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Perhaps the key element of PPW10 that sets it apart from the previous version is the fact that it has been prepared in the light of the Well-being of Future Generations (Wales) Act 2015 (WFGA), the objectives of which represent the central thread running through the document. The Ministerial Foreword expresses how PPW10 will “deliver the vision of the Wales we want set out in the Well-being of Future Generations Act” and the extent to which “PPW plays a significant contribution to the improvement of well-being in all its aspects.” Whilst this is undeniable, the result is that much of PPW10 is focused on setting the vision for the types of places that the Welsh Government wants to see in Wales, rather than providing detailed guidance for the implementation of this vision. This is a concern as deliverability is a fundamental issue in Wales due to generally lower sales/rental values but higher build costs than across the border in England.
The strong emphasis on local authorities working together to prepare joint LDPs “in most cases”, has been removed from PPW10. The Summary of Consultation Response that was published alongside the new policy refers to a number of respondents having suggested the joint LDP approach to be too rigid. Respondents also expressed their concerns regarding the potential risk that joint LDPs may undermine local democracy and the ability of local authorities to plan for their own areas.
Instead, PPW10 reverts to emphasising the importance of the National Development Framework (NDF) and Strategic Development Plans (SDPs), stating that “the preparation of an SDP allows opportunities and challenges to be considered and planned for in an integrated and comprehensive way, promoting the achievement of positive planning outcomes.” No further details or policies are provided in relation to how the NDF and SDPs are to be prepared.
Reference to collaborative working is also mentioned elsewhere within PPW10. For example, local authorities are encouraged to work together when identifying sites to be allocated for housing in development plans, where the housing market search areas cover more than one authority. There is also an emphasis on collaboration between local authorities and other sectors, including land owners and house builders to assist in development delivery.
It is clear from the above that collaborative working will be important for a variety of sectors going forward, as a way of gaining new perspectives, insights and experience in relation to development deliverability and the achievement of the overarching goals of PPW.
PPW is strong on vision but weak on distinguishing the particular challenges to delivering development in Wales and how policy interventions will assist in addressing these issues. It is recognised that much of the practical detail is being passed onto the LDP manual which is out for consultation at the moment and that these documents will need to be read together.
In our view, as the primary policy statement of Welsh Government, PPW should be stronger on setting out the policy interventions proposed should development fail to come forward. We applaud the focus on place making which is important but ultimately it is only relevant if development is actually happening. There are too many areas of Wales where development is held back by deliverability and viability issues that require active policy intervention.