Growth and Spatial Options Report of Consultation June 2021

Monmouthshire Replacement Local Development Plan

Monmouthshire County Council Replacement Local Development Plan

Growth and Spatial Options Report of Consultation June 2021

Planning Policy Service Monmouthshire County Council County Hall, Rhadyr, Usk, Monmouthshire NP15 1GA Tel: 01633 644429 Email: [email protected]

Contents

Page

1. Introduction 1

2. Growth Options Report of Consultation 5

3. Spatial Options Report of Consultation 20

4. Summary of other comments not directly related to the Growth and 29 Spatial Options Consultation questions

Monmouthshire Replacement Local Development Plan Growth and Spatial Options Report of Consultation (June 2021)

1 Introduction Background 1.1 The Council is preparing a Replacement Local Development Plan (RLDP) for Monmouthshire (excluding the part of the County that is within the Brecon Beacons National Park). The RLDP will identify where and how much new development will take place during the ‘Plan period’ (2018-2033). It will allocate land for development, identify areas to be protected, and contain policies to guide decisions on applications for planning permission. We aim to adopt the RLDP in autumn 2023.

1.2 In January 2021, the Council published a Growth and Spatial Options Paper for a four- week non-statutory consultation period. We originally consulted on a range of growth and spatial options in the summer of 2019, however, due to the publication of the Welsh Government 2018-based population and household projections the decision was made to revisit this stage of the Plan process. The Welsh Government population and household projections form the starting point for the RLDP evidence on growth levels, onto which policy choices can be added as needed, for example to ensure that the County’s identified issues are addressed, objectives met and vision achieved. The publication of the Welsh Government 2018-based population and household projections in August 2020 comprise important new evidence that requires consideration to ensure that the evidence base for the RLDP is robust and based in the most up to date information. Consequently, the Growth and Spatial Options stage of the Plan process has been revisited.

1.3 Purpose of this paper

1.3.1 The purpose of this report is to record the comments received in response to the non- statutory engagement/consultation undertaken on the Growth and Spatial Options Consultation Paper (December 2020) which allowed residents and interested stakeholders an opportunity to consider how much growth is needed over the Plan period and broadly where the growth should go. The consultation took place over a 4-week period between January and February 2021. Notification of the consultation, inviting comments, was sent to the statutory and other consultees, agents and individuals on the RLDP consultation database.

1.3.2 The consultation and engagement arrangements undertaken were revised in light of the Covid-19 pandemic and reflected the Coronavirus Regulations (2020) and Ministerial advice1. Increased digital involvement was therefore used to offer an

1 Minister for Housing and Local Government Letter to Local Authority Leaders and Chief Executives National Park Authority Chief Executives – Planning System and Covid19 – 7th July 2020.

Monmouthshire Replacement Local Development Plan Growth and Spatial Options Report of Consultation (June 2021)

opportunity to engage with Officers on the Options Paper. Consultation and engagement took place via:

. Two consultation webinars open to all to attend – 6pm, 14th January (84 views in total – 69 live and 14 via the recorded link) and 2pm, 20th January 2021 (87 views – 82 live and 5 viewed via the recorded link). . Making all relevant information available on the Council’s website including an Easy Read version and an animation to explain the different options. . Planning Policy Officer virtual attendance at the Town and Community Council Engagement Meeting – 21st January 2021. . A Members’ Workshop – 8th December 2020 (hosted by the Economy & Development Select Committee). . Scrutiny by Economy & Development Select Committee on 10th December 2020. . Internal discussions within the Council through Development Management Team (DMT) and Senior Leadership Team (SLT). . Notifying all parties on the RLDP database of the consultation (49 letters and 714 emails notifications were sent).

1.2.3 As a result of the non-statutory consultation and engagement a total of 105 responses were received. These have been summarised and grouped by the growth or spatial option that they relate to. A Council response to each of the general themes of comments submitted is provided, reflecting the strategic nature of this non-statutory consultation stage. A copy of all representations received is available to view on the Council’s website via the following link: GSO questions for database with general comments (5).pdf

1.2.4 The consultation responses received in relation to the Growth and Spatial Options Consultation Paper (December 2020) have been considered as part of this report and helped to inform the preparation of the Preferred Strategy. The Growth and Spatial Options Background Paper (June 2021) complements this Report of Consultation and adds further analysis of the options considered, including the extent to which they achieve the RLDP objectives and their performance against the Initial Sustainability Appraisal (ISA) themes.

Growth Options 1.2.5 Section 2 of this report summarises the views expressed in relation to the alternative Growth Options presented on how much Monmouthshire should grow over the Plan period of 2018-2033.

1.2.6 Six growth option scenarios were consulted upon, each with different outcomes in terms of population, dwellings, jobs and households. The Growth and Spatial Options Paper sets out details for each option on the number of new homes and the number

Monmouthshire Replacement Local Development Plan Growth and Spatial Options Report of Consultation (June 2021)

of people in the workforce, as well as implication for the age structure of the County. In addition to the initial modelling, all six options have been the subject of additional testing to establish the impact on demography, dwellings, household formation and employment of an affordable-housing policy-led strategy. Full details of the modelling and sensitivity assumptions are set out in the Edge Analytics Demographic Evidence Report (November 2020) and Affordable Housing Report (November 2020)2.

1.2.7 A summary of all the growth options considered in the preparation of the Preferred Strategy is set out in Table 1. A summary of the responses received in relation to the Growth Options and the Council’s response is set out in Section 2.

Table 1: Summary of Growth Options

Growth Option Additional Homes Additional jobs by 2033 by 2033 Option 1 – Balanced Migration (Demographic) -255 -1,800 Option 2 – Welsh Government 2018-based +3,930 +3,120 Principal Projection (Demographic) Option 3 – Welsh Government 2018-based +4,770 +3,975 Principal Projection with added policy assumptions (Demographic) Option 4 – Dwelling-led Average (Dwelling) +6,030 +5,460 Option 5 – Population-led projection +7,605 +7,215 (Demographic) Option 6 – Employment-led projection +9,060 +9,630 (Employment)

Spatial Options 1.2.8 Section 3 of this report summarises the views expressed in relation to the alternative Spatial Options presented in the consultation paper on how growth could be distributed within Monmouthshire. Four spatial options were selected for consultation each providing a summary of the advantages and disadvantages of each spatial option, along with a map to portray a spatial illustration, and consideration of the extent to which they will achieve the RLDP’s objectives.

1.2.9 A summary of all the spatial options considered in the preparation of the Preferred Strategy is set out in Table 2. A summary of the responses received in relation to the spatial options and the Council’s response is set out in Section 3.

2 Edge Analytics Demographic Report and Affordable Housing Evidence Addendum Report can be viewed via: https://www.monmouthshire.gov.uk/planning-policy/development-of-an-evidence-base/

Monmouthshire Replacement Local Development Plan Growth and Spatial Options Report of Consultation (June 2021)

Table 2: Summary of Spatial Options Spatial Option Brief Description Option 1: Distribute development around the County with a particular focus on Continuation of Main Towns3, some development in Severnside4 and some development the Existing in the most sustainable rural areas to enable provision of affordable LDP Strategy housing throughout the County. New residential development to be accompanied by new employment opportunities, where possible. Option 2: Distribute growth proportionately across Primary Settlements, Distribute Secondary Settlements, Severnside and those Rural Settlements Growth identified as having capacity for growth and/or in need of development Proportionately to sustain them, including, a small amount of development in the most across the sustainable Rural Settlements to bring forward affordable housing. County’s most Sustainable Settlements5 Option 3: Focus Growth would be predominantly located in the South of the County in on M4 corridor the Severnside area close to the M4/M48, to capitalise on its strategic links to the Cardiff Capital Region and South West England, existing economic opportunities and regional infrastructure connections, including via the South Wales Main rail line at Severn Tunnel Junction. Affordable Housing would be directed to those sustainable areas in the South of the County identified in the LHMA as having the greatest housing need. Option 4: Focus Growth would be predominantly located in the most sustainable on the North of settlements within the North of the County to capitalise on its strategic the County links to the Heads of the Valleys and wider Cardiff Capital Region via the A465, and towards Herefordshire via the A449 and A40, along with rail links to Newport, Cardiff and the North via the Welsh Marches line. Affordable Housing would be directed to those sustainable areas in the North of the County identified in the LHMA as having the greatest housing need.

3 As identified in Policy S1 of the Adopted Local Development Plan (2014), now renamed as Primary Settlements and includes the addition of Llanfoist as part of Abergavenny. 4 As identified in Policy S1 of the Adopted Local Development Plan (2014), with the addition of Crick as part of the Severnside area. 5 A Sustainable Settlement Appraisal will be published to inform the Preferred Strategy to identify these settlements. This will consider settlements in terms of their location, level of service provision, capacity and their role and function within the area.

Monmouthshire Replacement Local Development Plan Growth and Spatial Options Report of Consultation (June 2021) 2. Growth Options Report of Consultation

Question 1 – Growth Option 5 (Population-led Projection) is our preferred option. On the basis of the evidence provided, do you agree with our preferred growth option? Please explain why and provide your reasons? Number of responses Reasons for supporting Growth Option 5 Council’s Response Recommendation supporting Growth Option 5 42 respondents to Addresses Key Challenges and Issues Comments noted. Growth Option 5 - Population-led projection (with added policy assumptions) - is the Growth Option 5 - Population- question 1 support . Level of jobs and homes growth proposed in option 5 addresses preferred option. This option provides a level of growth that would best address the County’s key led projection (with added preferred growth the key challenges faced by the County, including demographic issues/challenges and meet the RLDP objectives. It would ensure the provision of a suitable number of policy assumptions) remains option 5. imbalance and housing affordability issues. market and affordable homes, sustainable economic growth and enable/support balanced and socially the preferred option. This . A lower growth rate would exacerbate the existing issues and sustainable communities, particularly in terms of demography; the importance of which has been option provides a level of (Of the 42 respondents challenges faced by the County and lead to further demographic heightened by the current pandemic. Overall, this option is considered to be the most conducive to growth that would best address 22 support Option 5 imbalance, displace the indigenous population and continue to achieving the RLDP vision and the Council’s core purpose of building sustainable and resilient the County’s key but can also see merit push up house prices and create further shortages of skills and communities across Monmouthshire. Growth Option 5 performs the most positively against the RLDP issues/challenges and meet the in Option 6) workforce. objectives and better overall against the ISA themes than any of the other five options. RLDP objectives. It would . Many of the issues faced by the County have been exacerbated ensure the provision of a by Covid-19 and Brexit and has shifted people’s focus on quality It is agreed that the Covid-19 pandemic may have impacted on many of the issues facing the County suitable number of market and of life. and initially resulted in a number of operational challenges, but it has also provided opportunities in affordable homes, sustainable how the planning system and the preparation of development plans can respond to the crisis. A review economic growth and of the aims, vision and objectives was undertaken in June 2020 which concluded that they remain valid enable/support balanced and in light of Covid-19 and in some instances had increased in importance. A review of the evidence base socially sustainable has also been undertaken and concluded that it is too soon to fully understand the impacts of Covid- communities, particularly in 19, but it will be an important consideration as the Plan progresses. terms of demography; the importance of which has been Methodology and Assumptions As noted, the publication of corrected Welsh Government 2018-based population and household heightened by the current . The approach taken to revisit the growth options in view of the projections in August 2020 comprise important new evidence that requires consideration to ensure pandemic. updated Welsh Government 2018 population projections is in that the evidence base for the RLDP is robust and based on the most up to date information. As stated accordance with PPW paragraph 4.2.3 – 4.2.9 which notes that in PPW11 the latest WG population and household projections form the starting point for the Plan’s Overall, this option is they form a fundamental part of the evidence base. evidence base on growth levels, onto which policy choices can be added to ensure that the issues are considered to be the most . The methodology and projections are founded on assumptions addressed, objectives met, and vision achieved. conducive to achieving the that reflect recent in-migration patterns, particularly from RLDP vision and the Council’s Bristol, the impact of the removal of the Severn Bridge tolls and The sensitivity testing aims to create a more balanced population structure to ensure that the County core purpose of building the potential long-term shift in employment working patterns as has a sufficient population base of working age people to support the economy and to ensure our sustainable and resilient a result of Covid-19. communities are sustainable and resilient, and to provide a level of growth that can provide communities across . Although comments were received recommending PG Long opportunities for younger people to both stay in and move into the area, whilst at the same time Monmouthshire. Growth Term Adjusted for 2 years and immigration from the Forest of reducing out-commuting by retaining more of the resident workforce. Option 5 performs the most Dean should have also been factored in. positively against the RLDP The removal of the tolls has been factored into the preferred option. This option adjusts in-migration objectives and better overall to take account of migration trends from Bristol and South Gloucestershire over the past 5 years. against the ISA themes than Migration trends from all other areas is based on an 18-year period. By extrapolating the recent any of the other five options. migration levels for these two groups over the Plan period gives an indication of likely trends going forward. As this scenario takes account of a longer period than that since the tolls were removed, it is more robust than the Scenario based on the 2 years since toll removal, as it is expected that migration levels would not continue at the higher level seen over the past 2 years.

The 2011 census indicated that 54% of the working age population commutes out of the County for work. The reduction in out-commuting in the sensitivity testing reflects the Council’s economic ambition to retain younger age groups, attract new employment to the County and reduce out- commuting. The reduction in out commuting also aligns with Welsh Government’s long-term ambition of 30% of Welsh workers from or near home6, and the Welsh Government’s transport policy hierarchy.

6 https://gov.wales/aim-30-welsh-workforce-work-remotely 5

Monmouthshire Replacement Local Development Plan Growth and Spatial Options Report of Consultation (June 2021)

Strategy to be supported by sufficient sites Comments noted. Agreed that the RLDP will need to identify sufficient viable and deliverable sites to . Supports the growth level but needs to be supported by viable deliver the preferred level of growth. A second call for Candidate Site will take place alongside the and deliverable sites. Preferred Strategy Consultation. This process will require site promoters to demonstrate that sites are . Responds to the underperformance/delivery of Adopted LDP viable and deliverable, and this will be a key consideration in the plan preparation process. sites. . A 10% flexibility allowance should be added in accordance with It is acknowledged that overall housing completion rates for the Adopted LDP period are below the paragraph 5.59 of the Development Plans Manual (Ed 3 – March required level, however, significant progress has been made in recent years with the shortfall steadily 2020). declining. This shortfall is largely attributable to the lead in period of the strategic housing sites. . Growth level supported but should not be a limit/maximum. However, progress is being made in bringing the LDP allocated sites forward, with six of the seven strategic sites now having planning permission and the submission of an application on the seventh at Vinegar Hill, Undy. This demonstrates that the strategic sites are deliverable and, as these sites have gained permission, their contribution to total completions has increased and are projected to meet or exceed the annual average requirement over the next 5 years as the remaining sites are build out, reducing the shortfall.

In accordance with the Development Plans Manual (March 2020) a 10% flexibility allowance has been incorporated as part of the Preferred Strategy. This figure will be kept under review as the Plan progresses to the Deposit stage.

The preferred growth level of option 5 is considered to be an appropriate level of growth to help address the key challenges and issues facing the County, including demographic imbalance, high house prices and out commuting whilst balancing against sustainability considerations. Supports Economic Recovery A key objective of the RLDP is to support a thriving, well connected, diverse economy that provides a . Seeks to deliver wider Council aspirations identified in range of good quality employment opportunities to enable and encourage indigenous business growth Economies of the Future Report and provides potential for and attract inward investment and competitive innovative business growth sectors. The RLDP has a Monmouthshire to play a role in helping provide homes and key role in supporting the Council’s vision for economic growth and will be one of the main enablers in employment opportunities to meet the aspirations of the Cardiff delivering sustainable economic growth and increasing employment opportunities in existing and Region City Deal. emerging sectors through the allocation of a range and choice of employment sites and a policy . Construction industry will play a vital role in economic recovery. framework to support key sectors such as tourism and retail. Monmouthshire’s priorities for economic . Housing and job growth levels will provide a long-term, robust growth are set out in ‘Monmouthshire 2040: Our Economic Growth and Ambition Statement’ approach towards future post Covid-19 and Brexit recovery. (November 2019) and Monmouthshire’s Inward Investment Prospectus 2020 (March 2020). These . Growth levels enable a boost in resident labour force to support reflect national and regional policies including ambitions for the Cardiff Capital Region and the Council’s new jobs in Monmouthshire. Corporate Plan and builds on the recommendations of the Economies of the Future Reports.

Monmouthshire Replacement Local Development Plan Growth and Spatial Options Report of Consultation (June 2021) economic impact of Covid-19 and aid recovery. Building Better Places recognises that the planning system will need to adapt quickly to the economic changes that may emerge as a result of Covid-19 or trends that have been accelerated such as agile working. In this respect, work has commenced on a revision of the Council’s Economic Growth and Ambition Plans in a Covid-19 recovery context. Number of responses Reasons for Objecting to Growth Option 5 Council’s Response Recommendation objecting to Growth Option 5 37 respondents to Flawed Strategy Comments noted. Growth Option 5 – Population-led Projection is the Council’s preferred level of Growth Option 5 - Population- question 1 object to . The level of growth proposed will be achieved as a result on in growth. This is considered to be an appropriate level of growth to help deliver the Council’s core led projection (with added preferred growth migration from Bristol. purpose of building sustainable and resilient communities. This option provides for a level of growth policy assumptions) remains option 5. . No evidence to support assumption that migration levels will not that addresses the key challenges and issues facing the County, including demographic imbalance, high the Council’s preferred option. continue at a higher rate than seen over the last 2 years. house prices and out commuting whilst balancing against sustainability considerations. Growth Option This option provides a level of Of the 37 respondents . Strategy does not address issued faced by the exsting ageing 5 performs the most positively against the RLDP objectives and better overall against the ISA themes growth that would best address 33 consider the growth population. than any of the other five options. the County’s key to be too high and 4 . There is no mention of rural communities and the strategy for issues/challenges and meet the respondents consider dealing with the needs of those areas not defined as a The evidence would not be robust if it failed to recognise the proximity of Monmouthshire to the Severn RLDP objectives. It would more growth should sustainable settlement. Bridge and relationship that exists with border authorities and the movement of people. For this ensure the provision of a be proposed. reason, the removal of the tolls has been factored into the preferred option. This option adjusts in- suitable number of market and migration to take account of migration trends from Bristol and South Gloucestershire over the past 5 affordable homes, sustainable years. Migration trends from all other areas is based on an 18-year period. By extrapolating the recent economic growth and migration levels for these two areas over the Plan period gives an indication of likely trends going enable/support balanced and forward. As this scenario takes account of a longer period than that since the tolls were removed, it is socially sustainable more robust than the Scenario based on the 2 years since toll removal, as it is expected that migration communities, particularly in levels would not continue at the higher level seen over the past 2 years. terms of demography; the importance of which has been The growth options consultation paper is a high-level stage of the Plan making process seeking to heightened by the current establish an appropriate level and distribution of growth. Detailed policy considerations including pandemic. appropriate policy responses to specific sectors of Monmouthshire’s population including the existing ageing population will be set out in the detailed policies that follow in the later stages of the Plan. Overall, this option is considered to be the most Sustaining rural communities is a key objective of the RLDP (objective 13) with several Strategic Policies conducive to achieving the within the Preferred Strategy seeking to address this issue. For example, Strategic Policy 2 – Spatial RLDP vision and the Council’s Distribution of Development, sets out an indicative level of growth for the rural settlements and core purpose of building Strategic S14 – Rural Enterprise and S15 – Visitor Economy, set out the strategic policy framework for sustainable and resilient supporting the rural economy and the sectors that play a key role such as agriculture, tourism and communities across hospitality. The detailed stages of the Plan will build on these and set out a policy framework to provide Monmouthshire. Growth for development of an appropriate scale and infrastructure such as broadband network, to assist in Option 5 performs the most building sustainable rural communities and strengthening the rural economy. Similarly, Future Wales positively against the RLDP 2040 establishes a commitment to supporting rural communities and economy. Policy 4 – Supporting objectives and better overall Rural Communities and Policy 5 – Supporting the Rural Economy, establishes the national policy against the ISA themes than approach for the RLDP to plan positively to meet the community and employment needs of rural areas any of the other five options. through appropriate and proportionate growth. Departure from Welsh Government Population Projections The latest WG population and household projections form the starting point for the Plan’s evidence . Growth option 5 represents a departure from Welsh base on growth levels, however, it is important to consider alternative scenarios to test the impacts of Government 2018 population projections for Monmouthshire, different assumptions over the Plan period. This approach reflects current national planning policy which proposed a 6.4% (6047) population increase giving a need guidance as set out in PPW11 (Feb 2021, paragraphs 4.2.6-4.2.7), which requires LPAs to consider and for 3,930 houses and 3,120 jobs for the period 2018 – 2033 provide for a level of housing that is based on various sources of evidence rather than just the WG (Growth Option 2 including affordable housing element). projections, this includes having regard to what the Plan is seeking to achieve, links between homes . ONS projections for births, deaths and migration produced in and jobs and affordable housing need as evidenced by the Local Housing Market Assessment (LHMA). August 2020 indicate population growth of 3.4% between 2018 – 2028. Option 5 represents an increase of 13.2%. The Council’s preferred option uses the 2018-based population and household projections as the . Stats Wales population projections show an increase of 4,000 to starting point. The 2018-based projections project an increase of 2,732 households and 2,861 dwellings 98,726 by 2033 and 6,500 by 2043. over the Plan period if the trends of the past 5 years are simply taken forward for the next 15 years 7

Monmouthshire Replacement Local Development Plan Growth and Spatial Options Report of Consultation (June 2021)

taking no account of any more recent evidence, trends or policy interventions to address the agreed objectives and evidenced issues. The growth scenarios being consulted upon take account of this by applying different assumptions.

In the past two years there has been a noticeable increase in in-migration from Bristol and South Gloucestershire following the removal of the Severn Bridge tolls. To reflect this more recent data on internal in-migration rates has been adjusted for the preferred option. In order to ensure that the issues identified in the Plan are addressed, objectives met and the vision for the County achieved sensitivity testing has also been undertaken. The sensitivity testing seeks to address the County’s unbalanced demographic and address out-commuting, key objectives for the RLDP. It does this by modelling adjustments to the household membership rates for three key younger age groups and reducing the level of out-commuting. In addition, further testing has been undertaken to establish the impact on demography, dwellings, household formation and employment of an affordable-housing policy-led strategy. The delivery of affordable housing is another key objective of the Plan. The LHMA is a core piece of baseline evidence for the Plan as it identifies the level of housing need in the County. The Development Plans Manual (paragraph 5.32) states that the scale of affordable housing need will be a key consideration when determining the overall level of housing in the Plan. The additional testing therefore uses the level of affordable housing need arising over the Plan period, as evidenced by the LHMA, and as a starting point proposes to meet 10% of this need on affordable housing-led sites where at least 50% of the homes are affordable.

By considering more recent evidence, policy interventions to tackle the agreed objectives and evidenced issues and affordable housing need the modelling projects that we will require 7,605 new dwellings over the Plan period, of which 3,658 new homes would be on new site allocations, the remainder being accounted for by existing commitments and windfall and small site allowances. Future Wales: 2040 Conformity Issues Planning Policy Wales 11 (Feb 2021) notes at paragraph 1.24 that Local Development Plans must be in . Growth of the scale proposed by Growth Option 5 is contrary to general conformity with Future Wales: 2040 and this will be tested through the examination process. Future Wales:2040 which directs growth to Newport, Cardiff and The Development Plans Manual (March 2020) provides advice on the definition of general conformity. the Valleys. Paragraph 2.17 notes that general conformity is achieved when the lower tier plan supports and upholds the general principles of the most up-to-date higher tier adopted plan.

Policy 1 – Where Wales will grow and Policy 33 of Future Wales establishes Cardiff, Newport and the Valleys as the main focus for growth and investment in the South East Wales. Policy 1 also notes however, that “Development and growth in towns and villages in rural areas should be of appropriate scale and support local aspirations and need”. These are also accompanied by a suite of policies seeking to facilitate sustainable growth across Wales as a whole. Of relevance to Monmouthshire, Policy 4 – Supporting Rural Communities – states that LDPs must identify their rural communities, assess their needs and set out policies that support them. Policies should consider how age balanced communities can be achieved, where depopulation should be reversed and consider the role of new affordable and market housing, employment opportunities, local services and greater mobility in tackling challenges. Similarly, Policy 5 – Supporting the Rural Community, supports sustainable, appropriate and proportionate economic growth in rural towns. Collectively, these policies seek to deliver the Future Wales Outcomes, particularly Outcome 2 which aims to deliver a Wales where people live in vibrant rural places with access to homes, jobs and services (page 54).

Future Wales also recognises that national and regional estimates of housing need should inform the housing requirements set out in LDPs but it is expected the housing requirements will differ from estimates of housing need (page 72). In this respect, Growth Option 5 is considered to be in general conformity with Future Wales as it seeks to specifically address local issues and challenges consistent with those noted in Policy 4 of Future Wales.

Monmouthshire Replacement Local Development Plan Growth and Spatial Options Report of Consultation (June 2021) The Preferred Strategy addresses Monmouthshire’s local issues and challenges whilst aligning with the objectives of Future Wales and establishes a policy framework that is in general conformity and makes a positive contribution to its policy aims. At a local and regional level, the RLDP is well-placed to implement the vision and objectives of Future Wales by ensuring that it includes policies that adhere to principles of placemaking and sustainable development. The issue of general conformity is discussed further in the Self-Assessment of the Preferred Strategy against the Test of Soundness Background Paper. The paper addresses all the tests of soundness and highlights the balance that needs to be struck between then the different tests including “Are the vision and the Strategy positive and sufficiently aspirational” and “Does it address the key issues?”. Climate Change Impact The Climate Emergency is recognised as a key issue (issue 38) and objective (17) of the RLDP and PPW11 . Preferred growth option is incompatible with the Council’s and Welsh Government Build Better Places document both recognise the important role the RLDP will Climate Emergency Declaration and will exacerbate the climate play in achieving a reduction in carbon emissions and achieving Welsh Government’s target of building emergency. zero carbon ready homes by 2025. . Difficult to reach the objective to be a net zero carbon council by 2030 with the scale of development proposed. The RLDP must balance a number of factors in line with the Well-being of Future Generation Act 2015 . No reference to the measures the Council will take to address which requires consideration of all four aspects of well-being: social, economic, environmental and climate change through the RLDP. Building houses that do not cultural and work towards the seven well-being goals established in the Act. In this respect, the RLDP meet net zero carbon standards should not be allowed. must address climate emergency whilst also delivering on other well-being aspects of the County, such . The strategy will lead to an increase in air pollution and as housing need, economic prosperity, and cohesive communities. Efforts to tackle climate change are congestion as it is likely to lead to increased out-commuting. wide-ranging and will require a co-ordinated approach to development including aspects such as active travel, green infrastructure, effective use of resources and land and flood resilience.

The Council is committed to tackling climate change and reducing carbon emissions and is currently developing an evidence base to support a policy framework for inclusion at the Deposit stage of the development plan process and will look for opportunities to build on carbon reductions being implemented through changes to Building Regulations. Developments will also be expected to mitigate the causes of climate change in accordance with the Energy Hierarchy set out in PPW. This seeks to reduce energy demand and increase energy efficiency, through the location, design and construction of new development. In line with PPW, the Deposit RLDP will also set out renewable energy generation targets and establish spatial policies which identify the most appropriate locations for developments below 10MW.

The Preferred Strategy seeks to reduce out-commuting and build on the fundamental shift in working patterns since the start of the Covid-19 pandemic with an increased propensity to work from home/remotely. It is expected that this trend will continue over the longer term and in accordance with Welsh Government’s ambition of 30% of the Welsh workforce working from or near home is something that we wish to encourage and enable. This approach will help to reduce congestion, emissions and pollution and enable the creation of sustainable communities and 20-minute neighbourhoods where residents live within 20 minutes walking distance of key everyday services. Biodiversity, Landscape Impact and Best and Most Versatile A key objective of the RLDP is to protect, enhance and manage Monmouthshire’s natural environment Agricultural Land Impact and ecosystems as well as the County’s other high quality distinctive landscapes, protected sites, . Potentially damage the character and landscape of the County, protected species, and other biodiversity interests. The assessment of growth option 5 against the particularly adjacent to the Brecon Beacons National Park. RLDP objectives recognises that the levels of growth proposed would likely result in further pressure . Growth option 5 will result in more greenfield development as on the natural environment. In accordance with the Environment (Wales) Act 2016 and the biodiversity there is limited brownfield sites in Monmouthshire. and resilience of ecosystems duty (Section 6 Duty), development must not cause any significant loss of . Best and Most Versatile agriculture land should be conserved as habitats or populations of species, locally or nationally and must provide a net benefit for biodiversity. a finite resource. In addition, new developments will be required to mitigate and incorporate improvements to Green . Biodiversity should be protected, and it is difficult to deliver Infrastructure and ecological connectivity through opportunities to create new linkages. Impact on biodiversity net gain with the scale of development proposed. landscape will also be an important consideration in making site allocation at the Deposit stage of the Plan. LANDMAP and its associated landscape character assessments as well as a Landscape Sensitivity Update will be used to inform local landscape policies, SPG and site allocations.

Monmouthshire Replacement Local Development Plan Growth and Spatial Options Report of Consultation (June 2021)

The RLDP will set out an approach to protect the Best and Most Versatile agricultural land and minimise its loss as far as possible through a sequential approach to development as required by national policy. However, it is recognised that there are limited opportunities for further development on brownfield and lower grade agricultural land in Monmouthshire. Affordable Housing Policy-led Element The affordable housing policy-led element of the Strategy aims to address the key issues associated . The Council is failing to deliver 35% affordable homes so will with housing affordability in the County. The current pandemic has increased the need for such homes struggle to deliver 50%. and revealed the extent of hidden homelessness in the County. The Minister for Housing and Local Government has announced that post-Covid-19, no-one should return to the streets and Welsh Government’s Building Better Places response to Covid-19 also highlights the delivery of new social and market housing making a significant contribution to economic recovery and social cohesion. The affordable housing policy-led growth will assist in addressing these fundamental issues/challenges by providing opportunities to retain/house those in need of social and intermediate homes. It will also help to redress the County’s demographic imbalance and improve the resilience and sustainability of our communities and the strength of our economic base.

A specific policy-led affordable housing element has been added to all the growth options, including the preferred growth option 5. These additional dwellings will be delivered on sites comprising at least 50% affordable housing and will meet 10% of the total affordable housing need within the County (identified by Monmouthshire’s Local Housing Market Assessment 2020). This approach will help to explicitly address the Council’s key/most prevalent issue of lack of affordable housing (RLDP Objectives 9, 10, 11, 12 and 13). There will be a requirement that this element of the option will be delivered on sites which have at least 50% affordable housing. The delivery of both market and affordable homes on these sites is in addition to homes delivered on sites allocated to meet the level of growth evidenced by the initial modelling. The appropriate level sought on these sites will emerge as part of the high-level viability appraisal being undertaken to establish the appropriate affordable housing thresholds.

In line with Policy 7 of Future Wales: 2040, the policy-led affordable housing element seeks to identify sites for affordable housing led development and explore all opportunities to increase the supply of affordable housing. In considering site allocations site promoters will be required to demonstrate that sites are viable, and deliverable based on the affordable housing threshold established either through policy or the viability modelling. This will be a key consideration in the plan preparation process. Overly Ambitious and Undeliverable Strategy A housing trajectory will be prepared to support the Deposit Plan. This will set out anticipated delivery . Required annual build rate associated with Growth Option 5 is rates for any allocations made. Historic rates have in part reflected the housing allocations made in unrealistic and more than has been achieved for last 15 years. past plans and longer than anticipated lead in times. In line with the Development Plans Manual (March 2020) site promoters are required to submit a viability assessment at the Candidate Site Stage to demonstrate that sites are viable prior to allocation. This work will feed into policy and the master planning of sites at the Deposit stage. As noted in the Development Plans Manual (March 2020) only in exceptional circumstances should further viability appraisals be undertaken at the planning application stage. In the past viability has been a big cause for delay/ slow delivery rates and it is hoped by bringing this assessment forward it will stop the delays in delivery rates. Infrastructure Capacity An Infrastructure Plan will be prepared as part of the evidence base to support the Deposit Plan and . The proposed level of growth will be additional strain on site allocations. Detailed policies will be prepared for site allocations at the Deposit stage and will infrastructure, for example, schools and roads and will not establish infrastructure requirements in policy. As part of the process site promoters will need to address existing infrastructure problems. demonstrate that sites are viable and deliverable having regard to these policy requirements including school and road infrastructure. In the meantime, we will continue to work with relevant infrastructure providers in the preparation of the Plan. Limited Evidence to Back Up Modelling Assumptions A detailed evidence base for the Growth Options is set out in the Edge Analytics Monmouthshire RLDP . No evidence that the demography of the County’s age structure Demographic Evidence (November 2020) and Monmouthshire RLDP Affordable Housing Evidence will improve. More homes do not necessarily mean more Addendum Report (November 2020). The Edge Analytics reports set out a demographic profile of the affordable homes, younger people and jobs. County, illustrating the geographical context, components of population change (i.e. births, deaths and . Little evidence to suggest Growth Option 5 will deliver more migration), housing completions and the changing ageing profile of the population. These documents affordable housing or jobs. illustrate how the preferred growth option 5 will positively affect the age structure of the County and 10

Monmouthshire Replacement Local Development Plan Growth and Spatial Options Report of Consultation (June 2021) also how the lower growth options would result in negative growth in the lower age groups of the County, resulting in an unbalanced demographic. It is recognised however, that additional policies and interventions will be required to deliver these changes on the ground. The RLDP will establish the wider policy framework required to facilitate such changes.

The RLDP will also sit alongside an Economic Development Strategy which will be prepared by the Councils’ Enterprise and Economy Section. This will set the Council's key mechanisms and actions for attracting businesses to the County and facilitating growth of existing companies. While the land use allocations of the Plan focus on industrial type employment (B Use Class) other sectors will also be important in job growth – for example tourism, leisure and hospitality sectors. Monmouthshire’s priorities for economic growth are set out in ‘Monmouthshire 2040: Our Economic Growth and Ambition Statement’ (November 2019) and Monmouthshire’s Inward Investment Prospectus 2020 (March 2020).

Delivering more affordable housing is a key objective of the Plan and will be supported by several policies to facilitate its delivery. For example, the policy-led affordable housing element of the housing requirement will be delivered on sites comprising at least 50% affordable housing. We will also be looking to adopt a housing mix policy which will require developers to incorporate a wider mix of house types including small starter homes, hopefully making these affordable to first time buyers. Smaller homes may also be appropriate to older generations who are looking to downsize. Job led Strategy Should be Pursued Informal feedback from Welsh Government officials has indicated a lack of confidence in economic-led . The strategy should be jobs led not housing led. projections. Whilst the Council has an aspiration for economic growth and is making progress towards this goal, there is less certainty around the effects of the employment-led scenarios on population/housing growth than the demographic and housing-led options. Considering this the Council does not propose to use an economic-led scenario as a basis for the preferred growth option. Economic Considerations There are a number of reasons as to why the job growth associated with the Growth and Spatial Options . Substantial increase in job numbers with no evidence provided Paper published in June 2019 and the revisited Paper in December 2020 has altered and therefore are that the County will attract greater employment growth not directly comparable: especially at such a time of economic uncertainty linked to Brexit and Covid-19. 1. The Starting points for the projections – WG Population projections – The differences between . Can allocate employment land but there is no control on the WG 2014-based and 2018-based local authority population projections reflect both a change in whether this will be used. demographic trends seen during this time period and also a change in the methodology between the . More mechanisms will be needed to achieve the jobs growth, two sets of projections, as well as the change in the base year of the projection. The 2018-based such as an Economic Strategy. population projections project an increase in the working-age population of some 3,175 over the 15 . The Growth and Spatial Options Consultation Report does not years to 2033 compared to 432 in the 2014-based projections. provide any details on the level of employment land required. 2. Policy-led Assumptions- There are also some differences between those assumptions applied to the previous demographic projections which use the 2014-based WG projections as the starting point and the current demographic projections which use the 2018-based WG projections as the starting point. Whilst an adjustment to the household membership rates for three young adult age groups, and a small adjustment to the commuting ratio is the same for both an additional assumption was applied to the base projection for the 2018-based projection. This adjusted internal in-migration rates to reflect the higher in-migration from Bristol and South Gloucestershire to take account of the Severn Bridge tolls.

The labour force and jobs implications of a population growth trajectory are estimated through the application to the base population of three key economic assumptions: economic activity rates, commuting ratio and an unemployment rate. These are broadly the same between the two sets of projections. However, as the starting point for estimating the labour force and job implications of a trajectory is the working age population growth the differences between the two sets of projections arising from the base projection and the policy-led assumptions will impact on the jobs arising.

Monmouthshire Replacement Local Development Plan Growth and Spatial Options Report of Consultation (June 2021)

A key objective of the RLDP is to support a thriving, well connected, diverse economy that provides a range of good quality employment opportunities to enable and encourage indigenous business growth and attract inward investment and competitive innovative business growth sectors. The RLDP has a key role in supporting the Council’s vision for economic growth and will be one of the main enablers in delivering sustainable economic growth and increasing employment opportunities in existing and emerging sectors through the allocation of a range and choice of employment land and a policy framework to support other key sectors such as agriculture, tourism and hospitality. Monmouthshire’s priorities for economic growth are set out in ‘Monmouthshire 2040: Our Economic Growth and Ambition Statement’ (November 2019) and Monmouthshire’s Inward Investment Prospectus 2020 (March 2020). These reflects national and regional policies including ambitions for the Cardiff Capital Region and the Council’s Corporate Plan and builds on the recommendations of the Economies of the Future Reports.

It is recognised however, that additional policies and interventions will be required to deliver this level of economic growth. The RLDP will also sit alongside an Economic Development Strategy which will set the Council's key mechanisms and actions for attracting businesses to the County and facilitating growth of existing companies. While the land use allocations of the Plan focus on industrial (B Use Class) type employment other sectors will also be important in job growth – for example tourism, leisure and hospitality sectors. The RLDP will set out the policy framework to support appropriate economic growth in all sectors.

Whilst growth option 5 projects a significant growth in jobs, with an increase of 7,215 jobs over the Plan period, it is recognised that there has been a fundamental shift in working practices since the start of Covid-19 pandemic with an increased propensity to work from home/remotely. It is expected that this trend will continue over the longer term and in accordance with Welsh Government’s ambition of 30% of the Welsh workforce working from or near home is something that we wish to encourage and enable. This provides residents with the opportunity to both live and work in the County in this new way, providing a flexible approach to achieving this level of job growth, whilst also achieving the Welsh Government and Council’s aim of reducing the need for commuting. This approach will help to reduce congestion, emissions and pollution, improve the work-life balance for employees and employers, support local businesses/services and enable the creation of sustainable vibrant communities and ’20 minute neighbourhoods’.

Welsh Government’s Building Better Places policy response to placemaking and the Covid-19 recovery recognises the significant role planning and Local Development Plans play in facilitating economic recovery post Covid-19. The Council has played an active role in administering UK and Welsh Government economic resilience funding for business throughout the pandemic to reduce the economic impact of Covid-19 and aid recovery. Building Better Places recognises that the planning system will need to adapt quickly to the economic changes that may emerge as a result of Covid-19 or trends that have been accelerated such as agile working. In this respect, work has commenced on a revision of the Council’s Economic Growth and Ambition Plans in a Covid-19 recovery context.

Details of the level of employment land required to support the preferred growth option are set out in Strategic Policy 13 – Employment Sites Provision, of the Preferred Strategy following the completion of the Employment Land Review (June 2021). This sets out a minimum requirement of 43ha of land on a suitable range and choice of sites for industrial and business development (B Use Classes). The methodology for this piece of evidence base is set out in Welsh Government’s Practice Guidance: Building an Economic Development Evidence Base to support a Local Development Plan. The site- specific employment allocations will be made at the Deposit Plan stage. Growth Option 5 does not propose enough growth Growth Option 5 provides a level of growth that would best address the County’s key issues/challenges . Growth Option 5 does not provide an adequate level of growth and meet the RLDP objectives. It would ensure the provision of a suitable number of market and to address the issues and challenges facing the County. affordable homes, sustainable economic growth, and enable/support balanced and socially sustainable 12

Monmouthshire Replacement Local Development Plan Growth and Spatial Options Report of Consultation (June 2021) . Does not provide sufficient growth or leverage for City Deal communities, particularly in terms of demography; the importance of which has been heightened by investment to be targeted in the area. the current pandemic. Overall, this option is considered to be the most conducive to achieving the RLDP . Does not provide enough growth in the working age population vision and the Council’s core purpose of building sustainable and resilient communities across to make a sufficient contribution to job growth. Monmouthshire. Growth Option 5 performs the most positively against the RLDP objectives and better . While Option 5 reflects the potential effects of higher net in- overall against the ISA themes than any of the other five options. migration associated with the removal of the Severn Bridge tolls no evidence is provided to justify migration will not continue as The population growth associated with Growth Option 5 results in a significant impact on the age profile the higher level seen over the past 2 years. of the County. Whiles there continues to be growth in the over 60 age group there is a corresponding growth in the key 30-49 age groups, with growth mirrored in the 0-19 age groups. This option captures increased in-migration in the key labour force age groups and it considered to show significant progress in achieving a more balanced demographic fuelling growth in employment provision.

The removal of the tolls has been factored into the preferred option. This option adjusts in-migration to take account of migration trends from Bristol and South Gloucestershire over the past 5 years. Migration trends from all other areas is based on an 18-year period. By extrapolating the recent migration levels for these two areas over the Plan period gives an indication of likely trends going forward. The approach taken to take account of a longer period than that since the tolls were removed, is considered to be a more robust approach than the Scenario based on the 2 years since toll removal, as it is expected that migration levels would not continue at the higher level seen over the past 2 years.

Question 2 - If you have a preference for a different option, please state which option and provide details of how your preferred option will address the issues/challenges Monmouthshire is facing and the RLDP and ISA objectives. No. of respondents Details of how Growth Option 1: Balanced Migration will address Council’s Response Recommendation with a preference for the issues/challenges of Monmouthshire Growth Option 1 2 respondents Climate Change The Climate Emergency is recognised as a key issue (issue 38) and objective (17) of the RLDP and PPW11 In view of the negative impacts preferred option 1 . This option would represent a serious commitment to climate and Welsh Government Build Better Places document both recognise the important role the RLDP will associated with this growth change. play in achieving a reduction in carbon emissions. option and its poor performance against the RLDP It is acknowledged that as Growth Option 1 does not propose any further growth it is likely to avoid objectives and identified ISA significant effects on factors relating to climate change such as land resources. However, the option themes, it is not considered performs poorly when assessed other RLDP objectives including demography, housing and prudent to take this option communities. The RLDP must balance several factors in line with the Well-being of Future Generation forward. Further details are set Act 2015 which requires consideration of all four aspects of well-being: social, economic, environmental out in the Growth and Spatial and cultural, and work towards the seven well-being goals established in the Act. In this respect, the Options Background Paper. RLDP must address climate emergency whilst also delivering on other well-being aspects of the County, such as housing need, economic prosperity, and cohesive communities. Efforts to tackle climate change are wide-ranging and will require a co-ordinated approach to development including aspects such as active travel, green infrastructure, effective use of resources and land and flood resilience.

We remain committed to tackling climate change and reducing carbon emissions and are currently developing an evidence base to support a policy framework for inclusion at the Deposit stage of the development plan process and will look for opportunities to build on carbon reductions being implemented through changes to Building Regulations. Developments will also be expected to mitigate the causes of climate change in accordance with the Energy Hierarchy set out in PPW. This seeks to reduce energy demand and increase energy efficiency, through the location, design and construction of new development. In line with PPW, the Deposit RLDP will also set out renewable energy generation targets and establish spatial policies which identify the most appropriate locations for developments below 10MW. Meets RLDP Objectives Growth Option 1 did not perform well against the RLDP objectives listed in the objection (i.e. Place- making, Communities, Rural Communities and Infrastructure) as this option projects a population decline of 5.4% which translates into a negative dwelling requirement of 17 dwelling per annum 13

Monmouthshire Replacement Local Development Plan Growth and Spatial Options Report of Consultation (June 2021)

. This option is best placed to meet objectives 11 (Place-making), between 2018 – 2033. The option impacts significantly on the age profile of the County leading to a 12 (Communities), 13 (Rural Communities) and 14 notably unbalanced demography and significant decline in employment. Collectively these factors (Infrastructure) of the RLDP. illustrate that the Growth Option 1 would not form the basis for creating sustainable and resilient communities. Additional Affordable Housing Growth option 1 already incorporates an element of growth to specifically address affordable housing . Should pursue this level of growth but extend it to allow some levels in the County. A specific policy-led affordable housing element has been added to all the growth affordable housing to be delivered, built in locations with good options, including Growth Option 1. These additional dwellings will be delivered on sites comprising at employment opportunities such as along the M4. least 50% affordable housing and will meet 10% of the total affordable housing need within the County (identified by Monmouthshire’s Local Housing Market Assessment 2020). However, as Growth Option 1 does not require any new housing development until 2033 it will fail to deliver any new affordable housing in addition to those already agreed as part of the existing commitments.

Location issues are discussed in Section 3 of this report. No. of respondents Details of how Growth Option 2: WG 2018-based Principal Council’s Response Recommendation with a preference for Projections will address the issues/challenges of Monmouthshire Growth Option 2 15 respondents Replicates Welsh Government 2018-based projections As noted, Growth Option 2 replicates the Welsh Government 2018-based Principal Projection and the In view of the negative impacts preferred option 2 (4 . This option replicates the Welsh Government 2018-based addition of an affordable housing policy-led strategy. The latest WG population and household associated with this growth of which suggest a projection. A strategy that relies on building substantially more projections form the starting point for the Plan’s evidence base on growth levels, however, it is option and its poor hybrid of options 2 & market housing than is projected need should not be pursued important to consider alternative scenarios to test the impacts of different assumptions over the Plan performance against the RLDP 3) unless sure it is to be accompanied by local employment growth. period. This approach reflects current national planning policy guidance as set out in PPW11 (Feb 2021, objectives and identified ISA paragraphs 4.2.6-4.2.7), which requires LPAs to consider and provide for a level of housing that is based themes, it is not considered on various sources of evidence rather than just the WG projections, this includes having regard to what prudent to take this option the Plan is seeking to achieve, links between homes and jobs and affordable housing need as evidenced forward. Further details are set by the Local Housing Market Assessment (LHMA). out in the Growth and Spatial Options Background Paper. The level of growth projected by Growth Option 2 gives a population increase of 6.4% over the Plan period resulting in an estimated average annual dwelling growth of 262 dwellings per annum: lower that the current Adopted LDP dwelling requirement of 450 dwellings per annum. This option has significant implications on the age profile of the County with much of the growth coming from the over 60 age groups resulting in an unbalanced demographic. Given the limited growth rate associated with Growth Option 2 and the level of existing commitments in the Adopted LDP this option also does not require any new allocations to be made. Consequently, this option does not perform well against the RLDP objectives and the key challenges the Council are seeking to address through the RLDP. Realistic Build Rate Growth Option 2 results in an estimated average annual dwelling growth of 262 dwellings per annum . Represents a continuation of the average build rate achieved over the 2018-2033 Plan period (total 3,920 dwellings). This is lower than the current LDP dwelling over the last 15 years. An annual requirement of 262 dwellings requirement of 450 dwellings per annum and also below average completions over the past 5 years per annum is similar to the average of 269 achieved over the (310 dwellings per annum) and 10 years (285 dwellings per annum). This level of housing and economic past 15 years. growth and the resultant demographic makeup of the County performs less well compared to other growth options in addressing the RLDP objectives and the key challenges the Council is seeking to address through the RLDP. Protects Natural Assets It is acknowledged that as Growth Option 2 does not require new allocations it is likely to avoid . As this option does not require any new allocations it is best significant effects on factors relating to natural resources and climate change. However, the RLDP must placed to protect landscape character, biodiversity and minimise balance several factors in line with the Well-being of Future Generation Act 2015 which requires CO2 emissions. consideration of all four aspects of well-being: social, economic, environmental and cultural, and work towards the seven well-being goals established in the Act. In this respect, the RLDP must address environmental and climate emergency issues whilst also delivering on other well-being aspects of the County, such as housing need, economic prosperity, and cohesive communities.

A key objective of the RLDP is to protect, enhance and manage Monmouthshire’s natural environment and ecosystems as well as the County’s other high quality distinctive landscapes, protected sites, protected species, and other biodiversity interests. These objectives will be pursued with any of the 14

Monmouthshire Replacement Local Development Plan Growth and Spatial Options Report of Consultation (June 2021) growth options. In accordance with the Environment (Wales) Act 2016 and the biodiversity and resilience of ecosystems duty (Section 6 Duty), development must not cause any significant loss of habitats or populations of species, locally or nationally and must provide a net benefit for biodiversity. In addition, new developments will be required to mitigate and incorporate improvements to Green Infrastructure and ecological connectivity through opportunities to create new linkages. Impact on landscape will also be an important consideration in making site allocations at the Deposit stage of the Plan. LANDMAP and its associated landscape character assessments as well as a Landscape Sensitivity Study Update will be used to inform local landscape policies, SPG and site allocations. Similarly, we remain committed to tackling climate change and reducing carbon emissions and are currently developing an evidence base to support a policy framework for inclusion at the Deposit stage of the development plan process which will set targets for renewable energy generation as well as carbon reductions in developments.

The RLDP will be accompanied by an Integrated Sustainability Appraisal (ISA) which will consider the environmental, equalities, health and well-being impacts of the Plan and will be updated as the RLDP progresses. Low Risk Strategy It is acknowledged that Covid-19 may have impacted on many of the issues facing the County and . Represents a low-risk strategy at a time of unprecedented resulted initially resulted in a number of operational challenges, but it has also provided opportunities uncertainty. in how the planning system and the preparation of development plans can respond to the crisis. A review of the issues, vision and objectives was undertaken in June 2020 and concluded that they remain valid in light of Covid-19 and in some instances had increased in importance. A review of the evidence base has also been undertaken and concluded that it is too soon to fully understand the impacts of Covid-19, but it will be an important consideration as the Plan progresses. Welsh Government’s Building Better Places policy response to placemaking and the Covid-19 recovery recognises the significant role planning and Local Development Plans play in facilitating economic recovery post Covid- 19.

This level of housing and economic growth and the resultant demographic makeup of the County associated with Growth Option 2 performs less well compared to other growth options in addressing the RLDP objectives and the key challenges the Council is seeking to address through the RLDP. Enhance Tourism, Leisure and Agricultural Industries This level of housing and job growth and the resultant demographic makeup of the County associated . Option 2 growth rate is preferred along with a focus to protect with Growth Option 2 performs less well compared to other growth options in addressing the RLDP and enhance tourism, leisure and agricultural industries, small objectives and ISA themes and the key challenges the Council is seeking to address through the RLDP. scale affordable housing and public transport improvements. Protecting and enhancing the County’s leisure and tourism industries and agricultural sector are key objectives of the RLDP and will be supported through the detailed policy framework of the Preferred Strategy and Deposit Stages of the Plan. No. of respondents Details of how Growth Option 3: WG Principal Projections with Council’s Response Recommendation with a preference for added policy assumptions will address the issues/challenges of Growth Option 3 Monmouthshire 10 respondents Good Balance of Growth and Protection The level of housing and job growth associated with Growth Option 3 would fail to address the Council’s In view of the negative impacts preferred option 3 (4 . Represents a good balance – would provide above average strategic ambitions from both an economic and social perspective and conflict with the proposed key associated with this growth of which suggest a housing and employment growth and allow for in-migration elements of the RLDP objectives and ISA themes relating to the economy and employment, population option and its poor hybrid of option 2 & 3) whilst respecting Monmouthshire’s character and environment and communities, health and wellbeing and equalities. As a result, it is unlikely to address the performance against the RLDP and addresses the aims of climate change. demographic and economic challenges that the County faces. objectives and identified ISA Lower Risk Strategy It is acknowledged that Covid-19 may have impacted on many of the issues facing the County and themes, it is not considered . This is a less risky option than options 4, 5 & 6 and represents an resulted in challenges in how planning operates, but also opportunities in how the planning system and prudent to take this option achievable and acceptable rate of growth. Given Covid-19 it is the preparation of development plans can respond to the crisis. A review of the aims, vision and forward. Further details are set unlikely that rural Monmouthshire will achieve higher new job objectives was undertaken in June 2020 and concluded that they remain valid in light of Covid-19 and out in the Growth and Spatial growth than the level 3 rate. in some instances had increased in importance. A review of the evidence base has also been Options Background Paper. undertaken and concluded that it is too soon to fully understand the impacts of Covid-19, but it will be an important consideration as the Plan progresses. Welsh Government’s Building Better Places policy

Monmouthshire Replacement Local Development Plan Growth and Spatial Options Report of Consultation (June 2021)

response to placemaking and the Covid-19 recovery recognises the significant role planning and Local Development Plans play in facilitating economic recovery post Covid-19.

With regards to jobs growth, it is recognised that additional policies and interventions will be required to deliver the level of economic growth associated with Growth Option 5. The level of job growth aligns with the projected population and housing growth and takes account of adjustments to household membership rates for key younger age groups and a reduced level of commuting by retaining more of the resident workforce and growing our working age demographic. There has been a fundamental shift in working practices since the start of Covid-19 pandemic with an increased propensity to work from home/remotely. It is expected that this trend will continue over the longer term and in accordance with Welsh Government’s ambition of 30% of the Welsh workforce working from or near home is something that we wish to encourage and enable. This provides residents with the opportunity to both live and work in the County in this new way, providing a flexible approach to achieving this level of job growth, whilst also achieving the Welsh Government and Council’s aim of reducing the need for commuting. This approach will help to reduce congestion, emissions and pollution, improve the work-life balance for employees and employers, support local businesses/services and enable the creation of sustainable vibrant communities.

The RLDP will also sit alongside an Economic Development Strategy which will set the Council's key mechanisms and actions for attracting businesses to the County and facilitating growth of existing companies. While the land use allocations of the Plan focus on industrial type employment other sectors will also be important in job growth – for example tourism, leisure and hospitality sectors. The RLDP will set out the policy framework to support appropriate economic growth in all sectors. Preferred Growth with additional focus on affordable housing Growth Option 3 already incorporates an element of growth to specifically address affordable housing . Option 2 with additional growth for affordable housing (referred levels in the County. A specific policy-led affordable housing element has been added to all the growth to as Option 2.5) is preferred. options, including Growth Option 3. These additional dwellings will be delivered on sites comprising at least 50% affordable housing and will meet 10% of the total affordable housing need within the County (identified by Monmouthshire’s Local Housing Market Assessment 2020). However, as Growth Option 3 only requires approximately 110 new homes on new site allocations until 2033 it offers few opportunities to deliver any new affordable housing in addition to those already agreed as part of the existing commitments. Retirement Village Focus Growth Option 3 results in a housing requirement of 4,770 new homes for the period 2018-2033. . This rate of growth is preferred but it should focus on providing Allowing for existing commitments and windfall allowances, this option would require an additional for the ageing demographic through the identification of 110 new dwellings over the Plan period, allowing for limited opportunities to promote retirement retirement villages. villages. RLDP Objective Assessment The assessment of Growth Option 3 against the RLDP objectives highlight a red score in relation to . The red scores against option 3 in the assessment against the Objective 9 - Demography, Objective 13 - Rural Communities and Objective 14 – Infrastructure, RLDP objectives do not fairly reflect the situation. indicating unlikely to achieve the objective. Given the level of growth associated with Growth Option 3 and the resultant unbalanced demographic and the need for approximately 110 new homes on new allocations until 2033 this is considered to be a fair assessment. No. of respondents Details of how Growth Option 4: Dwelling-led Average will Council’s Response Recommendation with a preference for address the issues/challenges of Monmouthshire Growth Option 4 2 respondents Lower Demand due to Brexit and Lower Economic Growth It is acknowledged that Brexit has created a degree of uncertainty as well as the Covid-19 pandemic. In view of the negative impacts preferred option 4 . This level of growth would be more appropriate given the lower The uncertainty in the market at present highlights the need for any planning for employment land to associated with this growth demand expected due to Brexit and lower economic growth. provide a flexible policy framework to adapt to change. Welsh Government’s Building Better Places option and its poor policy response to placemaking and the Covid-19 recovery also recognises the significant role planning performance against the RLDP and Local Development Plans play in facilitating economic recovery post Covid-19, the principles of objectives and identified ISA which are equally considered to apply to Brexit. themes, it is not considered Combination of Growth Option 4 for Homes and 5 for Jobs The link between homes and jobs are considered when undertaking the demographic modelling for the prudent to take this option . This rate of housing/population growth is preferred but with the different scenarios and are interrelated reflecting the level of working age population present. The forward. Further details are set job level of option 5. level of housing and job growth associated with Growth Option 4 would fail to address the Council’s 16

Monmouthshire Replacement Local Development Plan Growth and Spatial Options Report of Consultation (June 2021) strategic ambitions from both an economic and social perspective and conflict with the proposed key out in the Growth and Spatial elements of the RLDP objectives and ISA themes relating to the economy and employment, population Options Background Paper. and communities, health and wellbeing and equalities. As a result, it is unlikely to address the demographic and economic challenges that the County faces. No. of respondents Details of how Growth Option 6: Employment-led Projection will Council’s Response Recommendation with a preference for address the issues/challenges of Monmouthshire Growth Option 6 18 respondents Goes further in Addressing the County’s Key Issues It is acknowledged that Growth Option 6 also performs strongly against the RLDP objectives and ISA Informal feedback from Welsh preferred option 6 (14 . Option 6 also performs strongly against the RDLP and ISA themes particularly in relation to population, communities and economy and employment. However, Government officials has of which support objectives. It performs only marginally worse than option 5 in the ISA considers Option 5, by more closely aligning with past delivery rates in the earlier years of the indicated a lack of confidence in option 5 suggest there the assessment of objectives and issues raised can be addressed Plan period, presents a more realistic option. economic-led projections. is scope for higher through the spatial strategy. This option would go further in Whilst the Council has an growth) addressing the County’s demographic imbalance, small working aspiration for economic growth age population and high house prices. and is making progress towards Aligns with Council & CCR Aspirations It is accepted that Growth Option 6 is consistent with Monmouthshire’s priorities for economic growth this goal, there is little certainty . Aligns with the aims and objectives of the Economies of the set out in ‘Monmouthshire’s Economies of the Future Report (2018) and national and regional policies around the effects of the Future Report (2018) and assists with region’s economic growth including ambitions for the Cardiff Capital Region and the Western Powerhouse. While a key objective employment-led scenarios on as part of the Cardiff Capital Region City Deal and investment of the RLDP is to support a thriving, well connected, diverse economy this must be balanced against population/housing growth fund. The removal of the Severn Bridge tolls has also other key objectives and although Option 6 performs strongly against the RLDP objectives and ISA than the demographic and accelerated plans for a ‘Western Gateway’ that aims to themes, the ISA considers Option 5, by more closely aligning with past delivery rates in the earlier years housing-led options. capitalise on the combined potential of south Wales and the of the Plan period, presents a more realistic option. Considering this, the Council west of England. does not propose to use an Aligns with Welsh Government post Covid-19 Policy Comments noted. economic-led scenario as a . Aligns with Welsh Government’s Building Better Places policy basis for the preferred growth document which recognises the planning will play a significant option. role in the Covid-19 recovery. Housing industry is a critical component of the economic bounce back and a key driver of the The Council, does, however, future growth and distribution of population. recognise that this option Recognises Changing Working from Home Patterns Comments noted. It is acknowledged that Growth Option 6 also performs strongly against the RLDP performed strongly against the . Recognises a considerable degree of change to working and objectives and ISA themes particularly in relation to population, communities and economy and RLDP Objectives and ISA commuting patterns due to Covid-19, such as considerable employment. However, the ISA considers Option 5, by more closely aligning with past delivery rates in themes. levels of home working. A lower level of commuting enables the earlier years of the Plan period, presents a more realistic option. The fundamental shift in working residents to stay local and reduce car dependency. practices since the start of Covid-19 pandemic with an increased propensity to work from home/remotely is however recognised and forms a key consideration in relation to Growth Option 5. The Preferred Strategy acknowledges this shift in working practices and expects that this trend will continue over the longer term and in accordance with Welsh Government’s ambition of 30% of the Welsh workforce working from or near home is something that we wish to encourage and enable. This provides residents with the opportunity to both live and work in the County in this new way, providing a flexible approach to achieving this level of job growth, whilst also achieving the Welsh Government and Council’s aim of reducing the need for commuting. This approach will help to reduce congestion, emissions and pollution, improve the work-life balance for employees and employers, support local businesses/services and enable the creation of sustainable vibrant communities. Addresses Under Performance It is acknowledged that overall housing completion rates for the Adopted LDP period are below the . This rate of growth addresses previous under-performance. required level, however, significant progress has been made in recent years with the shortfall steadily declining. This shortfall is largely attributable to the lead in period of the strategic housing sites. However, progress is being made in bringing the LDP allocated sites forward, with six of the seven strategic sites now having planning permission and the submission of an application on the seventh at Vinegar Hill, Undy. This demonstrates that the strategic sites are deliverable and as these sites have gained permission their contribution to total completions has increased and are projected to meet or exceed the annual average requirement over the next 5 years as the remaining sites build out, reducing the shortfall.

Monmouthshire Replacement Local Development Plan Growth and Spatial Options Report of Consultation (June 2021)

Growth Must Fully Reflect In-migration from Bristol The removal of the tolls has been factored into the preferred option. Growth Option 5 adjusts in- . Preferred Strategy needs to fully account for in-migration from migration to take account of migration trends from Bristol and South Gloucestershire over the past 5 Bristol and pressure on housing growth. years. Migration trends from all other areas is based on an 18-year period. By extrapolating the recent migration levels for these two groups over the Plan period gives an indication of likely trends going forward. The approach taken which takes account of a longer period than that since the tolls were removed, is considered to be a more robust approach than the Scenario based on the 2 years since tolls removal, as it is expected that migration levels would not continue at the higher level seen over the past 2 years. Contribute to PWW’s Placemaking Agenda Comments noted. It is acknowledged that Growth Option 6 also performs strongly against the RLDP . Option 6 will help achieve PPW’s Placemaking agenda by objectives and ISA themes particularly in relation to population, communities and economy and creating places people can live, work, travel and play in. It has employment. However, the ISA considers Option 5, by more closely aligning with past delivery rates in the potential to deliver balanced and socially sustainable the earlier years of the Plan period, presents a more realistic option. communities and provide necessary infrastructure improvements. Greater Contribution to Affordable Housing Targets It is accepted that Growth Option 6 provides greater opportunities to secure higher levels of affordable . This level of growth has a better chance of achieving affordable housing, however there is greater ambiguity around the effects of employment-led scenarios due to housing targets identified by Welsh Government. uncertainty associated with economic forecasts.

Monmouthshire Replacement Local Development Plan Growth and Spatial Options Report of Consultation (June 2021) 3. Spatial Options Report of Consultation

Spatial Option 2 (Distribute Growth Proportionately across the County’s most Sustainable Settlements) is our preferred option. Do you agree with our preferred growth option? Please explain why and provide your reasons. Number of responses Reasons for supporting Spatial Option 2 Council’s Response Recommendation supporting Spatial Option 2 46 respondents Addresses Key Challenges and Issues It is agreed that Spatial Option 2 best addresses the key challenges and issues set out in Spatial Option 2 remains the support preferred . Allows for an increase in both market and affordable housing provision, job the RLDP. It is considered that this spatial option provides a land use framework that Preferred Spatial Option. This Spatial Option 2. growth and assisting in a more balanced population. will help to deliver the Council’s core purpose of helping to build sustainable and option will enable the provision . Recognises removal of Severn Bridge Tolls is likely to have had local impact. resilient communities for current and future generations and is considered to be the of a sufficient range and choice . Proportionate growth will help address challenges faced. most conducive to achieving the RLDP vision. Fundamentally, this option will enable of homes, both market and . Seeks to provide a range of housing to meet all needs, improve the balance of the provision of a sufficient range and choice of homes, both market and affordable to affordable to be provided age profile including through retention of the younger and working age be provided throughout the County’s most sustainable settlements, the need for which throughout the County’s most population. has been heightened by the current pandemic. This option will also assist in ensuring sustainable settlements. This . Scores well against the 17 RLDP objectives. our communities are balanced and socially sustainable, particularly in terms of option will also assist in . Acknowledges challenges Monmouthshire faces in delivering growth but sets demography, which is a key RLDP objective and the importance of which has been ensuring our communities are out a logical principle for delivering it in a sustainable manner by focussing on clearly demonstrated during the current pandemic. Likewise, employment growth will balanced and socially existing settlements. be directed to sustainable locations across the County, which will assist in reducing the sustainable, particularly in . Support the need to ensure provision of a range and choice of homes, this need to travel /levels of out-commuting, and promoting self-contained communities. It terms of demography. Both of should include provision of suitable homes for the elderly where care can be is also recognised that in light of the Covid-19 pandemic there has been an increase in which is are key RLDP provided. remote and home working, which is likely to continue over the longer term and further objectives and the importance . Scores well in regard to equalities as it seeks to support and sustain a reduce commuting levels over the Plan period. Appropriately located growth will of which has been heightened hierarchy of vibrant centres across the County. increase the customer base and workforce, supporting local facilities, businesses and by the Covid-19 pandemic. . Vital that a balance of housing is delivered in rural locations as well as towns, services. The increased reliance on access to local facilities and services during the including affordable housing, will help sustain other facilities including local current pandemic has highlighted their importance to our communities. Employment growth will be schools. directed to sustainable . A more balanced demography will assist in maintaining social infrastructure locations across the County, and future vitality of settlements. which will assist in reducing the . Will assist in sustaining existing services and facilities while securing new need to travel /levels of out- facilities where they do not currently exist. commuting, and promoting Proportionate Growth Comments noted, this option would provide proportionate growth in the most self-contained communities. . Reasonable to distribute growth proportionately given main towns have sustainable urban and rural areas, in accordance with the Sustainable Settlement There has been a fundamental exceeded their growth capacity and growth in some areas is limited due to Appraisal. The level of growth will be proportionate to the settlement’s size and shift in working practices since landscape impact. amenities, affordable housing need as identified in the Local Housing Market the start of the Covid-19 . Need to ensure sufficient land is allocated. Assessment (LHMA), the capacity for growth and/or need for development to sustain pandemic with an increased . Allows most flexibility, avoids missing good opportunities for growth without the community. propensity to work from overloading existing growth areas. home/remotely which is . Focuses growth on a fair and equitable basis across most sustainable This option will enable the provision of a sufficient range and choice of homes, both expected to continue over the settlements. market and affordable to be provided throughout the County’s most sustainable longer term. This provides . Can contribute to addressing lack of supply challenge. settlements, including in rural areas where growth has been limited previously. residents with the opportunity . Based on need and potential to accommodate growth rather than being Employment growth will also be directed to sustainable locations across the County to both live and work in the based on existing settlement size. which will assist in reducing the need to travel /levels of out-commuting, and County in this new way, . Allows for development in the centre and north of the County where house promoting self-contained communities. There has been a fundamental shift in working providing a flexible approach to prices have risen the fastest. practices since the start of the Covid-19 pandemic with an increased propensity to work achieving this level of job . Housing need will be achieved across the whole of the County including rural from home/remotely which is expected to continue over the longer term. This provides growth, whilst also achieving areas. residents with the opportunity to both live and work in the County in this new way, the Welsh Government and . Welcome the recognition that the level of growth should be based on more providing a flexible approach to achieving this level of job growth, whilst also achieving Council’s aim of reducing the than just settlement size. the Welsh Government and Council’s aim of reducing the need for commuting. This will need for commuting. This will . Proportionate growth serves the whole of the community. help to reduce congestion, emissions and pollution, improve the work-life balance for help to reduce congestion, . Distribution of growth around existing settlements will help support employees and employers, support local businesses/services and enable the creation of emissions and pollution, sustainable growth and is in accordance with Monmouthshire’s four sustainable vibrant communities. This option would best meet the needs of and improve the work-life balance identified objectives in the Well-being Plan. support both the urban and rural communities of Monmouthshire. for employees and employers,

Monmouthshire Replacement Local Development Plan Growth and Spatial Options Report of Consultation (June 2021)

Sustainable Settlements A Sustainable Settlements Appraisal is being prepared as part of the evidence base to support local . Consideration will need to be given to most sustainable settlements as a support the RLDP. The purpose is to identify those settlements that are potentially businesses/services and enable result of changing factors, type and size may change due to impact of COVID- suitable to accommodate future growth in terms of their location, role and function. This the creation of sustainable 19. paper provides valuable information to establish a settlement hierarchy to indicate a vibrant communities. . Delivery of growth in most sustainable settlements can reduce the need to settlement’s potential for accommodating development, and, the hierarchy in relation travel. to other settlements in Monmouthshire. The capacity of a settlement nevertheless Overall, Spatial Option 2 is . Secondary and Rural Settlements will play a key role in delivering housing depends on a wide range of other factors, such as impact on the character of the considered to be the most throughout the plan period. settlement along with consideration of its environmental, physical and policy constraints conducive to achieving the . Recognises the key role Primary Settlements play in providing housing, and its location in relation to other settlements. All of the settlements will be assessed in RLDP vision and the Council’s employment, retail and community facilities. core purpose of building the same way, for example, constraints such as flood risk will be considered for all . Support inclusion of Llanfoist as part of Abergavenny given the synergies and sustainable and resilient settlements. The proximity to other settlements which may have a better offer of interrelationship between both areas. communities across facilities will also be assessed for all settlements regardless of their current status in the . Number and quantity of new homes in settlements should reflect the Monmouthshire. sustainable settlement hierarchy. Adopted LDP. . Severnside is very sustainable in terms of accessibility and distribution of growth should reflect this. The Sustainable Settlements Appraisal (SSA) is published alongside the Preferred . Capacity of growth in Secondary Settlements should vary to take account of Strategy. constraints such as flood risk. . Settlement hierarchy must ensure rural settlements are considered in same way as Severnside settlements as many Severnside settlements are only modestly served by facilities. . Employment growth in sustainable locations would assist in reducing the need to travel, reduce out-commuting and promote self-contained communities. Affordable Housing Comments noted. The provision of affordable housing is a key priority for the Council . Affordable Housing would be spread across the County improving access to it and the RLDP. The need for appropriate, affordable and accessible housing across the in areas where there is little or no affordable housing available currently. County, in both urban and rural areas is highlighted in Objective 10 of the RLDP. It is . Will provide affordable housing to allow young people to stay in their villages. recognised that the provision of affordable housing can assist in building sustainable balanced communities. The current pandemic has emphasised the need to ensure the provision of a range and choice of homes in future housing developments to help address the County’s affordability issues. Infrastructure Proportionate Growth in the most sustainable settlements will allow existing . Ensures areas such as Chepstow are not overly developed without the infrastructure to be utilised, particularly in the Primary and Severnside Settlements. necessary infrastructure. Additional development will generate opportunities to both provide new infrastructure . Recognises the significant physical constraints which limit the amount of and enhance the existing within settlements across the County. The Covid-19 pandemic development that can take place in Main Towns. has highlighted the importance of the provision of digital infrastructure and active . Welcome cooperation with neighbouring authorities on infrastructure travel options to support and enable increased home/remote working and support local provision including active travel, schools and health care. communities. . Support preferred option but need to ensure additional infrastructure is provided to support developments as has not always been in the past. It is acknowledged that there is a perception that additional infrastructure has not been . A good public transport network is essential. provided to support developments in the past. Detailed policies will be prepared for . In accordance with PPW which states development should be located so that site allocations and will establish infrastructure requirements within the policies. An it can be well serviced by existing or planned infrastructure. infrastructure Plan will be prepared as part of the evidence base to support site . Would put less pressure on road traffic due to good public transport links. allocations in the Deposit Plan. . Larger water infrastructure is generally located in the more urbanised Primary and Severnside areas where there are fewer capacity restrictions. Currently It is accepted that there are difficulties in some areas in relation to capacity of existing public sewerage capacity issues in Monmouth, however, work will be infrastructure, any such issues will need to be addressed to enable further growth completed by 31st October 2022 and should be able to accommodate within these settlements. The update on public sewerage capacity issues in Monmouth anticipated growth of the RLDP. is welcomed, the completion of work by 31st October 2022 will help ensure that any further growth in this area is not restricted due to public sewerage capacity issues.

Monmouthshire Replacement Local Development Plan Growth and Spatial Options Report of Consultation (June 2021) National Policy Future Wales: The National Plan 2040 was published following consultation on the . Best fit with wider Welsh Government Policy aspirations. Growth and Spatial Options along with an updated version of Planning Policy Wales . Reflects requirements of Planning Policy Wales and Future Wales: the (Edition 11). It is considered that Spatial Option 2 is in general conformity with PPW11, National Plan 2040. Future Wales and the Well-being of Future Generations Act. . Is in accordance with PPW which states development should be located so that it can be well serviced by existing or planned infrastructure. Future Wales 2040 (Policy 34) requires the South East Wales Strategic Development Plan . Is in accordance with the Well-being of Future Generations Act. to identify a Green Belt to the north of Cardiff, Newport and the eastern part of the . Greenbelt – must ensure this is properly addressed in distribution of growth region to manage urban form and growth. The South East Wales Regional Strategic across Monmouthshire. Diagram set out in Future Wales indicates the indicative extent of the Green Belt in the region which includes part of rural Monmouthshire. The Spatial Strategy has regard to Policy 34 and the indicative Green Belt boundary. Monmouthshire’s five towns fall outside of the indicative Green Belt boundary and national planning policy allows for extensions to existing settlements within and adjoining the Green Belt of an appropriate scale having regard to the identified and longer term need for development land, the effects of development pressures in areas beyond the Green Belt, the need to minimise demand for travel, and the purpose of the overall greenbelt designation. PPW11 states that this may require land to be safeguarded and boundaries of proposed Green Belts must be carefully defined to achieve this.

Viability & Deliverability Agree, sites included in the RLDP must be proven to be both financially viable and . Focus should be on allocating deliverable and viable sites In sustainable deliverable in order for them to pass the test of soundness and to address the RLDP locations. issues and objectives. Climate Change Comment noted, while a ban on the sale of diesel and petrol cars will be in place from . The inclusion of housing in rural areas will not add to climate change 2030 it will take a number of years for the existing stock of cars to be completely following the ban of sale of new petrol and diesel cars, having a car and how phased out as not everyone will be able to afford an electric car. far it travels previously seen as an obstacle but will no longer be relevant post 2030 once other cars are phased out. Adjustments to Spatial Strategy Comment noted, as noted above in response to comments relating to Sustainable . Given the requirement for a Greenbelt in the South of the County Settlements the capacity of a settlement will depend on a wide range of factors, such as proportionate development should be weighted in favour of the North of the impact on the character of the settlement along with consideration of its environmental, County. physical and policy constraints and its location in relation to other settlements. Future Wales 2040 (Policy 34) requires the South East Wales Strategic Development Plan to identify a Green Belt to the north of Cardiff, Newport and the eastern part of the region to manage urban form and growth. The South East Wales Regional Strategic Diagram set out in Future Wales indicates the indicative extent of the Green Belt in the region which includes part of rural Monmouthshire. The Spatial Strategy has regard to Policy 34 and the indicative Green Belt boundary. Monmouthshire’s five towns fall outside of the indicative Green Belt boundary and national planning policy allows for extensions to existing settlements within and adjoining the Green Belt of an appropriate scale having regard to the identified and longer term need for development land, the effects of development pressures in areas beyond the Green Belt, the need to minimise demand for travel, and the purpose of the overall greenbelt designation. PPW11 states that this may require land to be safeguarded and boundaries of proposed Green Belts must be carefully defined to achieve this. Number of responses Reasons for Objecting to Spatial Option 2 Council’s Response Recommendation objecting to Spatial Option 2 30 respondents object Spatial Distribution Comments noted. This option would provide proportionate growth in the most Spatial Option 2 remains the to preferred Spatial . Will result in more focus on Main Towns as small sites will unlikely be sustainable urban and rural areas, in accordance with the Sustainable Settlement Preferred Spatial Option. This Option 2. developed. Appraisal. The level of growth will be proportionate to the settlement’s size and option will enable the provision . Increases proportion of residents in the South of the County and so fails to amenities, affordable housing need as identified in the Local Housing Market of a sufficient range and choice address problems of residents in more isolated locations. Assessment (LHMA), the capacity for growth and/or need for development to sustain of homes, both market and . Provides less flexibility than Spatial Option 1. the community. While the existing Main Towns are considered to be the most affordable to be provided 21

Monmouthshire Replacement Local Development Plan Growth and Spatial Options Report of Consultation (June 2021)

. Support general approach however will not address key issues on its own. sustainable settlements and will therefore take more growth proportionately, growth throughout the County’s most Should be complemented by a sustainable new settlement to achieve this. will be distributed across the County’s most sustainable settlements including sustainable settlements. This . Concentrates development in Main Towns rather than rural villages that have sustainable rural settlements throughout the County. option will also assist in sustainability issues, they would not benefit. ensuring our communities are . Abergavenny should not take proportion of development associated with a There is no evidence that smaller sites will not be delivered. A range and mix of sites balanced and socially Primary Settlement to ensure development does not adversely affect the will be provided throughout the County’s most sustainable settlements, including in sustainable, particularly in BBNP. rural areas where growth has been limited previously. This option would best meet the terms of demography. Both of . Severnside should have an appropriate level of development. needs of and support both the urban and rural communities of Monmouthshire which is are key RLDP . Chepstow and most sustainable settlements close to Chepstow should be objectives and the importance excluded because there are sufficient development opportunities close by in It is considered that the Preferred Spatial Option actually provides more flexibility than of which has been heightened Gloucestershire. Spatial Option 1 as it provides for a wider spread of development due to proposed by the current pandemic. . Spatial Option 2 is not compatible with Growth Option 5 due to in-migration, proportionate growth across the County’s most sustainable settlements. Employment growth will be focus for growth should be in the South of the County. directed to sustainable . Housing growth should be focussed on areas where there is easy access to Regarding locational factors, the capacity of a settlement depends on a wide range of locations across the County, employment such as Bristol, Newport, Cardiff and the M4 Corridor. factors, such as impact on the character of the settlement along with consideration of which will assist in reducing the its environmental, physical and policy constraints and its location in relation to other need to travel /levels of out- settlements, the proximity to the BBNP for example will be taken into consideration but commuting, and promoting balanced against other competing factors. The notion that Chepstow and nearby areas self-contained communities. should be excluded due to development opportunities nearby in the Forest of Dean/Gloucestershire cannot be entertained, Monmouthshire has its own level of Overall, Spatial Option 2 is housing need that must be satisfied. Growth in other Local Authority areas does not considered to be the most meet our housing need/targets and will not help to deliver the Council’s core purpose conducive to achieving the of helping to build sustainable and resilient communities for current and future RLDP vision and the Council’s generations. We do nonetheless liaise with neighbouring local authorities on such core purpose of building matters. sustainable and resilient Future Wales: 2040 Conformity Issues Future Wales: The National Plan 2040 was published following consultation on the communities across . Contrary to Future Wales: 2040 desire for green spaces and avoidance of Growth and Spatial Options along with an updated version of Planning Policy Wales Monmouthshire. ribbon development along M4 corridor. (Edition 11). It is considered that Spatial Option 2 is in general conformity with Policy 1 . Future Wales direction of growth to Newport, Cardiff and the Valleys. of Future Wales: The National Plan 2040 which supports sustainable growth in all parts . Need to identify a green belt. of Wales that seeks to address local aspirations and need. The Self-Assessment of the Preferred Strategy against the Tests of Soundness includes an assessment in the Appendix which demonstrates the Preferred Strategy is in general conformity with Future Wales. While the National Growth Area for the South East Region identifies Cardiff, Newport and the Valleys as the main focus for growth and investment in the South East region, Policies 4 and 5 specifically relate to supporting Rural Communities and Supporting the Rural Economy respectively. Policy 4 notes that ‘policies should consider how age balanced communities can be achieved, where depopulation should be reversed and consider the role of new affordable and market housing, employment opportunities, local services and greater mobility in tackling these challenges’. This is in line with the Council’s core purpose of helping to build sustainable and resilient communities for current and future generations.

Future Wales 2040 (Policy 34) requires the South East Wales Strategic Development Plan to identify a Green Belt to the north of Cardiff, Newport and the eastern part of the region to manage urban form and growth. The South East Wales Regional Strategic Diagram set out in Future Wales indicates the indicative extent of the Green Belt in the region which includes part of rural Monmouthshire. The Spatial Strategy has regard to Policy 34 and the indicative Green Belt boundary. Monmouthshire’s five towns fall outside of the indicative Green Belt boundary and national planning policy allows for extensions to existing settlements within and adjoining the Green Belt of an appropriate scale having regard to the identified and longer term need for development land, the effects of development pressures in areas beyond the Green Belt, the need to minimise 22

Monmouthshire Replacement Local Development Plan Growth and Spatial Options Report of Consultation (June 2021) demand for travel, and the purpose of the overall greenbelt designation. PPW11 states that this may require land to be safeguarded and boundaries of proposed Green Belts must be carefully defined to achieve this. Climate Change Impact The Climate Emergency is essential to the current agenda and is recognised accordingly . Development in towns such as Monmouth will exacerbate climate emergency as a key issue of the RLDP (Issue 38). Climate Change is also a standalone objective that due to commuting levels out of Monmouthshire. the RLDP will seek to address (Objective 17). Housing and employment growth will be . Takes insufficient account of climate change, will increase outward directed to sustainable locations across the County, which will assist in reducing the commuting due to lack of opportunities in existing centres which also has a need to travel /levels of out-commuting, and promote self-contained communities. It is resultant impact on climate change. also recognised that in light of the Covid-19 pandemic there has been an increase in remote and home working, which is likely to continue over the longer term and further reduce commuting levels over the Plan period. Appropriately located growth will increase the customer base and workforce, supporting local facilities, businesses and services. The increased reliance on access to local facilities and services during the current pandemic has highlighted their importance to our communities. Biodiversity, Landscape Impact and Tourism Impact The capacity of a settlement for growth depends on a wide range of factors, such as . Potential landscape impact on visually sensitive areas in close proximity to impact on the character of the settlement along with consideration of its Brecon Beacons National Park Boundary. environmental, physical and policy constraints and its location in relation to other . Importance and character of Main Towns is underestimated, settlements, the character of existing settlements and proximity to the BBNP will be overdevelopment would reduce attraction for tourism, particularly adjacent taken into consideration but balanced against other competing factors. Tourism is a key to the Brecon Beacons National Park. sector in the economy of Monmouthshire, the RLDP seeks to maximise benefits for the . Green wedge review should be undertaken before spatial option is economy and tourism accordingly. determined. . Reservations about proportionate growth, bulk of housing will fall on Main The Green wedge review will be undertaken to inform the Deposit Plan. Green Wedges Towns impacting on character. will be designated as part of a detailed Development Management Policy. It is not in . Does not consider current land use or Best and Most Versatile Agricultural the scope of either the Growth and Spatial Options or the Preferred Strategy for this Land. work to be undertaken at this stage.

Objective 6 of the RLDP recognises the need to promote the efficient use of land including; the need to maximise opportunities for development of previously development land, whilst recognising that brownfield opportunities are limited in Monmouthshire, and, protect the Best and Most Versatile (BMV) agricultural land, whilst at the same time recognising that this will not always be possible given the high proportion of BMV land in the County and the limited opportunities for brownfield development. The Preferred Option recognises the majority of development is likely to be predominately greenfield land. The assessment of Candidate Sites will nevertheless require site promoters to undertake an assessment of any sites considered to be BMV and a search sequence will be undertaken in line with requirements set out in PPW Edition 11. It is, however, recognised that there is a balance and that BMV land can be developed if there is an overriding need for development that outweighs the agricultural considerations. Housing While a number of consents are located in and around the Chepstow/Caldicot it is . High volume of housing consents in and around Chepstow/Caldicot and recognised that the majority of those referred to are located in the Forest of environs suggest these areas should be excluded from development. Dean/Gloucestershire, others relate to allocated sites in the LDP. Monmouthshire has . Small sites will not be delivered unless more can be done to support and its own level of housing need that must be satisfied, growth in other Local Authority encourage Small and Medium Size housebuilders (SME’s). The deliverability is areas does not meet our housing need/targets and will not help to deliver the Council’s questionable as relies on a focus on SME’s which is out of the core purpose of helping to build sustainable and resilient communities for current and control/influence of MCC. future generations.

Agree that more needs to be done to support and encourage SME’s in Monmouthshire. The Preferred Spatial Option will enable the provision of a sufficient range and choice of sites, including both market and affordable homes to be provided throughout the County’s most sustainable settlements including in rural areas where growth has been limited previously. The 60/40 allocations in the current LDP have proved successful with 23

Monmouthshire Replacement Local Development Plan Growth and Spatial Options Report of Consultation (June 2021)

a number of sites being completed, none of which have been undertaken by National housebuilders.

Infrastructure Capacity Proportionate Growth in the most sustainable settlements will allow existing . Chepstow should be excluded from this option due to traffic congestion and infrastructure to be utilised, particularly in the Primary and Severnside Settlements. poor air quality particularly as Chepstow bypass and M4 relief road are Additional development will generate opportunities to both provide new infrastructure unlikely to come into fruition in RLDP plan period. and enhance the existing within settlements across the County. The Covid-19 pandemic . Continuation of focussing growth on Main Towns will put additional strain on has highlighted the importance of the provision of digital infrastructure and active infrastructure and associated services. travel options to support and enable increase home/remote working and support local . Will result in less overall development of scale resulting in a missed communities. opportunity to secure substantial infrastructure investment. It is accepted that there are difficulties in some areas in relation to capacity of existing infrastructure, any such issues will need to be addressed to enable further growth within these settlements. An Infrastructure Plan will be prepared as part of the evidence base to support the Deposit Plan and site allocations. Detailed policies will be prepared for site allocations at the Deposit stage and will establish requirements in policy. In the meantime, we will continue to work with relevant infrastructure providers in the preparation of the Plan. Sustainable Settlements A Sustainable Settlements Appraisal is being prepared as part of the evidence base to . Distributes growth to sustainable settlements that haven’t yet been support the RLDP. The purpose is to identify those settlements that are potentially identified. Greater definition of the most sustainable settlements and suitable to accommodate future growth in terms of their location, role and function. This evidence of their capacity for growth is needed. paper provides valuable information to establish a settlement hierarchy to indicate a . While seeks to secure more local affordable housing in rural areas is settlement’s potential for accommodating development, and, the hierarchy in relation questionable in terms of sustainability. to other settlements in Monmouthshire. The capacity of a settlement nevertheless . Should postpone until Covid-19 impact is fully known, risk of villages depends on a wide range of other factors, such as impact on the character of the becoming out of town estates with no facilities or community. settlement along with consideration of its environmental, physical and policy constraints and its location in relation to other settlements. The proximity to other settlements which may have a better offer of facilities will also be assessed for all settlements regardless of their current status in the Adopted LDP. This option will enable the provision of a sufficient range and choice of homes, both market and affordable to be provided throughout the County’s most sustainable settlements, including in rural areas where growth has been limited previously, this will nevertheless only be directed to sustainable rural settlements listed in the sustainable settlement hierarchy.

The Sustainable Settlements Appraisal (SSA) is published alongside the Preferred Strategy.

It is not considered appropriate to postpone progress on the RLDP until the Covid-19 impact is fully known, this could widen the affordability gap further and have more of a long lasting impact on both urban and rural communities. Furthermore, Welsh Government’s Building Better Places policy response to placemaking and the Covid-19 recovery recognises the significant role planning and Local Development Plans play in facilitating economic recovery post Covid-19. Economic Considerations The Preferred Spatial Option would provide growth in sustainable areas that have . Commuting from areas such as Abergavenny and Monmouth should be existing access to facilities/services, active travel links and employment opportunities. discouraged. These settlements have the amenities to reduce the need to travel and in many cases to support 20 minute neighbourhoods. Employment growth will be directed to sustainable locations across the County, which will assist in reducing the need to travel /levels of out-commuting, and promoting self-contained communities. It is also recognised that in light of the Covid-19 pandemic there has been a fundamental shift in working practices with an increase in remote and home working, which is likely to 24

Monmouthshire Replacement Local Development Plan Growth and Spatial Options Report of Consultation (June 2021) continue over the longer term and further reduce commuting levels over the Plan period. Appropriately located growth will increase the customer base and workforce, supporting local facilities, businesses and services. This will help to reduce congestion, emissions and pollution, improve the work-life balance for employees and employers, support local businesses/services and enable the creation of sustainable vibrant communities. Mixed Use Development sites Comment noted. Individual site allocations will be made at the Deposit RLDP, however, . The failure of mixed-use development sites in the current LDP applies to this the Preferred Spatial Option provides the opportunity to create a thriving, well- option. connected and diverse economy. Employment allocations within the RLDP will be aligned with the findings of the Employment Land Review and other Council aspirations to ensure that it is located in the right areas to attract specific sectors/employers. Air Quality The Preferred Spatial Option relates to proportionate growth in the most sustainable . Increase in traffic congestion in the South of the County could impact on air urban and rural areas, in accordance with the Sustainable Settlement Appraisal. The quality affecting health and well-being. Preferred Spatial Option does not therefore focus growth in the South of the County. Climate Change is a standalone objective that the RLDP will seek to address (Objective 17) and seeks to reduce emissions and improve air quality. Objective 8 of the RLDP relates specifically to Health and Well-being, any developments allocated in the RLDP will be encouraged to support healthier lifestyles. Accessibility is also of key importance which is recognised in Objective 15, all new developments will need to fully consider active travel and integrated sustainable transport opportunities.

Likewise, employment growth will be directed to sustainable locations across the County, which will assist in reducing the need to travel /levels of out-commuting, and promoting self-contained communities. It is also recognised that in light of the Covid-19 pandemic there has been a fundamental shift in working practices with an increase in remote and home working, which is likely to continue over the longer term and further reduce commuting levels over the Plan period.

If you have a preference for a different option, please state your preferred option and provide details of how this option addresses the issues/challenges facing Monmouthshire and meeting the RLDP objectives? Number of responses Reasons for supporting Spatial Option 1 Council’s Response Recommendation with a preference for Spatial Option 1 19 respondents Addresses Key Challenges and Issues Comments noted, it is agreed that Spatial Option 1 performs well against both the RLDP It is recognised that Spatial preferred Spatial . Appears most equitable, ensuring some rural communities could be less objectives and the ISA and addresses many of the key challenges and issues facing the Option 1 performs well against Option 1. isolated. County. Preferred Spatial Option 2 will however provide more flexibility than Spatial both the RLDP objectives and . Agree with the advantages identified in the consultation document. Option 1 as it provides a wider spread of development due to proposed proportionate the ISA and addresses many of . Performs strongly against the RLDP objectives and ISA. growth across the County’s most sustainable settlements in both urban and rural areas. the key challenges and issues . Balances conflicting needs of economic development and housing. Individual site allocations will be made at the Deposit RLDP, however, the Preferred facing the County. Preferred . Limiting need to travel and offer of multiple transport modes can help reduce Spatial Option provides the opportunity to create a thriving, well-connected and diverse Spatial Option 2 will provide congestion and emissions, improve air quality and health. economy. Future employment allocations should be aligned with the findings of the more flexibility than Spatial Employment Land Review and other Council aspirations. Option 1 as it provides a wider Sustainable Settlements Comments noted, Spatial Option 1 does focus growth on the Main Towns of spread of development due to . Focuses growth towards the most sustainable settlements Abergavenny, Abergavenny, Chepstow and Monmouth with some development in the Severnside proposed proportionate Chepstow and Monmouth. area and some in the most sustainable rural areas. While it is recognised the existing growth across the County’s . A review of current allocations and appropriate additional sites in other LDP strategy is working well in terms of housing delivery in the County’s Main Towns most sustainable settlements in sustainable settlements should be undertaken, ensuring they can deliver and Severnside, delivery of affordable housing has not been fully achieved in the rural both urban and rural areas. growth with existing access to services/facilities and employment areas. A review of current housing allocations that have not been delivered to date has opportunities to reduce the need to travel. taken place. The landowners of such sites have been contacted in order to determine Whilst the existing strategy is . Housing would be located close to where people work. the reasons for non-delivery and to notify them that sites will not be automatically working well in terms of rolled forward into the RLDP; such sites will be deallocated if it cannot be demonstrated housing delivery in the that the sites can be progressed by Deposit Plan stage. Additional urban capacity work County’s Main Towns and has also been undertaken to determine if there are brownfield sites that could be Severnside, it is recognised that 25

Monmouthshire Replacement Local Development Plan Growth and Spatial Options Report of Consultation (June 2021)

redeveloped within existing settlement boundaries. A Housing Background Paper (June the proposed level of growth in 2021) has been produced as part of the evidence base for the Preferred Strategy, this rural areas has not been fully includes urban potential study findings as part of the Housing Potential Study. achieved and the overall Biodiversity, Landscape Impact and Tourism Impact Comments noted. The existing Spatial Strategy distributes growth around the County delivery of affordable housing . Protects the green belt and green wedge areas to the South of the County. with a particular focus of growth on the Main Towns of Abergavenny, Chepstow and as a result has not been . Will support and enhance natural beauty of the County, promoting leisure, Monmouth with some development in the Severnside area and some in the most sufficient. tourism, restaurant and retail opportunities. sustainable rural areas. Tourism is a key sector of the economy of Monmouthshire, the . Development would be located away from the BBNP and Wye Valley AONB. RLDP seeks to maximise benefits for the economy and tourism accordingly. It is recognised that there is a . Would have less tourism impact as growth would be directed away from need to link housing and tourist areas. Future Wales 2040 (Policy 34) requires the South East Wales Strategic Development Plan employment growth and any to identify a Green Belt to the north of Cardiff, Newport and the eastern part of the future employment allocations region to manage urban form and growth. The South East Wales Regional Strategic will be based on the findings of Diagram set out in Future Wales indicates the indicative extent of the Green Belt in the the Employment Land Review region which includes part of rural Monmouthshire. The Spatial Strategy has regard to and other Council aspirations Policy 34 and the indicative Green Belt boundary. Monmouthshire’s five towns fall outside of the indicative Green Belt boundary and national planning policy allows for It is therefore not considered extensions to existing settlements within and adjoining the Green Belt of an appropriate prudent to take Spatial Option scale having regard to the identified and longer term need for development land, the 1 forward. Further details are effects of development pressures in areas beyond the Green Belt, the need to minimise set out in the Growth and demand for travel, and the purpose of the overall greenbelt designation. PPW11 states Spatial Options Background that this may require land to be safeguarded and boundaries of proposed Green Belts Paper. must be carefully defined to achieve this.

Infrastructure Comment noted. The Preferred Spatial Option does not rule out urban extensions . Would allow for resources to be focused on specific projects rather than which in a Monmouthshire context could be considered to be development of scale. A spreading resources across the whole of the County. new settlement option has, however, been ruled out as an option for the RLDP. The Preferred Spatial Option still provides opportunity for infrastructure investment to be secured that could be utilised on specific projects. An Infrastructure Plan will be prepared as part of the evidence base to support the Deposit Plan and site allocations. Detailed policies will be prepared for site allocations at the Deposit stage and will establish requirements in policy. In the meantime, we will continue to work with relevant infrastructure providers in the preparation of the Plan.

Future Wales: 2040 Conformity Comments noted. Future Wales 2040 (Policy 34) requires the South East Wales Strategic . Most in keeping with national guidance as allows for a green belt north of the Development Plan to identify a Green Belt to the north of Cardiff, Newport and the M4. eastern part of the region to manage urban form and growth. The South East Wales . Supported by Future Wales: 2040 with a town centre first approach. Regional Strategic Diagram set out in Future Wales indicates the indicative extent of the Green Belt in the region which includes part of rural Monmouthshire. The Spatial Strategy has regard to Policy 34 and the indicative Green Belt boundary. Monmouthshire’s five towns fall outside of the indicative Green Belt boundary and national planning policy allows for extensions to existing settlements within and adjoining the Green Belt of an appropriate scale having regard to the identified and longer term need for development land, the effects of development pressures in areas beyond the Green Belt, the need to minimise demand for travel, and the purpose of the overall greenbelt designation. PPW11 states that this may require land to be safeguarded and boundaries of proposed Green Belts must be carefully defined to achieve this.

The RLDP will support the town centre first approach set out in Future Wales relating to significant new commercial, retail, education, health, leisure and public service facilities. Any such proposals will be considered as the RLDP progresses.

Monmouthshire Replacement Local Development Plan Growth and Spatial Options Report of Consultation (June 2021) Number of responses Reasons for supporting Spatial Option 3 Council’s Response Recommendation with a preference for Spatial Option 3 14 respondents Addresses Key Challenges and Issues Comments noted. While Spatial Option 3 provides the potential to link housing and Whilst the focus of growth on preferred Spatial . Would reduce travel to work with lesser impact on the environment. Preserve employment growth due to a choice and range of employment land with good links to the M4 corridor would provide Option 3. character of towns and the nature of communities. the M4 corridor along with rail links via Severn Tunnel Junction and Caldicot it does not an opportunity for building . Offers better opportunity for employment to be located closer to housing and enable any opportunities outside of this area. While it is recognised that in light of the sustainable communities and local transport. Covid-19 pandemic there has been a fundamental shift in working practices with an potential infrastructure increase in remote and home working, this option has potential to exacerbate out- improvements in the South of commuting in other areas and would not assist in improving self-containment of the the County, it would not Primary and Secondary Settlements outside of this area (i.e. Abergavenny/Llanfoist, address market and affordable Chepstow, Monmouth, Usk and Raglan). housing, social or economic needs across all areas of the Spatial Option 3 would not address the key challenges and issues facing the County as a County. It is therefore not whole due to the focus of growth on the M4 corridor. It would impact on both market considered prudent to take this and affordable housing provision across the County as a whole which would in turn Spatial Option forward. Further impact on demography as the younger population would be priced out of the areas details are set out in the away from the M4 corridor due to a lack of affordable housing. It would also have an Growth and Spatial Options impact on the sustainability of existing rural areas as there would be no additional Background Paper. support to help maintain rural facilities nor would there be any rural developments to attract additional rural employment opportunities. Spatial Option 3 could lead to rural isolation. This option would not address the County’s affordability issues or build sustainable and resilient communities throughout Monmouthshire. Future Wales: 2040 Conformity Future Wales: The National Plan 2040 was published following consultation on the . Growth would predominately located in the South of the County which is Growth and Spatial Options along with an updated version of Planning Policy Wales most in line with Future Wales:2040. (Edition 11). It is considered that Spatial Option 2 is in general conformity with Policy 1 of Future Wales: The National Plan 2040 which supports sustainable growth in all parts of Wales that seeks to address local aspirations and need. While the National Growth Area for the South East Region identifies Cardiff, Newport and the Valles as the main focus for growth and investment in the South East region Policies 4 and 5 relate to supporting Rural Communities and Supporting the Rural Economy respectively. Policy 4 notes that ‘policies should consider how age balanced communities can be achieved, where depopulation should be reversed and consider the role of new affordable and market housing, employment opportunities, local services and greater mobility in tackling these challenges’. Spatial Option 3 would contradict Policies 4 and 5 of Future Wales and would conflict with the Council’s core purpose of helping to build sustainable and resilient communities for current and future generations. Climate Change Impact Comment noted. It should not be assumed that all of the Monmouthshire residents . Would minimise CO2 emissions and environmental impact as better meets that work in Cardiff, Newport and Bristol live in the South of the County, this is not the needs of those working in Cardiff, Newport and Bristol. case. A lack of employment opportunities outside the Severnside area would exacerbate out-commuting in other areas within Monmouthshire thereby potentially increasing CO2 emissions elsewhere. It should nevertheless be recognised that in light of Covid-19 there has been an increase in agile and home working, which is likely to continue over the longer term and further reduce commuting levels over the Plan period. Biodiversity, Landscape Impact and Tourism Impact Comment noted. Spatial Option 3 would focus growth in the South of the County, any . Would direct growth away from approach to the Brecon Beacons National development would therefore be located some distance from the Brecon Beacons Park. National Park. However, landscape impact is one of many factors that has be taken into consideration when considering our growth options and must be balanced against other competing factors. Spatial Option 3 would conflict with the Council’s core purpose of helping to build sustainable and resilient communities for current and future generations throughout Monmouthshire.

Monmouthshire Replacement Local Development Plan Growth and Spatial Options Report of Consultation (June 2021)

Infrastructure Capacity Comments noted. It is recognised that Spatial Option 3 would limit any pressure on . Will ensure existing infrastructure is not overburdened. infrastructure to the South of the County in Severnside, in an area with good links to . Focuses growth on M4 corridor. the M4 and other sustainable travel links including by rail at Caldicot and Severn Tunnel . Growth should be weighted towards the M4 corridor due to better access Junction Train Stations. Lack of development outside this area would not generate and infrastructure. sufficient infrastructure improvements and gains in other areas across the County. It . Better prospect of major infrastructure investment in the South of the County would also only provide additional support for facilities in the Severnside area, in line with the Burns Commission Transport Report. additional support for facilities elsewhere will unlikely be achieved.

While the South of the County benefits from direct access to the M4 corridor there are significant transport links elsewhere in Monmouthshire. Abergavenny has strategic links via the Heads of the Valley and wider Cardiff Capital Region via the A465, towards Herefordshire via the A449 and A40 along with rail links to Newport, Cardiff and the North via the Welsh Marches Line. Chepstow has access directly onto the M48 to Bristol or Cardiff as well as good rail links. Monmouth, Raglan and Usk also have good links via the A40/A449 and Penperlleni via the A4042.

The Burns Commission Report recommends a ‘Network of Alternatives’ for South East Wales. While it is noted within the report that the number of stations should be increased between Cardiff and the River Severn from 3 to 9 it does not state where these will go, it is therefore uncertain how many of these stations will be located within Monmouthshire although reference is made to a new station at Magor along with a need for WG support for a new direct access junction from the M48 to the Severn Tunnel Junction. Active travel links and 20-minute neighbourhoods where residents live within 20 minutes walking distance of key everyday services are also of key importance.

Overall, Spatial Option 3 would conflict with the Council’s core purpose of helping to build sustainable and resilient communities for current and future generations throughout Monmouthshire.

Affordable Housing Disagree. Affordable Housing would be provided in the South of the County in the . Would enable more affordable housing with closer proximity to main work Severnside area only and would subsequently not meet housing needs across all sources. housing market areas. This would result in a negative impact on the provision of affordable housing overall, including in areas identified in the Local Housing Market Assessment (LHMA) as having the greatest need. This would in turn impact on demography as the younger population would be priced out of these areas. This option would not address the County’s affordability issues or build sustainable and resilient communities throughout Monmouthshire. Economic Considerations Comment noted, unfortunately this type of policy would be outside the remit of the . Potential retail impact on other centres can be addressed through other RLDP process. policies that encourage increased visitor spend, improved marketing/branding. Number of responses Reasons for supporting Spatial Option 4 Council’s Response Recommendation with a preference for Spatial Option 4 4 respondents Addresses Key Challenges and Issues Comments noted. While Spatial Option 4 would provide opportunity for building Whilst the focus of growth in preferred Spatial . Development in the north of the County has an important role in meeting sustainable communities through the provision of homes and jobs and improve levels the North of the County would Option 4. housing and employment needs, although recognise an exclusive focus on the of self-containment in the North of the County it does not enable any opportunities provide an opportunity for north would not be sustainable. outside of this area. While it is recognised that in light of the Covid-19 pandemic there building sustainable . Will assist in providing employment opportunities and access to market and has been a fundamental shift in working practices with an increase in remote and home communities and potential affordable homes for a wide population. working, this option has potential to exacerbate out-commuting in other areas and infrastructure improvements in . Will reduce out-commuting from the County which occurs predominately in would not assist in improving self-containment in these areas (i.e. Chepstow and the North of the County, it the South of the County. Severnside). would not address market and 28

Monmouthshire Replacement Local Development Plan Growth and Spatial Options Report of Consultation (June 2021) affordable housing, social or Spatial Option 4 would not address the key challenges and issues facing the County as a economic needs across all whole due to the focus of growth in the North of the County. It would impact on both areas of the County. It is market and affordable housing provision across the County as a whole which would in therefore not considered turn impact on demography as the younger population would be priced out of the prudent to take this Spatial areas away from the north of the County due to a lack of affordable housing in the Option forward. Further details other areas. It would also have an impact on the sustainability of existing rural areas are set out in the Growth and outside of the North of the County as there would be no additional support to help Spatial Options Background maintain rural facilities nor would there be any rural developments to attract additional Paper. rural employment opportunities. Spatial Option 4 could lead to rural isolation. This option would not address the County’s affordability issues or build sustainable and resilient communities throughout Monmouthshire. Sustainable Settlements Comments noted, while Spatial Option 4 focusses growth in the North of the County in . Growth should predominately be focussed in the North of the County as the the most sustainable settlements it does not enable opportunities for sustainable most sustainable settlements are in the North. This could be supplemented development in all of the Primary, Secondary and Rural Settlements or Severnside area. by growth in other sustainable settlements. A review of current housing allocations that have not been delivered to date has taken . A review of current allocations and appropriate additional sites in other place. The landowners of such sites have been contacted in order to determine the sustainable settlements should be undertaken, ensuring they can deliver reasons for non-delivery and to notify them that sites will not be automatically rolled growth with existing access to services/facilities and employment forward into the RLDP; such sites will be deallocated if it cannot be demonstrated that opportunities to reduce the need to travel. the sites can be progressed by Deposit Plan stage. Additional urban capacity work has . Raglan should be excluded from this option as it can be seen as a commuting also been undertaken to determine if there are brownfield sites that could be destination to Bristol which will impact traffic levels in Chepstow. redeveloped within existing settlement boundaries. A Housing Background Paper (June 2021) has been produced as part of the evidence base for the Preferred Strategy, this includes urban potential study findings as part of the Housing Potential Study.

The notion that development in Raglan would impact on traffic levels in Chepstow is unfounded. While properties may have been advertised in Bristol there is no evidence to support any increase in traffic impact. In any case Raglan benefits from excellent transport links via the A40/A449, journeys using this route to reach the M4 would be more direct than using rural lanes to reach Bristol via Chepstow. in light of the Covid-19 pandemic there has been a fundamental shift in working practices with an increase in remote and home working, this will act to improve self-sufficiency of Raglan.

Overall, Spatial Option 4 would conflict with the Council’s core purpose of helping to build sustainable and resilient communities for current and future generations throughout Monmouthshire. Affordable Housing Comment noted. Affordable Housing would be provided in the North of the County only . Would enable more affordable housing in the North of the County where and would subsequently not meet housing needs across all housing market areas. This there is greatest need. would result in a negative impact on the provision of affordable housing overall, including in areas identified in the Local Housing Market Assessment (LHMA) as having the greatest need such as Chepstow. This would in turn impact on demography as the younger population would be priced out of these areas. This option would not address the County’s affordability issues or build sustainable and resilient communities throughout Monmouthshire. Infrastructure Capacity Comments noted. It is recognised that Spatial Option 4 would assist in achieving . Utilises the road connections in the North of the County with good links to infrastructure improvements/provision in the North of the County. However, a lack of South and West Wales via the A465 and to England via the A40. development outside this area would not generate sufficient infrastructure . Will take pressure off the M4/M48 corridor. improvements and gains in other areas across the County. It would also only provide . Has infrastructure capacity to sustain development. additional support for facilities in the North of the County, additional support for facilities elsewhere will unlikely be achieved. Active travel links and 20-minute neighbourhoods where residents live within 20 minutes walking distance of key everyday services are of key importance.

Monmouthshire Replacement Local Development Plan Growth and Spatial Options Report of Consultation (June 2021)

Landscape Impact Comment noted, a focus of growth in the North of the County would result in no . Will protect green space and the rural landscape in the South of the County growth being allocated in the South of the County resulting in a lesser impact on and avoid urbanisation of the M4 corridor Chepstow and Severnside in terms of landscape. Air Quality & Traffic Benefits Comment noted, a focus of growth in the North of the County would result in no . Will lessen impact of traffic congestion and air quality in Chepstow. growth being allocated in the South of the County resulting in a lesser impact on Chepstow and Severnside in terms of traffic and air quality. It is accepted that there are difficulties in some areas in relation to capacity of existing infrastructure, any such issues will need to be addressed to enable further growth within these settlements. An Infrastructure Plan will be prepared as part of the evidence base to support the Deposit Plan and site allocations. Detailed policies will be prepared for site allocations at the Deposit stage and will establish requirements in policy. In the meantime, we will continue to work with relevant infrastructure providers in the preparation of the Plan.

Climate Change is however a standalone objective that the RLDP will seek to address (Objective 17) and seeks to reduce emissions and improve air quality. Accessibility is also of key importance which is recognised in Objective 15, all new developments will need to fully consider active travel and integrated sustainable transport opportunities.

Monmouthshire Replacement Local Development Plan Growth and Spatial Options Report of Consultation (June 2021) 4. Summary of other comments not directly related to the Growth and Spatial Options Consultation questions

Number of responses General Comment Council’s Response 69 respondents No comment at this stage Comments noted. submitted . No comments to make but wish to be consulted as the plan progresses. approximately 100 Mineral Reserves In accordance with national policy the RLDP will set out a policy framework to maintain a 10-year general comments . Maintaining a landbank of at least 10 years permitted reserves is a requirement of national land bank of permitted reserves. The safeguarded areas for potential sources of sand and gravel covering a range of policy. The needless sterilisation of safeguarded mineral safeguarded resources is opposed. and crushed rock aggregates will be identified on the Proposals Map accompanying the Deposit Plan issues. Any potential site allocations within a Mineral Safeguarded Area should be accompanied by a in accordance with the National Minerals Resource Maps and the National Aggerates Safeguarding detailed mineral assessment. Maps for Wales. This constraint will be considered as part of the Candidate Site assessment process. Historic Environment Monmouthshire’s heritage and its importance for tourism and culture is recognised in the Issues, . Development of any size and nature may have different impacts on the historic environment, Vision and Objectives Paper. These comments will be considered as part of the Plan preparation both positive and negative. This should be noted as a consideration. process. Infrastructure Requirements An Infrastructure Plan will be prepared as part of the evidence base to support the Deposit Plan and . Dependant on the scale and location of the growth proposed, developer funded hydraulic site allocations. Detailed policies will be prepared for site allocations at the Deposit stage and will modelling assessments of the water and sewerage networks and developer impact establish requirements in policy. In the meantime, we will continue to work with relevant assessments of the Wastewater Treatment Works (WwTW) may be required. A combination of infrastructure providers in the preparation of the Plan. reinforcement works through the Capital Investment Programme and developer contributions via both S106 contributions and the requisition provisions will ensure the growth can be delivered. . National Grid will provide advice and guidance to the Council concerning their networks as policy develops. Coal Mining Legacy Comments noted. . Monmouthshire has been subject to past coal mining which has left a legacy at shallow depth in the area. Consideration will need to be given to coal mining legacy issues when allocating sites. Green Wedges A Green Wedge review will be undertaken as part of the evidence base to inform the Deposit stage . Green wedges should not be eroded. of the Plan process. . Due to the increased pressure in the Severnside region a review of the Green Wedge designations should be reviewed and removed as it fails to serve the purpose of a Green Wedge. . Land to the north of Abergavenny should be protected as a Green Wedge. . Green Wedge review should be undertaken. The Growth Options Consultation Paper makes no reference to this. Green Belt Future Wales: The National Plan 2040 was published following consultation on the Growth and . Policy 34 of Future Wales: The National Plan 2040 places significant doubt over the ability of Spatial Options along with an updated version of Planning Policy Wales (Edition 11). It is considered Monmouthshire to deliver major development across a large area of the south of the County. that Spatial Option 2 is in conformity with PPW11, Future Wales and the Well-being of Future Representor estimates 16 of the 30 settlements within the draft Sustainability Settlement Generations Act. Hierarchy could be under consideration for Green Belt. Future Wales 2040 (Policy 34) requires the South East Wales Strategic Development Plan to identify a Green Belt to the north of Cardiff, Newport and the eastern part of the region to manage urban form and growth. The South East Wales Regional Strategic Diagram set out in Future Wales indicates the indicative extent of the Green Belt in the region which includes part of rural Monmouthshire. The Spatial Strategy has regard to Policy 34 and the indicative Green Belt boundary. Monmouthshire’s five towns fall outside of the indicative Green Belt boundary and national planning policy allows for extensions to existing settlements within and adjoining the Green Belt of an appropriate scale having regard to the identified and longer term need for development land, the effects of development pressures in areas beyond the Green Belt, the need to minimise demand for travel, and the purpose of the overall greenbelt designation. PPW11 states that this may require land to be safeguarded and boundaries of proposed Green Belts must be carefully defined to achieve this (paragraph 3.72). It is however recognised that the boundary of the Green Belt has not yet been established and is proposed instead to be identified through the Strategic Development 31

Monmouthshire Replacement Local Development Plan Growth and Spatial Options Report of Consultation (June 2021)

Plan (SDP) process. Given that the SDP is yet to be commenced Monmouthshire are committed to working with other Local Authorities in the South East Wales region in the development of this work for decision making purposes. Objections to Specific Sites The Growth and Spatial Options Consultation Paper is a strategic, high-level document which . Objection to the consideration of sites bordering the Brecon Beacons National Park, the lower identifies the Council’s preferred growth and spatial options that are considered to best address the slopes of the Sugar Loaf and the Black Mountains. These areas are scenically sensitive and County’s key issues/challenges and meet the RLDP objectives. The Growth and Spatial Options Paper ecologically very valuable. sets out a number of alternative growth and spatial strategy options for the County, informed by a . Objection to further consideration of land at ‘Chapel Fields’ and in the north west of range of evidence and will inform the next key stage of the process, the Preferred Strategy. Options Abergavenny generally. for potential areas of growth in the County’s settlements will be set out in the Preferred Strategy . Objection to Dixton Road site, Monmouth. which will be published for statutory consultation in summer 2021. Individual site allocations will be . Deri Mountain Field, Abergavenny. made at the Deposit stage of the Plan, which is scheduled for publication for statutory consultation . Land at Pentre Lane, Abergavenny. in summer 2022. Highway Improvements The Growth and Spatial Options Consultation Paper is an early stage in the development plan . There has been a 23% increase in traffic in the Chepstow area since the removal of the Severn process, establishing a strategic overview of the overall level of growth and broad distribution of Bridge tolls. The consultation does not discuss any plans to resolve congestion and air that growth. Detailed Transport Assessments and modelling will be undertaken to inform the site pollution in the Chepstow area. There has been debate about a relief road/bypass for selection process for individual allocations, when it is then possible to undertake modelling on Chepstow for many years but this is not addressed in the options report. specific road and rail networks as more details are known on the location of growth. This evidence . Following the Welsh Government’s decision not to support the M4 Relief Road, The Burns will feed into the detailed site allocations made at the Deposit Plan stage which is scheduled to be Commission recommends the provision of 3 new railway stations east of Newport, linked to published for consultation in Summer 2022. the expansions in bus services. One of these is in Magor – surprised that this is not featured in the documentation of the spatial options. An Integrated Planning and Transport Strategy will form part of the evidence base for the Deposit . Questions whether there is intention to make better use of the M48 by providing 2 new Plan and will have to be consistent with the strategies and policies contained in the Local Transport junctions. One to link the M48 to the A48 at Parkwall roundabout and the second to provide Plan, the Wales Transport Strategy and National Transport Finance Plan. better access to the Severn Tunnel Junction. In November 2020 the Council consulted on the Chepstow Transport Plan. This is a cross-border transport study, focussing on Chepstow and its transport connections beyond the immediate region, with consideration for the broader surrounding systems and longer-term resilience issues. The purpose of the stage 2 of study consultation was to examine a shortlist of options, helping to select a preferred option(s) to take forward. The RLDP will consider the findings of the Chepstow Transport Plan as it progresses. RLDP Objectives The review of options against the RLDP objectives is assessed according to its predicted effect on . The conclusions reached in the traffic light assessment against the RLDP objectives are very whether it helps achieve the objective, has neutral impact on the objective or is unlikely to achieve subjective and almost meaningless at this point in the plan. the objective. The assessment undertaken is considered to be fair, however it is recognised that the . Land Objective for Spatial Option 2 should be amended to green as any opportunities for potential impacts of the different growth rates can be complex with multiple factors to consider. previously developed land would be exhausted through site selection process advocated by The options are also assessed independently through the Integrated Sustainability Appraisal PPW. process. This considers the environmental, equalities, health and well-being impacts of the Plan. . Developers should not be allowed to reduce the amount of affordable housing required. The outcome of this assessment is summarised at Appendix 8 of the Growth and Spatial Options . Climate change and sustainability should be a central consideration. Consultation Paper. . Proximity to train stations should be a key factor in any major development. A detailed policy framework for achieving the RLDP objectives, including rural communities and climate change, will be set out in the Deposit Plan, scheduled for consultation during Summer 2022. It is agreed that sustainability, climate change and the creation of sustainable travel links including active travel should be a key factor in the consideration of locating development. In considering site allocations site promoters will be required to demonstrate that sites are viable, and deliverable based on the affordable housing threshold established either through policy or the viability modelling. This will be a key consideration in the plan preparation process. Affordable Housing Policy-led Element Support welcomed in relation to the affordable housing tenure approach. Consideration will be . Support for the change to mix of affordable housing tenure including social rent, intermediate given to 50:50 sites through the County and in relation to all scales of development. In accordance rent and LCHO. with the Minter for Housing and Local Government’s letter of July 2019 and Policies 3 (Public Sector . 50:50 sites should be pursued across the County, not just the Primary and Severnside Leadership) and 7 (Delivering Affordable Housing) of Future Wales, the use of publicly owned land settlements as previously suggested in the previous Preferred Strategy. Smaller sites have the will be given due consideration, however, all options will be considered.

Monmouthshire Replacement Local Development Plan Growth and Spatial Options Report of Consultation (June 2021) benefit of being able to come forward without significant infrastructure requirements making The Affordable Housing Policy-led element relates to meeting 10% of the affordable housing need more likely that 50% affordable housing will be viable. set out in the Local Housing Market Assessment (2020), not the overall housing requirement set out . If Affordable Housing Policy-led element is pursued publicly owned sites should be considered in the Growth and Spatial Options Consultation Report. It is proposed to meet this need on priority in line with the July 2019 ministerial letter and should be subject to viability affordable housing-led sites where at least 50% of the homes are affordable. considerations. . A total of 1,410 dwellings form part of the Affordable Housing Policy-led element. This accounts for 19% of the housing requirement, not 10% as stated. It is not clear how this has been arrived at. Sustainable Settlement Appraisal As part of the RLDP evidence base an update of the Sustainable Settlement Appraisal has been . Concern that Llanover is not identified as a Main Rural Settlement when Llanellen is, given the undertaken and accompanies the Preferred Strategy. The purpose of this appraisal is to identify similarities between the two settlements. those settlements which are potentially suitable to accommodate future housing and employment . Little Mill occupies a strategic location and should form the focus for growth to compliment growth in terms of their location, role and function. This involves an assessment of the current role Mamhilad in Torfaen and should therefore be recategorised as a Secondary Settlement. and function of settlements, as well as an understanding of the relationship between settlements . Shirenewton should be included as a Secondary Settlement due to the high levels of service and their potential future roles. This settlement appraisal has grouped settlements into different and school provision. tiers based upon their role and function and will thus help to inform the Plan’s settlement hierarchy. . Concern that village identity will be lost as the LDP refers to Main Villages but the RLDP refers However, it should be noted that the results of this assessment will form part of a larger evidence to draft Main Rural Sustainable Settlements. Some Main Villages are removed from Main Rural base and whilst it will give some indication of the relative sustainability of the settlements there are Sustainable Settlements, all of which are located in the North of the County, why aren’t more other criteria that will also need to be taken into consideration. For instance, any decisions on in the North included. whether or not to allocate particular sites for development in the settlements will also depend on such issues as their impact on the physical form of the settlement, landscape setting, agricultural land quality, environmental constraints and infrastructure capacity among other considerations. Well Being and Future Generations Act 2015 The Well Being of Future Generations (Wales) Act (WBFGA) forms an intrinsic part of the RLDP . The WBFG’s commissioner in her first five-year review of the Act published in 2020 expressed process. The links between the RLDP objectives and Well Being Goals (and Local Well-Being Goals) is deep concerns about the under-manning in Planning Departments. clearly set out in the Issues, Vision and Objectives Paper (as amended June 2021). Each Growth and . The RLDP options need to demonstrate and evidence that WBFGA has impacted on strategy. Spatial Option has been assessed against the RLDP objectives, which themselves aim to work towards the seven Well-Being Goals. This exercise will be undertaken at each key stage of the Plan process. The RLDP is also accompanied by an Integrated Sustainability Appraisal (ISA) which considers the environmental, equalities, health and well-being impacts of the Plan and is also founded on the principles of the Well Being Goals. Failure to Deliver Adopted LDP Housing Requirement It is acknowledged that overall housing completion rates for the Adopted LDP period are below the . The Adopted LDP has failed to deliver the required housing in Monmouthshire and failed to required level, however, significant progress has been made in recent years with the shortfall meet a 5-year land supply over the current plan period. steadily declining. This shortfall is largely attributable to the lead in period of the strategic housing sites. However, progress is being made in bringing the LDP allocated sites forward, with six of the seven strategic sites now having planning permission and the submission of an application on the seventh at Vinegar Hill, Undy. This demonstrates that the strategic sites are deliverable and as these sites have gained permission their contribution to total completions has increased and are projected to meet or exceed the annual average requirement over the next 5 years as the remaining sites build out, reducing the shortfall. Promotion of individual sites to meet the growth rate The Growth and Spatial Options Consultation Paper is a strategic, high-level document which . Land at Rockfield Road, Monmouth (CS0076) identifies the Council’s preferred growth and spatial options that are considered to best address the . North of A48, Crick County’s key issues/challenges and meet the RLDP objectives. The Growth and Spatial Options Paper . West of ‘Parklands’, Llandogo sets out a number of alternative growth and spatial strategy options for the County, informed by a . Goods Yard Site, Usk range of evidence and will inform the next key stage of the process, the Preferred Strategy. Options . Land adjacent to Burrium Gate, Usk for potential areas of growth in the County’s settlements will be set out in the Preferred Strategy . Land adjacent to Thistledown Barn, Shirenewton which will be published for statutory consultation in Summer 2021. A second Call for Candidate . Land at Bayfields, Chepstow Sites will run alongside the Preferred Strategy consultation when site promoters will be invited to . Land at Nantgavenny Lane, Abergavenny. submit details of their sites. Individual site allocations will be made at the Deposit stage of the Plan, . Land at Ross Road, Abergavenny which is schedule for publication for statutory consultation in Summer 2022. . Land west of Usk Road, Penperlleni . New settlement at Cwm Pentref . New Settlement at St Brides . Land at Penperlleni . Vinegar Hill Adopted LDP site 33

Monmouthshire Replacement Local Development Plan Growth and Spatial Options Report of Consultation (June 2021)

. Wonastow Road Adopted LDP site . St Lawrence Lane, Chepstow . Coopers and Westgate Llanfoist . Grove Farm, Llanfoist MOD Policy Comments noted. . Highlights specific operational need of MOD establishments, particularly with reference to the base at Caerwent. Suggests policy n MOD establishments for inclusion in the RLDP. Post Brexit Agriculture In accordance with national planning policy guidance the detailed stages of the RLDP will include a . Must prepare for greater self-sufficiency and explore possibilities for non-diary agriculture such policy framework to support rural enterprises and diversification. It is recognised however, that as vineyards. additional policies and interventions will be required to deliver locally specific economic growth . Monmouthshire has 25 County Farms, mostly located in the south of the County. The reflecting the rural nature of Monmouthshire. The RLDP will also sit alongside an Economic repurpose of how they can contribute to the greening of Monmouthshire should be Development Strategy which will set the Council's key mechanisms and actions for attracting considered. businesses to the County and facilitating growth of existing companies. While the land use . A vision of agricultural development, food production and procurement locally should be allocations of the Plan focus on industrial type employment other sectors will also be important in considered for all rural settlements. job growth. The RLDP will set out the policy framework to support appropriate economic growth in all sectors.

Solar Farms In accordance with PPW11 we are developing an evidence base to assess the opportunities for . Within Severnside the powerlines that serve south Wales straddle the edge of the estuary. renewable and low carbon energy in the County. This evidence will help establish spatial policies in Within this area will therefore be some appropriate sites or zones that could feature in the the Deposit Plan which will identify the most appropriate locations for development of energy future planning of Severnside and provision of solar farms. generation, such as solar farms. Neighbouring Authorities The level and spatial distribution of growth associated with Growth Option 5 and Spatial Option 2 is . There is no mention of the Local Plans for Newport. This will require more development to the preferred as it provides a level of growth that would best address Monmouthshire’s key south of the County to support Newport’s plans. issues/challenges and meet the RLDP objectives. Newport City Council commenced a formal review of the Adopted Local Development Plan in October 2020. The first stage in the process is to produce a Review Report and Delivery Agreement, which were subject to consultation during January – March 2021. Welsh Government confirmed its approval of Newport City Council’s Delivery Agreement on the 24th May 2021. At present there is therefore limited detail on the scale of growth proposed for Newport. We will, however, continue to work closely with all our neighbouring authorities and regionally with the south east Wales planning authorities. Display of Spatial Options Comments noted. Further consideration will be given to the clarity of the plans in future stages of . Caldicot should be marked as a green circle, with two yellow circles either side. the Plan process. Housing Upper floors are generally acceptable in principle for a residential use in Town Centres. Affordable . Good availability of commercial property in town centres becoming empty. Could be converted Housing (which includes Registered Social Landlord and Low Cost Home Ownership dwellings) have to social, low cost and private housing, rather than look to acquiring rural land at the edge of specific requirements set by Welsh Government. This includes size guidelines prescribed by towns. Acceptable Cost Guidance (ACG), it is often difficult to meet these requirements retrospectively through conversions. These commercial developments are also generally privately owned with landowners reluctant to convert to affordable dwellings when they could gain market values. Furthermore, any opportunities for conversions in town centres will be included as windfall developments. Local Housing Market Area The Housing Market Areas for Monmouthshire are set out and established as part of the Local . A unique Local Housing Market Area should be considered for the Severnside area to consider Housing Market Assessment (LHMA). The methodology for determining housing market boundaries how it could meet its own unique needs. is set out in Welsh Government Guidance – Local Housing Market Assessment Guide (March 2006) and Getting Started with your Local Housing Market Assessment (Nov 2014). These note that in defining the precise boundaries of housing market areas factors such as patterns of relocation within local areas, travel to work patterns, areas of high and low housing demand and other considerations such as the development plan should be considered. The Severnside area currently forms part of the Chepstow Housing Market Area in the LHMA, which roughly covers the southern half of the County. A review of the Local Housing Market Areas will be undertaken as part of the viability work feeding into the Deposit Plan.

Monmouthshire Replacement Local Development Plan Growth and Spatial Options Report of Consultation (June 2021) Affordable Housing The Adopted Local Development Plan has an Affordable Housing Rural Exceptions Policy (H7) that . Development should be restricted to affordable housing only which should be focussed states favourable consideration will be given to the siting of small affordable housing sites in rural primarily on struggling rural villages and other areas where there is a serious shortage. Primary areas adjoining Rural Secondary Settlements, Main Villages and Minor Villages subject to detailed drivers should be based on local need, availability of public transport, sustainability, landscape criteria. The Council also operates a Build Your Own Affordable Home scheme. Both policies will be and biodiversity. reviewed and considered for inclusion in the RLDP. Development for Affordable Housing in the Open . Small market and affordable housing sites within Minor Villages should be considered along Countryside would be contrary to National Planning Policy Guidance. with windfall growth for affordable housing in Minor Villages and the Open Countryside to pick up on latent unmet need.

New Settlement A new settlement spatial option has been discounted as Welsh Government planning officials . Acceptance that a new settlement cannot be progressed procedurally due to WG advice, deemed this contrary to national policy set out in PPW11 which states new settlements should only however support potential for a new settlement to be reconsidered via an emerging Strategic be proposed as part of a joint LDP, SDP or Future Wales. The Council is committed to being part of Development Plan. the South East Wales Strategic Development Plan and will therefore have an opportunity to . An additional Spatial Option should be considered which combines Spatial Option 2 with a reconsider the potential for a new settlement via that process. sustainable new settlement. Windfall Allowance The Development Plans Manual (Ed 3 – March 2020) sets a requirement to plan for realistic windfall . Windfall allowances are substantial. This does not meet the tests of soundness and does not rates, based on robust evidence of past delivery rates and the small sites register. The contribution promote plan-led housing delivery. Growth should be delivered through new allocations. windfalls and infill sites make to meeting the housing requirement has been reviewed as part of the evidence base for the Preferred Strategy and is set out in the Housing Background Paper (June 2021).