Dear LDP officer
Today it came to my attention that The vale Council has officially launched the consultation on the Deposit Replacement Local Development Plan (RLDP) which covers the period 2021-2036. Below you will find an extract of one of the numerous documents that have been made available to the public for comment.

(Image taken from the Council's website - 'Overview and Timescale')

Reading the Overview and Timescale I am prompted to make the following comments.
1 The Adoption of the RLDP is set for September 2027. The Plan cannot therefore represent the period 2021 to 2036.
2 I find it difficult to comprehend that this Plan will be relevant for only 9 years after which the tax payers of The Vale will have to fund another RLDP. This can hardly be called planning.
3 It beggars belief that the RLDP is helping to ‘’decide what developments will and will not be permitted at different locations and highlight areas that we need to protect.’’ What on earth does the current LDP do if it does not decide what developments will and will not be permitted at different locations and highlight areas that we need to protect?
Will those development applications which are currently pending, for one reason or another, now be delayed beyond September 2027?

Yours faithfully,

Ian C Davies

It is very very difficult for us, to navigate and comment on potentially 1000's pages of information with only 100 words per paragraph. We will persevere but, using this as an example, we are unclear of what we're commenting on. The paragraph above I assume? The process also assumes access and knowledge of computers an online representations. Older and more vulnerable residents will not have the opportunity to comment this way and will likely therefore to be not represented.

A couple of other concerns are that I live only 500 m from this development site, yet the Vale of Glamorgan chose to include telling me about this development. I had to hear by word of mouth. This is not acceptable.

I believe they should tell not only all residents in Barry, but all residents in the Vale. Telling only the homes that are adjacent to the field is not good enough. This development will have a long negative effect on the quality of life for all in the Vale.

The other issue I tried to utilise the web site to put my objections across and I found that the information was bloated out with rubbish, there is too little facts and too much. This was done to put people of reading. We need information backed up with fact not data and bloat.

When responding we are restricted to very few words, so we have no option but to be concise (One rule for one, another for others). The web site is off putting (maybe deliberately so) I did put my objection, but not convinced it worked at all.

How can councillors who have turned down smaller developments twice on this site before turn coat and vote for it, when the situation has only got worse.

1) On the public consultation: - As Rhoose, St. Athan and Dinas Powys are the affected settlements, the documentation should have been made available in their community run libraries. The council officers present at the public consultation meetings were not well enough briefed to answer the questions raised and could therefore only serve as a sounding board for the frustrations expressed.

2) The proposed development of 520 properties in Readers Way should not be considered in isolation. This development along with the development of 339 properties already approved in Rhoose, on land north of the railway line (east) HG1 (9), plus the proposals for 376 properties at N.W. Barry (KS1) and a further 1132 in St. Athan (KS4 and KS5) totals 2367 new dwellings. This will have a significant impact on the local residents in the pressure it will put upon the existing highway infrastructure and facilities available.

3) The highway infrastructure will be put under further strain due to the need for students to travel to the Cardiff and Vale College currently under construction next to the airport. In addition, the future development of the proposed Energy Park at Aberthaw and ongoing development of the St. Athan Enterprise zone and Cardiff Airport Business Park, along with the potential development at Model Farm will also add to the number of vehicles. Initial construction traffic will be followed by commuting traffic as employees travel to these places of work.

4) The A4226 Port Road forms the main route between St. Athan, Rhoose and Barry. The surrounding country lanes are not capable of absorbing the additional pressure and are not well maintained. Delays which already occur in the vicinity of Waycock Cross roundabout will only become more frequent. Options to improve this junction are clearly limited meaning that it will remain a bottle neck.

5) The proposals rely heavily on the concept of a public transport infrastructure replacing the use of private vehicles and thereby easing the pressure on the highways. This public transport infrastructure is however not in place, with both the train and bus services only operating on an hourly basis. It is clear that there is no guarantee that the train service, which is under the control of Transport for Wales (T.F.W), will be made more frequent in the future. Likewise, the provision of land at St. Athan for a possible new station could end up being a white elephant unless T.F.W. commit to both providing a new station and increasing the frequency of trains. An hourly service acts as a real disincentive to people using public transport as using your own vehicle provides far more flexibility.

6) Active Travel is also being promoted both within the Readers Way development and in the surrounding area. It is clear that the active travel routes both in Rhoose, to Lower Porthkerry and elsewhere, are underutilised. Walking or cycling to places does not fit in with the lives that people are living as time is precious. It is questionable as to how many people will opt to walk or cycle the distance into the centre of the village/town to access the local facilities rather than using their cars to either shop in Rhoose or at the supermarkets in Barry. Many working parentstaking their children to and from school will not have time to make a return journey and neither will people want to be carrying shopping over that distance. As such, further pressure will be put on the only main route through Rhoose ie. Rhoose/ Fontygary Road with on street parking already causing issues especially around school opening and closing times. Ironically this development will provide another route through Rhoose, but with residences all around has been designed to stop it being used as such.

7) It is wrong that Rhoose is expected to have an ever-expanding population without an infrastructure to cater for it. Three branch Doctor surgeries mean that doctor appointments often have to be obtained elsewhere. The library relies on volunteers and fund raising to remain open having had its council funding withdrawn. Rwys Primary will require further expansion to cater for the increase numbers and more pupils will have to take buses to their secondary education elsewhere.

8) Rhoose is hemmed in by the airport and sea and with an expanding quarry encroaching to the west of Fonmon Road. As such the maintenance of its green spaces is important for both the physical and mental wellbeing of its residents. Readers Way as with the other proposed developments are on greenfield sites. If the development goes ahead. the layout of the site should aim to maximise the retention of the existing trees and hedgerows both during and after development. There should be a requirement that any planted trees are maintained and replaced by the developer if they do not survive over a ten-year period. No consideration appears to have been given to planting trees around the edge of the development, which would both reduce its impact on the neighbouring properties and increase the tree cover in an area known for its lack of trees, hence why the group Rhoose Replant have been working to counter this. The public open space should be used to provide biodiversity mitigation and also to enhance it. A wildlife corridor should be provided linking the new public open space with the area around the existing pond and a second pond should be provided to increase the possibility of the newts returning.

9) It is important that plans for the public open space are delivered. The allotments appear to have replaced an earlier proposed community orchard or garden. How would these be managed? No pond is shown. The sports provision appears to consist of three pitches. Who would maintain and use them especially as there is already this provision at Ceri Road along with a club house building. Overall, the plans are unimaginative especially in light of the s106 funding that should be available as a result of the development which could be invested in the area

10) I question why the Vale of Glamorgan Council is choosing this option whilst ruling out developing a new town at Llandow, even though this could be built as fit for purpose. No consideration either seems to have been given to expanding Penarth, Cowbridge or Llantwit Major and other areas of Barry, all of which have the infrastructure to support a growing population. The inhabitants of these places are benefiting from the engagement offered by the placemaking initiative programme. Rhoose is excluded from this and yet is expected to take more than its fair share of housing with little to show for it.

No where near enough time to read through all these documents and this process to object has seemingly been made very difficult and confusing for people who want to object.

Re the planning proposal for waycock cross

Firstly can you feed back to the council that trying to make a representation is actually quite difficult. There really ahould be a big button which makes it obvious where you can submit your views. I spent 10 minutes clicking in circles until I realised what to do and I'm pretty proficient with tech.
Additionally, the number of documents and associated index's is quite off putting. It feels like the council are purposefully putting barriers in the way of people wanting to object. I understand the necessity for transparency but there should be a layman's version for normal people to be able to read through in a reasonable timeframe. I estimate would take a full day to read every word of the associated documents and I know I don't have that sort of time. Thank you for passing my comments on the relevant departments

First, the overall online presentation of the RLDP is utterly chaotic, confusing and way overlong. There is NO clear organization of the material and there are multiple cross-cutting documents making it painful to navigate. Documentary material for the KS1 site, for example, appears in multiple locations, needing the reader to consult other areas of the byzantine site to give meaningful responses. It looks overall like a mass dump of documents, with no regard for readership. Second, it takes NO regard whatever for digital poverty, it is thus discriminatory and offends basic principles of natural justice and fairness.

It would seem that decisions were being taken on the use of sites well before affected residents were even aware of them. The first I heard of the proposed rehash of the development at Weycock Cross (refused in 2015) was in July 2025, when we were invited to a consultation at Millwood Bowling Club. This was more of a show-and-tell than a consultation. No one took down our comments. Didn't they count? The next we heard was that there would be a vote in December to decide whether the NW Barry site should be removed or included. Some members of my family attended and were give three minutes to state their objections. I watched online and say how these objections were summarily dismissed by a planning officer. Then came the vote. Neck and neck, but passed through. Key councillors did not vote. Next was a 'consultation on the RDLP' in Memorial Hall, Barry. Here we were informed of how we could 'have our say' on the proposed developments, by stating our responses to the proposals through an online portal, which would have reports of all the detailed investigations into viability and suitability of their 'mitigation packages' to offset the objections. These would be found in the supporting documents. In order for our responses to be valid, they had to reference these documents. These turned out to be vast in number, packed with confusing and often contradictory details. This was the detail we were told we had to reply to. This process was grossly unfair in that the majority of residents would not have the digital skills to navigate the way through them. This is neither fair nor transparent. Those that were better able to trawl through the huge megabites of scattered and hidden graphs and reports found that the evidence was very thin and far from trustworthy, with many inner contradictions, inaccuracies and false conclusions. From this unreliable and unscientific data 'evidence' had been extrapolated and decisions made. This is neither transparent nor honest.

It is not democratic consultation.

The initial consultation, which focused on higher level strategy, was singularly limited. The large majority of residents in NW Barry were not even aware of any developments. Subsequently, we understand that some who knew of the consultation did register objections. These objections seemed to have been ignored and a "Preferred Strategy" was endorsed by full Counsel. As far far as we can ascertain, ex post facto, there were no site specific technical assessments available. Initial consultation occurred before key technical evidence was available on the sites. In relation to NW Barry, residents were told (in reply to questions) in June/July 2025 to "wait" for details (in a public meeting in Millwood Bowls club). This was the first occasion that we had heard of developments. Vale Planning and Council appear to have made final decisions about sites after this, however the public were not consulted at all. Barry is clearly expected to take substantial growth, but there is no record of targeted community engagement specific to Barry. Heavy reliance was placed on written representations. There was no evidence of community or stakeholder workshops and no co-design sessions. When we attended the in-person consultation event in Barry Memorial Hall in February 2026, there was no one to record our comments, no answers were given any queries and we were constantly told to go and look at the online consultation portal to get information and submit our concerns. The in-person event was simply a "signposting portal" to the online RLDP. There was no meaningful engagement. The public were simply asked to react to a pre-determined sites. Planning's subsequent behaviour has largely been negative and reactive to any suggested changes.

Unnecessary

'The local community are involved in the development of proposals... Proposals are shaped to help to meet these needs as well as create, integrate, protect and/or enhance a sense of community and promote equality. These engagement sessions are considered to assist in fulfilling this Charter'

My experience of these 'engagements' does not match the stated aims. I felt far from 'equal', more an irritation in the way of the council's justification of its intentions. The sheer difficulty of navigating this labrynthine 'consultation' has felt like abuse . I'm over 80. No council should treat its residents this way.

5) Website very hard to access 6) No Welsh language option for Welsh speakers

4) Website- very hard to access no Welsh language options for Welsh speakers

NA

Objection re: RLDP Consultation process
I am raising a general objection to the way in which the consultation process has been
carried out and am basing my comments on personal experience since July 2025 and a
review of the ‘Housing Growth in Barry – Report of Public Consultation’ document. I
believe there are structural weaknesses, omissions, and procedural gaps that
undermine the robustness and inclusivity of the consultation and question its
legitimacy.
In broad terms, the consultation process surrounding the proposed developments
raises significant concerns about accessibility and fairness. The consultation feedback
form was diAicult to locate and use, being hidden via multiple web pages rather than
clearly signposted. The consultation portal itself was poorly designed, being overly
complicated and unnecessarily layered. The sheer volume of documentation across the
site created unnecessary obstacles for residents who wanted to take part. Under the
Town and Country Planning (Local Development Plan) (Wales) Regulations 2005,
planning authorities have a clear duty to ensure that consultation arrangements are
accessible and enable meaningful engagement from the community.
Planning Policy Wales sets out firm expectations that public participation must be
transparent, inclusive, and straightforward, ensuring that all individuals are able to
contribute to the planning process without undue diAiculty.
When consultation tools are poorly designed, or overly complicated or burdensome, as
they were in this consultation, this calls into question the credibility and legitimacy of
the consultation exercise.
Consultation limited to the Preferred Strategy stage (not site-specific consultation)
The consultation undertaken (Dec 2023–Feb 2024) focused on high-level strategy, not
detailed impacts on specific sites such as NE Barry or alternative sites. The report itself
states the exercise was on the Preferred Strategy, which “identifies how much
sustainable growth is needed and where this growth will broadly be located.”
Gap: Residents were not consulted on the detailed implications of individual sites (e.g.,
infrastructure capacity, environmental constraints, transport, drainage), limiting the
ability of the public to make informed representations early in the process.
No evidence of direct engagement with a ected landowners or communities for
the largest site
The report acknowledges major deliverability issues with the largest key site (North East
Barry), including inability to secure landowner agreement across the fragmented
landholdings. “An agreement could not be secured with all relevant landowners.”
Gap: The Council relied on promoters’ claims rather than conducting independent
landowner engagement or reviewing deliverability before public consultation. As a
result, the public were consulted on a strategic option that was later abandoned.
Preferred Strategy proceeded despite strong objections and unresolved issues
There were “objections to each of the key sites” during the public consultation, yet the
Preferred Strategy was endorsed unchanged by Full Council on 30 Sept 2024.
Gap: There is no evidence that objections were meaningfully incorporated before
endorsing the Strategy. This suggests the consultation informed the Council but did not
shape the outcome.
Lack of site-specific technical assessments available at early consultation stage
and at this later stage
Much of the consultation occurred before key technical evidence was available,
including:
o Viability
o Deliverability
o Ownership constraints
o Infrastructure and transport assessments
o Environmental constraints (SSSI proximity, flood risk, etc.)
The report explicitly states that the viability and deliverability of sites (including the
900-unit NE Barry site) were still being assessed after the consultation.
In relation to North West Barry and from mid-July 2025, I requested to speak to Place
Scrutiny Committee and gave my views. At that meeting, and at a subsequent full
council meeting that I observed, residents like me and councillors who were
challenging the Planning Team were told to wait and that detail would be available at the
later consultation stage, via public meetings and the consultation portal. However,
either this detail was not made available because it doesn’t exist or else was it is buried
in thousands of pages of documents that we have been given 6 weeks sift through in
order to find out what is relevant.
Gap: The public were expected to comment without access to essential technical
information, undermining the quality of feedback and the transparency of the process.
This is still the case now, whereby after reading as much of the key information as
possible, there are still huge gaps in basic information that help residents make an
informed decision.
Consultation did not explore alternative growth locations until later
The public was shown only the five original key housing-led sites, even though at least
one (NE Barry) was already facing deliverability challenges. Only after public
consultation did the Council begin considering alternative options.
Gap: The public were not consulted on alternative or fallback options, limiting their
ability to compare spatial choices or suggest more acceptable solutions.
Evidence of restricted consultation scope for the Barry community
The report notes that Barry is expected to take substantial growth but there is no record
of targeted community engagement specific to Barry - the largest and most aAected
settlement.
Gap: No tailored engagement with Barry residents or community groups was
undertaken, despite the disproportionate scale of proposed development for Barry.
Limited clarity on how comments influenced later site selection
Although an “Initial Consultation Report” was prepared, the process described is
top-down:
o Consultation → summary → Preferred Strategy endorsed without change
o Only later did site feasibility issues force adjustments
Gap: A lack of transparency exists regarding how community feedback shaped
decisions. Changes to the strategy arose from landownership/deliverability - not from
public concerns.
Heavy reliance on written representations
My own experience and the Consultation report provided no evidence of:
o community workshops
o stakeholder panels
o co-design sessions
o facilitated deliberation
o youth engagement
o hard-to-reach community engagement
o ‘what does this mean for my area?’ summaries or similar
The process seemed to rely solely on written submissions. When we attended the in
person consultation event in Barry Memorial Hall in February 2026, there was no one to
record our comments, we were given no answers to our queries and concerns, and we
were constantly told to go and look at the consultation portal to get information and
submit our concerns. The in-person event was simply a ‘signposting to the consultation
portal’ event. It was not meaningful engagement and cannot legitimately be called a
consultation event.
Gap: This method excludes those less able to engage through formal written
consultation, reducing representativeness.
No community engagement prior to selecting the original five “key sites”
The five major sites (incl. North East Barry) were selected before consultation.
The report states: “As part of the Preferred Strategy, 5 new key housing-led sites were
identified…”
Gap: The public were not involved in early spatial option development; instead, they
were asked to react to a pre-determined set of locations.
Reactive, not proactive, approach to community concerns
The document describes a process where council decisions (such as dropping the NE
Barry site) follow behind-the-scenes technical negotiation rather than public influence.
The public consultation did not trigger the change - the failure of landowner agreement
did.
Gap: Public sentiment had little demonstrable impact on spatial strategy development.
The consultation was not inclusive, was discriminatory and fundamentally flawed. I
wish for this to be included as part of my objection.

Only the Council run libraries received copies of the deposit plan documents and not the community libraries where most of the allocated development sites are - ie Rhoose Dinas Powys and St Athan.

Only one short session to discuss with officers the plans was held and the plan for Rhoose was wrong misleading the public into the likely way the development would proceed.

A further session with officers was asked for but was refused,

The Plan is overcomplicated and not all sections in the plan can be commented on with word restrictions on each Policy.

I object to the proposed development at Weycock Cross for the below reasons:
1) Transport Sustainability
- Congestion already exists in North West Barry, with planning provisions + mitigations extremely weak
2) Local Education Capacity needs
- There is no provision for the expansion in school places in the plan, when existing schools are already struggling.
3) Green Wedge
- The proposal is in contravention of the 2015 inspector report finding the site essential to the green wedge openness.
4) Healthcare Provision
-Healthcare infrastructure is already weak, no provision are in the RLDP to mitigate this.



Key Documents Unavailable in Welsh Online

1) Loss of green wedge. Green Wedge should not be a moveable commodity to suit council policy.
2) Flooding-Weycock Cross roundabout constantly floods. The field in question also has flooding issues. There is no mitigation in the current RLDP.
3)Mitigation-This does not work, look at Culverhouse Cross.
4) Further development-Another 1600 houses prosed for Rhoose putting pressure on the main arterial route into Rhoose (at the Waycock cross roundabout)
5) Lack of public transport in the area. Doctors surgeries are over subscribed, along with schools and dentists etc.
6) Over capacity on Port Road. The road from the proposed site (onto port road) was built for approx 2,000 vehicles. The council carried out their own survey a number of years ago and it was found that over 24,000 cars were using the route.
7) The site is outside the Urban Boundary
8) Nant Talwg Way pumping station regularly breaks down + this after the supposed upgrade.
9) Loss of Agricultural Land

Some of the important documents on the website are only in English.

Either a further consultation or extended consultation period to allow for thorough review of all documents.

The sheer volume and inaccessibility of information held on the web pages in relation to this "consultation" makes the consultation period unsuitable and does not allow residents time for review let alone be able to provide a robust case for consideration.

1. Air Quality and Traffic
The RLDP has not been supported by a sufficiently robust, transparent and locally specific
evidence base in relation to traffic capacity, mitigation, air quality and sustainable transport delivery in Dinas Powys.
The Plan relies on high-level assumptions rather than detailed assessments of known local constraints, and it does not provide adequate certainty that necessary mitigation and sustainable transport measures will be delivered, funded and implemented in a timely manner.
As a result, there is a significant risk that the cumulative impacts of development will lead to increased congestion, adverse effects on air quality and a deterioration in the quality of life for existing and future residents.
Until these evidence gaps are addressed and clear, enforceable measures are put in place, the RLDP cannot be considered fully justified, effective or consistent with national policy in its application to Dinas Powys.
Traffic Capacity
I am concerned that the RLDP has not demonstrated that the existing road network in Dinas Powys can cope with the scale of development proposed. Roads and junctions within the village already experience significant congestion both at peak times and throughout the day, particularly along Cardiff Road, St Andrew’s Road and the A4055.
The Plan does not provide clear or accessible evidence, such as detailed junction capacity assessments or peak-hour traffic modelling, to show that additional development will not worsen these problems. Without this information, I cannot be confident that growth can be accommodated without unacceptable impacts on daily travel, safety and quality of life.
Questions: Can the Council confirm that the existing highway network in Dinas Powys can accommodate the growth proposed in the RLDP without causing unacceptable congestion?
Can the Council provide evidence including junction capacity assessments and peak hour traffic modelling?
Mitigation Measures
Where development in Dinas Powys is likely to increase traffic, I am concerned that the RLDP does not clearly explain how congestion will be mitigated.
Mitigation measures are described in general terms, but there is little clarity on what will actually be delivered, when it will happen, or who will pay for it. There is also no clear reassurance that mitigation will be in place before development takes place.
I am concerned that traffic conditions could deteriorate further if development proceeds without effective safeguards.
Questions: For any development allocations in Dinas Powys that may impact congestion, what measures are proposed to mitigate these effects?
Are these measures fully funded, deliverable, and enforceable?
Air Quality Impacts
Increased traffic has clear implications for local air quality, particularly in residential areas and near schools and community facilities. I am concerned that the RLDP has not clearly assessed how the proposed growth in Dinas Powys will affect air quality, especially when the cumulative impact of multiple developments is considered.
The Plan does not explain how compliance with statutory air quality standards will be monitored or maintained as traffic levels increase. This creates significant uncertainty about potential impacts on public health and the local environment.
Questions: Has the Council assessed the likely impact of the proposed growth on local air quality in Dinas Powys, including cumulative effects?
How will the Plan ensure compliance with statutory air quality standards?
Sustainable Transport
While the RLDP refers to encouraging walking, cycling and public transport, I am not convinced that realistic alternatives to car/motor use will be delivered in Dinas Powys.
There is limited detail on specific improvements, timescales or funding for sustainable transport. Without frequent, reliable public transport and safe, direct walking and cycling routes, it is unlikely that car use will reduce in practice.
As a result, traffic growth and air quality impacts may be greater than the Plan assumes.
Question: How does the Plan/Council intend to ensure that sustainable travel options (walking, cycling, public transport) will be delivered and used to reduce traffic and air quality impacts in Dinas Powys?
Evidence Gaps
Overall, I am concerned that key evidence relating to traffic and air quality in Dinas Powys is either missing or insufficiently detailed. Without clear, locally specific assessments, it is difficult to understand how the Council can be confident that the Plan is sound or that its impacts on the community are acceptable.
Question: There are limitations in the transport and air quality evidence for Dinas Powys, how does the Council justify that the RLDP remains sound in light of these uncertainties?
2. Flood risk
I am concerned about the Replacement Local Development Plan (RLDP) and its impact on Dinas Powys, in relation to flood risk.
Dinas Powys already experiences surface water flooding, overloaded drains and pressure on local watercourses. Any new development must be proven to be safe and must not make these problems worse. At present, the RLDP does not give me confidence that this has been properly addressed.
Flood Risk Has Not Been Properly Resolved
Welsh Government policy (TAN 15) says new development must be safe from flooding for its lifetime and that flood risk should be dealt with when the Plan is written, not later on.
The RLDP appears to allocate sites that are affected by flood risk without clearly showing how they can be made safe. Instead, it relies on the idea that solutions will be worked out later when planning applications are submitted. As a resident, this is worrying, as there is no guarantee that those solutions will ever work or be delivered.
Questions: Can the Council explain how allocations within [or affecting] TAN 15 flood risk areas comply with TAN 15’s requirement that development be flood-safe for its lifetime, rather than relying on mitigation to be designed later?
Where the Plan relies on mitigation to address flood risk, what evidence demonstrates that such mitigation is deliverable, funded, and capable of implementation within the Plan period?
Is it the Council’s position that compliance with TAN 15 can be deferred to the planning application stage, and if so, how does that align with the requirement for strategic flood risk to be resolved at plan-making stage?
Lack of Clear Evidence Behind Flood Assessments
The flood studies supporting the Plan are not easy for a lay person to understand and do not clearly show that the full impact of new development has been properly assessed.
In particular, it is unclear whether:
• The combined effect of multiple new developments has been considered
• The worst-case impacts of climate change and heavier rainfall have been tested
• Flood risk to existing homes and streets has been fully taken into account
Without this information, it is hard to see how the Council can be confident that new development will not increase flooding in Dinas Powys.
Questions: What level of modelling underpins the SFCA, and can the Council confirm whether it assesses downstream and off-site impacts arising from cumulative
development?
Does the SFCA test a ‘worst-case’ climate change scenario consistent with current Welsh Government guidance, and if not, why not?
How does the SFCA move beyond a desktop exercise to demonstrate that individual allocations are genuinely developable without increasing flood risk elsewhere?
Too Much Reliance on Future Drainage Solutions
The Plan relies heavily on Sustainable Drainage Systems (SuDS) to manage surface water, but there is little evidence showing that these systems can realistically work on all proposed sites.
I am concerned that:
• There may not be enough space on sites for effective drainage
• Water will still end up flowing into already stretched drains and streams
• Long-term maintenance of drainage systems is unclear
If these systems fail or are not properly maintained, flooding problems could become worse over time.
Questions: What evidence does the Plan rely on to show that SuDS can be accommodated on all relevant allocations without loss of developable area or displacement of flood risk?
Has the capacity of receiving watercourses and drainage networks been assessed at a strategic level, or is this assumed to be resolved site-by-site?
How does the Plan address the cumulative impact of multiple SuDS systems discharging into the same catchment?
What mechanisms are proposed to secure long-term maintenance of SuDS, and where is this evidenced in the Plan?
Doubts About Whether Sites Are Truly Deliverable
Some housing numbers in the Plan appear to depend on sites that may only work if major flood prevention measures are put in place, I believe that Dinas Powys is an example of this.
• It is not clear which sites depend on such measures
• There is no clear timetable or funding in place
• There is no backup plan if flood mitigation does not happen
I am concerned that the Plan may be relying on sites that cannot realistically be developed.
Question: Can the Council identify which allocations are dependent on flood mitigation infrastructure, and where the delivery, timing, and funding of that infrastructure are set out?
If mitigation fails to come forward, what contingency does the Plan provide to ensure housing delivery does not rely on undeliverable sites?
How does the Plan demonstrate that housing numbers are not inflated by sites whose flood risk constraints may ultimately prevent development?
Where NRW has expressed concerns or conditions relating to flood risk, how has the Council reflected those concerns in policy or allocations, rather than deferring them to later stages?
Has any NRW advice been departed from, and if so, what is the evidence base justifying that departure?
Climate Change and Long-Term Safety
Flooding is likely to become more frequent and severe due to climate change. The Plan does not clearly show that new development in or around Dinas Powys will remain safe for decades to come, not just during the Plan period.
Residents need reassurance that today’s decisions will not create long-term flooding problems for future generations.
Question: How does the Plan ensure resilience to increased rainfall intensity and flood frequency over the full lifetime of development, not just the Plan period itself? Does the Plan assume future flood defences or upgrades, and if so, where are those projects committed and funded?
For these reasons, I believe the RLDP has not properly resolved flood risk issues affecting Dinas Powys, I ask that the Council be required to:
• Properly address flood risk at the plan-making stage, not later
• Remove or review sites where flood risk has not been clearly resolved
• Provide stronger evidence that new development will not increase flooding for existing residents.
Until this is done, the Plan cannot be considered sound.
3. Wastewater Treatment
This objection relates to the proposed level of housing growth in Dinas Powys and whether the existing wastewater and sewerage system can safely and realistically support it.
I am concerned that the RLDP does not provide clear, settlement-specific evidence to show that wastewater treatment works and the local sewer network have enough capacity to accommodate the planned development, either now or within the Plan period.
Without this evidence, the Plan risks placing unacceptable pressure on already constrained infrastructure, increasing the risk of flooding and environmental harm.
Wastewater Treatment Capacity
The RLDP does not clearly explain whether the wastewater treatment works serving Dinas Powys has sufficient spare capacity to deal with additional development.
In particular, the Plan does not set out:
• how much wastewater the treatment works is currently allowed to treat (its “consented capacity”),
• how much spare capacity is actually available,
• when this information was last assessed, or
• whether this assessment has been formally confirmed by Dŵr Cymru Welsh Water.
Without this basic information, I lack sufficient information to understand whether the existing system is already close to capacity or whether it genuinely has room to cope with new development.
The Plan also does not clearly state how much additional wastewater would be generated by the new housing proposed for Dinas Powys, or how this compares with any available
capacity. This makes it impossible to judge whether the level of growth proposed is realistic.
There is no clear evidence that a Dinas Powys–specific assessment has been carried out. If the Council is relying on broad, county-wide modelling instead, this does not reflect local conditions or known issues within the village.
Sewer Network Constraints & Flood Risk
Many residents are already aware of problems with drainage, surface water, and sewer performance in Dinas Powys, particularly during periods of heavy rainfall.
However, the RLDP does not provide clear evidence on:
• existing sewer surcharging or flooding incidents,
• past or current problems with overloaded sewers, storm overflow activity affecting the area.
There is also no clear explanation of how the combined impact of multiple new development sites in Dinas Powys has been assessed together, rather than individually. This is especially concerning given the increasing frequency of intense rainfall linked to climate change.
Dinas Powys has known surface water and flood risk sensitivities, yet the Plan does not convincingly demonstrate that increased wastewater flows will not make flooding worse or lead to pollution of local watercourses.
I am concerned that problems will only become apparent after development has already taken place.
Deliverability & Infrastructure Planning
The RLDP does not identify any specific wastewater or sewerage upgrades needed to support the proposed growth in Dinas Powys.
Where upgrades may be required, the Plan does not explain:
• what infrastructure improvements would be needed,
• how much they would cost,
• who would pay for them, or
• when they would be delivered.
This creates significant uncertainty. I am concerned that development could go ahead before infrastructure is in place, leaving existing communities to deal with the consequences of overloaded systems.
There is also no clear explanation of how infrastructure will be phased to ensure that wastewater capacity is available before new homes are occupied, rather than relying on solutions being found later.
Role of the Statutory Undertaker – Dŵr Cymru Welsh Water
The Plan appears to rely heavily on future discussions with Dŵr Cymru Welsh Water at the planning application stage to resolve wastewater issues.
I am concerned that this approach puts off important decisions that should be made now, during the Plan-making process. National planning policy requires development plans to be based on a clear understanding of infrastructure capacity, not assumptions that problems can be fixed later.
Without clear, written confirmation from Dŵr Cymru Welsh Water that the proposed level of growth in Dinas Powys can be accommodated, I believe the Plan lacks the certainty needed to be considered sound.
Soundness & Policy Compliance
Because the RLDP does not clearly demonstrate that wastewater infrastructure:
• is available,
• can be upgraded in time, and
• has a realistic and funded delivery plan,
I do not believe the Plan is effective, which is a key test of soundness.
The Plan also appears to conflict with Planning Policy Wales, which states that development should be directed to locations where infrastructure is already in place or can be secured.
Deferring wastewater solutions to a later stage does not meet this requirement.
If wastewater capacity problems cannot be resolved within the Plan period, I question why the level of development proposed for Dinas Powys has not been reduced to reflect real infrastructure constraints.
4. Green Space & Green Infrastructure
For the reasons set out below I consider that the RLDP is unsound in relation to green space and green infrastructure in Dinas Powys because it:
• Fails to justify the loss of existing green space or show that mitigation will be delivered;
• Lacks clear evidence on the quantity, quality, and accessibility of green space;
• Does not safeguard the integrity of green infrastructure networks;
• Provides no mechanisms to ensure timely delivery of green space alongside new development;
• Does not demonstrate that alternatives were properly considered through the Sustainability Appraisal.
Until these issues are addressed, there is no clear basis to conclude that the proposed growth in Dinas Powys can be accommodated without unacceptable impacts on local green spaces and the wider environment.
I urge the Council to carefully consider these concerns and provide further evidence or modifications to ensure that the Plan is effective, sustainable, and compliant with national planning policy
Protection of Existing Green Space
The RLDP does not clearly explain why any existing green spaces in Dinas Powys might be lost, or whether the loss is unavoidable.
I am concerned that the Plan does not demonstrate:
• that all alternatives to protect existing green space have been considered, or
• that any replacement or mitigation will be provided within or near the village.
Without this evidence, there is no assurance that valued local green spaces, which are important for recreation, biodiversity, and the character of the settlement, will be preserved. This is a serious omission that makes the Plan unsound in this respect.
Question: How does the Plan justify the loss of any existing green spaces in Dinas Powys? Has an assessment been carried out demonstrating that loss is unavoidable, and that adequate replacement or mitigation will be provided within or near the settlement?
Quantity, Quality, and Accessibility of Green Space
The RLDP does not provide clear, settlement-specific information about the amount, quality, or accessibility of green space for Dinas Powys residents.
It is unclear whether the standards being applied:
• meet national policy requirements,
• reflect the needs of the local population, or
• will be sufficient to support an increased population from new housing.
Without clear evidence, I cannot be confident that new development will maintain adequate recreational and amenity space for all residents.
Question: What evidence supports the quantity, quality, and accessibility standards for green space in Dinas Powys? How do these standards compare with national policy and the needs of the local population?
Green Infrastructure Network Integrity
The Plan does not explain how green infrastructure networks—including wildlife corridors, footpaths, cycleways, and recreational routes—will remain coherent and functional as new development comes forward.
There is a real risk that the proposed growth could fragment these networks, reducing connectivity for wildlife and limiting access to recreational spaces. I am concerned that the Plan does not set out measures to prevent these negative impacts.
• Question: How does the Plan ensure that green infrastructure networks in Dinas Powys, including wildlife corridors, footpaths, and recreational routes, remain coherent and functional despite new development?
Delivery and Implementation
The RLDP does not make it clear how green space provision will be delivered at the same time as development, rather than being left to later planning agreements or discretionary decisions.
Without clear delivery mechanisms, there is no certainty that new or replacement green space will be provided when needed.
This creates risk that residents will face reduced access to recreation, wildlife habitats, and open space for years after new homes are built.
• Question: What mechanisms are in place to ensure that green space provision in Dinas Powys will be delivered alongside development, rather than deferred to later discretionary planning stages?
Consideration in the Sustainability Appraisal
It is not evident that the Plan’s Sustainability Appraisal has fully assessed the impact of proposed development on green space and green infrastructure in Dinas Powys.
There is no clear explanation of whether alternative development options were considered that would reduce the loss or fragmentation of green spaces, and if so, why these
alternatives were rejected.
I am concerned that the lack of settlement-specific analysis weakens the credibility of the Plan and its ability to safeguard local environmental assets.
Question: Has the Integrated Sustainability Appraisal fully considered the impacts of proposed development on green space and green infrastructure in Dinas Powys?
Were alternatives considered that would reduce loss or fragmentation, and if so, why were they rejected?
5. Health & Wellbeing
Alignment with RLDP Policy SP6
The RLDP does not clearly demonstrate how proposed allocations and policies affecting Dinas Powys will achieve the health and well-being objectives set out in Policy SP6.
In particular, the Plan does not provide evidence that new development will:
• maintain or enhance access to green spaces,
• support active travel (walking, cycling, public transport), or
• deliver inclusive and safe public environments for all residents.
Without clear mechanisms to ensure these outcomes, it is unclear how the Plan will contribute to the creation of healthy, inclusive communities in line with its own strategic policy.
Question: How does the Plan ensure that proposed allocations and policies affecting Dinas Powys will deliver the health and well-being objectives set out in Policy SP6, including access to green space, active travel, and inclusive public environments?
Alignment with the Vale of Glamorgan Well-Being Plan
The RLDP does not clearly show how its proposals for Dinas Powys are consistent with the objectives of the Vale of Glamorgan Public Services Board Well-Being Plan, particularly in relation to:
• physical and mental health,
• health equity, and
• equitable access to green and recreational spaces.
There is no settlement-specific evidence demonstrating that new housing or other
allocations will support these well-being objectives, leaving a gap in the Plan’s justification and effectiveness.
Question: How does the RLDP demonstrate consistency with the Vale of Glamorgan Public Services Board Well-Being Plan, particularly the objectives relating to physical and mental health, health equity, and access to green spaces in Dinas Powys?
Evidence for Health and Well-Being Outcomes
The Plan does not provide sufficient evidence that its spatial strategy, site allocations, or policies will produce measurable improvements in health outcomes for residents of Dinas Powys, particularly in areas where health needs are identified.
Without this evidence, it is impossible to determine whether the proposed development will genuinely support improved physical or mental health, reduce health inequalities, or provide accessible, high-quality spaces for recreation and social interaction.
Question: What evidence demonstrates that the Plan’s spatial strategy, allocations, and policies in Dinas Powys will produce measurable improvements in health outcomes for residents, especially in areas of identified need?
Integration with the Sustainability Appraisal
The RLDP’s Integrated Sustainability Appraisal (ISA) does not clearly demonstrate how health and well-being impacts have been addressed specifically for Dinas Powys.
There is limited information on:
• mitigation or enhancement measures to support healthy communities,
• the contribution of proposed allocations to active travel networks, or
• ways in which new development will improve access to green infrastructure or inclusive public spaces.
Without settlement-specific consideration, the ISA does not provide sufficient assurance that health and well-being outcomes will be achieved, nor does it demonstrate compliance with national planning policy on creating healthy and sustainable places.
Question: How has the Integrated Sustainability Appraisal addressed health and well-being impacts specifically for Dinas Powys, and what mitigation or enhancement measures are proposed to ensure alignment with national planning policy on healthy places?
6. Education & Medical Services
I believe that the RLDP is unsound in relation to education and healthcare services in Dinas Powys
Education Provision
The RLDP does not provide clear, settlement-specific evidence regarding school capacity in Dinas Powys.
My key concerns include:
• There is no demonstration that local primary and secondary schools have enough places for the children who will arise from the proposed housing.
• It is unclear whether the Plan relies on borough-wide estimates, which may overlook local pressures and result in shortages at specific schools.
• The Plan does not identify any specific improvements to school infrastructure (such as new classrooms, extensions, or new schools), nor does it set out funding, timing, or delivery mechanisms.
Without these assurances, there is no certainty that school places will be available before families move in, which could lead to overcrowding and diminished educational standards.
I am concerned that, in the absence of firm evidence and infrastructure commitments, the proposed scale of housing growth in Dinas Powys may be unsustainable and undeliverable.
Healthcare / Medical Services
The RLDP does not demonstrate that local healthcare services—including GP practices, dental services, and community health facilities—can accommodate the increased population.
My specific concerns include:
• There is no settlement-specific assessment of current or future healthcare capacity in Dinas Powys.
• The Plan does not indicate whether additional or expanded healthcare facilities will be provided, nor how this would be funded, phased, or secured alongside new housing.
• Without clear planning, the proposed growth could reduce access to essential health services for both existing and new residents, impacting physical and
mental health outcomes.
I am particularly concerned that increased demand without confirmed provision could lead to longer waiting times, reduced appointments, and pressure on local medical staff,
undermining the well-being of the community.
These gaps mean the Plan is not effective, justified, or consistent with national planning policy, which requires growth to be planned where infrastructure is available or can be secured.
7. Affordable Housing Allocation
I support the principle of providing affordable homes for local residents, especially young families, first-time buyers, and key workers who cannot afford market rates.
Well-planned affordable housing can help maintain a mixed and vibrant community and retain younger residents.
Affordable homes in Dinas Powys could reduce commuting pressures by allowing residents to live and work locally.
However, the RLDP does not provide clear evidence for how many affordable homes are needed in Dinas Powys or what types of homes are required for different groups (families, older residents, low-income households).
There is insufficient information about how and when affordable homes will actually be delivered alongside market housing.
Without clear delivery plans or safeguards, affordable homes may not remain genuinely affordable in the long term.
Concentrated or poorly planned affordable housing may put pressure on local schools, healthcare, transport, and green spaces, which are already constrained in Dinas Powys.
The Plan does not explain how affordable housing will be integrated with market housing to create sustainable, mixed communities rather than segregation or social imbalance.
Because of the lack of clear evidence, delivery mechanisms, and mitigation for potential negative impacts, I do not consider the Plan sound in terms of affordable housing in Dinas Powys.

8. Community Cohesion & Social Integration
I am concerned that the Plan, as currently drafted, does not ensure new growth will support strong, healthy, and inclusive communities.
Until the Council provides clear evidence and enforceable measures addressing community cohesion, housing mix, and health impacts, I cannot have confidence that the Plan is sustainable or fair.
Impact on Community Cohesion and Social Integration
I am concerned that the Plan does not explain how new housing and growth will integrate with existing communities.
There is a risk that rapid development could strain local services, schools, and community spaces, and make it harder for neighbours to get to know one another.
I would like to see evidence that social infrastructure will keep pace with population growth and that communities will remain inclusive and connected.
Risk of Over-Concentration of Affordable Housing
I am concerned that clusters of affordable housing in certain areas could lead to pockets of social exclusion or limit access to opportunities.
The Plan does not explain how it will ensure a good mix of housing types and tenures across the Vale.
I ask that the Council provide evidence that housing allocations will support socially balanced, inclusive communities.
Impacts on Mental and Physical Wellbeing
I am concerned about increased traffic, air pollution, noise, and the loss of green spaces
affecting health and wellbeing. The Plan does not provide clear commitments to protect or improve accessible green spaces or safe walking and cycling routes.
I would like to see evidence that the Plan has assessed the health impacts of growth and will take steps to mitigate them.
9. Climate Change & Sustainability
I am concerned that, as drafted, the Plan does not provide enough evidence or practical measures to ensure new development is sustainable and climate resilient. The RLDP is not fully justified, effective, or consistent with national policy on climate change and sustainability.
Key gaps include alignment with carbon reduction targets, enforceable delivery of low-carbon travel, energy-efficient homes, sustainable drainage, and climate-resilient infrastructure.
Without clear policies and enforceable commitments on low-carbon travel, energy-efficient homes, sustainable drainage, and climate-resilient infrastructure, the Plan risks harming both the environment and the wellbeing of communities.
Alignment with Welsh Government’s Carbon Reduction Targets
I am concerned that the Plan does not explain clearly how new homes, workplaces, and other development will help Wales meet its legally binding carbon reduction targets.
Without this, there is a risk that growth in the Vale could increase emissions rather than reduce them. I would like to see evidence showing how this (and each) new development contributes to lowering carbon emissions.
Promotion of Low-Carbon Travel, Energy-Efficient Homes, and Sustainable Drainage
I am worried that the Plan relies too much on people walking, cycling, or using public transport without clear plans to make this happen.
There is also little information on whether new homes will be energy-efficient or if systems to manage rainfall and reduce flooding (like sustainable drainage) will be properly installed and maintained.
I want to see clear, practical measures to make low-carbon travel, energy-efficient homes, and safe drainage a reality.
Resilience of Infrastructure to Extreme Weather Events
I am very concerned about the impacts of extreme weather, including flooding, heatwaves, and storms, on roads, utilities, and homes.
The Plan does not clearly show how new developments or existing infrastructure will be designed to cope with these risks.
I would like to have assurance that any buildings, roads, drainage, and community facilities will be climate-resilient and protect people’s health and safety.
10. Plan-making Process & Evidence Base
In my view, the RLDP is not fully justified or effective in its current form with respect to plan-making and the evidence base. Key gaps include accessibility and transparency of evidence, consideration of resident and stakeholder feedback, and robust monitoring and review
arrangements.
Without clear and accessible evidence, demonstrated consideration of local feedback, and robust monitoring and review mechanisms, residents cannot be confident that the Plan will be fair, effective, or responsive to changing circumstances.
Clarity, Transparency, and Accessibility of Evidence
The RLDP is not always clear and is not easy to access.
Technical reports, data, and assumptions are often difficult to find or understand, making it hard for residents to see why particular sites or policies were chosen.
The Council should provide accessible summaries and clear explanations so that everyone can understand and comment on the evidence.
Local Consultation and Consideration of Resident Feedback
I am concerned that residents’ views may not have been fully taken into account in shaping the Plan.
It is unclear how consultation responses have influenced allocation decisions or policy wording.
I seek assurance that feedback from local people and community groups has genuinely informed the Plan, and that future consultations will be inclusive and clearly reported.
Monitoring and Review Mechanisms
The Plan does not clearly explain how progress will be monitored or how changes will be made if things do not go as planned. For example, if housing delivery is slower than expected or infrastructure is delayed, there is little information on how allocations or policies would be adjusted.

Dear responsible officer,
I am objecting to the inclusion of grounds Site ID 4069 Land East of Colwinston for the following reasons:

1. The land just below the proposed development is already subject to flooding and this development would add to the run off whilst removing land that can currently absorb water during periods of sustained rainfall. Building here will increase the risk of flooding to other houses. Flooding has been an issue in the Village and remains of concern to current homeowners. Evidence suggests that concern around flooding can impact negatively on people's health. Has a health impact assessment been undertaken? Furthermore, I believe that there have already been capacity issues with the local sewerage system.

2. This will negatively impact nature. The fields are designated farming/agricultural land. Farming land is vital for sustainable food. Brown field sites would surely be more appropriate for re-development, rather than developing current countryside. In addition to farming livestock (sheep are currently grazing on that site) there are woodpeckers living nearby (probably in the older trees located in the adjacent field), hedgehogs and bats are frequently seen, and Kites hunt on the fields, especially after harvest. The site is part of the rural setting of the Conservation Area. Extending the current boundary fundamentally alters the settlement envelope and, as outlined above, this also conflicts with the statutory duty to preserve or enhance. The proposal also lacks the required sufficient specific justification (see 3 below).

3. There is no public transport infrastructure, meaning that all house owners will be required to use cars, potentially increasing small village traffic by around an additional 50 cars (assuming 2 per house). There are already traffic bottlenecks at school drop off and pick up. The roads out of this development would exit via Heol Cae Pwll into the existing bottleneck area. Furthermore, the planning for affordable housing is counter intuitive given the lack of public transport infrastructure and the realistic need for car ownership to access shops etc. This has been previously noted when families without cars are housed in rural villages, they seek alternative housing because they simply cannot access shops or services. Therefore, this is likely to result in overdevelopment and its negative impacts on current villagers, without realistic prospect of providing true affordable housing to those in need. A number of houses are currently for sale in Heol Cae Pwll, with some having been on the market for many months. In other words this development seems to be at odds with the evidence of housing need, and also at odds with the evidence of housing demand.

4. It is at odds with government policy to increase active sustainable transport. Noting that walking along the A-48 towards Bridgend or Cowbridge is dangerous as there are no pavements, and there are no cycle paths until nearer to Bridgend (I'm assuming that the nearest cycle path is actually in Bridgend LA region rather than the Vale of Glam). Integrated Site Appraisal Inclusion of this site is not supported by the Integrated Site Impact Assessment contravening almost all of the stated Sustainability Objectives within the LDP itself.

5. The digital approach adopted in this consultation is likely to have excluded many people in the local community from participating and responding, thus providing an inadequate consultation. Indeed, completion of pdf forms and subsequently hunting down the correct e-mail address to return the form was a laborious process. I was unable to access the online form method.

6. Previous site assessments had deemed this site unsuitable for development following impact assessment. The change in decision now appears illogical. This further undermines the principle that the site development is consistent with evidence of housing need.

Yours sincerely,

I wish to strongly object to the above proposal.

As a retired chartered civil and highway engineer I am fully aware that the existing infrastructure is overloaded and totally unable to accommodate more development , traffic , foul water disposal ……. and so on .

The above points were the fundamental and basic reasons why planning in 2010 was refused ( when only 200 houses were proposed ) .

Since then numerous housing developments in the west of the Vale of Glamorgan have been completed putting increased pressure on roads , schools, health care and centres, drainage disposal (foul , storm and highway) and other statutory services.

The Nant Talwg watercourse is continuously being subjected to “emergency”sewage overflow situations - the foul system and pumping station cannot handle the current increased volumes.

The current infrastructure was not designed for today’s requirements - it is outdated and unable to cope with increased traffic volumes and loadings from the additional developments .

I am also aware that the consultation period is not in accordance with regulations regarding “due consideration” , and is based on the timing of forthcoming Senedd elections in May.
It has become more of a political issue as opposed to that of logic and common sense.

I oppose the Vale of Glamorgan Council Replacement Local Redevelopment Plan (RLDP), in particular the Weycock Cross, Barry development for the following reasons:

1. The consultation form and accompanying literature/reports is excessively lengthy, making it difficult for many individuals, especially those with health challenges and older adults, to engage effectively. This renders the consultation process inequitable.
2. While I agree that personal details of those commenting should be shared with relevant Council members, these should not be made public, I question the legality of this. The current policy discourages participation due to fears of backlash, undermining fairness.
3. Neither I nor several other residents were informed about the public consultation event at Barry Memo Arts Centre on Monday, 2nd February, which is unfair.
4. The term "unit" is undefined in the documents. Does it refer to an entire block of flats/apartments or a single flat within a block? Clarification is needed on the number of units/blocks and flats/apartments per block planned for the Weycock Cross, Barry and other sites.
5. The RLDP specifies a minimum of 30% affordable housing for the proposed Weycock Cross, Barry site which is substantial. However, the maximum percentage is not stated. What is the proposed maximum amount?
6. How much of the affordable housing will be acquired by the council or private entities and converted into social housing?
7. Regarding social housing occupancy - with VOG Council being a "county of sanctuary" and the Government's "Operation Scatter" initiative, how many individuals with illegal or uncertain immigration status or with indefinite leave to remain, will reside in Weycock Cross, Barry? This could significantly impact the area's culture.
8. How many Houses of Multiple Occupancy (HMOs) will be established at Weycock Cross, Barry? What is the maximum number of occupants per HMO? This also relates back to point 7.
9. Traffic congestion is already a significant issue around Weycock Cross, Barry. Additional housing developments at Weycock Cross, Barry and surrounding areas (e.g. Rhoose, Llantwit Major, St Athan, etc.) will exacerbate this, increasing air pollution and affecting access to Cardiff Airport and access for emergency services.
10. Flooding is a serious concern. Areas like Porthkerry Park and the Millwood already experience significant flooding, which development at Weycock Cross would worsen, to potentially catastrophic levels.
11. Illegal sewage dumping is likely to increase with new developments, compounding environmental and health issues.
12. The loss of green spaces and wildlife habitats is troubling, especially given the ongoing ash dieback affecting Porthkerry Park and surrounding areas. Traffic has also resulted in otter fatalities.
13. According to the Council's report, there are insufficient primary school places to accommodate new housing developments.
14. Health and well-being facilities, such as GP surgeries, are inadequate to support additional residents, as noted in the Council's report.
15. Public transport is insufficient. The nearest train station, Barry, is a considerable distance away and requires an uphill walk. Bus services are infrequent, making car travel necessary. Walking to and from the town center is impractical.
16. Concerns exist regarding the use of Persimmon for this development, given past issues with fire regulation compliance at the White Farm, Barry development and legal action required to enforce infrastructure commitments at both the White Farm and the Barry Waterfront developments. What guarantees will the Council put in place to ensure this won't be repeated?

I write regarding the ongoing consultation relating to the Deposit Plan. I make these representations in my capacity as Leader of the Council's Conservative Group. Please take this correspondence as our Group's response to the consultation.

Our Group does not consider any of the key sites designated within the Plan to be suitable. The respective ward members for St Athan, Rhoose, Illtyd and Dinas Powys have articulated detailed reasons for this previously. I too, as ward member for Llandough, have raised concerns regarding the impacts developing the Cardiff Road site would have on road safety issues at the Merrie Harrier junction.

Our Group has been approached by residents from across the Vale of Glamorgan expressing deep concerns regarding the consultation process. Many have found the consultation portal difficult to navigate, and relevant information hard to locate. Given the time required to read all the relevant documents prior to crafting a response, residents do not feel the six-week consultation process is sufficient. As a Group, we agree. For this reason, at Full Council on Monday, I requested extension to the consultation period. It is regrettable this was not granted.

As such, it is the view of our Group that the consultation is flawed. We therefore believe that it must be carried out again.

Thank you for taking the time to consider our representations.

I have found the fractured and piecemeal format of the online RLDP to be confused and confusing. It has necessitated endless repetition, and I was constantly forgetting where I was and what I had already said. In consequence, I am writing here an overall narrative to pull it all together.

My objections begin with a critique of the lack of transparency, accessibility and ease of engagement within the consultation process. The difficulty in navigating the scattered information restricts many residents' ability to engage meaningfully. Such a barrier is against the stipulations of Planning Policy Wales for enabling inclusive consultation. The too-narrow time frame for such a mammoth undertaking has also proved an additional unacceptable barrier.

Vale of Glamorgan Deposit Replacement Local Development Plan Public Consultation

Local resident RLDP consultation feedback based on review of RLDP information and supporting documents as hosted on RLDP website https://valeofglamorgan.oc2.uk/

Objection:

"2026 RLDP consultation process is flawed and does not provide for meaningful public consultation on multiple grounds"

This document contains an analysis of the RLDP OC2 website used for the public consultation process, highlighting the multiple ways in which it creates barriers to any meaningful consultation with the public.

Also included is communication sent to the Vale of Glamorgan planning department during the RLDP consultation period, requesting these concerns to be considered and an extension of the RLDP consultation period to be granted. This was refused.

I would like the contents to be included in my RLDP submission

Ref: NWB_RLDP_JVN_010

Date: 10th March 2026Re: RDLP consultation period (proposed Weycock Cross housing development)

23rd February 2026

Hello

I am writing to you to raise serious concerns regarding the current Vale of Glamorgan council RDLP consultation process which I believe is demonstrably undemocratic and fails to meet the basic standards of accessibility required by such a consultation.

On the basis of the concerns outlined in the attached document, I would request that the consultation period be extended by a period of at least 2 months to provide any chance of the public being able to engage in the process in a fair and democratic way.

In light of the fact that the consultation exercise cutoff date is set for 11th March 2026, I would appreciate your response on this request at the earliest opportunity.


As a local resident of the area directly affected by the proposed development, I was an active participant in the previous consultation process (July 2025) via making written submissions and also by speaking as a member of the public at the Placemaking Scrutiny council meeting held in late 2025.

I am currently in the process of attempting to review the contents of the RDLP consultation website https://valeofglamorgan.oc2.uk/ in order to provide consultation feedback before the 11th March 2026 consultation window cutoff date.

Despite having spent many hours attempting to navigate the site and read and review the supporting documentation in order to give my feedback, this is proving virtually impossible, not only due to failings in the design of the website (further details below) but primarily due to the sheer volume of supporting documentation that the public are being expected to provide feedback on within the limited time window. As a result of becoming increasingly overwhelmed at the seemingly impossible task of simply accessing and reviewing the supporting documents, I took a moment to stop and assess the volume of content:

Considering only the 'landing page' at https://valeofglamorgan.oc2.uk/ (containing the main linked blocks 1-8) the excessive volume of documentation provided for the consultation process is astonishing. I ran a quick website audit on the supporting PDF documentation* contained solely on these 8 primary linked pages with the following results:

Total number of supporting PDF files: 159

Total (combined) file size of PDF files: 1034.7 MB

*Note: English language PDFs only; Welsh language PDFs not included in totals; further linked PDF documents at a lower URL level not counted. HTML content (web pages themselves) not included - this is only the supporting PDF documentation.

These numbers in themselves might not mean much to many people, but as someone who regularly uses AI tools in my work then in order to put them in perspective I ran these numbers through Google's AI assistant tool using the query "How long would it take to read, review and provide feedback on 1034MB of PDF files which are supporting documents in a public planning consultation?"

This provided the following results:

"Al Overview:

Based on these parameters, reviewing 1034 MB of planning documents would take approximately 1,103 hours, or 138 standard working days (8 hours/day).

Steps to calculate:

Using an industry-standard density of 10 pages per megabyte, with a typical text-to-image ratio of 90% to 10%, this results in approximately 9,300 pages (text) and 1034 pages (graphs/images).

Reviewing planning documents is more intensive than casual reading, as it requires analysis and drafting feedback. Estimating 6 minutes per page (text) and 10 minutes per page (graphs/images/diagrams) for reading, cross-referencing and feedback drafting:

9300 pages X 6 minutes/page = 55,800 minutes

1034 pages X 10 minutes/page = 10,340 minutes

Total: 66,140 minutes = 1103 hours = 138 daysAnswer: It would take a single reviewer approximately 1,103 hours (roughly 27.5 weeks of full-time work) to complete this task. For a standard 30-day consultation period, this workload would require a team of at least 7 to 8 full time reviewers."

Conclusion:

Planning consultations are legally required to be accessible. This specific, quantifiable overview provides clear evidence that the consultation process as it is currently being facilitated fails at this first requirement as it is totally unrealistic to expect the public to have any meaningful opportunity to read and review the supporting documentation in the time available that is critical to the entire consultation process.

These failings can be summarized as follows:

The volume of material is prohibitively large. The site provides no summaries, no filtering, and no guidance on which documents matter most. The time required to read everything is incompatible with the consultation deadline. This raises legitimate concerns about accessibility, fairness, and procedural transparency.

On the basis of the above, I would request that the consultation period be extended by a period of at least 2 months to provide any chance of the public being able to engage in the consultation process in a fair and democratic way.

In addition to these primary concerns over the sheer volume of supporting documentation needing to be read and reviewed, the website itself has serious failings in many other areas (see further notes below) which mean it further fails to meet the standards legally required for such a consultation process.

Therefore I would also request that serious consideration is given to a review of the consultation website as it is currently provided with a view to improving its accessibility to all users as is legally required.Concerns regarding website design, structure and implementation

1. The consultation website https://valeofglamorgan.oc2.uk/ is extremely poorly constructed, making it very difficult for any user, particularly those less digitally experienced, to find where and how to provide feedback.

For instance, following the first link on the homepage: "1: Vale of Glamorgan Deposit Replacement Local Development Plan" takes you through to the "Proposals Map" page which has a handy section saying "Have Your Say on the Deposit RLDP"; this leads immediately to the next section "How to Comment on the Deposit RLDP" which in turn states "The Council encourages responses to be made via its online consultation portal, which includes features to help you comment... " This is followed by the sentence: "The online consultation portal can be accessed at: https://valeofglamorgan.oc2.uk" whereby this link takes you right back to the original opening page where the user is faced with the same 8 boxes to choose all over again (this is called circular navigation and is a common sign of poor website implementation).

2. The website makes no attempt made to curate, organise or structure the supporting documentation in a manner that eases the burden on the user caused by the excessive volume. For instance, it is impossible to follow any logical path or structure to locate, read and review supporting documents pertaining to a single (in my case, Weycock Cross) development. For this reason, it is necessary to wade through the full reams of PDF documents as outlined above simply in order to locate any sections relevant to a particular proposed development.

3. Many, but not all of the PDF documents are available in both Welsh and English however several of the key supporting documents (flood assessment, candidate site assessment, etc) are only available in English

4. In addition to the single downloadable consultation feedback form there are multiple areas of the website where it is possible to provide feedback comments, however these are typically limited to 100 words, and the ability to provide comments in this way is scattered and unstructured (comments are available for some documents, but not for others, with no way of knowing whether any comment-able documents have been missed).

Likewise it is totally unclear whether those online comments boxes are meant to be taken in addition to, or instead of, the single downloadable feedback form. This simply adds to the overwhelming feeling of the user not knowing whether they have been able to provide the necessary feedback as part of the consultation process, and this simply reinforces the sense of exclusion and alienation from the whole consultation process.

5. Finally, in order to generate an impartial summary of the website's suitability as a legal platform for the RLDP consultation process I used Microsoft's Copilot AI tool to perform a quick scan and summary of the https://valeofglamorgan.oc2.uk website:

Copilot prompt: "Provide an assessment of how well constructed is the website https://valeofglamorgan.oc2.uk, and how easy is it to assess the content of the website for the process of providing feedback as part of the consultation process?"

The results are as follows:Overall Assessment of the Website's Construction Website: https://valeofglamorgan.oc2.uk Context: Public consultation platform for the Vale of Glamorgan Replacement Local Development Plan (RLDP)

Based on the page content, the site is functional but not especially user-centred. It presents information in a very linear, text-heavy, and document-driven way, which makes it technically complete but practically difficult for residents to navigate and meaningfully engage with.

1. Website Structure & Usability: Document-heavy, not task-oriented The site is essentially a list of links to large document sets. There is no thematic summary, no "start here" guidance, and no filtering by topic, impact, or geography.

No visual hierarchy Everything is presented as a flat list of expandable sections. Important items (e.g., the main plan) look visually identical to minor supporting documents.

No integrated search or tagging Users cannot search within the consultation documents or filter by theme (transport, housing, environment, etc.).

No previewing or quick-read tools Documents must be downloaded individually. There is no: in-browser PDF viewer executive summary extraction keyword search across documents "what's changed since last plan" summary This makes the site feel more like a document repository than a public engagement tool.

2. Accessibility of Content for Feedback Purposes Major Barriers:

Volume of documents The "Supporting Documents" and "Key Site Supporting Information" sections contain very large numbers of PDFs, many of them hundreds of pages long. The site provides no indication of: file size page count document purpose relevance to specific policies

Lack of contextual summaries The site does not provide: plain-English summaries policy impact explanations maps or interactive tools "what this means for your area" guidance

Fragmented navigation Clicking into a document often sends the user to a new page with more links, and sometimes back to the starting point - a common OC2 issue that creates a sense of circular navigation.

No support for lay readers Planning consultations are legally required to be accessible, but the site provides no: glossary simplified overview video explainers thematic breakdowns

Feedback process is unclear The homepage says: "For instructions on how to use the system and make comments, please see our help guide." But the help guide is not integrated into the workflow, and users must find it manually.3. How Easy Is It to Provide Feedback? Short answer:

Not easy at all. The platform meets the minimum legal requirement of making documents available, but it does not meaningfully support residents in understanding or responding to them.

Why it's difficult

Users must manually open and read dozens or even hundreds of PDFs. There is no summary of key issues requiring feedback. There is no guided questionnaire or structured comment form linked to specific policies. The site does not help users understand which documents are essential and which are technical appendices. The burden of interpretation is entirely on the resident.

Effect on public participation This design unintentionally favours:

planning professionals developers consultants residents with significant time and technical literacy It disadvantages:

ordinary residents people with limited time those unfamiliar with planning terminology

4. Overall Verdict Construction quality: Functional but outdated and not user-centred.

Ease of assessing content: Low - the site is difficult to navigate and lacks essential tools for understanding the material.

Ease of providing feedback: Low - the process is unclear, and the volume/complexity of documents creates a high barrier to meaningful participation.

What this means for the consultation Based on the structure visible on the website : The volume of material is prohibitively large. The site provides no summaries, no filtering, and no guidance on which documents matter most. The time required to read everything is incompatible with the consultation deadline. This raises legitimate concerns about accessibility, fairness, and procedural transparency.

Re the Vale of Glamorgan Planning RLDP and the Weycock Cross NW Barry site. There are two related issues which concern me as a resident. The first focuses on the Vale RLDP as a whole and a major concern is the manner in which the whole RLDP has been presented to the public and the compressed time period in which to read, digest and comment.

Vale Planning have already recently replied to a number of residents on the above timing question, namely, that they (Vale Planning) were only fulfilling a statutory requirement of six weeks. This response misses the point. The statutory consultation period is not the issue for residents. The core issue is rather the clumsy, overlong and ill-organised character of the whole RLDP, which eats up time. Vale Planning have a public duty of care for local residents, namely, to minimally help and facilitate public understandings of the issues. Sadly they entirely failed in this basic responsibility. Intentionally or not Vale Planning quite literally dumped thousands of pages of technical documents on the website with little or no guidance or clear pathways for ordinary readers, which is an unforgivable administrative lapse.

Vale Planning have argued that they do provide short executive summaries for documents. However this argument cuts no ice. Most of the executive summaries give no clear indication as to whether there are any substantive details about a relevant site for the reader. Therefore one can only ascertain whether a particular site is being addressed by trawling hundreds of pages of dense technical text. Consequently, the arguments that residents should either only read and comment on their own site, or that they should only read executive summaries, is spurious. Multiple PDFs in the RLDP on, for example, traffic, drainage, the environment (dropped in at random throughout the whole RLDP website), will often contain more detailed micro-policy comments on a relevant site. However, such micro-policy comments are literally submerged deep within hundreds of pages of dense text. The overall effect of this kaleidoscopic website is thus continual bafflement.

Like many residents I attended the walk-in sessions with Planning; however the only advice we were given by Planning operatives when we raised critical queries was that we had to consult the details of the online website. Notably this was also the same case for any paper-based responses. The supposed online evidence documents had to be addressed. The website has therefore been the evasive linchpin of this whole debacle. This makes the whole consultation process largely inaccessible to ordinary folk and those who have limited digital skills or limited time due to responsibilities. In point, for those with limited digital skills, the online RLDP offends against basal principles of natural justice. It is intrinsically discriminatory. This is simply not democratic consultation.

It is worth noting here, in passing, the factual nature of this timing issue. In running a Microsoft's CoPilot AI full analysis of the current RLDP, in terms of basic reading time, evaluation and assessment of the document. CoPilot concluded that "It would take a single reviewer approximately 1,103 hours (roughly 27.5 weeks of full-time work) to complete this task". This would be reading every day, all day, for 27 weeks. Bizarrely, Vale planning and Council appear to see no problem here whatsoever.

I am writing to object to the Vale of Glamorgan Council's Replacement Local Development Plan.

I strongly feel that all the key sites stipulated are unsuitable and inappropriate. The entire strategy behind the deposit plan is flawed and the process needs to begin again.

I also express deep concern that the public have been unable to easily access material owing to the ways it has been published. The average person has not been able to adequately consider all of the information within the consultation period. As such the public need more time to produce their consultation responses and at the very least, the consultation period must be extended.

I submit a formal and unequivocal objection to the proposed residential development of approximately 376 dwellings on the 18.73 hectare site at North West Barry. While the need for housing, including affordable housing, is acknowledged, the scale and location of this development will place unacceptable and unsustainable pressure on existing infrastructure, public services, educational provision, and the natural environment. The proposal fails to satisfy the requirements of Welsh planning policy and does not demonstrate that the town of Barry possesses the capacity to absorb such a significant population increase without serious and long-lasting harm.

**Conflict with Welsh Planning Policy**Under Planning Policy Wales, development must follow the principles of sustainable placemaking and ensure that infrastructure, services, and environmental protections are in place to support population growth. The proposal fails to meet these fundamental requirements.

Planning Policy Wales states that development must:

* Deliver sustainable locations with adequate infrastructure * Protect and enhance biodiversity and green infrastructure * Avoid placing unacceptable pressure on public services * Promote sustainable transport and reduce reliance on private vehicles

The current proposal fails to demonstrate compliance with these principles. No clear, binding commitments exist to deliver the infrastructure, educational capacity, healthcare provision, or environmental protections required to support 376 additional dwellings.

Furthermore, the Future Wales - The National Plan 2040 emphasises sustainable growth, protection of green infrastructure networks, and resilience to climate change. The large-scale development of open land on the edge of Barry directly conflicts with these objectives.

*Severe Pressure on Local Schools*

The proposed development will directly intensify existing pressures on local educational facilities. Schools within Barry already operate under high levels of demand, with waiting lists and limited capacity in several year groups.

Secondary schools such as *Whitmore High School* Pencoedtre High School* and *Ysgol Gymraeg Bro Morgannwg** already serve expanding catchment areas and face increasing enrolment pressure.

The addition of approximately 376 dwellings will generate a substantial number of additional school- aged children. Without the construction of new school facilities or significant expansion of existing schools, classroom overcrowding will intensify, waiting lists will expand, and local families will face reduced access to education within their community.

Planning authorities have a statutory duty to ensure that adequate educational provision exists before large residential developments are approved. This proposal fails to demonstrate that sufficient educational infrastructure accompanies the planned housing.

*Inadequate Healthcare Capacity**

Primary healthcare services in Barry already experience substantial demand. Local GP surgeries operate under capacity constraints and residents routinely experience extended waiting times for appointments.

The addition of hundreds of new households will significantly increase demand for GP services, dental care, community health provision, and pharmacy access. Without the simultaneous development of new healthcare facilities and additional medical staff, residents will experience worsening access to essential healthcare services.

This directly contradicts the planning principle that population growth must be matched with proportional expansion of public service capacity.**Transport Congestion and Infrastructure Failure*

The proposal recognises that *Weycock Cross Roundabout** already experiences significant congestion during peak commuting hours. This junction serves as a critical traffic node for the town and regularly experiences heavy queues.

The development will generate a substantial increase in daily vehicle movements connecting to A4226 Port Road West* intensifying congestion and reducing road safety.

Transport studies across the United Kingdom consistently show that new suburban housing developments increase vehicle dependency and traffic volumes. The Department for Transport** reports that suburban households typically generate multiple car journeys per day, particularly where employment centres are located outside the immediate area.

Incremental modifications to junction layouts do not address the structural limitation of a road network already operating close to capacity. Increased congestion results in longer commute times, greater accident risk, and elevated vehicle emissions.

*Environmental Damage and Biodiversity Loss**

The development site currently provides open land which contributes to ecological stability, wildlife habitats, and natural biodiversity. Urban development of this land will permanently disrupt ecosystems, fragment habitats, and reduce biodiversity levels.

The *Intergovernmental Panel on Climate Change** identifies land-use change and urban expansion as major contributors to biodiversity decline and environmental degradation. Once natural landscapes are replaced with housing infrastructure, ecological restoration becomes extremely difficult.

Furthermore, research from the UK Centre for Ecology & Hydrology** demonstrates that green spaces surrounding towns provide essential ecological services including flood mitigation, carbon storage, air purification, and wildlife corridors.

Development of the site undermines these environmental functions. Even when partial open space remains within housing developments, ecological quality declines significantly due to human disturbance, light pollution, and habitat fragmentation.

*Flood Risk and Drainage Concerns**

Open land naturally absorbs rainfall and reduces surface water runoff. Replacing permeable land with roads, roofs, and hard surfaces increases the risk of surface water flooding.

Research from the Environment Agency demonstrates that urban expansion significantly increases stormwater runoff, placing pressure on drainage systems and increasing flood risk in surrounding areas.

As extreme weather events become more frequent due to climate change, preserving permeable green land becomes increasingly important for managing water flow and protecting surrounding communities.*Climate Change and Carbon Impact**

Large-scale housing developments increase construction emissions, energy consumption, and long- term transport emissions. Construction materials such as concrete and steel generate significant carbon emissions during production.

The Climate Change Committee has emphasised the need for the UK to reduce emissions associated with land-use change and construction in order to meet legally binding climate targets.

Encouraging further suburban expansion that relies heavily on private vehicle travel conflicts with national climate commitments and undermines sustainable development objectives.

Loss of Local Character and Community Identity**

Barry possesses a distinctive character shaped by its historic development pattern, surrounding landscapes, and established communities. Rapid large-scale residential expansion risks eroding this identity and replacing it with dense housing estates disconnected from the town's traditional structure.

Sustainable placemaking requires balanced development that integrates infrastructure, community facilities, and green space. Housing-led expansion without equivalent investment in social infrastructure undermines community cohesion and reduces overall quality of life.

**Impact on Existing Residents*

Residents already living in the surrounding area will experience significant and direct negative impacts including:

* Increased traffic congestion and road safety risks * Overcrowding within local schools * Reduced access to healthcare services * Increased noise and air pollution * Loss of nearby green space and natural landscape * Additional pressure on public services and community resources

These consequences directly reduce the quality of life for existing residents who rely on already stretched local infrastructure.

*Conclusion**

The proposed development at North West Barry fails to satisfy the fundamental requirements of sustainable planning under Welsh national policy. It places severe pressure on schools, healthcare services, transport infrastructure, and environmental resources while offering no credible guarantees that these systems will expand proportionally.

The development also conflicts with national environmental objectives, contributes to biodiversity loss, increases flood risk, and undermines climate commitments.

For these reasons the proposal must be rejected in its current form. Any future development must demonstrate full compliance with national planning policy, provide new educational and healthcareinfrastructure, deliver genuine environmental protection, and ensure that Barry's community, infrastructure, and environment are not placed under unsustainable pressure.

* Accessibility and Fair Consultation Concern**

The consultation process for this proposed development raises serious concerns regarding accessibility and fairness. The objection form provided for public responses is difficult to access and not user-friendly, which creates a barrier for residents wishing to participate in the consultation. Under * *Town and Country Planning (Local Development Plan) (Wales) Regulations 2005 , planning authorities must ensure that consultation procedures are accessible and allow meaningful public participation. Additionally, the principles of public participation set out within Planning Policy Wales** require planning authorities to provide clear, transparent, and inclusive consultation opportunities so that all members of the community can engage with the planning process.

Where consultation mechanisms are difficult to locate, inaccessible, or overly complex to use, this restricts the ability of residents to submit representations and undermines the legitimacy of the consultation process. Public consultation must be conducted in a manner that is fair, transparent, and genuinely accessible to the community affected by the proposed development. If residents face barriers when attempting to submit objections or feedback, the consultation cannot be considered fully compliant with the principles of meaningful public engagement required in the planning process.

The sheer volume of documents to understand on the web pages has made it very difficult for average locals to understand fully.

Context:
This consultation feedback submission has been produced by Mr. David Richard Barton, also known as Community Campaigner David Barton who is promoting both the existing Built Historic Environment and Traditional Vernacular Architecture (TVA)/ Traditional Architecture (TA) as a key feature across UK and Ireland-wide Local Authorities and associated Planning Departments at all tiers of Local, Regional and Central Government.
This universal consultation therefore acts as an official Representation at all and any stage of official area UK Planning Consultations- Preliminary Scoping Documents, Named Stages of the Local Plan, Conservation Area Appraisals and Supplementary Planning Documents (SPDs), primarily regarding Design Codes.
Representations are being made by Mr. Barton as part of his ongoing work to champion the key stakeholders at various key areas old and new with a view to supporting their economic growth through the merits of High-Quality style Conservation with the hope of encouraging wider constructive and restorative support through positive and constructive working.
It is submitted that TVA should play a key part in any and all policy moving forwards on the grounds of conferring practical benefits be these periodic maintenance, their perceived support from the public, their invaluable contribution to achieving Climate Crisis Targets set local, nationally and internationally alongside their overall cost-effectiveness to key stakeholders alike in terms of Planning and sourcing of raw materials.
*One primary document that should be considered with significance especially alongside my own representation is a written academic account of the actual practicalities associated with Traditional Architecture from a leading expert in their field.i.) Not only does this in-depth analysis provide an in-depth take on the widely assorted merits of this type of Architecture but it fully corroborates my case made across all sections typically found in one of the consultations highlighted above.
Furthermore, my representations to date and contained herein this document are duly supported by the Founder and Director of The Institute for Traditional Architectureii.) who has identified and recognised my own contribution(s) to communities up and down the Sefton Borough. This is an internationally acclaimed organisation which periodically works with other leading agencies and organisations to bring about effective positive change.
Outlined throughout Submission are responses to existing Consultations which set out why I consider amendments to existing Planning Policy documents are necessary to ensure the best possible outcomes.
References to supporting documents are contained in the indented blue numbering.
This Submission has been prepared for UK and Ireland-wide Local Authorities in the hope that it may serve as an umbrella representation by Mr. Barton. This does not prejudice his ability to also comment on live stages of any one Consultation, merely providing the ability to be put in touch directly with any one Local Authority in receipt of this Representation with the prospect of also taking part in any version(s) of Consultations begin ran by said Local Authorities. If there are future consultations, especially regarding Design Codes and SPDs relating to this across both designated and non-designated heritage assets then it is hoped that these are duly provided to Community Campaigner David Barton.
Mr. Barton has cited material references and sources from his previous Representation to the Bootle Area Action Plan Consultation (2021-2026) that align with his existing and ongoing points which he would like to raise in parallel with other Local Authorities. Where a more detailed discussion with leading sources, such as Architects and Academics may prove conducive with these Councils then Mr. Barton would be delighted to discuss this further.
Community Campaigner David Barton:
Community Campaigner David Barton is a Heritage Campaigner of over 11 years’ experience who has championed and led a number of successful campaigns to promote TVA in modern-day life. His dual mandate is to provide effective (alternative) use of historical buildings encompassing a full restoration alongside achieving the mainstream construction of new classical architecture on numerous economic, environmental and ecological grounds that align with existing policy set out by Central Government covering the UK and increasingly elsewhere across the world.
Having worked with a wide array of residents, businesses and organisations in that time, which has included the full restoration of the Victorian Verandahs on Lord Street, Southport in tandem with the respective key stakeholders and other property owners to prevent demolition of Old Builds across Sefton, Mr. Barton is now hoping to make the process of utilising the built environment to its fullest potential a far simpler one that will enable Bootle to fully reach its maximum potential as a historic town.
SECTION 1: Design Codes:-
1. Design Codes based on TVA should be utilised in preference to Design Guides
2. LAs should establish recurring partnerships with key Consultation Bodies, such as Create Streets and The King’s Foundation, etc who specialise in getting through to a huge swathe of grassroots members of the public with tried and tested previous experience in Local Plans, such as Lichfield, etc.
3. Non-demolition of historic buildings prior to the 1950s must be made policy or adhered to as part of LCC’s commitment to combatting the Climate Crisis through sequestering carbon in its Old Builds.
4. LAs should adopt a Local List of Valued Buildings (Non-designated Heritage Assets), which have been a Government requirement since the policy introduction through the NPPF in 2012. Historic England produced a guide to help Councils in May 2012. Bristol produced an exemplar list in 2015, which is well worth reviewing.
5. Existing Action Plan if present for Designated and Non-designated Heritage Assets needs identifying and/ or establishing (I may support this if invited).
6. Option for people to provide feedback even if out of time for additional documents, such as SPDs or at the discretion of Councils where feedback may be particularly assistive or lead to additional academic and architect guidance. Option for public publishing of feedback should be encouraged with the consultee’s consent to encourage wider consultation uptake moving forwards.
7. Era-style Buildings, especially rows of Georgian, Victorian and Edwardian architecture must be faithfully restored, retained and recreated to complement surrounding historic streets that may or may not be classed in official Conservation Areas preventing harsh contrast with newer built housing estates from the 1950s onwards.
8. Where demolition is proposed for 1950s style housing onwards- any new construction must be in the historic building style and local materials to ensure high carbon capacity, quality aesthetic and true blending of the interconnected conurbations of any one area, place or location.
9. Concerted efforts to identify and locate core suppliers for raw materials and specific heritage skills should encourage new uptake of these limited artisan craft skills by new contractors locally based to support the local economy, provide employment, and reduce the cost of product and service in the long-term.
10. Volunteer labouring assemblies should be fully encouraged and supported identifying key individual an group skillsets that can be utilised to protect historic buildings or areas at risk with a view to supporting the construction of new authentic style housing (as and where appropriate) and the reconstruction of demolished prized old buildings beloved by the community, such as community pubs, libraries and community centres.
11. Simplified streamlined Planning Process for key stakeholders either working to authentically restore buildings and/ or build new ones, such as observed with many civic buildings in Budapest Hungary and the Federal University Buildings in the US.
12. Where there have been evolving building styles over years, eg. Combination of one or more: Georgian, Edwardian and Victorian, the style that best promotes the area, ie. One that has the majority era structures left or capacity size requirements as examples should be utilised by house builders, especially where a streetscape may have been annihilated during the World Wars.
SECTION 2: Designated & Non-Designated Heritage Assets:
1. Enhancement of Historic Areas to remove modern street furniture with the integration of classical style timepieces should be encouraged and pursued wherever possible with clear preferred guides set out for each part of the City.
2. Enhancement of Setting with funding grants and financial incentives from all tiers of Government for Private Investors especially those contributing actively towards achieving Net Zero through Embodied Energy/ Carbon Capacity rich measures, i.e. Retention of Old Builds.
3. Archive Pooling of invaluable source material, such as Historic Photographs, Oil Paintings, such as “Memory Lane” featured on InYourArea Magazine to enrich existing material archives.
4. New officialising of Non-Designated Heritage Assets must be actively supported even if informed by the (wider) community thereby providing some possibility of removing these from risk of demolition.
5. Incentives must be provided to those dependable sincere third party investors that take on, maintain and protect said sites against their annihilation from the streetscape with rescue-packages actively promoted and supported once again with a trusted Directory creating goodwill amongst the local community.
6. Opportunity to meet or correspond on Zoom Conference Call regarding key areas, buildings and places at risk where key stakeholders, such as property owners may be better placed to engage in positive and constructive discussion through third parties, such as myself and a trusted panel of experts in their fields and sectors who could enable these people and organisations to maximise their civic heritage, whilst proactively striving to protect more historic buildings from decline and/ or demolition where a strategy package for raising the revenue to do this could be arranged and facilitated.
7. Defining Character Areas- zoning symmetrical parallel construction recommended where distinctive individualised properties remain as checked against authentic archive blueprints. This will ensure high-quality housing for everyone reducing the societal divides between misperceived “good areas” where affluent people reside in historical style properties and less advantaged reside in contemporary ones.
8. Industry should be conserved at former industrial complexes, such as Economic Docks with equivalent sites offering modern-day uses, alongside traditional uses such as export and import of raw materials at places such as Docks and Port encompassing: ICT sector, Green Research & Development, etc.
9. Every effort must be made to reach out to Property Owners, especially Housebuilders that are pursuing demolition of long-beloved buildings, especially those with demonstrable evidence of Holy Worship.
10. Every effort must be made to reach out to Property Owners, especially Housebuilders that are pursuing demolition of landmark buildings, especially those with key links to an area’s founding or history locally.
11. All Powers to monitor, collaborate with existing and/ or new property owners to conserve these buildings should become mandatory with appointed Community Champions for Civic Heritage that area direct link between Local Authorities and said wider key stakeholders to prevent demolition of structures that may be at risk of destruction from vandalism, urban exploration and demolition.
12. Reconstruction Programme harnessing existing limited crafts people’s skillsets to be used as a fundraising vehicle to bring back buildings that may have been demolished to dissuade future demolition as a choice by property owners and by means of expanding these otherwise lost skillsets that are at live risk of becoming extinct from the UK.
13. Checklist of buildings at high risk must be expanded beyond the existing groups and organisations that are saturated with high caseloads, such as SAVE Britain’s Heritage, etc so that dialogue channels can be created and fostered between Community Champions for Civic Heritage.
14. Bespoke-tailored funding packages for Properties at Risk of decline or demolition should be integrated with Local, Regional and Central Government-funding as a means of regional economic output through the return on investment that may support other key grant funding capital infrastructure projects, such as transportation and drainage improvements.
SECTION 3: Conservation Areas:-
1. Alterations for Listed Building Consent must be simplified with additional streamlined testing methodologies, such as proof of legitimate third party support, such as correspondence chains between applicant and Groups, such as The Victorian Society that can assist LAs complete workload much sooner allowing more attention for challenging cases, such as Non-Designated Heritage Assets at live or upcoming risk of demolition by Housebuilders, etc.
2. Highways & Street Furniture should be duly supported across the whole of an area to enhance its historic appeal to the commercial community as much to its indigenous community; as this is supported greatly in equivalent Public Realm Strategy SPDs- where any and all guidance and support must and should be provided, with key at risk projects being an exceptional anecdote that may be cited in future documents or versions of this and other consultations to stimulate economic construction and restoration across other designated Conservation Areas, etc or otherwise.
3. Provide incentives for the return of lost adornments and decorative features, such as roof fixtures like Chimney Stacks once again with an approved contractor directory to make Old Builds practical to own, live and work in the 2020s onwards. If a Directory cannot be provided then specific wording and guides on esoteric restoration and new traditional building styles that would see modern-day use of decorative features must be provided by the Local Council.
4. Permissions for authentic replica and more durable materials, such as reproduction sash windows must be supported to prevent exorbitant high costs through procuring these, limited longevity and economic climates being unstable. This must be assessed on a case by case basis.
5. No more deliberate manipulation and selective misinterpretation of using contemporary modern designs using old-style fabric raw materials, such as stone cladding for new housing where the design and shape clearly undermine the concept of blending within or around a Conservation Area.
6. Compendium of approved and recognised TVA Architects based across the UK with a view to supporting the training in time of more Northern counterparts to reduce cost associated with travel expenses, etc. This will actively reduce the level of demolition applications countering the purpose of this SPD and other live Policy. If a Directory cannot be provided then specific wording and guides on esoteric restoration and new traditional building styles that would see modern-day use of decorative features must be provided by the Local Council.
7. New Conservation Areas should be established covering areas of surviving built historic environment to positively reverse fascia changes to more modern ones.
8. Blue Plaques should be fully supported across as many different Conurbations, especially if Applicants reach out for endorsements.
9. Discretionary Rate Relief should be provided to those proactively support LAs with conserving their respective Conservation Areas through their own resources, skillsets and time as an incentive to others to work alongside the Council positively and constructively.
10. Where long-lost prized buildings are reconstructed whether based in a Conservation Area or not this should confer discretionary financial support, e.g. Rate Relief for the length of time taken to produce this outcome acknowledging the embodied carbon now contributing positively towards the LA’s Climate Change Action Plan Targets.
11. Retention of historic street furniture, such as Lamp Posts adorning high streets or Promenade style streetscapes with collaborate fundraising models utilised from key stakeholders, such as property owners, undisclosed third party investors, Residents’ Groups, etc.
12. Retention of historic street furniture, such as Lamp Posts adorning high streets or Promenade style streetscapes with authentic identical reproductions permitted where all options to secure finance have been fully exhausted and/or the existing streetscape is at imminent risk of receiving contemporary replacement street furniture on health and safety grounds, eg. Lap Posts.
SECTION 4: Climate Change:-
1. Pleased to note that LAs broadly acknowledge and grasp this concept therefore the aim should be to increase the net number of carbon-rich Old Builds long-term through support packages that will combat the Climate Crisis, provide economic benefit and improve Conservation in a pioneering fashion that may draw wider funding opportunities for the area.
2. Retrofit Ventilation is a key point that should warrant future new construction utilising higher ceilings through the reconstruction of Old Builds outfitted for the modern day with retrofitted energy supplies, etc that will also serve to break down societal dives regarding perceived good and bad areas where streetscapes are harmonious yet distinctly unique in beauty like any one Conservation Area.
3. Embodied energy and embodied carbon- must remain a central priority and so influence new construction to readopt TVA principles as this will be pivotal towards the area’s future green credentials as outlined in many existing auxiliary planning documents approved presently with Carbon Studies taken of existing architecture, notably buildings saved from demolition.
4. A brick by brick case study of as many buildings as possible may warrant invitation of national and international academic institutions to undertake a regional or national Carbon Study further justifying the retention of prized Old Builds elsewhere across the area, region and the UK.
5. Sustainable Materials- an approved contractor directory that could readily advise and source the necessary raw materials with realistically reduced costs substantially again deterring potential demolition-driven applicants from consuming workload time of the Planning Department. If a Directory cannot be provided then specific wording and guides on esoteric restoration and new traditional building styles that would see modern-day use of sustainable materials must be provided by the Local Council.
6. Biodiversity- maximise greenery along all arterial roads ad commuter routes with dense tree planting and the introduction of hedgerows and wherever possible financial incentives to get more private property owners on side.
7. Flooding Defences- existing and prospective hotspot areas should be clearly identified for emergency grant funding whereby Local Authorities, especially across a region may agree with the respective Government Department to distribute emergency flooding to prevent costly consequential recurrent repairs.
8. Transportation using arterial roads and commuter routes (Motorways and Railways) should prioritise linking each end of a Local Government sphere with the surrounding Local Government spheres, such as Southport at the very northern tip of Merseyside where transportation links are much weaker with Lancashire in the north and east than with the rest of Merseyside to the south.
9. Coastlines should be reclassified as SSSIs, especially where the economic potential is not being fully realised, such as Coastal Towns with underused Beaches, such as Southport in Sefton as one example for other LAs.
10. Financial Incentives for the demolition of Carbon-poor Glass Towers and contemporary construction should be utilised to restore the skylines across any one area whilst providing better mathematical application of the space for residential and commercial use, such as larger tenement buildings or the original streetscape reinstated yet designated specifically for housing where there may be a deficit.
SECTION 5: Historic Buildings:-
1. Create a Designated AND a Non-Designated Heritage Asset List, such as AHV whereby existing buildings and those that may yet return can be logged and recorded to combat the Climate Crisis whilst making heritage work for LAs in modern day with attractive locations timeless for everyone to appreciate enhancing the investor appeal, all-round interest and acknowledging the industrial pioneering legacy of the City.
2. Clearance of vegetation along the Railway Lines alongside other equivalent parts of the Line to eradicate the perceived neglected aesthetic.
3. Exception Areas, such as those at risk or recently restored have the real potential for wider grant funding for ambitious projects out of the realm necessarily of undisclosed third party investors supporting Property Owners, therefore all and any support in reaching these person(s) will greatly contribute to all possible tangible success in the interim period.
4. Providing key guidance, such as agreed in-keeping historic street furniture, such as Cast Iron Lamp Posts, Bins, Planters approved upon inspection of historic photographs, agreed installation and where appropriate maintenance by the LA will ensure the iterative success of this transferring to other Conservation Areas, etc.
5. Scheme to rebuild and reconstruct long-lost buildings, prioritising vacant sites that could adapt some mixed use with residential accommodation and commercial application thereby supporting Climate Action, creating employment and recordable success through placing of necessary economic drivers, such as offices for Technology Sector if original use cannot be sourced in sufficient time simultaneously meeting housing targets.
6. Archive Blueprints for historic conurbations that have suffered architecturally over time through building conversions, demolitions, etc should be provided to key stakeholders, if necessary with a printing charge available for official spiral hard copy version to view detailed historic plans covering layouts, etc.
7. Those people and organisations that have either/ both maintained their properties well over the years or may wish to provide additional support to others, such as restorative support, archive blueprint guidance, etc should be eligible for discretionary reductions by the Council across various property taxes where they may be suffering hardship or through personal circumstances.
8. “Newer” style housing with true authentic rhythm, such as Suburban style faux Tudor fascia frontages with red clay tile pitched roofs and terracotta design windows (tile hung walls) are a good compromise whereupon finance and scheduling may otherwise adversely impact on housing settlements.
9. Fascia Frontage details should be reinstated whether in a Conservation Area or not, especially where approval has been granted to rebuild an entire house using breeze block to produce a stereotypical black, white and grey dwelling out of place.
10. LAs should work closely with Foundries to procure raw materials and building services in the event of harnessing their own Contractor Firm(s) in-house that could work cross-authority to make net savings whilst ensuring particular new housing neighbourhoods conform to an appropriate style.
11. Modern “Carbuncle” extensions should not be permitted at any one area- instead an authentic style addition may be used to retain blending.
12. Discretionary financial support packages to assist House Builders choosing the traditional vernacular route should be considered and utilised where it can be proven that this third party will restore the historic streetscape yet making it applicable or modern day requirements- residential or commercial. This may be especially so where they are able to help others prevent the demolition of a prized Old Build built before the 1950s.
SECTION 6: Traditional Vernacular Architecture:-
1. Provide a directory of approved and trusted Conservation Specialist Contractors- this will be key for repairs and maintenance reducing costs for all parties, expediting the physical process of regeneration and smoothen planning work schedules so that finer detail may be considered on priority cases or those that may be at risk of consequential repair, such as Places of Worship and detached Buildings with flat roofs, etc at higher risk of damage than customary dwellings.
2. These same people should be readily contactable for new construction
3. Encourage smart building methods and use of TVA as meticulously explained in this SPD outlining “Breathing” Solid Wall Construction using older style materials thereby reducing maintenance cost which combined with the approved contractor directory will further drive down costs, time and effort for everyone.
4. Alterations- must introduce a simplified listed building consent form and application process that is streamlined encouraging better maintenance of Old Builds and reducing the rising propensity of builders to allow buildings to deteriorate, such as the Historic Pub that had to be rebuilt in Kilburn, London post 2015.
5. Provide specialist Heritage Arts & Craft Skills Programmes that anyone can learn and use so that these high cost tasks can eventually stabilise in price making them more affordable and available to those that don’t have the time to do this themselves or may be risk averse even.
6. Extensions- there must be a proactive emphasis on in-keeping structural fabric to prevent future errors, such as the Municipal Building depicted in the SPD being replicated again thereby harming the Conservation value.
7. New Housing Estates should adopt historical archival blueprints, ie. A Georgian, Victorian or Edwardian layout with the likeliest period architecture utilised where this area remained greenbelt until the 1950s.
8. Area Expansion of housing must revert to traditional timeless designs that confer many practical advantages over modern styles that are harder to maintain are timeless with regard to dating and ensure a more evenly distributed community atmosphere in the long-term future.
9. Infrastructure should be appropriately considered for existing and new areas so that no one area is at risk of becoming congested through traffic for a particular commodity, such as Schools, Doctor Practice, Dental Practice, etc.
10. Site Layouts should complement the historic layout with a view to Post 1950s contemporary Architecture out of place being one day demolished to reinstate Long-lost beloved buildings from before the World Wars that could blossom economically today.
11. Building Form shouldn’t permit for dated modern structures that delineate and essentially divide communities between the old and new parts of any one location.
12. Façade Design mustn’t be compromised for contemporary architecture, especially in view of coveted Heritage Status for any one area being at risk of being lost if said contemporary architecture is pursued.
SECTION 7: Making an application:-
1. Identify recurring applicants that are harming civic heritage, be this across Conservation Areas, Non-designated heritage assets or elsewhere with experience of demolition to date- this should be considered before granting permission to apply or acquire planning approval.
2. Enforcement Penalties for key stakeholders that purposely allow their properties to fall into decline and hoped eventual demolition through this tactic, which is more prevalent since 2020.
3. Create an Action Plan to deter persons or organisations from pursuing demolition, such as financial incentives, sincere investor network directory set by Central Government to offload for profit and enforced Design Codes that cannot be manipulated through semantics like Design Guides in isolation as has happened elsewhere. This must be kept for emergency instances where there is an expected threat of decline or demolition.
4. Agreed that temporary alteration of heritage sites, such as stairs or ramps for wheelchairs should be utilised to prevent deleterious loss of historic surroundings and features alike.
5. Full Pre-Consultation publicised and utilised to ensure appropriate Design Codes for new housing alongside positioning and layout in case volunteer assemblies may assist property owners with restoration of historic buildings.
6. Brick by brick Analysis undertaken of projects set for Traditional reconstruction so that these statistics may provide both the Council with evidence for green grant funding support for other key infrastructure projects, such as Transportation and
Drainage Defences and property owners may incur a discretionary reduction in associated reconstruction costs of heritage buildings and vistas.
7. Ability to lock feedback in for Consultation automatically unless the council can alert interested consultees in taking part again whether they are locally, regionally or nationally based.
8. Special partnerships with Property Owners of historic buildings at risk of decline/ demolition to discreetly support them with the option to publicise this accordingly to reach out to others in the same position to secure alternative use for these structures as opposed to demolition.
9. Proactive effort to stop Breaking and Entering style of “Urban Explorers” who are coincidentally apparent whenever demolition is scheduled for buildings especially since 2020.
10. LAs to proactively work closely alongside Community Champions and other leading Heritage Groups, such as English Heritage giving these organisations a voice on the frontlines, especially where so many buildings are presently being overlooked for additional guidance and/ or support due to cost and time restraints facing these same groups and organisations (including the LA).
SECTION 8: MISCELLAENOUS:-
1. Provide all possible support for the reconstruction of Old Builds as is happening elsewhere across Europe, especially Budapest, Hungary, North America, etc to significantly increase Embodied Energy/ Carbon storage.
2. Establish a Plan to adopt Unadopted Roads or supply key services, such as carriageway resurfacing as disabled access and entry/ exit of Emergency Vehicles is presently a cause for concern.
3. Provide Pre-Approval and agreement of specialist Conservation Area style Historic Street Furniture, such as Cast Iron Lamp Posts, Bins and Planters for this prime Conservation Area including installation, maintenance costs (where appropriate).
4. Provide full access to the Archive Resources (at no/minimal cost) as an invaluable incentive for existing and parallel undisclosed third Party Investors. Discretionary waivers may be appropriate for those third parties proactively working to prevent decline and demolition of historic buildings.
5. Car Parking on and off street should be supported to ensure freedom of choice for everyone, accessibility and connectedness.
6. Car Parking abodes should be tastefully designed like modern-day stables for vehicles that are in-keeping with the built historic environment.
7. Provide publicly published names of consultees willing to work alongside the Local authority and other key stakeholders, such as property owners and undisclosed third party investors, etc.
8. Provide select tours for prospective investors and housebuilders of existing traditional architecture where Design Codes of this identical style would complement both old and new architecture bending the area better more cohesively, eg. the form and layout of Oxford City Centre which has changed minimally structurally since the 1800s.
9. Provide a focused effort on utilising people’s skillsets on a meritocratic basis, ie. Procure specialists and volunteers that could work together on key emergency projects, such as Historic buildings at risk without layered bureaucracy on achieving positive outcomes, such as Community Assets where deadlines can be thwarted by separate third parties.
10. Create a Top Ten Historic Buildings at Risk Register where appropriate conditions, such as security against Urban Exploration, etc can be utilised safeguarding these structures, providing the respective property owners peace of mind whilst actual scope for revitalising these for solid economic gain.
11. Infrastructure assessments should be fully outlined, such as Air Quality risk from new construction at presently congested areas, hence the case for Traditional Architecture that will confer longevity benefits in the long-term with as much free car parking as possible.
12. Free Car Parking may be monitored through expected proof of purchase when visiting, eg. minimal £1.00 at a shop encouraging partnerships between private businesses and LAs.