Cyngor Bro Morgannwg
Vale of Glamorgan Council

In order for Policy SP1 to achieve the third test of soundness (Will the plan deliver?), the policy must be updated to accommodate a greater level of housing delivery, that reflects the most up to date evidence. The Development Plans Manual states:

“In terms of considering the level of housing provision for a plan, the most up-to- date suite of Welsh Government Population and Household Projections are a fundamental part of the evidence base [paragraph 5.35]”

Policy SP1 as drafted sets out that the allocation of new [housing] sites will be primarily focused within the Strategic Growth Areas (SGA) identified on the Key Diagram and outside of the SGA, the allocation of sites will be limited to small-scale affordable housing led sites in appropriate Primary and Minor Rural Settlements. In order to meet the true identified housing needs of VoG during the RLDP period, Primary and Minor Rural Settlements will likely need to accommodate further new dwellings than the RLDP currently allocates (please refer to our comments below on Policy SP2 and Policy HG4 for further commentary).

Policy SP1 sets out that the plan will deliver 7,890 dwellings by 2036, including a minimum of 3,070 affordable homes. Policy SP1 also sets out that outside of the Strategic Growth Areas, the allocation of new sites will be limited to small-scale affordable housing led sites.

The number of households in VoG in mid-2021 (i.e. the start of the RLDP period) was 57,676. Based on Welsh Government’s 2022-based household projections, the number of households is projected to increase to 67,299 in VoG in mid-2036 (i.e. the end of the RLDP period). This equates to a household increase of 9,623 which is 22.0% more than the 7,890 dwellings the RLDP targets in Policy SP1. In addition, the Development Plan Manual requires a conversion factor from households to dwellings with 4% being the baseline (it is acknowledged that this will vary depending on local circumstances). Taking a 4% uplift, the dwelling requirement figure would be 10,008 which is 26.8% more than the RLDP seeks to deliver in Policy SP1. The number of overall dwellings identified in Policy SP1 will therefore not meet the identified household growth needs of VoG for the RLDP period. The Council should review the position in terms of the updated household projections.

It is important to note that the above calculations are purely to meet newly arising need and do not make any allowance for existing unmet affordable housing needs or any policy aspirations. As stated in the supporting text of Sustainable Growth Strategy 4 of the RLDP (paragraph 5.23) “The Local Housing Market Assessment (LHMA) 2023 identifies a need for 1,075 affordable homes per annum over the next five years based on principal projections or 1,114 based on the RLDP projections. There is an identified backlog of need across all the sub-market areas in the Vale of Glamorgan, and the issue is acute in many communities.” Policy SP1 seeks to deliver only 3,070 affordable homes over the RLDP period, equating to 205 affordable dwellings per annum. This is only 18.4% of identified need per annum for the five-year period from 2023-2028 in the LHMA. The number of affordable homes identified in Policy SP1 therefore falls drastically short of the identified need for affordable homes in VoG for the RLDP period.