Testun llawn:
Objection re: HG1 KS1: Community Infrastructure
Including Active Travel, Social Cohesion, Environmental Health, Education,
Community Infrastructure
I object to the proposed allocation of Land at North West Barry (HG1 KS1) based on
significant concerns raised by examination of BP37 – Primary, Community &
Intermediate Health Care along with the clear and repeatedly stated risks identified in
the BP3 Rapid Participatory HIA of the Preferred Strategy (2023) and BP3A Rapid
Participatory HIA of the Deposit Plan (2025)
The Deposit RLDP fails to demonstrate that suAicient healthcare infrastructure
(particularly primary and community care) will be delivered in step with growth. Close
reading of BP37 – Primary, Community & Intermediate Health Care shows there is no
identifiable set of mitigations, no delivery programme, no capital plan, and no agreed
actions with CardiA & Vale University Health Board (CAVUHB) to manage or expand
healthcare capacity in response to the growth proposed in the RLDP.
BP37 contains extensive description of pressures, including:
o 24% increase in registered population since 2015 and further growth expected.
o Significant growth in the 65+ population and prevalence of long-term conditions.
o Workforce shortages, premises constraints, dental access issues, mental health
pressures, and long secondary-care waits.
However, nowhere in BP37 is there:
o a list of healthcare infrastructure projects to be delivered
o costs, funding sources, or capital commitments
o timelines or delivery windows
o agreed expansion of GP practices or primary care hubs
o S106 / CIL contribution mechanisms
o phasing triggers tied to housing delivery
o CAVUHB implementation plan
o any actual mitigation measures for the increase in demand
BP37 explicitly highlights cross-boundary pressures, but without solutions. For
example, it acknowledges cross-boundary flows where residents from eastern and
western Vale access healthcare in CardiA or Cwm Taf Morgannwg. It highlights the need
for “continued collaboration” and “capacity planning” across HB boundaries. Yet again
it provides no evidence of joint capacity modelling; agreed service expansion; an
investment plan; any commitment from either CAVUHB or the Council.
It is an assessment document, not a mitigation or delivery document. This is a critical
gap, because the RLDP allocates 7,890 dwellings across the Vale, all of which will
significantly increase demand for primary and community healthcare. Yet BP37
provides no mitigation pathway for any of these settlements. Therefore, how can I have
been properly consulted in this respect?
Because of this, the RLDP risks failing Welsh Government policy tests of soundness:
CE2 — coherence and eAectiveness
CE3 — deliverability
CE4 — consistency with national policy (Planning Policy Wales)
Likewise, taking into account the content of BP3 Rapid Participatory HIA of the Preferred
Strategy (2023) and BP3A Rapid Participatory HIA of the Deposit Plan (2025), both HIAs
raise substantive risks to health, wellbeing, inequalities, and service capacity.
Both HIAs warn that if new development comes forward without simultaneous delivery
of GP, social care, open space and community facilities, significant negative health
impacts occur and car dependency rises.
When applied to North West Barry development (HG1/KS1), this indicates that this site
is an unsuitable, high-risk site - preliminary enquiries indicate that the only local GP
practice within access of North West Barry (Highlight Park) is already oversubscribed
and struggling to deliver the expected level of service for existing residents. The HIAs
repeatedly highlight the danger of early phases of development outpacing healthcare,
social care and community infrastructure capacity.
With particular reference to the North West Barry site, the only specific reference to any
measures to mitigate these serious and significant infrastructure concerns is a vague
statement promising “an oA-site financial contribution towards the provision or
enhancement of community facilities in the area”. Even more concerning, is the
likelihood that this will be delivered after need develops, not before. The Deposit HIA
explicitly flags that increased population without matching capacity can overstretch GP
access and reduce service availability for existing residents.
Furthermore, in light of Persimmon Homes’ documented track record of failure to
deliver legally-agreed S106 funding mitigation measures, this brings the whole inclusion
of North West Barry site in the RLDP into question.
The RLDP allocation is therefore not Sound because the plan does not ensure timely,
certain, or adequate delivery of health-critical infrastructure.
Active Travel / environmental health risks
The HIAs warn that active travel must be safe, direct, and attractive or it will fail. North
West Barry cannot deliver this due to its severance by major roads, and in particular, its
inherent location and topology which places it an arduous uphill 30–40-minute walk
from the nearest train station. No manner of active travel measures can change this
simple fact: it is the wrong location to build 376 houses.
The 2025 HIA states that active travel requires safe, well-lit, continuous, connected,
inclusive routes, and must be designed as the easiest and most attractive option.
The 2023 HIA highlights that behaviour change is extremely diAicult where car
dependence is entrenched or where routes are unsafe or indirect. Yet the NW Barry site
is isolated by the A4226 and relies on the already-heavily-congested and unsafe
Weycock Cross junction.
The HIA findings are:
o Severance by arterial roads undermines walkability.
o Major junctions without transformational redesign deter walking and cycling.
o Active travel routes along high-traAic corridors expose users to air pollution and
noise—both HIA-identified health risks.
The site cannot fulfil the RLDP’s health and transport objectives as required by its own
evidence base.
The HIAs highlight significant concerns about noise, air pollution and cumulative
environmental hazards—conditions that are unavoidable at this site. The Preferred
Strategy HIA identifies traAic noise, air pollution, respiratory impacts and cumulative
noise from heat pumps as major health risks requiring strong mitigation.
In addition, it is worth noting that in none of the three provided TA’s (Strategic Transport
Assessments) contained within the RLDP evidence base is any reference made to any
Air Quality Assessments having been undertaken for or as part of these TA’s.
The Deposit HIA confirms similar concerns and adds that safe, healthy environments
require:
o tree planting to mitigate noise and pollution
o reduced car dominance
o safeguards against environmental degradation.
However, the North West Barry site sits directly on a principal trunk route (A4226),
adjoining Weycock Cross, one of the Vale’s most congested junctions. Exposure to
transport-linked air pollution and noise is therefore inherent and unavoidable, not
mitigable through design alone.
The HIAs demonstrate that the environmental health risks at this location are too great
to justify residential allocation.
Social Cohesion
The HIAs emphasise the importance of social cohesion, community space and safe
public realm, yet the site’s design constraints make this unachievable.
The 2025 HIA warns against “designing out” legitimate social interaction and stresses
the need for community-led, inclusive, intergenerational public spaces. The 2023 HIA
stresses that poorly designed developments can limit social interaction, increase
isolation, and exacerbate inequality. North West Barry is a peripheral, edge-of-town site
with limited permeability and weak natural connections to established
neighbourhoods. The risk of creating a socially disconnected, car-dependent estate is
therefore substantial.
Summary:
The site is structurally incapable of supporting the health-enabling placemaking
envisaged by SP4 or the HIAs.
Development at the North West Barry is incompatible with HIA evidence
Bringing both HIA findings together, the allocation of NW Barry conflicts with:
o Health Inequality Mitigation: The site would place substantial new population
adjacent to some of the Vale’s most health-vulnerable communities without
providing guaranteed uplift in services or infrastructure.
o Environmental Health Requirements: Exposure to air pollution and noise at this
location directly contradicts HIA recommendations.
o Safe and EAective Active Travel: The site cannot deliver the direct, safe,
comfortable active travel networks the HIAs identify as essential.
o Infrastructure Phasing: Healthcare, education and community infrastructure
cannot be guaranteed early enough to prevent negative impacts.
o Social Cohesion: The edge-location and severance barriers undermine the
inclusive, connected, community-supportive placemaking the HIAs require.
Based on the evidence within the Council’s own Health Impact Assessments, the
allocation of Land at North West Barry (HG1 KS1) is neither sound, nor justified, nor
deliverable without causing avoidable and disproportionate harm to public health and
health equity. The allocation HG1 KS1 be removed from the RLDP. It cannot be claimed
that I have been consulted with when a full, site-specific Health Impact Assessment
has not been completed. The current evidence clearly demonstrates the site is not
appropriate.
Education provision
On careful review of BP43 – Education, I can see that the Vale of Glamorgan’s own RLDP
evidence shows that Barry’s schools cannot absorb the demand from the proposed
376-home Weycock Cross development:
Barry Primary Schools:
o The Barry cluster already contains 4,769 pupils across English-medium,
Welsh-medium, CIW, RC and Special streams
o Pressure is already high: several schools show deficits in the Area Data Matrix
(BP43 pp.20–58). Welsh-medium demand is ~19.6% of Barry pupils, way above
average, meaning specialist WM capacity must also grow.
Barry/Regional Secondary Schools:
o Secondary catchment totals 12,107 learners, with nearly 80% in
English-medium and ~11% in Welsh-medium
o The RLDP’s Area Data Matrix shows a secondary deficit of more than 1,000
places under RLDP growth
o No Barry secondary school currently has spare capacity to absorb new demand.
Special & ALN Provision:
o ALN deficits are flagged in red within the Area Data Matrix, meaning no cluster
has adequate ALN capacity
Using the Council’s own multipliers from the Education Cost Table, Weycock Cross
would generate:
o Nursery (0.10 per dwelling) → 38 pupils
o Primary (0.278 per dwelling) → 105 pupils
o Secondary 11–16 (0.208) → 78 pupils
o Post-16 (0.04) → 15 pupils
Language share (based on Barry patterns):
o Primary: ~67 English-medium, ~21 Welsh-medium, remainder faith/ALN.
o Secondary: ~62 English-medium, ~9 Welsh-medium.
These numbers must be accommodated somewhere, but the RLDP does not say where.
The Council’s own costing shows £27,558 per dwelling is needed for education build
costs. For 376 dwellings that’s: £10,361,808 education cost BEFORE land or external
works. The council hasn’t addressed the funding gap - no school expansions, new sites,
or S106 costings have been published for Weycock Cross.
The RLDP and the developer have not provided any detail on:
o where the 105 primary and 78 secondary pupils will go
o which schools will expand (and whether they physically can)
o how Welsh-medium and ALN capacity will be delivered
o how the £10m+ funding requirement will be met
o any phasing that prevents homes being occupied before school places exist.
As per my objections raised separately under Community Infrastructure, the only
specific reference to any measures to mitigate these serious and significant
infrastructure concerns is a vague statement promising “an oA-site financial
contribution towards the provision or enhancement of community facilities in the area”.
Until this information is published, the Weycock Cross allocation is not deliverable, not
compliant, and not justified. This is a soundness failure under planning law -
deliverability, infrastructure capacity, national policy compliance.
Conclusion: How can I be considered to have been consulted on community
infrastructure when there is such a lack of information and transparency in all these key
areas?
