Cyngor Bro Morgannwg
Vale of Glamorgan Council

In order for Policy SP1 and SP6, to achieve Test 2 (Is the Plan appropriate?) and Test 3 (Will the Plan deliver?), Policy SP1 and SP6 must be updated to accommodate a greater level of housing delivery based on the most up-to-date evidence.

Policy SP1 also states that: “The primary focus of housing growth within the Vale shall be within the Strategic Growth Area as identified on the Key Diagram. New housing developments will be concentrated in the following locations, which are served by existing public transport routes and provide the opportunity to enhance sustainable transport connectivity:
• Barry
• Penarth
• Llantwit Major
• Cowbridge
• Dinas Powys
• Rhoose
• St Athan
• Llandough
• Sully
Outside of the Strategic Growth Area, the allocation of new sites will be limited to small-scale affordable housing led sites in appropriate primary and Minor Rural Settlements.”

In order to accommodate the additional level of housing growth the VoG needs, both the Strategic Growth Area settlements, and the Primary and Minor Rural Settlements will need to be allocated additional housing sites. Land at Primrose Hill, Cowbridge (Site ID: 455) can assist greatly in accommodating this additional housing need in a sustainable location. The site is adjacent to the higher order Strategic Growth Area settlement of Cowbridge, has limited physical and environmental constraints and is capable of providing up to 220 dwellings at a density of 35 dwellings per hectare.

Policy SP1 sets out that the plan will deliver 7,890 dwellings by 2036, including a minimum of 3,070 affordable homes. Policy SP6 states that: “to meet the identified housing requirement of 7,890 dwellings, provision will be made for the delivery of 8,660 homes in the Plan Period 2021 to 2036. This will be delivered by:
• 3,837 dwellings from the existing land supply
• 3,520 dwellings on allocated sites
• 1,303 dwellings from large and small windfall developments”

The 8,660 provision equates to a flexibility allowance of 9.8% against the targeted delivery of 7,890 set out in Policy SP1. BDWR endorses the incorporation of a flexibility allowance, as is required by paragraph 5.59 of the Development Plans Manual (2020). However, it is considered that the flexibility allowance needs to be increased to a minimum of 15-20% to ensure that the ambitious anticipated annual build rate of between 885-906 dpa from 2027/28 to 2030/31 can be achieved. Whilst we note that the Development Management Manual references a starting point of 10% we note that other local authorities have utilised a higher percentage in draft plans. This includes Swansea (20%) and Monmouthshire (15%).

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 (published in November 2025), 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 for in Policy SP1.

However, the Development Plan Manual (para 5.37) also 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 that the RLDP seeks to deliver in Policy SP1.

It is therefore evident that the housing requirement figure proposed in Policy SP1 is insufficient to meet the newly arising needs of VoG for the RLDP period. Neither does the proposed housing requirement make sufficient allowance for meeting the backlog of unmet affordable housing need.

A fundamental review of the housing requirement figure is required to reflect the most up to date demographic information (i.e. the 2022 household projections) as set out in the Development Plan Manual. The housing requirement figure should also be further adjusted upwards to ensure that existing backlogs of unmet housing need can be addressed and reflect the plans aspirations for economic growth and social inclusion.

Paragraph 5.34 of the Development Plans Manual (2020) states that:

“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 states:

“…All LPAs should use these projections and the resultant household numbers when considering the level of housing provision for a plan period”

Whilst we understand that the latest household projections were not available at the time of drafting the deposit LDP it is clear that these will need to be revisited. We note that the Inspector examining the Cardiff, Monmouthshire and Carmarthenshire LDPs have asked the authorities to review the implications of the data.

As such, it is evident that the housing requirement and the sites identified for development is insufficient to meet the actual housing needs of VoG during the RLDP period.

It is important to note that the above calculations are purely to meet newly arising need and does not make any allowance for existing unmet affordable housing needs. 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. Taking account of the existing unmet need will push the housing requirement even higher.

The number of affordable homes identified in Policy SP1 and Policy SP6 therefore falls drastically short of the actual need for affordable homes in VoG for the RLDP period.