact Name Messrs T H J & C A Rees Contact Position and Company (if applicable) Contact Address New Inn, Bleanplwyf, Aberystwyth Ceredigion SY23 4DH Admin Number C1/6397 Representation Number S/60015 Summary Support

Respondent Name Mr D J Davies Respondent Number R/5671 Agent (Y or N) N Contact Name Mr D J Davies Contact Position and Company (if applicable) Contact Address Crosslane, Croeslan, Llandysul Ceredigion SA44 4SS Admin Number C1/6396 Representation Number S/60009 Summary Support

Respondent Name Jamson Estates Ltd , Tresaith Respondent Number R/6306 Agent (Y or N) Y Contact Name Mr O Hadley Contact Position and Architect c/o Lloyd-Hadley Company (if applicable) Contact Address Pentraeth, Tresaith, Aberteifi / Cardigan Ceredigion SA43 2JL Admin Number C1/6451

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Representation Number B/60122 Summary Objection to the proposed changes to policy H2.1 (550). The policy appears hastily drafted and ill-considered and hence unfair in implementation, unreasonable in terms of building economics and uncontrollable in practice. The policy should be re-drafted in its entirety. Specifically:

Paragraph 9: The number of affordable homes that could be achieved should not be left to the vagaries of the housing market and changing market conditions. The Council should identify and designate areas that are already in the UDP as suitable for ‘affordable housing’. Such sites would probably be on the borders of towns or larger settlements. This will ensure that numbers are achieved, that sites are satisfactory (position, infrastructure services etc.) and that land values would reflect ‘affordability’.

The 30% target, if adopted, does not suit all sites - some sites will be suitable for less, some for more. The figure should be treated as a guide only.

The requirement for all smaller developments to include an element of ‘affordable housing’ will probably restrict the overall number of new houses that are built in the County. The policy should be more flexible so that the inclusion of ‘affordable housing’ can also be judged on the site, layout, value and development costs etc.

Paragraph 14: The amendments will unreasonably restrict owners of small ‘affordable houses’ from moving on to the next ‘rung’ on the housing ladder if they are unable to improve/enlarge their property. Removing GPRO rights means that such properties are only suitable for renting – thus disadvantaging those who want to buy. Introduce a mechanism which will allow owners to improve their houses.

Respondent Name Mr Steven Gough Respondent Number R/7754 Agent (Y or N) N Contact Name Mr S Gough Contact Position and Company (if applicable) Contact Address 20 Maes crugiau, Rhydyfelin, Aberystwyth Ceredigion SY23 4PP Admin Number C1/6462 Representation Number B/60201 Summary Objection to the proposed changes to H2.1 (PC 550) because: - a 30% provision is not enough, a 50% target is needed in order to address existing deficiencies.

The Objector also made a number of comments which do not relate to the further proposed changes. These concerns related to the lack of robust data, that no mechanism exists to measure local need (which should include household incomes and house prices) and that a strategy should be developed to measure local need. The Objector also noted support for the principle of addressing affordable housing.

Respondent Name Mr & Mrs J V & S L Elias - Beulah Respondent Number R/7791 Agent (Y or N) N Contact Name Mr R Williams Contact Position and Boyer Planning Company (if applicable) Contact Address 33-35 Cathedral Road, Caerdydd/Cardiff CF11 9HB Admin Number C1/6417 Representation Number B/60069 Summary Objection to the proposed amendment to policy H2.1 (PC 550) as follows:

Paragraph number 3:

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Objection to Para 3 as the definition of ‘key workers’ (either the existing or an alternative) should be reinstated in line with TAN (W) 2 (para 8). Para 2 of the TAN identifies people whose work is important to the community and who need to live close to the community. The definition should be discussed between parties and should include, for example, local craftsmen and farm workers.

Objection to the inclusion of the words ‘to this general definition’. If house prices are being pushed up in Aberystwyth by the shortage of general housing stock this should be addressed by releasing more land for housing and not by increasing the pool of households that qualify for affordable housing. In additional, the recent price increases may prove unsustainable and house prices could fall during the plan period (as in early/mid 1990s), thus more houses on the open market will become affordable.

Paragraph number 6: Objection to paragraph 6 because in order for conditions to be valid they must be enforceable, however there is no mechanism available to secure condition ‘C’ (policing). In addition, s106 agreements should be enforced or modified in accordance with normal legal provisions, therefore condition ‘C’ is unnecessary and should be deleted.

Paragraph number 7: The statement that conditions will not relaxed subverts the provisions relating to modifying or discharging of a s106 and is potentially unlawful. The text should be amended as it does not cater for changing circumstances. In addition, the statement that ‘If a property is not selling then the price is too high not the conditions too tight’ is irrational. Properties may not sell because there are no qualifying households and this could lead to empty properties. Amend text to include a cascade or sequential test in line with government guidance.

Paragraph number 9: Objection to Para 9 because: - Lack of justification for the 30% figure, especially as the paragraph also states that the plan cannot deliver the necessary affordable housing. It is also misleading when the base documents are considered. - The plan does not contain a mechanism for determining how the % will vary between settlements –the housing needs survey does not consider individual settlements. - Lack of reference to WAG policy document relied upon for setting the site thresholds. - 30% of 5 gives a partial result which must result in either 20% or 40%. - It is unfair and excessively onerous for the developer that some sites will be required to provide more than 30% to make up for the failure of other sites. It could also be challenged under Human Rights legislation as unjustified deprivation of property. - Imposing high %’s will prevent development as sites become uneconomic, leading to fewer houses and inflated prices. Amend text to deal with the above points.

Paragraph number 14: Objection to the removal of GPDO rights. The use of such restrictions usually require evidence of serious adverse effect on amenity or the environment. Modest alterations may not affect the value of the house. Delete this restriction.

Respondent Name The House Builders Federation Respondent Number R/7848 Agent (Y or N) N Contact Name Ms L Healy Contact Position and Regional Planner - Wales Company (if applicable) Contact Address Haywood House, North Dumfries Place, Cardiff CF10 3GA Admin Number C1/6402 Representation Number B/60052 Summary Objection to the proposed amendment to policy H2.1 (PC 550) because:

Paragraph 3: The policy now lacks a definition of ‘key worker’ – a definition should be reinserted.

Paragraph 5:

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The wording ‘or other nominated body identified by the LA’ is contrary to TAN (W) 2 which notes that LA’s should not prescribe who developers should work with in delivering affordable housing. Delete ‘identified by the LA’.

Paragraph 9: The Council should not state that ‘ relaxation of conditions/requirements will not be entertained’ because the housing market is highly volatile and because the information which the LA has on affordable housing need is limited. Mortgage companies will not support schemes with such strict controls, leading to less ‘affordable houses’ being built and an increase in the overall affordability problem. Relaxations must be entertained if there is no longer a proven need.

It is unlikely that sites could support in excess of 30% affordable housing as suggested in paragraph 9. Such inflexible policies will increase in the overall affordability problem as landowners withhold their land until such policies are removed. Delete reference to seeking in excess of 30%.

Respondent Name Mr Mike Williams Respondent Number R/7900 Agent (Y or N) N Contact Name Mr M Williams Contact Position and West Coast Developments Company (if applicable) Contact Address Llawr Y Glyn, Lledrod, Nr. Aberystwyth Ceredigion Admin Number C1/6447 Representation Number B/60024 Summary Objection to the proposed amendment to policy H2.1 (PC 550) as follows:

Paragraph number 3: Objection to the deletion of the ‘key workers’ definition. A definition should be reinserted, but should be wider that the previous definition to allow for other categories which could bring in economic or social benefit to Ceredigion. Include the following definition after ‘key workers’: "and people who are likely and able to benefit Ceredigion both economically and socially."

Paragraph number 6: The definition of an affordable dwelling to buy (as set out by points a, b and c in paragraph 6) is too restrictive. The definition needs to be simpler and more equatable. The definition should be replaced by a simple shared equity scheme with purchasers able to buy equity according to their means and qualifying status, and the LA being gifted the balance of the equity. This would oviate the need for a s106 and would not disadvantage low income purchasers by restricting them from the open market. It would provide a constant supply of affordable homes and give the LP an inflation proof fund to help those in need.

Concern also noted regarding the ‘policing mechanism’ (requirement C) because: - the word positively’ should be replaced by ‘reasonable’; and - there is concern regarding the costs and practicalities of the policing mechanism especially as no indication has been provided as to how policing will be achieved.

Paragraph number 9: The additional wording from “That is, 30%..” to “…may be significantly higher” should be deleted. As written the policy removes the responsibility for design and layout from developers/architects and it also restricts the freedom of negotiation and is contrary to PPW.

Paragraph number 14: This additional mechanism is unnecessary as the house owner will be aware of the restricted future market, due to the s106, and could be reluctant to invest in extending the property. The additional wording should be deleted.

Respondent Name Mr Martin Douglas Turnpenney Respondent Number R/7901

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Agent (Y or N) N Contact Name Mr M D Turnpenney Contact Position and Company (if applicable) Contact Address 6 Bachrhiw, Rhydyfelin, Aberystwyth Ceredigion SY23 4QS Admin Number C1/6443 Representation Number B/60028 Summary Objection to the proposed amendment to policy H2.1 (PC 550), paragraph number 14. This additional mechanism is unnecessary as the house owner will be aware of the restricted future market, due to the s106, and could be reluctant to invest in extending the property. The additional wording should be deleted

Respondent Name Mr Stewart Kinninmonth Respondent Number R/7902 Agent (Y or N) N Contact Name Mr S Kinninmonth Contact Position and Company (if applicable) Contact Address 10 Cefn Llan, Llanbadarn Fawr, Aberystwyth Ceredigion sy23 3tf Admin Number C1/6445 Representation Number B/60029 Summary Objection to the proposed amendment to policy H2.1 (PC 550), paragraph number 9, the stipulation of a percentage as it takes away the element of negotiation and is contrary to PPW. The reference to 30% should be deleted.

Respondent Name Mr Robert James Mc Burnie Respondent Number R/7903 Agent (Y or N) N Contact Name Mr R J Mc Burnie Contact Position and Company (if applicable) Contact Address Brynheulwen, Blaenplwyf, Aberystwyth Ceredigion SY23 4DW Admin Number C1/6446 Representation Number B/60030 Summary Objection to the proposed amendment to policy H2.1 (PC 550), paragraph number 3, the deletion of the ‘key workers’ definition. A definition should be reinserted, but should be wider than the previous definition to allow for other categories which could bring in economic or social benefit to Ceredigion. Include the following definition after ‘key workers’: "and people who are likely and able to benefit Ceredigion both economically and socially."

Respondent Name Mr Geraint Wyn Hughes Respondent Number R/7904 Agent (Y or N) N Contact Name Mr G W Hughes Contact Position and Company (if applicable) Contact Address Cwmcoedwig, Llanfarian, Aberystwyth Ceredigion SY23 4BX Admin Number C1/6444

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Representation Number B/60032 Summary Objection to the proposed amendment to policy H2.1 (PC 550) as follows:

Paragraph number 3: Objection to the deletion of the ‘key workers’ definition. A definition should be reinserted, but should be wider that the previous definition to allow for other categories which could bring in economic or social benefit to Ceredigion. Include the following definition after ‘key workers’: ”…and people who are likely and able to benefit Ceredigion both economically and socially.”

Paragraph number 6: The definition of an affordable dwelling to buy (as set out by points a, b and c in paragraph 6) is too restrictive. The definition needs to be simpler and more equatable. The definition should be replaced by a simple shared equity scheme with purchasers able to buy equity according to their means and qualifying status, and the LA being gifted the balance of the equity. This would oviate the need for a s106 and would not disadvantage low income purchasers by restricting them from the open market. It would provide a constant supply of affordable homes and give the LP an inflation proof fund to help those in need.

Paragraph number 9: The additional wording from “That is, 30%..” to “…may be significantly higher” should be deleted. As written the policy removes the responsibility for design and layout from developers/architects and it also restricts the freedom of negotiation and is contrary to PPW.

Paragraph number 14: This additional mechanism is unnecessary as the house owner will be aware of the restricted future market, due to the s106, and could be reluctant to invest in extending the property. The additional wording should be deleted.

Respondent Name Lawrence and Williams Ltd Respondent Number R/7905 Agent (Y or N) N Contact Name Mr H Williams Contact Position and Company (if applicable) Contact Address Cwrt y Cadno, Plwmp Ceredigion SA44 6HL Admin Number C1/6452 Representation Number B/60036 Summary Objection to the proposed amendment to policy H2.1 (PC 550) as follows:

Paragraph number 3: Objection to the deletion of the ‘key workers’ definition. A definition should be reinserted, but should be wider that the previous definition to allow for other categories which could bring in economic or social benefit to Ceredigion. Include the following definition after ‘key workers’: ”…and people who are likely and able to benefit Ceredigion both economically and socially.”

Paragraph number 6: The definition of an affordable dwelling to buy (as set out by points a, b and c in paragraph 6) is too restrictive. The definition needs to be simpler and more equatable. The definition should be replaced by a simple shared equity scheme with purchasers able to buy equity according to their means and qualifying status, and the LA being gifted the balance of the equity. This would oviate the need for a s106 and would not disadvantage low income purchasers by restricting them from the open market. It would provide a constant supply of affordable homes and give the LP an inflation proof fund to help those in need.

Concern also noted regarding the ‘policing mechanism’ (requirement C) because: - the word positively’ should be replaced by ‘reasonable’; and - there is concern regarding the costs and practicalities of the policing mechanism especially as no indication has been provided as to how policing will be achieved.

Paragraph number 9:

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The additional wording from “That is, 30%..” to “…may be significantly higher” should be deleted. As written the policy removes the responsibility for design and layout from developers/architects and it also restricts the freedom of negotiation and is contrary to PPW.

Paragraph number 14: This additional mechanism is unnecessary as the house owner will be aware of the restricted future market, due to the s106, and could be reluctant to invest in extending the property. The additional wording should be deleted.

Respondent Name Cyngor Cymuned Trefeurig Community Council Respondent Number R/7906 Agent (Y or N) N Contact Name Mrs P A Walker Contact Position and Clerc/Clerk Company (if applicable) Contact Address Sunnyside, Cwmysmlog, Aberystwyth Ceredigion SY23 3HA Admin Number C1/6420 Representation Number B/60045 Summary Objection to the proposed amendment to policy H2.1 (PC 550) because it does not go far enough: - there is a substantial need for affordable housing, this need should be carefully measured; and - the number of affordable units to be provided should be increased from 30% to 50% (paragraph 9).

Respondent Name Ifor Jones Builders Respondent Number R/7907 Agent (Y or N) Y Contact Name Mr R Williams Contact Position and Director Boyer Planning Company (if applicable) Contact Address 33-35 Cathedral Road, Cardiff CF11 9HB Admin Number C1/6412 Representation Number B/60054 Summary Objection to the proposed amendment to policy H2.1 (PC 550) as follows:

Paragraph number 3: Objection to Para 3 as the definition of ‘key workers’ (either the existing or an alternative) should be reinstated in line with TAN (W) 2 (para 8). Para 2 of the TAN identifies people whose work is important to the community and who need to live close to the community. The definition should be discussed between parties and should include, for example, local craftsmen and farm workers.

Objection to the inclusion of the words ‘to this general definition’. If house prices are being pushed up in Aberystwyth by the shortage of general housing stock this should be addressed by releasing more land for housing and not by increasing the pool of households that qualify for affordable housing. In additional, the recent price increases may prove unsustainable and house prices could fall during the plan period (as in early/mid 1990s), thus more houses on the open market will become affordable.

Paragraph number 6: Objection to paragraph 6 because in order for conditions to be valid they must be enforceable, however there is no mechanism available to secure condition ‘C’ (policing). In addition, s106 agreements should be enforced or modified in accordance with normal legal provisions, therefore condition ‘C’ is unnecessary and should be deleted.

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Paragraph number 7: The statement that conditions will not relaxed subverts the provisions relating to modifying or discharging of a s106 and is potentially unlawful. The text should be amended as it does not cater for changing circumstances. In addition, the statement that ‘If a property is not selling then the price is too high not the conditions too tight’ is irrational. Properties may not sell because there are no qualifying households and this could lead to empty properties. Amend text to include a cascade or sequential test in line with government guidance.

Paragraph number 9: Objection to Para 9 because: - Lack of justification for the 30% figure, especially as the paragraph also states that the plan cannot deliver the necessary affordable housing. It is also misleading when the base documents are considered. - The plan does not contain a mechanism for determining how the % will vary between settlements –the housing needs survey does not consider individual settlements. - Lack of reference to WAG policy document relied upon for setting the site thresholds. - 30% of 5 gives a partial result which must result in either 20% or 40%. - It is unfair and excessively onerous for the developer that some sites will be required to provide more than 30% to make up for the failure of other sites. It could also be challenged under Human Rights legislation as unjustified deprivation of property. - Imposing high %’s will prevent development as sites become uneconomic, leading to fewer houses and inflated prices. Amend text to deal with the above points.

Paragraph number 14: Objection to the removal of GPDO rights. The use of such restrictions usually require evidence of serious adverse effect on amenity or the environment. Modest alterations may not affect the value of the house. Delete this restriction.

Respondent Name S & R Develpoments Respondent Number R/7908 Agent (Y or N) Y Contact Name Mr R Williams Contact Position and Director Boyer Planning Company (if applicable) Contact Address 33-35 Cathedral Road, Cardiff CF11 9HB Admin Number C1/6418 Representation Number B/60064 Summary Objection to the proposed amendment to policy H2.1 (PC 550) as follows:

Paragraph number 3: Objection to Para 3 as the definition of ‘key workers’ (either the existing or an alternative) should be reinstated in line with TAN (W) 2 (para 8). Para 2 of the TAN identifies people whose work is important to the community and who need to live close to the community. The definition should be discussed between parties and should include, for example, local craftsmen and farm workers.

Objection to the inclusion of the words ‘to this general definition’. If house prices are being pushed up in Aberystwyth by the shortage of general housing stock this should be addressed by releasing more land for housing and not by increasing the pool of households that qualify for affordable housing. In additional, the recent price increases may prove unsustainable and house prices could fall during the plan period (as in early/mid 1990s), thus more houses on the open market will become affordable.

Paragraph number 6: Objection to paragraph 6 because in order for conditions to be valid they must be enforceable, however there is no mechanism available to secure condition ‘C’ (policing). In addition, s106 agreements should be enforced or modified in accordance with normal legal provisions, therefore condition ‘C’ is unnecessary and should be deleted.

Paragraph number 7: The statement that conditions will not relaxed subverts the provisions relating to modifying or discharging of a s106 and is potentially unlawful. The text should be

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amended as it does not cater for changing circumstances. In addition, the statement that ‘If a property is not selling then the price is too high not the conditions too tight’ is irrational. Properties may not sell because there are no qualifying households and this could lead to empty properties. Amend text to include a cascade or sequential test in line with government guidance.

Paragraph number 9: Objection to Para 9 because: - Lack of justification for the 30% figure, especially as the paragraph also states that the plan cannot deliver the necessary affordable housing. It is also misleading when the base documents are considered. - The plan does not contain a mechanism for determining how the % will vary between settlements –the housing needs survey does not consider individual settlements. - Lack of reference to WAG policy document relied upon for setting the site thresholds. - 30% of 5 gives a partial result which must result in either 20% or 40%. - It is unfair and excessively onerous for the developer that some sites will be required to provide more than 30% to make up for the failure of other sites. It could also be challenged under Human Rights legislation as unjustified deprivation of property. - Imposing high %’s will prevent development as sites become uneconomic, leading to fewer houses and inflated prices. Amend text to deal with the above points.

Paragraph number 14: Objection to the removal of GPDO rights. The use of such restrictions usually require evidence of serious adverse effect on amenity or the environment. Modest alterations may not affect the value of the house. Delete this restriction.

Respondent Name Sansom Develpoments Respondent Number R/7909 Agent (Y or N) Y Contact Name Mr R Williams Contact Position and Director Boyer Planning Company (if applicable) Contact Address 33-35 Cathedral Road, Cardiff CF11 9HB Admin Number C1/6419 Representation Number B/60074 Summary Objection to the proposed amendment to policy H2.1 (PC 550) as follows:

Paragraph number 3: Objection to Para 3 as the definition of ‘key workers’ (either the existing or an alternative) should be reinstated in line with TAN (W) 2 (para 8). Para 2 of the TAN identifies people whose work is important to the community and who need to live close to the community. The definition should be discussed between parties and should include, for example, local craftsmen and farm workers.

Objection to the inclusion of the words ‘to this general definition’. If house prices are being pushed up in Aberystwyth by the shortage of general housing stock this should be addressed by releasing more land for housing and not by increasing the pool of households that qualify for affordable housing. In additional, the recent price increases may prove unsustainable and house prices could fall during the plan period (as in early/mid 1990s), thus more houses on the open market will become affordable.

Paragraph number 6: Objection to paragraph 6 because in order for conditions to be valid they must be enforceable, however there is no mechanism available to secure condition ‘C’ (policing). In addition, s106 agreements should be enforced or modified in accordance with normal legal provisions, therefore condition ‘C’ is unnecessary and should be deleted.

Paragraph number 7: The statement that conditions will not relaxed subverts the provisions relating to modifying or discharging of a s106 and is potentially unlawful. The text should be amended as it does not cater for changing circumstances. In addition, the statement that ‘If a property is not selling then the price is too high not the conditions too tight’ is

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irrational. Properties may not sell because there are no qualifying households and this could lead to empty properties. Amend text to include a cascade or sequential test in line with government guidance.

Paragraph number 9: Objection to Para 9 because: - Lack of justification for the 30% figure, especially as the paragraph also states that the plan cannot deliver the necessary affordable housing. It is also misleading when the base documents are considered. - The plan does not contain a mechanism for determining how the % will vary between settlements –the housing needs survey does not consider individual settlements. - Lack of reference to WAG policy document relied upon for setting the site thresholds. - 30% of 5 gives a partial result which must result in either 20% or 40%. - It is unfair and excessively onerous for the developer that some sites will be required to provide more than 30% to make up for the failure of other sites. It could also be challenged under Human Rights legislation as unjustified deprivation of property. - Imposing high %’s will prevent development as sites become uneconomic, leading to fewer houses and inflated prices. Amend text to deal with the above points.

Paragraph number 14: Objection to Para 14 and the removal of GPDO rights. The use of such restrictions usually require evidence of serious adverse effect on amenity or the environment. Modest alterations may not affect the value of the house. Delete this restriction.

Respondent Name Creugiau Developments Respondent Number R/7910 Agent (Y or N) Y Contact Name Mr R Williams Contact Position and Director Boyer Planning Company (if applicable) Contact Address 33-35 Cathedral Road, Cardiff CF11 9HB Admin Number C1/6414 Representation Number B/60079 Summary Objection to the proposed amendment to policy H2.1 (PC 550) as follows:

Paragraph number 3: Objection to Para 3 as the definition of ‘key workers’ (either the existing or an alternative) should be reinstated in line with TAN (W) 2 (para 8). Para 2 of the TAN identifies people whose work is important to the community and who need to live close to the community. The definition should be discussed between parties and should include, for example, local craftsmen and farm workers.

Objection to the inclusion of the words ‘to this general definition’. If house prices are being pushed up in Aberystwyth by the shortage of general housing stock this should be addressed by releasing more land for housing and not by increasing the pool of households that qualify for affordable housing. In additional, the recent price increases may prove unsustainable and house prices could fall during the plan period (as in early/mid 1990s), thus more houses on the open market will become affordable.

Paragraph number 6: Objection to paragraph 6 because in order for conditions to be valid they must be enforceable, however there is no mechanism available to secure condition ‘C’ (policing). In addition, s106 agreements should be enforced or modified in accordance with normal legal provisions, therefore condition ‘C’ is unnecessary and should be deleted.

Paragraph number 7: The statement that conditions will not relaxed subverts the provisions relating to modifying or discharging of a s106 and is potentially unlawful. The text should be amended as it does not cater for changing circumstances. In addition, the statement that ‘If a property is not selling then the price is too high not the conditions too tight’ is irrational. Properties may not sell because there are no qualifying households and this could lead to empty properties. Amend text to include a cascade or sequential test in line with government guidance.

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Paragraph number 9: Objection to Para 9 because: - Lack of justification for the 30% figure, especially as the paragraph also states that the plan cannot deliver the necessary affordable housing. It is also misleading when the base documents are considered. - The plan does not contain a mechanism for determining how the % will vary between settlements –the housing needs survey does not consider individual settlements. - Lack of reference to WAG policy document relied upon for setting the site thresholds. - 30% of 5 gives a partial result which must result in either 20% or 40%. - It is unfair and excessively onerous for the developer that some sites will be required to provide more than 30% to make up for the failure of other sites. It could also be challenged under Human Rights legislation as unjustified deprivation of property. - Imposing high %’s will prevent development as sites become uneconomic, leading to fewer houses and inflated prices. Amend text to deal with the above points.

Paragraph number 14: Objection to Para 14 and the removal of GPDO rights. The use of such restrictions usually require evidence of serious adverse effect on amenity or the environment. Modest alterations may not affect the value of the house. Delete this restriction.

Respondent Name Rheidol Developments Ltd Respondent Number R/7911 Agent (Y or N) Y Contact Name Mr R Williams Contact Position and Director Boyer Planning Company (if applicable) Contact Address 33-35 Cathedral Road, Cardiff CF11 9HB Admin Number C1/6413 Representation Number B/60084 Summary Objection to the proposed amendment to policy H2.1 (PC 550) as follows:

Paragraph number 3: Objection to Para 3 as the definition of ‘key workers’ (either the existing or an alternative) should be reinstated in line with TAN (W) 2 (para 8). Para 2 of the TAN identifies people whose work is important to the community and who need to live close to the community. The definition should be discussed between parties and should include, for example, local craftsmen and farm workers.

Objection to the inclusion of the words ‘to this general definition’. If house prices are being pushed up in Aberystwyth by the shortage of general housing stock this should be addressed by releasing more land for housing and not by increasing the pool of households that qualify for affordable housing. In additional, the recent price increases may prove unsustainable and house prices could fall during the plan period (as in early/mid 1990s), thus more houses on the open market will become affordable.

Paragraph number 6: Objection to paragraph 6 because in order for conditions to be valid they must be enforceable, however there is no mechanism available to secure condition ‘C’ (policing). In addition, s106 agreements should be enforced or modified in accordance with normal legal provisions, therefore condition ‘C’ is unnecessary and should be deleted.

Paragraph number 7: The statement that conditions will not relaxed subverts the provisions relating to modifying or discharging of a s106 and is potentially unlawful. The text should be amended as it does not cater for changing circumstances. In addition, the statement that ‘If a property is not selling then the price is too high not the conditions too tight’ is irrational. Properties may not sell because there are no qualifying households and this could lead to empty properties. Amend text to include a cascade or sequential test in line with government guidance.

Paragraph number 9: Objection to Para 9 because:

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- Lack of justification for the 30% figure, especially as the paragraph also states that the plan cannot deliver the necessary affordable housing. It is also misleading when the base documents are considered. - The plan does not contain a mechanism for determining how the % will vary between settlements –the housing needs survey does not consider individual settlements. - Lack of reference to WAG policy document relied upon for setting the site thresholds. - 30% of 5 gives a partial result which must result in either 20% or 40%. - It is unfair and excessively onerous for the developer that some sites will be required to provide more than 30% to make up for the failure of other sites. It could also be challenged under Human Rights legislation as unjustified deprivation of property. - Imposing high %’s will prevent development as sites become uneconomic, leading to fewer houses and inflated prices. Amend text to deal with the above points.

Paragraph number 14: Objection to Para 14 and the removal of GPDO rights. The use of such restrictions usually require evidence of serious adverse effect on amenity or the environment. Modest alterations may not affect the value of the house. Delete this restriction.

Respondent Name J Thomas Builders Respondent Number R/7912 Agent (Y or N) Y Contact Name Mr R Williams Contact Position and Director Boyer Planning Company (if applicable) Contact Address 33-35 Cathedral Road, Cardiff CF11 9HB Admin Number C1/6416 Representation Number B/60089 Summary Objection to the proposed amendment to policy H2.1 (PC 550) as follows:

Paragraph number 3: Objection to Para 3 as the definition of ‘key workers’ (either the existing or an alternative) should be reinstated in line with TAN (W) 2 (para 8). Para 2 of the TAN identifies people whose work is important to the community and who need to live close to the community. The definition should be discussed between parties and should include, for example, local craftsmen and farm workers.

Objection to the inclusion of the words ‘to this general definition’. If house prices are being pushed up in Aberystwyth by the shortage of general housing stock this should be addressed by releasing more land for housing and not by increasing the pool of households that qualify for affordable housing. In additional, the recent price increases may prove unsustainable and house prices could fall during the plan period (as in early/mid 1990s), thus more houses on the open market will become affordable.

Paragraph number 6: Objection to paragraph 6 because in order for conditions to be valid they must be enforceable, however there is no mechanism available to secure condition ‘C’ (policing). In addition, s106 agreements should be enforced or modified in accordance with normal legal provisions, therefore condition ‘C’ is unnecessary and should be deleted.

Paragraph number 7: The statement that conditions will not relaxed subverts the provisions relating to modifying or discharging of a s106 and is potentially unlawful. The text should be amended as it does not cater for changing circumstances. In addition, the statement that ‘If a property is not selling then the price is too high not the conditions too tight’ is irrational. Properties may not sell because there are no qualifying households and this could lead to empty properties. Amend text to include a cascade or sequential test in line with government guidance.

Paragraph number 9: Objection to Para 9 because: - Lack of justification for the 30% figure, especially as the paragraph also states that the plan cannot deliver the necessary affordable housing. It is also misleading when the base documents are considered.

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- The plan does not contain a mechanism for determining how the % will vary between settlements –the housing needs survey does not consider individual settlements. - Lack of reference to WAG policy document relied upon for setting the site thresholds. - 30% of 5 gives a partial result which must result in either 20% or 40%. - It is unfair and excessively onerous for the developer that some sites will be required to provide more than 30% to make up for the failure of other sites. It could also be challenged under Human Rights legislation as unjustified deprivation of property. - Imposing high %’s will prevent development as sites become uneconomic, leading to fewer houses and inflated prices. Amend text to deal with the above points.

Paragraph number 14: Objection to the removal of GPDO rights. The use of such restrictions usually require evidence of serious adverse effect on amenity or the environment. Modest alterations may not affect the value of the house. Delete this restriction.

Respondent Name Mr Wil Lewis Respondent Number R/7913 Agent (Y or N) N Contact Name Mr W Lewis Contact Position and Company (if applicable) Contact Address Rhyd Teifi, Pontrhydfendigaid, Ystrad Meurig Ceredigion SY25 6BH Admin Number C1/6433 Representation Number B/60097 Summary Objection to the proposed changes to policy H2.1 (550). The market price is historically the only fair way of valuing a property. Modifying the market price would not be in the interests of young people in the future.

Respondent Name Ms Joan Davies Respondent Number R/7914 Agent (Y or N) N Contact Name Ms J Davies Contact Position and Company (if applicable) Contact Address Garreglwyd, 13 Maes y ddewen, Pontrhydfendigaid Ceredigion Admin Number C1/6431 Representation Number B/60102 Summary Objection to the proposed changes to policy H2.1 (550). Partition in Countries, such as nationalism in the past, have proved a disaster (e.g. northern Ireland, the National Coal Board etc. Introducing these housing proposals would also be unsatisfactory.

Respondent Name Mr Alun Price Jones Respondent Number R/7915 Agent (Y or N) N Contact Name Mr A P Jones Contact Position and Company (if applicable) Contact Address Bryn Banon, Pontrhydfendigaid Ceredigion Admin Number C1/6430 Representation Number B/60107

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Summary Objection to the proposed changes to policy H2.1 (550). The traditional way in the housing market is to buy and sell based on open market prices. Going against this principle will cause problems in the future.

Respondent Name Ms Joy Dark Respondent Number R/7916 Agent (Y or N) N Contact Name Ms J Dark Contact Position and Company (if applicable) Contact Address Mur-Mur y Nant, Abbey Road, Pontrhydfendigaid Ceredigion SY25 6ED Admin Number C1/6428 Representation Number B/60112 Summary Objection to the proposed changes to policy H2.1 (550). The traditional way in the housing market is to buy and sell based on open market prices. Going against this principle will cause problems in the future.

Respondent Name Mr Morgan John Jones Respondent Number R/7917 Agent (Y or N) N Contact Name Mr M J Jones Contact Position and Company (if applicable) Contact Address Dolebolion, Pontrhydyfendigiad, Ystrad Meurig Ceredigion SY25 6BT Admin Number Q/6427 Representation Number B/60117 Summary Objection to the proposed changes to policy H2.1 (550). The principle may be favourable but nobody would buy and what they could do with the property would be restricted.

Respondent Name Griffiths Superior Homes Ltd Respondent Number R/7918 Agent (Y or N) Y Contact Name Mr A Haird Contact Position and Director Alan W Haird Ltd Company (if applicable) Contact Address Tyn Cae, Blaenplwyf, Aberystwyth Ceredigion SY23 4DH Admin Number C1/6429 Representation Number B/60125 Summary Objection to the proposed amendment to policy H2.1 (PC 550) as follows:

Paragraph number 3: Objection to the deletion of the ‘key workers’ definition. A definition should be reinserted, but should be wider that the previous definition to allow for other categories which could bring in economic or social benefit to Ceredigion. Include the following definition after ‘key workers’: ”…and people who are likely and able to benefit Ceredigion both economically and socially.”

Paragraph number 6: The definition of an affordable dwelling to buy (as set out by points a, b and c in paragraph 6) is too restrictive. The definition needs to be simpler and more equatable. The definition should be replaced by a simple shared equity scheme with purchasers

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able to buy equity according to their means and qualifying status, and the LA being gifted the balance of the equity. This would oviate the need for a s106 and would not disadvantage low income purchasers by restricting them from the open market. It would provide a constant supply of affordable homes and give the LP an inflation proof fund to help those in need.

Concern also noted regarding the ‘policing mechanism’ (requirement C) because: - the word positively’ should be replaced by ‘reasonable’; and - there is concern regarding the costs and practicalities of the policing mechanism especially as no indication has been provided as to how policing will be achieved.

Paragraph number 9: The additional wording setting out a target, that is from “That is, 30%..” to “…may be significantly higher” should be deleted. As written the policy removes the responsibility for design and layout from developers/architects and it also restricts the freedom of negotiation and is contrary to PPW.

Paragraph number 14: This additional mechanism is unnecessary as the house owner will be aware of the restricted future market, due to the s106, and could be reluctant to invest in extending the property. The additional wording should be deleted.

Respondent Name Mark Skitt Ltd Respondent Number R/7919 Agent (Y or N) Y Contact Name Mr A Haird Contact Position and Director Alan W Haird Ltd Company (if applicable) Contact Address Tyn Cae, Blaenplwyf, Aberystwyth Ceredigion SY23 4DH Admin Number C1/6426 Representation Number B/60130 Summary Objection to the proposed amendment to policy H2.1 (PC 550) as follows:

Paragraph number 3: Objection to the deletion of the ‘key workers’ definition. A definition should be reinserted, but should be wider that the previous definition to allow for other categories which could bring in economic or social benefit to Ceredigion. Include the following definition after ‘key workers’: ”…and people who are likely and able to benefit Ceredigion both economically and socially.”

Paragraph number 6: The definition of an affordable dwelling to buy (as set out by points a, b and c in paragraph 6) is too restrictive. The definition needs to be simpler and more equatable. The definition should be replaced by a simple shared equity scheme with purchasers able to buy equity according to their means and qualifying status, and the LA being gifted the balance of the equity. This would oviate the need for a s106 and would not disadvantage low income purchasers by restricting them from the open market. It would provide a constant supply of affordable homes and give the LP an inflation proof fund to help those in need.

Concern also noted regarding the ‘policing mechanism’ (requirement C) because: - the word positively’ should be replaced by ‘reasonable’; and - there is concern regarding the costs and practicalities of the policing mechanism especially as no indication has been provided as to how policing will be achieved.

Paragraph number 9: The additional wording setting out a target, that is from “That is, 30%..” to “…may be significantly higher” should be deleted. As written the policy removes the responsibility for design and layout from developers/architects and it also restricts the freedom of negotiation and is contrary to PPW.

Paragraph number 14: This additional mechanism is unnecessary as the house owner will be aware of the restricted future market, due to the s106, and could be reluctant to invest in extending

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the property. The additional wording should be deleted.

Respondent Name J Thomas Property Developer & Building Contractor Respondent Number R/7920 Agent (Y or N) Y Contact Name Mr A Haird Contact Position and Director Alan W Haird Ltd Company (if applicable) Contact Address Tyn Cae, Blaenplwyf, Aberystwyth Ceredigion SY23 4DH Admin Number C1/6423 Representation Number B/60135 Summary Objection to the proposed amendment to policy H2.1 (PC 550) as follows:

Paragraph number 3: Objection to the deletion of the ‘key workers’ definition. A definition should be reinserted, but should be wider that the previous definition to allow for other categories which could bring in economic or social benefit to Ceredigion. Include the following definition after ‘key workers’: ”…and people who are likely and able to benefit Ceredigion both economically and socially.”

Paragraph number 6: The definition of an affordable dwelling to buy (as set out by points a, b and c in paragraph 6) is too restrictive. The definition needs to be simpler and more equatable. The definition should be replaced by a simple shared equity scheme with purchasers able to buy equity according to their means and qualifying status, and the LA being gifted the balance of the equity. This would oviate the need for a s106 and would not disadvantage low income purchasers by restricting them from the open market. It would provide a constant supply of affordable homes and give the LP an inflation proof fund to help those in need.

Concern also noted regarding the ‘policing mechanism’ (requirement C) because: - the word positively’ should be replaced by ‘reasonable’; and - there is concern regarding the costs and practicalities of the policing mechanism especially as no indication has been provided as to how policing will be achieved.

Paragraph number 9: The additional wording setting out a target, that is from “That is, 30%..” to “…may be significantly higher” should be deleted. As written the policy removes the responsibility for design and layout from developers/architects and it also restricts the freedom of negotiation and is contrary to PPW.

Paragraph number 14: This additional mechanism is unnecessary as the house owner will be aware of the restricted future market, due to the s106, and could be reluctant to invest in extending the property. The additional wording should be deleted.

Respondent Name Mr Alan Haird Respondent Number R/7921 Agent (Y or N) N Contact Name Mr A Haird Contact Position and Company (if applicable) Contact Address Tyncae, Blaenplwyf, Aberystwyth Ceredigion SY23 4DH Admin Number C1/6422 Representation Number B/60140 Summary Objection to the proposed amendment to policy H2.1 (PC 550) as follows:

Paragraph number 3:

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Objection to the deletion of the ‘key workers’ definition. A definition should be reinserted, but should be wider that the previous definition to allow for other categories which could bring in economic or social benefit to Ceredigion. Include the following definition after ‘key workers’: ”…and people who are likely and able to benefit Ceredigion both economically and socially.”

Paragraph number 6: The definition of an affordable dwelling to buy (as set out by points a, b and c in paragraph 6) is too restrictive. The definition needs to be simpler and more equatable. The definition should be replaced by a simple shared equity scheme with purchasers able to buy equity according to their means and qualifying status, and the LA being gifted the balance of the equity. This would oviate the need for a s106 and would not disadvantage low income purchasers by restricting them from the open market. It would provide a constant supply of affordable homes and give the LP an inflation proof fund to help those in need.

Concern also noted regarding the ‘policing mechanism’ (requirement C) because: - the word positively’ should be replaced by ‘reasonable’; and - there is concern regarding the costs and practicalities of the policing mechanism especially as no indication has been provided as to how policing will be achieved.

Paragraph number 9: The additional wording setting out a target, that is from “That is, 30%..” to “…may be significantly higher” should be deleted. As written the policy removes the responsibility for design and layout from developers/architects and it also restricts the freedom of negotiation and is contrary to PPW.

Paragraph number 14: This additional mechanism is unnecessary as the house owner will be aware of the restricted future market, due to the s106, and could be reluctant to invest in extending the property. The additional wording should be deleted.

Respondent Name SAH Developments Ltd Respondent Number R/7922 Agent (Y or N) Y Contact Name Mr A Haird Contact Position and Director Alan W Haird Ltd Company (if applicable) Contact Address Tyn Cae, Blaenplwyf, Aberystwyth Ceredigion SY23 4DH Admin Number C1/6432 Representation Number B/60145 Summary Objection to the proposed amendment to policy H2.1 (PC 550) as follows:

Paragraph number 3: Objection to the deletion of the ‘key workers’ definition. A definition should be reinserted, but should be wider that the previous definition to allow for other categories which could bring in economic or social benefit to Ceredigion. Include the following definition after ‘key workers’: ”…and people who are likely and able to benefit Ceredigion both economically and socially.”

Paragraph number 6: The definition of an affordable dwelling to buy (as set out by points a, b and c in paragraph 6) is too restrictive. The definition needs to be simpler and more equatable. The definition should be replaced by a simple shared equity scheme with purchasers able to buy equity according to their means and qualifying status, and the LA being gifted the balance of the equity. This would oviate the need for a s106 and would not disadvantage low income purchasers by restricting them from the open market. It would provide a constant supply of affordable homes and give the LP an inflation proof fund to help those in need.

Concern also noted regarding the ‘policing mechanism’ (requirement C) because: - the word positively’ should be replaced by ‘reasonable’; and - there is concern regarding the costs and practicalities of the policing mechanism especially as no indication has been provided as to how policing will be

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achieved.

Paragraph number 9: The additional wording setting out a target, that is from “That is, 30%..” to “…may be significantly higher” should be deleted. As written the policy removes the responsibility for design and layout from developers/architects and it also restricts the freedom of negotiation and is contrary to PPW.

Paragraph number 14: This additional mechanism is unnecessary as the house owner will be aware of the restricted future market, due to the s106, and could be reluctant to invest in extending the property. The additional wording should be deleted.

Respondent Name Mr I W M Leushon Respondent Number R/7923 Agent (Y or N) N Contact Name Mr I W M Leushon Contact Position and Company (if applicable) Contact Address Glasnant, Llanfihangel y Creuddyn, Aberystwyth Ceredigion SY23 4LA Admin Number C1/6421 Representation Number B/60150 Summary Objection to the proposed amendment to policy H2.1 (PC 550) as follows:

Paragraph number 3: Objection to the deletion of the ‘key workers’ definition. A definition should be reinserted, but should be wider that the previous definition to allow for other categories which could bring in economic or social benefit to Ceredigion. Include the following definition after ‘key workers’: ”…and people who are likely and able to benefit Ceredigion both economically and socially.”

Paragraph number 6: The definition of an affordable dwelling to buy (as set out by points a, b and c in paragraph 6) is too restrictive. The definition needs to be simpler and more equatable. The definition should be replaced by a simple shared equity scheme with purchasers able to buy equity according to their means and qualifying status, and the LA being gifted the balance of the equity. This would oviate the need for a s106 and would not disadvantage low income purchasers by restricting them from the open market. It would provide a constant supply of affordable homes and give the LP an inflation proof fund to help those in need.

Concern also noted regarding the ‘policing mechanism’ (requirement C) because: - the word positively’ should be replaced by ‘reasonable’; and - there is concern regarding the costs and practicalities of the policing mechanism especially as no indication has been provided as to how policing will be achieved.

Paragraph number 9: The additional wording setting out a target, that is from “That is, 30%..” to “…may be significantly higher” should be deleted. As written the policy removes the responsibility for design and layout from developers/architects and it also restricts the freedom of negotiation and is contrary to PPW.

Paragraph number 14: This additional mechanism is unnecessary as the house owner will be aware of the restricted future market, due to the s106, and could be reluctant to invest in extending the property. The additional wording should be deleted.

Respondent Name Robert Aled Ellis Respondent Number R/7925 Agent (Y or N) N Contact Name Mr R A Ellis

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Contact Position and Company (if applicable) Contact Address 16 Terrace Road, Aberystwyth Ceredigion SY23 1NP Admin Number C1/6448 Representation Number B/60156 Summary Objection to the proposed amendment to policy H2.1 (PC 550) as follows:

Paragraph number 3: Objection to the deletion of the ‘key workers’ definition. A definition should be reinserted, but should be wider that the previous definition to allow for other categories which could bring in economic or social benefit to Ceredigion. Include the following definition after ‘key workers’: ”…and people who are likely and able to benefit Ceredigion both economically and socially.”

Paragraph number 9: Objection to the inclusion of a percentage. This restricts the freedom of negotiation and is contrary to PPW. Delete the 30% figure.

Respondent Name Mr J E Charles Raw-Rees Respondent Number R/7926 Agent (Y or N) N Contact Name Mr J E C Raw-Rees Contact Position and Company (if applicable) Contact Address Jim Raw-Rees & Co, 1 Chalybeate Street, Aberystwyth Ceredigion SY23 1HS Admin Number C1/6449 Representation Number B/60158 Summary Objection to the proposed amendment to policy H2.1 (PC 550) as follows:

Paragraph number 3: Objection to the deletion of the ‘key workers’ definition. A definition should be reinserted, but should be wider that the previous definition to allow for other categories which could bring in economic or social benefit to Ceredigion. Include the following definition after ‘key workers’: ”…and people who are likely and able to benefit Ceredigion both economically and socially.”

Paragraph number 6: The definition of an affordable dwelling to buy (as set out by points a, b and c in paragraph 6) is too restrictive. The definition needs to be simpler and more equatable. The definition should be replaced by a simple shared equity scheme with purchasers able to buy equity according to their means and qualifying status, and the LA being gifted the balance of the equity. This would oviate the need for a s106 and would not disadvantage low income purchasers by restricting them from the open market. It would provide a constant supply of affordable homes and give the LP an inflation proof fund to help those in need.

Concern also noted regarding the ‘policing mechanism’ (requirement C) because: - the word positively’ should be replaced by ‘reasonable’; and - there is concern regarding the costs and practicalities of the policing mechanism especially as no indication has been provided as to how policing will be achieved.

Paragraph number 9: The additional wording setting out a target, that is from “That is, 30%..” to “…may be significantly higher” should be deleted. As written the policy removes the responsibility for design and layout from developers/architects and it also restricts the freedom of negotiation and is contrary to PPW.

Paragraph number 14: This additional mechanism is unnecessary as the house owner will be aware of the restricted future market, due to the s106, and could be reluctant to invest in extending the property. The additional wording should be deleted.

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Respondent Name Mr Michael Kent Respondent Number R/7927 Agent (Y or N) N Contact Name Mr M Kent Contact Position and Company (if applicable) Contact Address 42 Garth Dinas, Penparcau, Aberystwyth Ceredigion SY23 3RZ Admin Number C1/6442 Representation Number B/60163 Summary Objection to the proposed amendment to policy H2.1 (PC 550) as follows:

Paragraph number 9: The additional wording, from “That is, 30%..” to “…may be significantly higher” should be deleted. As written the policy removes the responsibility for design and layout from developers/architects and it also restricts the freedom of negotiation.

Respondent Name Miss Nicola Jane Vaientine Respondent Number R/7929 Agent (Y or N) N Contact Name Miss N J Vaientine Contact Position and Company (if applicable) Contact Address Bwthynywern, High Street, Borth Ceredigion SY24 5YF Admin Number C1/6439 Representation Number B/60166 Summary Objection to the proposed amendment to policy H2.1 (PC 550) as follows:

Paragraph number 3: Objection to the deletion of the ‘key workers’ definition. A definition should be reinserted, but should be wider that the previous definition to allow for other categories which could bring in economic or social benefit to Ceredigion. Include the following definition after ‘key workers’: ”…and people who are likely and able to benefit Ceredigion both economically and socially.”

Respondent Name Mr Derek Donald Ross Respondent Number R/7930 Agent (Y or N) N Contact Name Mr D D Ross Contact Position and Company (if applicable) Contact Address Coed Mynach, Pantglas Lane, Llanilar, Aberystwyth Ceredigion SY23 4PJ Admin Number C1/6440 Representation Number B/60167 Summary Objection to the proposed amendment to policy H2.1 (PC 550) as follows:

Paragraph 3: Objection to the inclusion of a percentage. This restricts the freedom of negotiation and is contrary to PPW. Delete the 30% figure.

Respondent Name Mr William Copeland Respondent Number R/7931

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Agent (Y or N) N Contact Name Mr W Copeland Contact Position and Company (if applicable) Contact Address 3 Pantydderwen, Llandre, Aberystwyth Ceredigion SY24 5BT Admin Number C1/6441 Representation Number B/60168 Summary Objection to the proposed amendment to policy H2.1 (PC 550) as follows:

Paragraph number 14: This additional mechanism is unnecessary as the house owner will be aware of the restricted future market, due to the s106, and could be reluctant to invest in extending the property. The additional wording should be deleted.

Respondent Name Dilwyn Roberts Architects Respondent Number R/7932 Agent (Y or N) N Contact Name Mr D Roberts Contact Position and Company (if applicable) Contact Address 9 Science Park, Cefn Llan, Aberystwyth Ceredigion SY23 3AH Admin Number C1/6450 Representation Number B/60169 Summary Objection to the proposed amendment to policy H2.1 (PC 550) as follows:

Paragraph number 3: Objection to the deletion of the ‘key workers’ definition. A definition should be reinserted, but should be wider that the previous definition to allow for other categories which could bring in economic or social benefit to Ceredigion. Include the following definition after ‘key workers’: ”…and people who are likely and able to benefit Ceredigion both economically and socially.”

Paragraph number 6: The definition of an affordable dwelling to buy (as set out by points a, b and c in paragraph 6) is too restrictive. The definition needs to be simpler and more equatable. The definition should be replaced by a simple shared equity scheme with purchasers able to buy equity according to their means and qualifying status, and the LA being gifted the balance of the equity. This would oviate the need for a s106 and would not disadvantage low income purchasers by restricting them from the open market. It would provide a constant supply of affordable homes and give the LP an inflation proof fund to help those in need.

Concern also noted regarding the ‘policing mechanism’ (requirement C) because: - the word positively’ should be replaced by ‘reasonable’; and - there is concern regarding the costs and practicalities of the policing mechanism especially as no indication has been provided as to how policing will be achieved.

Paragraph number 9: The additional wording setting out a target, that is from “That is, 30%..” to “…may be significantly higher” should be deleted. As written the policy removes the responsibility for design and layout from developers/architects and it also restricts the freedom of negotiation and is contrary to PPW.

Paragraph number 14: This additional mechanism is unnecessary as the house owner will be aware of the restricted future market, due to the s106, and could be reluctant to invest in extending the property. The additional wording should be deleted.

Respondent Name RL Wales

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Respondent Number R/7933 Agent (Y or N) N Contact Name Mr R L Wales Contact Position and Company (if applicable) Contact Address 9 Science Park, Aberystwyth Ceredigion SY23 3AH Admin Number C1/6453 Representation Number B/60174 Summary Objection to the proposed amendment to policy H2.1 (PC 550) as follows:

Paragraph number 3: Objection to the deletion of the ‘key workers’ definition. A definition should be reinserted, but should be wider that the previous definition to allow for other categories which could bring in economic or social benefit to Ceredigion. Include the following definition after ‘key workers’: ”…and people who are likely and able to benefit Ceredigion both economically and socially.”

Paragraph number 6: The definition of an affordable dwelling to buy (as set out by points a, b and c in paragraph 6) is too restrictive. The definition needs to be simpler and more equatable. The definition should be replaced by a simple shared equity scheme with purchasers able to buy equity according to their means and qualifying status, and the LA being gifted the balance of the equity. This would oviate the need for a s106 and would not disadvantage low income purchasers by restricting them from the open market. It would provide a constant supply of affordable homes and give the LP an inflation proof fund to help those in need.

Concern also noted regarding the ‘policing mechanism’ (requirement C) because: - the word positively’ should be replaced by ‘reasonable’; and - there is concern regarding the costs and practicalities of the policing mechanism especially as no indication has been provided as to how policing will be achieved.

Paragraph number 9: The additional wording setting out a target, that is from “That is, 30%..” to “…may be significantly higher” should be deleted. As written the policy removes the responsibility for design and layout from developers/architects and it also restricts the freedom of negotiation and is contrary to PPW.

Paragraph number 14: This additional mechanism is unnecessary as the house owner will be aware of the restricted future market, due to the s106, and could be reluctant to invest in extending the property. The additional wording should be deleted.

Respondent Name Mr Julian Evans Respondent Number R/7934 Agent (Y or N) N Contact Name Mr J R Evans Contact Position and Company (if applicable) Contact Address Raymond, New Road, Ceinewydd / New Quay Ceredigion SA45 9SE Admin Number C1/6400 Representation Number B/60186 Summary Objection to the proposed changes to policy H2.1 (550) as follows:

Paragraph 3: The suggested amendment is farcical. The policy should apply to the whole of the County not just specific locations.

Paragraph 7: The mechanism providing qualification for ‘affordable’ should apply in perpetuity.

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Paragraph 9: The planning process does not have the outright responsibility in securing the provision of affordable housing. Include reference that assistance will be needed by way of WAG initiatives to promote the ability of the HAs.

Historically planning has rarely handles applications for estate developments – other from the Council/Has. The LA should not be giving such a high profile to this proposal when no indication has been provided of the potential development already banked.

Paragraph 14: Planning does not/cannot police existing conditions set out in planning consents.

Respondent Name Dr D Adams Respondent Number R/7935 Agent (Y or N) N Contact Name Mr R Williams Contact Position and Director Boyer Planning Company (if applicable) Contact Address 33-35 Cathedral Road, Cardiff CF11 9HB Admin Number C1/6415 Representation Number B/60059 Summary Objection to the proposed amendment to policy H2.1 (PC 550) as follows:

Paragraph number 3: Objection to Para 3 as the definition of ‘key workers’ (either the existing or an alternative) should be reinstated in line with TAN (W) 2 (para 8). Para 2 of the TAN identifies people whose work is important to the community and who need to live close to the community. The definition should be discussed between parties and should include, for example, local craftsmen and farm workers.

Objection to the inclusion of the words ‘to this general definition’. If house prices are being pushed up in Aberystwyth by the shortage of general housing stock this should be addressed by releasing more land for housing and not by increasing the pool of households that qualify for affordable housing. In additional, the recent price increases may prove unsustainable and house prices could fall during the plan period (as in early/mid 1990s), thus more houses on the open market will become affordable.

Paragraph number 6: Objection to paragraph 6 because in order for conditions to be valid they must be enforceable, however there is no mechanism available to secure condition ‘C’ (policing). In addition, s106 agreements should be enforced or modified in accordance with normal legal provisions, therefore condition ‘C’ is unnecessary and should be deleted.

Paragraph number 7: The statement that conditions will not relaxed subverts the provisions relating to modifying or discharging of a s106 and is potentially unlawful. The text should be amended as it does not cater for changing circumstances. In addition, the statement that ‘If a property is not selling then the price is too high not the conditions too tight’ is irrational. Properties may not sell because there are no qualifying households and this could lead to empty properties. Amend text to include a cascade or sequential test in line with government guidance.

Paragraph number 9: Objection to Para 9 because: - Lack of justification for the 30% figure, especially as the paragraph also states that the plan cannot deliver the necessary affordable housing. It is also misleading when the base documents are considered. - The plan does not contain a mechanism for determining how the % will vary between settlements –the housing needs survey does not consider individual settlements. - Lack of reference to WAG policy document relied upon for setting the site thresholds. - 30% of 5 gives a partial result which must result in either 20% or 40%. - It is unfair and excessively onerous for the developer that some sites will be required to provide more than 30% to make up for the failure of other sites. It could also be challenged under Human Rights legislation as unjustified deprivation of property.

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- Imposing high %’s will prevent development as sites become uneconomic, leading to fewer houses and inflated prices. Amend text to deal with the above points.

Paragraph number 14: Objection to the removal of GPDO rights. The use of such restrictions usually require evidence of serious adverse effect on amenity or the environment. Modest alterations may not affect the value of the house. Delete this restriction.

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