LRM have submitted its response to the above consultation concerning the proposed temporary dis-application of Paragraph 6.2 of TAN1.
The Welsh Government’s National Strategy ‘Prosperity for All’ identifies five priority areas. Housing is referred to in the following terms:
“the bedrock of living well is a good quality, affordable home which brings a wide range of benefits to health, learning and prosperity”
Having regard to this, the defined Well-Being goals and the importance attached to social cohesion, it is irrational for Welsh Government, in the face of endemic failure of the planning system to provide sufficient housing land, to put forward a measure that suggests that increasing the supply of housing land is anything other than important.
In our response we consider firstly whether this proposal it is consistent with the role of the planning system and the policy framework for housing, then to examine what Paragraph 6.2 in fact provides and then to consider the reasons given as justification for its temporary dis-application. In all respects, the
Consultation Document illustrates a lack of understanding as to planning procedure and practice.
It is widely understood that housing delivery in Wales has not meet policy requirements and housing land supply has fallen despite the increased coverage of development plan. In this circumstance planning policy rightly allows for proposals to be brought forward for additional housing through the development management process. This is a legitimate and necessary form of development, that has wrongly been characterised as ‘speculative’, implying that they are applications that are submitted without reason or firm evidence.
Where circumstances dictate, including the extent of the shortfall in housing land supply, the prospect of that shortfall being genuinely address through the plan-led system, the suitability of the site and the benefits of the proposed development, then the principle of granting planning permission for such development proposals is justified.
Regrettably, the proposals in the consultation document run counter to this and will serve only to worsen housing supply in the short and medium term without any corresponding and realistic prospect of the LDP process remedying this.
The reasons given for proposing this measure are without merit or evidenced justification and we disagree with the measure proposed in the consultation document.
Without prejudice to this position, if Welsh Government proceed with an amendment to TAN1 it should be based on an alternative form of wording for Paragraph 6.2 that would continue to record the fact that housing land supply is a material consideration but allows for a distinction to be drawn in the circumstances of individual local authorities. We have proposed such working on page 7 of our response.