Thank you for consulting the Welsh Government on the Vale of Glamorgan Council Replacement Local Development Plan (LDP) – Deposit Plan. It is essential the authority is covered by an up-to-date LDP to give certainty to local communities and businesses and provide a robust basis for decision making.
Without prejudice to the Minster’s powers, the Welsh Government is committed to assisting Local Planning Authorities (LPAs) minimise the risk of submitting unsound plans by making comments at the earliest stages of plan preparation. The Welsh Government looks for clear evidence that the plan is in general conformity with Future Wales: The National Development Framework, aligns with Planning Policy Wales (PPW) and the tests of soundness, as set out in the LDP Manual.
National planning policies are set out in Planning Policy Wales (PPW) Edition 12 and seek to deliver high quality, sustainable places through a place-making approach (the LDP should ensure it takes into account any further iterations of PPW prior to the examination). The implementation of the core policy areas in PPW, such as adopting a sustainable spatial strategy, appropriate housing and economic growth levels, infrastructure delivery and place-making, are articulated in more detail in the LDP Manual (Edition 3). We expect the core elements of the Manual, in particular Chapter 5 and the ‘De-risking Checklist(s)’ to be followed. Failure to comply with these key requirements may result in unnecessary delays later in the plan making process. The development planning system in Wales is evidence-led and demonstrating how a plan is shaped by the evidence is a key requirement of the LDP examination.
After considering the key issues and policies in Future Wales, the Welsh Government is of the opinion that the Replacement Deposit Plan is in general conformity with Future Wales: The National Development Framework. Specific comments are set out in the Statement of General Conformity (Annex 1 of this letter). Annex 2 highlights a range of issues that need to be addressed for the plan to align with PPW and the DPM. Collectively, our comments highlight a range of issues that need to be addressed for the plan to be considered ‘sound’ as follows:
Annex 1 – General Conformity with Future Wales
• No significant concerns
Annex 2 – Core matters that need to be/have been addressed (PPW and the DPM)
• Spatial Strategy and Primary Settlements
• Housing and Economic Growth Levels – Regional Collaboration
• Maximising Affordable Housing Provision
• Delivery & Implementation – General
• Gypsy and Travellers
• Renewable Energy
• Minerals
• Best and Most Versatile Agricultural Land (BMV)
• Welsh Language

I would urge you to seek your own legal advice to ensure you have met all the procedural requirements, including the Sustainability Appraisal (SA), Strategic Environmental Assessment (SEA) and Habitats Regulation Assessment (HRA), as responsibility for these matters’ rests with your authority. A requirement to undertake a Health Impact Assessment (HIA) arising from the Public Health (Wales) Act 2017, if appropriate, should be carried out to assess the likely effect of the proposed development plan on health, mental well-being and inequality.
My colleagues and I look forward to meeting you and the team to discuss matters arising from this response.
Yours sincerely,
Neil Hemington
Chief Planner Welsh Government

Annex 1 - Statement of General Conformity
The Welsh Government is of the opinion that the Vale of Glamorgan Council Replacement Local Development Plan (2021-2036) Deposit Plan is in general conformity with the National Development Framework: Future Wales, as set out in paragraphs 2.16 – 2.18 of the Development Plans Manual (Edition 3).
There is a joint position statement on the relationship between Bridgend, Cardiff and the Vale of Glamorgan (BP20A), which considers population growth, migration patterns, housing completions, employment characteristics, demographics, commuting and transport links between the three adjoining authorities. The Welsh Government supports the principle of this work which demonstrates how change in the Vale of Glamorgan relates and complements growth in adjoining local authorities. This approach illustrates a good mechanism for other local authorities to follow.
Reasons
Future Wales places emphasis on the development of National Growth Areas in a sustainable manner. Growth areas must be sustainably planned, reduce the need to travel by car, encourage walking and cycling (active travel), maximise public transport usage and incorporate green infrastructure. Growth areas must embed these principles within a wider regional consensus, focussing on the opportunities they bring to promote social and economic benefits across a broader geographical area. The Welsh Government supports sustainable growth in National Growth Areas to respond to the climate change and biodiversity emergencies, making the best use of resources.
Policy 1 and Policy 33 of Future Wales states that Cardiff, Newport, and the Valleys will be the main focus for growth and investment in the region. The strategic diagram (p163) also identifies the Vale of Glamorgan within the National Growth Area. The Vale of Glamorgan RLDP, specifically BP20A, provides robust evidence on the interrelationship and key issues with adjoining authorities, including their interaction and how they have shaped and influenced the scale/location of growth in the RLDP. This is set out in the three Joint Position Statements (JPSs).
BP45 ‘Regional Assessment of Future Growth and Migration for the Cardiff Capital Region (CCR), May 2024, provides further evidence on how the scale of growth indicated for the region has shaped the scale of future economic growth within the Vale of Glamorgan. This results in a higher level of employment growth in the Vale of Glamorgan primarily to increase self-containment and reduce out-flows to adjoining urban areas. Two key areas for future economic growth are identified at Cardiff Airport/Bro Tathan Enterprise Zone and Aberthaw Power Station.
The result is a Sustainable Transport Orientated Growth spatial strategy focusing on the Cardiff – Bridgend railway line and A48 corridor, with the key settlement for growth at Barry, followed by service centres on public transport corridors. On balance, the Welsh Government considers the Deposit Plan is in general conformity with key policies in Future Wales namely (not exhaustive):
Policy 1: Where will Wales grow
Policy 2: Shaping Urban Growth and Regeneration – Strategic Placemaking
Policy 6: Town Centre First
Policy 10: International Connectivity – Cardiff Airport
Policy 12 Regional Connectivity
Policy 33: National Growth Area – Cardiff, Newport and the Valleys
Policy 36: South-East Metro
Future Wales brings a new perspective that all LDPs have to embrace on how each LDP sits within the region as a whole and the relationship to other LDPs, in essence, a strategic approach to cross boundary relationships. There is evidence to support that approach in advance of an SDP. 4

Annex 2 – Core matters that need to be addressed (PPW and the DPM)
Spatial Strategy - Location of Growth
The Council tested 4 spatial options:
Option 1 – Continuation of the adopted LDP growth strategy
Option 2 – Dispersed Growth
Option 3 – Focused Growth
Option 4 – Sustainable Transport Orientated Growth
The Council has chosen Option 4: Sustainable Transport Orientated Growth for its Deposit Plan. The strategy seeks to locate most of the new growth in those settlements well served by existing/proposed rail infrastructure along the Vale of Glamorgan/Penarth branch lines. This will encourage and maximise the use of sustainable transport modes in the plans designated Strategic Growth Area (SGA). The SGA encompasses most of the Council’s largest and more sustainable settlements and the Council considers that focussing development here will reduce the need to travel and will co-locate housing with employment opportunities, services, and community facilities.
With a significant proportion of the Council’s brownfield land already developed/committed, there are limited opportunities for brownfield development moving forward. The existing land bank is stated as 5,140 dwellings (land supply 3,837 + windfall assumptions 1,303), to meet a proposed housing requirement 7,890 (provision 8,660). The authority has allocated 3,520 dwellings on new sites (Policy SP6, Table 2). As a result, the plan has adopted a predominantly greenfield strategy allocating the majority of new development on five key sites (Policy HG1, Sites KS1-5 totalling 2,278 dwellings) well-connected edge of settlement sites, close to existing or proposed rail stations. We note the Council has used TfW data in the site assessment process to assess sites and their proximity to transport nodes. The remaining sites are mainly ‘rolled’ forward from the adopted LDP. The Welsh Government supports the spatial strategy, which accords with Planning Policy Wales (PPW) and is in general conformity with Future Wales.
Spatial Strategy - Primary Settlements
The Council’s settlement hierarchy allocates circa 92% of all housing development (committed and proposed) to settlements in the top three tiers of the hierarchy. The Welsh Government does not object to this approach. The recognition that Culverhouse Cross with few facilities on site and the presence of BMV Land, the expectation for limited growth (paragraph 6.14 & 6.15) is welcomed. Similarly, it is noted that Wick benefits from a primary school and has some scope for future growth, albeit in keeping with the scale and accessibility of the settlement. The Welsh Government is content that the scale of growth reflected in these two locations will reflect the availability of local facilities and services.
The Level of Growth - Homes and Jobs
The Deposit Plan (Policy SP1 & SP6) makes provision for 8,660 homes to deliver a housing requirement of 7,890 new homes (526 p/a) over the plan period 2021-2036, of which a minimum of 3,070 homes will be affordable. The flexibility allowance proposed by the Council is 9.8%. The delivery of new jobs is for 5,388 over the plan period (Policy SP14).
Homes: The 2018 WG Principal Projection results in a requirement of 431 units p/a, or 6,465 units over the plan period. The housing growth proposed in the plan (requirement) is around +1,425 units (22%) above the WG 2018 principal projection, the provision being +2,195 (34%) above. The Council consider the 10 year average housing completions to represent a more realistic level of growth to deliver the key issues the plan is seeking to address. The Council considers that a lower level of growth (2018 projection) is not appropriate because the projections do not take account of 5

any policy decisions and were prepared in advance of the Covid-19 pandemic with implications for migration patterns and fewer jobs proposed.
BP8A (November 2025) considers the latest 2022 Welsh Government population and housing projections, noting they are higher than the 2018 based projections. The projections for the Vale of Glamorgan show significant variation in internal migration in particular which the Council considers should be treated with caution. The projections are trend based and are affected by specific factors that may have occurred within the previous 5 years. The 5 years in question included a period of high housebuilding associated with a newly adopted LDP, as well as the Covid 19 pandemic, where many students returned to home from term-time addresses and re-registered with GPs in the Vale.
Given the fluctuation in recent migration figures, the Council consider longer-term trends are more appropriate, and it is noted that the population change identified in the 10-year migration variant is of a similar level to that proposed under the RLDP projection. In conclusion, for the reasons identified above, despite the updated projections, the Council considers the RLDP housing requirement continues to represent a robust basis to deliver a sustainable and deliverable level of growth over the plan period. The Welsh Government does not object to the scale of housing contained within the plan.
The demographic evidence (February 2023, Edge Analytics) tested 12 growth scenarios comprising: demographic-led, dwelling-led, and employment-led scenarios. The preferred housing requirement is based on a 10-year dwelling-led scenario (526 dpa) that would result in a population growth of 9.7% over the plan period with an annual net in-migration of 1,009 persons. The Council considers this level of housing growth is deliverable with a large proportion met through existing commitments (51%) and a jobs total (4,875 jobs) that broadly aligns with the level of new jobs forecast in the Employment Land Study (5,338 jobs). Moreover, the scale of growth is considered by the Council to be compatible with Future Wales and the role the authority plays within the wider southeast region. With inward migration to the Vale of Glamorgan from Cardiff expected to slow as Cardiff’s strategic sites deliver higher levels of housing and with employment opportunities in the Vale co-located with housing sites, there are further opportunities to reduce the high levels of out-commuting into Cardiff. Overall, this approach is proposed by the Council to deliver a level of growth that is balanced with the emerging Cardiff LDP and wider southeast region. The Welsh Government does not object to the level of growth proposed in the plan.
We note that historic completion rates in the Vale of Glamorgan have fluctuated considerably over recent years. The past 10-year (2011-2021) average completion rate is 526 dwellings p/a. This has been exceeded over the last 5-years (2016-2021) with 698 dwellings constructed p/a. Build rates in recent years are in part attributed to the delivery of the current adopted LDP strategy that has more of a ‘rural settlement' focus, with multiple sites across many settlements being built out. Replicating this approach going forward (10,470 dwellings) would not comply with FW/PPW in terms of sustainable development and transport, potentially adversely impacting on Cardiff’s growth strategy. On this basis, the Council considers that achieving 526 dwellings p/a in the preferred 10-year dwelling-led scenario is sustainable and deliverable and would provide a level of job growth (5,338 jobs) that is balanced with the housing requirement. The Welsh Government does not object to the level of housing proposed in the plan but demonstrating delivery of the key housing sites will be essential.
The Welsh Government notes that BP0A identifies small and large windfalls, based on historic trends of 53/yr and 80/yr respectively. Also, the large windfalls are not included in the first two years of the trajectory, as per the DPM. A non-delivery allowance of 5% is identified, which reflects local characteristics in the Vale of Glamorgan. A flexibility allowance of 9.8% has been factored into the provision. The Welsh Government supports this approach, although whilst Appendix 1 contains a housing trajectory, there is no table to mirror that of Table 21, DPM. This should be included in Appendix 1. 6

Jobs: The Council’s 10-year dwelling-led growth option results in a requirement for 4,875 new jobs (325 p/a) over the plan period. This broadly aligns with the projected growth for 5,338 (355 p/a) new jobs in the Employment Land Review (BP12) and as set out in Policy SP14.
The level of employment growth proposed (5,338 jobs) over the plan period is below the target in the currently adopted plan (7,610-10,610 jobs). The lower target is considered by the Council to more accurately reflect the cohort of working aged people in the Vale of Glamorgan and would support a continuation of long-term housing delivery trends that takes into account lower housing growth post-recession and a shorter period of historically high dwelling completions (2016-2021). The Welsh Government does not object to the level of job growth proposed in the plan.
In summary, (and subject to the above clarification), the Welsh Government has no significant concerns with the level of homes and jobs proposed in the plan, which is in general conformity with Future Wales.
Affordable Housing Provision
The Local Housing Market Assessment 2023 (LHMA) (BP10B) calculates affordable housing need over the replacement plan period using the ‘policy neutral’ Welsh Government 2018 Principal Projection and the preferred growth option. The LHMA provides the latest evidence on affordable housing need, identifying a net annual need for 1,075 affordable units per annum for the next five-years and a further 154 units per annum over the following 10 years (BP10B, Executive Summary), resulting in a requirement for 6,915 affordable homes over the plan period (461 p/a) with a tenure split of 65% social rent and 35% intermediate. The Welsh Government note that the RLDP housing requirement is higher than the 2018 projections. Accordingly, to take this into account the affordable housing need for the RLDP is 502/yr which equates to a need of 7,530 over the plan period (RLDP, paragraph 6.116, Table 4).
Policy SP7 identifies a target of delivering a minimum of 3,070 affordable homes, the housing need being across all 13 Housing Market Areas, albeit it is more acute in Barry, Penarth, and Llantwit Major for 1-bed properties. The Welsh Government notes that most of the new housing development (51%) is proposed in the Key Settlement of Barry and Service Centre Settlements, which include Penarth and Llantwit Major.
The Welsh Government has no significant concerns regarding the relationship between the LHMA and the Deposit Plan.
Affordable Housing Led Sites
To deliver additional affordable housing above that which market led housing can provide, the authority proposes (Policy SP3 & HG4) to permit small scale affordable housing-led developments that provide a minimum of 50% affordable housing on sites up to 25 dwellings in minor rural settlements and 50 dwellings in primary settlements. The principle of this approach is supported.
Paragraph 6.137 of the plan states:
“Policy HG4 makes provision for affordable housing-led sites in locations outside the Strategic Growth Area. These sites, which are allocated for a minimum of 50% affordable housing, are included within the settlement boundary.”
The reference to being within the settlement boundary is not referenced in policy HG4. It would be beneficial to either include such a reference or demonstrate that settlement boundaries do include those sites listed in policy HG4 for clarity.
These sites must be in addition to the market housing led requirement and identified in the LDP. This policy approach is justified by the high level of affordable housing need evidence by the LHMA and must be accompanied by additional control over the land by the local planning authority to 7

ensure effective delivery. Evidence should include ownership of the land, a binding legal agreement where the land is in private ownership or a resolution of the council to use compulsory purchase powers. RLDP, paragraph 6.133 references to such controls, however, should such controls be contained within the policy?
Affordable Housing Exceptions Sites
Policy HG5, states 100% affordable housing exception sites can be located outside a settlement boundary where they comply with PPW/TAN2 and any threshold/policy requirements set in the Deposit Plan. The Welsh Government supports this approach.
Employment Land
The Council’s Employment Land Study (BP12, March 2023) identifies a requirement for 67.80ha of employment land, which includes a 5-year buffer. The requirement is based on rolling forward past trends (over 25 years) and is of a sufficient scale to meet the 5,338 jobs forecast. However, Policy SP14 identifies employment land allocations totalling 182ha, which is an increase of around 114ha above the employment land requirement. The sites that make-up this supply are largely major employment allocations that attract significant regional inward investment at Cardiff Airport and Bro Tathan Enterprise Zone totalling 127.85ha (70%) of the total provision. The Welsh Government does not object to the over-provision of employment land in the plan. The Enterprise Zone designation must be identified and the allocations within it (SP14: 1-3).
Delivery and Implementation
PPW and the DPM (Chapter 5) contain guidance on the requirements in respect of the delivery and implementation of plans. The Deposit Plan should set out site-specific details for Key Sites that includes general phasing timescales, key infrastructure requirements, placemaking principles (including concept / schematic masterplan frameworks), constraints, and developer requirements, where appropriate. We note the Deposit Plan has included emerging master planning/infrastructure work on key sites.
The phasing, timing, funding, and delivery of Key Sites will be critical to ensure the plan delivers the scale of growth required over the plan period. This includes the relationship between the two Key Sites in St Athan (KS4 and KS5) totalling up to 1,150 units and the delivery of a new rail station in St Athan to meet the objectives of the strategy and encourage a modal shift to more sustainable forms of public transport.
The development sites may also impact on the trunk road network, in particular the M4 J34 and there will need to be a suitable level and form of traffic assessment to accompany the plan. (The transport case may consider the South East Wales Traffic Model as part of any masterplan impacts on the Strategic Road Network (SRN) (Wales Regional Transport Models | TfW)). The Council will also need to demonstrate that all housing components are deliverable through a housing trajectory prepared by the Council and Housing Stakeholder Group. Statements of Common Ground for key allocations, especially those that have ‘rolled over’ from the adopted plan, would be advantageous to demonstrate the sites are deliverable in the timescales set out.
The Deposit plan is supported by a high-level affordable housing study and site-specific viability appraisals for Key Sites. All viability work and must be prepared in conjunction with the Viability Steering Group and site-specific promoters.
It will be for the Council to justify deliverability supported by robust financial viability.
Gypsy and Travellers
The Gypsy and Traveller Accommodation Assessment GTAA (June 2022, approved June 2024) identifies a total need for 11 pitches over the plan period up to 2036, of which 9 pitches are ‘immediate’ by 2026. WG note that 4 pitches have since gained planning permission, reducing the remaining need over the plan period being 7 pitches. 8

Policy SP9 identifies a site at Llangan (0.76Ha) to accommodate the 7 pitches needed. It will be for the Council to demonstrate the appropriate site selection assessment process has been followed and that the site complies with requirements in PPW (4.2.35), Circular 005/2018 (paragraph 35) any relevant guidance and the DPM (5.80-5.85) to allocate a deliverable site in the plan period. The views of the relevant statutory bodies must also be agreed with no outstanding objections to the delivery of the site. The Welsh Government has no objection in terms of meeting the numerical need for gypsy traveller accommodation.
Renewable Energy
Future Wales: The National Plan 2040 identifies Barry as a District Heat Network (DHN) Priority Area. The Renewable Energy Assessment (BP15) explores the opportunity for a DHN using waste heat from Barry Biomass, but as there is some uncertainty on the future of the plant, the study concludes there is considerable risk to using the plant as a source waste heat. Could the Council provide an update on alternative options for a DHN in Barry?
It is welcome that the Renewable Energy Assessment (REA) has considered BMV policy, specifically for solar PV, and use of the Predictive ALC Map. The assessment has only considered non-BMV land (Subgrade 3b, Grade 4 and 5). The assessment would benefit from referencing the clarification provided in the DCPO letter of 1st March 2022 in respect of solar PV and BMV agricultural land for completeness.
The study identifies that in the Vale of Glamorgan solar development is more suitable than wind energy because of the flight path of aircraft in the south of the County Borough. However, there are some opportunities for wind sites, but these are likely to be small (<10MW) where aviation risks are lower and there is some grid access. Conversely, there are large expanses of land suitable for solar areas (>10MW) to the West of the County Borough, where there is little existing development. The study identifies 20 large-scale solar areas but recognises that grid constraints may impact the ability of sites to come forward.
Solar and wind search areas (where appropriate) below the 10MW Developments of National Significance (DNS) have been identified (Policy CC3). The plan also includes a criteria-based policy for all renewable energy proposals, particularly wind development, under 10MW (Policy CC4). Policy CC3 makes reference to adhering to the criteria in Policy CC4. However, would it not be the case that if search areas have been identified in Policy CC3 have they not already met the criteria? If they would not, should they be identified in the first place? Clarity would be beneficial. The Welsh Government supports the approach but seeks clarity on the point raised.
The Welsh Government notes the proposed search areas for wind energy near Morfa Ystrad Owen/Nant Rhydhalog, according to the Peatlands of Wales Evidence Score Map, the search area includes areas of peatland (Evidence Score 4). The site is also a SINC. This raises concerns as to how the inclusion of this search areas meets the policy test in PPW 6.4.15, 1a and 1b (Stepwise) regarding avoidance of irreplaceable peatland habitats and PPW 6.4.34.
Policy CC4 refers to Developments of National Significance (DNS) in 6.344 and 6.346. This should now refer to Strategic Infrastructure Projects (SIP) which replaced DNS.
Minerals
The Regional Technical Statement (RTS 2nd Review) identifies a nil apportionment for land-won sand and gravel provision in the Vale of Glamorgan. The Welsh Government policy clarification letter (dated 11 November 2021) identifies a surplus of 1.68mt of crushed rock. As there is a surplus of crushed rock reserves and a lack of sand and gravel production in the Vale, no specific allocations are required in the replacement plan. It is unclear whether a Statement of Sub-Regional Collaboration with adjoining authorities in the Cardiff City sub-region been agreed, or does the latest Position Statement (July 2022) explain how any shortfall will be met across 9

the region, particularly for crushed rock, of which the Vale has a surplus? Clarification would be beneficial.
BMV Agricultural Land
The Welsh Government has engaged with the Council for land quality advice, survey advice and ALC survey validation for candidate sites. The LPA has produced a specific topic paper on BMV policy application. BP23A. The Deposit RLDP allocates 188 hectares of housing land, 5.62 ha is identified as BMV land (under 3% of total housing allocations). The RLDP:
• Has sought to avoid BMV land wherever possible;
• Uses the Predictive ALC Map as a core evidence layer to inform: The spatial strategy;
• Settlement hierarchy decisions; and
• Candidate site assessments.
•
• Directs strategic growth to areas with least BMV land
• Removes or avoids allocations where BMV impacts were significant or unjustified.
• Quantifies total BMV loss and demonstrates it is minimal (5.62ha) and proportionate at plan level.
• Applies a sequential approach through: Preference for brownfield and non-BMV sites;
• Replacement of higher-BMV sites with lower-grade alternatives where possible.
•
• Requires site-specific ALC surveys to verify actual land quality before allocation.
• Demonstrates that allocated BMV land is: Often small, fragmented, or constrained;
• Sometimes previously disturbed or incapable of being farmed differently from surrounding lower-grade land; and
• Necessary to deliver the Plan’s housing strategy where reasonable alternatives are unavailable.
•

In conclusion, the Welsh Government consider the Authority has demonstrated a sensible and pragmatic approach to considering BMV loss in the context of national planning policy, and on that basis no objection is offered.
Green Infrastructure
Policy SP19 should explicitly reference the need for development to be accompanied by a Green Infrastructure Statement.
PPW12 requires decision makers to apply the step wise approach to GI, with enhancement secured at every stage where possible, there is no distinction made between the quality of the GI assets – the qualification in the policy statement that states proposals will incorporate measures that protect and enhance high quality multi-functional green infrastructure should be redrafted to remove the quality reference. The need to avoid an impact in the first instance should also be explicitly incorporated into the policy.
Criterion 1 (Policy SP20) should be redrafted – the stepwise approach in PPW 12 6.4.15 1a - does not distinguish between relative ecological value – the avoidance step applies to biodiversity in its widest sense (i.e. the variety of species and habitats and their abundance) and ecosystem functioning.
Welsh Language
There is limited reference to the Welsh language in the plan, either potential adverse impacts arising through development, or mechanisms via a policy framework to support and grow the use of the language. There are references to a number of Welsh-medium schools (3.26) and the increase in the number of people able to speak Welsh according to the 2011 census (3.52) but there is no mention of the authority's Welsh Language Strategy or promoting or cross-referencing to the aims of 10

Cymraeg 2050: A million Welsh-speakers. Paragraph 6.81 of the plan refers to development north west of Barry:
“Land at North West Barry is allocated for a residential development of up to 376 dwellings and public open space. The site is in a sustainable location on the edge of the Barry, a key settlement, in a location that is well served by services and facilities, including a major supermarket, GP surgery, community centre, three primary schools (English Medium, Welsh Medium and Church in Wales) and two high schools (English and Welsh Medium) all located in reasonable walking distance. There is an active travel route along Port Road West, bus stops in close proximity providing buses to Llantwit Major, Cardiff and the centre of Barry. Barry station is 1.3 miles from the site entrance.”
There is no mention that the Council want to undertake a Welsh Language Impact Assessment (WLIA) so there appears no attempt to measure the impact on the Welsh schools resulting from housing development? Could the Council clarify if such implications have already been covered in the WLIA for the plan, ISA, or are any specific policies necessary?

This representation therefore seeks amendments to ensure that growth in St. Athan and Flemingston is proportionate, infrastructure-led, environmentally responsible, and compliant with Welsh planning policy

1. Section of Plan to which this Representation Relates
- Sustainable Growth Strategy
- Key Housing Sites:
KS4 - Land at Church Farm, St. Athan (532 dwellings) KS5 - Land to the West of St. Athan (600 dwellings)
- Housing Allocations: HG1(7)
Former Stadium Site, adjacent to Burley Place (80 dwellings)
HG1(8) - Clive Road, St. Athan (51 dwellings)
- Transport Policy (TR)
- Community Infrastructure Policy (CI)
- Policy SP13 - Infrastructure Provision
- Green Infrastructure Policies

2. Summary of Representation
This representation raises concerns regarding:
1. The scale of housing growth in St. Athan.
2. The absence of guaranteed sustainable transport infrastructure.
3. Insufficient retail and community infrastructure provision, particularly within the ward of Flemingston.
4. The allocation of the Clive Road site (HG1(8)), which currently functions as a de facto village green.
5. The cumulative infrastructure impact of candidate and legacy site allocations.
The representation seeks modifications to ensure the Plan is infrastructure-led, deliverable, and compliant with national planning policy and the Well-being of Future Generations (Wales) Act 2015.

3. Scale of Housing Growth in St. Athan
The RLDP allocates:
- KS4 - 532 dwellings
- KS5 - 600 dwellings
- HG1(7) - 80 dwellings
- HG1(8) - 51 dwellings
This equates to 1,263 dwellings in St. Athan.
This represents a very significant expansion of the settlement and must be assessed against:
- Existing infrastructure capacity
- Transport provision
- Education and healthcare availability
- Retail and service provision
At present, St. Athan does not have a rail station and relies heavily on private car travel.
The Plan must demonstrate clearly that this level of growth is proportionate and deliverable.

4. Transport Infrastructure and Deliverability
The RLDP safeguards land for a "transport interchange" at St. Athan. However:
- There is no confirmed rail station.
- There is no confirmed funding package.
- There is no defined delivery programme.
- There are no binding occupation triggers linking housing delivery to transport delivery.

Previous references in planning documents referred to a railway station. The revised terminology of "transport interchange" reflects uncertainty.

Under Future Wales - The National Plan 2040, growth within the South East National Growth Area should align with sustainable transport infrastructure. Without guaranteed rail provision, development risks being car-dependent and inconsistent with decarbonisation objectives.

This raises concerns under the soundness test: Will the plan deliver?

5. Retail and Local Service Provision - Flemingston Ward

The Deposit RLDP does not allocate new retail units or local service provision within the ward of Flemingston.
Given the scale of proposed housing growth across St. Athan and its surrounding areas, there is:

- No corresponding neighbourhood retail allocation.
- No clear commitment to small-scale convenience retail within walking distance of new development.
- No spatial recognition of Flemingston's service deficit.

This is inconsistent with Planning Policy Wales placemaking principles, which require:

- Mixed-use neighbourhoods.
- Walkable access to daily services.
- Reduced reliance on private vehicles.

Without provision of much-needed retail units within Flemingston ward, residents will remain dependent on car travel for everyday needs.
Modification is therefore sought to require neighbourhood retail and service provision proportionate to housing growth.

6. Clive Road Site (HG1(8)) - Community Function

The Clive Road site (HG1(8), 51 dwellings) currently functions as a de facto village green.
Although not formally designated, it is:
- Used informally for recreation.
- A visual open space within the settlement.
- A valued community amenity.
Its allocation for housing would result in:
- Loss of accessible informal open space.
- Erosion of community character.
- Reduction in green infrastructure connectivity.
The Plan should:
- Reassess the allocation in light of its community use; or
- Require equivalent or superior replacement open space within immediate proximity prior to development.
This matter engages Policy on Open Space and Green Infrastructure and must be considered in accordance with the prevention and long-term principles of the Well- being Act.

7. Candidate and Legacy Sites - Cumulative Impact Several allocations in St. Athan arise from:
- The Candidate Site process.
- Rolled-forward legacy allocations.
Individually, smaller sites may appear acceptable. However, cumulatively they produce substantial growth in a settlement with constrained infrastructure.
The Plan must demonstrate:
- Why these sites were preferred over alternatives.
- That lower growth options were robustly assessed.
- That greenfield loss is justified and mitigated.

8. Infrastructure and Phasing Concerns
Policy SP13 refers to securing infrastructure through planning obligations. However, reliance on financial contributions alone does not ensure timely delivery.

There is insufficient clarity regarding:
- Education capacity expansion.
- Primary healthcare provision.
- Highway mitigation triggers.
- Public transport enhancement sequencing.

Infrastructure must be delivered ahead of, or in tandem with, housing occupation - not retrospectively.

9. Compliance with the Five Ways of Working

Long-Term: Irreversible greenfield expansion without secured sustainable transport risks embedding long-term car dependency.
Prevention: Without infrastructure-first sequencing, congestion and service strain are foreseeable.
Integration: Housing growth appears to run ahead of confirmed transport and retail provision.
Collaboration: The Plan should demonstrate binding commitments from transport and infrastructure partners.
Involvement: Community concerns regarding scale and open space loss must be properly addressed.

10. Modifications Sought

To ensure soundness and compliance with national policy, the following modifications are requested:

1. Phasing Policy for KS4 and KS5
Introduce clear occupation thresholds tied to delivery of:
- Transport interchange infrastructure.
- Highway mitigation.Education capacity.
- Healthcare provision.

2. Retail Provision Requirement
Require neighbourhood retail and service provision within the ward of Flemingston proportionate to allocated and previous housing growth.

3. Clive Road Site Review (HG1(8))
Either:
- Remove the allocation; or
- Require replacement open space of equal or greater quality delivered prior to development.

4. Strengthened Infrastructure-First Wording
Amend Policy SP13 to make infrastructure delivery a pre-condition, not solely a contribution mechanism.

5. Monitoring Framework Enhancement Include specific indicators for:
- Sustainable transport modal share.
- Retail provision delivery.
- Open space replacement.
- Infrastructure phasing compliance.

11. Conclusion

St. Athan has a role within the wider Cardiff Capital Region and the South East National Growth Area. However, the current scale of housing allocation is not sufficiently matched by guaranteed infrastructure, retail provision, or community space protection.

Without modification, the Plan risks:
- Car-dependent growth,
- Loss of valued open space,
- Insufficient local retail provision,
- Pressure on community infrastructure.
This representation therefore seeks amendments to ensure that growth in St. Athan and Flemingston is proportionate, infrastructure-led, environmentally responsible, and compliant with Welsh planning policy.

Thank you for consulting Natural Resources Wales (NRW) on the Vale of Glamorgan Replacement Local Development Plan (RLDP) Deposit Plan, which we received on 28 January 2026.
We have reviewed the deposit plan and published documents and have recommendations on matters relating to coherence and consistency. We advise these are addressed prior to submission of the RLDP.
1. Summary
We welcome that the Vale of Glamorgan Council has declared a ‘nature emergency’ and in 2021 committed to a target of no net loss of biodiversity in the Vale of Glamorgan. The deposit plan takes this a step further through its vision, objectives and policies in seeking
the achievement of net biodiversity benefit. We also welcome the recognition within the deposit plan and supporting documents that additional growth within the Vale has the potential to lead to negative effects on nationally and locally designated biodiversity. We
appreciate that the deposit plan’s policies seek to mitigate against these potential adverse effects with detailed wording and requirements.
However, we consider that the deposit plan would benefit from more specific mention of designated conservation sites especially where these are related to specific allocations and their associated policies. We note this issue was raised within the Integrated Sustainability Assessment (ISA) (see Section 2 below) however we do not see this recommendation properly reflected within the deposit plan itself. We consider this is a gap that should be addressed to ensure clarity within the policy requirements for any future planning applications.
General Approach to Designated Sites
In line with our role in development planning and our consultation remit, we advise that where new development may occur within or be likely to affect statutory designated sites including Special Areas of Conservation (SAC), Special Protection Areas (SPA), Sites of Special Scientific Interest (SSSI), National Nature Reserves (NNR) and Marine Conservation Zones (MCZ) this could be more clearly identified as a key consideration especially with respect to site allocations (housing and employment). We consider that the issue of avoiding or mitigating potential impacts and utilising opportunities for supporting and enhancing these sites (as noted by para 6.401 of the deposit plan) could have more substantial recognition across the deposit plan and its supporting documents. This would improve the clarity of approach.
We have furthermore noted that Policy SP20 (Biodiversity and Ecosystem Resilience) currently excludes specific mention of designated sites (although it does refer to protected species and habitats) and we suggest that this is addressed – our comments on SP20 are set out in Section 3 of this letter.
By across the plan, we mean there is scope to include mention of relevant statutorily designated sites within the constraints text for the sites listed in Appendix B of document BP44 Infrastructure Delivery Plan (perhaps summarising in line with the approach taken to the Historic Environment Record) and within document BP32A Green Infrastructure Assessment of Key Sites, evidence which can then be reflected as appropriate in Key Sites Policies (HG1 KS1 to KS5) to inform their master planning. The Preliminary Ecological Appraisals already undertaken for Key Sites (Key Site Supporting Information) would appear to hold relevant information in this respect.
We note that document BP32A has a useful general paragraph on biodiversity assets at paras 3.7-3.8 linked to the evidence collated in the Green Infrastructure Assessment (GIA). In short, where designated sites are identified in proximity to allocated sites it would be
helpful to make clear reference to them in a consistent manner. This would bring the deposit plan more fully into alignment with the ISA findings. For any employment sites
within proximity of designated sites, we consider that the employment background paper BP12A could potentially be updated to similar effect.
With reference to omissions on this matter, we refer you to our comments on sites set out in Section 4 of this letter, including sites KS1, HG1 (1), SP14 1. and SP14 4.
Overall, we consider that the recognition of designated sites appears somewhat inconsistent in the deposit plan, although we recognise that much of this is done by the
Green Infrastructure Strategy (GIS) which incorporates the GIA.
It may be that Policy SP20 (please see our suggested amendments in Section 3 of this letter) together with addressing the meaning of “areas of high ecological value” will also go some way towards resolving the points we raise.
Master Planning
We welcome the illustrative master plans included in the deposit plan but would caveat that at the detailed stages schemes must be able to adapt, where necessary, to site
specific environmental constraints (including protected sites, species and habitats), for example in response to updated ecological appraisals or detailed species surveys.
Designs need to be flexible enough to ensure compliance with the stepwise approach (avoid, minimise, mitigate) in achieving Net Biodiversity Benefit (NBB) and improving the resilience of ecosystems as required by Planning Policy Wales, edition 12 (PPW12) and Policy 9 of Future Wales, the National Plan. We note the plan has good reference to this within Policy SP20 and supporting paragraph 6.405, thus enabling thorough consideration
at the project/planning application level and in master planning.
Please see our detailed site-specific comments in Section 4 in order to consider where our comments may lead to adjustments in master plans. For example, the species protection issues we highlight with regard to KS3 at Readers Way, Rhoose.
Strategic Opportunity at Bro Tathan
In addition to the above points, we advise that the Bro Tathan area of the Vale includes a number of different allocations and is already known as an important ecological area for great crested newts (GCN) and dormice, in particular. Given the commitments already
made under previous planning applications at the site and the necessary requirement for future biodiversity provisions, we advise a more strategic overview of the area should be considered and either set out within the deposit plan or secured within an updated GIS.
This will ensure that development in the area:
• does not cause detriment to the maintenance of the favourable conservation status of protected species;
• results in green spaces and infrastructure that is meaningfully spatially connected and sufficient in size.
Overall, we consider piecemeal development of the St Athan area will not lead to effective conservation delivery and will make the planning process less efficient at project level.
Areas of High Ecological Value
As previously noted within our preferred strategy response (Ref: CAS-244275-Q4F4, dated: 14th February 2024), the deposit plan continues to make reference to avoiding
areas of ‘High Ecological Value’ (criterion 1 of SP20). We have not been able to establish where these areas are or how their ecological value is being determined. We consider this issue needs to be clarified and ideally a definition provided.
2. Integrated Sustainability Assessment (ISA)
With regards to Section 9.9 of the ISA, we agree that additional growth in the Vale has the potential to lead to negative effects on nationally and locally designated biodiversity. The ISA concludes that the housing-specific policies set out within the deposit plan work well to
mitigate the potential adverse effects, through design stipulations and policy inclusions.
The ISA then goes on to recommend that Key Site policies are updated, where appropriate, to reference specific designated sites which they are in proximity to, in
order to help establish appropriate protection and/or enhancement measures.
We agree with these recommendations and would go further in advising that all allocations and their associated policies should reference specific designated sites relevant to that site. For instance, we would advise Barry Woodlands SSSI and Walters Farm SSSI is identified in relation to Key Site 1 – Land at North West of Barry, and Barry Woodlands SSSI should also be identified for Housing Allocation HG1 (1) Land to the West of
Pencoedtre Lane. Please refer to our site-specific comments in Section 4 below.

3. Plan and Policy Wording
Strategic Policies
Strategic Policy SP19 – Green Infrastructure
We welcome that the GIS and GIA has informed the master planning of the Key Site allocations (6.395). To ensure this approach is carried forward for other development proposals, we consider there should be a stronger “policy hook” within Policy SP19 to link the content and evidence of the GI work to the policy and its influence on decision-making. Without this we consider there may be a risk of a policy gap/mismatch when determining planning applications.
This could be resolved by a new criterion such as:
“the provision of green infrastructure must have regard to any adopted or emerging guidance including the Green Infrastructure Strategy/Green Infrastructure Assessment
(and the Assets listed therein), and Green Infrastructure (Action) Plan for the Vale.”
To strengthen Policy SP19 we also recommend an addition to the wording of criterion 2 to read:
“Protect and enhance connectivity between existing green infrastructure assets and be planned wherever possible to positively support areas of high ecological value”.
We furthermore note that criterion 3 of SP19 refers to achieving net benefit for biodiversity whilst the policy overall seeks to provide, protect and enhance high quality multi-functional green infrastructure. We have previously commented that multi-functional green spaces may not always be compatible with biodiversity. It should be recognised that multifunctional uses of space can be to the detriment of the natural environment and so must be carefully considered. We recommend that paragraph 6.397 wording is updated to reflect this potential conflict so that NBB required by PPW (and as promoted by para 6.396 together with Policy SP20) is able to be prioritised and not compromised.
This point could also be raised under Policy SP4 Placemaking – at para 6.32. It should not be assumed that multifunctional spaces will also be delivering for nature in every situation and in some cases separate provision of spaces to meet biodiversity goals will be essential.
Paragraph 6.401 is welcomed regarding the opportunities that exist for the protection, maintenance and further enhancement of green infrastructure assets.
Strategic Policy 20 (SP20) – Biodiversity and Ecosystem Resilience
We welcome the inclusion of SP20 which recognises the importance of natural assets and aims to protect these. We have made comments regarding the term “high ecological value” in our Summary section at the start of this letter.
We also note that whilst reference is made to sites and areas of European, national and local importance (para. 6.402), this is not distinctly carried through within SP20 or within a specific detailed policy in the deposit plan. We advise that a more detailed policy for the Natural Environment (similar to DNP4 for the Historic Environment) could be included within the deposit plan and this should include reference to the protection of statutorily designated sites. Alternatively, SP20 itself could be updated to include reference to these in a similar manner to the approach taken to non-statutory designated sites provided by criterion 5 of SP20. We consider this would strengthen the deposit plan’s alignment to
section 6.4.3 of PPW12. This issue is also reflected in our feedback to the ISA as set out in Section 2.
By adding a detailed policy for the wider protection of the natural environment, there is scope to ensure a clearer message within the deposit plan regarding the need for natural resources (including land, air, water and soils) in the Vale to be protected for themselves and the essential ecosystem services they deliver. This is opposed to merely preventing pollution (deposit plan Policy DNP5). Taking such an approach would enable an
opportunity to add the consideration of Sustainable Management of Natural Resources (SMNR) into the plan policy framework rather than confining this to the deposit plan context (para 2.11) and the policy context of the GIS (page 53).
We note that Policy CC4: Renewable, Low and Zero Carbon Energy Generation is more distinct in seeking to safeguard a range of assets (including nature conservation interests and soil conservation interests) and we consider a similar policy approach may be useful
for all development proposals. We also suggest that the placemaking strategic policy (Policy SP4) could be altered in order to highlight the Natural Environment alongside its
current reference to the Historic Environment. We note that placemaking principles (Figure 11 - Identity) includes the need for development to respond to natural physical attributes of the site. This is an issue is linked to our site-specific comments (Section 4 below) where we cite, for example, the need to buffer woodlands, hedgerows and watercourses and preserve linear corridors.
Ensuring an SMNR approach will impact positively on the ground to safeguard and improve ecological networks and protect and enhance ecosystems, essential to meeting
the nature emergency. Topics we draw your attention to include river restoration where, in particular, the removal/remediation of physical modifications can make a significant impact upon water quality. The GIS provides scope to capture various projects and wider initiatives, including those based on catchment scale improvements and we welcome the opportunity to be continually involved in this work. We note and welcome the recognition of
nature-based solutions within Policies SP16, SP19 and SP20 and in detailed Policy CC6.
With regards to natural assets and water resources, we consider that specific reference to water quality is lacking within the strategic and/or detailed policies. Whilst we note that water quality is mentioned within criterion 9 of Policy SP16, we consider the deposit plan should include more direct reference to the Water Framework Directive. We consider there is an opportunity for SP20 to be updated to ensure developments protect water quality and quantity. Alternatively, as mentioned above, this could fit within a detailed policy for the protection of the natural environment.
As a minor point, please note that the South Central Area Statement is not hyphenated (para 2.10 and 2.11). Please note also that, referring to paragraph 6.404 and 6.405, the
requirements for developments to demonstrate NBB is based on PPW12, rather than The Environment (Wales) Act 2016.

Detailed Policies

Infrastructure
Whilst we note that the infrastructure requirements (such as sewerage capacity) have been investigated for certain key sites within the deposit plan, we consider there could be scope for a detailed policy to cover infrastructure requirements for all development.

Policy DNP7
We welcome Policy DNP7 of the deposit plan, which recognises the importance of preserving the natural darkness of the night sky and minimising light pollution, which we consider to be important in limiting adverse impacts upon local biodiversity and ecological
connectivity.

Policy DPN8
Please refer to comments made with regards to this policy under Section 6: Habitats Regulation Assessment (HRA).

Policy HG5 - Affordable Housing Exception Sites
We advise that, particularly given these sites are permissible outside of settlements and could be in countryside locations, criterion 6 should be amended to:
“There is no loss of land with significant recreational, amenity, agricultural, ecological or natural heritage value”.

EMP1 – Employment Regeneration Opportunity Areas
We note that the Former Aberthaw Power Station has been identified as an employment regeneration opportunity area. There are otter and water vole records on the site and we are aware of GCN records within the local area. We would advise against the inclusion of
the Aberthaw Nature Reserve within the allocation and advise that any application on the site would need to be supported by up-to-date ecological survey information and
appropriate conservation measures. Given the nature of the site, future applications will also need to be supported by appropriate land contamination investigations.

CC3 – Renewable Energy Local Search Areas
This policy identifies several sites where the potential for wind and solar development are the greatest (known as ‘search areas’). There are significant search areas located between Llantrithyd and St Hilary; no ecological information has been provided for these search areas, however given the records for GCN, water vole and otter local to these areas, it is likely that provision in the form of suitable habitats will need to be made for these species.
This could be substantial in scale, however without further ecological information we cannot advise further at this time. Notwithstanding, given the scale of the search area in this location and the likely ecological impacts, we advise that this area would benefit from spatial planning of biodiversity provision, at a greater than individual site scale.

Paragraph 2.81 – The Vale Nature Recovery Action Plan
We note reference to ‘6 broad habitat types’ including Woodland, Freshwater, Grassland, Coastal, Agriculture and Urban. We suggest this is amended to ‘6 broad ecosystems’ to reflect correct terminology and the State of Natural Resources Report 2025.

4. Strategic Sites
Overview
We previously provided detailed comments on the RLDP’s Strategic Sites, as set out in our response ref: CAS-234819-C1V3, dated 4th October 2023, which we refer you to. We welcome the additional information provided and note the inclusion of Green Infrastructure
Strategies for each of the Key Sites. However, we note that these do not include reference to protected species specifically and as a result we are unable to confirm that the provision for each site is appropriate. We observe that the road infrastructure for many of these sites severs woodlands and other substantial linear corridors. We advise that such sites are designed to minimise fragmentation in the landscape and advise that the road layouts and consequent severance is re-visited.

KS4 and KS5 are located within the vicinity of St Athan. This area is important for (and we are aware of) multiple records of GCN and dormice. Some of the area is already secured as compensation for impacts on these species associated with previous developments. We advise that the wider St Athan area is subject to spatial planning of biodiversity provision at a greater than individual site scale (as we have referenced in the Section 1 of this letter), in order to determine that:
• It does not cause detriment to the maintenance of the favourable conservation status of both GCN and dormice (strategic conservation plans should be established for both species);
• To ensure that green spaces and infrastructure are meaningfully spatially connected and sufficient in size;
We consider piecemeal development of these areas will not lead to effective conservation delivery and will cause the delivery of these sites to be less effective during the planning process.

Spatial Planning of Biodiversity
A masterplan or spatial biodiversity or GI plan should demonstrate the retention, provision and enhancement of essential areas for protected species. It should ensure that individual site-based habitat provisions are not designed in isolation but considered in association with nearby sites to demonstrate how habitat connectivity and resilience will be provided both across the site and to the wider landscape. Note that functional separation of public
open space and areas for biodiversity compensation may be required. Suitable buffers will need to be applied to any woodland and retained or created habitats on site. A sensitive lighting strategy will also likely be required for these sites. This point was raised previously during our review of the strategic candidate sites (ref: CAS-234819-C1V3, dated 4th October 2023).

Updated Surveys and Appropriate Buffer Zones
Further to the above comments, we welcome reference within the Infrastructure Delivery Plan for the requirement for updated ecological surveys and appropriate buffer zones to watercourses and retained habitat features for KS1 and KS2. Given the various ecological
constraints for each key site, we consider this advice should be included for each of the key sites.

Site Specific Comments
KS1 – Land at North West Barry
Protected Species – Dormice and bats are present on site. We advise that the masterplan is informed by surveys to ensure that biodiversity interests are maintained and enhanced. The site may require some areas to be retained an/or provision for habitats to support them. Dark areas and/or bespoke lighting scheme may also be required at project stage.
Protected Sites – The site is located in close proximity to Walters Farm and Barry Woodlands SSSI. As raised in our previous responses (CAS-234819-C1V3, dated: 4th
October 2023 and CAS-276923-N7H6, dated 17th April 2025), we have some concerns with the potential for increased and inappropriate use of the protected sites through recreational activities. We welcome that requirements have been detailed within HG1 KS1
under Green Infrastructure, Recreation Spaces and Biodiversity, which includes reference to emerging guidance for Suitable Alternate Natural Greenspace (SANG).

KS2 – North of Dinas Powys, off Cardiff Road
Protected Species – We note the supporting Preliminary Ecological Appraisal (PEA) (13th September 2022) which identifies potential for this site to support GCN, dormouse and bats. In the absence of species specific surveys, we are unable to advise whether the housing number aspirations for the site are realistic. We advise the scheme is designed to minimise severance of ecological corridors.

KS3 – Land at Readers Way
Protected Species – GCN are known to be present on this site (Readers Way Pond). The current masterplan indicates that the pond will be surrounded by built development and therefore built upon much of the terrestrial habitat which supports this pond. It is essential
that the masterplan provides a wide corridor from this pond to the wider countryside, other than via the closely managed grassland at Cardiff Airport. Any masterplan should make provision for this and any loss of habitat should be compensated for.

KS4 – Land at Church Farm
Protected Species - There are records of dormouse and GCN in the wider area. However, the supporting PEA indicates no direct impacts on the latter of the species. There appears to be extensive green space proposed in the illustrative masterplan, which we support.

KS5 – Land to the West of St Athan
Protected Species - The St Athan area is important area for GCN and dormouse. We would generally concur with the lower risk assessed for these species in association with this site. However, this is a substantial site and this and other sites in the St Athan area would benefit from spatial planning of biodiversity provision at a greater scale as reaffirmed elsewhere in this response.

5. Housing And Employment Allocations
Housing Allocations

HG1 (1) Land to the West of Pencoedtre Lane
Protected Sites: The site is within close proximity (200m) to Barry Woodlands Site of Special Scientific Interest (SSSI) and there is a risk from increased recreational use as a result of residential development, which could lead to impacts on the SSSI. Green space design must consider any emerging guidance for SANG to reduce recreational pressure on adjacent sites of biodiversity importance.
HG1 (2) Land at the Mole
Land Contamination: Given previous land use at site, a Preliminary Risk Assessment would be required at planning application stage to determine risk of land contamination.
Marine: An adjacent watercourse forms a hydrological link to the Severn Estuary European Marine Site (EMS). A HRA at project level will therefore be required.

HG1 (3) Land at Hayes Lane
Land Contamination: Given previous land use at site, a Preliminary Risk Assessment would be required at planning application stage to determine risk of land contamination.

HG1 (4) Land at Neptune Road
Land Contamination: Given previous land use at site, a Preliminary Risk Assessment would be required at planning application stage to determine risk of land contamination.
Marine: An adjacent watercourse forms a hydrological link to the Severn Estuary EMS. A HRA at project level will therefore be required.

HG1 (5) Land between the Northern Access Road and Eglwys Brewis Road (Site C - Central Parcel)
Flood Risk: The site is located partially within Flood Zone 2 and 3 for Rivers, with the southern area of the site located within Flood Zone 3. We refer you to Sections 10.20 and 10.21 of TAN 15, which state that highly vulnerable development in Zone 3 should be avoided. Notwithstanding, we acknowledge that at masterplanning stage, there is scope to locate residential development away from areas of flood risk. We also welcome that
Appendix B of your Infrastructure Delivery Plan notes the requirement for an FCA at project level for this site.
Watercourse: Boverton Brook (Main River) runs through the site and any development will need to ensure no adverse impacts to the watercourse with appropriate buffers and design considerations.

HG1 (6) Land adjoining St Athan Road
Land Contamination: The site is located over a principal aquifer. Any development would need to consider the hydrological setting of the site and vulnerability of pollution.

Rural Affordable Housing Led Sites
HG4 (1) Land to the East of Colwinston
Land Contamination: The site is located over a principal aquifer. Any development would need to consider the hydrological setting of the site and vulnerability of pollution.

Major Employment Allocations
SP14 (1) Land east of Cardiff Airport, Rhoose
Protected Species and Protected Sites: The site is within close proximity (360m) of Barry Woodlands SSSI and there also appears to be significant potential for the site to support dormouse, GCN, otter and water vole. There are large areas of semi-natural habitats associated with this site including woodland, mature hedgerow and watercourses. These should be retained and significantly buffered from development. Connectivity between the
site and the wider environment should also be maintained. It is therefore currently not possible to advise whether the full aspirations of the site could be fulfilled.
Land Contamination: Given previous land use at site, a Preliminary Risk Assessment would be required at planning application stage to determine risk of land contamination.

SP14 (2) Land south of Port Road (Model Farm), Rhoose
Land Contamination: Given previous land use at site, a Preliminary Risk Assessment would be required at planning application stage to determine risk of land contamination.

SP14 (3) Bro Tathan Aerospace and Business Park
Protected Species: The site is located within an important area for GCN and dormice. As mentioned, this area would benefit from spatial planning of biodiversity provision at a
greater scale to better inform allocation.
Land Contamination: Given previous land use at site, a Preliminary Risk Assessment would be required at planning application stage to determine risk of land contamination.

SP14 (4) Land to the South of Junction 34 of the M4, Hensol
Protected Sites: The site is located directly adjacent to Ely Valley SSSI. Given the biodiversity interest at the site, previous applications at the site include planning
commitments to conserve and enhance grasslands habitats on the site. These commitments have not yet materialised and the requirement for these provisions should be noted within the LDP.
Flood Risk: The site is located partially within Flood Zone 3 for Sea. We advise that an FCA will be required at project level to determine any flood risk implications at the site.

Local Employment Allocations
SP14 (5) Atlantic Trading Estate, Barry
Land Contamination: Given previous land use at site, a Preliminary Risk Assessment would be required at planning application stage to determine risk of land contamination. The site is located over a principal aquifer. Any development would need to consider the hydrological setting of the site and vulnerability of pollution.
Marine: An adjacent watercourse forms a hydrological link to the Severn Estuary EMS. A HRA at project level will therefore be required.

SP14 (6) Windmill Park, Hayes Road, Barry
Land Contamination: Given previous land use at site, a Preliminary Risk Assessment would be required at planning application stage to determine risk of land contamination. The site is located over a principal aquifer. Any development would need to consider the hydrological setting of the site and vulnerability of pollution.
Flood Risk: The site is located partially within Flood Zone 3 for Sea. We advise that an FCA will be required at project level to determine any flood risk implications at the site.
Marine: An adjacent watercourse forms a hydrological link to the Severn Estuary EMS. A HRA at project level will therefore be required.

SP14 (7) Vale Business Park, Llandow
Land Contamination: Given previous land use at site, a Preliminary Risk Assessment would be required at planning application stage to determine risk of land contamination.

SP14 (8) Land at Llandow Trading Estate
Land Contamination: Given previous land use at site, a Preliminary Risk Assessment would be required at planning application stage to determine risk of land contamination.

6. Habitats Regulations Assessment (HRA)
Marine and Coastal Physical Processes
Coastal Squeeze
We note that coastal squeeze has been screened in and taken through to Appropriate Assessment where a conclusion of no adverse effect was reached. The justification for this is that it “is unlikely that the Vale of Glamorgan RLDP will allocate many developments on
greenfield sites adjoining the estuary”.
We also note that Policy CC6 specifically relates to Coastal Defences and Shoreline Management, with reference to the Shoreline Management Plans. We recommend the use of NRW’s Assessment of Coastal Squeeze at the project level for anyone proposing to
undertake works to coastal structures.

Loss of Functionally Linked Habitat
As part of the Preferred Strategy consultation, we advised that consideration was given to potential impacts on migratory fish features of the Severn Estuary EMS. In particular, we referenced the River Ely and its tributaries providing supporting habitat for essential life cycle processes of some or all the diadromous fish species.
Within the deposit plan HRA, it is noted that likely significant effects to the migratory fish features of the Severn Estuary EMS has been ruled out, as none of the sites allocated in the RLDP lie in close proximity to the River Ely and connected watercourses. We therefore
agree with this conclusion.
In relation to bird features, Table 8 of the Appropriate Assessment identifies many key sites and allocations with high to medium potential for functional linkage to the Severn Estuary EMS. We note that loss of functionally linked habitat has been screened in and taken through to Appropriate Assessment where a conclusion of no adverse effect was reached. The justification for this is the inclusion of ‘Policy DNP8 – Severn Estuary Recreational
Pressure’ within the deposit plan.

Policy DNP8
We advise that clarification is needed in relation to this policy, as while we welcome the supporting text regarding functionally linked land outlined in paragraph 6.76 of the HRA, the policy is mainly focused on recreational pressure and is titled as such. We also note a discrepancy between the policy wording in paragraph 6.76 and Policy DNP8 in the deposit plan itself.

Visual and Noise Disturbance (During Construction)
Within the deposit plan HRA, visual and noise disturbance has been screened in and taken through to Appropriate Assessment where a conclusion of no adverse effect was reached. The justification for this is through the inclusion of recommendations outlined in 6.83 of the HRA to the supporting text of Policy SP20, which we welcome.
We also welcome the recommendation in relation to potential functionally linked land as outlined in paragraph 6.84 of the HRA.

Recreational Pressure
Within the deposit plan HRA, recreational pressure has been screened in and taken through to Appropriate Assessment where a conclusion of no adverse effect was reached. Again, the justification for this is the inclusion of ‘Policy DNP8 – Severn Estuary Recreational Pressure’ within the deposit plan, which as above, we advise needs
clarification.
We note that no visitor data has been collected from access points within the Vale of Glamorgan, but we welcome reference to the visitor surveys undertaken by
Monmouthshire and Torfaen, as well as the 2022 visitor survey commissioned by Stroud District Council.
We note that paragraph 6.25 of the HRA states that “three Key Sites and several other housing allocations lie within the 12.6km core recreational catchment that has been
deemed most appropriate for the Severn Estuary SAC/SPA/Ramsar”. However, we also note that Table 6 in the HRA only includes two Key Sites requiring mitigation, with KS3 being omitted. We advise that clarification is needed at the project level as to whether developments are situated within the 12.6km catchment area.

7. Strategic Flood Consequence Assessment (SFCA)
We have reviewed the submitted SFCA and agree with the scope of the assessment made.
We note there is currently an upper catchment Natural Flood Management (NFM) / Nature Based Solutions (NbS) project on the Cadoxton to reduce flood risk to Dinas Powys, Any updated SCFA should have regard to NFM schemes being progressed in their area and
proposals should be clearly outlined in the Development Plan (in accordance with TAN 15 2025).

8. Green Infrastructure Strategy (GIS)
We understand that the published GIS has not been updated to reflect the latest stage of the deposit plan and refers only to the preferred strategy stage (para 2.2.3). We previously provided advice on the Green Infrastructure Assessment (GIA) (re: CAS-252087-F0H1, dated 14th May 2024) which is included within the GIS. We refer you to these comments, noting that the GIS will be kept under continual review (para 1.2.5).

Introduction
These representations are provided on behalf of Barratt Redrow in respect of the Vale of Glamorgan Council’s consultation on the Replacement Local Development Plan (RLDP) Deposit Plan and Candidate Site Register. They should be read in conjunction with the enclosed completed Comments Forms.
Barratt Redrow are promoting land at St Nicholas (Site ID 486) for a residential-led development of up to 140 modern, energy efficient homes, 40% of which are currently proposed to be affordable.
Barratt Redrow is generally supportive of the Council’s work in preparing the RLDP. The preparation of an up-to-date development plan for the Vale is plainly important and the Council is to be supported in progressing the RLDP through to Deposit stage. The principle of a plan-led strategy, rooted in settlement evidence, affordable housing need and sustainable transport objectives, is endorsed. That is particularly important in the current plan-led Welsh planning context.
That said, in its current form the Deposit RLDP is not sufficiently ambitious and, in our view, requires a number of important changes in order to ensure soundness. The key concerns relate to the overall housing requirement, the level of flexibility built into the strategy, the degree of reliance placed on key sites, windfalls and rolled forward supply, the unduly restrictive approach taken to sustainable settlements outside of the Strategic Growth Area and the introduction of onerous policies that when considered together could impact deliverability. Those issues are especially relevant to St Nicholas, which the Council’s own evidence identifies as one of the better performing Minor Rural Settlements and one which has an established role in supporting a sustainable rural community.
The Council’s own evidence base supports a stronger role for St Nicholas than the Deposit Plan currently allows. It demonstrates that proportionate growth in settlements such as St Nicholas is not a departure from the Council’s established strategy; it is consistent with it. The Deposit RLDP should be amended so that it better reflects both national policy and the Council’s own evidence, and in particular so that sustainable and deliverable opportunities such as St Nicholas are able to make an appropriate contribution to meeting the Vale’s housing needs.
The remainder of these representations address the specific policies of the Deposit Plan.
Deposit Plan Plan Period Position: Object
Based on the Development Plans Manual, when a plan is adopted, there should be at least 10 years of the plan period remaining.
On the Council’s current timetable, adoption is only anticipated for August/September 2027, and those post-Deposit stages are expressly identified in the Delivery Agreement as indicative, because they depend on external factors including the number of representations received and the examination process. The Deposit Plan runs only to 2036. That means that, even if the Council hits its best-case programme and adopts in September 2027, the Plan would have only about 8 years and 3 months left to run. That is already below the DPM expectation of at least 10 years remaining at adoption. Any slippage would make that position worse.
Based on the current timetable, an end date of 2038 (with associated increase in housing requirement) would therefore ensure a sound plan.
Policy SP1 – Sustainable Growth Strategy Position: Comment / Object in part
Barratt Redrow supports the broad objective of pursuing a sustainable growth strategy and agrees that growth should be directed towards the most sustainable locations. The emphasis on public transport connectivity, access to services and the need to align housing growth with wider regional aspirations is supported in principle. The Deposit Plan’s summary of Future Wales correctly notes that the Vale lies within the Cardiff, Newport and the Valleys National Growth Area and that Local Development Plans should recognise this area as the focus for strategic economic and housing growth, services and facilities, and transport infrastructure. The Plan also correctly highlights Future Wales’ wider outcomes, including vibrant rural places with access to homes, jobs and services.
Our concern is that the strategy as drafted is not sufficiently nuanced and, in practice, it places too much weight on the Strategic Growth Areas and not enough weight on sustainable settlements outside it. In doing so, it risks overlooking villages which perform well against the Council’s own settlement evidence and which can accommodate proportionate growth in a highly sustainable way. St Nicholas is a clear example of that. The earlier Barratt David Wilson Homes representations made this point and it remains equally relevant now: the strategy should not be read as favouring rail-served locations to the exclusion of settlements with strong bus accessibility and established local services.
This is important because the Council’s own evidence does not justify such a narrow interpretation of sustainable transport. The BP5 methodology was adapted specifically to better appreciate the role and function of settlements in the Vale, including their relationship to key services and facilities. In other words, the Council has already recognised in its evidence base that sustainability in the Vale cannot sensibly be reduced to rail access alone.
St Nicholas benefits from strong bus connectivity and a strategic relationship to Cardiff and other settlements. Supporting population growth in proximity to regular bus services can itself help reinforce the viability of those routes. Para 3.45 of PPW states the following in respect of relationships beyond the Council’s administrative area:
“The evidence to identify suitable areas and sites for development should not be confined by local authority boundaries. It should reflect realities like housing markets, travel to work areas, retail catchments and the nature of activity or development itself.” (emphasis added)
Cardiff is by far the greatest attractor in terms of commuting destination, as shown in the below Census data for the Vale of Glamorgan:
St Nicholas is 16 minutes from Cardiff via bus. Not all people will want to live in towns (as recognised by the Council in their response to the draft NDF). The Spatial Option is depicted on Page 28 of the Spatial Options Background Paper (June 2023). This fails to show St Nicholas as a settlement with frequent bus connectivity despite it being served by excellent bus service provision.
Future Wales supports development which aligns with the South East Wales Metro which includes bus infrastructure and services as well as the rail network. The Deposit Plan’s focus on settlements with railway stations ignores settlements with bus service provision such as St Nicholas where travel via bus is an attractive, sustainable and convenient option for residents. For example, the travel time on bus to Cardiff from St Nicholas is 15 minutes, whereas the travel time from Rhoose to Cardiff via train is over double the time at 36 minutes.
Settlements such as St Nicholas will require additional growth over the coming years in order to contribute to their vibrancy and support existing services and facilities such as the local school and bus service. That remains a legitimate and important planning point. Future Wales, as summarised in the Deposit Plan, requires local authorities to maximise opportunities arising from public transport investment and to plan for growth that supports sustainable connectivity more generally, not simply around rail stations.
There is therefore a soundness issue here. The Council’s own evidence and national policy context support a strategy that captures sustainable bus-connected settlements as well as rail-served settlements. St Nicholas should be expressly recognised as one of those locations. If the Council is seeking to direct development to places “best served by public transport connectivity and [which] offer a good range of services and facilities”, then it should ensure that this is applied consistently to settlements such as St Nicholas rather than in a way that, in practice, privileges only a narrow subset of locations.
For that reason, Policy SP1 should be amended to make clearer that sustainable settlements outside the Strategic Growth Area, where there is good bus connectivity, local facilities and a clear functional relationship with wider employment and service centres, are capable of accommodating proportionate growth. That change would make the strategy more aligned with the evidence base and would support a more robust and resilient pattern of housing delivery.
Policy SP2 – Settlement Hierarchy Position: Object
Barratt Redrow objects to Policy SP2 in its current form.
The Council’s own evidence shows that St Nicholas performs strongly as a Minor Rural Settlement. It scored 39 points and ranked 5th out of 21 Minor Rural Settlements within the Settlement Appraisal Background Paper. It is one of the few settlements in this tier with a school in the village and that its strategic position and public transport accessibility lend support to it being treated as a sustainable settlement capable of accommodating further growth.
That broader conclusion is reinforced by the Deposit Plan itself. Paragraph 6.16 expressly identifies St Nicholas as one of the smaller rural settlements which contains a primary school serving a wider catchment area. The Plan goes on to recognise that, due to the functional links between rural settlements, it is essential to ensure that existing services and facilities are safeguarded, supported or enhanced where appropriate. Those are helpful and important acknowledgements.
However, notwithstanding that evidence, the policy framework remains highly restrictive. The Deposit Plan states that, in Minor Rural Settlements, general market housing will be limited to infill and conversion opportunities within the settlement boundary, whilst any more meaningful growth outside the Strategic Growth Area is essentially restricted to small scale affordable housing-led schemes with a minimum 50% affordable housing requirement. In our view that is too blunt an approach and is not justified by the evidence.
The reason this matters is because the Council’s own historic and current evidence points in the opposite direction. BP5 explains that the adopted LDP provided for moderate growth in Minor Rural Settlements to help meet local housing need and support existing local services. The adopted LDP Written Statement similarly states that minor rural settlements such as St Nicholas play an important role in underpinning sustainable rural communities and that there is a need for some moderate growth in these settlements. The earlier strategy therefore recognised that such locations could accommodate growth without undermining their character or function. The successful development of by Redrow of Cae Newydd, St Nicholas provides an example of how new residential development can successfully integrate into a Minor Rural Settlement.
In our view the current Deposit strategy has moved too far away from that balanced position. The Plan now acknowledges the sustainability credentials of St Nicholas but does not allow those credentials to translate into an appropriate development role. That disconnect between the evidence and the policy response is one of the main reasons why the Plan, as drafted, is not sound.
Accordingly, Policy SP2 should be amended. At the very least, it should be recast so that settlements such as St Nicholas are not treated as locations where only very limited growth can occur. A more proportionate and evidence-led approach would be to allow moderate mixed-tenure growth in the more sustainable Minor Rural Settlements, where this is supported by site-specific evidence and good placemaking. That would better reflect both the Council’s own settlement appraisal and the adopted LDP approach that preceded it. As drafted, the Plan expects a great deal from a very limited rural supply offer. It seeks to secure a minimum 50% affordable housing provision on qualifying sites, requires the mix of homes to respond to latest evidence, including specialist and older persons’ needs, and recognises the need for both affordable and market housing to support mixed communities in rural areas. The Plan also acknowledges the functional role of Minor Rural Settlements such as St Nicholas and the importance of supporting local services within them. In our view, those objectives are unlikely to be achieved through the very limited number of affordable housing-led allocations currently proposed. Additional sites in the more sustainable Minor Rural Settlements are therefore required if the Plan is to deliver what it seeks in a realistic, deliverable and sustainable manner.
Policy SP6 – Housing Requirement Position: Object
Barratt Redrow objects to Policy SP6.
Whilst we support the Council’s intention to plan positively for housing growth through an up-to-date RLDP, the proposed housing requirement of 7,890 dwellings is not considered sufficiently ambitious and, in our view, is no longer justified by the most up-to-date evidence. The Deposit Plan identifies a requirement of 7,890 dwellings, equating to 526 dwellings per annum, with provision for 8,660 homes once the 10% flexibility allowance is applied. That requirement remains rooted in the RLDP’s dwelling-led scenario, which the LHMA explains was derived from average completions over a 10-year period. In our view, that is too conservative an approach in present circumstances.
PPW and the Development Plans Manual is clear on this point. PPW sets out the following requirements for local authorities when setting a housing requirement at paragraph 4.2.6:
“The latest Welsh Government local authority level Household Projections for Wales, alongside the latest Local Housing Market Assessment (LHMA) and the Well-being plan for a plan area, will form a fundamental part of the evidence base for development plans. These should be considered together with other key evidence in relation to issues such as what the plan is seeking to achieve, links between homes and jobs, the need for affordable housing, Welsh language considerations and the deliverability of the plan, in order to identify an appropriate strategy for the delivery of housing in the plan area. Appropriate consideration must also begiven to the wider social, economic, environmental and cultural factors in a plan area in order to ensure the creation of sustainable places and cohesive communities.”
The Deposit Plan housing requirement is based on past delivery rates and does not take account of the above policy requirements. Whilst past build rates can be used as a benchmark for comparison, it is not appropriate for this to be used to set the future growth of the Authority Area. The Development Plans Manual states the following in this respect:
“5.55 Extrapolating forward past take-up rates for both jobs and homes over various time periods gives a factual representation of what has been delivered in the past. This approach can provide a useful benchmark against which to compare future employment and household growth, assuming previous conditions remained constant. However, this may have been constrained by contextual influences applicable at a previous point in time, for example global economic markets, or have led to undesirable outcomes which should not be repeated, such as a mismatch between the number of homes and jobs.
5.56 It will be important to understand the relationship between the past and the future direction of the plan, including such contextual circumstances. If there are/were limitations that hindered the ability to deliver growth previously, then until mechanisms are in place to address such matters this could have a bearing on future growth levels. Understanding the context within which delivery was/can be achieved will be important, particularly when considering a housing trajectory as this could influence the speed and increase delivery rates, or conversely result in a delivery cap until such matters are resolved.
5.57 Just relying on past build rates as the sole evidence base to quantify future employment and housing land requirements is not sufficient on its own. Additional evidence will be required to identify the scale of new jobs and homes necessary and the related land requirement.”
Contextual factors that mean utilising past build rates in setting future housing growth is inappropriate include:
• Utilising past build rates incorporates recession-based trends. This includes supressed build rates following the 2008 recession and more recently, reduced housing completions as a result of the Covid-19 pandemic and the current cost of living crisis;
• Does not actively seek to address the area’s ageing demographic;
• Does not reflect or take account of the Vale of Glamorgan’s position within a Growth Area within Future Wales;
• Does not seek to leverage any of the investment into the region through the CCR City Deal;
• Conflicts with the Deposit Plan’s ambition in terms of Homes For All and the Economy – in that there has been no recent job growth in the Vale of Glamorgan delivered under the current LDP and there is a shortage of housing and affordable housing. Applying the same build rate over the RLDP plan period would compound these issues; and
• During the period considered, many people were prevented from forming new households due to a lack of mortgage finance, lower employment levels and reduced rates of housing completions. There is a considerable body of evidence to show that household formation will return to long term trends if housing is made available. Research by the former National Housing and Planning Advice Unit (NHPAU)4 found that cohorts who are less able to access home ownership earlier in their housing career due to “boom” or “recession” factors impacting on affordability are nevertheless able to “catch-up” later on – 80% of the gap at the age of 30 is “caught-up” by the age of 40. This finding supports the resumption of long-term household formation trends.
In short, just relying on past build rates as the sole evidence base to quantify future housing land requirements is not sufficient on its own, and that additional evidence is required to identify the scale of new homes necessary, with alternative scenarios considered rather than simply extrapolating previous delivery trends. That is directly relevant here. A housing requirement derived too closely from historic completion rates risks baking in past under-delivery rather than planning positively for future need.
That concern is reinforced by the updated Welsh Government evidence published after the RLDP’s preferred growth scenario was formulated. The latest 2025-based estimates of additional housing need identify newly arising need in Wales of between 7,800 and 9,300 additional homes per annum over the first five years, with a central estimate of around 8,700 homes per annum, alongside a separate estimate of existing unmet need of 9,400 homes. Whilst those are national figures and do not automatically translate into a single local housing target, they plainly point towards a materially higher level of need than has previously been assumed and strengthen the case for local planning authorities, particularly in growth areas, to revisit conservative housing requirements.
The updated 2022-based household projections point in the same direction. Welsh Government’s latest figures show that the number of households in Wales is projected to increase by 7.2% between mid-2022 and mid-2032, and that the Vale of Glamorgan is projected to experience one of the largest percentage increases in Wales, at 11.7%. The same release notes that the Vale is also amongst the authorities expected to experience some of the strongest private household population growth. In short, the latest demographic evidence does not support a low-growth or “business as usual” response for the Vale. It points the other way.
This sits uncomfortably with the Council’s own housing evidence. The Deposit Plan records that the Vale has the highest affordability ratio in Wales and a significant need for affordable homes. It further records that the LHMA identifies affordable housing need averaging 461 dwellings per annum over 15 years using the principal projections, rising to 502 dwellings per annum under the RLDP projection figures. The Deposit Plan also acknowledges that only a proportion of new households will require affordable housing because others will meet their needs through the market. That is important, because it underlines the need for both affordable and open market housing, and therefore for a higher overall housing requirement than the Plan currently proposes.
The Deposit Plan principally seeks to address issues of affordability through a blanket 50% affordable housing requirement on sites other than the Key Sites. Whilst we fully support the Council in looking to address issues of affordability, we consider that an increase in the housing requirement and subsequent increase in housing supply (both open market and affordable) should be pursued.
There is a broader strategic point as well. The Vale sits within the wider Cardiff housing market and the Deposit Plan itself recognises the strong migration relationship with Cardiff and the role that strategic collaboration should play in considering housing growth. Against that background, and having regard to the updated Welsh Government evidence, the present requirement of 7,890 dwellings does not appear sufficiently ambitious for a National Growth Area authority with strong migration inflows, severe affordability pressures and one of the highest projected household growth rates in Wales. In our view, the Plan should test a higher housing requirement through examination.
A higher growth rate, such as the PG-5Y scenario or higher should be adopted to better align housing and job growth and redress socio economic trends. The likelihood of this of level of growth occurring is even greater in the context of the ambition and funding available to support the City Deal. However, in seeking to deliver the economic vision for the area, it is important to ensure that economic growth is not constrained by a lack of land (for either housing or employment).
Whilst this is higher than past build rates, it should be noted that build rates are closely related to the availability of deliverable sites; therefore, the allocation of sufficient housing land in the RLDP would go a long way to increasing delivery. Current delivery rates have been supressed by wider socio economic trends and reliance within the existing LDP on large strategic sites (i.e. Barry Waterfront). Basing the RLDP Growth Option on past delivery would therefore result in an increase in the number of suppressed households. There is no rationale or justification to set future housing need by reference solely to past delivery rates.
The key point for soundness is therefore a simple one. The Development Plans Manual requires a housing requirement to be grounded in a broad evidence base and not simply in past completion trends. The latest demographic and housing need evidence now available points towards stronger growth pressure than that reflected in Policy SP6. In those circumstances, retaining the current requirement without revisiting it would not, in our view, be consistent with the Development Plans Manual or with a genuinely evidence-led plan-making exercise.
The Council’s own evidence supports the use of a 4% household-to-dwelling conversion factor. The LHMA states that the RLDP preferred growth scenario assumes growth of 7,586 households, which equates to 7,890 dwellings once vacancy rates are applied, effectively applying a 4% uplift in practice. That approach is also consistent with the adopted Vale of Glamorgan LDP, which expressly applied a
1.04 household-to-dwelling conversion ratio in deriving part of its housing requirement. In those circumstances, and absent any robust local evidence justifying a different factor, it is entirely appropriate to apply the Development Plans Manual baseline uplift of 4% to any updated household-led requirement. On that basis, a requirement of 9,623 households would convert to 10,008 dwellings, which is around 26.8% above the 7,890 dwellings currently sought under Policy SP6 and further underlines that the Deposit RLDP is not sufficiently ambitious in housing terms.Accordingly, Policy SP6 should be amended to provide for a higher housing requirement. The precise figure is ultimately a matter for examination, but the current requirement is too low, too closely tied to past build rates, and insufficiently responsive to updated Welsh Government projections and housing need evidence. A higher requirement would also require a broader and more resilient supply portfolio, which in turn strengthens the case for additional deliverable sites in sustainable settlements such as St Nicholas.
Policy SP6 – Flexibility, housing land supply and trajectory Position: Object
Barratt Redrow also objects to the level of flexibility embedded within Policy SP6 and raises concern regarding the resilience of the housing land supply and the robustness of the housing trajectory.
The Development Plans Manual is clear that housing supply is the housing requirement plus a flexibility allowance. It further states that it will be extremely rare for all sites identified in a plan to come forward within the timescales anticipated, and that a development plan will not be effective if it cannot accommodate changing circumstances. For that reason, a flexibility allowance must be embedded into the plan. Whilst the Manual says that 10% may be a starting point, it also makes clear that the level of flexibility is for each authority to determine based on local issues and that any chosen level must be robustly evidenced.
In our view, a 10% flexibility allowance is not sufficient in the context of this Plan. The Deposit Plan’s housing provision of 8,660 dwellings is made up of 3,837 dwellings from the existing land supply, 3,520 dwellings on allocated sites and 1,303 dwellings from windfalls. The Council’s housing land supply paper then shows that the allocation component itself includes 959 dwellings on rolled-forward LDP sites, 2,278 dwellings on key housing allocations, 122 dwellings on affordable housing-led sites and 161 dwellings on other allocations. That is a relatively exposed and finely balanced supply portfolio.
The resilience issue is due to a substantial element of the supply depends on a relatively small number of key sites, a significant rolled-forward component, and a large windfall assumption. The Development Plans Manual states that rolled-forward allocations require careful justification, that there must be a substantial change in circumstances to demonstrate such sites can be delivered and justify being included again, and that clear evidence will be required that those sites can be delivered. That is a demanding test, as it should be. In our view, the Plan’s reliance on rolled-forward sites and key sites means that a modest flexibility allowance of 10% does not provide a sufficient margin of safety.
The housing trajectory also warrants closer scrutiny. The Development Plans Manual describes the housing trajectory as the key mechanism for demonstrating how all sites will be delivered in the identified timescales throughout the whole plan period. It states that lead-in times for larger sites, inter-relationships between sites, constraints, infrastructure timing and assumptions for both large and small windfalls must all be taken into account. It also requires trajectories to provide a steady flow of sites through the plan period and not to be unduly loaded towards the end of the period.
Against that benchmark, there is a legitimate question over whether the RLDP trajectory is sufficiently robust. The Council’s own housing land supply paper records stakeholder concerns that the trajectory shows a significant step change in delivery above previous rates, that there is too great a reliance on key sites, and that the assumed timescales for pre-application work, application determination and discharge of conditions are too short. The consultation summary specifically records concern that delivery rises from around 400 to 500 dwellings per annum in the early monitored years to around 1,000 dwellings per annum by 2027/28, and that this represents a marked and pronounced step change. Those are not peripheral issues; they go directly to the credibility and resilience of the trajectory.
The same background paper also confirms that over 25% of the Plan’s total provision is attributed to key sites. Again, that does not make the Plan unsound in itself, but it does mean the trajectory and flexibility allowance need to be particularly robust. In our view, the current Plan does not yet demonstrate that level of resilience. The delivery assumptions may prove achievable, but the point for examination is that they require close scrutiny and should not simply be accepted at face value, particularly when the Development Plans Manual emphasises realism, flexibility and steady delivery through the full plan period.
There is also a concern about the windfall component. The Council’s evidence assumes delivery of 1,303 dwellings from large and small windfall developments over the lifetime of the plan. The Development Plans Manual accepts that windfalls can form part of supply, but it also requires the assumptions behind them to be evidenced and scrutinised. Here, the windfall figure is material, not marginal. That is another reason why the resilience of the identified allocation portfolio matters so much. Where a plan is relying on rolled-forward sites, key sites and substantial windfalls all at once, there is a stronger case for a higher flexibility allowance and for a broader pool of deliverable sites.
In our view, the sounder approach would be to increase the flexibility allowance from 10% to 15% and broaden the supply base through the inclusion of additional sustainable and deliverable sites. That would better reflect the Development Plans Manual’s requirement for plans to remain effective in the face of delay and changing circumstances, and it would reduce the risk of the RLDP becoming over-dependent on a narrow set of sites and optimistic delivery assumptions. It would also be entirely consistent with wider Welsh plan-making practice, where flexibility allowances above 10% have been accepted where local circumstances justify it. By way of example, Flintshire’s adopted LDP applies a flexibility allowance of over 13%, while Bridgend’s recently adopted RLDP provides for a 14% flexibility allowance following examination. Against that background, and having regard to the Vale RLDP’s reliance on key sites, rolled-forward allocations, a substantial windfall component and a stepped housing trajectory, a 15% allowance is justified here as a proportionate and robust response to the particular delivery risks of this Plan.This point also links directly back to St Nicholas. If the Plan is to be made sound, it should not rely so heavily on a small number of large, longer-lead sites and on a substantial windfall allowance. It should include a broader range of deliverable sites capable of contributing earlier and more reliably to the housing trajectory. A sustainable, mixed-tenure site at St Nicholas would assist in precisely that respect by diversifying the supply portfolio and improving resilience.
Policy SP7 – Affordable Housing Provision Position: Support in principle / Object in part
Barratt Redrow supports the objective of delivering affordable housing and agrees that this is one of the key issues the RLDP must address. Policy SP7 is therefore supported in principle. However, the policy should be read in conjunction with a more ambitious overall housing strategy, because affordable housing delivery cannot sensibly be divorced from the wider question of total supply.
The Deposit Plan is clear that the delivery of affordable housing is a key objective of the RLDP and that the strength of the Vale’s housing market has resulted in many local people experiencing difficulties in purchasing suitable housing on the open market. Barratt Redrow supports that objective in principle. The policy also correctly identifies that a mix of affordable housing will be required, with reference to the LHMA, and that this should include a range of tenures, types and sizes of homes. That said, the wording of Policy SP7 lacks sufficient clarity. In particular, the reference to the affordable housing mix being “informed” by the LHMA is ambiguous. It is unclear whether the LHMA is intended to provide a broad evidence base and starting point for negotiation, or whether the Council expects schemes to replicate that mix as a fixed requirement. In our view, the policy should be clarified so that the LHMA is expressly treated as a guiding framework rather than a prescriptive formula, with the final tenure mix, type and size of affordable provision being determined having regard to site-specific circumstances, up-to-date evidence, viability and deliverability.The LHMA is highly relevant here. It explains that affordable need is no longer confined to traditional social rented housing and that current economic conditions have squeezed many households out of both home ownership and the private rented sector, creating additional need for intermediate rent and low-cost home ownership products. It also notes that an ongoing supply of new build properties remains important to the operation of assisted home ownership products in the Vale.
That evidence is important because it confirms there is a need for both affordable and open market housing. The market sector is not separate from the affordable housing challenge; it is part of how that challenge is addressed. The LHMA also makes clear that only a proportion of new households will require affordable housing because others will meet their needs through the market. This is another reason why the overall housing requirement matters so much.
There is also a more local point relevant to St Nicholas. The LHMA identifies St Nicholas & Llancarfan as a distinct housing market area and shows need arising there across tenures. It is therefore not correct to approach St Nicholas on the basis that only one tenure or one product type is needed. The evidence points to a requirement for a broader mix.
The Deposit Plan itself supports that conclusion. It acknowledges that, in meeting Policy SP7, a range of affordable tenures, types and sizes of homes will be required. It also records that the Council will seek to secure an appropriate level and mix of affordable housing in all proposed residential developments.
In our view, the main issue with Policy SP7 is therefore not its objective, but the fact that the rest of the strategy is not sufficiently ambitious to support it. The Plan cannot identify very substantial affordable need and then pursue a relatively low overall housing requirement combined with a narrow rural growth model. A sound approach would be to increase the overall housing provision and broaden the pool of sustainable and deliverable mixed-tenure sites so that affordable housing delivery through the planning system can be maximised. St Nicholas should form part of that response.
Policy SP8 – Affordable Housing Requirements Position: Support in principle / Object in part
Barratt Redrow supports the principle that residential development should contribute towards affordable housing need. However, there are concerns about how Policy SP8 interacts with the rest of the strategy, especially outside the Strategic Growth Area.
The Deposit Plan confirms that, within Primary and Minor Rural Settlements, new development will generally be required to provide 40% affordable housing. It also confirms that outside delineated settlement boundaries proposals for additional housing will be strictly controlled and limited to affordable housing exception sites or housing in support of rural enterprises. The Plan then layers on the separate affordable housing-led model under Policy HG4, where a minimum of 50% affordable housing is required.
In principle, Barratt Redrow has no issue with seeking ambitious affordable housing delivery where supported by viability evidence. The concern is that the overall strategy becomes too rigid when SP8 is read alongside SP2, SP3, HG4 and other potentially onerous policy requirements, including Policy CC1. In practice, this risks leaving sustainable settlements such as St Nicholas with very little scope to contribute to general housing delivery unless schemes meet a highly demanding affordable-led model. That is not a balanced or flexible way to plan for rural communities. It also gives rise to a lack of clarity between Policies SP7 and SP8 which should be addressed. Policy SP7 states that the mix of affordable housing to be delivered over the plan period will be “informed” by the LHMA, waiting list data and the Older Persons Housing Strategy, but it is unclear whether that is intended simply as a starting point for negotiation or whether the Council expects the identified mix to be applied more prescriptively. By contrast, Policy SP8 expressly provides greater flexibility: it states that affordable housing will be negotiated on a site-by-site basis having regard to evidenced viability, that the exact mix of affordable housing will be considered on a case-by-case basis having regard to the Council’s latest needs evidence, and that where proven economic circumstances affect delivery the Council may negotiate the level, type, tenure and nature of provision. In our view, those two policies should be aligned. That would better reflect Planning Policy Wales, which requires planning authorities to develop evidence-based market and affordable housing policies, but also makes clear that affordable housing targets and policy expectations must take account of deliverability and viability considerations. In that context, Policy SP7 should be clarified so that the LHMA and related evidence are expressly treated as guiding the starting point for discussions on mix, rather than imposing a fixed outcome irrespective of site-specific circumstances, technical constraints, abnormal costs or viability. That is especially important given the Deposit Plan’s blanket affordable housing percentages across the Vale and the cumulative effect of other policy requirements, which may affect the deliverability of particular allocations and should therefore be capable of being addressed on a site-by-site basis.The Deposit Plan recognises that an appropriate mix of affordable housing will be required, and that in the rural Vale there is a desire for smaller market homes as well as affordable homes. It also accepts that affordable housing delivery may be lower than anticipated because of viability constraints and that, where proven economic circumstances affect delivery, the Council may negotiate the level, type, tenure and nature of provision. This should feed through into a more flexible strategy overall. In particular, the Plan should not be read or applied in a way that suppresses the delivery of mixed-tenure schemes in sustainable rural settlements where those schemes can contribute both market and affordable housing and support local services. That is especially so given the evidence in the LHMA that a range of tenures is required and that intermediate and low-cost home ownership products are an increasingly important part of the housing response.
8. Policy HG1 / Housing Allocations and overall supply portfolio Position: Comment / Object in part
Barratt Redrow does not object in principle to the Council allocating key sites and other strategic locations. However, there remains a significant concern that the Plan is overly reliant on a relatively narrow supply portfolio.
The Deposit Plan confirms that the allocation component of supply comprises 2,278 dwellings on key sites, 959 dwellings on rolled forward sites, 161 dwellings on new housing allocations and 122 dwellings on affordable housing-led sites. It also confirms that 1,303 dwellings are expected from windfalls. That means a large proportion of the Plan’s supply is tied up either in a small number of large sites, historic carry-over, or a substantial assumption about unallocated windfall delivery.
Our earlier Preferred Strategy reps raised exactly this issue and those points should all be carried forward. In particular:
• the Plan is overly reliant on a small number of key sites;
• medium-sized sites in sustainable locations can provide resilience to the housing trajectory;
• windfalls account for a significant proportion of the supply and provide less certainty over geographical distribution and delivery; and
• rolled forward allocations require careful justification if they are to be relied upon as part of the plan’s effective provision.
The Deposit Plan’s own figures support that concern. It states that only a small proportion of development is likely to take place outside of the Strategic Growth Area, with some of this reflecting permissions granted under the adopted strategy. It also shows that the total housing provision attributable to Minor Rural Settlements and Primary Settlements outside the Strategic Growth Area is only 390 dwellings. In our view that is too low, particularly given the evidence that some of those settlements perform relatively well and can help diversify the supply portfolio.
Based on the revised RLDP Delivery Agreement, should there be no further slippage the RLDP will be adopted in September 2027 with there being some 7 years before the end of the plan period (of 2034) post-adoption. There may of course be some slippage in the adoption of the RLDP. We therefore would query whether the quantum of homes proposed on the larger Key Sites can realistically be delivered within the plan period.
The following conclusions of Lichfield’s Start to Finish (2nd Edition, Feb 2020) research are relevant in this respect:
• From the date at which an outline application is validated, the average figures can be 5.0-8.4 years for the first home to be delivered.
• If a scheme of more than 500 dwellings has an outline permission, then on average it delivers its first home in circa 3 years.
• The average build out rate of sites between 500-999 dwellings is 68 homes per annum and 107 homes per annum for sites between 1,000 and 1,499 dwellings.
All of the Key Sites have no outline application having been submitted. Given the revocation of TAN 1 and Welsh Government’s emphasis on a plan led system, the very earliest that the Key Sites could have outline permission in place would be post-adoption of the plan limiting its housing land supply contribution within the early years of the plan period. Allowing for an appropriate amount of time to secure necessary permissions, consents and infrastructure delivery, the Key Sites’ contribution to housing supply within the plan period would fall significantly below the quantum currently assumed in the Preferred Strategy. In that context, it is all the more important that sustainable and deliverable medium-sized sites are included in the Plan where appropriate. Again, St Nicholas is an obvious example.
In short, the issue is not that key sites should not exist. It is that the current portfolio is not broad enough and not resilient enough. The Plan should be strengthened through the inclusion of additional medium-sized, sustainable allocations capable of delivery within the plan period.
Policy HG4 – Rural Affordable Housing Led Sites Position: Support in principle / Object in part
Barratt Redrow supports the principle of identifying rural affordable housing-led sites. It is entirely appropriate that the RLDP seeks to respond to local housing need in rural communities and to secure affordable provision in settlements where opportunities may otherwise be more limited.
However, Policy HG4 also illustrates the broader weakness in the Plan’s current rural strategy. The Deposit Plan allocates four affordable housing-led sites at Colwinston, Aberthin, Wick and Fferm Goch, totalling 122 dwellings. It also requires applicants to demonstrate how both the market and affordable housing on those sites will meet local housing needs in terms of tenure, type and size, so that a range of housing is delivered to meet different groups in the community. The supporting text then expressly notes that Planning Policy Wales requires a sufficient number of sites suitable for the full range of housing types, and that in the rural Vale there is demand for smaller market homes as well as affordable homes.
Those are important statements and, in our view, they assist the case being made here. They show that the Council itself accepts that rural settlements need a range and choice of homes, not just affordable housing in isolation. They also show that some open market housing in rural locations is not only acceptable, but in fact part of how mixed communities and affordable delivery are achieved.
The problem is that the strategy remains too narrow in how it applies that logic. The Plan effectively says that outside the Strategic Growth Area, growth should generally be confined to affordable-led schemes with a minimum 50% affordable requirement, and anything below that will not be supported. In our view that is too rigid and may well suppress otherwise sustainable and beneficial development, particularly where sites are capable of delivering a strong policy-compliant affordable contribution but not necessarily the precise affordable-led model the Council has chosen.
We continue to raise concerns that a blanket 50% affordable requirement could create deliverability issues, including reliance on complex developer/RSL arrangements and a level of uncertainty around funding and market conditions. Without repeating every operational point, the central planning concern remains valid: the strategy should not be so rigid that it prevents settlements from growing and adapting in a sustainable way. This is especially the case given the ever more challenging delivery context set by increasingly onerous policy requirements.
St Nicholas is relevant here because it demonstrates the missed opportunity in the current approach. The village is expressly identified by the Council as one of the smaller rural settlements with a primary school serving a wider catchment area. It performs well in the settlement appraisal and is the sort of place where a sensitive mixed-tenure allocation could help support local services, provide both market and affordable housing, and diversify the Plan’s supply. In our view, the omission of St Nicholas from the rural housing strategy is not justified by the evidence currently before the Council.
Policy CC1 – Residential Operational Net Zero Carbon Development Position: Object
Barratt Redrow supports the wider objective of improving the energy performance of new homes and reducing carbon emissions from development. However, Policy CC1 in its current form gives rise to a number of concerns regarding consistency with national standards, deliverability, viability and practical implementation. The Deposit Plan is explicit that Policy CC1 is intended to require new dwellings to exceed current Building Regulations standards. Welsh Government’s own sustainable buildings guidance confirms that Building Regulations set mandatory standards for the design and construction of buildings, including environmental performance. In our view, that raises a legitimate question as to whether an additional local policy layer of this kind is necessary or proportionate, particularly where it risks inconsistency across local planning authorities and may duplicate, or move ahead of, the national regulatory framework.
There is also a need for greater precision in the policy wording itself. As drafted, Policy CC1 requires development to provide on-site renewable electricity generation equivalent to at least the annual energy consumption of the development, assessed through an energy performance model. The supporting text explains that the relevant metric is Energy Use Intensity, which measures all energy consumed by the building. If the policy approach is to be progressed, the policy should make clear that compliance relates only to regulated energy use, consistent with Building Regulations methodology. Developers can influence the performance of the building fabric and regulated building services, but they cannot control future occupant behaviour, appliance use, plug loads or other forms of unregulated energy demand. Without that clarification, there is a risk that the policy extends beyond matters that can reasonably and consistently be secured through the planning process.
A further issue is that the policy should expressly allow its requirements to fall away, or be treated as satisfied, where national Building Regulations subsequently catch up with or exceed the standards sought under Policy CC1, or where the national regime adopts a different but equivalent methodology. Without such a safeguard, there is a real risk that the RLDP imposes outdated or duplicative requirements later in the plan period, which would not only create unnecessary complexity but could also compromise the delivery of much-needed housing. That concern is heightened by the cumulative policy burden elsewhere in the Plan, including affordable housing, open space, placemaking, green infrastructure and other low carbon requirements. In our view, the Council should therefore demonstrate, through its viability work, that the housing allocations in Policy HG1 are capable of absorbing the cumulative costs of Policy CC1 alongside the wider requirements of the RLDP.
Clarification is also required in relation to the fallback Project Zero Fund contribution. The Deposit Plan states that where it is not technically feasible to provide a policy-compliant level of renewable energy on site, the residual energy is to be offset through an appropriate contribution to the Council’s Project Zero Fund “as far as economic viability allows”, with further detail to be provided in SPG. In our view, that is presently too uncertain. The policy should make clear how any such contribution will be calculated, what assumptions will be used, what evidence will be required, and how viability will be taken into account. These are all matters which go directly to deliverability and should not be left entirely to post-adoption guidance.
In summary, Building Regulations are sufficient to achieve Welsh Government’s objectives for improving energy efficiency and delivering net-zero carbon development. Additional local policy requirements risk creating inconsistency across Local Planning Authorities and may exceed what is necessary to align with national policy. If a local approach is to be taken, as a minimum, Policy CC1 should be amended so that: (i) it applies only to regulated energy use; (ii) its requirements fall away, or are deemed satisfied, where Building Regulations subsequently meet or exceed them or adopt an alternative national methodology; and (iii) the policy and supporting text provide a clearer framework for viability, Project Zero contributions and practical implementation.
Policy CI1 – Open Space Provision
Position: Support in principle / Object in part
Barratt Redrow supports the objective of ensuring that new development makes appropriate provision for open space and recreation. That is entirely consistent with good placemaking and with national policy support for healthy, inclusive and green environments. However, Policy CI1 as drafted is overly prescriptive and, in our view, requires amendment to provide greater flexibility and to better reflect local context and design-led principles.
The main concern is the way in which the policy translates the Fields in Trust benchmarks into a rigid per-dwelling requirement of 62.2 sq m per dwelling. The Deposit Plan itself recognises, at paragraph 6.233, that on-site provision should be design led rather than standards led, and that the type of provision should respond to local context and identified local need having regard to the Open Space Background Paper. That is an important and sensible acknowledgement. In our view, however, the policy wording pulls in the opposite direction by setting out what reads in practice as a uniform quantitative requirement. Fields in Trust guidance is ordinarily framed around population and typologies, to be applied strategically and flexibly, rather than as a blanket per-dwelling metric irrespective of scheme context, form and composition. A rigid application of the standard risks disproportionate land take, unnecessary design constraints and, ultimately, pressure on viability and delivery.
There is also concern regarding the separate requirement for an Open Space Strategy for all housing and commercial developments meeting the thresholds. In many cases, the provision of open space within a development will already be addressed through the Design and Access Statement, Green Infrastructure Statement and the overall layout and placemaking rationale of the scheme. We would therefore question whether a standalone Open Space Strategy is necessary in every case. In our view, the policy should be amended so that open space can be addressed through the principal design and green infrastructure material submitted with the application, unless there is a particular site-specific reason why a separate strategy is required. That would avoid unnecessary duplication without weakening the quality of assessment.
Change sought: amend Policy CI1 and supporting text to make clear that the benchmark standards are to be applied flexibly and strategically, having regard to site context, typology and local need, and that open space provision may be addressed through the Design and Access Statement and/or Green Infrastructure material rather than requiring a standalone Open Space Strategy in every case.
Policy SP4 – Placemaking
Position: Support in principle / Comment
Barratt Redrow supports Policy SP4 in principle. The emphasis on placemaking is fully consistent with Planning Policy Wales and with the Deposit Plan’s wider design-led approach to development. The policy framework rightly seeks to ensure that major development is shaped by the placemaking principles from the outset.
That said, the wording of the policy should better reflect the position already set out in the supporting text. Paragraph 6.34 of the Deposit Plan makes clear that the required Placemaking Statement should form part of the Design and Access Statement for most major planning applications. That is helpful and sensible. In our view, the policy itself should say the same thing expressly, so that there is no suggestion that applicants are expected to prepare a separate freestanding document in addition to the DAS.
Suggested wording amendment:
“Major development proposals must be supported by a Placemaking Statement, to be incorporated within the Design and Access Statement where one is required, demonstrating clearly how the proposal accords with the placemaking principles of the Plan.”
That amendment would improve clarity, avoid duplication and align the policy wording with paragraph
6.34 of the supporting text.
Policy SP5 – Creating Healthy and Inclusive Places and Spaces Position: Support in principle / Comment in part
Barratt Redrow supports the objective of creating healthy and inclusive places and spaces and agrees that health and well-being are legitimate and important planning considerations. The wider thrust of Policy SP5 is consistent with PPW’s placemaking agenda and with the Deposit Plan’s recognition that the built environment can have a significant influence on health outcomes.
However, there is a need to ensure that the assessment requirements under Policy SP5 are proportionate and do not create unnecessary cost and duplication. The policy requires all qualifying major development to undertake screening at pre-application stage and, for significant developments, a rapid Health Impact Assessment. The supporting text explains that a rapid HIA may involve literature review, stakeholder engagement and wider evidence gathering. In our view, whilst that may be appropriate for larger or more complex schemes, the policy should recognise more clearly that the health implications of development will often already be addressed through the Design and Access Statement, Placemaking Statement, Green Infrastructure material, Transport Assessment and related application documents. There is a risk that the current wording adds a further procedural burden, with associated cost implications, without always adding materially new value.
We therefore consider that the policy should be applied proportionately, with the checklist and any rapid HIA focused on developments where there is a realistic prospect of significant or complex health implications, rather than as a routine additional requirement in every qualifying case. The policy would also benefit from clarification that the conclusions of the screening/HIA can be incorporated into the main design and supporting statements submitted with the application, rather than requiring standalone reporting unless specifically justified by the scale or sensitivity of the proposal.
Change sought: amend Policy SP5 and/or its supporting text to confirm that health assessment requirements will be applied proportionately, and that the outcomes of the checklist or rapid HIA may be integrated within other application documents, including the Design and Access Statement, Placemaking Statement and Green Infrastructure material, unless a standalone report is specifically justified.
Policy CC2 – Presumption Against Demolition Position: Support in principle / Object in part
Barratt Redrow supports the broad objective of encouraging the repair, refurbishment, re-use and re-purposing of existing buildings where that represents the most sustainable outcome. The policy’s underlying intent, to avoid unnecessary loss of embodied carbon and encourage circular economy principles, is understood.
Nevertheless, Policy CC2 as drafted is overly onerous and risks giving rise to unintended consequences for deliverability. The policy establishes a strong presumption against demolition and requires extensive justification through either a Demolition Statement or an Energy Report / Whole Life Carbon Assessment. Whilst that may be appropriate in certain cases, a blanket presumption of this kind risks frustrating otherwise sustainable redevelopment proposals, including proposals involving poor quality farm buildings, obsolete structures, and buildings that are not well suited to modern standards of layout, accessibility, thermal performance or efficient land use. In some cases, insisting on retention or retrofit may not represent the most sustainable outcome overall.
There is also a tension with the wider objective of making the most effective and efficient use of land. Some buildings may be technically capable of retention, but only at disproportionate cost, with compromised design outcomes or reduced site efficiency. On previously developed or rural redevelopment sites alike, that could affect development timescales, viability and ultimately the ability to bring forward policy-compliant schemes. The policy does contain some flexibility through criteria 3 and 4, which recognise that a lower net carbon solution may in some circumstances arise from demolition and redevelopment. However, in our view, the overall wording still leans too heavily towards a presumption against demolition rather than a balanced assessment of the most sustainable whole-life outcome in each case.
The policy would therefore benefit from a more balanced formulation which supports retention and reuse where appropriate, but does not create a disproportionate barrier to demolition where redevelopment would deliver a better placemaking, operational carbon, viability or land-use outcome. That is particularly important in relation to sites containing redundant agricultural or rural buildings, and sites where retrofit would be impractical, inefficient or environmentally sub-optimal.
Change sought: amend Policy CC2 so that it supports the retention and re-use of existing buildings where feasible and sustainable, but allows demolition where this would deliver a more effective overall development outcome having regard to whole-life carbon, operational performance, design quality, viability, land efficiency and deliverability.
Land at St Nicholas / omission from the Deposit Plan Position: Object to omission
Barratt Redrow objects to the omission of land at St Nicholas from the Deposit Plan.
The case for St Nicholas is, in our view, strong and is rooted in the Council’s own evidence base. As already noted, the settlement performs strongly in the BP5 appraisal, the adopted LDP and current review both identify the role of minor rural settlements in supporting sustainable communities, and both the adopted LDP and the current Deposit Plan recognise the specific significance of St Nicholas as a village with a primary school serving a wider catchment area.
Deposit Plan Conclusion
Overall, Barratt Redrow is supportive of the Council’s continued work in preparing the RLDP and supports the objective of putting in place a robust, plan-led framework for growth in the Vale of Glamorgan. However, the Plan in its current form is not sufficiently ambitious and requires modification in order to be sound.
In particular:
• The Plan Period is too short. An extended plan period (and associated increase in housing requirement) is required to provide for at least ten years post adoption;
• the housing requirement under Policy SP6 is too low and is too closely tied to past build rates;
• the 10% flexibility allowance is not sufficient given the structure and risk profile of the supply;
• the Plan relies too heavily on key sites, rolled forward sites and windfalls;
• the strategy for settlements outside the Strategic Growth Area is too restrictive and does not properly reflect the evidence on bus-connected, serviceable and functionally linked settlements; and
• the omission of St Nicholas is not justified by the Council’s own evidence base.
The evidence before the Council supports a stronger role for St Nicholas. The adopted LDP and current BP5 review both recognise the role of Minor Rural Settlements in supporting sustainable rural communities and providing for moderate growth. The Deposit Plan itself acknowledges St Nicholas’ role as a settlement with a primary school serving a wider catchment area. The LHMA demonstrates that there is a need for a range of housing products and tenures, and the Deposit Plan itself accepts that rural areas require both affordable and market housing to meet local needs.
For those reasons, Barratt Redrow seeks amendments to Policies SP1, SP2, SP6, SP7, SP8 and HG4, together with a more flexible and resilient housing strategy overall, and the inclusion of land at St Nicholas as an appropriate and deliverable source of mixed-tenure housing growth within the RLDP period.
Candidate Site Register - Site ID 486
Land to the south of the A48 at St Nicholas (Site ID 486) is being promoted by Barratt Redrow for a residential-led development.
Stage 2 Candidate Site Assessment
The Council’s Stage 2 Candidate Site Assessment states:
“The development would have an adverse impact on the character and setting of the St Nicholas Conservation Area and would also be considered to represent an unacceptable intrusion in to the open countryside. Predictive Agricultural Land Classification Map indicates that the site is Grade 3a agricultural land loss of this land would be contrary to national policy.”
The key issues raised are all capable of being overcome as part of the ongoing promotion of the site, as set out below:
Impact upon Character and Setting of the St Nicholas Conservation Area
Wessex Archaeology have prepared a Heritage Appraisal in support of the site’s development. This concludes that future development within the site would unlikely cause harm to the significance of the designated heritage assets if the development is in keeping with the surrounding built character.
The impact upon the character and setting of the St Nicholas Conservation Area is considered acceptable and the site is considered to be the best option to accommodate the growth of St Nicholas in a sensitive manner, particularly with regard to the following:
• The Site is located outside of the Conservation Area whereas other fields outside the settlement boundary (e.g. to the south of The Manor House) are within the Conservation Area;
• The Conservation Area covers the majority of St Nicholas and most options for the village’s growth would be within its setting;
• PPW Para. 6.5.22 advises that proposals should be tested against a Conservation Area Appraisal where they are available. The St Nicholas Conservation Area Appraisal does not identify any features or important characteristics on the candidate site; and
• The proposals for the site are being developed so that they are sensitively designed, in keeping with the surrounding built character and retain important landscape features and views beyond the site.
Countryside Impacts
The Urbanists have undertaken a Landscape and Visual Appraisal in support of the site’s development. It concludes that the site could be developed without causing unacceptable visual impacts on key receptors, the landscape character and types within the proposed site and its surrounds, with the inclusion of appropriate green infrastructure enhancement and mitigation.
The emerging proposals have been underpinned by existing landscape features, with green infrastructure areas and landscape edges proposed within and around the site. New parkland and amenity spaces, footpaths along with a network of sustainable drainage features are incorporated with tree planting proposed throughout. It is accordingly considered that the proposals will sit well within the receiving landscape with limited impacts beyond its immediate setting.
Agricultural Land Quality
Technical Advice Note (TAN) 6 notes that agricultural land within Grades 1, 2, and 3a are considered to be the “most flexible, productive and efficient land in terms of output”. Paragraph 3.59 of PPW sets out the search sequence when considering allocating land within LDPs stating that poorer quality agricultural land should be considered ahead of higher quality land. Accordingly, whilst the site comprises Grade 3a agricultural land quality based on the currently available survey data, it comprises the poorest quality of other options for growth around St Nicholas. There is an overriding need for housing growth as part of the preparation of the RLDP and the allocation of the site would accord with the search sequence set out in PPW.
As the proposals for the site develop further, there is scope to include allotments/community growing areas and open space areas allowing much of the very good quality soils to be retained. The soils that are retained on site in the open spaces and gardens will still be able to provide various ecosystem functions, particularly in the support of biodiversity, and water and carbon storage.
Appendix 2 – Summary of Assessment
We comment on the Council’s Summary of Assessment as follows:
• Developer Interest: should be amended from red to green. The site is under single positive control by Barratt Redrow who have a track record of successfully developing residential-led sites within the Vale of Glamorgan.
• Historic Environment: should be amended from red to green. The site and proposal’s potential impact upon the historic environment is outlined within the candidate site submission and earlier within these representations as being acceptable.
• Special Landscape Area and Glamorgan Heritage Coast Designations: should be amended from red to green. The Urbanists have undertaken a Landscape and Visual Appraisal in support of the site’s development. It concludes that the site could be developed without causing unacceptable visual impacts on these designations.
• Environmental & Physical Constraints Conclusions: should be amended from red to green. The site is not subject to any environmental or physical constraints which cannot be accommodated through the sensitive design approach adopted by Barrat Redrow.
• Access/proximity to services and facilities conclusions: should be amended from amber to green. The Transport Appraisal which formed part of the candidate site submission evidences the site’s accessibility and proximity to services and facilities.
• Connectivity and Capacity: should be amended from red to green. The candidate site submission demonstrates the site’s capacity for the quantum of development proposed and its connectivity to the settlement and other key locations in the Vale of Glamorgan via sustainable transport modes.
• Climate Change: should be amended from red to green. The site is in a sustainable location, with a number of local facilities including a bus stop, a school, health and wellbeing facilities all within a short walk from the site as well as the retail facilities situated within acceptable cycling distances site and highly accessible by public transport. Overall, the accessible location of the development will mean that there is a reduced need for private car journeys, in turn reducing overall pollution. The development will be supported by a Travel Plan in favour of sustainable modes of travel. Moreover, the dwellings will be built to Part L 2025 which means the new homes will produce reduced levels of CO2.
• Placemaking Character and Place: should be amended from red to green. The proposals comply with the National Sustainable Placemaking Outcomes, as set out within the Appraisal which formed part of the candidate site submission.
• Suitable for Further Consideration: should be amended from red to green for the reasons set out below and within the candidate site submission.
Suitability for Allocation and Key Benefits
For the sake of brevity, we do not intend to repeat the considerable and detailed content of the Candidate Site Submission here. The previously submitted information however contained substantial information to support the allocation of the site as well as a detailed sustainability and connectivity appraisal undertaken in accordance with PPW.
In summary, the submission demonstrated that the site is suitable for allocation within the Council’s RLDP and its inclusion would help contribute to the overall soundness of the emerging Plan. The proposed site fully accords with National Sustainable Placemaking Outcomes and Sustainable Transport Hierarchy set out in PPW and the site is considered to be deliverable and viable.
The proposed development of the site would deliver the following key benefits:
• Delivering a range and choice of housing (including a proportion of affordable housing) in a sustainable location on a deliverable site which can contribute towards the resilience of the RLDP’s housing trajectory and the effectiveness of the Plan;
• The proposals would support the vibrancy of St Nicholas with the site being closely related to the settlement and capable of integrating effectively with the settlement to the benefit of existing and proposed residents;
• The provision of multi-functional open space – including amenity space for residents, play spaces, potential for local growing spaces, nature walks, sustainable drainage and wildlife habitats to achieve biodiversity enhancements;
• Encouraging and supporting active travel with cleaner, greener travel choices and reduced out commuting being located close to public transport provision;
• Good quality open spaces with significant biodiversity benefits (delivering a biodiversity enhancement), surface water resilience and efficient energy, water and communications infrastructure;
• Economic benefits – including that the proposed development is expected to:
o Support the employment of 434 people;
o Create circa £1,687,420 in additional tax, including £158,124 in council tax revenue for the Vale of Glamorgan Council.
It is accordingly concluded that allocation of the site would contribute to the soundness of the RLDP and would accord with the well-being goals specified in the Well-being of Future Generations (Wales) Act 2015.
Barratt Redrow, Highlight Planning and the project team are keen to work collaboratively with the Council and other parties to demonstrate the suitability of the land for development and its identification as an allocation in the RLDP.
I trust the above representations assist in the Council’s preparation of the RLDP. We would welcome the opportunity to discuss the above matters with the Council if that would be helpful. If you have any queries please do not hesitate to contact us.

REPRESENTATIONS TO THE DEPOSIT VALE OF GLAMORGAN REPLACEMENT LOCAL DEVELOPMENT
PLAN 2021–2036 ON BEHALF OF SETH HILL AND SON LTD
1. Introduction
These representations are submitted on behalf of Seth Hill & Son Ltd in response to the Deposit Vale
of Glamorgan Replacement Local Development Plan 2021–2036.
They relate specifically to the treatment of Pant-y-Ffynnon Quarry / Seth Hill Quarry, Bonvilston in the
Deposit Plan and the associated candidate site assessment process.
The principal concern arises from the Council’s candidate site assessment, which states that a positive
allocation for mineral working is not included because “The 2nd Review of the Minerals Regional
Technical Statement indicates no further allocations are specifically required to be identified within
the Vale of Glamorgan RLDP.”
That explanation addresses only the narrow issue of whether a fresh minerals allocation is presently
required on RTS2 arithmetic. It does not adequately address the planning merits of Pant-y-Ffynnon
Quarry itself, nor does it justify a limited or negative treatment of the site in the Deposit RLDP.
These representations therefore object to the overly narrow basis on which the site appears to have
been discounted for positive recognition and seek a more balanced and evidence-based treatment of
Pant-y-Ffynnon Quarry within the Plan.
2. Site context
Pant-y-Ffynnon Quarry is an established quarrying location with an existing mineral planning history
and an established role within the local minerals framework.
The candidate site planning statement explains that the site comprises the full extent of the currently
consented Ffynnon Quarry, together with adjoining land to the south. It confirms that the quarry
extracts limestone and that the consented quarry element is identified in the adopted LDP as a Quarry
Site, with adjoining land within the Buffer Zone and wider Mineral Safeguarding Area. The submission
sought to retain the existing LDP status of the consented element and to safeguard the potential for
further quarrying to take place on the remainder of the site in the longer term.
The candidate site statement also recorded the continuing active planning context at the site, including
application ref. 2021/01379/FUL for the resumption of limestone extraction in the North Quarry, the
establishment of an aggregates recycling facility, and restoration of the North Quarry using inert
waste materials. That position has since been materially reinforced by the ROMP determination.
Decision notice 2024/00246/ENV is a Determination of New Working Conditions for Pantyffynnon
Quarry / Seth Hill Quarry, Bonvilston. The decision provides that the new conditions replace those
attached to permissions 97/01084/FUL and 2009/00184/ENV. Condition 1 states that “No operations
authorised by this permission, with the exception of restoration and after-treatment works approved
under these conditions shall take place after 21 February 2042.” The decision also requires a detailed
working scheme, revised working programmes every five years, and imposes an annual production
limit of 250,000 tonnes.
BP25 independently corroborates the continuing active status of the quarry. It identifies Pantyffynnon
in Table 1 as an active quarry with an extraction end date of 21.02.2042. BP25 also confirms that the
Vale of Glamorgan is an “important supplier of Carboniferous limestone for general aggregate use”.
Taken together, that evidence confirms that the site is not simply a historic quarry with uncertain
prospects. It is an active quarry with a recently updated modern conditions framework and an
extraction end date beyond the RLDP period.
3. Objection to the candidate site assessment
The Council’s candidate site assessment relies on the proposition that no further allocations are
specifically required because of the RTS2 position. That reasoning is too narrow.
The statement that no further allocations are specifically required may explain why the Council has
concluded that it does not presently need to identify a fresh minerals allocation in order to meet the
current quantitative apportionment. It does not, however, address the separate issue of how the Plan
should treat an existing quarry site such as Pant-y-Ffynnon Quarry.
The absence of a current need for a new allocation is not the same as a conclusion that an established
quarry site should cease to be positively recognised, should no longer be meaningfully safeguarded,
or should be treated as strategically unimportant.
The candidate site submission itself demonstrates why the Council’s reasoning is incomplete. The
submission did not merely seek a fresh allocation on the basis of additional tonnage need. It sought
retention of the existing quarry status of the consented element and safeguarding of the wider site for
longer-term quarrying potential.
The ROMP decision strengthens that point considerably. A site that has recently been granted updated
mineral working conditions and is authorised to continue operations until 21 February 2042 cannot
sensibly be treated as though its future role is immaterial simply because current RTS2 figures do not
require a further allocation elsewhere in the Vale.
The Council’s approach is also difficult to reconcile with national plan-making guidance. The
Development Plans Manual states that plans should be based on “robust evidence” so they can be
delivered, that candidate sites should not be purposefully excluded from assessment, and that the key
objective is whether a promoter has a serious intention to bring the site forward, which links directly
to the soundness question “Will the plan deliver?”
In those circumstances, the candidate site assessment appears to conflate two distinct questions:
whether a new specific allocation is numerically required under RTS2, and whether an established
quarry site should continue to be positively recognised and safeguarded in the Plan. Those questions
are not the same. The former may currently be answered in the negative. The latter, in the case of
Pant-y-Ffynnon Quarry, should plainly be answered in the affirmative.
4. National and local policy context
The wider policy and evidence framework supports a more positive treatment of Pant-y-Ffynnon
Quarry than is reflected in the candidate site assessment.
PPW states that it is in the interests of the minerals industry that landbanks reflect “real possibilities
for future mineral working” and adds that authorities should provide “a clear guide to where nonenergy
mineral extraction is likely to be acceptable”.
MTAN1 explains that development plans should identify “dormant reserves” separately and states that
“A more realistic landbank assessment is the aim of this process” so that a more accurate picture
emerges of reserves “that are likely to have real potential for future working”. It also states that the
future landbank should include land specifically allocated for the working of aggregates as an
“extended landbank”.
The SWRAWP RTS reinforces the point that reserve arithmetic is not the whole picture. It states that
“Caution must be exercised in using these landbank figures” because the calculation does not take
account of geographical or operational aspects, changes in planning policy, protected site
designations or other permitting constraints. This is particularly relevant given the increasingly
important role of NRW licensing and abstraction controls, including quarry dewatering considerations,
which may mean that some reserves are no longer as readily available or economically viable as
historic landbank figures imply. Accordingly, apparent reserve sufficiency in quantitative terms may overstate the extent of genuinely deliverable supply. SWRAWP also confirms that dormant reserves
“must be counted separately”.
The Deposit RLDP’s own framework is consistent with that broader policy approach. The Plan
safeguards known limestone resources and retains quarry buffer zones so that incompatible
development does not prejudice mineral operations or future working. BP25 explains that the RLDP
safeguards finite mineral resources for future generations and protects them from permanent
development that could sterilise or hinder extraction.
The Plan also provides a detailed framework for sustainable mineral working, including new workings,
extensions and the reworking or reopening of old workings. That mechanism is intended to deal with
the detailed merits of mineral proposals, including environmental effects, amenity, hydrology,
transport and restoration. There is therefore no sound policy basis for adopting an unduly negative
position toward Pant-y-Ffynnon Quarry at plan-making stage simply because no fresh allocation is
currently required.
5. Benefits of continued extraction at Pant-y-Ffynnon Quarry
Continued extraction at Pant-y-Ffynnon Quarry would give rise to a number of important site-specific
and strategic benefits.
PPW expressly recognises the planning advantages of extending established quarry sites. Paragraph
5.14.48 states that “The presence of an existing quarry should be a material consideration when
considering a proposal for an extension. There may be benefits to extending a site in terms of shared
infrastructure, for instance, as opposed to working a new greenfield site.” That principle is directly
relevant to Pant-y-Ffynnon Quarry. The site is an existing quarrying location with an established
operational and planning context, and any continued working or extension would be able to build upon
that existing quarrying footprint, associated infrastructure and minerals land use relationship. In
planning terms, that is materially preferable to directing future working to an entirely new greenfield
location, and it reinforces the case for the Deposit RLDP to continue to recognise the site positively
within the minerals strategy rather than treating it as strategically unimportant simply because no
fresh allocation is currently required.
The site is an existing quarrying location with an established mineral planning history. Continued
extraction would therefore amount to the continuation and proper management of an existing
quarrying use rather than the introduction of mineral development into a wholly new location. That is
a material land use consideration.
The candidate site statement identifies the effective use of mineral resources and the avoidance of
sterilisation of unworked reserves as clear benefits of the proposal. That carries substantial weight.
Mineral resources can only be worked where they occur, and it is generally more efficient and
sustainable to make prudent use of an established quarry resource than to disregard it while pressure
for future supply is directed elsewhere.
The site can also contribute to continuity and resilience of supply. The candidate site statement
expressly states that continued quarrying at the wider site would provide continuity in mineral supply
at this location and contribute to resilience through the provision of a consistent supply over the plan
period and beyond. Existing operational or consented sites will often provide a more realistic and
deliverable source of continuing supply than wholly new mineral sites.
Continued extraction would also support the construction industry through the provision of an
adequate and continuous supply of minerals. This sits comfortably with BP25’s recognition that the
Vale is an “important supplier of Carboniferous limestone for general aggregate use” .
There are also local economic benefits. The candidate site submission refers to the maintenance of
local economic benefits. An established quarrying operation supports employment, haulage, plant use, contractors and associated supply chains. Continued recognition of the site therefore supports local
economic activity as well as mineral supply.
Environmental and restoration benefits are also relevant. The candidate site statement refers to
benefits through new planting and habitat creation and treats restoration as part of the overall site
concept. Continued quarrying should therefore not be considered solely in terms of extraction. It also
creates the opportunity to secure restoration, habitat creation, landscape management and long-term
after-use benefits through a modern planning framework.
A further important benefit is that any continued working would proceed under modern planning
controls. The ROMP approval confirms that continued extraction has been reviewed through a
contemporary planning process, that updated conditions now regulate the site, that the quarry must
be worked in accordance with an approved working scheme, that annual production is capped at
250,000 tonnes, and that extraction may continue until 21 February 2042. That provides a robust and
sustainable planning basis for future quarrying.
Continued recognition of Pant-y-Ffynnon Quarry within the Deposit RLDP would also ensure that the
site remains properly integrated into the authority’s safeguarding, buffer and minerals policy
framework. That would provide clarity, consistency and transparency in the Plan.
6. Changes sought
The Deposit RLDP should not treat the absence of a current RTS2 requirement for further allocations
as determinative of the planning treatment of Pant-y-Ffynnon Quarry.
The Plan should continue to recognise the consented quarry element positively within the minerals
strategy.
The wider site should remain properly safeguarded within the minerals safeguarding and quarry
buffer framework.
The supporting text should make clear that the absence of a new allocation reflects only the current
RTS2 quantitative position and not any conclusion that the site is unsuitable in principle for continued
quarrying.
The Plan should rely on its existing minerals development management policies, together with the
ROMP framework and any future application process, to assess the detailed merits of continued
working, associated development and restoration proposals at the site.
That approach would better reflect the site’s planning status, the candidate site evidence, the ROMP
determination and the wider objective of maintaining a sound and effective minerals strategy in the
Vale of Glamorgan.
7. Conclusion
The Council’s reliance on the statement that the 2nd Review of the Minerals Regional Technical
Statement indicates that no further allocations are specifically required within the Vale of Glamorgan
RLDP is too narrow a basis on which to assess Pant-y-Ffynnon Quarry.
That statement may explain why the Council has not identified a new formal mineral allocation on
numerical grounds. It does not, however, justify removing or diluting positive recognition of an existing
quarry site with an established planning status, a recent ROMP approval permitting continued
extraction until 21 February 2042, and clear evidence of continuing supply, economic and restoration
benefits.
Pant-y-Ffynnon Quarry should therefore continue to be positively recognised as part of the Vale of
Glamorgan’s minerals framework. The Deposit RLDP should distinguish clearly between the absence
of a current need for a fresh allocation and the continuing strategic relevance of an established quarry
site. In the case of Pant-y-Ffynnon Quarry, the latter plainly remains.
8. Summary
 Overall minerals strategy: Support in part / Object in part.
Seth Hill & Son Ltd supports the general objective of maintaining an adequate minerals supply
and managing mineral resources through a plan-led framework. Objection is taken to the
extent that the Deposit RLDP relies too narrowly on the RTS2 conclusion that no further
allocations are specifically required, without properly reflecting the continuing role of Panty-
Ffynnon Quarry as an existing quarry site with ongoing strategic relevance.
 Strategic minerals policy / supply and safeguarding approach: Support in part / Object in part.
The strategic objective of securing a continuous supply of minerals and safeguarding mineral
resources is supported. Objection is taken insofar as that strategic approach is not properly
applied to Pant-y-Ffynnon Quarry, which should continue to be recognised positively within
the minerals framework notwithstanding the absence of a current need for a fresh allocation.
 Policy MIN1 – Mineral safeguarding areas: Support.
Support is given to the safeguarding of limestone resources from unnecessary sterilisation.
That approach is directly relevant to Pant-y-Ffynnon Quarry, particularly given that the
candidate site submission sought to retain quarry status for the consented element and to
safeguard the wider site for longer-term quarrying.
 Policy MIN2 – Quarry buffer zones: Support.
The principle of retaining quarry buffer zones is supported because it protects existing and
future quarrying operations from encroachment by incompatible development. Continued
positive recognition of Pant-y-Ffynnon Quarry sits logically alongside that buffer framework.
 Policy MIN4 – Sustainable mineral working: Support in principle.
Support is given to the policy framework for new workings, extensions and continued mineral
extraction subject to environmental safeguards, amenity protection and restoration. Pant-y-
Ffynnon Quarry is capable of being assessed under that framework, and detailed issues
should be dealt with through the policy and application process rather than by withholding
positive plan recognition now.
 Candidate Site Assessment – Pant-y-Ffynnon Quarry: Object.
Objection is taken to the candidate site assessment insofar as it relies on the statement that
no further allocations are specifically required under RTS2 as the reason for not taking the
site forward positively. That reasoning is too narrow because it fails to engage with the fact
that the site is an existing quarrying location, that the candidate submission sought retention
of quarry status as well as longer-term safeguarding, and that the site has benefited from
ROMP approval ref. 2024/00246/ENV, which permits operations until 21 February 2042.
 Status of the existing quarry site: Object to insufficient recognition.
Seth Hill & Son Ltd objects to any approach which treats Pant-y-Ffynnon Quarry as
strategically unimportant simply because no new allocation is numerically required. The
consented quarry element should continue to be positively recognised in the Plan, reflecting
its existing planning status, updated ROMP conditions and ongoing minerals planning context.
 Benefits of continued extraction at Pant-y-Ffynnon Quarry: Positive material consideration.
Continued extraction would make productive use of an existing quarry site, avoid sterilisation
of unworked reserves, provide continuity and resilience of mineral supply, support local
economic benefits and allow restoration-led environmental gains through planting, habitat
creation and long-term after-use. Those benefits weigh in favour of continued positive
recognition of the site within the Deposit RLDP.
 Soundness and evidence base: Object to insufficiently evidence-led treatment.
The Development Plans Manual requires plans to be based on “robust evidence” so they can
be delivered and links candidate sites directly to the soundness question “Will the plan deliver?” The current treatment of Pant-y-Ffynnon Quarry does not fully reflect the evidence
before the Council on the site’s planning status, deliverability and continuing operational role.
 National policy compliance – PPW, MTAN1 and SWRAWP: Support in principle / Object to
incomplete application.
The broad alignment of the Deposit RLDP with national minerals policy is supported. The
objection is that the Plan does not go far enough in applying PPW’s reference to “real
possibilities for future mineral working”, MTAN1’s requirement for a “more realistic landbank
assessment”, and SWRAWP’s warning that “Caution must be exercised in using these landbank
figures” when considering the ongoing role of Pant-y-Ffynnon Quarry.
 Overall position: Support in part / Object in part.
In overall terms, Seth Hill & Son Ltd supports the Deposit RLDP’s broad minerals framework.
The objection is a focused one: the Plan should more clearly distinguish between the absence
of a current need for a fresh mineral allocation and the continuing strategic relevance of Panty-
Ffynnon Quarry as an established quarry site with planning status, ongoing supply potential
and a recent ROMP approval extending operations beyond the plan period.

Amend plan period.

REPRESENTATIONS TO THE DEPOSIT VALE OF GLAMORGAN REPLACEMENT LOCAL DEVELOPMENT
PLAN 2021–2036 ON BEHALF OF TOM PRICHARD (HOLDINGS) LTD
1. Introduction
These representations are submitted on behalf of Tom Prichard (Holdings) Ltd in respect of the Deposit
Vale of Glamorgan Replacement Local Development Plan 2021–2036. They relate specifically to the
Plan’s minerals strategy and policy framework, the treatment of dormant mineral sites, and the
candidate site assessment and supporting evidence relating to Argoed Isha Quarry, Llansannor.
The respondent supports the broad direction of the Deposit RLDP minerals framework, but contends
that the Plan is unsound in part in the way it presently treats Argoed Isha Quarry. The central point is
straightforward: the Council’s own evidence accepts that usable reserves remain at the site, that those
reserves could still be extracted if required, and that the site has the potential to be reworked. Yet that
conclusion is not carried through into a sufficiently positive and coherent plan-led position.
The objection is therefore not to the principle of maintaining a minerals strategy founded on
safeguarding, environmental protection and modern control of extraction. Nor is it suggested that the
Plan must necessarily allocate Argoed Isha as a new specific site simply because a candidate site was
submitted. Rather, the objection is that the Deposit RLDP does not properly reflect the evidential
position it has itself reached. It acknowledges that Argoed Isha should not be made subject to a
Prohibition Order, but stops short of recognising clearly that the site remains a dormant limestone
quarry with continuing mineral significance, realistic future reactivation potential and scope for future
working under modern planning controls, restoration obligations and biodiversity enhancement.
2. Site context and planning status
Argoed Isha is a long-established limestone quarry. The candidate site planning statement explains
that the site has a historic quarry planning status, that recommencement would require updated
working conditions, and that the site was promoted through the candidate site process precisely
because there remains interest in recommencing mineral extraction. The same statement records the
local planning authority’s earlier position that, in relation to a previous proposal, the Council could
only seek a Prohibition Order if it was satisfied that resumption of extraction was unlikely, but that
“this requirement is not met” at Argoed Isha because of continuing interest in re-opening the quarry.
It also records the mineral adviser’s view that “The site currently has planning permission for a quarry”
and that, absent relinquishment, “the permission to quarry remains valid”.
The candidate site material also addresses availability and deliverability. It states that the site is
available for development, that the proposal is considered viable and deliverable owing to the
underlying need for the mineral, and that the site is a brownfield / underutilised site. It further notes
that the proposal comprises mineral development within a mineral safeguarding area and within a
site which benefits from a planning permission for quarrying, such that it is considered acceptable in
principle. Those points are important because they show that Argoed Isha is not simply a theoretical
reserve detached from any realistic prospect of future use.
3. Soundness and the role of evidence
The Development Plans Manual states that plans should be based on robust evidence so they can be
delivered and that LPAs must be able to demonstrate, in broad terms, that the plan is deliverable with
no significant impediments to implementation. It also emphasises the importance of a detailed
candidate site process and of ensuring delivery and viability are embedded in that process from the
outset. Elsewhere, the Manual explains that the plan-making process should prepare more effective,
efficient and deliverable plans and refers expressly to the tests of soundness which must be satisfied
if a development plan is to be recommended for adoption.
Those principles matter here because the Council had before it a candidate site submission which set
out the site’s planning status, constraints, deliverability and rationale for retention as a mineral site.
It also had its own local evidence in BP25 and the wider regional evidence from RTS2, the sub-regional
collaboration work and SWRAWP. In those circumstances, a sound plan ought to explain clearly how
that evidence has informed the Council’s chosen strategy for Argoed Isha. In the respondent’s
submission, the Deposit RLDP presently falls short because it recognises part of the evidence, but not
its full implications. The Plan is therefore unsound in part because it is not fully justified by the
evidence and is not as effective as it should be in setting out a coherent future approach to this
dormant but still viable mineral resource.
4. National policy context – Planning Policy Wales
Planning Policy Wales establishes the national context for these representations. It requires planning
authorities to maintain landbanks for non-energy minerals in demand and states that, for crushed
rock, a minimum ten-year landbank should be maintained through the plan period unless agreement
is reached for other authorities to make a compensating increase in provision. PPW also recognises
that individual authority boundaries are not always an adequate basis for landbank policy where
environmental constraints are too important or workable resources too limited, in which case
authorities must agree a joint approach with neighbouring authorities in line with regional
arrangements.
PPW is especially important in relation to inactive sites. Paragraph 5.14.17 provides that inactive sites
with planning permission for future working which are considered unlikely to be reactivated should
be identified in the development plan and should be the subject of a suitable strategy, which could
include prohibition orders, restoration and aftercare proposals, and a suitable proposed after-use.
Paragraph 5.14.18 then states that “It is in the interests of the minerals industry that landbanks reflect
real possibilities for future mineral working” and adds that, where sites have been inactive and “there
is no prospect of future working”, authorities should consider the use of prohibition orders.
That distinction is central to the present case. The Council has not concluded that there is no prospect
of future working at Argoed Isha. Quite the contrary: BP25 states that usable reserves remain at the
site, that they could be extracted if required, and that they have the potential to be reworked. The logic
of PPW is therefore that Argoed Isha is not a site to be treated as effectively closed or exhausted. It
remains a site with continuing mineral relevance, albeit one that would require modern conditions and
a fresh scheme of workings before any extraction could recommence.
PPW is also directly relevant to areas of future working. Paragraph 5.14.19 states that “Where
necessary, planning authorities should provide a clear guide to where non-energy mineral extraction
is likely to be acceptable” and that policies and proposals should cover mineral resources “which are
currently used or which may need to be used in the foreseeable future”. It further explains that such
areas should be clearly identified on a proposals map and may take the form, in order of preference,
of specific sites, preferred areas or areas of search.
The respondent does not suggest that PPW compels the Council to identify Argoed Isha as a specific
site. However, PPW plainly supports a more positive and more explicit plan-led recognition of sites
which retain real future mineral potential. Once the Council’s own evidence accepts that Argoed Isha
is such a site, it is difficult to reconcile a largely passive policy response with the national expectation
that development plans should give a clear guide to where future mineral working may be acceptable.
5. National policy context – MTAN1
MTAN1 reinforces the need for a realistic and evidence-based approach to landbanks and dormant
sites. It explains that a landbank is composed of permitted reserves at active and inactive sites, and
that development plans should include an assessment of both the current and future landbank.
Paragraph 47 then states that development plans should identify those sites that are dormant and
count these as “dormant reserves” to be clearly shown in landbank calculations as a separate
category. Paragraph 48 continues by stating that a more realistic approach is required, observing that
extensive historic landbanks can perpetuate unsustainable supply patterns if left unaltered. MTAN1
therefore states that “A more realistic landbank assessment is the aim of this process” so that a more accurate picture is obtained of permitted reserves “that are likely to have real potential for future
working”.
That policy language is highly material. It confirms that dormant reserves are not irrelevant simply
because they are not counted within the active landbank. They are to be identified separately and
realistically assessed. That is precisely the position that should be taken with Argoed Isha. The Council
has already undertaken the essential assessment in substance through BP25 and has concluded that
usable reserves remain and that the site has the potential to be reworked. MTAN1 therefore supports
a more nuanced and more positive treatment of the site than a simple “no allocation required”
conclusion.
MTAN1 also recognises that in some authorities it may not be possible or acceptable to provide an
adequate current or extended landbank because of environmental designations, limited suitable
resources, or amenity considerations, and that RAWPs should consider the environmental capacity of
authorities to supply aggregates. This is an important reminder that reserve arithmetic is not the only
issue. Deliverability, environmental capacity, and the practical availability of reserves remain relevant.
6. Apportionment and Plan Period
The regional and sub-regional evidence does not undermine the respondent’s case. It explains why
there is no present quantitative requirement for a further minerals allocation in the Vale, but it does
not justify a negative or dismissive treatment of Argoed Isha.
BP25 records the RTS2 and Statement of Sub-Regional Collaboration position for the Cardiff City subregion.
Table 5 identifies the Vale of Glamorgan apportionment for crushed rock as 17.05 million tonnes
over 25 years, with existing permitted reserves of 18.73 million tonnes at the end of 2016 and a
minimum allocation needed of 0, alongside 13 million tonnes of additional reserves at dormant sites.
BP25 then states that, based on those figures, the SSRC identifies that the Vale of Glamorgan does not
require any allocations for future workings of crushed rock to be identified within the RLDP.
Based on the Development Plans Manual, when a plan is adopted, there should be at least 10 years of
the plan period remaining.
On the Council’s current timetable, adoption is only anticipated for August/September 2027, and those
post-Deposit stages are expressly identified in the Delivery Agreement as indicative, because they
depend on external factors including the number of representations received and the examination
process. The Deposit Plan runs only to 2036. That means that, even if the Council hits its best-case
programme and adopts in September 2027, the Plan would have only about 8 years and 3 months left
to run. That is already below the DPM expectation of at least 10 years remaining at adoption. Any
slippage would make that position worse.
Based on the current timetable, an end date of 2038 (with associated review of mineral reserves)
would therefore ensure a sound plan.
Notwithstanding our comment in respect of the Plan Period, we remain concerned of how the Plan
should treat a dormant site which the Council accepts has remaining usable reserves and realistic
reactivation potential. Nor does it justify treating Argoed Isha as though it lacked future significance.
The respondent’s case is therefore not that the RTS2 figure is wrong, but that it has been taken too
far. A conclusion that no additional formal allocation is presently required is not the same thing as a
conclusion that the site has no future role.
7. BP25 – the Council’s own minerals evidence
BP25 is the most important local evidence document for present purposes. It records that the Vale of
Glamorgan is an “important supplier of Carboniferous limestone for general aggregate use”. It then
addresses dormant mineral sites in the Vale. Paragraphs 5.48 to 5.50 explain that many dormant sites
have not been worked for many years and are considered unlikely to be worked in the future;
accordingly, the Council intends to serve Prohibition Orders on those sites, which would provide certainty for nearby residents and remove reserves which are not realistically available. BP25 also
explains that the level of reserves at dormant sites is not counted in the landbank.
Crucially, BP25 then distinguishes Argoed Isha from that general class of dormant sites. Paragraph
5.51 states: “While Argoed Isha quarry is classified as ‘dormant’, useable reserves remain at the site
and could be extracted if required.” It goes on to record that a Construction Plant Competence Training
Centre has operated at the site since 2016 and has temporary planning consent until 2030, but then
adds: “While the reserves at the site are not included in the current landbank, they have the potential
to be reworked and therefore a Prohibition Order will not be served at Argoed Isha Quarry until the
current circumstances change.”
That is a very clear evidential conclusion. BP25 does not simply refrain from prohibiting the site
without explanation. It positively explains why Argoed Isha is different: usable reserves remain, they
could be extracted if required, and they have the potential to be reworked. In the respondent’s
submission, that conclusion requires a correspondingly clearer and more positive policy response
within the Deposit RLDP than is presently provided.
BP25 is also supportive on restoration and aftercare. It states that the serving of Prohibition Orders
is intended to provide certainty and, where necessary, restoration of sites may be sought. More
broadly, the background paper recognises the importance of sustainable minerals management and
balancing mineral extraction with environmental protection and community well-being. That policy
background is entirely consistent with the respondent’s case that any future working at Argoed Isha
should be controlled through a modern framework of environmental safeguards and restoration-led
after-use.
8. SWRAWP Annual Report 2024
The SWRAWP Annual Report 2024 is also highly relevant because it warns against over-reliance on
headline landbank figures. Paragraph 4.10 states that “Caution must be exercised in using these
landbank figures” because the calculation does not take account of geographical or operational
aspects that may restrict the availability of certain reserves, nor constraints arising from changes in
planning policy, protected site designation or other non-planning permitting requirements. Paragraph
4.11 then confirms that dormant sites have not been included in landbank calculations and that local
planning authorities should carry out their own assessments of the likelihood of reactivation, but that
in any event “dormant reserves must be counted separately”.
That evidence materially supports the respondent’s case. It shows that the statement “no further
allocations are specifically required” is not, in itself, the end of the analysis. Landbank figures are a
starting point, but they do not tell the whole story. Questions of practical availability, regulatory and
environmental constraints elsewhere, and the separate role of dormant reserves remain relevant.
Argoed Isha therefore retains importance as part of the broader mineral resource picture even though
it is not part of the active landbank.
9. Response to the Council’s candidate site assessment
The Council’s candidate site assessment records that a positive allocation for mineral working is not
included because “the 2nd Review of the Minerals Regional Technical Statement indicates no further
allocations are specifically required to be identified within the Vale of Glamorgan RLDP”. That point
should be addressed directly.
The respondent accepts that the RTS2 position explains why the Council may have concluded that
there is no immediate need for a fresh mineral allocation in quantitative terms. However, that is not a
sufficient reason, on its own, to reject a more positive policy treatment of Argoed Isha or to give the
impression that the site lacks future significance. BP25 itself shows why. It records both that the Vale
does not presently require additional allocations and, separately, that Argoed Isha retains remaining
usable reserves and has the potential to be reworked. Those two propositions are not inconsistent.
They point toward a more nuanced and more accurate conclusion: namely, that Argoed Isha may not need to be allocated now to meet a current numerical shortfall, but it remains a dormant limestone
reserve of continuing strategic relevance that should be positively recognised within the Plan.
That approach is also supported by PPW, MTAN1 and SWRAWP. PPW states that landbanks should
reflect “real possibilities for future mineral working” and that prohibition orders are appropriate where
there is “no prospect of future working”. MTAN1 requires dormant reserves to be separately identified
and assessed so as to achieve “A more realistic landbank assessment”. SWRAWP says that “Caution
must be exercised” in using landbank figures and that dormant reserves must be counted separately.
Those documents all point to a need for a broader planning judgment than simple reserve arithmetic.
Accordingly, the flaw in the candidate site reasoning is not that it refers to the RTS2 position, but that
it appears to stop there. In the respondent’s submission, the sounder and more evidence-based
approach would have been either to give the site more positive recognition in the Plan’s supporting
text, or at the very least to make clear that the site was not allocated because no immediate additional
allocation was required, not because the site lacked merit, availability or future potential.
Moreover, SWRAWP reinforces the point that reserve arithmetic is not the whole picture. It states that
“Caution must be exercised in using these landbank figures” because the calculation does not take
account of geographical or operational aspects, changes in planning policy, protected site
designations or other permitting constraints. This is particularly relevant given the increasingly
important role of NRW licensing and abstraction controls, including quarry dewatering considerations,
which may mean that some reserves are no longer as readily available or economically viable as
historic landbank figures imply. Accordingly, apparent reserve sufficiency in quantitative terms may
overstate the extent of genuinely deliverable supply.
10. The existing temporary training permission does not sterilise the reserve
BP25 states that a Construction Plant Competence Training Centre has operated at the site since 2016
and has temporary planning consent until 2030. The significance of that point is not that the site has
permanently moved away from minerals. The significance is the opposite: BP25 records the temporary
training use while simultaneously concluding that usable reserves remain and may be reworked, and
that a Prohibition Order should therefore not be served.
In planning terms, a temporary training use of this kind cannot properly be treated as sterilising the
mineral reserve. PPW’s safeguarding policy is concerned with preventing sterilisation by permanent
development. A time-limited interim use, particularly one expressly acknowledged in BP25 as coexisting
with a potentially reworkable reserve, does not extinguish the underlying mineral significance
of the site. The temporary training use should therefore be understood as an interim overlay rather
than a permanent change in land use character.
11. Benefits of continued extraction at Argoed Isha Quarry
Continued extraction at Argoed Isha Quarry would give rise to a number of site-specific and strategic
benefits which the Deposit RLDP should recognise when considering the future role of the site.
The site is not a greenfield mineral proposal on an entirely undeveloped site. It is an existing quarry
with a long-established mineral planning history and extant mineral status in principle, subject to
updated modern conditions. The principle of mineral working at the site is therefore already
established in land use terms, and the future reworking of the reserve would represent the
continuation of an existing mineral use rather than the introduction of quarrying into a wholly new
location. That is a material distinction when considering the appropriateness of retaining the site as a
realistic future mineral resource.
Continued extraction would also assist in making use of a proven local limestone resource in the Vale
of Glamorgan, rather than forcing greater reliance on more distant or more constrained sources. BP25
confirms that the Vale is an “important supplier of Carboniferous limestone for general aggregate
use”. In practical terms, continued extraction at Argoed Isha would accord with the proximity principle by helping to meet demand from a comparatively well-located source close to markets in the Vale and
wider Cardiff area, rather than depending unduly on more remote sources or on supply patterns that
may become more constrained over time.
The site would also contribute to the resilience and flexibility of the wider minerals supply position.
Even if no immediate additional allocation is numerically required under RTS2, national and regional
policy make clear that landbank figures are not the only relevant consideration. A dormant quarry with
remaining usable reserves provides contingency, flexibility and productive capacity in the event that
supply circumstances change during the plan period. This is especially important where SWRAWP
warns that landbank figures do not capture geographical, operational, policy or other permitting
constraints, and where MTAN1 requires a realistic view of reserves with future potential. Argoed Isha
therefore has value not merely as a theoretical reserve, but as part of a resilient longer-term supply
position.
Continued extraction at Argoed Isha would also support local supply chains and a more diverse
quarrying sector. The candidate site submission identified the benefit of maintaining provision from a
range of operators, including smaller and medium-sized businesses, rather than relying only on a
limited number of larger established sites. In planning terms, that diversity is relevant to continuity of
supply, competition, responsiveness to local demand and the overall resilience of the minerals sector
in the Vale and wider region.
A further benefit is that any future extraction would be carried out under modern planning control
rather than being left sterilised or underused. If the site is reworked in future, that would necessarily
be through a fresh scheme of modern conditions and under the policy framework of the RLDP and
national minerals policy. Issues such as traffic, hydrology, hydrogeology, ecology, landscape, amenity,
blasting, dust, restoration and long-term aftercare would all be capable of being addressed through
a contemporary planning and environmental control regime. That is an important benefit in itself,
because it means any future extraction would not take place under outdated historic controls, but
under a modern framework designed to secure sustainable mineral working.
Continued extraction would also create the opportunity for a comprehensive restoration and aftercare
strategy delivering environmental gains. PPW recognises that restoration and aftercare proposals for
inactive sites may include natural re-vegetation for nature conservation and ecological interests.
BP25 records that restoration may be sought where necessary. In practice, any future extraction
proposal at Argoed Isha could be accompanied by a restoration-led scheme involving landform
improvement, habitat creation, ecological enhancement and long-term stewardship. The site should
therefore not be seen simply as a mineral reserve, but as a place where carefully managed extraction
could unlock biodiversity, landscape and geodiversity benefits over time.
The site also represents the productive use of an underutilised brownfield quarry. The candidate site
material identifies it as a brownfield / underutilised site. In land use terms, there is a clear logic in
making effective use of an existing quarried landscape with established mineral status, rather than
placing additional pressure on wholly undeveloped land elsewhere. In this case, the Council’s own
evidence confirms the key factor: usable reserves remain and the site has the potential to be
reworked.
There is finally a longer-term safeguarding benefit in recognising the case for continued extraction.
PPW requires mineral resources to be safeguarded to prevent sterilisation by permanent
development, and makes clear that landbanks should reflect “real possibilities for future mineral
working”. Positive recognition of the benefits of continued extraction at Argoed Isha is therefore
entirely consistent with the basic objectives of national minerals policy: prudent use of finite mineral
resources, maintenance of flexibility in supply, and avoidance of circumstances in which sites with
genuine future potential are prematurely written off.
12. Restoration, aftercare and biodiversity gain
The respondent’s case is not simply that Argoed Isha should be recognised as a future mineral source.
It is also that any future reworking can and should be subject to a modern restoration-led scheme
capable of securing environmental gains.
PPW contemplates restoration and aftercare proposals for inactive sites, including natural revegetation
for nature conservation and ecological interests. BP25 records that, where necessary,
restoration may be sought at dormant sites. The candidate site material also identifies that the site is
not close to internationally or nationally important wildlife sites, while noting the presence of existing
ecological and geological interests that could be appropriately managed through buffers, mitigation
and future planning controls. These are precisely the kinds of circumstances in which a carefully
designed extraction and restoration scheme could deliver meaningful biodiversity and geodiversity
benefits alongside the prudent working of the remaining mineral resource.
Future working at Argoed Isha should therefore not be viewed in binary opposition to environmental
enhancement. The modern policy framework envisages integrated mineral development in which
extraction, restoration and aftercare are part of a single coherent process. That is an additional reason
why the Plan should positively recognise the site’s continuing potential rather than leaving it in a policy
grey area.
13. Overall conclusion
The evidence base points clearly to a more positive and more coherent treatment of Argoed Isha than
is presently provided in the Deposit RLDP.
PPW says that landbanks should reflect “real possibilities for future mineral working” and that
prohibition orders are appropriate where there is “no prospect of future working”. MTAN1 requires a
separate assessment of “dormant reserves” and seeks “A more realistic landbank assessment”.
SWRAWP states that “Caution must be exercised in using these landbank figures”. BP25 records that
“useable reserves remain at the site and could be extracted if required” and that they “have the
potential to be reworked”. The Development Plans Manual requires plans to be based on robust
evidence and to be deliverable.
Against that background, the Council’s reliance on the proposition that the RTS2 indicates no further
allocations are specifically required does not dispose of the issue. It may explain why there is no
immediate need for a fresh mineral allocation, but it does not justify a passive or dismissive treatment
of Argoed Isha. The more sound and evidence-based approach is to recognise that, whilst no additional
formal allocation is presently required, Argoed Isha remains a dormant limestone quarry with usable
reserves and realistic future reactivation potential, capable of coming forward in future under modern
policies for sustainable working, restoration and aftercare.
14. Summary
These representations contend that, whilst the Deposit RLDP minerals strategy is broadly supported,
the Plan is unsound in part in its treatment of Argoed Isha Quarry. In particular, the objection goes
principally to whether the Plan is justified by the evidence and whether it is effective in delivery. The
objection also concerns consistency with national minerals policy to the extent that the Deposit RLDP
does not fully reflect PPW and MTAN1 in positively planning for the safeguarding and potential future
working of this identified limestone resource.
 Strategic Policy SP18 – Minerals Supply and Safeguarding: Support in part / Object in part.
The respondent supports the overarching strategy of maintaining a continuous supply of
minerals, safeguarding mineral resources and avoiding sterilisation. However, objection is
taken insofar as the strategy does not carry through the Council’s own evidence that Argoed
Isha retains usable reserves and future potential for reworking.
 Policy MIN1 – Mineral Safeguarding Areas: Support.
This policy is supported because it reflects national policy by safeguarding limestone resources from permanent development that would sterilise them or hinder future extraction.
That approach is directly relevant to Argoed Isha, which remains a safeguarded resource with
extant mineral significance.
 Policy MIN2 – Quarry Buffer Zones: Support.
The principle of protecting mineral operations from encroachment by incompatible
development is supported. If Argoed Isha is to remain a realistic future source of limestone,
the Plan should continue to avoid prejudice to its potential reactivation.
 Policy MIN3 – Dormant Mineral Sites: Support in principle / Object in part.
The respondent supports the Council’s decision not to serve a Prohibition Order at Argoed
Isha. That is plainly the correct approach because BP25 confirms that usable reserves remain
and may be reworked. However, objection is taken to the absence of stronger wording
recognising that the site remains a realistic future source of limestone.
 Policy MIN4 – Sustainable Mineral Working: Support in principle.
The respondent supports the policy framework for future reworking or reopening of old
workings, including the need for acceptable impacts, restoration and beneficial after-use.
Argoed Isha is capable of being assessed under that type of modern policy framework.
 Supporting text to the dormant quarry provisions / paragraph 6.386 equivalent approach:
Object in part.
The Plan is correct to recognise that the reserves at Argoed Isha could be reworked in future.
The objection is that this conclusion is not carried through into a fuller and more positive
policy narrative.
 Plan Period: Object.
Amend in line with the Development Plans Manual such that there are at least 10 years
remaining at adoption.
 Candidate Site 411 – Argoed Isha Quarry: Object.
The respondent objects to the candidate site assessment insofar as the site appears to have
been rejected solely or mainly because RTS2 indicates that no further allocations are
specifically required. That is too narrow an approach and does not properly reflect PPW,
MTAN1, SWRAWP or BP25’s conclusion that usable reserves remain and may be reworked.
 Minerals Background Paper BP25: Support in part / Object in part.
BP25 is supported where it correctly records that Argoed Isha is dormant, that usable
reserves remain, and that the site has the potential to be reworked. Objection is taken only
insofar as the Deposit RLDP does not fully reflect the implications of that evidence in a more
positive and coherent plan-led position.
 Temporary training use: Clarificatory comment in support of the representation.
The current training use does not sterilise the limestone reserve. BP25 records the temporary
training use until 2030 while also confirming that usable reserves remain and that the site
may be reworked. It should therefore be treated as an interim use only.
 Benefits of continued extraction at Argoed Isha: Positive material consideration.
Continued extraction at Argoed Isha would make productive use of an existing dormant quarry
with remaining usable reserves, support local and sub-regional limestone supply from a Vale
source, contribute to flexibility and resilience in the minerals strategy, and enable future
working to proceed under modern planning controls with restoration, aftercare and
biodiversity enhancement.
 Overall position on the Deposit RLDP minerals strategy: Support in part / Object in part.
In overall terms, the respondent supports the Deposit RLDP’s general minerals framework.
The objection is a precise and limited one: the Plan should more clearly and positively recognise Argoed Isha as a dormant quarry with usable reserves, realistic reactivation
potential, and scope for a future scheme of continued extraction and restoration, such that the Plan is properly justified by its evidence base and effective in delivering a resilient minerals strategy over the plan period.