The current plan was adopted before Future Wales identified the Vale of Glamorgan as a national growth area; therefore, planning to continue delivering at the same average rate as before this change in status clearly lacks ambition.

Para 5.8, there is no mention that the ten-year period used includes the pandemic and a significant increase in building costs, both of which slowed housebuilding rates and brought down the average annual delivery rate.

HBF suggests a higher rate of annual delivery could be achievable, as demonstrated by previous annual completions of 917 at its highest point and with six of the ten years higher than 526. This is supported by the Council's document BP7 Housing and Employment growth options, which identifies the 5yr build rate average (2016-2021) as 780 units, again well above that currently suggested by this plan.

In order to meet the high demand for affordable homes, a larger housing target would deliver more affordable homes, as each site would be subject to a percentage contribution of affordable homes.

Although it is right for the plan to be as sustainable as possible, a balance also has to be achieved, due to the position of the Vale of Glamorgan so close to Cardiff and Bridgend, there are always going to be job opportunities outside of the authority. Both Cardiff and Bridgend have very good linkages by rail, so such commuting can easily be achieved sustainably. In fact, the plan has said that its strategy is to place new development close to these public transport facilities. HBF consider that the level of employment planned within the Vale of Glamorgan should not be a limit on the level of housing proposed. This is an example of where cross-boundary issues need to be given more consideration, particularly due to the Vale's role as part of the wider national growth area.

The latest housing needs data released by the Welsh Government shows a significant increase in the need for affordable housing to meet unmet need and an increase in annual arising need. These figures both exceed those currently in Future Wales. This new data means the plan should increase its housing requirement to take account of this increased housing need. HBF suggests this adds to the previous reasons why the housing requirement figure should be increased.

In terms of detailed wording, HBF questions whether a plan can deliver. It can allocate land to allow for delivery, but the plan can't actually deliver.

In line with the comments already made on point 1 of the sustainable growth strategy, the HBF considers that the level of housing proposed lacks ambition and is not in line with the Vale of Glamorgan's position as a regional growth area in Future Wales.

The words 'including a minimum of 3,070 affordable homes' should be changed to ' a target of 3,070 affordable homes'. The reason for this is that a minimum suggests that it should be more; however, other relevant housing policies are worded to provide for a defined number or target. This change in wording does not stop more from being delivered.

The approach to limiting housing development, other than affordable-led schemes with a minimum of 50% affordable, in the identified towns and villages, restricts the ability of SME developers and, therefore, the range of homes that might be provided by the plan.

The HBF questions the wording under the heading 'Infrastructure', which is not appropriate wording, as it is part of the plan's role to identify the necessary infrastructure to deliver the level of growth proposed. The provision of infrastructure, which is necessary for development, is covered by other policies in the plan.

Why is the housing flexibility allowance figure not included in this policy?

In order for Policy SP1 to achieve the third test of soundness (Will the plan deliver?), the policy must be updated to accommodate a greater level of housing delivery, that reflects the most up to date evidence. The Development Plans Manual states:

“In terms of considering the level of housing provision for a plan, the most up-to- date suite of Welsh Government Population and Household Projections are a fundamental part of the evidence base [paragraph 5.35]”

Policy SP1 as drafted sets out that the allocation of new [housing] sites will be primarily focused within the Strategic Growth Areas (SGA) identified on the Key Diagram and outside of the SGA, the allocation of sites will be limited to small-scale affordable housing led sites in appropriate Primary and Minor Rural Settlements. In order to meet the true identified housing needs of VoG during the RLDP period, Primary and Minor Rural Settlements will likely need to accommodate further new dwellings than the RLDP currently allocates (please refer to our comments below on Policy SP2 and Policy HG4 for further commentary).

Policy SP1 sets out that the plan will deliver 7,890 dwellings by 2036, including a minimum of 3,070 affordable homes. Policy SP1 also sets out that outside of the Strategic Growth Areas, the allocation of new sites will be limited to small-scale affordable housing led sites.

The number of households in VoG in mid-2021 (i.e. the start of the RLDP period) was 57,676. Based on Welsh Government’s 2022-based household projections, the number of households is projected to increase to 67,299 in VoG in mid-2036 (i.e. the end of the RLDP period). This equates to a household increase of 9,623 which is 22.0% more than the 7,890 dwellings the RLDP targets in Policy SP1. In addition, the Development Plan Manual requires a conversion factor from households to dwellings with 4% being the baseline (it is acknowledged that this will vary depending on local circumstances). Taking a 4% uplift, the dwelling requirement figure would be 10,008 which is 26.8% more than the RLDP seeks to deliver in Policy SP1. The number of overall dwellings identified in Policy SP1 will therefore not meet the identified household growth needs of VoG for the RLDP period. The Council should review the position in terms of the updated household projections.

It is important to note that the above calculations are purely to meet newly arising need and do not make any allowance for existing unmet affordable housing needs or any policy aspirations. As stated in the supporting text of Sustainable Growth Strategy 4 of the RLDP (paragraph 5.23) “The Local Housing Market Assessment (LHMA) 2023 identifies a need for 1,075 affordable homes per annum over the next five years based on principal projections or 1,114 based on the RLDP projections. There is an identified backlog of need across all the sub-market areas in the Vale of Glamorgan, and the issue is acute in many communities.” Policy SP1 seeks to deliver only 3,070 affordable homes over the RLDP period, equating to 205 affordable dwellings per annum. This is only 18.4% of identified need per annum for the five-year period from 2023-2028 in the LHMA. The number of affordable homes identified in Policy SP1 therefore falls drastically short of the identified need for affordable homes in VoG for the RLDP period.

Before further plans for building new housing areas are considered, there should be an increase in the provision of basic facilities such as GP Surgery, Dental Surgery, improved public transport links, creation of more spaces within schools at all levels from Reception to Year 12.

The proposed plan will place further strain on already barely adequate public services; the roads are already heavily congested particularly during peak travel times; there will be a detrimental loss of green spaces within the area which may reduce the area's capacity to create a feeling of well being.
The roads are already in a poor state with much restorative work urgently required so any increase in the number of cars will only exacerbate this situation.

Don’t build at Weycock Cross, and reconsider the housing in Rhoose due to the volume of traffic along one main road.

Why is all the housing being considered all along one main road from Rhoose to Weycock Cross? The area can’t handle the current level of traffic. One small car breaking down along that road chokes up the whole of Barry. Then you want to add 1000+ houses along the same route. How can this not be seen as a poor decision? We all understand that there needs to be new housing, but surely more thought could go into choosing a more suitable area to build.

I went to the consultation meeting in Rhoose yesterday. My questions are why is an access road being built to the bypass instead of sending the traffic through the village. Also no amenities are being provided as what happened with Rhoose point. There is also the problem with the college traffic plus more houses being built at Rhoose point and also the ongoing battle at Model farm. More houses are being built at Weycock cross adding to traffic congestion. The proposed changes to Weycock cross roundabout will not work because if you put traffic lights on port road to allow traffic out of the proposed development by the toby inn the amount of traffic coming from Rhoose would be a nightmare. If you lived around here you would know that you only have to have roadworks on port road coming from the airport and it’s gridlocked for hours. There also is only one train and bus an hour so if you’re trying to get cars off the roads these need to be increased.

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

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

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

We write specifically with regard to the Key Site at ‘North West Barry’ (Policy SP4: KS1). As the Authority
are aware, a significant amount of supporting information has been prepared in relation to the Key Site over the course of the preparation of the Replacement LDP to date – this detailed evidence has clearly demonstrated that the inclusion of ‘North West Barry’ as a Key Site with the Replacement Plan fully accords with the Replacement LDP strategy. Furthermore, the detailed submissions have evidenced that the site is entirely deliverable and viable.

In summary, this representation sets out support for the inclusion of Land at North West Barry as a Key Site within the Replacement LDP. Our Client (Persimmon Homes) is fully committed to the delivery of the allocation, in accordance with the policies of the Replacement Plan (both site-specific and plan-wide policies inclusive).

We would highlight that although the representation provides overarching support for the Deposit Plan
(and the inclusion of North West Barry as a Key Site), a number of detailed objections are submitted in relation to specific elements of the proposed wording of the Key Site policy (HG1: KS1). In addition, the wider policies of the Deposit Plan have been reviewed in detail and comments are submitted accordingly.

Background
By way of background context, as the Authority are aware, a Candidate Site representation was submitted on behalf of Persimmon Homes in relation to Land at Weycock Cross, Barry, at the Stage 1 Call for Sites in September 2022 (Site Ref. 449). The land (circa 7 hectares) was put forward for inclusion in the Replacement LDP for a housing allocation (for circa 180 units). Within the Replacement LDP Preferred Strategy (published November 2023), the Candidate Site at Weycock Cross was not identified as a Key Site, in light of the preferred allocation of 1,500 units at land at North East Barry.
Further to issues arising in relation to the deliverability of the North East Barry Key Site, the Authority subsequently
consulted on alternative options for the provision of sufficient housing land within Barry, with the Candidate Site at Weycock Cross (‘North West Barry’) identified as capable of delivering 376 units (as taken forward within the Deposit Plan). A significant degree of supporting survey and assessment work has been prepared in relation to the North West Barry Key Site which serves to demonstrate that the site (at a capacity of 376 units) presents a sustainable, deliverable and viable allocation, capable of accordance with national sustainable placemaking outcomes.

Sustainable Growth Strategy (Policy SP1)
The Deposit Plan’s overarching strategy in relation to sustainable growth is supported. The primary focus of concentrating housing growth within the ‘Strategic Growth Area’ (i.e. where the main centres of population are accommodated, and which are served by a range of facilities and services, and are accessible by a range of transport modes) as outlined by Policy SP1 is considered appropriate and will allow for the delivery of sustainable and resilient communities. As per previous representations
submitted by Asbri Planning on behalf of Persimmon Homes in relation to the RLDP Preferred Strategy,
the prior identification of the strategic-scale (1,500 unit) Key Site at North East Barry was considered to represent an over-reliance on one site to meet the housing demand of the Authority’s Key Settlement (with associated constraints in relation to the delivery of units on a strategic-scale site within the earlymid part of the plan period). It is considered that the inclusion of North West Barry as a Key Site, supplemented by a number of smaller housing allocations as identified in Policy HG1, will ensure that the housing requirement for the Barry can be met in a robust and deliverable manner.

Overall Growth Levels (Policy SP6)
It is acknowledged that the preferred growth option (dwelling-led 10 Year scenario), upon which the
RLDP housing requirement figure is based, reflects what has been delivered in the Authority in recent years, and is considered by the Authority to be realistic and suitably ambitious given the Vale's position within the National Growth Area. However, as a general comment, it is considered that targeting a higher/more ambitious growth rate would be appropriate. In reviewing the most recent LDP Annual Monitoring Report (Vale of Glamorgan LDP 2011-2026, 7th Annual Monitoring Report, 1st April 2024
31st March 2025) (published October 2025), it is clear that there is a shortfall in housing delivery in the Vale of Glamorgan. It is stated that: “Between 1st April 2011 and 1st April 2025, a total of 6,999 dwellings were completed within the Vale of Glamorgan of which 4,641 units were general market dwellings against the 2025 AMR target of 6,387 that should have been developed at this point in the plan period, in accordance with the target. The number of additional general market dwellings delivered is 27.3% below the monitoring target”.

In light of the fact that there is a significant shortfall in housing delivery (i.e. currently 27.3% lower than the LDP target), it is considered that a higher growth level for the
Replacement Plan period would assist in rectifying under-delivery, allowing for housing completions to be better aligned with evidence of need (rather than repeating past shortfalls).

On February 12th 2026, the Welsh Government published updated estimates of additional housing need in Wales. The figures replace the 2019-based estimates and draw on the latest available data, including the 2022-based household projections published in late 2025. In summary, Welsh Government identify that there is a current estimated existing unmet need of 9,400 housing units. Estimates of existing unmet need have increased by 64% since the 2019-based estimates, due to a rise in homeless households in temporary accommodation.

In terms of future housing need, on average, between 7,800 and 9,300 additional housing units are estimated to be needed annually over the five-year period from July 2025 to June 2030, with a central estimate of 8,700 from newly arising need. The estimated newly arising need for July 2025 to June 2030 is higher than in the 2019-based estimates. This increase reflects higher projected household growth in the 2022-based household projections compared with the 2018-based projections used previously. The Authority will need to give detailed consideration to the implications of the updated estimates of housing need. As the most up to date projections, the Replacement LDP must properly account for the
new dataset to ensure soundness of the plan. In this regard, it is stated at Paragraph 5.34 of the Development Plans Manual that “In terms of considering the level of housing provision for a plan, the most up-to- date suite of Welsh Government Population and Household Projections are a fundamental part of the evidence base.”

Accordingly, Paragraph 5.35 goes on to state that “All LPAs should use these projections and the resultant household numbers when considering the level of housing provision for a plan period”.

In light of the February 2026 publication of updated estimates of housing need in Wales (which indicate
a substantial increase in both existing unmet housing need and newly arising need), and in the context of the existing under-delivery of units evidenced within the most recent LDP AMR (i.e. which identifies a shortfall in housing delivery of 27.3% on the adopted LDP target), it is considered essential that the overall growth levels for the Replacement Plan are revisited (and increased accordingly).

Policy HG1 KS1 – Land at North West Barry
Overall Support for Allocation

The detailed supporting information prepared on behalf of Persimmon Homes in relation to the Land at North West Barry site to date, including the masterplanning work undertaken in liaison with the Local Authority and their statutory consultees, has demonstrated that a sustainable, high-quality residential development which responds sensitively to both local character and landscape setting can be delivered on the site. It is considered that the allocation of Land at North West Barry (KS1) represents an entirely suitable housing allocation, which has been evidenced as being both viable and deliverable. The
inclusion of KS1 as a housing allocation in the Deposit Plan is therefore welcomed and supported.

Policy HG1 KS1 - Detailed Wording - Objections As stated, although the representations provide overarching support for the Deposit Plan and the inclusion of Land at North West Barry as an allocation, a number of detailed matters are objected to in relation to specific elements of the proposed KS1 policy wording.

It is acknowledged that the Key Site will need to be delivered in accordance with placemaking principles
(as set out in Policy SP4 Placemaking and Policy PGD1 Creating Well Designed Places), and masterplanning work to date has demonstrated that the site is fully capable for compliance with both Policy SP4 and PGD1.

Comments are provided on the additional requirements which the site is anticipated to comply with as set out at Policy HG1 KS1. Revised wording where required is identified in red.

• The provision of a minimum of 113 affordable housing units (30%) with a unit mix reflecting the requirements of the latest Local Housing Market Assessment and the Council’s waiting list data.

In order to deliver a greater social mix, the affordable units should be dispersed across the site in clusters of no more than 10 units, The positioning of the affordable units will be informed by the experience and best-practice of the Registered Social Landlord responsible for the delivery and ongoing management of the units, with their delivery being phased across the development trajectory.

The policy as currently worded is considered to be overly prescriptive with regards to the positioning of affordable units on the site. It is the case the Registered Social Landlord who is responsible for the delivery and ongoing operation/management of the affordable units is best-placed to advise upon the positioning of the affordable units within the site layout. As such, it is requested that the prescriptive nature of the above bullet point is mended to allow for the RSL to advise on best practice.

• Provision of land across the site frontage to allow for the widening of the A4226 Port Road West and the delivery of an Active Travel route across the frontage of the site as part of the Weycock Cross to Cardiff Airport Active Travel route, as identified in Policy TR1 (relating specifically to the delivery of the section of the Active Travel route adjoining the northern boundary of the Key Site only).

• Creation of a new signalised junction on to the A4226 Port Road West, which will need to accommodate controlled pedestrian/cycle crossing facilities.

With regards to the first two bullet points set out under the ‘Sustainable Transport and Highways’ section of the Policy HG1 KS1 (copied above), to confirm, as part of the development of the Key Site, it is proposed (as detailed within the submitted Transport Assessment) to construct a new junction from Port Road to the west of the Weycock Cross roundabout at the location of the existing field gated access in the form of a signal-controlled junction, which would allow for the safe and timely exit of traffic from
the development onto the local highway network. Such an access would also provide enhanced Active Travel infrastructure in conjunction with the proposed Active Travel route between the Weycock Cross junction and Cardiff Airport. Traffic signals at the proposed site access would provide for dedicated demand dependent green time for pedestrians and cyclists along this section of the A4226 Port Road.

Significant work has been undertaken to date in demonstrating that the above is deliverable. However,
it is requested that further clarification is included within the policy text to confirm that the Key Site is not responsible for the delivery of any further/additional sections of the Weycock Cross to Cardiff Airport Active Travel route, over and above the section of the route which adjoins the Key Site.

Suggested additional text is outlined in red above.
• A proportionate contribution towards off-site improvements to the capacity and flow of Weycock
Cross roundabout and other junctions on the strategic highways network where necessary (in the
context of the impact of wider committed developments on the strategic highway network).

As set out within the Transport Assessment (May 2025) prepared in support of the Key Site, the traffic movements associated with the North West Barry allocation could be accommodated on the highway network with a marginal and inconsequential impact on the conditions already experienced on the local highway network. An appraisal of the impact of committed development (as agreed with the Highways Authority) has been undertaken as part of the Transport Assessment, which identifies that committed
development within the vicinity of the Weycock Cross junction would have a greater impact upon the local highway network than the North West Barry Key Site. The North West Barry development is smaller in comparison to the other committed development assessed, and would have a marginal and inconsequential impact upon the operation of the Weycock Cross junction. It is therefore considered that the policy wording should be amended to reflect the ‘proportionate’ nature of contributions required.

Suggested additional text is outlined in red above.
• A contribution towards off-site sustainable transport measures in the area (as necessary and related to the Key Site).

Further clarification is required in regards to the above bullet point. It will be important to ensure that any off-site measures are directly related to the proposed development, and are necessary to ensure the acceptability of the proposed development. The requirement for a contribution towards off-site measures ‘in the area’ is not specific enough, and it is requested that the wording is amended as per the suggested text outlined in red above.

• The provision of a key area of open space (minimum 2.3 ha) to the south of the site adjoining Porthkerry Country Park which will serve as a buffer to the adjoining SINC at Mill Wood and offer opportunities for significant iodiversity enhancements. The ownership of this area should be
transferred to the Vale of Glamorgan Council, together with an appropriate financial contribution, for management as part of Porthkerry Country Park.

It is considered that the inclusion of a specified figure for the area of open space to be provided within the southern section of the site is unnecessary within the policy text.

The Indicative Plan for the Key Site included at Figure 13 of the Deposit Plan illustrates the indicative extent of ‘Significant Open Space’ to be provided adjoining Porthkerry Country Park, which will be subject to further detailed masterplanning work as the Planning Application is prepared in due course. A figure for the exact area
of open space to be provided within this section of the site cannot therefore be robustly specified until the further stages of masterplanning work are completed. As such, it is requested that the figure is removed from the policy text, with the identification of ‘Significant Open Space’ on Indicative Plan being considered satisfactory.

Furthermore, it is not considered appropriate that the policy wording should refer specifically to the financial contribution towards the management of this land, in addition to its transfer, as such contributions will be subject to detailed viability appraisal work at the Planning Application stage.

Deposit Plan Appendix 1 - Housing Trajectory
The identified delivery timescales and quantum of units for the site as set out at Appendix 1 of the Deposit Plan (as copied below) are agreed with and considered to be suitable/deliverable:

2028-2029: 30 units
2029-2030: 60 units
2030-2031: 60 units
2031-2032: 60 units
2032-2033: 60 units
2033-2034: 60 units
2034-2035: 46 units

Persimmon Homes are committed to the delivery of the allocation, in accordance with the phasing trajectory outlined in the Deposit Plan. Further to the detailed submissions previously made, including extensive viability evidence which has been discussed in detail with the Local Authority and their viability consultant, it is confirmed that the site is viable and deliverable in accordance with the identified delivery timescales. It should be noted that there is a possibility that the number of units to be delivered within the first year (2028-2029) could be increased slightly, however, it is considered that the above presents a realistic trajectory for the site.

Deposit Plan Appendix 2 – Infrastructure Delivery Plan
A number of amendments to the text are requested in regard to the infrastructure requirements for KS1
North West Barry as set out within the Infrastructure Delivery Plan at Appendix 2 of the Deposit LDP.

Within the ‘Key site issues and constraints’ section of the Infrastructure Requirements table, the following amendments to the text are considered necessary:

• Proportionate access and junction arrangements on to the A4226 and a financial contribution towards strategic highway network enhancements (in the context of the impact of wider committed developments on the strategic highway network).

As set out above, it is important that the required financial contribution towards strategic highway network enhancements is proportionate to the scale of the North West Barry development, and that additional committed developments, which would have a greater impact on the strategic highway network, are considered in the round.

• Previous desk-based assessment and site visits dentified that development would have a major impact on five features (?), including important hedgerows which form historic boundaries. Archaeological features were also identified.

The above bullet point requires clarification as to the ‘five features’ which the development would have a ‘major impact’ upon. It should be noted that masterplanning work to date has been informed by extensive survey and assessment work which ensures that the proposed development is capable of addressing all constraints.

Within the section of the table where ‘broad costs’ of key infrastructure requirements are outlined, it is considered that the following amendments to the text are necessary:

• Education – Estimated Cost Circa £3,730,000 (£TBC)
It is considered that an estimated cost for education contributions cannot be specified at this stage, as the contribution will be directly related to current school capacity figures at the time of the Planning Application, with school capacities being fluid and subject to change. As such, the ‘circa’ figure should be removed from the text and replaced with ‘TBC’ at this point.

• A proportionate contribution towards on-site improvements to the capacity and flow of Weycock
Cross roundabout and other junctions on the strategic highways network where necessary (in the context of the impact of wider committed developments on the strategic highway network).

• VOGC to deliver improvements to junctions on the Strategic Highways Network using s106 contributions (from the North West Barry Key Site and other relevant commitments) . As set out above, it is important that the required financial contribution towards strategic highway
network enhancements is proportionate to the scale of the North West Barry development.

• Contribution towards off-site sustainable transport measures in the area as necessary and related
to the Key Site.

As per the wording contained within the policy text of HG1 KS1, the requirement for a contribution towards off-site measures ‘in the area’ is not specific enough to provide certainty for the developer, and it will be important to ensure that any off-site measures are necessary and directly related to the North West Barry development.

• Community Facilities – Estimated Cost Circa £665,000 (£TBC) It is considered that an estimated cost for community facility contributions cannot be specified at this
stage – no background calculations are provided to evidence that this estimate is robust. As such, the
‘circa’ figure should be removed from the text and replaced with ‘TBC’ at this point.

Policy CC1 – Residential Operational Net Zero Carbon Development

Persimmon Homes has significant concerns regarding Policy CC1 and objects to it on the basis that it replicates requirements already being progressed at a national level through Welsh Government’s Future Homes Standard (FHS). The FHS is intended to deliver “zero carbon ready” homes via a unified Building Regulations framework, making additional local policy unnecessary. At present, Building Regulations Part L1A sets out the standards for energy efficiency in new dwellings, and Persimmon
already designs its homes to go beyond these minimum thresholds. This includes enhanced insulation and improved building fabric performance, with reduced U values for elements such as walls, roofs, floors and windows to minimise heat loss. As a result, our homes typically achieve strong Energy Performance Certificate (EPC) ratings, generally in the A–B categories. Introducing further operational net zero requirements at a local planning level risks adding cost, complexity and uncertainty, potentially affecting the viability and deliverability of housing sites. The Development Plans Manual for Wales is clear that local plans should not repeat national policy or seek to regulate matters already addressed through other statutory regimes.

On that basis, Policy CC1 is not considered to be justified and is inconsistent with the second test of soundness.
The proposed shift in standards from April 2030 represents a substantial and abrupt escalation in expectations. Although the policy refers to schemes such as Tai ar y Cyd and AECB CarbonLite, these examples largely relate to grant funded affordable housing projects. There is no robust evidence that equivalent standards can be met on mainstream housing sites without undermining overall viability. The Development Plans Manual requires policies to be based on strong evidence and to be realistically deliverable across the plan period. Without this, there is a risk that the proposed policy could impede
housing delivery and compromise the RLDP’s ability to meet identified needs.

Policy CC1 could also lead to inconsistent energy performance requirements across Local Planning
Authorities in Wales, contradicting the advantages of a unified regulatory system via Building Regulations. For volume housebuilders working across several authority areas, this would introduce unnecessary variation and complication. The DPM highlights the importance of policies that support housing delivery and avoid avoidable burdens. By introducing bespoke modelling thresholds and
operational monitoring requirements, CC1 risks blurring the line between planning and Building Control, raising questions about the policy’s justification and practical application.

It is Persimmon’s view that Policy CC1 is premature and that it is more appropriate for such matters to be addressed through building control rather than planning policy. In its current form, the policy risks impacting housing supply, affordable housing delivery and overall implementation across the plan period. For these reasons, we consider that Policy CC1 fails to satisfy the relevant tests of soundness and should be removed from the emerging RLDP.

Summary

As summarised above, and set out in full detail within the supporting survey/assessment work that has been provided to the Local Authority in relation to the site, the inclusion of Land at North West Barry as a Key Site (Policy HG1: KS1) with the Replacement Plan fully accords with the RLDP strategy. Furthermore, it is considered that (with the inclusion of the site), the Deposit Plan complies with the tests of soundness. Further to ongoing discussions with the Authority, we would reiterate the Site Promoter’s commitment to delivering the allocation which has been evidenced as being entirely deliverable and viable
As set out within this representation, overall support is provided for the Deposit Plan (and the inclusion of North West Barry as a Key Site), however, as detailed, bjections are submitted in relation to the specific elements of the proposed wording of the Key Site policy (SP4: KS1).

We look forward to the RLDP progressing towards examination, and would welcome the opportunity to
take part in the relevant Hearing Sessions (in relation to Policy HG1: KS1, and wider strategic policies as required). Please do not hesitate to contact me should you require any further detail or wish to discuss any aspect of the representations.

Suggested wording includes:
“The Local Development Plan will support resilient and sustainable local food systems by safeguarding productive agricultural land, promoting peri-urban food growing opportunities, and facilitating local food supply chains as an integral part of sustainable growth.”

The overall contribution to health and wellbeing of the Deposit RLDP is positive and there are opportunities to develop further detail through the supplementary planning
guidance (SPG) proposed. We are keen to ensure that these SPG’s are progressed within the short-term and that Cardiff and Vale University Health Board (CAVUHB) are
involved in the development of some of these. The content and application of the SPG’s will be fundamental to the effectiveness of several of the policies identified in the
deposit plan. These must be supported by effective processes and relationships that ensure the intentions for positive contributions to health and wellbeing are delivered.

The Deposit RLDP provides a strong framework for placemaking, climate action, and healthy communities. Opportunities exist to further embed healthy and sustainable food systems as essential spatial infrastructure rather than solely as community
amenity or retail management issues. Strengthening policy wording in areas such as placemaking, rural diversification, employment land, green infrastructure, and community infrastructure would better align the Deposit Plan with the Well-being of Future Generations Act, Planning Policy Wales Placemaking agenda, and emerging Welsh food system strategies. This is particularly relevant as the Future Generations Commissioner named his first priority area in office being food, and the Welsh Government has recently published its Community Food Strategy. The Future Generations Office also recently produced guidance for local authorities including several planning-related recommendations.


The following comments are provided in the order they appear in the document:

Spatial strategy: SP1 - Sustainable growth: While the plan addresses overall growth distribution, it does not consider how development affects local food resilience, including the protection of agricultural land, peri-urban growing spaces, or local supply chains. There is no strategic reference to food as a component of sustainable, resilient
communities. The vision and strategic objectives currently contain no mention of ‘food’ or ‘farming’.

Request to add reference (Spatial strategy or Strategic objectives section) to supporting resilient and sustainable local food systems in spatial strategy principles, including protection of productive land and support for local supply chains. Suggested wording includes: “The Local Development Plan will support resilient and sustainable
local food systems by safeguarding productive agricultural land, promoting peri-urban food growing opportunities, and facilitating local food supply chains as an integral part
of sustainable growth.”

SP4 Placemaking: Placemaking principles are clear and it is encouraging that prioritising the determinants of health and wellbeing during the design process are included as one of the principles. The placemaking statement forming part of the Design and Access statement is welcome to ensure any proposal aligns with the principles. The placemaking SPG will be key to consolidate guidance on physical activity, transport, climate resilience, mental wellbeing, access to food and food production, and inclusive design. Whilst this section focuses on design quality, density, and public spaces it does not explicitly incorporate food production or edible landscaping. Opportunities for multifunctional green spaces that produce food are missed, which could support local
diets, biodiversity, and community engagement. Suggestion to include wording to support multi-functional green infrastructure consistent with placemaking principles:

“Development proposals, where appropriate, should incorporate productive landscapes, edible landscaping, rooftop or community growing spaces, and other
opportunities for local food production as part of multifunctional green infrastructure.”

SP5 Creating Healthy and Inclusive Places and Spaces: CAVUHB support the statement that 'Developers are required to undertake a screening assessment of their
proposal at the pre-application stage to identify the potential health impacts of their development'. CAVUHB agrees with the criteria set out in the table and would like to see examples/further guidance of 'other' developments where there is likely to be a significant impact on health and wellbeing. HIA should also consider the cumulative
impact across multiple smaller developments in the same area, and whether they trigger thresholds collectively.

6.54 We suggest adding the word 'abilities' to the sentence '...enabling people of all ages, backgrounds and abilities to live in an environment that will support them to live
full, productive and prosperous lives.'

6.60 We welcome the requirement for new developments to conduct screening at the pre-application stage using the Council's Health and Wellbeing checklist and the rapid
HIA. We are keen that CAVUHB are involved in the development of the Healthy Placemaking SPG to consider how submitted HIAs will be assessed by the Council to
ensure Developers submit a quality HIA and implement the conclusions.

6.61 Amendment to organisation titles to: Cardiff and Vale University Health Board and Wales Health Impact Assessment Support Unit (Public Health Wales).

6.62 Wales Health Impact Assessment Support Unit has recently released guidance on HIA - see https://phwwhocc.co.uk/whiasu/ for more information and toolkits to ensure most up to date is in use.

6.63 Suggestion to amend the paragraph to include reference to 'access' to services, for example 'A further role of the RLDP is to support the access to and delivery of community, health and social care and wellbeing services within the community..'.

6.65 Suggestion to change wording from 'encouraged' to 'expected' for example:
Developers are expected to engage with the Health Board at pre-application stage to enable due consideration of healthcare infrastructure requirements.' The requirement
for HIA will assist with this expectation.

Key housing sites (HG1 KS1 onwards): The Key Site requirements reference “enhancements to leisure, sport and recreation spaces”. Without quantified standards or phasing triggers, however, these requirements may be difficult to enforce consistently at the planning application stage. Clear policy hooks or supporting standards prior to submission would strengthen implementation. It is recommended that the Key Site schedules include minimum on-site provision standards and delivery
phasing obligations to ensure that both sport infrastructure and recreational space provision keep pace with the additional demand generated by future population
growth.

SP11 Retail, commercial and service centre hierarchy and RCS1 Resilient retail, commercial and service centres: This policy focuses on hierarchy and vitality of retail
centres but fails to actively support the resilience of local retail, through measures which support local food markets, small-scale fresh food retailers, or local producer
supply chains. This limits opportunities for strengthening local food economies.
It is important that the need for convenience food retail space within Barry, Penarth and Llantwit Major, recognised in SP11, is matched with this rational for ‘local affordable food’ outlined in SP5.

Consider adding: “The Council will support local food markets, cooperative food retail, and initiatives that strengthen local producer supply chains within town and service centres, in line with the Town Centres First approach.”

RCS3 - hot food takeaways: CAVUHB commends the recognition that the clustering of unhealthy food outlets is a significant health issue and supports the proposals to
consider controls on takeaway proliferation (RCS3). This will support the creation of healthy environments, a commitment within the Cardiff and Vale Good Food and
Movement Framework endorsed by RPB. Health and inclusion policies mention general wellbeing but do not specifically address access to healthy food, food deserts, or distribution of retail providing fresh/local food, especially in new or expanding residential areas.

Proposal to include criteria for equitable access to healthy food and community food infrastructure in development proposals, such as: “Major developments should demonstrate equitable access to healthy food outlets, community growing facilities, or other community food
infrastructure within walking distance of new residential areas.” This addresses diet related health inequalities, encourages healthier communities and aligns with HIA
guidance.

EMP6 Rural diversification: The plan frames food production predominantly as a community activity rather than recognising its commercial, economic, and supply
chain potential. This limits opportunities for climate-resilient rural economies in a county with such a rural character as the Vale. Policy supports general rural business diversification but does not explicitly enable
agro-ecological practices, local food processing, CSA (community-supported agriculture), or other sustainable farming models.

Proposal that the plan should explicitly support sustainable, commercially viable local food enterprises as legitimate rural employment uses - to include the following wording: “Rural diversification proposals that support agro-ecological farming, sustainable local food production,
community-supported agriculture, and short supply chain enterprises will be supported where compatible with landscape and environmental considerations.”

SP10 Sustainable transport: We support these policies, and suggest the plan is explicit that all new active travel infrastructure should meet the statutory Active Travel
Act guidance (Link: ttps://www.gov.wales/sites/default/files/publications/2022
01/active-travel-act-guidance.pdf) and also that infrastructure should be built to a specification to ensure resilience as extreme weather events increase, preventing
flooding and making use more comfortable during hot weather (such as shading from trees). We note the absence of reference to people living with disabilities and suggest adding 'wheeling' as well as walking and cycling.

SP13 Community infrastructure and planning obligations:

We want to take this opportunity to highlight the challenges that population growth places on healthcare
services. The projected level of population growth identified within the RLDP will have an impact on the CAVUHB's community healthcare facilities and infrastructure. Please refer to the information provided as part of the background evidence paper titled 'BP37
Primary, Community and Intermediate Health Care 'for more detail on the CAVUHB response which identifies there is limited scope for the current infrastructure within
existing GP premises to absorb the LDP growth. CAVUHB recognises the need to prioritise the expansion of the existing estate (where feasible) or support new
developments to take forward its strategic objectives.

Open space and recreation (CI1 and CI2): The evidence base supporting the sport and recreation elements of Policies CI1 and CI2 could be strengthened. At present
there does not appear to be a full Open Space Assessment setting locally-derived standards, nor a Playing Pitch Strategy nor Indoor Sport Facility Assessment. The Cardiff and Vale of Glamorgan Sports and Physical Activity Facilities audit report is
currently underway (with completion anticipated in May 2026), which should make a useful contribution to the evidence base once available.

Community Facilities: this policy focusses on schools, healthcare and social infrastructure, but does not include food-related community facilities such as kitchens, food hubs or education centres. Proposal to include the following information: “Community facilities should include, where appropriate, community kitchens, food hubs, educational facilities for food skills, and other infrastructure that enhances local food resilience and social cohesion.”
There is no reference to the expectation that local communities are consulted in relation to the development of community facilities. We would like to see a
requirement for community engagement and that such developments are based on a detailed understanding of existing community strengths, assets, needs and
challenges. This might be achieved as part of the HIA which includes stakeholder engagement.

SP14 Employment Growth: Employment land allocations focus on general industrial and office uses, with no explicit support for food hubs, processing, or logistics facilities
that would enable local food supply chains. Again, in an agricultural county such as the Vale, and given Wales’ push for local supply resilience, this is a major opportunity gap. Consider including the following wording:

“Employment land allocations should consider the needs of food processing, distribution, and logistics facilities that support local and regional food supply chains.” This supports local supply chain development, reduces food miles and provides local employment opportunities, Welsh Government evidence highlights the importance of food processing in local supply resilience.

SP19 Green infrastructure: this policy emphasises the biodiversity, climate adaptation and recreation, but does not explicitly recognise productive landscapes or
urban agriculture as part of the multifunctional green infrastructure.

Suggested wording: “Green infrastructure networks should recognise and integrate food productive landscapes, urban agriculture, and community growing spaces as multifunctional components contributing to biodiversity, climate adaptation, and wellbeing.”

SP16 Climate change: this policy addresses migration and adaptation but omits food systems. It also does not recognise the emissions reductions from local food
production, short supply chains or sustainable farming practices.
Consider including the following wording: “Development proposals should encourage short supply chains, low-carbon farming methods, and local food production where feasible, in order to support climate change mitigation and adaptation objectives.”

1.1. Savills is instructed by Hallam Land (‘Hallam’) to respond to the consultation on the Deposit version of the Replacement Local Development Plan (‘RLDP’) by the Vale of Glamorgan Council (‘VoG’).
1.2. Hallam is the strategic land arm of Henry Boot PLC and is one of the UK’s most well established and successful land promoters. Hallam operates throughout England, Scotland and Wales from 7 regional offices working with landowners, developers, local authorities, communities and other parties to bring forward development opportunities. Hallam has been in operation since 1990, specialising in obtaining planning permission and delivering development larger schemes including new communities and urban extensions.
Background to Representations
1.3. The Preferred Strategy was published in November 2023. The Preferred Strategy identified “Land West of St Athan” and “Land South of the B4265, St Athan” (Site IDs 456 and 457) as one of five Key Sites in the Preferred Strategy. Both of these sites are under the control of Hallam and were submitted as part of the Call for Sites. A site-specific illustrative masterplan and policy wording were provided under Policy SP4 KS5 (Land to the West of St Athan).
1.4. Hallam submitted representations on the consultation on the Preferred Strategy. These representations were very much supportive of the identification of “Land to the West of St Athan” as a Key Site and the approach that was taken more generally taken in the Preferred Strategy.
Approach to Responding to Consultation
1.5. The VoG has published the Deposit version of the RLDP. The Deposit is the first version of the RLDP to include emerging allocations, and detailed development management policies, as well as a Proposals Map. It is accompanied by a substantial evidence base which includes various supporting technical documentation submitted as part of the promotion of the allocated sites.
1.6. Building upon the Preferred Strategy, the Deposit RLDP proposes to allocate Land to the West of St Athan as a Key Site. The site is identified under Policy HG1 KS5 (Land to the West of St Athan) as key mixed-use site with capacity for 600 new homes alongside new community and commercial facilities.
1.7. Hallam’s representation to this consultation broadly splits into three separate sections:
• It offers general support for the housing requirement, growth strategy and settlement hierarchy. This is covered in Chapter 2 of this Statement;
• It wholly supports the approach of allocating Land to the West of St Athan as part of the Deposit RLDP whilst also providing detailed commentary on the specific wording of Policy HG1 KS5 (Land to the West of St Athan). This is covered in Chapter 3 of this Statement; and
• It provides commentary on a range of development management policies. This is covered in Chapters 4, 5, 6, and 7 of this Statement.
1.8. As well as this Statement, Savills has provided commentary on these specific policies under the VoG’s consultation website.

Policy SP1 (Sustainable Growth Strategy), Policy SP2 (Settlement Hierarchy), and Policy SP6 (Housing Requirement)
2.1. Together, these policies have the effect of:
• Setting the housing requirement to be delivered over the RLDP plan period of 7,890 homes with a flexibility allowance applied on top so that provision is made for a total of 8,660 homes. This is the same housing requirement to that included in the Preferred Strategy which was found by Welsh Government to be in conformity with Future Wales (Policies SP1 and SP6);
• Identifying the extent of the Strategic Growth Area as the primary focus of new housing growth. Concentrations of new housing are focussed in those locations served by existing transport routes and where there are opportunities to enhance sustainable transport connectivity. St Athan is a specifically named settlement within the Strategic Growth Area (Policy SP1); and
• Identifying St Athan as a Primary Settlement in the third tier of the settlement hierarchy. This is the same tier of the settlement hierarchy as St Athan is in the adopted LDP (Policy SP2).
2.2. Hallam are generally supportive of the aims of these three policies.
2.3. They recognise that the housing requirement has been subject to extensive scrutiny and been found to be appropriate by Welsh Government in response to the Preferred Strategy. In that sense, there is nothing further for Hallam Land to comment upon here other than to note that it should reasonably be seen as the minimum number of homes that the RLDP should be aiming to deliver, particularly following the publication of the 2022-based household projections between Welsh Government’s comments on the Preferred strategy and the publication of the Preferred Strategy.
2.4. The strategy – of focussing new housing in those locations served by existing transport routes and where there are opportunities to enhance sustainable transport connectivity – is wholly supported. St Athan is clearly already a sustainable location for growth and its sustainability and connectivity have clear potential to enhance alongside further development. The delivery of growth in St Athan is therefore considered to firmly align with the RLDP’s strategy.
2.5. The continued positioning of St Athan as a Primary Settlement in the third tier of the settlement hierarchy is considered appropriate though clearly the delivery of two Key Sites within St Athan as part of the RLDP has the potential to further elevate its position in the future. This is reflected in Table 10 of Background Paper 5 Settlement Appraisal Review where St Athan is given one of the higher scores of the Primary settlements.

Policy HG1 KS5 (Land to the West of St Athan)
3.1. Policy HG1 (Housing Allocations) identifies those sites that are to be allocated to meet the housing requirement of 7,890 homes that is set out in Policy SP1 (Sustainable Growth Strategy) and Policy SP6 (Housing Requirement) of the RLDP. As well as the existing landbank and an allowance for windfalls, Policy HG1 notes that this requirement will be met through a mix of Key Sites, conventional housing allocations, housing-led regeneration opportunities, and rural affordable housing led sites.
3.2. There is a standalone separate policy for each of the five Key Sites that are identified in Policy HG1 (Housing Allocations). Each separate Key Site policy identifies what the site is proposed to be allocated for before providing setting out expectations of how each Key Site should come forward – both in terms of land uses that should be delivered and constraints and opportunities needing to be responded to – that are framed under a series of sub-headings. A masterplan sits alongside each Key Site policy whilst a package of supporting documentation for each Key Site submitted by the site promoter is also made available as part of the consultation on the Deposit RLDP.
3.3. The relevant policy for Land to the West of St Athan is Policy HG1 KS5.
3.4. As a starting point, Hallam wholeheartedly support the allocation of Land to the West of St Athan as a Key Site within the RLDP. Hallam made a comprehensive submission as part of the Call for Sites stage and since then have worked proactively with the VoG and other stakeholders to demonstrate that the site is suitable, deliverable, and viable. It’s identification as a Key Site in the Deposit RLDP represents extensive and thorough assessment – its proposed allocated is therefore considered to be sound and firmly evidence based.
3.5. So that the policy functions as effectively as possible, Hallam has a small number of comments and included at Appendix A is a re-worded version of Policy HG1 KS5 which incorporates those changes with text suggested to be removed crossed through and text to be added shown underlined.
3.6. These proposed adjustments are considered in turn below and are structured around the sub-headings that are contained within the policy wording itself.
Site Capacity and Housing Trajectory
3.7. Extensive environmental and technical work has been undertaken by Hallam to support the promotion of the site and the development of a masterplan (and site capacity) that responds to the site’s constraints and opportunities.
3.8. That said, Hallam is not a housebuilder and once an outline planning application has progressed, Hallam will identify a development partner (which could be a single or multiple housebuilders / housing associations). Clearly different housebuilders have different house types and differing approaches to density.
3.9. In addition, whilst a lot of technical and environmental work has been undertaken to date, clearly further technical work would be submitted at planning application stage which would further validate the site’s capacity.
3.10. Legislative and guidance changes also have the potential to impact a site capacity. Whilst the masterplanning process has been prepared to be SAB compliant, the impact of the introduction of the requirement to secure SAB approval has had an impact on site capacity and it follows that a further, and as yet unknown, legislative or guidance change could have a similar impact.
3.11. This is not to suggest that there isn’t a high degree of confidence that the site can deliver roughly 600 homes, rather that Hallam suggest that the word ‘approximately’ is added to the policy wording to reflect the potential for a degree of deviation (which could be upwards or downwards).
3.12. Background Paper 9A Housing Land Supply and Housing Trajectory sets out the anticipated annual delivery rates for housing over the RLDP. With regards to the ability of the site to deliver the number of homes it is allocated for in the RLDP plan period, the housing trajectory for the site reflects that the first completion date was pushed back from 2027/2028 to 2028/2029 since the consultation on the Preferred Strategy. This means that the whole site continues to be shown as being delivered within the RLDP plan period.
3.13. Hallam support and agree with the approach set out in the Draft Housing Trajectory and see it to be realistic and achievable based on their experience and subject to usual caveats around the condition of the market, RLDP progression, and swift determination of a planning application.
Affordable Housing
3.14. At present, Policy HG1 KS5 (like all of the standalone policies for the other four Key Sites), states that the site should provide a minimum of 210 affordable housing units. This figure is derived from 35% of the number of homes that the site is allocated for (600 homes).
3.15. Worded at present, a strict interpretation of this policy could be that 210 affordable units must be provided onsite regardless of the total number of homes that are proposed. For example, it could be interpreted as requiring a fixed number of affordable homes of 210 homes, even if the total number of homes that are proposed on the site is fewer than the 600 homes that the site is allocated for or, conversely, that only 210 homes should be delivered as affordable if more than 600 homes were to be delivered and the RLDP allocation exceeded.
3.16. Hallam recognise that this is not what the policy wording is seeking to achieve (and their viability work for the site is based on the site delivering 600 homes of which 35% are affordable) but suggest that its wording could be clarified by removing reference to a specific number of affordable homes for the site to deliver in favour of just the affordable housing percentage being noted in the policy.
3.17. Hallam also suggest that the requirement for affordable housing units to not be in clusters of more than 10 homes is removed and that the approach is for this to be considered on a site by site and case by case basis and with recognition that Policy HG5 (Affordable Housing Exception Sites) which can provide a framework for 100% affordable sites of more than 10 homes to be delivered. As an example, and in the case of Land to the West of St Athan, the “Land South of the B4265, St Athan” (Site ID 457) portion of the site is likely better suited to a mixed-use development alongside the future St Athan Railway Sation. This portion of the site is probably better suited to a flatted form of development (either above non-residential uses or as a block) which tend to be delivered as 100% affordable housing developments rather than comprising a mix of private and affordable housing.
Sustainable Transport and Highways
3.18. This part of the policy sets out expectations relating to sustainable transport and highways and there are a number of matters which Hallam wish to comment on.
3.19. As a starting point, Hallam support the delivery of St Athan Railway Station and therefore commits to its safeguarding. Likewise, Hallam recognise the potential suitability for the “Land Between the Railway Line and B4265, St Athan” (Site ID 458) site to accommodate a Welsh-Medium Secondary School and can also therefore commit to safeguarding land for the delivery of a pedestrian and cycle bridge over the railway line. Specific comments on Policy TR1 (Transport Proposals) and Policy CI3 (New Community Facilities) are made elsewhere in this Statement.
3.20. With regards to the Sustainable Transport and Highways section of Policy HG1 KS5, Hallam’s overall position is that a careful balance needs to be reached between the policy wording being explicit as to what highway works must be delivered and reserving consideration of this until planning application stage where the exact site capacity is better understood and a full Transport Assessment submitted.
3.21. At present, Hallam’s view is that the policy wording is overly explicit and suggest that it could be qualified through the addition of the following text before listing the offsite highways improvements:
‘Subject to the Strategic Transport Assessment and site-specific Transport Assessment submitted at planning application stage’.
3.22. Turning to the specific offsite highways measures that are listed within the policy wording, Hallam have four comments.
3.23. Firstly, it is suggested that the delivery of an active travel link along the B4265 between the site entrance and the Gileston Road junction should be secured via a financial contribution that is pooled with KS4 Church Farm. This reflects that the delivery of this link not only links Hallam’s site to other services in St Athan but also linking KS4 Church Farm to the services that are proposed and uses for which land is safeguarded within Hallam’s site. Clearly this is also to the benefit of existing residents of St Athan. This would reflect the approach that is proposed to be taking for the pooling of Section 106 monies for the delivery of an active travel route between St Athan and Llantwit Major.
3.24. Secondly, Hallam flag the need for the RLDP to be sufficiently flexible with regards to the delivery of an active travel link between St Athan and Llantwit Major. Ultimately, the purpose of delivering this active travel route would be to provide a connection from St Athan to Llantwit Major Railway Station and the delivery of a Railway Station in St Athan would remove the necessity of delivering this active travel connection. Hallam’s suggested amendments to the policy wording seeks to reflect this.
3.25. Thirdly, Hallam have been consistent in highlighting that, whilst there is an aspiration to deliver an improved pedestrian link along Llantwit Road, a combination of the road width and the extent of third party ownerships make delivering a continuous link very challenging with a pragmatic approach instead needing to take place that recognises the ability to deliver betterments but acknowledges that delivering a continuous link is unlikely to be possible. Hallam has suggested additional wording to clarify this.
3.26. Fourthly, Hallam highlight that the designing of a loop road within the site to facilitate access by a bus may be superfluous and represent an over-engineered solution given the potential for the St Athan Transport Interchange that land is safeguarded for under Policy TR1 (Transport Proposals) is envisaged to accommodate infrastructure to accommodate a bus connection. On that basis, it is suggested that the following clause is added to the policy wording to reflect that bus connectivity to the site may be delivered not via an internal bus loop:
‘Subject to progress on the St Athan Transport Interchange as land is safeguarded for under Policy TR1 (Transport Proposals)’
Community Infrastructure
3.27. There are three points which Hallam wish to make in connection to this element of Policy HG1 KS5.
3.28. Firstly, Hallam suggest that the wording of the part of the policy relating to financial contributions to fund the delivery of additional school places needs to be adjusted. At present this part of the policy is worded as if there is an automatic requirement to provide Section 106 monies for school places where Circular 13/97 is clear that a contribution should only be sought where the schools do not have current projected capacity to accommodate the new children from the development. Hallam’s proposed adjustments seek to ensure that this part of the policy reflects this though note that Background Paper 43 Education forecasts a need for a financial contribution to be made for additional school places at all English and Welsh primary and secondary schools that the site is within the catchment of.
3.29. Secondly, Hallam note that Table 10 of Background Paper 34 Community Facilities identifies an existing over-provision of community space within the St Athan Ward of 778sqm and a surplus of 531sqm of community floorspace at 2036 when the level of housing to be allocated in the Deposit RLDP is delivered. It is understood that this is on the basis of no community floorspace being delivered as part of Hallam’s proposals or as part of the KS4 Church Farm site. Hallam suggest that the wording of this element of the policy needs to reflect that community floorspace should only be required to be provided in the case of a local shortage in provision. Aligned to this, Hallam also suggest that the reference to specifically providing a ‘community building’ is adjusted to instead make reference to ‘community space’. This reflects that the community space element of scheme, if indeed it is actually required, could be a part of a larger mixed-use building (probably in the Mixed-Use / Community area) rather than as a standalone building.
3.30. Thirdly, Hallam note the error in the wording of the sixth bullet point under the ‘Sustainable Transport and Highways’ heading where reference is made to the safeguarding of land on the southern side of the railway line as being identified in Policy CI3(2) where-as it should be Policy CI3(6). This is a minor amendment that should be made to ensure consistency.
Green Infrastructure, Recreation Spaces, and Biodiversity
3.31. The masterplan prepared by PAD Design and submitted by Hallam shows the site delivering a mix of public open space and green infrastructure including the provision of allotments, a Neighbourhood Equipped Area of Play, a Local Equipped Area of Play, and a sports pitch. This is welcomed in Background Paper 32A Green Infrastructure Assessment of Key Sites which, at Paragraph 5.55 recognises that a ‘ground up’ approach has been taken in the masterplanning approach.
3.32. This is shown indicatively to illustrate the composition of public open space and green infrastructure that the site could provide alongside the other elements of built development that the site is allocated and the masterplan makes provision for.
3.33. Whilst, Hallam recognise the need to provide public open space, the starting point for this should be the Fields In Trust Standards and Hallam therefore suggest an approach where the policy wording is not specific about what forms this should take.

Policy TR1 (Transport Proposals)
4.1. This policy identifies three active travel routes and two public transport schemes that the Deposit RLDP safeguards land for, as well as three highway improvement schemes that are identified as being required to mitigate the impact of development. Two of these are in St Athan – one being the St Athan Transport Interchange for which land is safeguarded for and the second being the Gileston Road Junction which is identified as a required highway improvement. Both are considered in turn below.
St Athan Transport Interchange
4.2. Hallam support the safeguarding of land for the St Athan Transport Interchange and see that its delivery would be to the benefit of the Key Site itself but also more broadly to St Athan and western parts of the VoG.
4.3. It is clear from discussions with Transport for Wales that there is a strong business case for the delivery of a railway station and that the creation of “critical mass” through residential development around it has a key role in driving its delivery, as does the nationally significant economic role that the Bro Tathan Enterprise Zone has and the Aberthaw Green Energy Park will have. The proximity of St Athan to both of these hubs clearly contributes to its fundamental sustainability and suitability for growth whilst the further development of a critical mass of housing and employment generating uses will further support linkages between them and strengthen the business case for a new railway station at St Athan. This is reflected in TFW’s ‘Today, Tomorrow, Together: A Vision for Rail Across Wales and the Borders’ which confirms that the delivery of St Athan Railway Station remains in TFW’s pipeline which has been endorsed by the Westminster Government.
4.4. The location that is identified on the Proposals Map is Transport for Wales’ preferred location within the site and has been incorporated into the masterplanning approach which seeks to create a node around it by incorporating a bus interchange and a mix of uses.
4.5. At present, the Proposals Map identifies the location of the Railway Station using a red star which is positioned on the railway line itself but without the required land take not spatially being defined.
4.6. Whilst Hallam recognise that the exact land take required will need to be refined further through discussion with TFW, it may be the case that the mixed-use element on this portion of the site comes forward before the Railway Station.
4.7. The early delivery of these elements should be welcomed as clearly the mixed-use element both enhances the range of services and facilities in St Athan but also would mean that the Railway Station is integrated upon delivery.
4.8. On that basis, it is imperative that the safeguarding of land for the Transport Interchange is limited only to that land required to deliver the Transport Interchange and is done in such a way such the safeguarding does not sterilise non-transport related development from this portion of the site until the Railway Station has been delivered.
Gileston Road Junction, St Athan
4.9. Paragraphs 6.199 and 6.200 relate to the expectation that vehicle trips as a result of RLDP allocations in St Athan are anticipated to trigger the need to upgrade the Gileston Road Junction to a signal-controlled arrangement. This is informed by the conclusions of Table 3 of the Strategic Transport Assessment which forecasts that the junction will be operating above capacity during both the weekday AM and PM peak by the RLDP’s end point.
4.10. Hallam note that Technical Note 08 of the Strategic Transport Assessment identifies that the improvements to the Gileston Road Junction are to be delivered by VoG and funded through financial contributions from seven sites that the RLDP proposes to allocate.
4.11. Improvements to this junction are to be funded by a number of sites; however it is unclear whether (and if so, when) forward funding will be secured by the Council and clearly there cannot be a situation where none of the sites can deliver homes until strategic highways works are funded / completed. We therefore seek further clarification over the phasing of these works and note that early delivery of homes ahead of strategic highway improvements is likely to be important for deliverability of each strategic site.
4.12. To respond to Hallam’s above comments, one approach could be for references to highway improvement works to be entirely removed from this policy or, if they are to remain, that qualifying text is added to note that the need for and format of any improvements will be subject to detailed consideration at planning application stage and that such contributions must be justified in planning terms, particularly where (in the case of Pen Y Turnpike Road and Waycock Cross for Land to the West of St Athan), the distance from a site and the junction to be improved is significant and therefore thee number of vehicle trips that would be generated modest.
4.13. This aligns with Hallam’s suggested approach to the specific wording of Policy HG1 KS5.

Policy CI1 (Open Space Provision)
5.1. This policy consists of four parts which, combined, dictate how open space should be provided. These parts of the policy set expectations for the level of public open space that should be provided for, confirm that provisions for open space should also be made for commercial uses, notes that it is expected that open space will be provided onsite, and requires that an open space strategy is submitted as part of applications where open space is required to be provided.
5.2. Hallam note that Policy CI1 (Open Space Provision) of the Deposit RLDP, when compared with Policy MD3 (Provision of Open Space) of the adopted LDP, proposes an increase in public open space provision from a total of 2.4ha / 1000 people to 2.75ha / 1000 people.
5.3. Hallam is not clear as to what has driven the increased level of public open space that Policy CI1 (Open Space Provision) identifies as being required and would welcome clarification on this matter.

Policy CI3 (New Community Facilities)
6.1. As well as allocating land for five new or improved education developments, this policy safeguards ‘Land South of the Railway Line, St Athan’ for the delivery of a Welsh-medium secondary school.
6.2. This policy is clearly of interest to Hallam because Paragraph 6.250 places a requirement for the safeguarding of land on the northern side of the railway line on their Land to the West of St Athan Key Site for a footbridge to land on.
6.3. With the policy wording being intentionally light-touch, Paragraph 6.250 of the Deposit RLDP provides greater detail about the safeguarding of this land (and other paragraphs in the Deposit RLDP relate to other community facilities that Policy CI3 covers). It effectively does two things.
6.4. Firstly, it notes that the delivery of this school will require active travel improvements including the safeguarding of land for a pedestrian and cyclist footbridge over the railway line.
6.5. Secondly, it is clear that the safeguarding of this land is in response to a forecast increase in demand for Welsh-medium secondary school places across the whole of the VoG as a result of expanded capacity at Welsh-medium primary schools across the VoG. On this basis, it follows that this location has been selected as a preferred location because of its ability to serve the wider sub-region.
6.6. Hallam recognise that this site could be a suitable location for a Welsh Medium Secondary School and, as a principle, is agreeable to the safeguarding of land for the footbridge landing on the northern side of the railway line.
6.7. Paragraph 6.250 of the Deposit RLDP is clear that the delivery of a Welsh-Medium secondary school is in response to a regional / sub-regional demand rather than a local need as a result generated either by the development of Land West of St Athan or other emerging allocations within St Athan and it cannot be the case that Hallam are expected to make disproportionate contributions to either the delivery of the school or required active travel improvements just because they have control of the site or that it is next to the Key Site.

Policy CC1 (Residential Operational Net Zero Carbon Development)
7.1. The effect of this policy is to require new build development to achieve net-zero operational emissions. This is to be achieved through the following of the Energy Hierarchy for Planning with Policy CC1 (Residential Operational Net Zero Carbon Development) before the policy wording sets out space heating and energy use intensity standards to be met from RLDP adoption through to 2030 and then from 2030 onwards, and setting a requirement for on-site renewable electricity generation to have an output equivalent to annual energy consumption. The policy notes that this may not be technically feasible and, in these cases, requires that development maximises onsite renewable generation and / or connects or proposes to connect to a heat network and / or contributes to offsetting.
7.2. As a starting point, Hallam share the concerns expressed by the wider development industry that setting requirements above and beyond building regulations (the 2025 Future homes Standard) can present challenges. Building regulations are there as a mechanism to set fixed requirements that any development must achieve and the effect of introducing requirements to go beyond this will result in an uneven framework for housebuilders, significantly adding cost and reducing certainty.
7.3. The justification for using planning policy to set requirements exceeding building regulations is set out in Section 7 of Background Paper 33A Net Zero Buildings and throughout Background Paper 33 Net Zero Buildings Feasibility Study and Cost Assessment and centres on the fact that there is a precedent for such policies in both adopted and emerging policies.
7.4. There are two points to be made by Hallam here:
7.5. Firstly, a Written Ministerial Statement by then Housing and Planning Minister Lee Rowley made clear that it was not for Local Plans to set local energy efficiency standards that go beyond the requirements of building regulations with Inspectors to take this position at Local Plan examination stage that such an approach would not be sound. This Written Ministerial Statement was subject to an unsuccessful judicial review.
7.6. Clearly this is the position of the Westminster Government rather than the Welsh Government but the point is that it is wrong to suggest that there is a clear approach emerging in England for Local Plans to incorporate such policies when the Written Ministerial Statement warns Local Plans against setting energy efficiency targets that are stricter than building regulations. Where there are existing Local Plans in England that take this approach, they do not align with the Westminster Government’s position and there will be no Local Plans emerging including such policies.
7.7. Turning to a Wales context, whilst it may be the case that other local planning authorities are considering or looking into the use of such policies, it is worth noting that the two South East Wales local planning authorities which have adopted RLDPs (Bridgend and Merthyr Tydfil) do not include such policies and therefore that can be no confidence that the incorporation of such a policy approach will be found to be sound at Examination stage.
7.8. Secondly, Hallam have concerns with the approach that has been taken with regards to viability.
7.9. From Hallam’s review, a figure for achieving the requirements of Policy CC1 (Residential Operational Net Zero Carbon Development) is based on an analysis of three separate house type typologies as presented in Figure 4 of Background Paper 33A Net Zero Buildings. Background Paper 33A Net Zero Buildings is dated November 2025 but Background Paper 33 Net Zero Buildings Feasibility Study and Cost Assessment is from January 2024.
7.10. As a starting point, the figures for achieving this upgrade have been used by Hallam in the undertaking of the Development Viability Model with the development of the site found to continue to be viable with these incorporated. This is important as it demonstrates that, whilst Hallam do not believe such a policy approach should be taken, the development of the site at the time of the completion of the Development Viability Model for the site is viable whilst meeting the requirements of Policy CC1 (Residential Operational Net Zero Carbon Development).
7.11. Hallam’s concern is around the robustness of an approach that considers only three building typologies and does not carry out the exercise for a far broader range of house types that are deployed by all of the active housebuilders (both market and affordable) across Wales. This concern is particularly exacerbated by the fact that, as recognised at Paragraph 6.47 of Background Paper 42 Viability Assessment, takes the lowest estimate for the works required to achieve these policy expectations, Savills’ experience – both that of their development land team based in Wales and their environmental sustainability team based across England - is that in reality the cost associated with delivering these standards is in reality far higher and closer to the £15,000 or £20,000 per unit mark.
7.12. Taking the above together, not only is the approach proposed to be taken in Policy CC1 (Residential Operational Net Zero Carbon Development) out of line with the approach that is to be taken in England and the approach that has been taken in Wales, it is considered that there is insufficient certainty around the ability for these works to be delivered when they are required to be without harming viability.

Policy DNP3 (Glamorgan Heritage Coast)
8.1. This policy relates to the Glamorgan Heritage Coast, identifying a series of land uses that are permissible within the policy area before setting three tests that must be satisfied for development within the Glamorgan Heritage Coast to be permissible where there is an adverse environmental impact.
8.2. Hallam note that the ‘Land South of the B4265, St Athan’ portion of the land that they control is both proposed to be retained as part of the Glamorgan Heritage Coast (a continuation of the position taken in the adopted LDP) whilst also forming part of the Land to the West of St Athan Key Site where the masterplan at Figure 17 shows it as accommodating the potential new railway station and a mixed-use area (including car parking).
8.3. The relevant extract of the Proposals Map is replicated below:
8.4. The exact composition of the buildings proposed on this portion will require further refinement and will need to be driven by occupier requirements, but the masterplanning work undertaken by pad Design envisages that they could provide a mix of retail and food and drink uses most likely across some or all of the ground floor, alongside workshop, co-working or office incubator space at upper floor levels and perhaps at ground floor level. There could also be the potential for additional homes, likely in the form of apartments at upper floors, as part of a mix of uses. It is realistic therefore to anticipate that this portion of the site will accommodate buildings of up to three or four storeys with a high plot ratio to reflect the uses and supporting infrastructure that it is to accommodate.
8.5. Hallam’s position is that the continued inclusion of this parcel of land as part of the wider Glamorgan Heritage Coast is inappropriate for two reasons.
8.6. Firstly, and its most basic level, the approach of allocating the site for development whilst retaining a designation that inherently seeks to restrict the type, form, and quantum of development, is wholly contradictory.
8.7. Designation of this portion of the site as part of the Glamorgan Heritage Coast will mean, given that the uses that Figure 17 envisages as being delivered on the site are not those that the first part of Policy DNP3 (Glamorgan Heritage Coast) allows for, any application for development will need to demonstrate that there is a compelling need for the development, that the benefits outweigh the harm, and that appropriate mitigation measures are in place. This the potential to prejudice its development or, at very least, greatly impact how it is developed whilst requiring.
8.8. Secondly, it is difficult to see how this land warrants ongoing inclusion within the designated Glamorgan Heritage Coast. This is something that is considered in more detail in the Review of Landscape Character and Visual Amenity (December 2022) prepared by FPCR and submitted as part of the Call for Sites (and also available as part of the consultation on the Deposit RLDP as a piece of Key Site Supporting Information). Paragraph 5.13 of the FPCR document concludes on this piece of land that:
‘Through the fieldwork it is considered that the Site does not display any “special environmental qualities” identified by the Policy and plays no intrinsic role in the Policy designation, as it is effectively forms a rather ordinary grazing field. It is influenced by the urbanising elements of the adjacent B4265, the Railway Line, the Tarmac Cement works, and to some degree the built edge of St Athan. Furthermore, it is bound and contained by trees and woodland beside the railway line, which prevents wider intervisibility with the coastline.’
8.9. Taking the above together, Hallam suggest that the preparation of the RLDP provides the opportunity to define the extent of the Glamorgan Heritage Coast to respond to both the landscape value of certain sites but also the wider aspirations of the RLDP. If it is not within the gift of VoG to redefine the boundaries of the Glamorgan Heritage Coast through the RLDP then Hallam suggest that an additional element could be added to this policy to confirm that it does not apply to land which is allocated for development.

Appendix A - rewording of Policy HG1 KS5

It is strongly recommended that appropriate consideration is given to the widening of the Strategic Growth Areas to include St Nicholas as a sustainable settlement which is capable of accommodating a new allocation.

The Spinney, St Nicholas (Site Ref: 460)
Boyer have prepared the following representation on behalf of Mr Fairweather in response to the current Vale of Glamorgan Replacement Local Development Plan (RLDP) 2021-2036 Deposit Plan Consultation.

A summary of our main representations is as follows:
• Significant concern is raised regarding the lack of residential allocations within the Minor Rural Settlements, in particular St Nicholas.
• Concern regarding the overall housing requirement and the need for an increased flexibility allowance.
• Questions asked regarding the spatial distribution and the lack of other allocations to provide a range and choice of housing.
• Confirmation of the limited constraints for The Spinney, St Nicholas (Site Ref: 460).
• Review of the Candidate Site Assessment; and
• Need to review the Settlement Boundary of St Nicholas.

SP1: Sustainable Growth Strategy
Whilst Policy SP1 outlines the housing delivery requirement (addressed under the response to SP6), the main concern for Mr Fairweather is the proposed primary focus of housing growth within the Vale being within the Strategic Growth Area. Whilst it is understood and supported by Mr Fairweather that new housing developments would be concentrated in locations which are served by existing public transport routes and provide the opportunity to enhance sustainable transport connectivity, it is shortsighted to concentrate this growth specifically along the railway line. The justification being that those settlements identified as being ‘Outside of the Strategic Growth Area’ – including St Nicholas, are equally as important as those within. St Nicholas is a sustainable location and located on an important public transport route (A48) and is well served by bus transport.

The principle of locating development at sustainable settlement is supported, however Mr Fairweather considered that limiting development at suitable settlements outside the Strategic Growth Area is not the correct approach and that greater flexibility is required to deliver the housing need. Currently under Policies HG1 and HG4, the only allocations in any Minor Rural Settlements amount to 122 dwellings in total (excluding any from St Nicholas). This also needs to be considered in the context of the 1,303 dwellings expected from large and small windfall developments. Clearly there is a requirement to provide further allocations in sustainable Minor Rural settlements identified as being ‘Outside of the Strategic Growth Area’ – namely St Nicholas.

In context of above, Mr Fairweather strongly recommends that appropriate consideration is given to the widening of the Strategic Growth Areas to include St Nicholas as a sustainable settlement which is capable of accommodating a new allocation at The Spinney (Site Ref: 460).

SP2: Settlement Hierarchy
Mr Fairweather previously supported the identification of St Nicholas as a Minor Rural Settlement and acknowledged its capacity to accommodate proportionate and sustainable growth, particularly given its accessibility and relationship with Cardiff to the east and access to Bridgend to the West. The Deposit Plan retains St Nicholas within the Minor Rural Settlement tier, however, does confirm that the settlement is outside the Strategic Growth Area.

Whilst the overarching principle of directing growth to the most sustainable settlements is supported, the Plan does not clearly demonstrate why settlements that are well connected and functionally related to larger centres, such as St Nicholas, should be subject to such constrained growth.

In this context, Mr Fairweather highlights Paragraph 3.10 which indicates that Minor Rural Settlements provide an ‘important range of services and facilities that play a functional role in meeting some of the basic needs of residents within rural areas, reducing the need to travel’.
Building upon this, Policy SP2 does highlight that ‘Minor Rural Settlements identified will be limited to the efficient and sustainable use of existing buildings, infill opportunities, small-scale affordable housing led schemes, and rural enterprise/ agricultural related developments’.

Furthermore, the supporting text to Policy SP2 (Paragraph 6.17) confirms that ‘those settlements that are considered to have sufficient population, services, and facilities to accommodate small scale growth without it having a detrimental impact on their existing character and local environment’.

This all buildings upon the identified importance of Minor Rural Settlements within the Preferred Strategy which outlined in Paragraph 6.50 that it is ‘essential for the LDP to balance the growth in a way that supports the need of rural communities’ and whilst it is evident that within these settlements ‘general market housing will be limited to opportunities including infill’ (Paragraph 6.51), the enabling of an element of ‘open market housing will provide opportunities for the delivery of affordable housing reflecting the aspirations of rural communities to sustain their housing needs’ (Paragraph 6.51). This importance of Minor Rural Settlements needs to be carried more strongly forward in the Deposit Plan.

Moreover, the evidence base does not sufficiently justify the degree of restriction now applied, nor does it explain why proportionate additional growth in appropriate Minor Rural Settlements would undermine the spatial strategy. As drafted, the policy risks limiting flexibility in the distribution of housing across the Vale. Accordingly, it is considered that the approach to St Nicholas under Policy SP2 is not justified.

Clearly there continues to be a disconnect between the identified role and function of St Nicholas, which is supported, and the actual ability to deliver the appropriate range and choice of dwellings in the rural settlements. For example, The Spinney, St Nicholas (Site Ref: 460) is considered to naturally round-off the existing boundary, enclosing the envelope of development, without encroaching or sprawling beyond the existing line of built form, in a sustainable location which can accommodate an appropriate allocation.

SP6: Housing Requirement
As per Mr Fairweather’s previous comments to the Preferred Strategy, the concerns regarding a need for a higher housing level and the need for development to be appropriate placed in sustainable allocations in a settlement in which people want to live is still relevant.

Currently Policy SP6 establishes the overall housing requirement and applies a 10% flexibility allowance. The Policy suggests that to meet the identified housing requirement of 7,890 dwellings, provision will be made for the delivery of 8,660 homes and this will be delivered by:
• 3,837 dwellings from the existing land supply
• 3,520 dwellings on allocated sites
• 1,303 dwellings from large and small windfall developments

As per previous representations, Mr Fairweather considers that it’s important to take account of recent guidance provided to other Local Planning Authorities in Wales which have either adopted or are in the latter stages of bringing forward a new Local Development Plan. For example, in Bridgend the Council recently adopted their new Local Development Plan (covering the period 2018 to 2033) which is underpinned by a flexibility allowance of 14% equating to an additional 1,053 dwellings. This level of provision was required in order to demonstrate the Anticipated Annual Build Rate (AABR) were deliverable and ensure that the Plan remains effective in the event of changing circumstances. During the examination process the Inspector explained that an increase beyond the standard 10% was fundamental to enable the plan and its housing trajectory to be resilient and sufficiently adaptable. The overarching purpose of which is to account for any unforeseen changes and potential shortfalls/ delays to the strategic site allocations whilst still enabling the overall housing requirement to be delivered.
More recently in Swansea, the Council published their LDP2 Pre-Deposit Plan (Preferred Strategy) for consultation. In terms of housing delivery this incorporates a 20% flexible allowance above the proposed housing requirement and is predicated on the basis of needing to account for certain sites not coming forward as anticipated and other unforeseen factors affecting delivery.
Applying the same approach to other current Local Development Plans, it is evident that a flexible housing allowance above the current 10% threshold will be required. Having reviewed the Council’s evidence base Mr Fairweather considered that a minimum allowance of 15% would be reflective of the County’s growth aspirations and would seek an additional circa 400 dwellings (equating to a housing requirement of 9,074 dwellings inclusive of the 15% flexibility).

To accommodate this increased in flexibility allowance and over all housing numbers, it should be outlined that smaller sites typically deliver more quickly, are less infrastructure-dependent, and increase build-out rates through diversification. The Spinney represents precisely the type of deliverable site that should form part of an enhanced flexibility allowance.

Policy SP6 should therefore be amended to increase the flexibility margin to up to 15%, with consequential allocation of additional small and medium-sized sites.
HG1: Housing Allocations Table 3 spatial distribution
Mr Fairweather does not comment on any of the proposed housing allocations, however, does highlight that the delivery in incumbent upon a number of larger strategic sites, and that to allow a greater range and choice then smaller allocations in the Minor Rural Settlements. Only 161 units are proposed on smaller allocated sites, equating to approximately 7% of newly allocated supply.
In the context of the above, there remains significant concern that the spatial strategy continues to exclude allocations within Minor Rural Settlements, including St Nicholas.

The Plan recognises that Minor Rural Settlements provide an important range of services and facilities and play a functional role in meeting the needs of residents within rural areas. It further acknowledges that it is essential for the LDP to balance growth in a way that supports rural communities. Whilst general market housing is described as being limited to infill opportunities, the Plan also recognises that enabling an element of open market housing provides opportunities for the delivery of affordable housing and helps sustain rural communities.

There is therefore a clear disconnect between the identified role and function of settlements such as St Nicholas and the absence of any allocated sites (excluding the affordable led schemes under Policy HG4) capable of delivering an appropriate range and choice of dwellings. The strategy effectively restricts development to windfall and infill, without positively identifying opportunities that would logically consolidate and strengthen the settlement.

This approach is inconsistent with the settlement’s accessibility and functional role. St Nicholas is:
• Well connected to the A48 strategic highway network.
• Served by bus routes within close proximity to the site.
• Within commuting distance of Cardiff and Cowbridge.
• A sustainable and established residential community.

Land adjoining The Spinney, St Nicholas (Site Ref: 460) represents a contained and sustainable opportunity that naturally rounds off the existing settlement boundary. The site encloses the envelope of development without encroaching into open countryside or extending beyond the established line of built form. It is well related to existing services and infrastructure and is capable of accommodating a modest allocation consistent with the scale and character of the village.

A proportionate allocation at this location would align with the stated objectives of supporting rural communities, enabling a mix of market and affordable housing, and providing genuine choice within Minor Rural Settlements. The continued absence of such allocations undermines the internal consistency of the spatial strategy.
Furthermore, the strategy places substantial emphasis on rail-based corridors. Whilst development near rail infrastructure is supported in principle, sustainable growth should not be exclusively rail-led. Strategic highway connectivity and bus accessibility also represent legitimate and sustainable locational advantages.

The complete absence of allocations in Minor Rural Settlements creates an imbalance in distribution and limits housing choice. A modest allocation at The Spinney would represent proportionate growth consistent with the scale and character of the settlement.
HG4 – Affordable Housing Allocations

It is recognised that Policy HG4 does allocate development within some Minor Rural Settlements, but in the context of them being affordable housing led sites where there will be a requirement for the provision of a minimum 50% affordable housing to meet the affordable housing needs of the local community. Mr Fairweather has no objection in principle to this but does object to the fact that there is no development in St Nicholas (despite it being sustainably located on the A48).

Furthermore, The Spinney, St Nicholas (Site Ref: 460) proposes a 40% affordable housing provision which accords with Policy SP8 of the Deposit Plan. Should the Authority consider that the site is suitable for allocation under Policy HG4 then the provision can be amended to 50% to accord with the policy.

Candidate Site Response: The Spinney, St Nicholas (Site Ref: 460)
From a review of the Background Paper (BP18 a) - Candidate Site Assessment at Preferred Strategy Stage, we are aware that the candidate site The Spinney, St Nicholas (Site Ref: 460) has not progressed beyond Stage 2: Detailed Site Assessment: Site Characteristics and Physical Constraints.

The justification provided states that ‘The development would have an adverse impact on the character and setting of the St Nicholas Conservation Area’. Whilst this is disputed and it is considered that the site should have progressed, it is important to highlight that of all the Candidate Sites within St Nicholas, The Spinney has the least issues raised.

Other sites within the assessment raised concerns regarding Best and Most Versatile Land, intrusion into the open countryside and the loss of a sites identified as providing important views. Ultimately, Site Ref: 460, is clearly the most appropriate site for any development within St Nicholas and with limited constraints raised.
Turning to the reasons for not taking the site forward, the following is reiterated in the context of the impact on the character and setting of the Conservation Area.

Conservation Area Impact
St Nicholas is described in the Conservation Area Appraisal and Management Plan as ‘a low density, linear village located on the A48’ and the candidate site is located towards the west of the village and lies partially within the current Conservation Area boundary. The Authority will be aware that the Conservation Area has been amended over the years to its current illogical designation regarding the Paddock area, similar to that of the Settlement Boundary.

The development of the Candidate Site is a clearly a logical and sensible infill development, which would have limited impact upon the Conservation Area. The majority of the site is already hidden from the A48 via mature vegetation and existing boundary features, and any proposed development would maintain this approach and minimise the visual appearance on the Conservation Area.
Listed buildings and other historic buildings of special interest are identified in the Conservation Area Appraisal as ‘County Treasures’. These are situated at the heart of the Conservation Area. The buildings and their settings establish a scale and density for the historic area of the village to the south of St Nicholas’ Church.

More modern development, away from the centre of the village at Ger-y-Llan to the northeast, Dyffryn Close to the southeast and Old Rectory Drive to the west are suburban in character with larger houses and generous gardens. These are all excluded from the Conservation Area and represent development at a lower density than the historic core of the village.

Whilst only a part of the Candidate Site is located within the Conservation Area, it has to be seen in the context of an appropriate infill site that links the southern part of the village with the more modern suburban type of development at Old Rectory Drive to the west. More significantly, the site provides an opportunity for a development to make a positive contribution to the character and appearance of the Conservation Area as well as respect or enhance the special architectural or historic interest.

This can be achieved by providing a new front boundary to the site and houses with gardens, of the type identified in the Conservation Area Appraisal and Management Plan that help define the character of the village. Whilst the Candidate Site extends to the A48, this is to allow the appropriate minimal access junction, whilst the majority of the generous grass verge will be retained, meaning that development will be clearly set back a considerable distance from the road and the opposite pavement.

Thus, the development will be totally screened when travelling along the A48 and is therefore not considered to affect the views to the north of the site. The development will complement and enhance the character of the rural and built environment surrounding the site.
In line with the objectives of the St Nicholas Conservation Appraisal and Management Plan, the boundary treatments proposed will be sympathetic and in keeping with the surrounding area, such that they do not detract from the historic assets and desired lines of view. Again, whilst detailed design has not yet been progressed, any boundary treatments proposed will avoid the use of stained close boarded timber fencing, over-elaborate modern metal railings and gates. It is reiterated that the building line for the front of the development will not encroach any further forward that the existing boundary and will be designed to be innkeeping and not detract from the existing character of the Conservation Area. Moreover, the layout of the site has been designed in such a way that the spaciousness and green infrastructure is retained and enhanced from a redundant Paddock.

Furthermore, the characteristics that give the Conservation Area its special interest, as identified in the Conservation Area Appraisal and Management Plan have been used as references for the design of the illustrative site layout.

The proposal is to use local materials and design details designed to preserve or enhance the special interest of the Conservation Area. Limestone laid as rubble external walling, slate roofs and roadside walls of varying sizes predominate. More modern houses in the area are rendered and painted white. This, according to the Conservation Area Appraisal gives ‘some cohesiveness [to the area] despite their modern details’.

Elsewhere in the appraisal the village is described as having a ‘rural character’, a character that is reinforced by the existence of mature trees, singularly or in groups and simple pavements with narrow stone curves. The use of modern railings or timber fences are considered to be detrimental to the historic character of the conservation area.

Given the sites relationship with the Conservation Area, the proposal has been designed in to ensure that the development endeavours to protect, preserve and enhance the character of the area.

The site layout has been designed to avoid having the appearance of a suburban estate by providing a range of house types on plots that vary in size thereby maintaining the open structure of the conservation area as described. Furthermore, the existing boundaries to the east and west, which are subject to TPOs, will be retained and enhanced and not detract from the character of the Conservation Area.

The site marks a transition point between the western end of the linear historic core of the village and the lower density development at Old Rectory Drive.
The landscape proposals have been designed to include sustainable drainage, and the tree planting reflects the isolated trees or groups of trees referred to in the Conservation Area Appraisal as significant areas of character.

The illustrative site layout represents an appropriate scale of development and an efficient use of land and as such the proposed development will not have any detrimental impact upon the Conservation Area.
Deposit Plan Amendments
Settlement Boundary

Given the above and the further assessment below, the strong preference would be for the site to be allocated for residential development within St Nicholas. This would form a logical amendment to the Settlement Boundary to include the western parcel (former Paddock) of Candidate Site - The Spinney, St Nicholas (Site Ref: 460). The current Settlement Boundary is illogical as the site is surrounded by development on 3 boundaries and the simple rounding off along the southern boundary would allow for an appropriate windfall infill development.
Conservation Area

Given the above then it is considered that the Conservation Area boundary would need to be amended to reflect the allocation of the site.
These amendments would be required to the Deposit Proposals Map.

Site Assessment
The site was promoted through the Candidate Site process and assessed at Preferred Strategy stage. However, it is not allocated within the Deposit Plan and thus was not subject to updated reassessment as part of this stage of plan preparation.

For completeness, and in order to clearly demonstrate the limited and proportionate nature of the site’s constraints, the previous site assessment summary table is reproduced below. This is included to highlight that the site performs favourably in sustainability and deliverability terms, and that the matters previously cited as constraints are capable of mitigation through design.

A table comparing an updated site assessment prepared by Boyer against the Council’s assessment has been provided.

This representation, submitted on behalf of Mr Fairweather in response to the current Vale of Glamorgan Council Replacement Local Development Plan (RLDP) 2021–2036 Deposit Plan Consultation, maintains that Land adjoining The Spinney, St Nicholas (Site Ref: 460) represents a logical, sustainable and deliverable parcel that should be allocated as a suitable and viable residential site within the RLDP.

Significant concern remains regarding the absence of residential allocations within Minor Rural Settlements, particularly St Nicholas, and the continued reliance on a limited flexibility allowance under Policy HG1. An increased flexibility margin of up to 15% would necessitate the identification of additional sustainable and deliverable sites. Such growth should be directed, in part, toward appropriate locations within Minor Rural Settlements to ensure a genuine range and choice of housing and to support rural community sustainability.

It is further noted that the site performs favourably in the Council’s Candidate Site Assessment, with limited constraints identified. The matters previously raised, including Conservation Area considerations, are capable of sensitive mitigation through design and have been subject to detailed review. There is no substantive evidence demonstrating that the site is unsuitable for development.

Accordingly, the site is considered to represent a suitable, available and achievable allocation capable of contributing to the housing requirement, supporting affordable housing delivery, and reinforcing the spatial objectives of the Plan.
The Deposit Plan should therefore be amended to allocate Land adjoining The Spinney, St Nicholas (Site Ref: 460), or alternatively identify it as a reserve or flexibility site, in order to ensure the Plan is justified, effective and deliverable.

I advocate for a broader search beyond Barry and recognise Sully’s role within the Strategic Growth Area. Growth should be allocated to the most suitable, sustainable locations, not solely within Barry.

1. Introduction

1.1.1 Savills is instructed by Taylor Wimpey PLC (‘Taylor Wimpey’) to respond to the consultation on the Deposit Plan as part of the preparation of the Replacement Local Development Plan (‘RLDP’) by the Vale of Glamorgan Council (‘VoG’).

1.1.2 The submission is made in the context of Taylor Wimpey’s position as the promoter of Site ID 376 (Land West of Swanbridge Road, Phase 3). The site is being promoted for a residential development comprising of 260 homes.

1.1.3 Taylor Wimpey is one of the UK’s leading national housebuilders, with extensive experience in delivering high-quality residential developments across a wide range of local authority areas. The company has an established presence within the VoG area. Taylor Wimpey is in the process of delivering Phase 1 of the site with development of Phase 2 close to commencing to dovetail with the completion of Phase 1. Phase 3 would act as a logical extension to the site, effectively rounding off development in this part of Sully and dovetailing with Phase 2 which is anticipated to be completed in 2029.

1.1.4 The site was originally submitted as a candidate site as part of the Call for Candidate Sites stage in September 2022 by Taylor Wimpey. This was a comprehensive site submission demonstrating that the site was viable, deliverable and sustainable – the three tests for Candidate Sites to satisfy as set out in Paragraph 3.36 of the Development Plans Manual. The Candidate Site submission consisted of the following information:

• Archaeological Desk-based Assessment (prepared by RPS);
• Design Vision (prepared by Pegasus Group);
• Drainage Strategy & Flood Risk Assessment (prepared by Pheonix Design);
• Landscape Appraisal (prepared by Pegasus Group);
• Preliminary Ecological Appraisal (prepared by Soltys Brewster);
• High Level Viability Statement (prepared by Savills);
• Transport Technical Note (prepared by Vectos); and
• Supporting Statement (prepared by Savills).

1.1.5 Since then, and on behalf of Taylor Wimpey , Savills have also responded to the consultation on the Preferred Strategy in February 2024 as well as the Housing Growth in Barry consultation in July 2025 and the Housing Trajectory in October 2025.

1.1.6 This supporting statement is structured to initially comment on the approach taken by the VoG in assessing the Land West of Swanbridge Road, Phase 3 site before commenting on specific policies that are contained within the Deposit RLDP.

1.1.7 In general, Taylor Wimpey’s position is that, at present, the Deposit RLDP is not sound but that it could be made sound through the amendments as suggested throughout this Statement.

2. Candidate Site Assessment Process and Integrated Sustainability Assessment
Introduction

2.1.1 Candidate sites are in essence assessed through two means – the Candidate Site Assessment Background Papers and the Integrated Sustainability Appraisal.

2.1.2 Taylor Wimpey’s position is that both of these documents do not provide an adequate assessment of the Land West of Swanbridge Road, Phase 3 site.

2.1.3 Each is considered in turn below.

Candidate Site Assessment Process

2.1.4 All candidate sites have been assessed at Preferred Strategy stage (reported as Background Paper 18) and Deposit stage (reported as Background Paper 18a).

2.1.5 The reason for the Land West of Swanbridge Road (Phase 3), Sully (Ref. 376) site not being carried forward as part of these assessments was presented in Background Paper 18 at the time of publication of the Preferred Strategy with Backgropund Paper 18a providing no further site analysis. The reason for the site not progressing this stage of the Candidate Site assessment process is as follows:

“Development of the site would lead to a loss of the Best and Most Versatile Grade 3a agricultural land contrary to national policy.”

2.1.6 Whilst parts of the site do constitute Best and Most Versatile (BMV) land, Taylor Wimpey’s position is that there are compelling reasons relating to the site’s context and how it is utilised that mean a more nuanced position needs to be taken. Without such nuance, the RLDP risks not allocating a site that, whilst perhaps containing BMV, is otherwise suitable for development and more suitable for development then sites that the Deposit RLDP proposes to instead allocate.

2.1.7 Included at Appendix A, and included as part of Taylor Wimpey’s representations on the Preferred Strategy and the Housing Growth in Barry consultations, is an Agricultural Assessment prepared by The Andersons Centre.

2.1.8 The key conclusions from this Assessment are that:

• The site is farmed by a tenant farmer whose main base is approximately 12km away which presents logistical and practical challenges. These challenges are exacerbated by the lack of farm buildings and the fact that there is no mains electricity;

• The site forms part of a wider 230 acre farm and so the cessation of agricultural practices on this parcel will not, by virtue of its size, prejudice the continued farming of the wider land parcel;

• The tenant farmer farms approximately 3,000 acres of land and so the loss of the ability to farm this parcel will have a negligible impact on the continuation of their agricultural operations;

• The site is bound on two sides by existing or permitted housing, on a third boundary by a railway line, and on its eastern boundary by a road; and

• Farming of the land does not support a high level of employment and if the land was lost for development, 0.15 of a full time labour unit’s equivalent work would be lost.

2.1.9 Taking the above together, the conclusion needs to be reached that the site’s size and context presents challenges for farming and that the development of Phase 2 by Taylor Wimpey has the potential to exacerbate these challenges. Aligned to this, the level of employment that the farming of the site supports is negligible and the cessation of farming of this particular parcel of land will not materially impact either the continued farming operations of the wider farm that the land sits apart of or the tenant farmer that farms the land.

Integrated Sustainability Appraisal

2.1.10 The Initial Integrated Sustainability Appraisal undertaken at Preferred Strategy stage provides a GIS based appraisal of all sites against 17 objectives. Inherently the Initial Integrated Sustainability Appraisal can be a bit of a blunt tool but Taylor Wimpey’s position is that the site performs better against a substantial number of the 17 objectives than the current assessment.

2.1.11 Included at Appendix B is an assessment undertaken by Taylor Wimpey which provides commentary against certain objectives and suggests why the site performs considerably better than forecast in the Initial Integrated Sustainability Appraisal.

2.1.12 A summary of this is presented below:
Table 1 Summary of ISA and Suggested Taylor Wimpey Approach

2.1.13 Taylor Wimpey’s position here is clear – the inadequacy of the Integrated Sustainability Appraisal as a tool for assessing candidate sites can only be appropriate where the Integrated Sustainability Appraisal is done correctly and considers the mitigation measures that a candidate site submission proposed to put in place. Without this, the Integrated Sustainability Appraisal risks a situation – as Taylor Wimpey suggest has been the case in Policy HG1 KS1 – where a Key Site is selected in favour of alternative sites that are better performing.

3. Deposit Plan

3.1 Introduction

3.1.1 The following section of this Statement comments on the relevant Key Themes, Strategic Objectives and draft Policy Framework forming part of the Deposit Plan Consultation.

3.1.2 The Policy Framework has been reviewed with comments provided on only those policies considered to be of most relevance to Land West of Swanbridge Road (Phase 3), Sully. The position on individual policies contained within the Deposit RLDP are summarised in the table below:

Table 2 Taylor Wimpey Policy Position

Relevant Policy Support or Object
SP1 Sustainable Growth Strategy - Object
SP2 Settlement Hierarchy - Support
SP 6 Housing Requirement - Object
HG1 Housing Allocations: HG1 KS1 – Land at North West Barry - Object
TR1 Transport Proposals: TR1(2) Active Travel Route Sully to Cosmeston - Support
TR1 Transport Proposals: TR1(6) Highway Improvement Works Weycock Cross Roundabout - Object
CC1 Residential Operational Net Zero Carbon Development - Object
CI1 Open Space Provision - Clarity required
DNP5 Environmental Protection - Object as currently worded

3.2 Key Themes and Strategic Objectives

Homes For All

3.2.1 As noted in paragraphs 3.17 and 3.18 of the Deposit Plan the VoG has the highest affordability ratio in Wales with average house prices 9.7 times the average workplace earnings compared to the Welsh average, giving rise to a significant need for affordable homes which is under significant pressure. This highlights the ever increasing need for sufficient high quality housing, which Taylor Wimpey are committed to provide and supply the mix, type and tenure of housing needed within the local authority’s growing population.

Placemaking

3.2.2 Taylor Wimpey embed strong placemaking standards across their developments as detailed within their Placemaking Charter. Taylor Wimpey consider Land West of Swanbridge Road (Phase 3) to present an opportunity to provide a comprehensive residential development that is accessible and well-connected with the existing settlement of Sully and compliments the earlier phases of development. As demonstrated in the earlier phases of development, the Site offers a sustainable location for future growth with easy access to a range of services and facilities in Sully.

Protecting and Enhancing the Natural Environment

3.2.3 Taylor Wimpey support the VoG’s commitment to protect and enhance the natural environment through the integration of green/blue infrastructure network and the sustainable management of resources within the VoG. However where Objective 5 seeks to safeguard land from inappropriate development, proposals must be subject to the relevant planning balance giving weight to the surrounding land use and appropriateness of safeguarding agricultural land that would otherwise be unconstrained and considered suitable for development given the outstanding need for housing.

Promoting Active and Sustainable Travel Choices

3.2.4 Taylor Wimpey support the promotion of sustainable travel and active modes of transport, including the provision of designated active travel routes that improve the connectivity between primary and key settlements, such as the Sully to Cosmeston active travel route.

3.2.5 As demonstrated in the earlier phases of Land West of Swanbridge Road, Taylor Wimpey support the promotion of active travel within new developments and provide opportunities for residents to easily engage with active travel.

3.3 Policy Framework

Policy SP1 Sustainable Growth Strategy

3.3.1 Taylor Wimpey’s comments on this policy relate to the sustainable growth strategy in so much as it relates to the spatial strategy rather than the housing requirement that the RLDP adopts with further comments on the housing requirement provided in connection to Policy SP6 (Housing Requirement).

3.3.2 Taylor Wimpey appreciate the need to balance the ten strategic objectives against the need for growth and protection of the VoG’s natural and built environment, and strongly support the strategic objective to provide homes for all. Taylor Wimpey maintain their position on the proposed growth strategy that has been established within earlier consultation responses submitted throughout the RLDP process, including the most recent consultation on ‘Growth Options in Barry’.

3.3.3 Taylor Wimpey consider that to date the growth strategy has placed disproportionate emphasis on identifying an alternative site within Barry, rather than giving due consideration to potential sites in nearby high‑performing settlements such as Sully. Taylor Wimpey therefore strongly encourage the VoG to widen the search for additional allocations beyond the administrative boundary of Barry Town Council and to consider locations that represent a logical and sustainable extension to neighbouring primary settlements that are located within the Strategic Growth Area, including Sully.

3.3.4 The six key elements of the Sustainable Growth Strategy are noted and Taylor Wimpey support a spatial strategy that locates major new development for the delivery of sustainable housing growth in appropriate locations, such as Sully, that are supported by the relevant infrastructure, services and facilities. Providing new homes within Phase 3 aligns with the Strategic Growth Area identified within the RLDP Strategy which forms the primary focus for housing growth.

3.3.5 Policy SPG1 continues to identify Sully as a location where new housing development will be concentrated, therefore establishing a principle of development for Phase 3 and help to further align the provision of new housing with the existing facilities of Sully, reducing the need to travel. Sully represents an inherently sustainable location for future growth and aligns well with the Sustainable Transport Oriented Growth Option. As identified in the Deposit RLDP, Sully is classified as a Primary Settlement and performs a complementary role to Barry as a key centre. Its position within the Strategic Growth Area further indicates that an appropriate level of development at Sully would be acceptable, with both existing housing delivery and the current allocation at Swanbridge Road supporting its established role.
3.3.6 With existing development ongoing to the north of the Site, at Phases 1 and 2 of Land West of Swanbridge Road, Phase 3 is considered to provide an appropriate level of growth in a sustainable location that would form a logical extension to existing allocations. The sustainability and suitability of Sully to accommodate residential development is reinforced by the allocation of 500 dwellings under Policy MG2(37) (‘Land West of Swanbridge Road, Sully’) on land directly north of the site promoted by Taylor Wimpey. The progression of this location into a phase 3 development would continue to strengthen Sully’s function as a primary settlement and would constitute a logical and coherent extension to the existing built form.

Figure 1 Extract of Growth Strategy

3.3.7 Taylor Wimpey appreciate the aspirations of the Council to deliver housing to meet the identified future housing needs of the VoG and wider growth aspirations of the South East Wales Region at a strategic level. Taylor Wimpey support the revised strategy moving away from North East Barry, however maintain the position that this level of growth should be re-allocated to those locations that are most suitable for growth, including sustainable settlements outside of Barry. Growth should not be focuses solely on Barry.

Policy SP2 Settlement Hierarchy

3.3.8 Taylor Wimpey support the conclusions of the Settlement Appraisal Review Background Paper which identifies Sully as a Primary Settlement, reflecting its important role in providing a level of housing growth, in addition to key local services and facilities. Within this Background Paper, Sully is recognised for its vital role as a sustainable community, scoring highly across all key principles in demonstrating its sustainability by providing for the day-to-day needs of its residents. Taylor Wimpey concur with the supporting evidence which reinforces Sully’s importance within the settlement hierarchy.

3.3.9 Whilst Draft Policy SP2 presents a ‘broad distribution of development within the Strategic Growth Area..’, serious concerns continue to be raised around the level of growth around Barry and the emphasis placed on it as the focus for future development. Taylor Wimpey do not dispute the identification of Barry as a Key Settlement, given its position as the largest town within the VoG, however believe Barry should not remain the sole focus for growth where there are opportunities available around primary settlements located within the Strategic Growth Area.

3.3.10 Put another way, it seems perverse for the Deposit RLDP to direct no new growth to a Primary Settlement within the identified Strategic Growth Area.

Policy SP 6 Housing Requirement

3.3.11 The purpose of this policy is to set the housing requirement and then identify the components of supply that are anticipated to meet this housing requirement. A number of Background Papers (nos. BP7, BP8, BP8A, ad BP9A) underpin the approach that is taken. Taylor Wimpey have a number of comments to make on the approach taken in this policy.

Housing Requirement

3.3.12 The approach taken in the Deposit RLDP, as with the Preferred Strategy beforehand, is for the housing requirement to make use of a 10 year dwelling-led scenario, an approach that reflects past completions and looks to extrapolate this forward over the lifetime of the RLDP.

3.3.13 Taylor Wimpey provided detailed commentary on the proposed housing requirement in their comments on the Preferred Strategy but note that Welsh Government have subsequently provided their comments on the Preferred Strategy raising no objection with the housing requirement proposed to be taken.

3.3.14 Taylor Wimpey’s position though remains – if a dwelling-led scenario is to be used to determine the housing requirement then it needs to have a far shorter scenario length then 10 years as the first three years of the 10 year period selected were when supply was suppressed as a result of the current LDP not having been adopted.

3.3.15 That said, there is a clear contextual change since the Preferred Strategy was adopted, this being the publication of the 2022-based household projections have been published. Table 5 of Background Paper 8A Supplementary Demographic Evidence – 2022-based WG Projections provides a comparison of the 2022-based projections with the 2018-based projections and the Deposit RLDP’s housing requirement. A simplified version of this table is shown overleaf:

Table 3 RLDP Housing Requirement
Scenario Housing Requirement
RLDP 7,587
2018-based projections 6,214
2022-based projections 9,623

3.3.16 This is important as Paragraph 4.2.6 of PWW states that:

‘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.’

3.3.17 The proposed approach of continuing to use the 10 year dwelling-led scenario, as a methodology, clearly does not do this.

3.3.18 The approach of using the 2022-based household projections would comply with the aspirations of PPW. Taylor Wimpey’s position is that the commentary provided in the Background Paper 8A Supplementary Demographic Evidence – 2022-based WG Projections for not using 2022-based projections is wholly inadequate and that these projections should be used.

Flexibility Allowance

3.3.19 Paragraph 5.58 of Edition 3 the Development Plans Manual (March 2020) makes it clear that there is a requirement for a flexibility allowance to be added on top of the housing requirement to derive the number of homes the RLDP should plan for. This is in the interest of ensuring that sufficient housing is delivered in the event of some allocated sites either not delivering in their entirety or delivering less homes than anticipated. Paragraph 5.59 of the Manual clarifies that the extent of the flexibility allowance should be informed by local issues with 10% as a starting point (i.e. as the minimum).

3.3.20 The Adopted Local Development Plan (ALDP) applies a 10% flexibility allowance on top of the housing requirement for 9,460 homes so that provision is made for 10,408 homes.

3.3.21 Paragraph 1.2.34 of the Annual Monitoring Report 2024-2025 provides a comparison of the number of homes that have been completed and the level of completions that the ALDP anticipates. This shows that 6,999 homes have been delivered up to 1st April 2025 against a cumulative dwelling target of 8,829 homes, representing a shortfall of 20.7%.

3.3.22 Taylor Wimpey’s point here is that the ALDP’s flexibility allowance of 10% is insufficient to ensure that the ALDP’s housing requirement is actually being delivered. This is clear evidence that a higher flexibility allowance should be used for the RLDP. Although for different reasons, but following a direction from the Welsh Government Planning Inspector, Bridgend County Borough Council has increased its flexibility allowance to 20% and, it is considered that such a buffer is appropriate for the VoG’s RLDP.

Non-Delivery Allowance on Land Bank

3.3.23 Line C of Table 2 of the Preferred Strategy relates to those sites that either benefit from planning permission or are subject to a resolution to grant planning permission subject to planning permission. Combined, these sites are identified as having capacity for 1,860 homes.

3.3.24 The current approach, which assumes that all other sites which are under construction or sites where there is either a planning permission in place or sites where there is a resolution to grant planning permission subject to the signing of a Section 106 agreement will be completed in full, causes concern for Taylor Wimpey.

3.3.25 There are multiple reasons why homes that benefit from either planning permission or a resolution to grant planning may not be delivered. These relate to viability, but also to specific site constraints and landowner intentions.

3.3.26 A point that is separate, but inherently linked, to the above is that often the capacity of a site for which reserved matters approval is sought is less than that permitted at outline stage. Requirements for SAB approval and the demonstration of a biodiversity net benefit, for example, reduce the capacity of a site at detailed design stage but are often not factored in at outline stage, particularly where the outline application is not progressed by a housebuilder.

3.3.27 Research undertaken by the Local Government Association for England (no such data is available for Wales) suggests that, between 2010/2011 and 2019/2020 a total of 2,782,300 dwelling were granted planning permission whilst there were only 1,627,730 completions. This means that during this period just 58.5% of those homes which were granted planning permission were completed.

3.3.28 Taylor Wimpey is not suggesting that applying a discount of 41.5% is necessarily correct and the above is both from England and a few years out of date but the need for a discount that relates specifically to Line C is very clear.

3.3.29 It’s difficult to know what this figure should be but Taylor Wimpey suggest that a 20% figure is used to reflect the flexibility allowance.

Windfall Allowances

3.3.30 The approach taken in the Deposit RLDP is to assume that 1,303 homes will be delivered across Windfall Sites. This has been calculated on the basis of previous completion delivered as windfalls.

3.3.31 Taylor Wimpey’s concern is that the delivery of homes on Windfall Sites inherently becomes more challenging over time as the easier to develop sites have been delivered and the buildings and land that hasn’t been developed is subject to increasing levels of policy protection. The approach taken by Cardiff Council in their Deposit RLDP is to assume that 75% of the 10 year average Windfall Sites will be delivered and such an approach seems entirely appropriate in this case.

3.3.32 An Urban Capacity Study (October 2023) prepared by the VoG, seeks to corroborate this by identifying 2,627 homes that could be delivered across the VoG. Whilst the windfall allowances would be less than the suggested urban capacity, this shouldn’t be seen as problematic or as a conflict as the purpose of the Urban Capacity Study is, as the name suggests, just to identify sites which may have capacity. It doesn’t account for land ownership (and whether the land owners have aspirations to dispose of the site) or development viability. In addition, the approach taken to site capacity to is to assume a density based on site type but it does this without an appreciation of site constraints and is based on the gross rather than net area.

Rolled Forward Sites

3.3.33 Taylor Wimpey have concerns with the approach that is taken in Table 2 of the Deposit RLDP which identifies allocations for 959 homes that are to be rolled over from the ALDP to the RLDP.

3.3.34 Concerns are raised around two sites in particular - Land to the west of Pencoedtre Lane, Barry and Land between new Northern Access Road and Eglwys Brewis Road, These sites are allocated in the ALDP but have failed to be delivered. Given the longstanding period during which there has been clear policy support for development but no completions, it follows that there are serious concerns around the deliverability of these two sites which, together, are allocated for 370 homes.

3.3.35 The failure to deliver these dwellings is due to a number of factors which are detailed in Taylor Wimpey’s Preferred Strategy consultation response, which questions whether these sites will deliver at all or at a significantly reduced capacity due to the following reasons:

▪ Viability constraints;
▪ Site specific constraints;
▪ Landowner intentions;
▪ Requirements for SAB approval; and
▪ Biodiversity net benefit;

3.3.36 Whilst it is recognised that there may be policy support for the delivery of these two sites, there deliverability is clearly uncertain and they should be removed from Table 2.

Conclusion

3.3.37 The following table summarises the approach previously proposed in the Deposit RLDP and compares it to the amendments suggested by Taylor Wimpey in the preceding sections of this Statement.

Table 4 Deposit RLDP Housing Supply and Taylor Wimpey’s Suggested Approach
Housing Supply - Deposit Plan (December 2025) - Taylor Wimpey Suggested Approach (March 2026)
Housing Requirement - 7,890 - 9,623
Flexibility Allowance - 10% - 20%
Flexibility Allowance – 770 - 1,925
Housing Requirement + Flexibility Allowance - 8,660 - 11,548
A – Completions - 1,747 - 1,747
B – Units Under Construction - 313 - 313
C and D- Units with Planning Permission Minus Non-Delivery Allowance - 1,777 1,488
Existing Supply - 3,827 - 3,548
E – Large Windfall Sites - 720 - 540
F – Small Windfall Sites - 583 - 438
E+ F Total Windfall Allowance - 1,303 - 978
RLDP Allocations - 3,520 - 3,150

3.3.38 The conclusion reached in Taylor Wimpey’s analysis is that, as a result of both the suggested housing requirement and flexibility allowance combined with Taylor Wimpey’s comments on the components of supply, the Deposit RLDP needs to find allocations to deliver a further 3,872 homes.

Policy HG1 KS1 – Land at North West Barry
3.3.39 Policy HG1 (Housing Allocations) identifies those sites that are to be allocated to meet the housing requirement of 7,890 homes that is set out in Policy SP1 (Sustainable Growth Strategy) and Policy SP6 (Housing Requirement) of the RLDP. Taylor Wimpey has provided comments on the housing requirement that is set in the RLDP and the components of supply that are anticipated to meet it in the proceeding sections of this Statement.

3.3.40 As well as the existing landbank and an allowance for windfalls, Policy HG1 notes that this requirement will be met through a mix of Key Sites, conventional housing allocations, housing-led regeneration opportunities, and rural affordable housing led sites.

3.3.41 There is a standalone separate policy for each of the five Key Sites that are identified in Policy HG1 (Housing Allocations). Each separate Key Site policy identifies what the site is proposed to be allocated for before providing setting out expectations of how each Key Site should come forward – both in terms of land uses that should be delivered and constraints and opportunities needing to be responded to – that are framed under a series of sub-headings. A masterplan sits alongside each Key Site policy whilst a package of supporting documentation for each Key Site submitted by the site promoter is also made available as part of the consultation on the Deposit RLDP.

3.3.42 Policy HG1 KS1 proposes to allocate the site known as ‘Land at North West Barry’.

3.3.43 The proposed allocation of this site follows a consultation – entitled ‘Housing Growth in Barry’ - undertaken by the VoG in July 2025 which proposed to allocate three sites in Barry as an alternative to the North East Barry site that was identified as a Key Site in the Preferred Strategy but was considered to no longer be deliverable.

3.3.44 Taylor Wimpey responded as part of the ‘Housing Growth in Barry’ consultation, supporting the removal of North East Barry as a Key Site but raising serious concerns with the proposed allocation of ‘Land at North West Barry’ as an alternative.
3.3.45 These concerns remain and Taylor Wimpey strongly consider there need to be other alternative sites – such as Land West of Swanbridge Road (Phase 3), Sully (Ref. 376) - within nearby settlements that perform better than the Land at North West Barry site and should be allocated for housing.
3.3.46 To support this conclusion, Taylor Wimpey has undertaken a review of the Integrated Sustainability Appraisal (ISA) which provides a scoring of different candidate sites against the 17 objectives as well as considering and comparing the sustainability and accessibility of the two sites.

Integrated Sustainability Appraisal

3.3.47 The below table provides a comparison of how the Integrated Sustainability Appraisal scores Land West of Swanbridge Road (Phase 3), Sully (Ref. 376) compared to the Land at North West Barry site. Two different comparisons are provided – one which compares the actual scoring in the ISA and a second which compares the two sites following Taylor Wimpey’s suggested scoring which is included as Appendix A.

3.3.48 These tables clearly highlight where the subject site out performs North West Barry across numerous objectives.

Table 5 Comparison of Phase 3 Land West of Swanbridge Road (Site ID 376) and North West Barry (Site ID 490) ISA performance

3.3.49 From an initial review, the Integrated Sustainability Appraisal shows that Land West of Swanbridge significantly outperforms North West Barry in terms of the number of significantly positive scores ‘++’ and the number of ‘—’ scores. To this end the subject site provides clear advantages above and beyond North West Barry in terms of homes, health, and transport. As such Land West of Swanbridge is considered to have the capacity to deliver a significant number of new homes (≥ 100 dwellings) and it does not intersect with a designated green wedge; The site is within 800m of a health service and an active travel route; and, The site is within close proximity (≤800m) to a railway station or bus stop, town/ retail centre and an active travel route. Taylor Wimpey consider this assessment should go further to recognise the associated benefits to the leisure than be provided by the site’s development.

3.3.50 Following Taylor Wimpey’s re-assessment of the site against the Integrated Sustainability Appraisal ISA objectives it is also considered to obtain notably more positive ‘+’ scores than North West Barry. It is also worth noting that North West Barry has more unknown impacts than Land West of Swanbridge which introduces a level of uncertainty around its potential for further negative impacts. Moreover, North West Barry scores a significant number of negative impacts across the ISA, with the extension site obtaining double the amount than Land West of Swanbridge Road.

3.3.51 Taylor Wimpey’s position is that it would be unsound to allocate a site that performs considerably poorer in the Integrated Sustainability Appraisal than a site that is not proposed to be allocated.

Accessibility and Sustainability

3.3.52 SLR Consulting have prepared an updated document demonstrating the Site’s sustainability credentials and providing a detailed overview of existing and future active travel and public transport infrastructure. This is included as Appendix C.

3.3.53 As a starting point, it considers those services within Sully. In terms of local amenities, the population size of Sully, naturally benefits from a good range of local amenities and services, and therefore it is anticipated that a high proportion of future residents’ day-to-day journeys would be contained within the village and undertaken via walking or cycling. The Walking Catchment Map prepared by SLR demonstrates this and illustrates services within walking distance from the Site.

3.3.54 The proposed development benefits from local existing and future / planned infrastructure which will help support travel by sustainable modes such as walking, cycling and public transport. The Site falls within the less than 15 minutes Public Transport Catchment for bus and rail services. The Site is supported by the existing bus network, connecting Sully with Barry, Penarth and Cardiff – the nearest bus stop approximately 400m from the centre of the site; Moreover the Site is within proximity to Cadoxton and Penarth railway stations which have regular services in each direction in addition to the existing walking and cycling infrastructure in and around Sully.

3.3.55 The future accessibility of the Site will be further enhanced through the ongoing and planned South Wales Metro improvements, future active travel routes and the proposed Sully to Penarth mixed use link. The below figure shows several newly proposed active travel routes running close to the site including a new walking / cycling route along Swanbridge Road. Planning applications are now being submitted to support the delivery of these new active travel links. In March 2025 a planning application was submitted proposing a new route between Palmerstown and Dinas Powys.

3.4 SLR have undertaken further assessment work comparing the sustainability credentials of Land West of Swanbridge Road to Land North West of Barry. Land North West of Barry, is separated from the existing built-up area by the B4266 Pontypridd Road where the eastern and southern boundaries abut residential properties. As such, the proposed access for all modes would be taken from the A4226 Port Road West. The A4226 and B4266 can be a barrier to the promotion of active travel in that they facilitate vehicular travel and do not provide an attractive environment for pedestrians.

3.5 Furthermore, Land North West of Barry is on the fringes of Barry and had few if any facilities within a 10 minute walk, other than bus stops. In comparison, Land West of Swanbridge Road in Sully benefits from its proximity to the High Street in Sully and the services there.

3.6 The below table demonstrates differences in accessibility to amenities between the two sites, where Land West of Swanbridge Road presents a more favourable location for future development.

Table 6 Comparison of Local Facilities Between Land North West of Barry (Site ID 449) and Land West of Swanbridge Road (Phase 3) (Site ID 376)

3.7 Whilst the walking distance shown from Land North West of Barry to the nearest bus stop is slightly less than the Swanbridge Road Site, it should be noted that the bus services that can be accessed from Sully are more frequent and more direct than those which can be accessed from Land North West of Barry.

Conclusion

3.8 Taking the above together, the conclusion Taylor Wimepy reach is that their Land West of Swanbridge Road (Phase 3), Sully (Ref. 376) site performs more strongly than the Land North West of Barry site.

Policy TR1 Transport Proposals

3.9 The draft transport proposals contained within the Deposit RLDP have been reviewed with the following proposals considered to be pertinent to the Site and draft residential allocations.

TR 1 (2) Active Travel Route: Sully to Cosmeston

3.10 Taylor Wimpey support the designation of an active travel route connection the eastern side of Sully with Cosmeston in the north-east. Most notably the proposed route will pass Swanbridge Road which provides direct access to Land West of Swanbridge Road Site, with Phase 3 in close proximity to the travel route. The proposal would further enhance the accessibility and sustainability of the Site as a logical extension for residential development in Sully.

Figure 4 Extract of Deposit RLDP Proposals Map with Land West of Swanbridge Road (Phase 3) Identified

TR1 (6) Highway Improvement works: Weycock Cross Roundabout, Barry

3.11 Taylor Wimpey raise concerns around the proposed works at the Wyecock Cross Roundabout, compared to the other improvement works proposed. As noted in the Deposit RLDP, this roundabout forms a key connection within the wider strategic highway network and therefore of high importance for the local area and surrounding communities. The proposed options presented within the Deposit RLDP provide little certainty of the scope of works required with no preferred option identified. This raises concerns around the impacts of the highway improvements on the deliverability of the adjacent draft allocation of North West Barry. The same concerns arise when considering the roundabout improvement works in combination with the proposed access strategy contained within North West Barry’s supporting information package. The proposed road widening measures (c.11m increase) required to make the draft allocation accessible would have a significant impact on the wider transport network at this strategic junction.

Policy CC1 (Residential Operational Net Zero Carbon Development)

3.12 The effect of this policy is to require new build development to achieve net-zero operational emissions. This is to be achieved through the following of the Energy Hierarchy for Planning with Policy CC1 (Residential Operational Net Zero Carbon Development) then setting out space heating and energy use intensity standards to be met from RLDP adoption through to 2030 and then from 2030 onwards, and setting a requirement for on-site renewable electricity generation to have an output equivalent to annual energy consumption. The policy notes that this may not be technically feasible and, in these cases, requires that development maximises onsite renewable generation and / or connects or proposes to connect to a heat network and / or contributes to offsetting.

3.13 As a starting point, Taylor Wimpey share the concerns expressed by the wider development industry that setting requirements above and beyond building regulations (the 2025 Future homes Standard) is not appropriate. Building regulations are there as a mechanism to set fixed requirements that any development must achieve and the effect of introducing requirements to go beyond this results to an uneven framework for housebuilders, significantly adding cost and reducing certainty.

3.14 The justification for exceeding building regulations is set out in Section 7 of Background Paper 33A Net Zero Buildings and throughout Background Paper 33 Net Zero Buildings Feasibility Study and Cost Assessment and centres on the fact that there is a precedent for such policies in both adopted and emerging policies.

3.15 There are two points to be made here:

3.16 Firstly, a Written Ministerial Statement by then Housing and Planning Minister Lee Rowley made clear that it was not for Local Plans to set local energy efficiency standards that go beyond the requirements of building regulations with Inspectors to take this position at Local Plan examination stage. This Written Ministerial Statement was subject to a judicial review which was dismissed with the position taken in it found to be legally sound.

3.17 Clearly this is the position of the Westminster Government rather than the Welsh Government but the point is that it is wrong to suggest that there is a clear approach emerging in England for Local Plans to incorporate such policies when the Written Ministerial Statement warns Local Plans against setting energy efficiency targets that are stricter than building regulations.

3.18 Turning to a Wales context, whilst it may be the case that other local planning authorities are considering or looking into the use of such policies, it is worth noting that the two South East Wales local planning authorities which have adopted RLDPs do not include such policies and therefore that can be no confidence that the incorporation of such a policy approach will be found to be sound.

3.19 Secondly, Taylor Wimpey have concerns with the approach that has been taken with regards to viability.

3.20 From Taylor Wimpey’s review, a figure for achieving the requirements of Policy CC1 (Residential Operational Net Zero Carbon Development) is based on an analysis of three separate house type typologies as presented in Figure 4 of Background Paper 33A Net Zero Buildings. Background Paper 33A Net Zero Buildings is dated November 2025 but Background Paper 33 Net Zero Buildings Feasibility Study and Cost Assessment is from January 2024.

3.21 As a starting point, the figures for achieving this upgrade have been used by Hallam in the undertaking of the Development Viability Model with the development of the site found to continue to be viable with these incorporated.

3.22 Taylor Wimpey’s concern is around the robustness of an approach that considers only three building typologies and does not carry out the exercise for a far broader range of house types that are deployed by all of the active housebuilders (both market and affordable) across Wales. Savills’ experience is that in reality the cost associated with delivering these standards is in reality far higher and closer to the £15,000 or £20,000 per unit mark.

3.23 Taylor Wimpey’s other concern with this approach is that the figure assumed as being required to achieve the policy requirements of Policy CC1 (Residential Operational Net Zero Carbon Development) is driven from a Cost Assessment report published in January 2024. With the Background Paper 9A Housing Land Supply and Housing Trajectory not forecasting first completion onsite until 2028/2029, there is likely to be a period of approximately five years from the establishment of the figure for delivering the policy requirements of Policy CC1 (Residential Operational Net Zero Carbon Development) and when the first units would be delivered onsite.

3.24 Taking the above together, not only is the approach proposed to be taken in Policy CC1 (Residential Operational Net Zero Carbon Development) out of line with the approach that is to be taken in England and the approach that has been taken in Wales, it is considered that there is insufficient certainty around the ability for these works to be delivered when they are required to be without harming viability.

Policy CI1 (Open Space Provision)

3.25 This policy consists of four parts which, combined, dictate how open space should be provided. These parts of the policy set expectations for the level of public open space that should be provided for, confirm that provisions for open space should also be made for commercial uses, notes that it is expected that open space will be provided onsite, and requires that an open space strategy is submitted as part of applications where open space is required to be provided.

3.26 Taylor Wimpey note that Policy CI1 (Open Space Provision) of the Deposit RLDP, when compared with Policy MD3 (Provision of Open Space) of the adopted LDP, proposes an increase in public open space provision from a total of 2.4ha / 1000 people to 2.75ha / 1000 people.

3.27 Taylor Wimpey is not clear as to what has driven the increased level of public open space that Policy CI1 (Open Space Provision) identifies as being required and would welcome clarification on this matter, Policy DNP5 Environmental Protection

3.28 Taylor Wimpey consider the inclusion of ‘the loss of the best and most versatile agricultural land’ to be at odds with the other elements listed, where unlike the others mentioned, the loss of agricultural land would have limited, if any, impact on people, residential amenity and property.

3.29 It is acknowledged that the loss of BMV agricultural land may impact the VoG’s overall amount of high quality agricultural land, however this should be assessed against the existing high level of BMV agricultural land within the County. The extent to which its loss is considered “unacceptable” should be subject to the planning balance against the overriding need for affordable housing and local housing need. Consideration towards the farming business case and economic viability are also required within the planning balance. In the case of Land West of Swanbridge Road, the loss of BMV agricultural land remains the only constraint that cannot be overcome, as noted in the Candidate Site Assessment. Whilst the loss of high quality agricultural land should be avoided, Taylor Wimpey consider that where the merits of the Site are overwhelmingly in favour for sustainable residential development in a suitable and logical location, Policy DNP5 should not stand in the way of housing delivery.

3.30 Whilst Taylor Wimpey support the clause within the draft policy: “Where impacts are identified the Council will require applicants to demonstrate that appropriate measures can be taken to minimise the impact identified to an acceptable level. Planning conditions may be imposed, or legal obligation entered into, to secure any necessary mitigation and monitoring processes.” However, in the context of BMV agricultural land, it is not clear how the mitigating measures, in the form of planning conditions or legal obligations, can be applied. This reinforces the earlier view that the inclusion of ‘the loss of the best and most versatile agricultural land’, as currently worded within the draft policy, is at odds with the other elements listed where mitigation strategies for pollution can be suitably conditioned.

Greater flexibility should be introduced to allow appropriate small-scale allocations within sustainable rural settlements.

Land adjacent to Waterton Lodge, Colwinston (Site Ref: 409)
Boyer have prepared the following representation on behalf of Andrew Raymond regarding their land interests associated with Candidate Site 409 (Land adjacent to Waterton Lodge, Colwinston) in response to the current Vale of Glamorgan Replacement Local Development Plan (RLDP) 2021– 2036 consultation.

A summary of the main representations are as follows:
• Concern regarding the absence of proportionate residential growth opportunities within rural settlements such as Colwinston;
• Concern regarding the overall housing requirement and the need for an increased flexibility allowance within the housing trajectory;
• Questions regarding the spatial distribution of development and the limited range and choice of sites outside the Strategic Growth Area;
• Confirmation that Candidate Site 409 (Land adjacent to Waterton Lodge, Colwinston) represents a logical and sustainable opportunity for modest residential development;
• Review of the Candidate Site Assessment process and the current status of the site within the Candidate Site Register; and
• The need to consider appropriate settlement boundary adjustments to facilitate proportionate growth in sustainable rural settlements.

SP1: Sustainable Growth Strategy
Whilst Policy SP1 outlines the housing delivery requirement (addressed under the response to SP6), the principal concern in relation to the site promotion is the concentration of the majority of future housing growth within the defined Strategic Growth Area.
It is understood and supported that new housing development should be located in sustainable locations with access to public transport and services. However, the approach adopted within the RLDP places an overly narrow emphasis on growth within the Strategic Growth Area, primarily focused along rail corridors. This approach risks overlooking other sustainable rural settlements which also demonstrate appropriate connectivity and capacity to accommodate proportionate growth.

Settlements outside the Strategic Growth Area continue to perform an important role within the Vale’s settlement hierarchy and rural economy. Villages such as Colwinston provide an established residential community and contribute to the vitality and sustainability of rural areas. Restricting opportunities for modest growth within such settlements risks undermining the long-term sustainability of rural communities.

The principle of directing development to sustainable settlements is supported. However, limiting development opportunities exclusively within the Strategic Growth Area is not considered to represent the most balanced or flexible spatial strategy. Greater flexibility should be introduced to allow appropriate small-scale allocations within sustainable rural settlements.

In this context, Candidate Site 409 (Land adjacent to Waterton Lodge, Colwinston) represents a sustainable opportunity for a modest residential development that would align with the scale and character of the settlement. The site lies adjacent to existing built form and would represent a logical and contained extension to the village.
SP2: Settlement Hierarchy

Mr Raymond supports the identification of Colwinston as a Minor Rural Settlement and acknowledged its capacity to accommodate proportionate and sustainable growth, particularly given its accessibility and relationship with Bridgend to the west and Cowbridge, Barry and Cardiff to the east. The Deposit Plan retains Colwinston within the Minor Rural Settlement tier, however, does confirm that the settlement is outside the Strategic Growth Area.
Whilst the overarching principle of directing growth to the most sustainable settlements is supported, the Plan does not clearly demonstrate why settlements that are well connected and functionally related to larger centres, such as Colwinston, should be subject to such constrained growth.

In this context, Mr Raymond highlights Paragraph 3.10 which indicates that Minor Rural Settlements provide an ‘important range of services and facilities that play a functional role in meeting some of the basic needs of residents within rural areas, reducing the need to travel’.
Building upon this, Policy SP2 does highlight that ‘Minor Rural Settlements identified will be limited to the efficient and sustainable use of existing buildings, infill opportunities, small-scale affordable housing led schemes, and rural enterprise/ agricultural related developments’.

Furthermore, the supporting text to Policy SP2 (Paragraph 6.17) confirms that ‘those settlements that are considered to have sufficient population, services, and facilities to accommodate small scale growth without it having a detrimental impact on their existing character and local environment’.

This all building upon the identified importance of Minor Rual Settlements within the Preferred Strategy which outlined in Paragraph 6.50 that it is ‘essential for the LDP to balance the growth in a way that supports the need of rural communities’ and whilst it is evident that within these settlements ‘general market housing will be limited to opportunities including infill’ (Paragraph 6.51), the enabling of an element of ‘open market housing will provide opportunities for the delivery of affordable housing reflecting the aspirations of rural communities to sustain their housing needs’ (Paragraph 6.51). This importance of Minor Rural Settlements needs to be carried more strongly forward in the Deposit Plan.

Moreover, the evidence base does not sufficiently justify the degree of restriction now applied, nor does it explain why proportionate additional growth in appropriate Minor Rural Settlements would undermine the spatial strategy. As drafted, the policy risks limiting flexibility in the distribution of housing across the Vale. Accordingly, it is considered that the approach to Colwinston under Policy SP2 is not justified.

Clearly there continues to be a disconnect between the identified role and function of Colwinston, which is supported, and the actual ability to deliver the appropriate range and choice of dwellings in the rural settlements. For example, a modest allocation at Land adjacent to Waterton Lodge, Colwinston (Candidate Site 409) would represent proportionate growth that reflects the scale and character of the settlement. The site sits adjacent to existing development and would consolidate the existing settlement pattern without resulting in sprawl into the open countryside.

The current approach within Policy SP2 risks constraining flexibility within the spatial strategy and limiting opportunities to support sustainable rural communities.

SP6: Housing Requirement
Concerns are raised regarding the overall housing requirement and the level of flexibility incorporated within the Plan.

Policy SP6 currently establishes a housing requirement of 7,890 dwellings over the Plan period and includes a flexibility allowance of 10%, resulting in an overall provision of 8,660 dwellings.
The proposed supply is anticipated to be delivered through:
• 3,837 dwellings from the existing land supply
• 3,520 dwellings on allocated sites
• 1,303 dwellings from large and small windfall developments
Whilst the inclusion of a flexibility allowance is supported, it is considered that a 10% allowance may not be sufficient to ensure resilience within the housing trajectory.
Recent experience from other Local Development Plans across Wales has demonstrated the importance of incorporating higher flexibility allowances to account for delivery uncertainty, infrastructure constraints and potential delays to larger strategic sites.

For example, other authorities have incorporated flexibility allowances in excess of the standard 10% to ensure the robustness of their housing supply and to provide a greater degree of adaptability should circumstances change during the Plan period.

In this context, it is considered that the Vale of Glamorgan RLDP should incorporate a flexibility allowance of at least 15%. This would provide additional resilience within the housing trajectory and reduce reliance on a limited number of larger strategic allocations.
Smaller sites such as Candidate Site 409 at Waterton Lodge, Colwinston are particularly valuable in this context. Smaller sites are typically:
• More deliverable in the short term
• Less dependent on major infrastructure investment
• Capable of contributing to early housing delivery
• Able to increase overall build-out rates
Such sites can therefore play an important role in supporting the delivery of the Plan’s housing requirement and enhancing flexibility within the supply.

HG1: Housing Allocations
Mr Raymond does not comment on any of the proposed housing allocations, however, does highlight that the delivery is incumbent upon a number of larger strategic sites, and that to allow a greater range and choice then smaller allocations in the Minor Rural Settlements are required. Only 122 units are proposed on smaller allocated sites, equating to approximately 2.6% of newly allocated supply under (E) Rural Affordable Housing Led Sites – policy HG4.

In the context of the above, there remains significant concern that the spatial strategy continues to exclude the required number of allocations within Minor Rural Settlements, including Colwinston.

The Plan recognises that Minor Rural Settlements provide an important range of services and facilities and play a functional role in meeting the needs of residents within rural areas. It further acknowledges that it is essential for the LDP to balance growth in a way that supports rural communities. Whilst general market housing is described as being limited to infill opportunities, the Plan also recognises that enabling an element of open market housing provides opportunities for the delivery of affordable housing and helps sustain rural communities.
It is agreed that the inclusion of smaller allocations can:
• Improve overall housing delivery rates
• Provide greater choice within the housing market
• Reduce delivery risk by diversifying supply
• Support rural communities through proportionate growth

Whilst it is noted that there is a proposed allocation within Colwinston – HG4 (1) – Land to the East of Colwinston for 25 units, Mr Raymond maintains that there is still a clear disconnect between the identified role and function of settlements such as Colwinston and the absence of any further allocated sites capable of delivering an appropriate range and choice of dwellings.

The strategy effectively restricts development to windfall and infill, without positively identifying opportunities that would logically consolidate and strengthen the settlement.
This approach is inconsistent with the settlement’s accessibility and functional role. Colwinston is:
• Well connected to the A48 strategic highway network;
• Served by bus routes within close proximity to the site;
• Within commuting distance of Bridgend, Cowbridge, Barry and Cardiff;
• A sustainable and established residential community.
Land adjacent to Waterton Lodge, Colwinston (Site Ref: 409) represents a contained and sustainable opportunity that naturally rounds off the existing settlement boundary. The site encloses the envelope of development without encroaching into open countryside or extending beyond the established line of built form. It is well related to existing services and infrastructure and is capable of accommodating a modest allocation consistent with the scale and character of the village.

A proportionate allocation at this location would align with the stated objectives of supporting rural communities, enabling a mix of market and affordable housing, and providing genuine choice within Minor Rural Settlements. The continued absence of such allocations undermines the internal consistency of the spatial strategy.

Furthermore, the strategy places substantial emphasis on rail-based corridors. Whilst development near rail infrastructure is supported in principle, sustainable growth should not be exclusively rail-led. Strategic highway connectivity and bus accessibility also represent legitimate and sustainable locational advantages.

The complete absence of allocations in Minor Rural Settlements creates an imbalance in distribution and limits housing choice. A modest allocation at Waterton Lodge would represent proportionate growth consistent with the scale and character of the settlement.

HG4 – Affordable Housing Allocations
It is recognised that Policy HG4 does allocate development within some Minor Rural Settlements, and in particular within Colwinston HG4 (1) – Land to the East of Colwinston for 25 units. In the context of Policy HG4 they will be affordable housing led sites where there will be a requirement for the provision of a minimum 50% affordable housing. This is to meet the affordable housing needs of the local community. Mr Raymond has no objection in principle to this but does object to the fact that there is no other development opportunities recognised in Colwinston (despite it being sustainably located on the A48).

Furthermore, Land adjacent to Waterton Lodge, Colwinston (Site Ref: 409) could be reduced in size and could be amended to offer 50% affordable housing to accord with the policy (or even 100% affordable if the Authority sought this).

A balanced approach which allows both affordable housing led schemes and modest mixed-tenure developments would provide greater flexibility and assist in delivering a broader range of housing needs.

A modest development at Land adjacent to Waterton Lodge, Colwinston (Candidate Site 409) could provide an opportunity to deliver both market and affordable housing in accordance with Policy SP8. This would support local housing needs whilst maintaining the scale and character of the settlement.

Candidate Site Response: Land adjacent to Waterton Lodge, Colwinston (Candidate Site 409)
Candidate Site 409 (Land adjacent to Waterton Lodge, Colwinston) was submitted to the Vale of Glamorgan Council during the 2022 Call for Candidate Sites as part of the preparation of the Replacement Local Development Plan (RLDP) 2021–2036.

The site is currently included within the Candidate Site Register, which represents a list of sites submitted for consideration through the plan-making process. Inclusion within the register does not in itself indicate that a site will be allocated for development, as all sites are subject to a structured assessment process.

These stages consider a range of factors including sustainability, accessibility, environmental constraints and deliverability.

As part of the ongoing plan preparation process, the Council produced an updated Candidate Site Register following the initial submissions. Sites continue to be evaluated as part of the evidence base supporting the RLDP.

In this context, Land adjacent to Waterton Lodge, Colwinston represents a sustainable and deliverable opportunity for modest residential development which could contribute positively towards the Plan’s housing supply.

The site is located adjacent to the existing settlement and is well related to the current built form. Development in this location would represent a logical and contained extension to the village, rather than an isolated incursion into open countryside.

Furthermore, the site has been promoted through the formal candidate site process and should therefore be considered fully within the Council’s site assessment framework.

Deposit Plan Considerations
Settlement Boundary

Given the location of Candidate Site 409 adjacent to the existing settlement of Colwinston, consideration should be given to whether a modest adjustment to the settlement boundary would enable the site to be appropriately integrated within the settlement.

A logical rounding-off of the existing settlement edge would allow development to occur in a manner that respects the existing built form and maintains a clear and defensible settlement boundary.

Such an approach would represent a proportionate response to the need for modest housing growth within rural settlements.

Site Assessment
The site was formally submitted through the Candidate Site process and is currently listed within the Council’s Candidate Site Register.

Given the role that smaller deliverable sites can play in supporting housing delivery, it is important that sites such as Land adjacent to Waterton Lodge, Colwinston are fully considered as part of the ongoing assessment process.
Smaller sites can provide valuable flexibility within the housing trajectory and contribute to early housing delivery within the Plan period.

Turning to the main reasons the site was not taken forward Mr Raymond provides the following response:
(a) Alleged intrusion into the open countryside
The Stage 2 Register cites “unacceptable intrusion into the open countryside”. Mr Raymond submits that this conclusion fails to reflect the site’s physical containment and relationship to the built form.
• The site directly adjoins existing dwellings at Waterton Lodge and mature boundary hedgerows; development here would constitute rounding-off rather than isolated sprawl.
• A strong landscape framework already exists, and additional planting could reinforce defensible boundaries.
Accordingly, the site’s development would not materially extend the settlement into open countryside or harm landscape character, consistent with PPW paragraph 3.60.
(b) Highways and accessibility constraints
The Council refers to “major highways constraints” but no evidence highway assessment has been published by the Authority. Mr Raymond’s preliminary review confirms that safe vehicular access can be achieved from the adjoining local highway with modest engineering works and that the scale envisaged would generate limited traffic, well within local-road capacity.
Future submission of a Transport Statement can demonstrate compliance with PPW (Section 5: Active and Socially Just Places) and LDP Policy MD2 (criteria 6 and 8).
The site lies within walking distance of Colwinston’s core facilities (village hall, public house, bus stops), enabling sustainable travel choices for residents.
(c) Scale of development
Development at a scale that represents proportionate growth for Colwinston can be provided and would be entirely consistent with the “limited expansion” envisaged for minor rural settlements under PPW and the RLDP.
This level of growth would strengthen local demographics, support the rural housing supply and modestly contribute to the Vale’s overall housing requirement, without exceeding infrastructure capacity.
(d) Ecology, landscape and agricultural land classification
The land is semi-improved grassland with no statutory designations. Preliminary review indicates no SINC coverage or protected species constraints. Detailed ecological and agricultural-land surveys can be provided to confirm that any residual impacts are minor and capable of full mitigation.

Development can achieve net biodiversity gain through buffer planting, sustainable drainage and native-hedgerow reinforcement, fully consistent with PPW and RLDP environmental objectives.

5. Sustainability and deliverability
• Availability: Mr Raymond, as landowner/promoter, confirms the site is immediately available for development.
• Deliverability: The site is modest, unconstrained by flood risk or abnormal infrastructure requirements, and can deliver homes within the early part of the plan period.
The proposal supports rural-settlement vitality, contributes to local housing choice, and allows design to embody placemaking principles (PPW Ed. 12 Section 2).

Conclusion
This representation, submitted on behalf of Mr Raymond in response to the current Vale of Glamorgan Council Replacement Local Development Plan (RLDP) 2021–2036 Deposit Plan Consultation, maintains that Land adjacent to Waterton Lodge, Colwinston (Site Ref: 409) represents a logical, sustainable and deliverable parcel that should be allocated as a suitable and viable residential site within the RLDP.

Accordingly, the site is considered to represent a suitable, available and achievable allocation capable of contributing to the housing requirement, supporting affordable housing delivery, and reinforcing the spatial objectives of the Plan.

Catesby suggests that VoGC considers the inclusion of additional sites to deliver the predicted growth strategy identified in the RLDP. This will strengthen the land supply position ensuring a robust RLDP can be adopted which has the ability to ensure the delivery of the necessary growth.

VALE OF GLAMORGAN DEPOSIT REPLACEMENT LOCAL DEVELOPMENT PLAN - REPRESENTATION ON BEHALF OF CATESBY ESTATES

This response to the consultation on the Vale of Glamorgan Council (‘VoGC’) Deposit Replacement Local Development Plan (‘RLDP’) is submitted by Turley on behalf of Catesby Estates (‘Catesby’). It sets out Catesby’s comments on the Vale of Glamorgan Deposit Replacement LDP published for consultation on 28th January 2026.

Catesby control a significant amount of land at, and surrounding Llandow Airfield, and sought promotion (previously promoted by L&Q Estates prior to its acquisition by Catesby) of the site during the call for Candidate Sites (Site ID Ref: 448). The Stage 2 Candidate Site Register confirms that the site was not considered suitable for further consideration by VoGC. This was primarily due to its location outside of existing settlement boundaries and the scale of dwellings/services proposed. It was concluded that the scale of development proposed could be considered a new settlement, which should only be proposed as part of a joint LDP, an SDP or Future Wales.

Catesby acknowledges that promotion of a site of this scale falls outside the scope of the RDLP. The site will be promoted through the emerging South East Wales Strategic Development Plan in due course. Catesby maintains that the site is capable of accommodating major development and that its promotion for strategic scale regeneration is entirely appropriate given its sustainable credentials and the contribution that it can make to the Vale of Glamorgan and wider Cardiff Capital Region. Catesby remains keen to working collaboratively with VoGC to bring forward development at Llandow in the medium to long term and looks forward to continuing the largely positive discussions that have taken place to date.

VISION AND STRATEGIC OBJECTIVES

The vision for the Deposit RLDP maintains that, by 2036, VoGC will provide housing growth which responds to the authority’s growing population and caters for all. This should be shaped through successful placemaking, delivering diverse communities and ensuring that the Vale is a healthy and inclusive place for everyone.

VoGC identifies key themes and strategic objectives to deliver the vision of the Deposit RLDP. This includes “ensuring that all new residential developments provide high quality housing that includes the right mix, tenure and type of homes that respond to the changing needs of the Vale’s population”, to address the accommodation needs of all the Vale’s communities (Objective 3 - Homes for All). Objective 4 – Placemaking also seeks for new development to be appropriately located, contribute towards creating active, safe and accessible places, and protect and enhance the character of existing communities.

The provision of a mix of new homes is also crucial in fostering diverse, vibrant and connected communities in line with Objective 7. Consequently, physical, economic and social regeneration are facilitated, reflecting the needs and aspirations of local communities. Vital and vibrant rural communities are also provided through the delivery of growth in sustainable locations and supporting infrastructure.

Catesby broadly SUPPORTS the vision and strategic objectives of the Deposit RLDP to deliver a mix of high-quality new housing which responds to the authority’s growing population, caters for all, and has placemaking at its heart. This new housing should be facilitated across the Vale in a variety of sustainable locations to best serve as many communities as possible.

SUSTAINABLE GROWTH STRATEGY

A key part of the Sustainable Growth Strategy for the Deposit RLDP is to deliver a sustainable level of housing growth which accords with the Vale’s position within the Cardiff Capital Region (CCR). Specifically, the Deposit RLDP makes provision for a housing requirement of 7,980 dwellings over the Plan period (526 dwellings per annum). The Deposit RLDP makes clear that this is both deliverable and ambitious, reflecting the Vale’s position in the Future Wales national growth area. Crucially, the housing requirement will be achieved through a range of housing opportunities, to encourage existing residents to live and work in the Vale and encourage inward migration of new residents, at a level commensurate with the CCR.

However, Catesby would suggest that this level of growth is still too low, taking into account the aspirations of Future Wales for the area and the latest population and household projections, which suggest a higher level of need is required for the Vale.
The Sustainable Growth Strategy also seeks for new and existing housing, employment, services and facilities to be co-located to reduce the need to travel. New housing development shall be specifically located in places that are already well served by existing and/or proposed services, facilities and employment opportunities. This includes, where appropriate, those offered by the business parks and industrial estates already established in the Vale. The Strategy also allows for regeneration opportunities on previously developed and under-utilised land.

The Key Diagram (Figure 1) identifies the proposed Strategic Growth Area (SGA), connectivity routes, key locations for future development, the Plan’s hierarchy of settlements and interrelationships with adjoining local authorities.

Figure 1: Key Diagram

Catesby considers that the Minor Rural Settlements dispersed within the ‘Connectivity’ corridor, such as Llandow, should play a supporting role in accommodating housing growth, given their important range of services and facilities that reduce the need to travel. The Sustainable Growth Strategy also allows for small scale affordable housing led developments in Minor Rural Settlements, where appropriate.

Noting Llandow’s accessible location and proximity to existing and emerging strategic employment opportunities, Catesby broadly SUPPORTS the Sustainable Growth Strategy insofar as seeking to achieve the housing requirement through a range of housing opportunities. This includes the co-locating of housing and employment growth, with a focus on established business parks and industrial estates.

Paragraph 5.14 notes that “where appropriate, the broad principle is that the spatial strategy should look to ensure that new housing is in places where employment opportunities already exist or are proposed.” Catesby supports this principle, noting that the Llandow Airfield site offers the potential to deliver co-located residential and employment opportunities at scale, as identified within the promotion document submitted in support of its response to the call for Candidate Sites. This will remain a key aspiration of the site’s future promotion via the emerging SDP.

However, Catesby reiterates that the housing requirement for the Vale should be higher, accounting for the aspirations of Future Wales for the area and the latest population and household projections. A more ambitious Growth Strategy is needed to accommodate this increased housing requirement.

POLICY FRAMEWORK

Policy SP1 - Sustainable Growth Strategy reiterates that the Plan will deliver 7,890 dwellings by 2036, including a minimum of 3,070 affordable homes. Policy SP1 also sets out that, outside of the Strategic Growth Areas, the allocation of new sites will be limited to small-scale affordable housing led sites.

In order to ensure that the minimum target figure is met, it is important that the Plan identifies a sufficient number of sites / housing allocations to meet both the short and longer term development needs. As previously stated, Catesby SUPPORTS the overall growth strategy across the Vale of Glamorgan contained in the Deposit RLDP. However, it is questioned whether or not there is sufficient land allocated to deliver the growth required.

Of the overall housing target of 7,890 dwellings, approximately half of these are to be delivered via rolled forward allocations and extant consents. Whilst some such sites can be expected to come forward, Catesby would caution against the over-reliance on delivery of historically allocated sites.

Catesby suggests that VoGC considers the inclusion of additional sites to deliver the predicted growth strategy identified in the RLDP. This will strengthen the land supply position ensuring a robust RLDP can be adopted which has the ability to ensure the delivery of the necessary growth. Catesby supports growth along the ‘Connectivity’ corridor, particularly in Minor Rural Settlements such as Llandow to assist with this.

Policy SP2 – Settlement Hierarchy broadly distributes development in line with the hierarchy of settlements, reflecting the role and function of places and directing growth to locations that will provide the greatest opportunities for delivering housing to meet affordable needs, community infrastructure and enhanced sustainable transport provision. Llandow is identified as a Minor Rural Settlement, new development associated with which should be mainly limited to infill opportunities and small-scale affordable housing led schemes (sites of up to 25 dwellings with a minimum of 50% affordable provision).

Catesby would suggest that specific sites in and around all settlement types may be suitable for a greater level of development than that suggested by the settlement hierarchy, and these should be explored accordingly. As part of this, Catesby SUPPORTS the recognition in the Policy Framework that the existing services and facilities in and around the Minor Rural Settlements should be safeguarded, supported and enhanced, and that in order to do this, growth should still be balanced in a way which supports these rural communities (Paras 6.16 and 6.17).

Policy SP3 – Development in the Countryside is clear that development will only be permitted in the countryside where it falls within one of the specified uses. This only includes Affordable Housing Exception Sites in respect of housing development. Catesby suggests that further development sites are required across the Vale in order to meet the Council’s housing requirement, which should consider locations within the countryside where appropriate.

Catesby reiterates that the co-location of housing with existing infrastructure and facilities will be crucial to achieving the overall Growth Strategy of the RLDP. Development in and adjacent to Minor Rural Settlements is also key to this, especially those located in proximity to the ‘Connectivity’ corridor on the Key Diagram.

Catesby SUPPORTS development within these locations, particularly at Llandow. This is key in order for the Vale of Glamorgan to achieve part of its overarching vision, which states that “growth within rural settlements has provided for the needs of residents and supports balanced multi-generational communities that contribute to the vibrancy of the rural area”.

SUMMARY

We trust that the above representations can be considered duly made and look forward to receiving confirmation accordingly. Catesby welcomes the opportunity to comment further as the RLDP progresses through to adoption. Catesby looks forward to engaging with the Council over the months ahead to continue a dialogue regarding the future delivery of development at Llandow. If you require any further information, please do not hesitate to contact me on the details below.

Penarth Town Council Deposit RLDP Consultation Response

Comments collated at a meeting of the Council’s Consultation Task and Finish Group on 9th February 2026

Some Members attended the RLDP consultation drop-in session in Penarth and in general found it to be very informative.

Members support the general development strategy but did note the lack of information concerning discussions with adjacent and other nearby Principal Councils in the CJC Region. In view of the forthcoming Strategic Development Plan, encompassing the ten authorities, members felt that some further commentary regarding this is warranted.1

It is clear that the approach taken in the Cardiff paper is still that ideally, each Council is self-contained and “consumes its own smoke,” which does not show any wider strategic thinking between the ten authorities in preparation for a regional Strategic Development Plan.

Members agreed with the view that infrastructure to support new housing developments was required in order to create successful developments, although they acknowledged that logistically it was difficult to pre-empt demand for some services such as travel and health services. Members also noted that predicting developmental needs and opportunities within wider context surrounding the UK’s economic, political, and social landscapes.

Members noted that there was not much focus on Penarth or identified potential future development for Penarth beyond that already underway at the location near to Cosmeston but welcomed flexibility in its approach. Members expected to be more closely involved in the decisions and planning of this, and other such developments, and provide opportunity for wider consultation where appropriate, such as pre-application consultations, as well as would expect to be included in consultations concerning sites adjacent to Llandough, Dinas Powys, and Sully given their impact upon the town.

Penarth as a town is currently developed to its boundaries, save for the development at Cosmeston. It is, therefore, more dependent than other Service Centres on windfalls of land or buildings which may arise during the currency of the Plan. In 2023, an extensive assessment of the potential of the town concluded the following:

“There is marginally less capacity in Penarth [and Llandough] than the projected figures. However, this does not mean that the projections are incorrect or unjustifiable. The reported figures have not included a significant amount of capacity on open space land, and the projected figures for conversion of existing buildings and intensifications will be surpassed if the extant consents that exist this early in the Plan period are implemented.”

The degree of flexibility, however, is substantially depending on one large site. P009, Headland School, is identified as both a potentially disused building and as a site with a capacity of 111-120 units. This special school is full to capacity and used by many Council in both Wales and England.

Members did note the inclusion of Cogan Transport Interchange under section 6.196 but would have liked to see more information about its future developments as they see it as key to increasing public transport use to Barry and further to West Wales in general.

Members wished to advise that issues with both the bridge and the platforms at Cogan have been long term, with accessibility being central to these issues. Members felt that improvements to accessibility should be a priority at this site, with planting and landscaping considered secondary to this.

Members felt it was key to consider the additional stress on Penarth from increased anticipated demand of public transport needs and emphasised the need for this to be aptly considered by bus route providers as part of development work.

Members wanted to see a strategy that actively protects the town’s heritage and culture whilst still being able to provide for current and future generations.

Members welcomed the inclusion of specific climate change mitigation and adaptation measures under SP16 and section CC1-CC6, noting the considerable attention given to Net Zero transition proposal relating to public buildings and energy. Whilst the evidence presented does not include the UK Climate Change Committee Report2, Members were pleased to see that CC1-CC6 largely reflect the Committee’s finds and are tailored to a transition which reflects what is presently feasible. This is providing that the necessary skills to understand and undertake carbon assessments within a policy implementation and regulation context are readily available.

Under CC2, it was noted that the presumption against demolition3 in favour of retrofit and reuse may constrain maximum transition to net zero as, whilst there is grant aid available for public buildings and social housing, the retrofit monies available for private stock is limited.

Additional considerations will also need to be made as part of the Third Carbon Budget (2026-2030), Local Area Energy Plans and the climate change ISA theme.

Members also felt similar about the inclusion and consideration of sustainable development through the specific strategy outlined in section 5 of the document and felt this linked in well with ongoing Placemaking work and its strategic approach as detailed in SP4.

Members were pleased to see mention of the diversification of high streets, although noted that Penarth was above average in terms of occupancy. They hoped that the RLDP would be able to support the town centre and support other ways it could be improved, such as a fishmonger or identifying a site for a new Cemetery.

With Penarth classified as a Service Centre, they are identified as having a defined role. However, the decline of in-person retailing means that defining role is not that evident, and Members felt there is potentially a need to move away from the traditional retail role of Town Centres in favour of “repurposing, creating multifunctional, commercial, and service centres that meet the needs of the communities they serve” in line with Future Wales Town Centre First Policy. The term ‘repurposing’ suggests a stronger role for the public sector in enabling these new purposes, and Members felt that Placemaking Plans could be one potential framework for this.

Members felt that potential functional support that could be provided could include:
• The appointment of a Town Centre Manager
• Using supporting interventions such as an extension or reshaping of normal services such as Neighbourhood Services.
• Using existing or emerging new powers, such as compulsory purchases.

Members wished for the RLDP to facilitate the safeguarding of essential public services, including health, policing, fire and rescue in the town, which would help to develop the defining role of a Service Centre, and felt that specific reference to these would be beneficial.

Members supported the avoidance of coalescence with adjacent settlements through the reconfirmation of Green Wedges as it allows for relevant extensions to those settlements whilst allowing them to retain their identity.

Members noted that the Quiet Area provision under DNP6 only applies to Penarth and wished to know why this was the case.

Members advised that they welcomed further opportunity for consultation, particularly in relation to developments in the neighbouring Cardiff Bay area whilst acknowledging that this is not necessarily an RLDP concern.

Footnotes

1 There is an evidence paper concerning relations with Cardiff and a Statement of Common Ground with Bridgend. However, there is only a reference in the RLDP text to discussions with other regional Councils and not the paper itself. We would be grateful if you could provide the paper as it does impact on the soundness of this Plan.

2The UK Climate Change Committee’s ‘Progress Report: Reducing Emissions in Wales’ highlighted the following aspects of import: Skills, Vehicle Charging Networks, Improving Recycling, Energy Plans, Decarbonising Public Buildings and Social Housing, and reducing Road transport Demand (Car-Kilometres).

3The UK Environmental Audit Committee (2022) noted that “the evidence we received consistently recommended that retrofit and reuse be prioritised over new build.”

ANNEX 1
Preface

This Annex sets out the detailed case in support of these representations, and by association the case for allocation of the site.

The representations are structured into the following sections:

1. Response to the Deposit Plan;
2. Comments on specific policies; and
3. A summary of the suitability of the site for development.

SECTION 1. Response to the Deposit Plan

Distribution of Growth

We object to the distribution of growth within the Deposit Plan. Specifically, we object to the strategy that underpins the Deposit Plan, which seeks to introduce the proposed ‘Strategic Growth Area’ which is expected to contain the majority of housing growth in the Vale over the Plan period, or rather the over-reliance on this defined area, and the associated absence of growth in other parts of the Plan area.

As outlined in our previous representations, the allocation of housing and the location of strategic growth neglects the Rural Vale, and in our view, overprovides in the Strategic Growth Area. For example, with limited housing stock and average house sales at over £500,000 over the last 12 months, there is a clear and established need for new homes in the Ystradowen area, particularly at an affordable level. This is reinforced by the Local Housing Market Assessment that identified a need for over 1,114 new affordable homes per annum over the next five years throughout the county, and 196 units per annum thereafter (average of 502 units per annum over 15 years). Further to this, it is widely known that the rural Vale comprises the majority of the county’s ageing population, which, as a demographic, has and will continue to grow rapidly over the Plan period. This is evident in the ‘Population Change’ chart below – which is taken from the Deposit Plan:
VofG Deposit Plan: Figure 4 Population Change 2011 to 2021

It is clearly the case that younger populations are migrating to other Authorities, where access to housing is typically cheaper and more affordable, whilst more older populations are significantly migrating into the Authority. This trend will result in an extremely unbalanced demographic, given that the working-age population have sought housing elsewhere.

Without a suitable supply of affordable housing delivered over the Plan period, this trend will only worsen. Accordingly, it is not considered that the RLDP takes into account the lack of supply of affordable homes within the rural Vale, as well as increased housing to support the growing ageing population within these areas.

Para 3.19 of the Deposit Plan clearly outlines that affordable housing is required in the short term, in order to meet pressing needs. Specifically, it outlines the following: “There is significant pressure on temporary accommodation in the Vale, for a variety of reasons including increased homelessness presentations… The need for sufficient permanent affordable housing to assist in moving people out of temporary accommodation is critical and the planning system has a vital role in assisting in new affordable housing delivery.”
Accordingly, the distribution of growth within the Authority must be proportionate, to ensure that populations / areas are not left behind where they must seek access to housing elsewhere.

The RLDP Sustainable Growth Strategy sets out 6 objectives. Objective 4 states: “Allowing for small scale affordable housing led development in settlements outside the Strategic Growth Area at a scale proportionate to the size of settlement.” (Page 66)
Para 5.25 states “Therefore, a key part of the strategy is to allow for affordable housing led developments within sustainable primary and minor rural settlements outside of the Strategic Growth Area, at a scale that is appropriate to the size of the community it is serving. An ‘affordable housing led’ scheme is one where a minimum of 50% of the dwellings would need to be affordable, although this could increase to a maximum of 100% if the site is brought forward by a social landlord”.

In terms of the definition / explanation of what the affordable housing-led development sites are seeking to achieve, paragraph 6.132 of the Deposit Plan outlines the following:

“Accordingly, to ensure that new developments respond to the high demand for smaller properties, as identified in the LHMA, priority will be given to affordable homes that are small to medium-sized, typically comprising one to three bedrooms. Representations received from the local community through the RLDP process also highlighted a desire for new housing developments to offer opportunities for accessing smaller market homes. This is particularly relevant in the rural Vale, where housing choices are more limited. Providing smaller, more affordable market homes may assist first-time buyers and enable older residents to downsize to more manageable properties within their local area. Affordable housing-led sites will therefore need to demonstrate that an appropriate range of both affordable and market dwellings has been provided.”

Despite the acknowledgement within this strategic objective, we do not consider that the RLDP goes far enough to meet this objective, nor are its provisions and allocations adequate.

It is considered that this objective is undermined by the allocations set out by the RLDP (not least the absence of allocations in the rural Vale). Notwithstanding the Vision’s clear acknowledgement of the benefit of the growth of the rural Vale, these areas have not been supported through the plan due to the lack of growth which has been attributed to these areas in terms of further housing, employment and sustainable transport. All growth options have been selected on the basis of being in either a Key Settlement, Service Centre Settlement or Primary Settlement, all of which are already sustainable areas served by rail. As a result, it is not clear how this objective can be achieved, without the allocation of further sites within the Minor Rural Settlements, such as Ystradowen. The Vale is characteristically ‘rural’, and as such, there needs to be a stronger emphasis on supporting and delivering new development in order to bolster the rural economy. This includes enabling opportunities to provide employment and business premises within / near to rural settlements, as well as focusing housing growth in these areas to reduce travel time, and promote the use of sustainable transport.

It is considered that the current Strategy does not provide adequately for all residents across the Vale, only those within the Strategic Growth Area. The underlying Vision and Objectives set out in the emerging Plan are accordingly wholly un-provided for by the detail of the Plan. This brings into question the “soundness” of the Plan.

The Strategic Growth Area does not take into account the important role and proximity of Bridgend to the West and/or the Principal Settlement and Strategic Growth Area of Talbot Green / Pontyclun / Llantrisant to the north (as defined in the RCTCBC LDP). The Minor Rural Settlements to the west are more likely to be supported by job opportunities and employment in Bridgend than further east in Barry or Cardiff. Similarly, those in the north align with, and function in association with, the Principal Settlement and Strategic Growth Area of Talbot Green / Pontyclun / Llantrisant to the north. These settlements are served by existing bus services that provide sustainable modes of travel to key employment locations in and around Bridgend. This is acknowledged in Paragraph 3.3 of the Strategy which states “The greatest number of residents who travel outside of the Vale for work purposes travel to Cardiff followed by Bridgend and Rhondda Cynon Taf, whilst a smaller proportion commute into the Vale from these neighbouring authorities”. The Demographic Evidence (Feb 2023) estimates the Vale as being a net importer of workers from RCT and Caerphilly (Para 3.6) - as shown in Figure 10 in the Preferred Strategy.

The current Strategy does not support any improvement of sustainable travel or further investment in settlements linked more closely to these areas - given that Growth has been apportioned in only the Key Service Centre and Primary Settlements. It is considered that this will fail to support and facilitate the current (and any future) employment coming into the Vale, nor will it support any employment which is located outside of the Vale to the West and North. The Growth Option is too heavily reliant on access to railway stations as the key and sole sustainable transport method, whereas access to bus services should also be appropriately assessed and focused on in terms of promoting sustainable development. It is unreasonable to devise a strategy that hinges on directing growth to areas that are accessible to railway facilities, where it is recognised in the Plan that the Vale is inherently rural. The delivery and soundness of the Plan is therefore questioned and we continue to object to the spatial growth strategy as set out in the Deposit Plan.

Housing Supply

RLDP Allocations - Key Sites

As set out in representations made throughout the Plan preparation process, we consider that the Plan is too reliant on the delivery of ‘key sites’ to meet the housing need over the Plan period. Specifically, the Plan makes provision for 2,278 units in these Key Sites, which equates to circa 65% of RLDP allocations in the housing supply. The 5 key sites that are allocated in the Deposit Plan are as follows:

• Land at North West Barry – 376no. units;
• North of Dinas Powys – 250no. units;
• Land at Readers Way, Rhoose – 520no. units;
• Land at Church Farm, St Athan – 532no. units; and
• Land to the West of St Athan – 600no. units.

We object to the current housing supply to allocate 2,278no. (65%) of units across strategic sites, as this makes for a risky and unrobust strategy for delivering housing, and in turn, meeting the identified housing need over the Plan period.

As stated in previous representations, there is concern that the proposed timing and phasing of the proposed Key Sites is unrealistic and unrobust, and in turn, undermines the soundness of the Plan, given the heavy reliance on Key Sites delivering new homes across the Plan period. Whilst it is not disputed that the sites would have gone through rigorous assessment to inform their proposed allocation, the timescales for securing planning permission (with all associated conditions discharged) is considered to be unachievable. This is particularly the case for the following timescales that are set out in the Housing Trajectory that underpin the Plan:

• “Time period of pre-application discussions/PAC consultation” – 4 months
• “Time between submission of planning application and determination” – 6 months
• “Time taken from planning consent to the discharge of relevant conditions to enable site construction” – 4 months

It is considered that the above timescales are fundamentally unrobust, and result in a distorted position of housing sites over the RLDP Plan period. It is not considered that these reflect or are informed by the timescales that are currently being incurred for planning applications submitted for major housing sites across Wales. It is rather the case that such applications would typically be determined 1-2 years following submission, given that there are a wide range of stakeholders involved in the determination of major planning applications – which often adds to the delays associated with the determination of such applications.

It is equally the case that the assumptions in the trajectory are solely based on expected timescales for processing formal submissions made to the Council, and do not factor in the timescales associated with, and needed for, the preparation of the material for submission.

It is assumed that these timescales have not considered that such major developments can be subject to the need to undertaking and submitting an Environmental Impact Assessment (EIA), which adds another layer to the determination of any planning application – given the additional considerations that form part of this process. As such, any site subject to EIA would very likely result in further delays extending beyond the timescales set out in the trajectory. Equally, as set out above, the preparation of an application subject to an EIA requires even more detail and assessment, which only further adds to the preparation stage (which has not been factored into as part of the trajectory). Accordingly, it is not considered that the trajectory contains any contingency if any site is required to undertake EIA as part of their application.

For the reasons stated above, it is unlikely that the sites will yield in full, particularly those sites which are expected to deliver housing right up to the final year of the Plan period (‘Land at Readers Way’ and ‘Land to the West of St Athan’). These sites do not allow for any ‘slippage’ should any delays arise through the development management process (which for the reasons set out above, will very likely be the case), and as such, a gap in housing delivery will be brought about as a result of these sites not yielding in full.

Given the proposed ambitious timescales set out for the delivery of the Key Sites, it is considered the housing trajectory is unrobust, and in turn, undermines the soundness of the Plan as a result. A change in strategy should be pursued whereby a greater proportion of small to medium sites are allocated for housing in the Plan period, which are more likely to fully yield given that such sites are subject to less assessment and consideration compared to strategic sites. This would make for a more robust strategy, where a greater number of small to medium sites can deliver housing in the short and medium term of the Plan period, whereas the strategic sites represent a more longer-term strategy to deliver housing – which would then spill into the next Plan period.

Accordingly, we object to the Deposit Plan in its current form, where there is an overreliance on housing need to be met through the delivery of the Key Sites, which we consider to be unrobust, and undermine the integrity and soundness of the Plan. The current strategy of the Plan is at significant risk of not delivering the level of housing expected based on the sites allocated, as least as swifty as identified in the housing trajectory. Should no change be made to the Plan to address the above issues, then it is extremely likely that the Plan would ‘fail’ in meeting the identified housing need.

Windfall Sites

It is noted that the RLDP is made up of the following:

• Existing land supply (3,838 units)
• Windfall sites (1,303 units)
• Allocated sites (3,521 units)

Para 6.69 states that “Analysis of historical delivery of housing indicates that on average small windfall sites (sites of less than 10 dwellings) have provided some 53 dwelling completions per year, and large windfall sites (10 dwellings or greater) contributed on average 80 dwellings per year. Overall, it is projected that windfall sites could contribute a further 1,303 dwellings over the remainder of the plan”.

As set out in our previous representations to the Housing Trajectory, we would object to the expected numbers of completions expected during the Plan period, given that there are a number of issues with delivering housing in Wales and given past completions rates for The Vale of Glamorgan – which is discussed in greater detail later in this submission. Again, this results in the Plan being at risk of not delivering the level of housing expected based on the sites allocated – including any windfall sites.

St Athan Train Station

The RLDP Sustainable Growth Strategy comprises six key elements, of which the following is set out in respect to the allocation of new housing growth in the Authority:

“3. Focusing development at locations that are well served by existing and proposed rail stations as part of the South Wales Metro and in areas with good bus links.”

The strategy outlines that a feasibility study for a station in St Athan had been undertaken in 2022, which identifies that a new station could be located in St Athan, subject to further investigation work. Accordingly, in line with the spatial strategy adopted for the RLDP (i.e. focus development around sustainable transport nodes), St Athan was identified as a ‘Strategic Opportunity Area’ to accommodate strategic growth – through the proposed allocation of two key sites : ‘Land at Church Farm’ and ‘Land West of St Athan’. These sites have been identified to deliver 532no. and 600no. units respectively in the Plan period. These are separate to, and are in addition to, the 51no. units that have now been attributed to the site ‘Land South of Clive Road’ and 80no. units attributed to ‘Former Stadium Site, adjacent to Burley Place’ in St Athan. Accordingly, in total, the Housing Trajectory makes a provision for a total of 1,263no. homes to be delivered in St Athan over the Plan period.

It is now the case, however, that the proposed railway station at St Athan is not in the first phase of delivery for new stations in South Wales – as confirmed in the ‘Today, Tomorrow, Together: A vision for rail across Wales and Borders’ (February 2026) recently published by Transport For Wales. This paper acknowledges that a new railway station at St Athan would represent a longer term opportunity, and therefore, will not be delivered in the short term / within the Plan period of the emerging Plan. Equally the Council have not provided any evidence to contradict this, and therefore, it is very unlikely that any new train station will be delivered in St Athan over the Plan period. This brings about significant questions regarding the suitability and acceptability of the proposed allocations set out above.

The strategy to allocate new housing growth is predicated on focusing residential development around sustainable transport nodes, and given that St Athan will be without any railway station in the Plan period, it is not considered that the sites align with the strategy of the RLDP. Accordingly, the wider Housing Trajectory is considered to be unsound, given that a total of 1,263no. homes (36% of the Plan’s new housing allocations) are expected to be delivered in St Athan within the Plan period.

It is considered that there has been an overprovision for housing growth in St Athan generally, and this issue is now further exacerbated by the lack of any forthcoming rail provision. Given this, to add further sites for housing in this location over and above the original provision is considered to be unsound. As set out above, the justification to allocate sites at St Athan has relied heavily on the railway station being delivered in the Plan period, and as such, there are serious questions marks associated with the acceptability of the proposed allocated sites - given their incompatibility with the core strategy of the RLDP.

In terms of the expected delivery of the Key Sites in St Athan, it is noted that the trajectory identifies that for the majority of the Plan period, both sites will be delivering 80no. dwellings per annum on each site (equating to 160no units in total). Whilst these are two separate sites, we seriously question the realistic prospects of the significant number of homes being built simultaneously on two sites in proximity to one another – given the considerable logistical issues that would be brought about.

Accordingly, it remains that there are serious questions regarding the suitability and acceptability of the proposed allocations at St Athan, which do not accord with the strategy adopted for the RLDP – to focus housing growth on settlements that are supported by railway stations. Moreover, the scale of development proposed at St Athan is also not considered to be proportionate, with a significant number of homes delivered in a location not served by a railway station.

Rolled forward LDP Sites

The proposed land supply within the housing trajectory includes provision for ‘rolled forward’ LDP sites, which contribute to the total of ‘Proposed Additional Housing Allocations’ forming part of the housing supply. Specifically, a total of 1,242no. units have been identified as additional housing allocations, of which 959no. are expected to be delivered on the rolled forward LDP sites. As such, these sites are to provide for a significant proportion of additional housing in the Plan period (specifically circa 77%).

The Development Plans Manual (DPM) sets out that allocations rolled forward from a previous plan will require careful justification for inclusion in a revised plan. The DPM outlines that “there will need to be a substantial change in circumstances to demonstrate sites can be delivered and justify being included again. Clear evidence will be required that such sites can be delivered.” The below table included in the consultation document provides a breakdown of the rolled forward LDP sites, and in particular, sets out the status of each site:
Table 6: Existing LDP allocations to be carried forward

The above table evidences that the current LDP has under delivered in regard to its targeted unit number of the Plan period, given that these sites did not yield any housing over the current Plan period. This is further exacerbated by the Land Bank sites that have also not delivered any housing across the existing LDP period, amounting to 1,860no units. Accordingly, when considering the non-delivery of both rolled forward LDP sites and Land Bank sites, this amounts to an approximate shortfall of 2,189 homes being delivered, or 33% of the total housing supply identified for the current LDP (8,525no. dwellings).

It is therefore considered that, as a minimum, the units carried over from the LDP (without planning permission) should be a surplus to the housing supply proposed for the RLDP, as opposed to being relied on to deliver the housing need over the Plan period. This is particularly the case for the two sites (Land to the west of Pencoedtre Lane, and Land between Northern Access Road and Eglwys Brewis Road) which do not currently have any active planning application submitted for their development. These sites total an amount of 370no. units to be delivered in the Plan period, which represents more than a third of the additional housing allocations to make up the housing supply.

As such, it is considered that the unmet need deriving from the existing LDP is still present – indeed it has grown, and will continue to do so, not least when considered in conjunction with the projected population growth over the coming years to 2036, and the aspirations for growth in the Plan’s strategy.

Accordingly, in order to secure the targeted level of housing, a greater level of provision for new allocations should be applied in order to meet the housing requirement. This would bring about better certainty that the housing requirement is met by the housing supply over the Plan period, not least given that the current Plan failed in this respect. Without a re-apportioning of the housing supply, it is considered that the Plan would heavily rely on the contingency (i.e. rolled forward LDP sites) coming forward in the Plan period, yet there is uncertainty that these will yield in full over the new Plan period. This raises issues of ’soundness’, and risks rendering the Plan unrobust.

Housing Delivery Rate Assumptions

As set out in our previous representations to the Housing Trajectory consultation, we have considerable concerns in relation to the proposed delivery of the sites identified in the trajectory – which we do not consider are robust or reasonable.

Appendix 1 of the Deposit Plan sets out the development trajectory bar chart – which illustrates the proposed delivery of housing, on a per annum basis, over the Plan period.
Extract of Housing Trajectory (annotated by GJP - red dotted line)

It is our view that the trajectory makes for an unrealistic and unrobust delivery rate of housing, which does not reflect the pattern of housing completions in the Vale of Glamorgan. We therefore have concerns regarding the soundness of the trajectory, not least that there remain significant uncertainties as to the delivery of the Key Sites (as discussed earlier in these representations).

Firstly, the graph / trajectory illustrates a large ‘spike’ in terms of housing delivery in the year 2027-28, which is considered to be a marked and pronounced step change in the rate of delivery. This envisages / relies on a significantly higher rate of delivery than previous years in the Vale of Glamorgan (2021 through 2021 – as depicted by the green columns). It is considered that this level of delivery is unlikely to materialise, not least given prevailing market circumstances, past rates of delivery on the ground, and also in light of levels achieved across Wales and the UK in general.

The published trajectory shows that the average level of completions from 2021 - 2025 has been approx. 400 - 500 units, however, the chart shows that from 2027 – 2028, completions are expected to rise to approx. 1,000 units per year. The expected delivery levels in the trajectory therefore show and assume a doubling in delivery rates and unit numbers (an increase of approx. 100% relative to past rates). There is no clear evidence as to how this level of completions can be achieved let alone guaranteed. This is the case in particular given that the forthcoming years (2025-2027) are expected to see performance (yield) drop significantly (delivery rates in 2025 – 2026 and 2026 – 2027). The chart shows only approx. 200 units being delivered over these years. It is therefore unclear how completion rates are expected to rise so quickly (from 200 in 2025-26 to 1000 in 2027-28), and by such a significant amount. The assumptions in the trajectory are wholly unrobust in our view.

It is also the case that the anticipated delivery of housing fails to be consistent within and across the Plan period. It is unclear as to why completions rates aren’t spread out more evenly throughout the Plan period - to ensure a robust and most realistic housing trajectory until 2036. By comparison to the marked increase in the rate of delivery between and over the period 2027 to 2031, there is then a marked fall-off or drop in delivery towards and by the end of the Plan period. Indeed, in the final year, the level of completions are expected to be lower than the period 2021-2025.

Accordingly, we consider that the housing trajectory, as proposed, is entirely manufactured and unreflective of the past completion rates, as well as the recent published completion rates provided by Welsh Government recently in August 2025. As set out in our previous representations, it has been evidenced that there has been a general decline in the number of new dwellings started and completed.
Description of Figure 1: ‘New House Building: April 2024 to March 2025’
As identified in the graph above, in 2024-25, 4,631 new dwellings were completed, which represents 3% fewer than the previous year. This figure represented the second lowest number on record, with the lowest number recorded in 2021-22, a year heavily affected by the coronavirus (COVID-19) pandemic (in 2021-22, 4,616 new dwellings were completed) The New Housing Pipeline Report Quarter 3, 2025 Report (December 2025) published by the HBF evidenced that the number of residential units approved in the UK fell by 7% during the third quarter of 2025, extending the decline seen during the first half of the year. At 45,075, the number of units approved was 34% down on the third quarter of 2024 and the lowest quarterly total since 2012 Q2. At 146,798, the overall number of units approved during the first nine months of 2025 was 25% lower than a year ago.
HBF Graph Illustrating Residential Approvals (2006-2025)

The above graph clearly shows a pronounced downward trend in the number of residential planning approvals over the period, particuarly with a sharp decrease seen since 2020. Further, the HBF document ‘Increasing Housing Supply in Wales’ (4th September 2025) clearly shows that The Vale of Glamorgan has not met the housing delivery requirements in recent years in 2023 – 2024 – along with every other authority in Wales (except Newport). Accordingly, this further adds to the argument that historically The Vale (and most other authorities) have underprovided. This adds considerable uncertainty on the assumed transformation in yield and delivery as built into the trajectory.
Graph: Housing Delivery as a proportion of annual housing requirement in Wales per Authority

More recently, the Welsh Government has released its new estimates of housing need (Estimates of Additional Hosing Need: 2025-based – February 2026). The estimates show how many new homes need to be built over the next twenty years to address existing unmet need as well as newly arising need. The figures set out that around 8,700no. new homes a year are needed over the next Senedd term up to 2030 to meet new housing need. Additionally, there is an unmet need for 9,400 affordable homes.

Overall, this represents more than double 2024/25 levels of supply, where just 4,638 new homes were built.

HBF: Estimates of Housing Need

HBF: Actual Delivery vs Estimates of Need

The above graphs unequivocally evidence that historical rates of delivery of housing in Wales has remained low, and moreover, significant numbers of housing need to be allocated in order to meet the estimate of need. It is not considered that the housing trajectory, in its current form, is robust to meet the housing need over the Plan period, given the uncertainties of the Key Sites, and the level of housing delivery that has been identified for the Plan.

Affordable Housing-Led Sites

HG4 - Rural Affordable Housing Led Sites

Policy HG4 of the Deposit Plan identifies four sites to be allocated as affordable housing-led sites, totalling approximately 122 dwellings within the plan period. Given the target levels of achieving 3,070 affordable dwellings over the course of the Plan period (up to 2036), it is not considered that this policy goes far enough to address the target and level of affordable housing need.
It is noted that the number of units identified for each site relate to the ‘total’ number of units delivered, as opposed to the affordable housing provision. Accordingly, it can be assumed that circa 50% of each allocation will comprise affordable units (given each site is affordable-led), which would equate to a total provision of circa 61no. units. The contribution from the affordable housing-led sites would only equate to 2% of the total need (3,070no. units). Even when coupled with the affordable housing provision from open market sites and 100% exception sites, the total delivery of affordable housing will still be nowhere near enough to meet the overall affordable housing need over the Plan period. Accordingly, it is considered that inadequate provision has been made for such sites.

Insofar as to the sites chosen and allocated are concerned, it is clear from reviewing the Stage 1 and Stage 2 Candidate Site Assessment that the allocated sites HG4(1) – (4) were not considered acceptable due to being outside the strategic growth areas, and were considered to be unacceptable intrusions into the open countryside. After being resubmitted as affordable housing-led sites, the sites were allocated, some with a smaller area in order to accommodate less dwellings in total.

The sustainable credentials of the sites allocated is not disputed, and it is acknowledged that these minor rural settlements have the ability to accommodate further growth, in the form of affordable-led housing allocations. However, it is considered that Land at Ystradowen (Site ID: 430 / 4060) should also form an allocation as part of this policy, given its high sustainability credentials and its appropriate location to accommodate a suitable level of development. Please refer to the previous representations made to the Housing Trajectory Consultation (dated 17th October) and Annex 2 for further, more detailed comments regarding the above sites.

The LHMA 2023 shows that there is a need for 230 affordable homes in the Cowbridge housing market area / ward - which Ystradowen is located within. As such, there is an identified need for affordable housing in this area, something which the site could address through an allocation – see Annex 2.

Securing further delivery of Affordable Units

As set out above, the affordable housing-led allocated sites only provide 122no. affordable dwellings, which comprise 4no. allocated sites that are expected to deliver approximately between 20 – 50 dwellings. However, the RLDP sets a target of 3,070 affordable homes to be delivered in the Plan period. This means that affordable housing-led allocations make up less than 4% of the target provision and will only make provision for 2% of the targeted number. We would therefore object to the sites included within Policy HG4 and would suggest that more sites should be allocated as part of the policy in order to secure delivery of a higher number of affordable housing units to mere the target.
Whilst it is acknowledged that the Key Sites will provide for a significant proportion of affordable housing, as set out above in these representations, there is serious concern regarding the deliverability of these sites, which would result in a significant gap of affordable housing delivered.

A greater number of affordable housing-led sites allocated would ensure there is sufficient contingency built into the Plan, to ensure that the overall affordable housing need is met over the Plan period. Failure to do so would result in affordable housing need being unmet, with demand continuing to outstrip supply.

Previous representations to the Preferred Strategy (dated 14th February 2024) provided comment on the sustainability scoring of Ystradowen and the proposed site. As outlined within these representations, it is considered that the site (ID 430) represents a sustainable, deliverable and acceptable site. The site is located within 2.7 miles Cowbridge and
2.8 miles of Pontyclun. Due to the availability of frequent bus services, and active travel links, key services are readily available to access for any residents within Ystradowen without the need to travel by car. The site is within a maximum 9- and 14-minute bus journey (respectively) of the following key services:

• Cowbridge and ‘Y Pant’ Comprehensive Schools;
• Cowbridge Health Centre and Old School Surgery; and
• Cowbridge Town Centre, and Talbot Green / Pontyclun / Llantrisant (Strategic Growth Area), for various Retail Services.

Accordingly, the settlement of Ystradowen represents an acceptable location to allocate an affordable housing-led site, given the access to existing services and facilities that would serve future residents of the site.

To conclude, the settlement, location and site are inherently suitable and deliverable, and will make a significant contribution to achieving and realising the housing and economic development needs of Ystradowen, support the surrounding settlements, and the Plan area as a whole. As such, the site should be considered further.

Comments on Specific Policies

HG5 - Affordable Housing Exception Sites

Given the unmet need and extant backlog of affordable housing, as identified within the LHMA (2023), it is noted that an Affordable Housing Exception Sites policy has been adopted in order to assist in the delivery of affordable housing. Policy HG5 sets out the specific criteria where proposals for 100% small scale affordable housing developments will be permitted outside settlement boundaries. The current policy wording for the Affordable Housing Site Exception Policy and the criteria listed out in the policy is generally supported.

That said, it is noted that a ‘cap’ of 10 dwellings (as referenced within supporting text Para 6.140) is set. This should be amended due to such a ‘cap’ limiting the flexibility of the policy, in particularly for sites coming forward as part of this policy in Minor Rural Settlements.
As such, we would suggest that supporting Para 6.140 should be amended in order to allow for further flexibility for sites in Minor Rural Settlements to come forward and to deliver affordable housing, given that the criteria set out in the policy would already protect and restrict the extent of any development as it stands. Therefore, the proposed amendments to Para 6.140 are outlined below in red:

6.140 “For the purposes of this policy, ‘small-scale’ will generally mean no more than around 10 dwellings on sites adjoining Minor Rural Settlements. In Primary Settlements outside the Strategic Growth Area, proposals for more than 10 dwellings may be acceptable where required to meet a specific need and where the number of dwellings is proportionate to the size of the settlement. In assessing the scale and extent of any proposed local needs housing, consideration should also be given to affordable housing already planned in the ward or nearby area, including sites with existing planning permissions and those allocated in the RLDP. The size and type of affordable housing proposed should reflect the identified local need in the area.”
The above suggested wording would achieve a more flexible policy, which would allow for a variety of scaled applications to secure planning permission for solely 100% affordable housing across the Authority area. This greater flexibility would enable the policy to make a significant contribution towards meeting the affordable housing need – which, as set out earlier is in considerable need.
SECTION 3. Suitability of the site for development

The site promoter objects to the overall assessment of the site, in that it is not considered suitable for further development in the Plan. The promoted site has undergone extensive scrutiny and appraisal at a high level to ascertain the qualities of the site, in light of all identified material considerations which relate to the proposals.

The delivery of the site will yield much needed housing (including Affordable housing) and contribute to the overall supply in the new Plan period, whilst making effective use of a suitably located site for residential development.

Moreover, as set out in ‘Annex 2’ of our representations, the site has overcome the ‘constraints’ set out in the Candidate Site Assessment undertaken for the site, which demonstrates that the proposal is both acceptable and deliverable.

Deliverability of the Site

In summary, the site seeks to deliver the following key elements:

• Provision of circa 67 new-build residential dwellings (including 50% affordable housing provision);
• A mix of house-types and tenures across the site to cater for a variety of needs;
• Creation of a new primary access into the site;
• Connection to pedestrian links within the wider area;
• Public open space; and
• Green Infrastructure; and
SUMMARY AND CONCLUSIONS

In summary, the site promoters:

• Object to the distribution of growth proposed for the Plan area, with a more balanced and equitable distribution of housing sites required in order to meet the identified housing need;
• Object to the level of growth identified for the Plan period;
• Object to the housing trajectory that underpins the delivery of housing within the Plan period – which is considered to be unrealistic and unrobust, leading to serious uncertainty regarding the “soundness” of the Plan;
• Object to the over-reliance on Key Sites and Rolled Forward Sites in making up the Plan’s housing land supply;
• Object to the scale and timing of delivery of sites in / around St Athan – all of which are predicated on railway station provision which will not be realised in the Plan period;
• Object to the under-provision of sites under Policy HG4 – Rural Affordable Housing-Led sites, not least given their extremely limited contribution to the targeted need for affordable housing;
• Object to the current wording of the HG5 Policy ‘Affordable Housing Exception Sites’ which requires greater flexibility to play an important role in delivery much-needed affordable homes across the Authority; and
• Object the Council’s assessment that the site is not considered suitable for development.

The site and proposals are consistent with the RLDP strategy, other Vale of Glamorgan strategies, and the requirements of Planning Policy Wales and Future Wales. It will make a significant contribution to the Vale’s identified housing requirement in the RLDP period and will provide for a wide range of uses that will support the wider community whilst embodying principles relating to placemaking and the well-being of future generations.

The site has no fundamental constraints and has the ability to deliver significant economic, social and environmental benefits for the benefit of future residents and the existing local community. The site is demonstrated to be viable, being able to deliver policy-compliant levels of affordable housing and given its location within a strong market area, will benefit from high delivery rates.

ANNEX 2
SECTION 4. A summary of the suitability of the site for development including a Response to the Candidate Site Assessment

Land at Ystradowen (Site ID: 4060)

This section of the overall representations to the Deposit Plan is to respond to, and address, the Council’s assessment of the site. The ‘Candidate Sites Assessment Deposit Plan Stage v2’ for ‘Land at Ystradowen (Site ID: 4060)’ sets out that the position of the site at the Deposit Stage is as follows:

“Amendment of proposed use from housing to affordable housing led. Previous site reference 430. The original assessment concluded that whilst the site was adjoining the existing LDP settlement boundary this is by virtue of an existing adopted plan LDP allocation this is currently under review. Notwithstanding this the site would represent unacceptable intrusion in to the open countryside.
The LDP site in question has subsequently been granted planning permission for housing. This site will serve the future needs of residents in the area and it is not considered that additional land should be allocated in this location.”

In terms of the first paragraph, the assessment/conclusion implies and suggests that ‘Land at Ystradowen’ (4060)’ does not adjoin the existing LDP settlement boundary as the allocated site (‘Land off Sandy Lane, Ystradowen’) has not been built out – “by virtue of an existing adopted plan LDP allocation this is currently under review”. Detailed representations have been made and submitted previously at the Housing Trajectory (see Appendix B& C) that outlines that this is fundamentally incorrect. This is not repeated in full here, with just the main points re-iterated.

First and foremost, ‘Land at Ystradowen (4060)’ directly adjoins the existing LDP settlement boundary. Secondly, there has been a significant change in the position and circumstances. The allocated site (‘Land off Sandy Lane, Ystradowen’) is currently being “built out”, with work commencing on site (see photographic evidence in Appendix C)
- post the implementation of the planning permission ref. 2023/00948/FUL (post approval on 9th December 2024). Accordingly, the site no longer adjoins “the existing LDP settlement boundary … by virtue of an existing adopted plan LDP allocation … currently under review”. Given this, the ‘Land at Ystradowen’ site boundary therefore directly adjoins/is adjoining the LDP settlement boundary and the site promoted herein.

With regards to the second paragraph, the assessment/conclusion outlines that “The LDP site … will serve the future needs of residents in the area and it is not considered that additional land should be allocated in this location”. The arguments and case presented in Appendix B & C. There is a clear overreliance on ‘rolled forward’ sites / existing allocated sites. A total of 1,242no. units have been identified as additional housing allocations, of which 959no. are expected to be delivered on the rolled forward LDP sites. As such, these sites are to provide for a significant proportion of additional housing in the Plan period (specifically circa 77%). We believe that a greater level of growth is achievable and should be considered. Not least as there is an approximate shortfall of 2,189 homes being delivered, or 33% of the total housing supply identified for the current LDP (8,525no. dwellings). As such, it is considered that the unmet need deriving from the existing LDP is still present – indeed it has grown, and will continue to do so, not least when considered in conjunction with the projected population growth over the coming years to 2036, and the aspirations for growth in the Plan’s strategy. Accordingly, in order to secure the targeted level of housing, a greater level of provision for new allocations should be applied in order to meet the housing requirement. The provision of housing should be adjusted to rebalance the provision to include new allocations in lieu of rolled forward LDP sites in the housing supply. The “future needs of residents in the area” will therefore not be met/served by just this site, and it is considered that additional land should be allocated in this location.

Furthermore, to reinforce, illustrate, and evidence the point in specific reference to the site the subject to this representation (located in Ystradowen), reference is made to application ref. 2013/00856/OUT – ‘Land off Badgers Brook Rise, Ystradowen’. The Final Report of the application states that “Ystradowen is considered a sustainable settlement for further housing development” – i.e. “additional land should be allocated in this location”.

While the issues the Council have raised in their assessment of the site have been addressed and discussed within the representations made at the Preferred Strategy stage of the Plan (see Appendix B), a similar ‘scoring’ exercise has been undertaken as part evidence base for the Deposit Plan. As such, it is still pertinent to consider and respond to the Council’s assessment of the site as part of these representations. A comparison between the site assessments undertaken at both the Preferred Strategy stage and Deposit Plan stage can be seen below for reference:
BP18 Candidate Ste Assessment at Preferred Strategy Stage
As demonstrated above, there has been a positive change to the scoring attributed to the site (‘Land at Ystradowen’). The change is a positive change to the ‘Infrastructure Availability’ section changing from: ‘Grey’ (no score) to ‘Amber’. Infrastructure Availability is outlined as: “Existing or proposed services would be suitable subject to local improvements without impacting on development viability and/or delivery timescales” (see below):
The explanation for the scoring provided by the Vale sets out that “Sites will be assessed against the availability of water connections to the site, in addition to the method of foul sewage disposal from the site. Consultation shall be undertaken with DCWW to determine whether there is sufficient capacity to the wastewater treatments works, and how it links into DCWW’s Capital Investment Programme.
Where consultation indicates limited capacity, or the site is located away from a viable connection this may impact on the deliverability/viability of a site should this require significant connection costs or upgrades. Consequently, the Council shall require site proposers to undertake detailed site viability assessment to determine the impact that additional cost shall have on development cost and deliverability timescales.”

As set out above, this is a positive change. This is most likely derived from the allocated site (‘Land off Sandy Lane, Ystradowen’) currently being “built out”, with work commencing on site that would facilitate and improve the ‘Infrastructure Availability’. This re-iterates the point made previously re the incorrect assessment reached, and the ever changing position of this site – which will only improve given the neighbouring allocated site (‘Land off Sandy Lane, Ystradowen’) being “built out”.

Land West of Maendy Road, Aberthin (Site ID: 2299)

There are material similarities between ‘Land West of Maendy Road, Aberthin (Site ID: 2299)’ and the site the subject of these representations. It is therefore considered pertinent to assess and compare the suitability of ‘Land West of Maendy Road, Aberthin’. Not least as ‘Land at Ystradowen (Site ID: 4060)’ is for a “small-scale affordable housing led development in a minor rural settlement”, within “the ward of Cowbridge”.

The site ‘Land West of Maendy Road (Site ID: 2299)’ has been registered as an Affordable Housing Led Allocation candidate site for the RLDP, however from our review of the evidence base submitted as part of the Housing Trajectory consultation, there was no assessment and critique of this site at this stage. This raises questions regarding the “soundness” of this site, given it appears this sites acceptability and inclusion was pre-determined.

The site (‘Land West of Maendy Road’) has since had a detailed assessment and critique published, however concerns still remain regarding the “soundness” of the site which forms part of the intended housing land supply. The ‘Stage 2 Detailed Site Assessment’ summary undertaken for ‘Land West of Maendy Road’ has been extracted below:

“The site is proposed for a small-scale affordable housing led development in a minor rural settlement, which would accord in principle with the strategy. Aberthin itself has limited services and facilities, but is within reasonable walking distance of primary and secondary school provision with the wider range of services and facilities in Cowbridge just over 2000m away. The settlement is also served by public transport, although this is relatively infrequent.
The 2023 LHMA indicated that the ward of Cowbridge has a need for 230 additional affordable units over the next 15 years and this site could make an important contribution in meeting that.”

As mentioned previously, there are material similarities between ‘Land West of Maendy Road, Aberthin (Site ID: 2299)’ and ‘Land at Ystradowen (Site ID: 4060)’ (the subject of these representations). Firstly ‘Land at Ystradowen (Site ID: 4060)’ is also for a “small-scale affordable housing led development”, that is “in a minor rural settlement” (Ystradowen). Accordingly, it should follow that as ‘Land West of Maendy Road, Aberthin (Site ID: 2299)’ “would accord in principle with the strategy”, ‘Land at Ystradowen (Site ID: 4060)’ would also “accord in principle with the strategy”.

Furthermore, there is no material difference between the following assessment of Aberthin and Ystradowen:

“Aberthin itself has limited services and facilities, but is within reasonable walking distance of primary and secondary school provision with the wider range of services and facilities in Cowbridge just over 2000m away. The settlement is also served by public transport, although this is relatively infrequent.”

There is no material difference between ‘Land West of Maendy Road’ and ‘Land at Ystradowen’ in sustainability terms.

As set out in our representations to the Preferred Strategy, we reviewed the key services in proximity to the site. The following services were identified as part of that review:

• In terms of public transport, there are two bus stops located approximately 0.2 miles (4-minute walk) from the site (‘Land West of Maendy Road’), with the 321 providing services between Llantwit Major and Talbot Green;

• In terms of public transport, there are two bus stops located approximately 400m (7-minute walk) from the site (‘Ty Mawr Close’), with the ‘321 Nat Group Service’ providing services between Llantwit Major and Talbot Green. The 321 service is the same bus service that serves ‘Land West of Maendy Road’ / Aberthin;

• The site is also located 0.2 miles (4-minute walk) from The Farmers Arms Pub and 0.2 miles (4-minute walk) from The Hare and Hounds Inn; and

• The site is located 0.2 miles (5-minute walk) from Aberthin Village Hall.

Given the above, “The settlement (Ystradowen) is also served by public transport”.
Furthermore, Ystradowen is located only 2.7 miles from Cowbridge (9-minute bus journey). The “primary and secondary school provision with the wider range of services and facilities in Cowbridge” mentioned in relation to Aberthin are therefore also in close proximity to Ystradowen.

Given the above, any candidate site at ’Land at Ystradowen’ (the subject of these representations – Site ID: 430 / 4060) is no less sustainable than the site at Aberthin (Site ID: 2299).

Not least as the following additional key services are located within Ystradowen and therefore in close proximity to the promoted site:

• The site is also located 300m (3-minute walk) and 600m (10-minute walk) from Sports Pitches/Playing Fields such as ‘Ystradowen Children’s Park’, and the 3/4G Sports Pitch at ‘Ystradowen Petanque Club’; and
• Furthermore, the site is located 480m (7-minute walk) from the ‘Murco – Tudor Garage’ which can provide basic goods to meet day-today needs such as bread, butter, milk etc.

Furthermore it is important to note that the above scoring criteria is very limiting, and does not take into account the important role and proximity of settlements in a wider context. For example, it does not take into account the important role and proximity of the Principal Settlement and Strategic Growth Area (as defined in the RCTCBC LDP) of Talbot Green / Pontyclun / Llantrisant which is 2.8 miles to the north (14-minute bus journey). Ystradowen would also naturally align, and function, in association with this Principal Settlement and Strategic Growth Area (of Talbot Green / Pontyclun / Llantrisant) – see Appendix B for full details.

In addition, as set out within the representations made in relation to the House Trajectory (Appendix C), the following extracts have been taken from the Officer’s Reports associated with the applications for the site that directly adjoins the western boundary of the promoted site 430 - ‘Land off Sandy Lane, Ystradowen’ (Housing Allocation 48). An aerial view extract is outlined below to give spatial context:
As set out above, it is important to note that the Final Report of application ref. 2013/00856/OUT states that “Ystradowen is considered a sustainable settlement for further housing development”, due to “the sustainable nature of the settlement”. Furthermore, the Final Report of app ref. 2023/00948/FUL states:

• “Notwithstanding this, the site is located in close proximity to local services and there is a bus stop located nearby. Whilst the comments relating to the reliance and frequency of the bus services have been considered, there still remains a bus service in the area”; and
• “Firstly, as aforementioned, many neighbouring comments refer to the site as unsustainable and have commented on the suitability of public transport and cycle routes etc. This has been addressed above.”

The above clearly evidences that the location has previously been endorsed as, and is currently still found to be, sustainable.

Accordingly, it can be considered therefore that if the proposed allocated site ‘Land West of Maendy Road, Aberthin (Site ID: 2299)’ is considered sustainable and by association suitable to be an Affordable Housing Led Allocation, ‘Land at Ystradowen (Site ID: 430 / 4060)’ is equally suitable to be an Affordable Housing Led Allocation.

The second section/paragraph of the assessment states:

“The 2023 LHMA indicated that the ward of Cowbridge has a need for 230 additional affordable units over the next 15 years and this site could make an important contribution in meeting that.”
‘Land at Ystradowen (Site ID: 4060)’ is also located within “the ward of Cowbridge”. As per the above and outlined by the Authority, there is “a need for 230 additional affordable units over the next 15 years”. It is clear therefore that there is a need for additional affordable units in this ward, and this site would therefore also help to alleviate this need.

This position is a direct contradiction of course of the assessment/conclusion for ‘Land at Ystradowen (Site ID: 4060)’ which stated “it is not considered that additional land should be allocated in this location”. It is clear from the above however that “additional land should be allocated in this location” to satisfy this “need for 230 additional affordable units over the next 15 years” – which ‘Land at Ystradowen (Site ID: 4060)’ can do. This is not least the case given the detailed arguments, case and representations presented and evidenced previously above and in Appendix B & C.
To briefly reiterate there is a clear overreliance on ‘rolled forward’ sites / existing allocated sites which has resulted in the unmet need deriving from the existing LDP being still present. A greater level of provision for new allocations should therefore be applied in order to meet the housing requirement. The provision of housing should be adjusted to rebalance the provision to include new allocations in lieu of rolled forward LDP sites in the housing supply, so these can “make an important contribution in meeting” the “need for 230 additional affordable units over the next 15 years” in “the ward of Cowbridge” – which ‘Land at Ystradowen (Site ID: 4060)’ can do.

As set out within the representations made in relation to the housing trajectory (see Appendix C), a further key consideration to note and one which does differentiate between the relative merits of the ‘Land at Maendy Road, Aberthin’ and ‘Land at Ystradowen’ is that the LDP Proposals Map demonstrates that ‘Land West of Maendy Road’ is within a Special Landscape Area - see below:
Vale of Glamorgan Proposals Map (Land West of Maendy Road outlined in red
Under Policy MG17 ‘Special Landscape Areas’ it is considered that development in SLA could pose an “unacceptable harm to the important landscape of the area”. Accordingly, this development and proposed allocation could therefore cause “unacceptable harm to the important landscape of the area”.

‘Land at Ystradowen’ by contrast does not sit within a SLA (see below). This site would therefore not pose any potential concern in this respect as it would ultimately not cause any “unacceptable harm to the important landscape of the area”.
Vale of Glamorgan Proposals Map (Land at Ystradowen in red)
It is noted that the detailed assessment scores the site ‘amber’ in respect to Special Landscape Area (refer to / see later section for full details), with the assessment methodology setting out that “the site is located within a Special Landscape Area/The Glamorgan Heritage Coast and the development may result in little or no change in character and little or no significant effect on landscape character and visual amenity.”
A detailed assessment of the impact upon the SLA in respect to the development of ‘Land West of Maendy Road, Aberthin’ should therefore be, and will need to be, undertaken as part of any planning application. If it is found that the site causes “unacceptable harm to the important landscape of the area”, this will lead to this proposed allocation being at risk of not being delivered. This will be as a result of its impacts and acceptability at the planning application stage that the landscape and visual impact of development of the site is unacceptable. As such, these proposed affordable units are at a potential considerable risk of being lost and not satisfying the “need for 230 additional affordable units over the next 15 years” in “the ward of Cowbridge” – which ‘Land at Ystradowen (Site ID: 4060)’ can do as it is not located in an SLA.

In addition the draft housing trajectory set out that “there is a need for small scale affordable housing led development (minimum 50% affordable) to respond to local affordable needs and help sustain services and facilities within these rural communities”. There is a clear possibility therefore that this proposed allocation is not delivered (as it is located in a SLA), and so a “small scale affordable housing led development” which is needed to “respond to local affordable needs and help sustain services and facilities within these rural communities” is not provided for. This is clearly an issue. Given however ‘Land at Ystradowen’ does not sit within a SLA – and so not pose any potential concern or cause any “unacceptable harm to the important landscape of the area” – the allocation of this site would be more suitable and “safer” - as there would be no concerns over this proposed allocation being removed and/or not being delivered in this respect (as it is not located in a SLA). This would ensure that affordable units, where “there is a need for small scale affordable housing led development (minimum 50% affordable) to respond to local affordable needs and help sustain services and facilities within these rural communities”, are provided for, and the need for 230 additional affordable units over the next 15 years” in “the ward of Cowbridge” would be satisfied.

As mentioned previously, a detailed assessment and critique has now been undertaken of ‘Land West of Maendy Road, Aberthin (Site ID: 2299)’ as part evidence base for the Deposit Plan using the similar ‘scoring’ exercise. As such, it is again pertinent to consider and respond to the Council’s ‘scoring’ exercise assessment of the site ‘Land West of Maendy Road, Aberthin (Site ID: 2299)’ as part of these representations.

The ‘Summary of Assessment of New Candidate Sites’ table can be seen overleaf for reference:
BP18A Candidate Site Assessment at Deposit Plan Stage
A comparison between the site assessments undertaken for both ‘Land West of Maendy Road, Aberthin (Site ID: 2299)’ (on the left), and ‘Land at Ystradowen (Site ID: 4060)’ (on the right) has been undertaken, and can be seen below for reference:

Having undertaken a review of the scoring for both ‘Land West of Maendy Road, Aberthin (Site ID: 2299)’ and ‘Land at Ystradowen (Site ID: 4060)’, it is clear that ‘Land at Ystradowen (Site ID: 4060)’ scores higher/more positively (i.e. green) than ‘Land West of Maendy Road, Aberthin (Site ID: 2299)’:

• ‘Land at Ystradowen (Site ID: 4060)’: 17/33 criteria are scored green = 52%

• ‘Land West of Maendy Road, Aberthin (Site ID: 2299)’: 12/34 criteria are scored green = 36%

It is clear therefore given the above that ‘Land at Ystradowen (Site ID: 4060)’ is a better site, and should be allocated accordingly.

One key example to note is how the criterion ‘Access to Services and Facilities’ has been scored. For ‘Land at Ystradowen (Site ID: 4060)’ this has been scored green, yet for ‘Land West of Maendy Road, Aberthin (Site ID: 2299)’, this has been scored red. Given this, this corroborates the position outlined previously above that, if the proposed allocated site ‘Land West of Maendy Road, Aberthin (Site ID: 2299)’ is considered sustainable and by association suitable to be an Affordable Housing Led Allocation, ‘Land at Ystradowen (Site ID: 430 / 4060)’ is equally as sustainable – in fact considered more suitable (given its higher scoring in this respect).

Furthermore, we question the “soundness” of the assessment of ‘Land West of Maendy Road, Aberthin (Site ID: 2299)’, given that 7/34 (21%) of the criteria do not appears to have not been assessed – i.e. 7/34 (21%) of the criteria are scored grey. This raises questions regarding the “soundness” of this site, given it appears this sites acceptability and inclusion was pre-determined.

It is clear therefore that if ‘Land West of Maendy Road, Aberthin (Site ID: 2299)’ has been deemed acceptable for allocation, yet ‘Land at Ystradowen (Site ID: 4060)’ scores higher/more positively (i.e. green) than this site, ‘Land at Ystradowen (Site ID: 4060)’ should also be deemed acceptable and be allocated. Not least as the site is “proposed for a small-scale affordable housing led development in a minor rural settlement … would accord in principle with the strategy”, and “could make an important contribution in meeting “a “need for 230 additional affordable units over the next 15 years” in “the ward of Cowbridge”.

Summary and Conclusion

To re-iterate, and to summarise the case made and set out, these representations seek to object to the Deposit Plan published as part of the consultation.

In terms of SECTION 4, and a response to the Candidate Site Assessment at Deposit Plan Stage, the following key points have been made:

• The Council’s ‘Stage 2 Detailed Site Assessment’ justification for ‘Land at Ystradowen (Site ID: 4060)’ is fundamentally incorrect;

• Given the material positive similarities between ‘Land at Ystradowen (Site ID: 4060)’ and ‘Land West of Maendy Road, Aberthin (Site ID: 2299)’, which has been deemed acceptable and allocated, ‘Land at Ystradowen (Site ID: 4060)’ should also be deemed acceptable and allocated accordingly;

• ‘Land at Ystradowen (Site ID: 4060)’ would help to alleviate and satisfy “a need for 230 additional affordable units over the next 15 years” within “the ward of Cowbridge”; and
• ‘Land at Ystradowen (Site ID: 4060)’ scores higher/more positively (i.e. green) than ‘Land West of Maendy Road, Aberthin (Site ID: 2299)’, and so should also be deemed acceptable and be allocated;

Ultimately, ‘Land at Ystradowen (Site ID: 4060)’ is “proposed for a small-scale affordable housing led development in a minor rural settlement”, and as such “would accord in principle with the strategy”. It would therefore “make an important contribution in meeting“ the “need for 230 additional affordable units over the next 15 years” in “the ward of Cowbridge”.

We would therefore object the Council’s assessment that the site is not considered suitable for development.

Summary of These Representations

In short, and to summarise the case made and set out, these representations seek to object to the Housing Trajectory published as part of the consultation on the Draft Housing Trajectory For Housing Stakeholder Group (October 2025) which underpins the Plan and the delivery / realisation of its underlying strategy.

Detailed submissions and objections are raised below in respect to the trajectory information published regarding the soundness and robustness of this information (and it’s consultation), which we do not consider are adequate, robust, or sound to deliver the Plans aims and objectives.

Preface

This Submission sets out the detailed case in support of these representations. The representations are structured as follows:

1. Procedural Consultation Matters;
2. Timing Assumptions underpinning the Trajectory;
3. Housing Delivery Rate Assumptions;;
4. Status & Standing of Sites included in the Trajectory;
5. Key Sites;
6. St Athan Train Station;
7. Geographic distribution of the ‘new’ sites / provision;
8. Detailed comments in respect to ‘new’ sites;
9. Credentials of this site subject to this submission; and
10. Conclusions Procedural Consultation Matters
Firstly, we do not consider that the consultation on the Housing Trajectory information has been procedurally undertaken appropriately or suitably.

Only 14 days have been afforded to parties to make representations on the information provided. This is despite new sites being introduced (at this late stage) i.e. Land South of Clive Road (identified in Table 4), as well as a number of affordable housing-led housing sites being introduced (i.e. those outlined in Table 5). This does not provide an adequate process or timescale for objectors to scrutinise the published content, and to make comments on sites which have been presented for the first time at a late stage in the process.

As part of these representations, we will be making brief comment on the sites which have not been previously consulted upon, namely:
Other Housing Allocations
• Land south of Clive Road, St Athan;

Affordable Housing Led Sites
• Land at Heol Fain, Wick;
• Land west of Maendy Road, Aberthin;
• Land Noth of West Winds Business Park, Fferm Goch; and
• Land to the east of Coliwinston, Colwinston.

It is considered necessary to comment on these sites, given that they form an important and critical part of the housing trajectory, and by association in the Council and Plan reaching their targets. Moreover, these sites have not been consulted on previously. Accordingly we consider it necessary to pass comment on these in order to ensure that the consultation is fair and robust.

As well as limited time given to comment on the information contained within the Housing Trajectory, the LPA have failed to set up a Housing Stakeholder group to agree and discuss the trajectory information and data – with the cover email to the consultation (dated 3rd October 2025) stating “it is considered that it would be the best use of stakeholder time to conduct this engagement via email, particularly as many of the forecasts have been developed in consultation with site promoters including developers and their agents”.

We submit that the stakeholder consultation has not been a transparent nor robust consultation process, given that the Development Plans Manual states at Para 5.66 “A housing trajectory must be prepared to support the Deposit Plan. In order to generate a housing trajectory and associated phasing tables it will be necessary for LPAs to engage with stakeholders through a Housing Stakeholder Group. This will ensure that the timing and phasing of sites is robust and based on up to date information”. Given that this has not taken place, we would raise fundamental concerns that the consultation of the trajectory has not adequately taken place as per the relevant guidance. Afterall, the guidance stresses that a Group should be formed as a necessity. Accordingly, there has not been an adequate process and opportunity to review and comment on the information published, including in respect to the other sites have been introduced at this late stage.

Timing Assumptions underpinning the Trajectory

The assumed and factored in timescales of the various stages of bringing forward sites i.e. the pre-application stage, the planning application process, and the discharge of condition process outlined in the trajectory are considered to be fundamentally inaccurate, and result in a distorted position of the delivery of housing sites over the RLDP Plan period. The assumptions are far too ambitious, and without evidence / are not comparable with the timescales being incurred in processing such stages at the Development Management stage(s).

Specifically, we raise objection to the following timescales which are considered to be extremely ambitious and unrealistic:

• “Time period of pre-application discussions/PAC consultation” = 4 months
• “Time between submission of planning application and determination” = 6 months
• “Time taken from planning consent to the discharge of relevant conditions to enable site construction” = 4 months

In our experience, having submitted a significant number of major and other applications for housing and other forms of development in the last 1-2 years to the Council (and elsewhere in Wales and England), it is extremely unlikely that major applications can be submitted, and planning permissions granted, within the timeframes assumed by the trajectory. A wide range of stakeholders are also involved in the determination of major planning applications, which often adds to the delays associated with the determination of such applications. We would therefore consider that a time period of “6 months” given to all major applications in the housing trajectory is not feasible, and distorts the trajectory timescales for the remaining Plan period.

The assumptions in the trajectory are also solely based on expected timescales for the processing of formal submissions made to the Council, and do not factor in the timescales associated with, and needed for, the preparation of the material for submission (i.e. pre-application enquiry submissions / planning application / discharge of condition details etc). When factored in these will elongate the timescales for bringing forward schemes considerably.

Moreover, it is common practice for larger housing sites and major applications to have a range of pre-commencement conditions attached to a permission once granted. Again, we would raise concerns with the timescales indicated in the trajectory related to this part of the planning process. It is highly unusual and questionable that any technical work required by these conditions (usually relating to drainage and highways matters) would be instructed, completed and submitted within 2 months, and for these to then be signed off / approved in a further 2 months. There are also other technical matters and necessary approvals falling outside of, and over and above, the planning system, such as SAB, s.106, s.38 and s.278 agreements, timescales for which have not been accounted for – and all of which are rarely completed within “4 months” as indicated.

It is therefore highly doubtful that the timescales legislated for in the trajectory for the various stages pre-construction are achievable – with no information about these proposed timescales outlined within the supporting text of the Housing Trajectory. We would therefore raise considerable concerns and objections to these as they stand without full evidence to fully show how these have been calculated, and without there being considerable (and necessary) adjustment to the timescales indicated and factored in.

We would therefore object to the timescales indicted in the ‘Timing and Phasing of Sites’ table, given that the delivery start dates will be pushed back further into the Plan period. Accordingly, and as a result, the Plan is at risk of not delivering the level of housing expected based on the sites allocated, at least as swiftly as is set out in the trajectory.

Housing Delivery Rate Assumptions

We would also raise considerable doubt over the proposed delivery of the sites identified in the Housing Trajectory - which we do not consider are robust or reasonable.

The development trajectory bar chart set out in the consultation material (extracted below) anticipates and legislates for a number of critical events and circumstances – all of which are considered to be unrobust and unsound.
Extract of Housing Trajectory Graph (annotated by GJP – red dotted line)

Firstly, a large ‘spike’ (material increase) in housing delivery is factored in to take place in 2027 – 2028. This is a marked and pronounced step change in the rate of delivery, and envisages / relies on a significantly higher rate of delivery than previous years in The Vale of Glamorgan (2021 through 2025 - as depicted by the green columns). This is considered extremely unlikely to materialise, not least given prevailing market circumstances, past rates of delivery on the ground, and also in light of levels achieved across Wales and the UK in general.

The published trajectory shows that the average level of completions in The Vale of Glamorgan from 2021 - 2025 has been approx. 400 - 500 units. However, the chart shows that from 2027 – 2028, completions are expected to rise to approx. 1,000 units per year. The expected delivery levels in the trajectory therefore show and assume a doubling in delivery rates and unit numbers (an increase of approx. 100%relative to past rates). There is no clear evidence as to how this level of completions can be achieved let alone guaranteed. This is the case in particular given that the forthcoming years (2025-2027) are expected to see performance (yield) drop significantly (delivery rates in 2025 – 2026 and 2026 – 2027). The chart shows only approx. 200 units being delivered over these years. It is therefore unclear how completion rates are expected to rise so quickly (from 200 in 2025-26 to 1000 in 2027-28), and by such a significant amount. The assumptions in the trajectory are wholly unrobust in our view.
The anticipated delivery of housing also fails to be consistent within and across the Plan period. It is unclear as to why completions rates aren’t spread out more evenly throughout the Plan period - to ensure a robust and most realistic housing trajectory until 2036. By comparison to the marked increase in the rate of delivery between and over the period 2027 to 2031, there is then a marked fall-off or drop in delivery towards and by the end of the Plan period. Indeed, in the final year, the level of completions are expected to be lower than the period 2021-2015.

To summarise, we consider the defined position to be wholly manufactured and unreflective of the past completion rates, as well as the recently published completion rates provided by Welsh Government recently in August 2025. In the Welsh Government Statistics Document ‘’New House Building: April 2024 to March 2025’, information on the number of new dwellings started is provided, where building has commenced and those completed for April 2024 to March 2025. Figure 1 provides a graph showing starts in the last 10 years, and it is clear that there has been a general decline in the number of new dwellings started and completed.
Description of Figure 1:.‘New House Building: April 2024 to March 2025’
In 2024-25, 4,631 new dwellings were completed, 3% fewer than in the previous year. This was the second lowest number on record, with the lowest number recorded in 2021-22, a year heavily affected by the coronavirus (COVID-19) pandemic (in 2021-22, 4,616 new dwellings were completed). The New Housing Pipeline Report Quarter 2, 2025 Report (September, 2025) published by the HBF evidenced that the number of residential units approved in the UK fell by 6% during the second quarter of 2025, continuing the decline of approval during the first three months of the year. Wales saw one of the largest declines in the UK in approvals with a decline of 29%.

Further, the HBF document ‘Increasing Housing Supply in Wales’ (4th September 2025) clearly shows that The Vale of Glamorgan has not met the housing delivery requirements in recent years in 2023 – 2024 – along with every other authority in Wales (except Newport). Accordingly, this further adds to the argument that historically The Vale (and most other authorities) have underprovided. This adds considerable uncertainty on the assumed transformation in yield and delivery as built into the trajectory.
Graph: Housing Delivery as a proportion of annual housing requirement in Wales per Authority

The Home Building Sector Skills Plan (Aug 2025) published by the HBF also identified the following issues with the workforce to bring forward built development in Wales:

• “A shortfall in numbers entering roles from the education system;
• An ageing workforce: 25% of the home building workforce is aged over 50, meaning the sector is facing an impending retirement cliff edge;
• Challenges attracting a wider talent pipeline into the sector;
• A lack of understanding of critical future skills needed, and direction from the Future Homes Standard; and
• Output within the sector fluctuating with demand and economic pressures, leading to additional pressures in recruitment and training”.

It is not considered that in the next 1-2 years that any of these issues can or will be substantially corrected – at least sufficiently so to allow for, and enable, the planned delivery rates of new housing completions to be as high as < > 1,000 homes in one year (and for four consecutive years at that).

We would therefore object to the proposed numbers of completion expected during the Plan period, given that there are a number of issues with delivering housing in Wales and given past completions rates for The Vale of Glamorgan. Again, this results in the Plan being at risk of not delivering the level of housing expected based on the sites allocated.

Status & Standing of Sites included in the Trajectory

The proposed land supply within the housing trajectory includes provision for ‘rolled forward’ LDP sites, which contribute to the total of ‘Proposed Additional Housing Allocations’ forming part of the housing supply. Specifically, a total of 1,242no. units have been identified as additional housing allocations, of which 959no. are expected to be delivered on the rolled forward LDP sites. As such, these sites are to provide for a significant proportion of additional housing in the Plan period (specifically circa 77%).

The Development Plans Manual (DPM) sets out that allocations rolled forward from a previous plan will require careful justification for inclusion in a revised plan. The DPM outlines that “there will need to be a substantial change in circumstances to demonstrate sites can be delivered and justify being included again. Clear evidence will be required that such sites can be delivered.” The below table included in the consultation document provides a breakdown of the rolled forward LDP sites, and in particular, sets out the status of each site:
Table 6: Existing LDP allocations to be carried forward
The above table evidences that the current LDP has under delivered in regard to its targeted unit number of the Plan period, given that these sites did not yield any housing over the current plan period. This is further exacerbated by the Land Bank sites that have also not delivered any housing across the existing LDP period, amounting to 1,860no units. Accordingly, when considering the non-delivery of both rolled forward LDP sites and Land Bank sites, this amounts to an approximate shortfall of 2,189 homes being delivered, or 33% of the total housing supply identified for the current LDP (8,525no. dwellings).

It is therefore considered that, as a minimum, the units carried over from the LDP (without planning permission) should be a surplus to the housing supply proposed for the RLDP, as opposed to being relied on to deliver the housing need over the Plan period. This is particularly the case for the two sites (Land to the west of Pencoedtre Lane, and Land between Northern Access Road and Eglwys Brewis Road) which do not currently have any active planning application submitted for their development. These sites total an amount of 370no. units to be delivered in the Plan period, which represents more than a third of the additional housing allocations to make up the housing supply.

As such, it is considered that the unmet need deriving from the existing LDP is still present – indeed it has grown, and will continue to do so, not least when considered in conjunction with the projected population growth over the coming years to 2036, and the aspirations for growth in the Plan’s strategy.

Accordingly, in order to secure the targeted level of housing, a greater level of provision for new allocations should be applied in order to meet the housing requirement. This would bring about better certainty that the housing requirement is met by the housing supply over the Plan period, not least given that the current Plan failed in this respect. Without a re-apportioning of the housing supply, it is considered that the Plan would heavily rely on the contingency (i.e. rolled forward LDP sites) coming forward in the Plan period, yet there is uncertainty that these will yield in full over the new Plan period. This raises issues of ‘’soundness’’, and risks rendering the Plan unrobust.

On this basis, we would object to the Plan if the provision of housing is not adjusted to rebalance the provision to include new allocations in lieu of rolled forward LDP sites in the housing supply.
Key Sites

As set out in previous representations at Preferred Strategy stage, it is considered that the housing supply relies heavily on the delivery of the ‘key sites’ to deliver housing (and meet need) over the Plan period. The total number of housing units attributed to key sites amounts to 2,278, which equates to over 25% of the total provision in the Plan period.

As detailed above, we consider there to be concerns regarding the proposed ‘Timing and Phasing of Sites’ table included in the Housing Trajectory which we consider are not reflective or accurate and will therefore have the effect of delivery start dates being much later into the Plan period than anticipated. The result of this will be that the Plan will be at risk of not delivery the level of housing expected and needed. Moreover, the Housing Trajectory Graph presents an overly ambitious level of housing completions over the Plan period - which the Council consider will be markedly higher than the average levels experienced in the last five years. Again, for the reasons set out above, we consider that these rates of expected completions to have no evidence supporting them, and to be unachievable and unsound.

Insofar as to the removal of the previously proposed site ‘Land at North East Barry’, this site was expected to deliver 900no. units in the Plan period. Following its omission from the housing supply, other sites have been identified, which comprises the inclusion of a new key site (Land at North West Barry), 3no. non-strategic sites, and also affordable housing-led allocations. In terms of the quantum of development attributed to these new sites, this amounts to 659no. dwellings. This is some 250 units less than the 900no. homes that was previously attributed to ‘Land at North East Barry’. Whilst it is appreciated that the number of homes forming part of the existing supply (completions, units with planning permission etc.) have increased since Preferred Strategy stage, there will be a net loss in market housing provision and delivery.

This position is made worse and compounded as a result of accounting for the affordable-led sites in making up the housing supply.

As set out within the Preferred Strategy, these sites are expected to deliver at least 51% affordable housing. These units are not open market units, and will not / cannot contribute to the supply of such housing. These units will contribute to the provision of affordable housing, and will go some way to meeting the acute need for such housing (albeit will not eradicate / address in full the well known and accepted considerable requirement). Accordingly it is considered that these sites should be in addition to the housing supply, as opposed to forming part of the provision. In turn, there would need to be an increase in allocations for non-strategic sites, to ensure that there is sufficient market housing delivery over the Plan period.

Were such changes to be made and introduced, this would achieve and assist realise a more robust and sound housing supply, which will ensure that the identified housing need is met / addressed over the Plan period. Without these changes it is considered that the housing supply is not sufficient, and inevitably, housing need will not be met within the Plan.

St Athan Train Station

As set out in the Preferred Strategy (para A3.29), the strategy seeks to focus development around key sustainable transport nodes. The strategy outlined that a feasibility study for a station in St Athan had been undertaken, which identifies that a new station could be located in St Athan, subject to further investigation work. Accordingly, in line with the spatial strategy adopted for the RLDP (i.e. focus development around sustainable transport nodes), St Athan was identified as a ‘Strategic Opportunity Area’ to accommodate strategic growth – through the proposed allocation of two key sites : ‘Land at Church Farm’ and ‘Land West of St Athan’. These sites have been identified to deliver 532no. and 600no. units respectively in the Plan period. These are separate to, and are in addition to, the 51no. units that have now been attributed to the site ‘Land South of Clive Road’ in St Athan. Accordingly, in total, the Housing Trajectory makes a provision for a total of 1,183no. homes to be delivered in St Athan over the Plan period.

It is now the case that, subsequent to the publication of the Preferred Strategy, the proposed railway station at St Athan is not in the first phase of delivery for new stations in South Wales. The focus in the first phase of such improvements across the region is towards improving connectivity in east Cardiff, Newport, and Magor. Accordingly, it is very unlikely that any new train station will be delivered in St Athan over the Plan period, which significantly questions the suitability and acceptability of the proposed allocations set out above.

The strategy to allocate new housing growth is predicated on focusing residential development around sustainable transport nodes, and given that St Athan will be without any railway station in the Plan period, it is not considered that these sites align with the strategy of the RLDP. Accordingly, the wider Housing Trajectory is considered to be unsound, given that a total of 1,183no. homes are expected to be delivered in St Athan within the Plan period.

It is considered that there has been an overprovision for housing growth in St Athan generally, and this issue is now further exacerbated by the lack of any forthcoming rail provision. Given this, to add a further site for housing in this location over and above the original provision is considered to be unsound. As set out above, the justification to allocate sites at St Athan has relied heavily on the railway station being delivered in the Plan period, and as such, there are serious questions marks associated with the acceptability of the proposed allocated sites - given their incompatibility with the core strategy of the RLDP.

We therefore consider the Trajectory to be both unrobust and unsound, and therefore, we object to the Trajectory in its current form accordingly.

Geographic distribution of the ‘new’ sites / provision

As a general and overarching comment in respect to the additional sites now included within the Plan, and forming part of the trajectory, (and a matter expanded upon when critiquing each of these sites in the next section to this submission), it is clear and evident that these additional sites have been positioned to settlements that have already, and recently, been attributed significant growth in the preceding Plan and plan period.

Significant allocations (which have also contributed to significant levels of affordable housing) have been realised and built out in locations such as Wick and Colwinston). Notwithstanding this, two of the additional sites are now proposed for these recently expanded settlements. Given that the purpose of the affordable housing led allocations is to meet unmet affordable housing need, it is questioned why such new allocations are attributed to settlements that have already seen open market and affordable housing provision, as compared to other comparable settlements that have not received any growth whatsoever over a considerable period of time.

It is considered accordingly that the geographic positioning of these allocations is at odds with their underlying purpose - to meet unmet affordable housing need in communities that have seen no provision.
Detailed Comments in respect to ‘new’ sites

Other Housing Allocations

Land south of Clive Road, St Athan

A summary of the Candidate Sites Assessment at Preferred Strategy Stage has been extracted below for ease:
As set out at the outset of these representations, and whilst we note the findings of the Candidate Sites Assessment at Preferred Strategy Stage (i.e. Suitable for further consideration), we do not consider that the consultation on this site has been undertaken procedurally appropriately or suitably. We therefore consider the consultation on this site is “unrobust” and “unsound”.
As set out previously, the strategy seeks to focus development around key sustainable transport nodes. The strategy outlined that a feasibility study for a station in St Athan had been undertaken, which identifies that a new station could be located in St Athan, subject to further investigation work. It is now the case that, subsequent to the publication of the Preferred Strategy, the proposed railway station at St Athan is not in the first phase of delivery for new stations in South Wales, where the focus is towards improving connectivity in east Cardiff, Newport, and Magor. Accordingly, it is very unlikely that any new train station will be delivered in St Athan over the Plan period, which significantly questions the suitability and acceptability of the proposed allocations set out above.

It is considered that there has been an overprovision for housing growth in St Athan generally, and this issue is now further exacerbated by the lack of any forthcoming rail provision, and as such, to add a further site for housing over and above the original provision is considered to be unsound. As set out above, the justification to allocate sites at St Athan has relied heavily on the railway station being delivered in the Plan period, and as such, there are serious questions marks associated with the acceptability of the proposed allocated sites – given their incompatibility with the core strategy of the RLDP.

Affordable Housing Led Allocations

Land at Heol Fain, Wick
A summary of the Candidate Sites Assessment at Preferred Strategy Stage has been extracted below for ease:
Candidate Site Stage 2 Assessment (Site Ref. 404)
The findings of the Candidate Site Assessment for this site are noted. We are assuming the reason this site is proposed to be allocated is a product of the site promoters/developers heading the findings stated below, and changing the form of development to be in accord with this:
“A market housing led scheme would not be acceptable, but the site could be reconsidered as a small scale affordable housing led development subject to need and viability at a maximum of 50 dwellings. In accordance with the Settlement Appraisal Review, it is considered that Wick could potentially accommodate limited affordable housing led growth.”

Whilst no clearly evident deficiency exists in respect to the site, it is known that Wick has been subject to significant growth and expansion in recent years – not least by virtue of significant housing allocations in the settlement as part of previous plans.

To evidence this, 35% of the 124 units approved on the ‘Rectory Field, St Brides Road’ site (i.e. circa 43 units as per site allocation ref. MG(47) and PP ref. 2014/01424/FUL) were approved as Affordable Housing units. This makes a substantial provision of such Affordable Housing units (and housing generally) in the settlement in recent years.

Other similarly sized and comparable settlements and locations have not by contrast been subject to any growth for some considerable time, and accordingly would warrant and benefit from provision as part of this new replacement plan.

Notwithstanding the location of such provision, and as set out in detail at the outset of these representations, National Planning Policy advocates the high and acute need for affordable housing, whilst recent analysis evidences that there is a housing emergency. These circumstances - coupled with the shortcomings identified and set out earlier in these submissions in respect to the adequacy of provision within the plan (rolled forward sites / inadequate provision etc) – means that notwithstanding any potential allocation at Wick, further provision ought to be made in comparable (previously unprovided for) locations, such as Ystradowen.
Land West of Maendy Road, Aberthin

‘Land West of Maendy Road’ has been registered as an Affordable Housing Led Allocation candidate site for the RLDP, however as far as we know from our review, there is no assessment and critique of this site. This site has not been included in the ‘Candidate Assessment at Preferred Strategy Stage’ (October 2023). As such, with an absence of publicly available information, it is not clear how the Council has judged this site against the criteria. This raises questions accordingly in respect to the “soundness” of a site which forms part of the intended housing land supply, and by association the trajectory. Without this, and without being consulted on (as others have been prior to this) we question whether this allocation is “sound” (i.e. its allocation is considered to be “unsound”).

Despite the absence of site-specific assessment criteria, as the RLDP preferred strategy states a key objective guiding site selection is that the Plan will “provide for vital and vibrant rural communities whilst protecting the countryside through the delivery of growth in sustainable locations related to the settlement hierarchy alongside the provision of supporting infrastructure” (Objective 7 ‘Fostering Diverse Vibrant and Connected Communities’), it is reasonable to assume that the Council considers ‘Land West of Maendy Road’ to be a ‘sustainable’ location.

Given this, we have reviewed the key services in proximity to the site. The following services were identified:

• In terms of public transport, there are two bus stops located approximately 0.2 miles (4-minute walk) from the site (‘Land West of Maendy Road’), with the 321 providing services between Llantwit Major and Talbot Green.

• The site is also located 0.2 miles (4-minute walk) from The Farmers Arms Pub and 0.2 miles (4-minute walk) from The Hare and Hounds Inn.

• The site is located 0.2 miles (5-minute walk) from Aberthin Village Hall.

Aberthin is in close proximity (1.2 miles/14-minute walk) to the key settlement of Cowbridge - which is identified as a sustainable location, and is ranked 4th place for services and facilities within the Vale of Glamorgan. The following key services are found in Cowbridge, and are therefore in close proximity to ‘Land West of Maendy Road’:

• Cowbridge Comprehensive Schools;
• Cowbridge Health Centre; and
• Cowbridge Town Centre for various Retail Services.

Considering this, there is no material difference between ‘Land West of Maendy Road’ and ‘Land at Ystradowen’ in sustainability terms. Given that Ystradowen is located only 2.7 miles from Cowbridge (9- minute bus journey), the candidate site at ’Land at Ystradowen’ is no less sustainable than the site at Aberthin. The following key services are within Ystradowen and therefore in close proximity to the promoted site:

• In terms of public transport, there are two bus stops located approximately 400m (7-minute walk) from the site (‘Ty Mawr Close’), with the ‘321 Nat Group Service’ providing services between Llantwit Major and Talbot Green. The 321 service is the same bus service that serves ‘Land West of Maendy Road’ / Aberthin.
• The site is also located 300m (3-minute walk) and 600m (10-minute walk) from Sports Pitches/Playing Fields such as ‘Ystradowen Children’s Park’, and the 3/4G Sports Pitch at ‘Ystradowen Petanque Club’.

• Furthermore, the site is located 480m (7-minute walk) from the ‘Murco – Tudor Garage’ which can provide basic goods to meet day-today needs such as bread, butter, milk etc.

Accordingly, it can be considered therefore that if the proposed allocated site ‘Land West of Maendy Road, Aberthin’ is considered sustainable and by association suitable to be an Affordable Housing Led Allocation, ‘Land at Ystradowen’ is equally suitable to be an Affordable Housing Led Allocation.
Furthermore, to reinforce the above position and to illustrate and evidence the site’s sustainability, the following has been taken from the Officer’s Reports associated with the applications for the site that directly adjoins the western boundary of the promoted site 430 - ‘Land off Sandy Lane, Ystradowen’ (Housing Allocation 48). An aerial view extract is outlined below to give spatial context:
Reference is made in the Final Report of app ref. 2013/00856/OUT which states that “Ystradowen is considered a sustainable settlement for further housing development”, due to “the sustainable nature of the settlement”.

Furthermore, the Final Report of app ref. 2023/00948/FUL states:

• “Notwithstanding this, the site is located in close proximity to local services and there is a bus stop located nearby. Whilst the comments relating to the reliance and frequency of the bus services have been considered, there still remains a bus service in the area.”
• “Firstly, as aforementioned, many neighbouring comments refer to the site as unsustainable and have commented on the suitability of public transport and cycle routes etc. This has been addressed above.”

The above clearly evidences that the location has previously been endorsed as, and is currently still found to be, sustainable.

A further key consideration to note and one which does differentiate between the relative merits of the ‘Land at Maendy Road, Aberthin’ and ‘Land at Ystradowen’ is that the LDP Proposals Map demonstrates that ‘Land West of Maendy Road’ is within a Special Landscape Area - see overleaf:
Vale of Glamorgan Proposals Map (Land West of Maendy Road outlined in red)
Under Policy MG17 ‘Special Landscape Areas’ it is considered that development in SLA could pose an “unacceptable harm to the important landscape of the area”. Accordingly, this development and proposed allocation could therefore cause “unacceptable harm to the important landscape of the area”.

‘Land at Ystradowen’ by contrast does not sit within a SLA (see below). This site would therefore not pose any potential concern in this respect as it would ultimately not cause any “unacceptable harm to the important landscape of the area”.
Vale of Glamorgan Proposals Map (Land at Ystradowen in red)

This is a significant factor to consider. ‘Land West of Maendy Road, Aberthin’ causing “unacceptable harm to the important landscape of the area” will lead to this proposed allocation being at risk of not being delivered by virtue of detailed assessments of its impacts and acceptability at planning application stage holding that the landscape and visual impact of development of the site is unacceptable. As such 25 affordable units will be lost from the proposed affordable 122 units, and ultimately being lost from the overall housing land supply. As stated in the draft housing trajectory “there is a need for small scale affordable housing led development (minimum 50% affordable) to respond to local affordable needs and help sustain services and facilities within these rural communities”. There is a clear possibility therefore that this proposed allocation is not delivered (as it is located in a SLA), and so a “small scale affordable housing led development” which is needed to “respond to local affordable needs and help sustain services and facilities within these rural communities” is not provided for. This is clearly an issue. Given however ‘Land at Ystradowen’ does not sit within a SLA – and so not pose any potential concern or cause any “unacceptable harm to the important landscape of the area” – the allocation of this site would be more suitable and “safer” - as therefore would be no concerns over this proposed allocation being removed and/or not being delivered in this respect (as it is not located in a SLA). This would ensure that affordable units, where “there is a need for small scale affordable housing led development (minimum 50% affordable) to respond to local affordable needs and help sustain services and facilities within these rural communities”, are provided for. As such the proposed housing trajectory would be maintained.
Land North of West Winds Business Park, Fferm Goch

The below sets out the candidate site stage two assessment of ‘Land to north and west of Westwinds Business Park’:

Candidate Site Stage 2 Assessment (Site Ref. 398)
As can be seen above, the site was not considered suitable for further consideration, with the site scoring negatively (red) in respect to a number of key factors. These include the following:

• Access to Retail;
• Access to Health Services;
• Sustainable Transport- Public Transport;
• Access/ Proximity to services and facilities conclusion;
• Climate Change; and
• Health and Wellbeing.

Given the fact the site scores red in ‘Sustainable Transport – Public Transport’, this shows the site is not served by public transport connections within 800m, as outlined in the key below:
Additionally, Policy SP7 (Sustainable Transport) of the Vale of Glamorgan Preferred Strategy states “New development must support an enhanced transport network that increases the proportion of journeys being undertaken by sustainable travel modes”. Additionally Objective 8 (Promoting Active and Sustainable Travel Choices) states “new development is directed to locations that are or can be accessible by a choice of modes of transport, including walking, cycling, and public transport.”

It is well known that residents of affordable housing are statistically less likely to own private vehicles, making access to reliable and frequent public transport essential for ensuring equitable mobility. The provision of public transport infrastructure in close proximity to such developments is therefore a critical component in supporting access to employment, education, healthcare, and other key services, while also promoting sustainable travel patterns and social inclusion.

The site also scores red in respect to Access/Proximity to services, showing the site is greater than 1200m away from key services, as seen in the key below:
In respect of the above, Preferred Strategy 6.40 states the need “To ensure that new development takes place in locations that have the best access to a wide range of services, facilities, and employment opportunities, whilst minimising the need to travel, the distribution of growth is guided by the following settlement hierarchy”. To further highlight the importance of both sustainable transport and proximity to services, the preferred strategy also states the need to “Facilitate the development of adaptable, accessible, well-connected communities that have a strong sense of identity, offer a sustainable range of services and facilities and are equipped with adequate infrastructure”. In addition, Promoting Active and Sustainable Travel Choices outlines to “Promote and encourage the use of sustainable methods of travel, particularly active modes of transport, whilst simultaneously reducing the need to travel”.

In light of the above, this site does not align with the aims and targets set out in the Preferred Strategy, as it fails to meet several key development goals set out. It should therefore not be considered suitable to be allocated for future developments. Its inclusion is therefore unsound.

Should this view be concurred with, 22 affordable units will be lost from the proposed affordable 122 units, and ultimately will be lost from the overall housing land supply. As stated in the draft housing trajectory “there is a need for small scale affordable housing led development (minimum 50% affordable) to respond to local affordable needs and help sustain services and facilities within these rural communities”. There is a clear possibility therefore that this proposed allocation is removed and/or not delivered as its inclusion is unsound as it does not align with the aims and targets set out in the Preferred Strategy - as it fails to meet several key development goals set out. A “small scale affordable housing led development” which is needed to “respond to local affordable needs and help sustain services and facilities within these rural communities” will therefore not be provided for. This is clearly an issue.

When comparing this with ‘Land at Ystradowen’, the following is set out:

Access to Services and Facilities

This criterion has been assessed firstly on the location of the site proposal in terms of whether it is located within, adjacent to, or outside a settlement, and secondly the ease of pedestrian and cycle access to key services listed below.
With reference to the above:

• In terms of public transport, there are two bus stops located approximately 400m (7-minute walk) from the site (‘Ty Mawr Close’), with the ‘321 Nat Group Service’ providing services between Llantwit Major and Talbot Green.

• The site is also located 300m (3-minute walk) and 600m (10-minute walk) from Sports Pitches/Playing Fields such as ‘Ystradowen Children’s Park’, and the 3/4G Sports Pitch at ‘Ystradowen Petanque Club’.

• Furthermore, the site is located 480m (7-minute walk) from the ‘Murco – Tudor Garage’ which can provide basic goods to meet day-today needs such as bread, butter, milk etc.

These services and facilities are therefore well within the best category (i.e. categorised/scored as ‘green’) - within 800m of site (10-minute walk). Accordingly, the site therefore has good access to services and facilities.

Furthermore, the settlement of Ystradowen has been ranked highly in the VoG Sustainable Settlements Appraisal, scoring a total of 14 points according to the distance to key services and facilities available. This places Ystradowen 26th out of a total of 87 settlements. As a result, this would be deemed a suitable area to accommodate growth.

As stated above the key settlement of Cowbridge is located in close proximity being only 2.7 miles to the south and a 9- minute bus journey. Cowbridge is identified as a sustainable location, and is ranked 4th place for services and facilities within the Vale of Glamorgan. The following key services are found in Cowbridge, and are therefore in close proximity to ‘Land West of Maendy Road’:

• Cowbridge Comprehensive Schools;
• Cowbridge Health Centre; and
• Cowbridge Town Centre for various Retail Services.

Furthermore, it is important to note that the above criteria does not take into account the important role and proximity of the Principal Settlement and Strategic Growth Area (as defined in the RCTCBC LDP) of Talbot Green / Pontyclun / Llantrisant which is 2.8 miles to the north (14-minute bus journey). Ystradowen would also naturally align, and function, in association with this Principal Settlement and Strategic Growth Area (of Talbot Green / Pontyclun / Llantrisant). These areas comprise for example the following key services:

• Cowbridge and ‘Y Pant’ Comprehensive Schools;
• Cowbridge Health Centre and Old School Surgery; and
• Cowbridge Town Centre, and Talbot Green / Pontyclun / Llantrisant (Strategic Growth Area), for various Retail Services.

Given the above, ‘Land at Ystradowen’ does/should align with the aims and targets set out in the Preferred Strategy as it meets several of the key development goals set out. Its inclusion should therefore, in our view, be considered “sound” and therefore suitable to be allocated for future developments. The site should properly and appropriately be allocated in lieu of ‘Land to north and west of Westwinds Business Park’ – the inclusion of which is “unsound”. ‘Land at Ystradowen’ would therefore ensure that affordable units, where “there is a need for small scale affordable housing led development (minimum 50% affordable) to respond to local affordable needs and help sustain services and facilities within these rural communities”, are provided for. As such the proposed housing trajectory would be maintained.
Land to the East of Colwinston, Colwinston

A summary of the Candidate Sites Assessment at Preferred Strategy Stage has been extracted below:

As outlined above, the site was rejected and considered not suitable for further consideration. In fact, and unlike ‘Land at Heol Fain, Wick’ and ‘Land to north and west of Westwinds Business Park’ it was stated that this site “could not be considered as a suitable affordable housing led development site”. Despite this, this site is identified to be allocated as an Affordable Housing Led Allocation. As such, the inclusion of this site is “unsound”.

It is known that Colwinston has been subject to significant housing allocations in the settlement as part of previous plans. To evidence this, 25% of the 64 units (i.e. 16 units) were approved on the site allocation ref. MG2(41) and PP ref. 2014/00242/FUL. This makes a substantial provision of such Affordable Housing units (and housing generally) in the settlement in recent years.
Other similarly sized and comparable settlements and locations have not by contrast been subject to any growth for some considerable time, and accordingly would warrant and benefit from provision as part of this new replacement plan.

Notwithstanding the location of such provision, and as set out in detail at the outset of these representations, National Planning Policy advocates the high and acute need for affordable housing, whilst recent analysis evidences that there is a housing emergency. These circumstances - coupled with the shortcomings identified and set out earlier in these submissions in respect to the adequacy of provision within the plan (rolled forward sites / inadequate provision etc) – means that notwithstanding any potential allocation at Colwinston, further provision ought to be made in comparable (previously unprovided for) locations, such as Ystradowen.
Credentials of this site subject to this submission

There has been a significant change in the position and circumstances since the promoted site herein was assessed at Candidate Site Stage and the Assessment undertaken. The Stage 2 Assessment of the site concluded the following: ‘Whilst adjoining the existing LDP settlement boundary this is by virtue of an existing adopted plan LDP allocation this is currently under review. Notwithstanding this the site would represent unacceptable intrusion in to the open countryside.’
The assessment/conclusion implies that as this site (‘Land off Sandy Lane, Ystradowen’) has not been built out and is “currently under review”, it suggests that ‘Land at Ystradowen’ (430) does not adjoin the existing LDP settlement boundary. Given recent developments however associated with the implementation of the planning permission ref. 2023/00948/FUL (post approval on 9th December 2024) and the site being currently being “built out” and work commencing on site, the site no longer adjoins “the existing LDP settlement boundary … by virtue of an existing adopted plan LDP allocation … currently under review”. Accordingly, and given this, the ‘Land at Ystradowen’ site boundary therefore directly adjoins/is adjoining the LDP settlement boundary and the site promoted herein.
The following specific photo evidences ‘Land off Sandy Lane, Ystradowen’ (Housing Allocation 48) is being built out the western boundary of the promoted Site ID 430. This therefore clearly highlights that the site’s boundary is representing the existing settlement limit in the existing development plan. Accordingly, the ‘Land at Ystradowen’ site boundary therefore directly adjoins/is adjoining the existing LDP settlement boundary.
Summary of These Representations

To re-iterate, and to summarise the case made and set out, these representations seek to object to the Housing Trajectory published as part of the consultation on the Draft Housing Trajectory For Housing Stakeholder Group (October 2025) which underpins the Plan and the delivery / realisation of its underlying strategy.

Detailed submissions and objections are raised above in respect to the trajectory information published regarding the soundness and robustness of this information (and it’s consultation), which we do not consider are adequate, robust, or sound to deliver the Plans aims and objectives.

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.

Amend SP1.

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.

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.

Policy SP1 - Sustainable Growth Strategy
Policy SPl sets out that the plan will deliver 7,890 dwellings by 2036, including a minimum of 3,070 affordable homes. Policy SP1 also sets out that outside of the Strategic Growth Areas, the allocation of new sites will be limited to small-scale affordable housing led sites.
The number of households in VoG in mid-2021 (i.e. the start of the RLDP period) was 57,676. Based on Welsh Government's 2022-based household projections, the number of households is projected to increase to 67,299 in VoG in mid-2036 (i.e. the end of the RLDP period). This equates to a household increase of 9,623 which is 22.0% more than the 7,890 dwellings the RLDP targets in Policy SPl. In addition, the Development Plan Manual requires a conversion factor from households to dwellings with 4% being the baseline (it is acknowledged that this will vary depending on local circumstances). Taking a 4% uplift, the dwelling requirement figure would be 10,008 which is 26.8% more than the RLDP seeks to deliver in Policy SPl. The number of overall dwellings identified in Policy SPl will therefore not meet the identified household growth needs ofVoG for the RLDP period. The Council should review the position in terms of the updated household projections.
It is important to note that the above calculations are purely to meet newly arising need and do not make any allowance for existing unmet affordable housing needs or any policy aspirations. As stated in the supporting text of Sustainable Growth Strategy 4 of the RLDP (paragraph 5.23) "The Local Housing Market Assessment (LHMA) 2023 identifies a need for 1,075 affordable homes per annum over the next five years based on principal projections or 1,114 based on the RLDP projections. There is an identified backlog of need across all the sub-market areas in the Vale of Glamorgan, and the issue is acute in many communities." Policy SPl seeks to deliver only 3,070 affordable homes over the RLDP period, equating to 205 affordable dwellings per annum. This is only 18.4% of identified need per annum for the five-year period from 2023-2028 in the LHMA. The number of affordable homes identified in Policy SPl therefore falls drastically short of the identified need for affordable homes in VoG for the RLDP period.
In order for Policy SPl to achieve the third test of soundness (Will the plan deliver?), the policy must be updated to accommodate a greater level of housing delivery, that reflects the most up to date evidence. The Development Plans Manual states:
"In terms of considering the level of housing provision for a plan, the most up-to- date suite of Welsh Government Population and Household Projections are a fundamental part of the evidence base [paragraph 5.35]"
Policy SP1 as drafted sets out that the allocation of new [housing] sites will be primarily focused within the Strategic Growth Areas (SGA) identified on the Key Diagram and outside of the SGA, the allocation of sites will be limited to small-scale affordable housing led sites. The identification of St Athan as a settlement where development should be concentrated is supported.

Policy SP2 - Settlement Hierarchy
The identification of St Athan as a 'Primary Settlement' is supported. It is important that sufficient growth is directed to the Primary Settlements to reflect the opportunities presented for delivering new homes, both market and affordable.
As recognised at Paragraph 6.11 of the Deposit Plan, St Athan is a key location for employment growth and also benefits from a range of services and facilities. This is also reflected in the Integrated Sustainability Appraisal (Paragraph 9.2.10), which recognises that locating new development in proximity to the Cardiff Airport and Bro Tathan Enterprise Zone will help integrate housing and employment, supporting sustainable travel and local labour markets. Future growth at St Athan will therefore support its role within the wider regional growth area, as well as existing and future transport proposals.

Policy SP4 - Placemaking
We support the recognition in Policy SP4 that successful placemaking can add social, economic, environmental and culture value to new development. Placemaking is an important part of all developments brought forward by Barratt Redrow.
The identification of high level placemaking principles in the Deposit Plan is supported, but a degree of flexibility should be applied. This is important to ensure the appropriate placemaking approach can be applied for each site / development. For example, it will not necessarily be appropriate for all developments to incorporate a 'diverse mix of uses... ' or to be developed at 'high densities... and supporting mixed uses'. Where developments are delivered on a phased basis, any mix of uses, residential densities etc may vary between each phase.
Policy SP4 also requires all major development to provide a 'Placemaking Statement'. It should be made clear in the Policy, as per Paragraph 6.34 of the Deposit Plan, that this is not expected to be a standalone statement, but will form part of a Design and Access Statement. We recommend the policy is amended as follows:
"Placemaking Statements will be required as part of Design and Access Statements for all... " Paragraph 6.33, which supports Policy SP4 should also be amended. It is not appropriate to state that development will be 'favoured' where meaningful community involvement has been demonstrated. Taking allocated sites, significant consultation will have already taken place through the LDP process,
with further engagement required at the application stage through the PAC process. The RLDP should be amended to note that consultation will be 'encouraged' or similar.

Policy PGDl - Creating Well Designed and Inclusive Places
There is a degree of crossover and repetition between Policy PGDl and Policy SP4. For clarity and brevity of the Plan, a single policy could be taken forward.

Policy PGD2 - Residential Site Densities
It is noted that the minimum density sought for sites within the Key, Service Centre and Primary Settlements is higher than that currently required by the adopted LDP. It is important that flexibility is adopted where proposed allocations in the RLDP crossover with existing LDP allocations.

This is relevant to Church Farm, St Athan, which is allocated in the adopted LDP. The Deposit Plan retains this allocation, but also proposes a further phase of development to the east (through Policy HGl KS4). A planning application is currently being prepared for the first phase of development (relating to the existing allocation), which accords with the adopted LDP requirement of 30 dph. The RLDP should recognise that flexibility will be required where sites are delivered on a phased basis, with earlier phases also being identified in the adopted LDP.

The inclusion of caveats recognising that lower residential densities can, in some cases, be acceptable is welcomed. It is important that the characteristics of each site/ surrounding context can be taken into account, along with sites constraints and other technical requirements (such as SuDS).

Policy SP6 - Housing Requirement
Policy SP6 currently includes a flexibility allowance of 10%. The provision of a flexibility allowance is supported, but it should be increased to 15%. The Development Plan Manual 3 indicates that 10% should be the starting point. This would be consistent with a number of other adopted and emerging LDPs, which have been based on allowance above the standard 10% (e.g. adopted Bridgend LDP at 14% and emerging Monmouthshire LDP at 15%). A higher figure is considered appropriate due to the low level of new allocations, the limited number of key sites allocated in the plan and the need to increase the level of required growth (as referred to in our response to Policy SPl).

The number of homes delivered through new allocations should be increased to make the Plan more ambitious and align with Future Wales and the Vale's identified role as a National Growth Area.

Policy HSI - Housing Allocations
We support the identification of Church Farm, St Athan as a 'Key Site'.

The table within Policy HG1 should be amended to make it clear that the number of units listed for each site are approximate figures, allowing a degree of flexibility.

Policy HG1 KS4 - Land at Church Farm, St Athan
Paragraph 6.96 rightly acknowledges that the allocation will be delivered on a phased basis. With the first phase (the western parcel), representing land allocated through the adopted LDP. A hybrid planning application is due to be submitted in March 2026 for this phase of development. The application proposes 232 new homes and a new Class Al foodstore - as per Paragraph 6.99 of the Deposit Plan.
Paragraph 6.102 states that there is limited capacity in West Aberthaw Waste Water Treatment Works (WwTW). It continues by stating that if the development wishes to connect in advance of the planned AMP scheme, a Developer Impact Assessment to establish the reinforcement works needed at the WwTW will be required. It should be recognised in the Deposit Plan that this applies to the wider allocation, with sufficient capacity existing for the first phase of development.
Policy HG1 KS4 should be amended to read that the site will deliver "approximately 532 homes over the plan period... ".
The policy requires the development to comply with the Placemaking Principles set out in Policy SP4. This policy has been commented on separately, but as previously noted, it is important that the phased nature of the Church Farm development is recognised when applying the placemaking principles. As a result, there may be slight differences in what is appropriate across each phase.
The policy currently requires affordable dwellings to be dispersed across the site in clusters of not more than 10. This should be amended to clusters of no more than 15 units.
Policy HG1 KS4 also sets out a number of other requirements that the development "must" comply with. We do not support the current wording and use of "must comply with". Some of the requirements listed will require further consideration during the design development of the scheme. This will be supported by detailed technical work to be prepared in support of a future planning application. The wording should be amended to reflect that the list 'requirements' will be subject to further consideration, and should not be treated as definitive.
For example, the points listed under 'Sustainable Transport and Highways' should be informed by a Transport Assessment. This is reflected in Background Paper BP44 (Infrastructure Delivery Plan), which recognises that contributions towards off-site improvements to the capacity/ flow of junctions will be determined through a site-specific Transport Assessment.
The first bullet point under Policy HGl KS4 should be amended to read:
"A proportionate contribution towards off-site improvements to the capacity and flow of junctions on the strategic highway network, if identified as being necessary by a site-specific Transport Assessment". As per Policy HGl KS4, the first phase of development at Church Farm has been developed on the basis of an access point from Gileston Road. This is as per the request from the Highway Authority. The hybrid planning application will also deliver localised road widening on Gileston Road and provision of a new active travel route.

(continued) Policy HG1 KS4 - Land at Church Farm, St Athan
The third bullet point under the 'Sustainable Transport and Highways' heading should be amended. Transport work undertaken to date has demonstrated that there is no need for a new signalised junction at Gileston Road/ B4265. The need for and nature of any work required to this junction should be determined through the planning application process, informed by a Transport Assessment. It is therefore not appropriate for the Policy to state that an upgraded signalised junction 'must' be provided. The intention is for a second access point to be provided for the second phase of development from the B4265. This is in line with the access strategy requested by the Highway Authority. The form and nature of this access point will be agreed through the planning application process, informed by a Transport Assessment.
The hybrid planning application for the first phase makes provision for a new pedestrian and vehicular access to St Athan Primary School. Whilst the developer can make provision for such a link, it will be down to the Highway Authority and Education Department to determine whether it is provided. Policy HGl KS4 should be amended to reflect that it is not within the developers gift to guarantee the link is taken up, delivered or actually 'replace' the existing access on Rock Road. At the moment is unclear what type of access could be sought (e.g. pedestrian and / or vehicular) and whether this would solely be through Phase 1 (as indicated by Figure 16).
Upgrades to existing bus infrastructure is expected to be delivery through planning obligations. Again, the nature of any improvements will be determined through the planning application process.
The Policy sets out a number of requirements relating to 'Community Infrastructure'. This includes the transfer of land to the east of St Athan Primary School and an off-site contribution towards the delivery of additional school places. No detail is provided as to the quantum ofland expected to be transferred. It is also noted that Policy CI3 states that land 'may be' required.
Whilst the principle of transferring land for the redevelopment I expansion of St Athan Primary School would be considered in principle by BWD, further information will be required to consider this request in full. As it stands, no information has been provided as to the extent ofland required. It is also important that Policy HG1 KS4 recognises that the need to provide for/ contribute towards education facilities will need to be determined at the point of any future planning application.
If a land transfer is required and agreed as part of the second phase of development at Church Farm, this must be reflected in any request for off-site contributions. Background Paper 44 (Infrastructure Delivery Plan) states that the second phase of development will require the transfer ofland, or a Section 106 contribution of £5.8 million. The basis and justification for this sum of contribution is not detailed within the Plan or supporting documents. Full details will need to be provided and considered at the planning application stage.

(continued) Policy HG1 KS4 - Land at Church Farm, St Athan
Policy HG1 KS4 also identifies the need for a contribution towards the provision and enhancement of community facilities in the area, and a contribution towards training and development for the commercial element of Phase 1. Whilst the principle of providing a community facilities contribution is accepted, evidence of need for such a contribution will be required at the planning application stage. The Policy should also be amended to recognise that training and development could either be provided a contribution or as part of the development itself.
The need to respect the setting of the listed War Memorial is reflected in the hybrid planning application due to be submitted imminently for Phase 1. The scheme has been carefully designed, with the relocation of the proposed foodstore to the northwest corner of the site, setting housing back from the B4265 and realignment of the central green corridor.
The importance of green infrastructure, recreation spaces and biodiversity is recognised and supported. Land at Church Farm offers the opportunity to deliver high-quality landscape buffers, accessible green space, integrated SuDS features and pedestrian and cycle connectivity with the village of St Athan and the wider strategic active travel route.
It is important that the Policy is not overly prescriptive about the types of green infrastructure and open spaces to be provided, which could potentially constrain the ability to deliver a design and landscape led masterplan. Instead, the policy should focus on outcome-based placemaking principles and flexibility in how these outcomes are achieved through design. It is also important that the ability to provide GI and open space across the site reflects other policy requirements, such as the delivery of SuDS.
The Deposit Plan includes an indicative plan for Church Farm at Figure 16. Whilst referred to as 'indicative', the purpose and status of this plan should be made clear in the supporting text. It should only be treated as illustrative, with the final development for Phase 1 and 2 being subject to further detailed design and technical work. For example, it is noted that within the Phase 1 development, land identified as 'Significant POS' on the plan is actually intended to accommodate the main attenuation basin. Whilst it would serve a qualitative purpose, it would not act as POS per se.

Policy SP7 - Affordable Housing Provision

The provision of a range of tenures, types and sizes of affordable homes is supported in principle. This should be assessed on a site by site basis at the application stage, with the LHMA being a starting point for discussions with the Housing Strategy Service. This flexibility will ensure that the most appropriate mix of dwellings is brought forward based on factors such as site characteristics, local context, placemaking etc.

It is also important that Policy SP7 acknowledges that affordable housing provision should also consider the evidenced viability of a development. This would be consistent with Policy SPS.

Policy SP8 - Affordable Housing Requirements

Recognition that the provision of affordable housing should be negotiated on a site by basis, considering the evidenced viability of a development, is supported. Recognition that the exact mix of affordable housing will need to be considered on a case-by-case basis is also welcomed. This is important to ensure sufficient flexibility when discussing the most appropriate mix of affordable homes at the application stage.

Policy TRI - Transport Proposals
Policy TRI states that to mitigate the impact of development on the highway network, strategic highway improvements have been identified to the Gileston Road junction in St Athan. As per our comments under Policy HG I KS4, the need, and nature of any works to the Gileston Road / B4265 junction must be informed by detailed technical work.

We can confirm that the first phase of development, which will be subject to a hybrid planning application in March 2026, has been designed to not prejudice any future improvement works to the junction (should measures be demonstrated as necessary in the future).

Policy SP12 - Retail Floorspace Provision
The identification of new convenience floorspace at Church Farm, St Athan is supported. The provision of new retail floorspace in this location will support the existing and future population of St Athan, reducing the need to travel to other settlements to serve their needs.

Policy SP13 - Community Infrastructure and Planning Obligations.
We support the recognition in Policy SP13 that any requirement for planning obligations must be appropriate and have regard for development viability.
Policy SP13 also states that the delivery of new/ improved infrastructure should be timed to meet the needs of communities prior to, or from the commencement of, relevant phases of development. It must be recognised in the policy or supporting text that the delivery / timing of some infrastructure measures will be outside the control of developers I developments. This is particularly the case where financial contributions are made and measures will be delivered by others. Flexibility should therefore be allowed for through Policy SP13.

Policy Cll - Open Space Provision
The wording of Policy Cll, and/ or the supporting text, must allow greater flexibility to be applied to the open space standards. This is essential to ensure that the spaces provided are design, rather than standards led. It is also important that the type and range of provision is reflective oflocal context/ needs. This is reflected in Paragraph 6.233 of the Deposit Plan but Policy Cll should also be amended to reference this directly.

The proposed 62.2 sq m per dwelling requirement is overly prescriptive and not aligned with FiT's methodology, which is per person and intended to be applied strategically across different open space typologies, not as a uniform per dwelling metric. FiT's approach emphasises flexibility, multifunctionality and local context, meaning that applying a rigid per dwelling standard oversimplifies the guidance and risks generating disproportionate land take and unnecessary design constraints. When combined with the wider cumulative policy requirements of the RLDP, such an approach has the potential to impact development viability and reduce delivery.
The recognition that in some instances off-site contributions will be appropriate in lieu of on-site provision is welcomed.

Policy Cll requires an 'Open Space Strategy' to be submitted for all housing developments that meet the relevant thresholds. In many instances, the provision of open space within a scheme will be addressed through a Design and Access Statement and/ or Green Infrastructure. This ensures that open space provision is considered as part of the comprehensive approach to design, landscape and biodiversity. We would question the need for a standalone strategy or statement. The Policy should be amended to reflect this.

Policy CI3 - New Community Facilities
Policy CI3 identifies the 'allocation' ofland at St Athan Primary School for new community facilities. The supporting text (Paragraph 6.245) confirms that this land is allocated for the redevelopment and expansion of the existing school site. It continues by stating that a "small area of additional land may be required required ... to facilitate the delivery of the school" as part of the Key Site allocation at Church Farm. It states that improved access "may also be necessary".

As worded, the Policy is not clear what land is allocated - whether it is actually within the Primary School and/ or adjoining land. Ifland may be required within the Church Farm development (as implied by Policy HG1 KS4), it is currently unclear what quantum ofland would be sought. Whilst the principle of transferring land for expansion of the school (as part of Church Farm Phase 2) and facilitating improved access would be considered by BDW, it is important that what is being sought is clear.

It is important that there is coordination between policies in the Plan - for example, Policy CI3 and Policy HG1 KS4. This should include an amendment to Policy HG1 KS4 that the land 'may' be required, rather than must be provided. It is also important that ifland is provided for the school expansion, or improved access is facilitated, by the development at Church Farm, this is reflected in other requirements and expectations across the Plan (e.g. in terms of design, planning obligations etc).

Policy CCI - Residential Operational Net Zero Carbon Development
Current Building Regulations targets 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.

The policy should clarify that it applies only to regulated energy use. Developers have no control over how future homeowners use their homes, and therefore unregulated energy consumption such as appliance use, occupant behaviour, and plug loads, cannot form part of compliance requirements. This is consistent with Building Regulations methodology

Alternatively, if Policy CCI is kept in the RLDP, there must be some flexibility introduced for the requirements of Policy CCI to fall away should Building Regulations catch up or exceed or require different provisions than the requirements of Policy CCI during the lifetime of the RLDP. To not provide this flexibility would mean that the ability of the RLDP to deliver the new homes in VoG needs could be compromised. Clarification is also required on how the contribution to the Council's Project Zero fund is to be calculated and whether the timeframes in Policy CCI relate to the date of planning approval.
Furthermore, the demands of Policy CCI have to be considered in the context of all of the other requirements that impact on development viability (e.g. affordable housing). The Council must provide evidence that an assessment has been undertaken to demonstrate that development, specifically the housing allocations in Policy HGI, can bear the cumulative policy costs of the RLDP, including Policy CCL

The policy wording should be amended so that the performance requirements apply based on the date of planning permission rather than the RLDP adoption date. Changes in energy performance requirements can significantly affect site layout, building orientation, and design considerations. Without this amendment, approved schemes could unnecessarily require variations via Section 73 or Non Material Amendment applications.

ANNEX 1
Preface

This Annex sets out the detailed case in support of these representations, and by association the case for allocation of the site.

The representations are structured into the following sections:

1. Response to the Deposit Plan;
2. Comments on specific policies; and
3. A summary of the suitability of the site for development.

SECTION 1. Response to the Deposit Plan

Distribution of Growth

We object to the distribution of growth within the Deposit Plan. Specifically, we object to the strategy that underpins the Deposit Plan, which seeks to introduce the proposed ‘Strategic Growth Area’ which is expected to contain the majority of housing growth in the Vale over the Plan period, or rather the over-reliance on this defined area, and the associated absence of growth in other parts of the Plan area.

As outlined in our previous representations, the allocation of housing and the location of strategic growth neglects the Rural Vale, and in our view, overprovides in the Strategic Growth Area. For example, with limited housing stock and average house sales at over £800,000 over the last 12 months, there is a clear and established need for new homes in the Bonvilston area, particularly at an affordable level. This is reinforced by the Local Housing Market Assessment that identified a need for over 1,114 new affordable homes per annum over the next five years throughout the county, and 196 units per annum thereafter (average of 502 units per annum over 15 years). Further to this, it is widely known that the rural Vale comprises the majority of the county’s ageing population, which, as a demographic, has and will continue to grow rapidly over the Plan period. This is evident in the ‘Population Change’ chart below – which is taken from the Deposit Plan:

VofG Deposit Plan: Figure 4 Population Change 2011 to 2021

It is clearly the case that younger populations are migrating to other Authorities, where access to housing is typically cheaper and more affordable, whilst more older populations are significantly migrating into the Authority. This trend will result in an extremely unbalanced demographic, given that the working-age population have sought housing elsewhere.

Without a suitable supply of affordable housing delivered over the Plan period, this trend will only worsen. Accordingly, it is not considered that the RLDP takes into account the lack of supply of affordable homes within the rural Vale, as well as increased housing to support the growing ageing population within these areas.

Para 3.19 of the Deposit Plan clearly outlines that affordable housing is required in the short term, in order to meet pressing needs. Specifically, it outlines the following: “There is significant pressure on temporary accommodation in the Vale, for a variety of reasons including increased homelessness presentations… The need for sufficient permanent affordable housing to assist in moving people out of temporary accommodation is critical and the planning system has a vital role in assisting in new affordable housing delivery.”
Accordingly, the distribution of growth within the Authority must be proportionate, to ensure that populations / areas are not left behind where they must seek access to housing elsewhere.

The RLDP Sustainable Growth Strategy sets out 6 objectives. Objective 4 states: “Allowing for small scale affordable housing led development in settlements outside the Strategic Growth Area at a scale proportionate to the size of settlement.” (Page 66)
Para 5.25 states “Therefore, a key part of the strategy is to allow for affordable housing led developments within sustainable primary and minor rural settlements outside of the Strategic Growth Area, at a scale that is appropriate to the size of the community it is serving. An ‘affordable housing led’ scheme is one where a minimum of 50% of the dwellings would need to be affordable, although this could increase to a maximum of 100% if the site is brought forward by a social landlord”.

In terms of the definition / explanation of what the affordable housing-led development sites are seeking to achieve, paragraph 6.132 of the Deposit Plan outlines the following:

“Accordingly, to ensure that new developments respond to the high demand for smaller properties, as identified in the LHMA, priority will be given to affordable homes that are small to medium-sized, typically comprising one to three bedrooms. Representations received from the local community through the RLDP process also highlighted a desire for new housing developments to offer opportunities for accessing smaller market homes. This is particularly relevant in the rural Vale, where housing choices are more limited. Providing smaller, more affordable market homes may assist first-time buyers and enable older residents to downsize to more manageable properties within their local area. Affordable housing-led sites will therefore need to demonstrate that an appropriate range of both affordable and market dwellings has been provided.”

Despite the acknowledgement within this strategic objective, we do not consider that the RLDP goes far enough to meet this objective, nor are its provisions and allocations adequate.

It is considered that this objective is undermined by the allocations set out by the RLDP (not least the absence of allocations in the rural Vale). Notwithstanding the Vision’s clear acknowledgement of the benefit of the growth of the rural Vale, these areas have not been supported through the plan due to the lack of growth which has been attributed to these areas in terms of further housing, employment and sustainable transport. All growth options have been selected on the basis of being in either a Key Settlement, Service Centre Settlement or Primary Settlement, all of which are already sustainable areas served by rail. As a result, it is not clear how this objective can be achieved, without the allocation of further sites within the Minor Rural Settlements, such as Bonvilston. The Vale is characteristically ‘rural’, and as such, there needs to be a stronger emphasis on supporting and delivering new development in order to bolster the rural economy. This includes enabling opportunities to provide employment and business premises within / near to rural settlements, as well as focusing housing growth in these areas to reduce travel time, and promote the use of sustainable transport.

It is considered that the current Strategy does not provide adequately for all residents across the Vale, only those within the Strategic Growth Area. The underlying Vision and Objectives set out in the emerging Plan are accordingly wholly un-provided for by the detail of the Plan. This brings into question the “soundness” of the Plan.

The Strategic Growth Area does not take into account the important role and proximity of Bridgend to the West and/or the Principal Settlement and Strategic Growth Area of Talbot Green / Pontyclun / Llantrisant to the north (as defined in the RCTCBC LDP). The Minor Rural Settlements to the west are more likely to be supported by job opportunities and employment in Bridgend than further east in Barry or Cardiff. Similarly, those in the north align with, and function in association with, the Principal Settlement and Strategic Growth Area of Talbot Green / Pontyclun / Llantrisant to the north. These settlements are served by existing bus services that provide sustainable modes of travel to key employment locations in and around Bridgend. This is acknowledged in Paragraph 3.3 of the Strategy which states “The greatest number of residents who travel outside of the Vale for work purposes travel to Cardiff followed by Bridgend and Rhondda Cynon Taf, whilst a smaller proportion commute into the Vale from these neighbouring authorities”. The Demographic Evidence (Feb 2023) estimates the Vale as being a net importer of workers from RCT and Caerphilly (Para 3.6) - as shown in Figure 10 in the Preferred Strategy.

The current Strategy does not support any improvement of sustainable travel or further investment in settlements linked more closely to these areas - given that Growth has been apportioned in only the Key Service Centre and Primary Settlements. It is considered that this will fail to support and facilitate the current (and any future) employment coming into the Vale, nor will it support any employment which is located outside of the Vale to the West and North. The Growth Option is too heavily reliant on access to railway stations as the key and sole sustainable transport method, whereas access to bus services should also be appropriately assessed and focused on in terms of promoting sustainable development. It is unreasonable to devise a strategy that hinges on directing growth to areas that are accessible to railway facilities, where it is recognised in the Plan that the Vale is inherently rural. The delivery and soundness of the Plan is therefore questioned and we continue to object to the spatial growth strategy as set out in the Deposit Plan.

Housing Supply

RLDP Allocations - Key Sites

As set out in representations made throughout the Plan preparation process, we consider that the Plan is too reliant on the delivery of ‘key sites’ to meet the housing need over the Plan period. Specifically, the Plan makes provision for 2,278 units in these Key Sites, which equates to circa 65% of RLDP allocations in the housing supply. The 5 key sites that are allocated in the Deposit Plan are as follows:

• Land at North West Barry – 376no. units;
• North of Dinas Powys – 250no. units;
• Land at Readers Way, Rhoose – 520no. units;
• Land at Church Farm, St Athan – 532no. units; and
• Land to the West of St Athan – 600no. units.

We object to the current housing supply to allocate 2,278no. (65%) of units across strategic sites, as this makes for a risky and unrobust strategy for delivering housing, and in turn, meeting the identified housing need over the Plan period.

As stated in previous representations, there is concern that the proposed timing and phasing of the proposed Key Sites is unrealistic and unrobust, and in turn, undermines the soundness of the Plan, given the heavy reliance on Key Sites delivering new homes across the Plan period. Whilst it is not disputed that the sites would have gone through rigorous assessment to inform their proposed allocation, the timescales for securing planning permission (with all associated conditions discharged) is considered to be unachievable. This is particularly the case for the following timescales that are set out in the Housing Trajectory that underpin the Plan:

• “Time period of pre-application discussions/PAC consultation” – 4 months

• “Time between submission of planning application and determination” – 6 months
• “Time taken from planning consent to the discharge of relevant conditions to enable site construction” – 4 months

It is considered that the above timescales are fundamentally unrobust, and result in a distorted position of housing sites over the RLDP Plan period. It is not considered that these reflect or are informed by the timescales that are currently being incurred for planning applications submitted for major housing sites across Wales. It is rather the case that such applications would typically be determined 1-2 years following submission, given that there are a wide range of stakeholders involved in the determination of major planning applications – which often adds to the delays associated with the determination of such applications.

It is equally the case that the assumptions in the trajectory are solely based on expected timescales for processing formal submissions made to the Council, and do not factor in the timescales associated with, and needed for, the preparation of the material for submission.

It is assumed that these timescales have not considered that such major developments can be subject to the need to undertaking and submitting an Environmental Impact Assessment (EIA), which adds another layer to the determination of any planning application – given the additional considerations that form part of this process. As such, any site subject to EIA would very likely result in further delays extending beyond the timescales set out in the trajectory. Equally, as set out above, the preparation of an application subject to an EIA requires even more detail and assessment, which only further adds to the preparation stage (which has not been factored into as part of the trajectory). Accordingly, it is not considered that the trajectory contains any contingency if any site is required to undertake EIA as part of their application.

For the reasons stated above, it is unlikely that the sites will yield in full, particularly those sites which are expected to deliver housing right up to the final year of the Plan period (‘Land at Readers Way’ and ‘Land to the West of St Athan’). These sites do not allow for any ‘slippage’ should any delays arise through the development management process (which for the reasons set out above, will very likely be the case), and as such, a gap in housing delivery will be brought about as a result of these sites not yielding in full.

Given the proposed ambitious timescales set out for the delivery of the Key Sites, it is considered the housing trajectory is unrobust, and in turn, undermines the soundness of the Plan as a result. A change in strategy should be pursued whereby a greater proportion of small to medium sites are allocated for housing in the Plan period, which are more likely to fully yield given that such sites are subject to less assessment and consideration compared to strategic sites. This would make for a more robust strategy, where a greater number of small to medium sites can deliver housing in the short and medium term of the Plan period, whereas the strategic sites represent a more longer-term strategy to deliver housing – which would then spill into the next Plan period.

Accordingly, we object to the Deposit Plan in its current form, where there is an overreliance on housing need to be met through the delivery of the Key Sites, which we consider to be unrobust, and undermine the integrity and soundness of the Plan. The current strategy of the Plan is at significant risk of not delivering the level of housing expected based on the sites allocated, as least as swifty as identified in the housing trajectory. Should no change be made to the Plan to address the above issues, then it is extremely likely that the Plan would ‘fail’ in meeting the identified housing need.

Windfall Sites

It is noted that the RLDP is made up of the following:

• Existing land supply (3,838 units)
• Windfall sites (1,303 units)
• Allocated sites (3,521 units)

Para 6.69 states that “Analysis of historical delivery of housing indicates that on average small windfall sites (sites of less than 10 dwellings) have provided some 53 dwelling completions per year, and large windfall sites (10 dwellings or greater) contributed on average 80 dwellings per year. Overall, it is projected that windfall sites could contribute a further 1,303 dwellings over the remainder of the plan”.

As set out in our previous representations to the Housing Trajectory, we would object to the expected numbers of completions expected during the Plan period, given that there are a number of issues with delivering housing in Wales and given past completions rates for The Vale of Glamorgan – which is discussed in greater detail later in this submission. Again, this results in the Plan being at risk of not delivering the level of housing expected based on the sites allocated – including any windfall sites.

St Athan Train Station

The RLDP Sustainable Growth Strategy comprises six key elements, of which the following is set out in respect to the allocation of new housing growth in the Authority:

“3. Focusing development at locations that are well served by existing and proposed rail stations as part of the South Wales Metro and in areas with good bus links.”

The strategy outlines that a feasibility study for a station in St Athan had been undertaken in 2022, which identifies that a new station could be located in St Athan, subject to further investigation work. Accordingly, in line with the spatial strategy adopted for the RLDP (i.e. focus development around sustainable transport nodes), St Athan was identified as a ‘Strategic Opportunity Area’ to accommodate strategic growth – through the proposed allocation of two key sites : ‘Land at Church Farm’ and ‘Land West of St Athan’. These sites have been identified to deliver 532no. and 600no. units respectively in the Plan period. These are separate to, and are in addition to, the 51no. units that have now been attributed to the site ‘Land South of Clive Road’ and 80no. units attributed to ‘Former Stadium Site, adjacent to Burley Place’ in St Athan. Accordingly, in total, the Housing Trajectory makes a provision for a total of 1,263no. homes to be delivered in St Athan over the Plan period.

It is now the case, however, that the proposed railway station at St Athan is not in the first phase of delivery for new stations in South Wales – as confirmed in the ‘Today, Tomorrow, Together: A vision for rail across Wales and Borders’ (February 2026) recently published by Transport For Wales. This paper acknowledges that a new railway station at St Athan would represent a longer term opportunity, and therefore, will not be delivered in the short term / within the Plan period of the emerging Plan. Equally the Council have not provided any evidence to contradict this, and therefore, it is very unlikely that any new train station will be delivered in St Athan over the Plan period. This brings about significant questions regarding the suitability and acceptability of the proposed allocations set out above.

The strategy to allocate new housing growth is predicated on focusing residential development around sustainable transport nodes, and given that St Athan will be without any railway station in the Plan period, it is not considered that the sites align with the strategy of the RLDP. Accordingly, the wider Housing Trajectory is considered to be unsound, given that a total of 1,263no. homes (36% of the Plan’s new housing allocations) are expected to be delivered in St Athan within the Plan period.

It is considered that there has been an overprovision for housing growth in St Athan generally, and this issue is now further exacerbated by the lack of any forthcoming rail provision. Given this, to add further sites for housing in this location over and above the original provision is considered to be unsound. As set out above, the justification to allocate sites at St Athan has relied heavily on the railway station being delivered in the Plan period, and as such, there are serious questions marks associated with the acceptability of the proposed allocated sites - given their incompatibility with the core strategy of the RLDP.

In terms of the expected delivery of the Key Sites in St Athan, it is noted that the trajectory identifies that for the majority of the Plan period, both sites will be delivering 80no. dwellings per annum on each site (equating to 160no units in total). Whilst these are two separate sites, we seriously question the realistic prospects of the significant number of

homes being built simultaneously on two sites in proximity to one another – given the considerable logistical issues that would be brought about.

Accordingly, it remains that there are serious questions regarding the suitability and acceptability of the proposed allocations at St Athan, which do not accord with the strategy adopted for the RLDP – to focus housing growth on settlements that are supported by railway stations. Moreover, the scale of development proposed at St Athan is also not considered to be proportionate, with a significant number of homes delivered in a location not served by a railway station.

Rolled forward LDP Sites

The proposed land supply within the housing trajectory includes provision for ‘rolled forward’ LDP sites, which contribute to the total of ‘Proposed Additional Housing Allocations’ forming part of the housing supply. Specifically, a total of 1,242no. units have been identified as additional housing allocations, of which 959no. are expected to be delivered on the rolled forward LDP sites. As such, these sites are to provide for a significant proportion of additional housing in the Plan period (specifically circa 77%).

The Development Plans Manual (DPM) sets out that allocations rolled forward from a previous plan will require careful justification for inclusion in a revised plan. The DPM outlines that “there will need to be a substantial change in circumstances to demonstrate sites can be delivered and justify being included again. Clear evidence will be required that such sites can be delivered.” The below table included in the consultation document provides a breakdown of the rolled forward LDP sites, and in particular, sets out the status of each site:


The above table evidences that the current LDP has under delivered in regard to its targeted unit number of the Plan period, given that these sites did not yield any housing over the current Plan period. This is further exacerbated by the Land Bank sites that have also not delivered any housing across the existing LDP period, amounting to 1,860no units. Accordingly, when considering the non-delivery of both rolled forward LDP sites and Land Bank sites, this amounts to an approximate shortfall of 2,189 homes being delivered, or 33% of the total housing supply identified for the current LDP (8,525no. dwellings).

It is therefore considered that, as a minimum, the units carried over from the LDP (without planning permission) should be a surplus to the housing supply proposed for the RLDP, as opposed to being relied on to deliver the housing need over the Plan period. This is particularly the case for the two sites (Land to the west of Pencoedtre Lane, and Land between Northern Access Road and Eglwys Brewis Road) which do not currently have any active planning application

submitted for their development. These sites total an amount of 370no. units to be delivered in the Plan period, which represents more than a third of the additional housing allocations to make up the housing supply.

As such, it is considered that the unmet need deriving from the existing LDP is still present – indeed it has grown, and will continue to do so, not least when considered in conjunction with the projected population growth over the coming years to 2036, and the aspirations for growth in the Plan’s strategy.

Accordingly, in order to secure the targeted level of housing, a greater level of provision for new allocations should be applied in order to meet the housing requirement. This would bring about better certainty that the housing requirement is met by the housing supply over the Plan period, not least given that the current Plan failed in this respect. Without a re-apportioning of the housing supply, it is considered that the Plan would heavily rely on the contingency (i.e. rolled forward LDP sites) coming forward in the Plan period, yet there is uncertainty that these will yield in full over the new Plan period. This raises issues of ’soundness’, and risks rendering the Plan unrobust.

Housing Delivery Rate Assumptions

As set out in our previous representations to the Housing Trajectory consultation, we have considerable concerns in relation to the proposed delivery of the sites identified in the trajectory – which we do not consider are robust or reasonable.

Appendix 1 of the Deposit Plan sets out the development trajectory bar chart – which illustrates the proposed delivery of housing, on a per annum basis, over the Plan period.

Extract of Housing Trajectory Graph (annotated by GJP – red dotted line)
It is our view that the trajectory makes for an unrealistic and unrobust delivery rate of housing, which does not reflect the pattern of housing completions in the Vale of Glamorgan. We therefore have concerns regarding the soundness of the trajectory, not least that there remain significant uncertainties as to the delivery of the Key Sites (as discussed earlier in these representations).

Firstly, the graph / trajectory illustrates a large ‘spike’ in terms of housing delivery in the year 2027-28, which is considered to be a marked and pronounced step change in the rate of delivery. This envisages / relies on a significantly higher rate of delivery than previous years in the Vale of Glamorgan (2021 through 2021 – as depicted by the green columns). It is considered that this level of delivery is unlikely to materialise, not least given prevailing market

circumstances, past rates of delivery on the ground, and also in light of levels achieved across Wales and the UK in general.

The published trajectory shows that the average level of completions from 2021 - 2025 has been approx. 400 - 500 units, however, the chart shows that from 2027 – 2028, completions are expected to rise to approx. 1,000 units per year. The expected delivery levels in the trajectory therefore show and assume a doubling in delivery rates and unit numbers (an increase of approx. 100% relative to past rates). There is no clear evidence as to how this level of completions can be achieved let alone guaranteed. This is the case in particular given that the forthcoming years (2025-2027) are expected to see performance (yield) drop significantly (delivery rates in 2025 – 2026 and 2026 – 2027). The chart shows only approx. 200 units being delivered over these years. It is therefore unclear how completion rates are expected to rise so quickly (from 200 in 2025-26 to 1000 in 2027-28), and by such a significant amount. The assumptions in the trajectory are wholly unrobust in our view.

It is also the case that the anticipated delivery of housing fails to be consistent within and across the Plan period. It is unclear as to why completions rates aren’t spread out more evenly throughout the Plan period - to ensure a robust and most realistic housing trajectory until 2036. By comparison to the marked increase in the rate of delivery between and over the period 2027 to 2031, there is then a marked fall-off or drop in delivery towards and by the end of the Plan period. Indeed, in the final year, the level of completions are expected to be lower than the period 2021-2025.

Accordingly, we consider that the housing trajectory, as proposed, is entirely manufactured and unreflective of the past completion rates, as well as the recent published completion rates provided by Welsh Government recently in August 2025. As set out in our previous representations, it has been evidenced that there has been a general decline in the number of new dwellings started and completed.

Description of Figure 1: ‘New House Building: April 2024 to March 2025’
As identified in the graph above, in 2024-25, 4,631 new dwellings were completed, which represents 3% fewer than the previous year. This figure represented the second lowest number on record, with the lowest number recorded in 2021-22, a year heavily affected by the coronavirus (COVID-19) pandemic (in 2021-22, 4,616 new dwellings were completed) The New Housing Pipeline Report Quarter 3, 2025 Report (December 2025) published by the HBF evidenced that the number of residential units approved in the UK fell by 7% during the third quarter of 2025, extending the decline seen during the first half of the year. At 45,075, the number of units approved was 34% down on the third quarter of 2024 and the lowest quarterly total since 2012 Q2. At 146,798, the overall number of units approved during the first nine months of 2025 was 25% lower than a year ago.



HBF Graph Illustrating Residential Approvals (2006-2025)

The above graph clearly shows a pronounced downward trend in the number of residential planning approvals over the period, particuarly with a sharp decrease seen since 2020. Further, the HBF document ‘Increasing Housing Supply in Wales’ (4th September 2025) clearly shows that The Vale of Glamorgan has not met the housing delivery requirements in recent years in 2023 – 2024 – along with every other authority in Wales (except Newport). Accordingly, this further adds to the argument that historically The Vale (and most other authorities) have underprovided. This adds considerable uncertainty on the assumed transformation in yield and delivery as built into the trajectory.

Graph: Housing Delivery as a proportion of annual housing requirement in Wales per Authority

More recently, the Welsh Government has released its new estimates of housing need (Estimates of Additional Hosing Need: 2025-based – February 2026). The estimates show how many new homes need to be built over the next twenty years to address existing unmet need as well as newly arising need. The figures set out that around 8,700no. new homes a year are needed over the next Senedd term up to 2030 to meet new housing need. Additionally, there is an unmet need for 9,400 affordable homes.

Overall, this represents more than double 2024/25 levels of supply, where just 4,638 new homes were built.

HBF: Estimates of Housing Need

HBF: Actual Delivery vs Estimates of Need

The above graphs unequivocally evidence that historical rates of delivery of housing in Wales has remained low, and moreover, significant numbers of housing need to be allocated in order to meet the estimate of need. It is not

considered that the housing trajectory, in its current form, is robust to meet the housing need over the Plan period, given the uncertainties of the Key Sites, and the level of housing delivery that has been identified for the Plan.

Affordable Housing-Led Sites

HG4 - Rural Affordable Housing Led Sites

Policy HG4 of the Deposit Plan identifies four sites to be allocated as affordable housing-led sites, totalling approximately 122 dwellings within the plan period. Given the target levels of achieving 3,070 affordable dwellings over the course of the Plan period (up to 2036), it is not considered that this policy goes far enough to address the target and level of affordable housing need.


It is noted that the number of units identified for each site relate to the ‘total’ number of units delivered, as opposed to the affordable housing provision. Accordingly, it can be assumed that circa 50% of each allocation will comprise affordable units (given each site is affordable-led), which would equate to a total provision of circa 61no. units. The contribution from the affordable housing-led sites would only equate to 2% of the total need (3,070no. units). Even when coupled with the affordable housing provision from open market sites and 100% exception sites, the total delivery of affordable housing will still be nowhere near enough to meet the overall affordable housing need over the Plan period. Accordingly, it is considered that inadequate provision has been made for such sites – not least given that 3 of the 4 allocated affordable housing-led sites are located west of Cowbridge.

Insofar as to the sites chosen and allocated are concerned, it is clear from reviewing the Stage 1 and Stage 2 Candidate Site Assessment that the allocated sites HG4(1) – (4) were not considered acceptable due to being outside the strategic growth areas, and were considered to be unacceptable intrusions into the open countryside. After being resubmitted as affordable housing-led sites, the sites were allocated, some with a smaller area in order to accommodate less dwellings in total.

The sustainable credentials of the sites allocated is not disputed, and it is acknowledged that these minor rural settlements have the ability to accommodate further growth, in the form of affordable-led housing allocations. However, it is considered that Land South of A48, Bonvilston (Site ID: 435 / 3857) should also form an allocation as part of this policy, given its high sustainability credentials and its appropriate location to accommodate a suitable level of development. Please refer to the previous representations made to the Housing Trajectory Consultation (dated 17th October) for further, more detailed comments regarding the above sites.

The LHMA 2023 shows that there is a need for 77 affordable homes in the St Nicholas & Llancarfan housing market area (which Bonvilston is located within), and a need for 242 affordable homes in the Wenvoe housing market area. As such, there is an identified need for affordable housing in this area, something which the site could address through an allocation.

Securing further delivery of Affordable Units

As set out above, it can be assumed that the affordable housing-led allocated sites only provide 61no. affordable dwellings, which comprise 4no. allocated sites that are expected to deliver approximately between 20 – 50 dwellings (including both affordable and market housing). However, the RLDP sets a target of 3,070 affordable homes to be delivered in the Plan period. This means that affordable housing-led allocations make up less than 4% of the target provision and will only make provision for 2% of the targeted number. We would therefore object to the sites included

within Policy HG4 and would suggest that more sites should be allocated as part of the policy in order to secure delivery of a higher number of affordable housing units to meet the target.
Whilst it is acknowledged that the Key Sites will provide for a significant proportion of affordable housing, as set out above in these representations, there is serious concern regarding the deliverability of these sites, which would result in a significant gap of affordable housing delivered.

A greater number of affordable housing-led sites allocated would ensure there is sufficient contingency built into the Plan, to ensure that the overall affordable housing need is met over the Plan period. Failure to do so would result in affordable housing need being unmet, with demand continuing to outstrip supply.

Previous representations to the Preferred Strategy (dated 14th February 2024) provided comment on the sustainability scoring of Bonvilston and the proposed site. As outlined within these representations, it is considered that the site (ID 435 / 3857) represents a sustainable, deliverable and acceptable site. This proposed allocation is situated in proximity to Cowbridge, Culverhouse Cross and Cardiff, which comprise all key services. Given that the site is located within 4 miles of both Cowbridge and St Nicholas, the site is within a maximum 20-minute bus journey of the following key services:

• Cowbridge Comprehensive School;
• St Nicholas Primary School;
• Cowbridge Health Centre; and
• Cowbridge town centre for various Retail Services.

Accordingly, the settlement of Bonvilston represents an acceptable location to allocate an affordable housing-led site, given the access to existing services and facilities that would serve future residents of the site.

To conclude, the settlement, location and site are inherently suitable and deliverable, and will make a significant contribution to achieving and realising the housing and economic development needs of Bonvilston, support the surrounding settlements, and the Plan area as a whole. As such, the site should be considered further.

Comments on Specific Policies

HG5 - Affordable Housing Exception Sites

Given the unmet need and extant backlog of affordable housing, as identified within the LHMA (2023), it is noted that an Affordable Housing Exception Sites policy has been adopted in order to assist in the delivery of affordable housing. Policy HG5 sets out the specific criteria where proposals for 100% small scale affordable housing developments will be permitted outside settlement boundaries. The current policy wording for the Affordable Housing Site Exception Policy and the criteria listed out in the policy is generally supported.

That said, it is noted that a ‘cap’ of 10 dwellings (as referenced within supporting text Para 6.140) is set. This should be amended due to such a ‘cap’ limiting the flexibility of the policy, in particularly for sites coming forward as part of this policy in Minor Rural Settlements.

As such, we would suggest that supporting Para 6.140 should be amended in order to allow for further flexibility for sites in Minor Rural Settlements to come forward and to deliver affordable housing, given that the criteria set out in the policy would already protect and restrict the extent of any development as it stands. Therefore, the proposed amendments to Para 6.140 are outlined below in red:

6.140 “For the purposes of this policy, ‘small-scale’ will generally mean no more than around 10 dwellings on sites adjoining Minor Rural Settlements. In Primary Settlements outside the Strategic Growth Area, proposals for more than 10 dwellings may be acceptable where required to meet a specific need and where the number of dwellings is proportionate to the size of the settlement. In assessing the scale and extent of any proposed local needs housing, consideration should also be given to affordable housing already planned in the ward or nearby area, including sites

with existing planning permissions and those allocated in the RLDP. The size and type of affordable housing proposed should reflect the identified local need in the area.”

The above suggested wording would achieve a more flexible policy, which would allow for a variety of scaled applications to secure planning permission for solely 100% affordable housing across the Authority area. This greater flexibility would enable the policy to make a significant contribution towards meeting the affordable housing need – which, as set out earlier is in considerable need.

SECTION 3. Suitability of the site for development

The site promoter objects to the overall assessment of the site, in that it is not considered suitable for further development in the Plan. The promoted site has undergone extensive scrutiny and appraisal at a high level to ascertain the qualities of the site, in light of all identified material considerations which relate to the proposals.

The delivery of the site will yield much needed housing (including Affordable housing) and contribute to the overall supply in the new Plan period, whilst making effective use of a suitably located site for residential development.

Moreover, as set out in ‘Annex 2’ of our representations, the site has overcome the ‘constraints’ set out in the Candidate Site Assessment undertaken for the site, which demonstrates that the proposal is both acceptable and deliverable.

Deliverability of the Site

In summary, the site seeks to deliver the following key elements:

• In summary, the opportunity of the site seeks to deliver:
• Residential development comprising up to 25 dwellings, with at least 50% affordable housing in accordance with Policy SP2,
• Highways infrastructure within the site;
• Upgraded access to the site;
• Strong legible pedestrian and cycle connections throughout the site and with the existing settlement;
• Green Infrastructure; and
• Sustainable Drainage Systems (SuDS).

SUMMARY AND CONCLUSIONS

In summary, the site promoters:

• Object to the distribution of growth proposed for the Plan area, with a more balanced and equitable distribution of housing sites required in order to meet the identified housing need;
• Object to the level of growth identified for the Plan period;
• Object to the housing trajectory that underpins the delivery of housing within the Plan period – which is considered to be unrealistic and unrobust, leading to serious uncertainty regarding the “soundness” of the Plan;
• Object to the over-reliance on Key Sites and Rolled Forward Sites in making up the Plan’s housing land supply;
• Object to the scale and timing of delivery of sites in / around St Athan – all of which are predicated on railway station provision which will not be realised in the Plan period;
• Object to the under-provision of sites under Policy HG4 – Rural Affordable Housing-Led sites, not least given their extremely limited contribution to the targeted need for affordable housing;
• Object to the current wording of the HG5 Policy ‘Affordable Housing Exception Sites’ which requires greater flexibility to play an important role in delivery much-needed affordable homes across the Authority; and
• Object the Council’s assessment that the site is not considered suitable for development.

The site and proposals are consistent with the RLDP strategy, other Vale of Glamorgan strategies, and the requirements of Planning Policy Wales and Future Wales. It will make a significant contribution to the Vale’s identified housing requirement in the RLDP period and will provide for a wide range of uses that will support the wider community whilst embodying principles relating to placemaking and the well-being of future generations.

The site has no fundamental constraints and has the ability to deliver significant economic, social and environmental benefits for the benefit of future residents and the existing local community. The site is demonstrated to be viable, being able to deliver policy-compliant levels of affordable housing and given its location within a strong market area, will benefit from high delivery rates.

ANNEX 2
SECTION 4. A summary of the suitability of the site for development including a Response to the Candidate Site Assessment

This section of the overall representations to the Deposit Plan is to respond to, and address, the Council’s assessment of the site.

While the issues the Council have raised in their assessment of the site have been addressed and discussed within the representations made at the Preferred Strategy stage of the Plan, a similar ‘scoring’ exercise has been undertaken as part of the evidence base for the Deposit Plan. As such, it is still pertinent to consider and respond to the Council’s assessment of the site as part of these representations

The Detailed Site Assessment for Land South of the A48, Bonvilston (Site ID: 3857) sets out that the position of the site at the Deposit Stage is as follows:

“Notwithstanding the amendment from a market led to an affordable housing led scheme (original CS 435), the other reasons why the site was previously discounted still remain.
The development would have an adverse impact on the character and setting of the Bonvilston Conservation Area. Development of the site would require major highway mitigation works to enable safe vehicular access on to the A48.
The Predictive ALC Maps indicates that site is Grade 2 Best and Most Versatile Land. Development of the site would lead to the loss of BMV land. BMV land should only be developed if there is an overriding need for the development and either previously developed land or land is lower agricultural grades is unavailable. There is housing land available within the ward of St Nicholas and Llancarfan that can support the delivery of affordable housing.”
Conservation Area
In terms of the assertion that “The development would have an adverse impact on the character and setting of the Bonvilston Conservation Area, this is strongly disputed.

Whilst it is acknowledged that the site lies within the Bonvilston Conservation Area, the conclusion that it would be adversely affected is not considered to be accurate. Firstly, the site as it currently stands, consists of an open field. This does not match the conservation area which is characterised primarily by residential dwellings of varying densities, and as such, it is considered that development of the site with sensitively designed buildings would enhance as opposed to harming its surroundings.

Secondly, the large residential development to the north of the site, ‘Land at Sycamore Cross’ ref. 2015/00960/FUL encroaches on the Bonvilston Conservation area but was deemed acceptable by the LPA. Although not all of the site is within the Conservation Area, it’s encroachment and presence adjoining and surrounding a large proportion of the area is considerable and was deemed acceptable by Officers in 2017. Given this, a development at the Land South of the A48 should be deemed acceptable, as it follows the same principles albeit at a much smaller scale.

Highways
As for the statement that “Development of the site would require major highway mitigation works to enable safe vehicular access on to the A48”, this is also strongly disputed.

The site is located immediately adjacent to the adopted highway where it is proposed to upgrade and enhance the existing gated access point. Due to the existing access point, it is not considered that ‘major’ highway mitigation works would be needed, rather this would be enhanced and improved as part of the proposed development. Furthermore, given the nature of the road, with long views extending in both directions, it is anticipated that appropriate visibility

splays could be achieved to enable safe access and egress. As such, it is considered that the site would achieve appropriate highway access within the need for “major” highway mitigation works.

Agricultural Land Classification
The Detailed Site Assessment also sets out that “The Predictive ALC Maps indicates that site is Grade 2 Best and Most Versatile Land. Development of the site would lead to the loss of BMV land. BMV land should only be developed if there is an overriding need for the development and either previously developed land or land is lower agricultural grades is unavailable.” This is strongly disputed.

A review of the Agricultural Land Classification Predictive Map indicates that the site lies primarily within ‘Grade 2: Very good quality agricultural land’ but no Grade 1 land is present. Further assessment and tests to establish the quality would therefore be undertaken in due course to confirm the quality of the land. However, it is not considered that it would be suitable to farm in any event given the location immediately adjoining existing residential development and the fact that it is within private ownership. Overall, given that the site is relatively small with a gross area of 0.88 hectares, it is not considered that its development would result in a detrimental or significant loss of agricultural land – not least given that site is not capable of beneficial agricultural production due to its limited size.

Housing / Housing Land
Further to the above, it is also set out that “There is housing land available within the ward of St Nicholas and Llancarfan that can support the delivery of affordable housing”, however, this is not considered to be entirely accurate.

The LHMA 2023 shows that there is a need for 77 affordable homes in the St Nicholas & Llancarfan housing market area and a need for 242 affordable homes in the Wenvoe housing market area. This need has not been met through the allocations of sites within the RLDP, nor has it been met through outstanding commitments.

As outlined in Annex 1, it can be assumed that the affordable housing-led allocated sites will only provide for 61no. affordable dwellings within the Rural Vale, comprising 4no. sites that are expected to deliver approximately 20 – 50 dwellings (including both affordable and market housing). However, the RLDP sets a target of 3,070 affordable homes to be delivered in the Plan period. This means that affordable housing-led allocations make up less than 4% of the target provision and will only make provision for 2% of the targeted number. Therefore, more sites should be allocated in order to secure the delivery of a higher number of affordable housing units to meet the target.

As set out within Annex 1, it is acknowledged that the Key Sites will provide for a significant proportion of affordable housing, however, there is serious concern regarding the deliverability of these sites, which would result in a significant gap in the total affordable housing that is delivered. Therefore, allocating a greater number of affordable housing-led sites would ensure there is sufficient contingency built into the Plan, to ensure that the overall affordable housing need is met over the Plan period. Failure to do so would result in the both the overall affordable housing need, and the need for the St Nicholas & Llancarfan housing market area, being unmet, with demand continuing to outstrip supply.

The LHMA 2023 sets out the existing stock and planned supply of affordable housing over the next 5 years (up until 2028). This assessment found that the housing market area of St Nicholas & Llancarfan has a committed supply of 4no. one beds, 11no. two beds, and 3no. three beds, with 2 no. three beds as expected re-lets. The assessment also identifies a committed supply of 39no. units for intermediate housing.

The LHMA also sets out the existing stock and planned supply for Wenvoe, identifying the committed supply of social rent homes to be 12no. one beds, 11no. two beds, and 5no. three beds, with 7no. one beds and 8no. two beds as expected re-lets. There is no committed supply for intermediate housing in Wenvoe.

It should be noted that the development of ‘Land East of Nicholas’ (Campbell Court and Cae Newydd), has now been completed, and as such, can not form part of the housing land available. The latest Pre-Application Response for the site subject to these representations (Land South of the A48, Bonvilston) accounted for the development of the site in

St Nicholas, stating that “even after the developments at St Nicholas and Culverhouse Cross, there was the need in the Wenvoe ward for 1 Bed 71, 2 Bed 49, 3 Bed 29, 4 Bed 7, 5 Bed 5, Total 161".

It should also be noted that there are existing commitments within the Bonvilston area (‘Land to the east of Bonvilston’), however, the deliverability of the existing commitment is seriously questioned. Application Ref. 2015/00960/FUL was approved in July 2017, with the Housing Land Supply and Housing Trajectory Report (December 2025) confirming that of the total 120 units permitted, only 40 had completed by 1st April 2025, with the remaining 80 units not started by this same date. Of the 80 units not started, 25 units are affordable homes.

It is well known that phase 1 of the development at ‘Land to the east of Bonvilston’ has faced difficulties which has led to the development remaining incomplete. This does of course put into question the overall deliverability of the site, and raises concerns about the units that were, and still are, required within the Bonvilston area.

The allocation of the site promoted herein would not only help in the short term in meeting the overall affordable housing target for the Plan, but would also assist in meeting the unmet needs of affordable housing within Bonvilston – not least given the serious concern regarding the deliverability of the committed supply of housing within the St Nicholas & Llancarfan housing market area.

For the reasons set out above, and in light of the information provided within the LHMA 2023 and the Housing Land Supply and Housing Trajectory Report (December 2025), it is evident that there is considerable need for affordable housing within Bonvilston, and accordingly, the housing market areas of St Nicholas & Llancarfan, and Wenvoe. There have not been any sites allocated to assist within meeting the local need, and more sites should be allocated in order to secure delivery of a higher number of affordable housing units to meet the overall target of the Plan.

The contention that “There is housing land available within the ward of St Nicholas and Llancarfan that can support the delivery of affordable housing” is therefore strongly disputed – not least given that there is a clear and evident need to allocate more affordable housing-led sites in order to meet the target set out in the Plan.

Interim Summary

In summary, it is considered that the site subject to these representations would not have an adverse impact on the character and setting of the Bonvilston Conservation Area, nor would major highway mitigation works be required to enable safe vehicular access on to the A48. Moreover, it is considered that the site’s classification as BMV Agricultural Land does not pose a fundamental constraint to development – as the site represents a relatively small parcel with a gross area of 0.88 hectares, which is not capable of beneficial agricultural production due to its limited size.

There is also a considerable need for the affordable housing in Bonvilston and the housing market area of St Nicholas & Llancarfan. The site promoted herein would assist in meeting these local needs and should be allocated accordingly.

Candidate Site Assessment

The Detailed Site Assessment undertaken by the LPA includes a summary and assessment of the ‘scoring’ system used at the Preferred Strategy stage. A comparison between the site assessments undertaken at both the Preferred Strategy stage and Deposit Plan stage is provided overleaf for reference.



Site Assessment at Preferred Strategy Stage Site Assessment at Deposit Plan Stage

As demonstrated above, there has only been one change to the scoring attributed to the site, this being a change from ‘red’ to ‘amber’ for ‘Developer Interest’. Detailed submissions were made on the previous assessment undertaken by the Council at Preferred Strategy stage, and as such, should be read in conjunction with these representations accordingly (see Appendix B).

Whilst detailed submissions were made on the previous assessment, it is considered pertinent for the scoring of the key criteria’s to be addressed as part of these representations. As such, these have also been discussed below.
Developer Interest

As set out above, the Detailed Site Assessment for ‘Developer Interest’ has changed from ‘red’ to ‘amber’. The assessment methodology for this section of the assessment has been extracted below for reference.


As set out above, ‘amber’ refers to there being no development interest identified at this stage, however, there is evidence to indicate that the site is being actively promoted by the owners.

The representations made to the Preferred Strategy (Appendix B) sets out that whilst the site does not yet have an agreement with a developer to take on the land, it is considered that this would be achieved should the site be allocated, and planning permission granted. Newydd Housing association have been engaged previously and had agreed to take the site forward as a 100% affordable scheme, albeit is also considered that they could take on the affordable units as part of a mixed tenure scheme.

In addition to Newydd, the site promoter has also received an offer from a private social housing provider who would be prepared to support the site as a mixed tenure scheme.

This position has not changed since the Preferred Strategy stage, and is considered that there is continued developer interest for the site. This is not considered to change at any point – not least given the discussions held between the owners of the site in questions and developers of interest.

Environmental and Physical Constraints

As set out at the Pre-Application Stage. the site underwent a Preliminary Ecological Appraisal in September 2022 which identified that whilst some precautionary measures were recommended in terms of protecting priority habitats and reptiles, the site is not fundamentally constrained from development on ecological terms. Given this, it is considered that further ecological surveys would be undertaken at the planning stage to inform any development proposals and ensure the safeguarding of the natural environment.

Access to Key Services (Retail, Primary Schools, and Health Services) and to Services and Facilities

As set out within the representations made to the Preferred Strategy, the site is located within a maximum of a 20-minute bus journey to a version of every key service listed, due to the proximity of the site to settlements such as Cowbridge, Culverhouse Cross and St Nicholas. Due to the availability of frequent bus services, and active travel links, these key services are readily available to access for any residents within Bonvilston without the need to travel by car.

To reiterate, the site ‘Land South of the A48, Bonvilston’ is situated in proximity to Cowbridge, Culverhouse Cross and Cardiff, which comprise all key services. Concluding this allocation as ‘unsustainable’ in regard to ‘availability of local facilities in and around settlements’ is not accurate. Given that the site is located within 4 miles of both Cowbridge and St Nicholas, the site is within a maximum 20-minute bus journey of the following key services:

• Cowbridge Comprehensive School;
• St Nicholas Primary School;
• Cowbridge Health Centre; and
• Cowbridge town centre for various Retail Services.

It should also be noted that Bonvilston contains a number of facilities within a short and level walking distance of the site, including the village shop and Café, as well as the Red Lion Public House.

Given the accessibility of the site to other settlements, and the fact that these are made accessible by bus and active travel routes, it is considered that the site should be concluded as sustainable in regard to access to key services.

Summary and Conclusion

As evidenced above, and within the representations made to the Preferred Strategy (Appendix B), there are no fundamental constraints at, or associated with the site, that would preclude the site coming forward for development in the RLDP period.

To conclude, the settlement, location, and site, are inherently suitable and deliverable, and will make a significant contribution to achieving and realising the housing and economic development needs of the Vale of Glamorgan.

Summary of These Representations

In short, and to summarise the case made and set out, these representations seek to object to the Housing Trajectory published as part of the consultation on the Draft Housing Trajectory For Housing Stakeholder Group (October 2025) which underpins the Plan and the delivery / realisation of its underlying strategy.

Detailed submissions and objections are raised below in respect to the trajectory information published regarding the soundness and robustness of this information (and it’s consultation), which we do not consider are adequate, robust, or sound to deliver the Plans aims and objectives.

Preface

This Submission sets out the detailed case in support of these representations. The representations are structured as follows:

1. Procedural Consultation Matters;
2. Timing Assumptions underpinning the Trajectory;
3. Housing Delivery Rate Assumptions;;
4. Status & Standing of Sites included in the Trajectory;
5. Key Sites;
6. St Athan Train Station;
7. Geographic distribution of the ‘new’ sites / provision;
8. Detailed comments in respect to ‘new’ sites;
9. Conclusions Procedural Consultation Matters
Firstly, we do not consider that the consultation on the Housing Trajectory information has been procedurally undertaken appropriately or suitably.

Only 14 days have been afforded to parties to make representations on the information provided. This is despite new sites being introduced (at this late stage) i.e. Land South of Clive Road (identified in Table 4), as well as a number of affordable housing led housing sites being introduced (i.e. those outlined in Table 5). This does not provide an adequate process or timescale for objectors to scrutinise the published content, and to make comments on sites which have been presented for the first time at a late stage in the process.

As part of these representations, we will be making brief comment on the sites which have not been previously consulted upon, namely:
Other Housing Allocations
• Land south of Clive Road, St Athan;

Affordable Housing Led Sites
• Land at Heol Fain, Wick;
• Land west of Maendy Road, Aberthin;
• Land Noth of West Winds Business Park, Fferm Goch; and
• Land to the East of Colwinston.

It is considered necessary to comment on these sites, given that they form an important and critical part of the housing trajectory, and by association in the Council and Plan reaching their targets. Moreover, these sites have not been consulted on previously. Accordingly we consider it necessary to pass comment on these in order to ensure that the consultation is fair and robust.

As well as limited time given to comment on the information contained within the Housing Trajectory, the LPA have failed to set up a Housing Stakeholder group to agree and discuss the trajectory information and data – with the cover email to the consultation (dated 3rd October 2025) stating “it is considered that it would be the best use of stakeholder time to conduct this engagement via email, particularly as many of the forecasts have been developed in consultation with site promoters including developers and their agents”.

We submit that the stakeholder consultation has not been a transparent nor robust consultation process, given that the Development Plans Manual states at Para 5.66 “A housing trajectory must be prepared to support the Deposit Plan. In order to generate a housing trajectory and associated phasing tables it will be necessary for LPAs to engage with stakeholders through a Housing Stakeholder Group. This will ensure that the timing and phasing of sites is robust and based on up to date information”. Given that this has not taken place, we would raise fundamental concerns that the consultation of the trajectory has not adequately taken place as per the relevant guidance. Afterall, the guidance stresses that a Group should be formed as a necessity. Accordingly, there has not been an adequate process and opportunity to review and comment on the information published, including in respect to the other sites have been introduced at this late stage.

Timing Assumptions underpinning the Trajectory

The assumed and factored in timescales of the various stages of bringing forward sites i.e. the pre-application stage, the planning application process, and the discharge of condition process outlined in the trajectory are considered to be fundamentally inaccurate, and result in a distorted position of the delivery of housing sites over the RLDP Plan period. The assumptions are far too ambitious, and without evidence / are not comparable with the timescales being incurred in processing such stages at the Development Management stage(s).

Specifically, we raise objection to the following timescales which are considered to be extremely ambitious and unrealistic:

• “Time period of pre-application discussions/PAC consultation” = 4 months
• “Time between submission of planning application and determination” = 6 months
• “Time taken from planning consent to the discharge of relevant conditions to enable site construction” = 4 months

In our experience, having submitted a significant number of major and other applications for housing and other forms of development in the last 1-2 years to the Council (and elsewhere in Wales and England), it is extremely unlikely that major applications can be submitted, and planning permissions granted, within the timeframes assumed by the trajectory. A wide range of stakeholders are also involved in the determination of major planning applications, which often adds to the delays associated with the determination of such applications. We would therefore consider that a time period of “6 months” given to all major applications in the housing trajectory is not feasible, and distorts the trajectory timescales for the remaining Plan period.

The assumptions in the trajectory are also solely based on expected timescales for the processing of formal submissions made to the Council, and do not factor in the timescales associated with, and needed for, the preparation of the material for submission (i.e. pre-application enquiry submissions / planning application / discharge of condition details etc). When factored in these will elongate the timescales for bringing forward schemes considerably.

Moreover, it is common practice for larger housing sites and major applications to have a range of pre-commencement conditions attached to a permission once granted. Again, we would raise concerns with the timescales indicated in the trajectory related to this part of the planning process. It is highly unusual and questionable that any technical work required by these conditions (usually relating to drainage and highways matters) would be instructed, completed and submitted within 2 months, and for these to then be signed off / approved in a further 2 months. There are also other technical matters and necessary approvals falling outside of, and over and above, the planning system, such as SAB, s.106, s.38 and s.278 agreements, timescales for which have not been accounted for – and all of which are rarely completed within “4 months” as indicated.

It is therefore highly doubtful that the timescales legislated for in the trajectory for the various stages pre-construction are achievable – with no information about these proposed timescales outlined within the supporting text of the Housing Trajectory. We would therefore raise considerable concerns and objections to these as they stand without full evidence to fully show how these have been calculated, and without there being considerable (and necessary) adjustment to the timescales indicated and factored in.

We would therefore object to the timescales indicated in the ‘Timing and Phasing of Sites’ table, given that the delivery start dates will be pushed back further into the Plan period. Accordingly, and as a result, the Plan is at risk of not delivering the level of housing expected based on the sites allocated, at least as swiftly as is set out in the trajectory.

Housing Delivery Rate Assumptions

We would also raise considerable doubt over the proposed delivery of the sites identified in the Housing Trajectory - which we do not consider are robust or reasonable.

The development trajectory bar chart set out in the consultation material (extracted below) anticipates and legislates for a number of critical events and circumstances – all of which are considered to be unrobust and unsound.

Extract of Housing Trajectory Graph (annotated by GJP – red dotted line)

Firstly, a large ‘spike’ (material increase) in housing delivery is factored in to take place in 2027 – 2028. This is a marked and pronounced step change in the rate of delivery, and envisages / relies on a significantly higher rate of delivery than previous years in The Vale of Glamorgan (2021 through 2025 - as depicted by the green columns). This is considered extremely unlikely to materialise, not least given prevailing market circumstances, past rates of delivery on the ground, and also in light of levels achieved across Wales and the UK in general.

The published trajectory shows that the average level of completions in The Vale of Glamorgan from 2021 - 2025 has been approx. 400 - 500 units. However, the chart shows that from 2027 – 2028, completions are expected to rise to approx. 1,000 units per year. The expected delivery levels in the trajectory therefore show and assume a doubling in delivery rates and unit numbers (an increase of approx. 100%relative to past rates). There is no clear evidence as to how this level of completions can be achieved let alone guaranteed. This is the case in particular given that the forthcoming years (2025-2027) are expected to see performance (yield) drop significantly (delivery rates in 2025 – 2026 and 2026 – 2027). The chart shows only approx. 200 units being delivered over these years. It is therefore unclear how completion rates are expected to rise so quickly (from 200 in 2025-26 to 1000 in 2027-28), and by such a significant amount. The assumptions in the trajectory are wholly unrobust in our view.

The anticipated delivery of housing also fails to be consistent within and across the Plan period. It is unclear as to why completions rates aren’t spread out more evenly throughout the Plan period - to ensure a robust and most realistic housing trajectory until 2036. By comparison to the marked increase in the rate of delivery between and over the

period 2027 to 2031, there is then a marked fall-off or drop in delivery towards and by the end of the Plan period. Indeed, in the final year, the level of completions are expected to be lower than the period 2021-2015.

To summarise, we consider the defined position to be wholly manufactured and unreflective of the past completion rates, as well as the recently published completion rates provided by Welsh Government recently in August 2025. In the Welsh Government Statistics Document ‘’New House Building: April 2024 to March 2025’, information on the number of new dwellings started is provided, where building has commenced and those completed for April 2024 to March 2025. Figure 1 provides a graph showing starts in the last 10 years, and it is clear that there has been a general decline in the number of new dwellings started and completed.

Description of Figure 1:.‘New House Building: April 2024 to March 2025’
In 2024-25, 4,631 new dwellings were completed, 3% fewer than in the previous year. This was the second lowest number on record, with the lowest number recorded in 2021-22, a year heavily affected by the coronavirus (COVID-19) pandemic (in 2021-22, 4,616 new dwellings were completed). The New Housing Pipeline Report Quarter 2, 2025 Report (September, 2025) published by the HBF evidenced that the number of residential units approved in the UK fell by 6% during the second quarter of 2025, continuing the decline of approval during the first three months of the year. Wales saw one of the largest declines in the UK in approvals with a decline of 29%.

Further, the HBF document ‘Increasing Housing Supply in Wales’ (4th September 2025) clearly shows that The Vale of Glamorgan has not met the housing delivery requirements in recent years in 2023 – 2024 – along with every other authority in Wales (except Newport). Accordingly, this further adds to the argument that historically The Vale (and most other authorities) have underprovided. This adds considerable uncertainty on the assumed transformation in yield and delivery as built into the trajectory.



Graph: Housing Delivery as a proportion of annual housing requirement in Wales per Authority

The Home Building Sector Skills Plan (Aug 2025) published by the HBF also identified the following issues with the workforce to bring forward built development in Wales:

• “A shortfall in numbers entering roles from the education system;
• An ageing workforce: 25% of the home building workforce is aged over 50, meaning the sector is facing an impending retirement cliff edge;
• Challenges attracting a wider talent pipeline into the sector;
• A lack of understanding of critical future skills needed, and direction from the Future Homes Standard; and
• Output within the sector fluctuating with demand and economic pressures, leading to additional pressures in recruitment and training”.

It is not considered that in the next 1-2 years that any of these issues can or will be substantially corrected – at least sufficiently so to allow for, and enable, the planned delivery rates of new housing completions to be as high as < > 1,000 homes in one year (and for four consecutive years at that).

We would therefore object to the proposed numbers of completion expected during the Plan period, given that there are a number of issues with delivering housing in Wales and given past completions rates for The Vale of Glamorgan. Again, this results in the Plan being at risk of not delivering the level of housing expected based on the sites allocated.

Status & Standing of Sites included in the Trajectory

The proposed land supply within the housing trajectory includes provision for ‘rolled forward’ LDP sites, which contribute to the total of ‘Proposed Additional Housing Allocations’ forming part of the housing supply. Specifically, a total of 1,242no. units have been identified as additional housing allocations, of which 959no. are expected to be delivered on the rolled forward LDP sites. As such, these sites are to provide for a significant proportion of additional housing in the Plan period (specifically circa 77%).

The Development Plans Manual (DPM) sets out that allocations rolled forward from a previous plan will require careful justification for inclusion in a revised plan. The DPM outlines that “there will need to be a substantial change in circumstances to demonstrate sites can be delivered and justify being included again. Clear evidence will be required that such sites can be delivered.” The below table included in the consultation document provides a breakdown of the rolled forward LDP sites, and in particular, sets out the status of each site:




The above table evidences that the current LDP has under delivered in regard to its targeted unit number of the Plan period, given that these sites did not yield any housing over the current plan period. This is further exacerbated by the Land Bank sites that have also not delivered any housing across the existing LDP period, amounting to 1,860no units. Accordingly, when considering the non-delivery of both rolled forward LDP sites and Land Bank sites, this amounts to an approximate shortfall of 2,189 homes being delivered, or 33% of the total housing supply identified for the current LDP (8,525no. dwellings).

It is therefore considered that, as a minimum, the units carried over from the LDP (without planning permission) should be a surplus to the housing supply proposed for the RLDP, as opposed to being relied on to deliver the housing need over the Plan period. This is particularly the case for the two sites (Land to the west of Pencoedtre Lane, and Land between Northern Access Road and Eglwys Brewis Road) which do not currently have any active planning application submitted for their development. These sites total an amount of 370no. units to be delivered in the Plan period, which represents more than a third of the additional housing allocations to make up the housing supply.

As such, it is considered that the unmet need deriving from the existing LDP is still present – indeed it has grown, and will continue to do so, not least when considered in conjunction with the projected population growth over the coming years to 2036, and the aspirations for growth in the Plan’s strategy.

Accordingly, in order to secure the targeted level of housing, a greater level of provision for new allocations should be applied in order to meet the housing requirement. This would bring about better certainty that the housing requirement is met by the housing supply over the Plan period, not least given that the current Plan failed in this respect. Without a re-apportioning of the housing supply, it is considered that the Plan would heavily rely on the contingency (i.e. rolled forward LDP sites) coming forward in the Plan period, yet there is uncertainty that these will yield in full over the new Plan period. This raises issues of ‘’soundness’’, and risks rendering the Plan unrobust.

On this basis, we would object to the Plan if the provision of housing is not adjusted to rebalance the provision to include new allocations in lieu of rolled forward LDP sites in the housing supply.

Key Sites

As set out in previous representations at Preferred Strategy stage, it is considered that the housing supply relies heavily on the delivery of the ‘key sites’ to deliver housing (and meet need) over the Plan period. The total number of housing units attributed to key sites amounts to 2,278, which equates to over 25% of the total provision in the Plan period.

As detailed above, we consider there to be concerns regarding the proposed ‘Timing and Phasing of Sites’ table included in the Housing Trajectory which we consider are not reflective or accurate and will therefore have the effect of delivery start dates being much later into the Plan period than anticipated. The result of this will be that the Plan will be at risk of not delivery the level of housing expected and needed. Moreover, the Housing Trajectory Graph presents an overly ambitious level of housing completions over the Plan period - which the Council consider will be markedly higher than the average levels experienced in the last five years. Again, for the reasons set out above, we consider that these rates of expected completions to have no evidence supporting them, and to be unachievable and unsound.

Insofar as to the removal of the previously proposed site ‘Land at North East Barry’, this site was expected to deliver 900no. units in the Plan period. Following its omission from the housing supply, other sites have been identified, which comprises the inclusion of a new key site (Land at North West Barry), 3no. non-strategic sites, and also affordable housing-led allocations. In terms of the quantum of development attributed to these new sites, this amounts to 659no. dwellings. This is some 250 units less than the 900no. homes that was previously attributed to ‘Land at North East Barry’. Whilst it is appreciated that the number of homes forming part of the existing supply (completions, units with planning permission etc.) have increased since Preferred Strategy stage, there will be a net loss in market housing provision and delivery.

This position is made worse and compounded as a result of accounting for the affordable-led sites in making up the housing supply.

As set out within the Preferred Strategy, these sites are expected to deliver at least 51% affordable housing. These units are not open market units, and will not / cannot contribute to the supply of such housing. These units will contribute to the provision of affordable housing, and will go some way to meeting the acute need for such housing (albeit will not eradicate / address in full the well known and accepted considerable requirement). Accordingly it is considered that these sites should be in addition to the housing supply, as opposed to forming part of the provision. In turn, there would need to be an increase in allocations for non-strategic sites, to ensure that there is sufficient market housing delivery over the Plan period.

Were such changes to be made and introduced, this would achieve and assist realise a more robust and sound housing supply, which will ensure that the identified housing need is met / addressed over the Plan period. Without these changes it is considered that the housing supply is not sufficient, and inevitably, housing need will not be met within the Plan.

St Athan Train Station

As set out in the Preferred Strategy (para A3.29), the strategy seeks to focus development around key sustainable transport nodes. The strategy outlined that a feasibility study for a station in St Athan had been undertaken, which identifies that a new station could be located in St Athan, subject to further investigation work. Accordingly, in line with the spatial strategy adopted for the RLDP (i.e. focus development around sustainable transport nodes), St Athan was identified as a ‘Strategic Opportunity Area’ to accommodate strategic growth – through the proposed allocation of two key sites : ‘Land at Church Farm’ and ‘Land West of St Athan’. These sites have been identified to deliver 532no. and 600no. units respectively in the Plan period. These are separate to, and are in addition to, the 51no. units that have now been attributed to the site ‘Land South of Clive Road’ in St Athan. Accordingly, in total, the Housing Trajectory makes a provision for a total of 1,183no. homes to be delivered in St Athan over the Plan period.

It is now the case that, subsequent to the publication of the Preferred Strategy, the proposed railway station at St Athan is not in the first phase of delivery for new stations in South Wales. The focus in the first phase of such improvements across the region is towards improving connectivity in east Cardiff, Newport, and Magor. Accordingly,

it is very unlikely that any new train station will be delivered in St Athan over the Plan period, which significantly questions the suitability and acceptability of the proposed allocations set out above.

The strategy to allocate new housing growth is predicated on focusing residential development around sustainable transport nodes, and given that St Athan will be without any railway station in the Plan period, it is not considered that these sites align with the strategy of the RLDP. Accordingly, the wider Housing Trajectory is considered to be unsound, given that a total of 1,183no. homes are expected to be delivered in St Athan within the Plan period.

It is considered that there has been an overprovision for housing growth in St Athan generally, and this issue is now further exacerbated by the lack of any forthcoming rail provision. Given this, to add a further site for housing in this location over and above the original provision is considered to be unsound. As set out above, the justification to allocate sites at St Athan has relied heavily on the railway station being delivered in the Plan period, and as such, there are serious questions marks associated with the acceptability of the proposed allocated sites - given their incompatibility with the core strategy of the RLDP.

We therefore consider the Trajectory to be both unrobust and unsound, and therefore, we object to the Trajectory in its current form accordingly.

Geographic distribution of the ‘new’ sites / provision

As a general and overarching comment in respect to the additional sites now included within the Plan, and forming part of the trajectory, (and a matter expanded upon when critiquing each of these sites in the next section to this submission), it is clear and evident that these additional sites have been positioned to settlements that have already, and recently, been attributed significant growth in the preceding Plan and plan period.

Significant allocations (which have also contributed to significant levels of affordable housing) have been realised and built out in locations (such as Wick and Colwinston). Notwithstanding this, two of the additional sites are now proposed for these recently expanded settlements. Given that the purpose of the affordable housing led allocations is to meet unmet affordable housing need, it is questioned why such new allocations are attributed to settlements that have already seen open market and affordable housing provision, as compared to other comparable settlements that have not received any growth whatsoever over a considerable period of time.

It is considered accordingly that the geographic positioning of these allocations is at odds with their underlying purpose - to meet unmet affordable housing need in communities that have seen no provision

Detailed Comments in respect to ‘new’ sites

Other Housing Allocations

Land south of Clive Road, St Athan

A summary of the Candidate Sites Assessment at Preferred Strategy Stage has been extracted below for ease:


As set out at the outset of these representations, and whilst we note the findings of the Candidate Sites Assessment at Preferred Strategy Stage (i.e. Suitable for further consideration), we do not consider that the consultation on this site has been undertaken procedurally appropriately or suitably. We therefore consider the consultation on this site is “unrobust” and “unsound”.

As set out previously, the strategy seeks to focus development around key sustainable transport nodes. The strategy outlined that a feasibility study for a station in St Athan had been undertaken, which identifies that a new station could be located in St Athan, subject to further investigation work. It is now the case that, subsequent to the publication of the Preferred Strategy, the proposed railway station at St Athan is not in the first phase of delivery for new stations in South Wales, where the focus is towards improving connectivity in east Cardiff, Newport, and Magor. Accordingly, it is very unlikely that any new train station will be delivered in St Athan over the Plan period, which significantly questions the suitability and acceptability of the proposed allocations set out above.

It is considered that there has been an overprovision for housing growth in St Athan generally, and this issue is now further exacerbated by the lack of any forthcoming rail provision. Given this, to add a further site for housing over and above the original provision is considered to be unsound. As set out above, the justification to allocate sites at St Athan has relied heavily on the railway station being delivered in the Plan period, and as such, there are serious questions marks associated with the acceptability of the proposed allocated sites – given their incompatibility with the core strategy of the RLDP.

Affordable Housing Led Allocations Land at Heol Fain, Wick
A summary of the Candidate Sites Assessment at Preferred Strategy Stage has been extracted below for ease:

Candidate Site Stage 2 Assessment (Site Ref. 404)

The findings of the Candidate Site Assessment for this site are noted. We are assuming the reason this site is proposed to be allocated is a product of the site promoters/developers heading the findings stated below, and changing the form of development to be in accord with this:

“A market housing led scheme would not be acceptable, but the site could be reconsidered as a small scale affordable housing led development subject to need and viability at a maximum of 50 dwellings. In accordance with the Settlement Appraisal Review, it is considered that Wick could potentially accommodate limited affordable housing led growth.”

Whilst no clear deficiency exists in respect to the site, it is known that Wick has been subject to significant growth and expansion in recent years – not least by virtue of significant housing allocations in the settlement as part of previous plans.

To evidence this, 35% of the 124 units approved on the ‘Rectory Field, St Brides Road’ site (i.e. circa 43 units as per site allocation ref. MG(47) and PP ref. 2014/01424/FUL) were approved as Affordable Housing units. This makes a substantial provision of such Affordable Housing units (and housing generally) in the settlement in recent years.

Other similarly sized and comparable settlements and locations have not by contrast been subject to any growth for some considerable time, and accordingly would warrant and benefit from provision as part of this new replacement plan.

Notwithstanding the location of such provision, and as set out in detail at the outset of these representations, National Planning Policy advocates the high and acute need for affordable housing, whilst recent analysis evidences that there is a housing emergency. These circumstances - coupled with the shortcomings identified and set out earlier in these submissions in respect to the adequacy of provision within the plan (rolled forward sites / inadequate provision etc) – means that notwithstanding any potential allocation at Wick, further provision ought to be made in comparable (previously unprovided for) locations, such as Ogmore By Sea.

Land West of Maendy Road, Aberthin

‘Land West of Maendy Road’ has been registered as an Affordable Housing Led Allocation candidate site for the RLDP, however as far as we know from our review, there is no assessment and critique of this site. This site has not been included in the ‘Candidate Assessment at Preferred Strategy Stage’ (October 2023). As such, with an absence of publicly available information, it is not clear how the Council has judged this site against the criteria. This raises questions accordingly in respect to the “soundness” of a site which forms part of the intended housing land supply, and by association the trajectory. Without this, and without being consulted on (as others have been prior to this) we question whether this allocation is “sound” (i.e. its allocation is considered to be “unsound”).

Land North of West Winds Business Park, Fferm Goch

The below sets out the candidate site stage two assessment of ‘Land to north and west of Westwinds Business Park’:

Candidate Site Stage 2 Assessment (Site Ref. 398)

As can be seen above the site was not considered suitable for further consideration with the site scoring negatively (red) in a number of key factors. These include the following:

• Access to Retail;
• Access to Health Services;
• Sustainable Transport- Public Transport;
• Access/ Proximity to services and facilities conclusion;
• Climate Change; and
• Health and Wellbeing.

Given the fact the site scores red in ‘Sustainable Transport – Public Transport’, this shows the site is not served by public transport connections within 800m, as outlined in the key below:


Additionally, Policy SP7 (Sustainable Transport) of the Vale of Glamorgan Preferred Strategy states “New development must support an enhanced transport network that increases the proportion of journeys being undertaken by sustainable travel modes”. Additionally Objective 8 (Promoting Active and Sustainable Travel Choices) states “new development is directed to locations that are or can be accessible by a choice of modes of transport, including walking, cycling, and public transport.”

It is well known residents of affordable housing are statistically less likely to own private vehicles, making access to reliable and frequent public transport essential for ensuring equitable mobility. The provision of public transport infrastructure in close proximity to such developments is therefore a critical component in supporting access to employment, education, healthcare, and other key services, while also promoting sustainable travel patterns and social inclusion.

The site also scores red in Access/Proximity to services, showing the site is greater than 1200m away from key services, as seen in the key below:


In respect of the above, Preferred Strategy 6.40 states the need “To ensure that new development takes place in locations that have the best access to a wide range of services, facilities, and employment opportunities, whilst minimising the need to travel, the distribution of growth is guided by the following settlement hierarchy”. To further highlight the importance of both sustainable transport and proximity to services, the preferred strategy also states the need to “Facilitate the development of adaptable, accessible, well-connected communities that have a strong sense of identity, offer a sustainable range of services and facilities and are equipped with adequate infrastructure”. In addition, Promoting Active and Sustainable Travel Choices outlines to “Promote and encourage the use of sustainable methods of travel, particularly active modes of transport, whilst simultaneously reducing the need to travel”.

In light of the above, this site does not align with the aims and targets set out in the Preferred Strategy as it fails to meet several key development goals set out. It should therefore not be considered suitable to be allocated for future developments. Its inclusion is therefore unsound.

Should this view be concurred with, 22 affordable units will be lost from the proposed affordable 122 units, and ultimately will be lost from the overall housing land supply. As stated in the draft housing trajectory “there is a need for small scale affordable housing led development (minimum 50% affordable) to respond to local affordable needs and help sustain services and facilities within these rural communities”. There is a clear possibility therefore that this proposed allocation is removed and/or not delivered as its inclusion is unsound as it does not align with the aims and targets set out in the Preferred Strategy - as it fails to meet several key development goals set out. A “small scale

affordable housing led development” which is needed to “respond to local affordable needs and help sustain services and facilities within these rural communities” will therefore not be provided for. This is clearly an issue.

Land to the East of Colwinston, Colwinston

A summary of the Candidate Sites Assessment at Preferred Strategy Stage has been extracted below:


As outlined above the site was rejected and considered not suitable for further consideration. In fact, and unlike ‘Land at Heol Fain, Wick’ and ‘Land to north and west of Westwinds Business Park’ it was stated that this site “could not be considered as a suitable affordable housing led development site”. Despite this, this site has been outlined as an Affordable Housing Led Allocation. As such, the inclusion of this site is “unsound”.

It is known that Colwinston has been subject to significant housing allocations in the settlement as part of previous plans. To evidence this, 25% of the 64 units (i.e. 16 units) were approved on the site allocation ref. MG2(41) and PP ref.

2014/00242/FUL. This makes a substantial provision of such Affordable Housing units (and housing generally) in the settlement in recent years.

Other similarly sized and comparable settlements and locations have not by contrast been subject to any growth for some considerable time, and accordingly would warrant and benefit from provision as part of this new replacement plan.

Notwithstanding the location of such provision, and as set out in detail at the outset of these representations, National Planning Policy advocates the high and acute need for affordable housing, whilst recent analysis evidences that there is a housing emergency. These circumstances - coupled with the shortcomings identified and set out earlier in these submissions in respect to the adequacy of provision within the plan (rolled forward sites / inadequate provision etc) – means that notwithstanding any potential allocation at Colwinston, further provision ought to be made in comparable (previously unprovided for) locations, such as Land South of A48, Bonvilston.

Summary of These Representations

To re-iterate, and to summarise the case made and set out, these representations seek to object to the Housing Trajectory published as part of the consultation on the Draft Housing Trajectory For Housing Stakeholder Group (October 2025) which underpins the Plan and the delivery / realisation of its underlying strategy.

Detailed submissions and objections are raised above in respect to the trajectory information published regarding the soundness and robustness of this information (and it’s consultation), which we do not consider are adequate, robust, or sound to deliver the Plans aims and objectives.

ANNEX 1
Preface

This Annex sets out the detailed case in support of these representations, and by association the case for allocation of the site.

The representations are structured into the following sections:

1. Response to the Deposit Plan;
2. Comments on specific policies; and
3. A summary of the suitability of the site for development.

SECTION 1. Response to the Deposit Plan

Distribution of Growth

We object to the distribution of growth within the Deposit Plan. Specifically, we object to the strategy that underpins the Deposit Plan, which seeks to introduce the proposed ‘Strategic Growth Area’ which is expected to contain the majority of housing growth in the Vale over the Plan period, or rather the over-reliance on this defined area, and the associated absence of growth in other parts of the Plan area.

As outlined in our previous representations, the allocation of housing and the location of strategic growth neglects the Rural Vale, and in our view, overprovides in the Strategic Growth Area. For example, with limited housing stock and average house sales at over £500,000 over the last 12 months, there is a clear and established need for new homes in the Ogmore By Sea area, particularly at an affordable level. This is reinforced by the Local Housing Market Assessment that identified a need for over 1,114 new affordable homes per annum over the next five years throughout the county, and 196 units per annum thereafter (average of 502 units per annum over 15 years). Further to this, it is widely known that the rural Vale comprises the majority of the county’s ageing population, which, as a demographic, has and will continue to grow rapidly over the Plan period. This is evident in the ‘Population Change’ chart below – which is taken from the Deposit Plan:

VofG Deposit Plan: Figure 4 Population Change 2011 to 2021

It is clearly the case that younger populations are migrating to other Authorities, where access to housing is typically cheaper and more affordable, whilst more older populations are significantly migrating into the Authority. This trend will result in an extremely unbalanced demographic, given that the working-age population have sought housing elsewhere.

Without a suitable supply of affordable housing delivered over the Plan period, this trend will only worsen. Accordingly, it is not considered that the RLDP takes into account the lack of supply of affordable homes within the rural Vale, as well as increased housing to support the growing ageing population within these areas.

Para 3.19 of the Deposit Plan clearly outlines that affordable housing is required in the short term, in order to meet pressing needs. Specifically, it outlines the following: “There is significant pressure on temporary accommodation in the Vale, for a variety of reasons including increased homelessness presentations… The need for sufficient permanent affordable housing to assist in moving people out of temporary accommodation is critical and the planning system has a vital role in assisting in new affordable housing delivery.”
Accordingly, the distribution of growth within the Authority must be proportionate, to ensure that populations / areas are not left behind where they must seek access to housing elsewhere.

The RLDP Sustainable Growth Strategy sets out 6 objectives. Objective 4 states: “Allowing for small scale affordable housing led development in settlements outside the Strategic Growth Area at a scale proportionate to the size of settlement.” (Page 66)
Para 5.25 states “Therefore, a key part of the strategy is to allow for affordable housing led developments within sustainable primary and minor rural settlements outside of the Strategic Growth Area, at a scale that is appropriate to the size of the community it is serving. An ‘affordable housing led’ scheme is one where a minimum of 50% of the dwellings would need to be affordable, although this could increase to a maximum of 100% if the site is brought forward by a social landlord”.

In terms of the definition / explanation of what the affordable housing-led development sites are seeking to achieve, paragraph 6.132 of the Deposit Plan outlines the following:

“Accordingly, to ensure that new developments respond to the high demand for smaller properties, as identified in the LHMA, priority will be given to affordable homes that are small to medium-sized, typically comprising one to three bedrooms. Representations received from the local community through the RLDP process also highlighted a desire for new housing developments to offer opportunities for accessing smaller market homes. This is particularly relevant in the rural Vale, where housing choices are more limited. Providing smaller, more affordable market homes may assist first-time buyers and enable older residents to downsize to more manageable properties within their local area. Affordable housing-led sites will therefore need to demonstrate that an appropriate range of both affordable and market dwellings has been provided.”

Despite the acknowledgement within this strategic objective, we do not consider that the RLDP goes far enough to meet this objective, nor are its provisions and allocations adequate.

It is considered that this objective is undermined by the allocations set out by the RLDP (not least the absence of allocations in the rural Vale). Notwithstanding the Vision’s clear acknowledgement of the benefit of the growth of the rural Vale, these areas have not been supported through the plan due to the lack of growth which has been attributed to these areas in terms of further housing, employment and sustainable transport. All growth options have been selected on the basis of being in either Key Settlement, Service Centre settlement or Primary Settlements, all of which are already sustainable areas served by rail. As a result, it is not clear how this objective can be achieved, without the allocation of further sites within the Minor Rural Settlements, such as Ogmore By Sea. The Vale is characteristically ‘rural’, and as such, there needs to be a stronger emphasis on supporting and delivering new development in order to bolster the rural economy. This includes enabling opportunities to provide employment and business premises within
/ near to rural settlements, as well as focusing housing growth in these areas to reduce travel time, and use of sustainable transport.

It is considered that the current Strategy does not provide adequately for all residents across the Vale, only those within the Strategic Growth Area. The underlying Vision and Objectives set out in the emerging Plan are accordingly wholly un-provided for by the detail of the Plan. This brings into question the “soundness” of the Plan.

The Strategic Growth Area does not take into account the important role and proximity of Bridgend to the West and/or the Principal Settlement and Strategic Growth Area of Talbot Green / Pontyclun / Llantrisant to the north (as defined in the RCTCBC LDP). The Minor Rural Settlements to the west are more likely to be supported by job opportunities and employment in Bridgend than further east in Barry or Cardiff. Similarly, those in the north align with, and function in association with, the Principal Settlement and Strategic Growth Area of Talbot Green / Pontyclun / Llantrisant to the north. These settlements are served by existing bus services that provide sustainable modes of travel to key employment locations in and around Bridgend. This is acknowledged in Paragraph 3.3 of the Strategy which states “The greatest number of residents who travel outside of the Vale for work purposes travel to Cardiff followed by Bridgend and Rhondda Cynon Taf, whilst a smaller proportion commute into the Vale from these neighbouring authorities”. The Demographic Evidence (Feb 2023) estimates the Vale as being a net importer of workers from RCT and Caerphilly (Para 3.6) - as shown in Figure 10 in the Preferred Strategy.

The current Strategy does not support any improvement of sustainable travel or further investment in settlements linked more closely to these areas - given that Growth has been apportioned in only the Key Service Centre and Primary Settlements. It is considered that this will fail to support and facilitate the current (and any future) employment coming into the Vale, nor will it support any employment which is located outside of the Vale to the West and North. The Growth Option is too heavily reliant on access to railway stations as the key and sole sustainable transport method, whereas access to bus services should also be appropriately assessed and focused on in terms of promoting sustainable development. It is unreasonable to devise a strategy that hinges on directing growth to areas that are accessible to railway facilities, where it is recognised in the Plan that the Vale is inherently rural. The delivery and soundness of the Plan is therefore questioned and we continue to object to the spatial growth strategy as set out in the Deposit Plan.

Housing Supply

RLDP Allocations - Key Sites

As set out in representations made throughout the Plan preparation process, we consider that the Plan is too reliant on the delivery of ‘key sites’ to meet the housing need over the Plan period. Specifically, the Plan makes provision for 2,278 units in these Key Sites, which equates to circa 65% of RLDP allocations in the housing supply. The 5 key sites that are allocated in the Deposit Plan are as follows:

• Land at North West Barry – 376no. units;
• North of Dinas Powys – 250no. units;
• Land at Readers Way, Rhoose – 520no. units;
• Land at Church Farm, St Athan – 532no. units; and
• Land to the West of St Athan – 600no. units.

We object to the current housing supply to allocate 2,278no. (65%) of units across strategic sites, as this makes for a risky and unrobust strategy for delivering housing, and in turn, meeting the identified housing need over the Plan period.

As stated in previous representations, there is concern that the proposed timing and phasing of the proposed Key Sites is unrealistic and unrobust, and in turn, undermines the soundness of the Plan, given the heavy reliance on Key Sites delivering new homes across the Plan period. Whilst it is not disputed that the sites would have gone through rigorous assessment to inform their proposed allocation, the timescales for securing planning permission (with all associated conditions discharged) is considered to be unachievable. This is particularly the case for the following timescales that are set out in the Housing Trajectory that underpin the Plan:

• “Time period of pre-application discussions/PAC consultation” – 4 months

• “Time between submission of planning application and determination” – 6 months
• “Time taken from planning consent to the discharge of relevant conditions to enable site construction” – 4 months

It is considered that the above timescales are fundamentally unrobust, and result in a distorted position of housing sites over the RLDP Plan period. It is not considered that these reflect or are informed by the timescales that are currently being incurred for planning applications submitted for major housing sites across Wales. It is rather the case that such applications would typically be determined 1-2 years following submission, given that there are a wide range of stakeholders involved in the determination of major planning applications – which often adds to the delays associated with the determination of such applications.

It is equally the case that the assumptions in the trajectory are solely based on expected timescales for processing formal submissions made to the Council, and do not factor in the timescales associated with, and needed for, the preparation of the material for submission.

It is assumed that these timescales have not considered that such major developments can be subject to the need to undertaking and submitting an Environmental Impact Assessment (EIA), which adds another layer to the determination of any planning application – given the additional considerations that form part of this process. As such, any site subject to EIA would very likely result in further delays extending beyond the timescales set out in the trajectory. Equally, as set out above, the preparation of an application subject to an EIA requires even more detail and assessment, which only further adds to the preparation stage (which has not been factored into as part of the trajectory). Accordingly, it is not considered that the trajectory contains any contingency if any site is required to undertake EIA as part of their application.

For the reasons stated above, it is unlikely that the sites will yield in full, particularly those sites which are expected to deliver housing right up to the final year of the Plan period (‘Land at Readers Way’ and ‘Land to the West of St Athan’). These sites do not allow for any ‘slippage’ should any delays arise through the development management process (which for the reasons set out above, will very likely be the case), and as such, a gap in housing delivery will be brought about as a result of these sites not yielding in full.

Given the proposed ambitious timescales set out for the delivery of the Key Sites, it is considered the housing trajectory is unrobust, and in turn, undermines the soundness of the Plan as a result. A change in strategy should be pursued whereby a greater proportion of small to medium sites are allocated for housing in the Plan period, which are more likely to fully yield given that such sites are subject to less assessment and consideration compared to strategic sites. This would make for a more robust strategy, where a greater number of small to medium sites can deliver housing in the short and medium term of the Plan period, whereas the strategic sites represent a more longer-term strategy to deliver housing – which would then spill into the next Plan period.

Accordingly, we object to the Deposit Plan in its current form, where there is an overreliance on housing need to be met through the delivery of the Key Sites, which we consider to be unrobust, and undermine the integrity and soundness of the Plan. The current strategy of the Plan is at significant risk of not delivering the level of housing expected based on the sites allocated, as least as swifty as identified in the housing trajectory. Should no change be made to the Plan to address the above issues, then it is extremely likely that the Plan would ‘fail’ in meeting the identified housing need.

Windfall Sites

It is noted that the RLDP is made up of the following:

• Existing land supply (3,838 units)
• Windfall sites (1,303 units)
• Allocated sites (3,521 units)

Para 6.69 states that “Analysis of historical delivery of housing indicates that on average small windfall sites (sites of less than 10 dwellings) have provided some 53 dwelling completions per year, and large windfall sites (10 dwellings or greater) contributed on average 80 dwellings per year. Overall, it is projected that windfall sites could contribute a further 1,303 dwellings over the remainder of the plan”.

As set out in our previous representations to the Housing Trajectory, we would object to the expected numbers of completions expected during the Plan period, given that there are a number of issues with delivering housing in Wales and given past completions rates for The Vale of Glamorgan – which is discussed in greater detail later in this submission. Again, this results in the Plan being at risk of not delivering the level of housing expected based on the sites allocated – including any windfall sites.

St Athan Train Station

The RLDP Sustainable Growth Strategy comprises six key elements, of which the following is set out in respect to the allocation of new housing growth in the Authority:

“3. Focusing development at locations that are well served by existing and proposed rail stations as part of the South Wales Metro and in areas with good bus links.”

The strategy outlines that a feasibility study for a station in St Athan had been undertaken in 2022, which identifies that a new station could be located in St Athan, subject to further investigation work. Accordingly, in line with the spatial strategy adopted for the RLDP (i.e. focus development around sustainable transport nodes), St Athan was identified as a ‘Strategic Opportunity Area’ to accommodate strategic growth – through the proposed allocation of two key sites : ‘Land at Church Farm’ and ‘Land West of St Athan’. These sites have been identified to deliver 532no. and 600no. units respectively in the Plan period. These are separate to, and are in addition to, the 51no. units that have now been attributed to the site ‘Land South of Clive Road’ and 80no. units attributed to ‘Former Stadium Site, adjacent to Burley Place’ in St Athan. Accordingly, in total, the Housing Trajectory makes a provision for a total of 1,263no. homes to be delivered in St Athan over the Plan period.

It is now the case, however, that the proposed railway station at St Athan is not in the first phase of delivery for new stations in South Wales – as confirmed in the ‘Today, Tomorrow, Together: A vision for rail across Wales and Borders’ (February 2026) recently published by Transport For Wales. This paper acknowledges that a new railway station at St Athan would represent a longer term opportunity, and therefore, will not be delivered in the short term / within the Plan period of the emerging Plan. Equally the Council have not provided any evidence to contradict this, and therefore, it is very unlikely that any new train station will be delivered in St Athan over the Plan period. This brings about significant questions regarding the suitability and acceptability of the proposed allocations set out above.

The strategy to allocate new housing growth is predicated on focusing residential development around sustainable transport nodes, and given that St Athan will be without any railway station in the Plan period, it is not considered that the sites align with the strategy of the RLDP. Accordingly, the wider Housing Trajectory is considered to be unsound, given that a total of 1,263no. homes (36% of the Plan’s new housing allocations) are expected to be delivered in St Athan within the Plan period.

It is considered that there has been an overprovision for housing growth in St Athan generally, and this issue is now further exacerbated by the lack of any forthcoming rail provision. Given this, to add further sites for housing in this location over and above the original provision is considered to be unsound. As set out above, the justification to allocate sites at St Athan has relied heavily on the railway station being delivered in the Plan period, and as such, there are serious questions marks associated with the acceptability of the proposed allocated sites - given their incompatibility with the core strategy of the RLDP.

In terms of the expected delivery of the Key Sites in St Athan, it is noted that the trajectory identifies that for the majority of the Plan period, both sites will be delivering 80no. dwellings per annum on each site (equating to 160no units in total). Whilst these are two separate sites, we seriously question the realistic prospects of the significant number of

homes being built simultaneously on two sites in proximity to one another – given the considerable logistical issues that would be brought about.

Accordingly, it remains that there are serious questions regarding the suitability and acceptability of the proposed allocations at St Athan, which do not accord with the strategy adopted for the RLDP – to focus housing growth on settlements that are supported by railway stations. Moreover, the scale of development proposed at St Athan is also not considered to be proportionate, with a significant number of homes delivered in a location not served by a railway station.

Rolled forward LDP Sites

The proposed land supply within the housing trajectory includes provision for ‘rolled forward’ LDP sites, which contribute to the total of ‘Proposed Additional Housing Allocations’ forming part of the housing supply. Specifically, a total of 1,242no. units have been identified as additional housing allocations, of which 959no. are expected to be delivered on the rolled forward LDP sites. As such, these sites are to provide for a significant proportion of additional housing in the Plan period (specifically circa 77%).

The Development Plans Manual (DPM) sets out that allocations rolled forward from a previous plan will require careful justification for inclusion in a revised plan. The DPM outlines that “there will need to be a substantial change in circumstances to demonstrate sites can be delivered and justify being included again. Clear evidence will be required that such sites can be delivered.” The below table included in the consultation document provides a breakdown of the rolled forward LDP sites, and in particular, sets out the status of each site:


The above table evidences that the current LDP has under delivered in regard to its targeted unit number of the Plan period, given that these sites did not yield any housing over the current Plan period. This is further exacerbated by the Land Bank sites that have also not delivered any housing across the existing LDP period, amounting to 1,860no units. Accordingly, when considering the non-delivery of both rolled forward LDP sites and Land Bank sites, this amounts to an approximate shortfall of 2,189 homes being delivered, or 33% of the total housing supply identified for the current LDP (8,525no. dwellings).

It is therefore considered that, as a minimum, the units carried over from the LDP (without planning permission) should be a surplus to the housing supply proposed for the RLDP, as opposed to being relied on to deliver the housing need over the Plan period. This is particularly the case for the two sites (Land to the west of Pencoedtre Lane, and Land between Northern Access Road and Eglwys Brewis Road) which do not currently have any active planning application

submitted for their development. These sites total an amount of 370no. units to be delivered in the Plan period, which represents more than a third of the additional housing allocations to make up the housing supply.

As such, it is considered that the unmet need deriving from the existing LDP is still present – indeed it has grown, and will continue to do so, not least when considered in conjunction with the projected population growth over the coming years to 2036, and the aspirations for growth in the Plan’s strategy.

Accordingly, in order to secure the targeted level of housing, a greater level of provision for new allocations should be applied in order to meet the housing requirement. This would bring about better certainty that the housing requirement is met by the housing supply over the Plan period, not least given that the current Plan failed in this respect. Without a re-apportioning of the housing supply, it is considered that the Plan would heavily rely on the contingency (i.e. rolled forward LDP sites) coming forward in the Plan period, yet there is uncertainty that these will yield in full over the new Plan period. This raises issues of ’soundness’, and risks rendering the Plan unrobust.

Housing Delivery Rate Assumptions

As set out in our previous representations to the Housing Trajectory consultation, we have considerable concerns in relation to the proposed delivery of the sites identified in the trajectory – which we do not consider are robust or reasonable.

Appendix 1 of the Deposit Plan sets out the development trajectory bar chart – which illustrates the proposed delivery of housing, on a per annum basis, over the Plan period.

Extract of Housing Trajectory Graph (annotated by GJP – red dotted line)
It is our view that the trajectory makes for an unrealistic and unrobust delivery rate of housing, which does not reflect the pattern of housing completions in the Vale of Glamorgan. We therefore have concerns regarding the soundness of the trajectory, not least that there remain significant uncertainties as to the delivery of the Key Sites (as discussed earlier in these representations).

Firstly, the graph / trajectory illustrates a large ‘spike’ in terms of housing delivery in the year 2027-28, which is considered to be a marked and pronounced step change in the rate of delivery. This envisages / relies on a significantly higher rate of delivery than previous years in the Vale of Glamorgan (2021 through 2021 – as depicted by the green columns). It is considered that this level of delivery is unlikely to materialise, not least given prevailing market

circumstances, past rates of delivery on the ground, and also in light of levels achieved across Wales and the UK in general.

The published trajectory shows that the average level of completions from 2021 - 2025 has been approx. 400 - 500 units, however, the chart shows that from 2027 – 2028, completions are expected to rise to approx. 1,000 units per year. The expected delivery levels in the trajectory therefore show and assume a doubling in delivery rates and unit numbers (an increase of approx. 100% relative to past rates). There is no clear evidence as to how this level of completions can be achieved let alone guaranteed. This is the case in particular given that the forthcoming years (2025-2027) are expected to see performance (yield) drop significantly (delivery rates in 2025 – 2026 and 2026 – 2027). The chart shows only approx. 200 units being delivered over these years. It is therefore unclear how completion rates are expected to rise so quickly (from 200 in 2025-26 to 1000 in 2027-28), and by such a significant amount. The assumptions in the trajectory are wholly unrobust in our view.

It is also the case that the anticipated delivery of housing fails to be consistent within and across the Plan period. It is unclear as to why completions rates aren’t spread out more evenly throughout the Plan period - to ensure a robust and most realistic housing trajectory until 2036. By comparison to the marked increase in the rate of delivery between and over the period 2027 to 2031, there is then a marked fall-off or drop in delivery towards and by the end of the Plan period. Indeed, in the final year, the level of completions are expected to be lower than the period 2021-2025.

Accordingly, we consider that the housing trajectory, as proposed, is entirely manufactured and unreflective of the past completion rates, as well as the recent published completion rates provided by Welsh Government recently in August 2025. As set out in our previous representations, it has been evidenced that there has been a general decline in the number of new dwellings started and completed.

Description of Figure 1: ‘New House Building: April 2024 to March 2025’
As identified in the graph above, in 2024-25, 4,631 new dwellings were completed, which represents 3% fewer than the previous year. This figure represented the second lowest number on record, with the lowest number recorded in 2021-22, a year heavily affected by the coronavirus (COVID-19) pandemic (in 2021-22, 4,616 new dwellings were completed) The New Housing Pipeline Report Quarter 3, 2025 Report (December 2025) published by the HBF evidenced that the number of residential units approved in the UK fell by 7% during the third quarter of 2025, extending the decline seen during the first half of the year. At 45,075, the number of units approved was 34% down on the third quarter of 2024 and the lowest quarterly total since 2012 Q2. At 146,798, the overall number of units approved during the first nine months of 2025 was 25% lower than a year ago.



HBF Graph Illustrating Residential Approvals (2006-2025)

The above graph clearly shows a pronounced downward trend in the number of residential planning approvals over the period, particuarly with a sharp decrease seen since 2020. Further, the HBF document ‘Increasing Housing Supply in Wales’ (4th September 2025) clearly shows that The Vale of Glamorgan has not met the housing delivery requirements in recent years in 2023 – 2024 – along with every other authority in Wales (except Newport). Accordingly, this further adds to the argument that historically The Vale (and most other authorities) have underprovided. This adds considerable uncertainty on the assumed transformation in yield and delivery as built into the trajectory.

Graph: Housing Delivery as a proportion of annual housing requirement in Wales per Authority

More recently, the Welsh Government has released its new estimates of housing need (Estimates of Additional Hosing Need: 2025-based – February 2026). The estimates show how many new homes need to be built over the next twenty years to address existing unmet need as well as newly arising need. The figures set out that around 8,700no. new homes a year are needed over the next Senedd term up to 2030 to meet new housing need. Additionally, there is an unmet need for 9,400 affordable homes.

Overall, this represents more than double 2024/25 levels of supply, where just 4,638 new homes were built.

HBF: Estimates of Housing Need

HBF: Actual Delivery vs Estimates of Need

The above graphs unequivocally evidence that historical rates of delivery of housing in Wales has remained low, and moreover, significant numbers of housing need to be allocated in order to meet the estimate of need. It is not

considered that the housing trajectory, in its current form, is robust to meet the housing need over the Plan period, given the uncertainties of the Key Sites, and the level of housing delivery that has been identified for the Plan.

Affordable Housing-Led Sites

HG4 - Rural Affordable Housing Led Sites

Policy HG4 of the Deposit Plan identifies four sites to be allocated as affordable housing-led sites, totalling approximately 122 dwellings within the plan period. Given the target levels of achieving 3,070 affordable dwellings over the course of the Plan period (up to 2036), it is not considered that this policy goes far enough to address the target and level of affordable housing need.


It is noted that the number of units identified for each site relate to the ‘total’ number of units delivered, as opposed to the affordable housing provision. Accordingly, it can be assumed that circa 50% of each allocation will comprise affordable units (given each site is affordable-led), which would equate to a total provision of circa 61no. units. The contribution from the affordable housing-led sites would only equate to 2% of the total need (3,070no. units). Even when coupled with the affordable housing provision from open market sites and 100% exception sites, the total delivery of affordable housing will still be nowhere near enough to meet the overall affordable housing need over the Plan period. Accordingly, it is considered that inadequate provision has been made for such sites.

Insofar as to the sites chosen and allocated are concerned, it is clear from reviewing the Stage 1 and Stage 2 Candidate Site Assessment that the allocated sites HG4(1) – (4) were not considered acceptable due to being outside the strategic growth areas, and were considered to be unacceptable intrusions into the open countryside. After being resubmitted as affordable housing-led sites, the sites were allocated, some with a smaller area in order to accommodate less dwellings in total.

The sustainable credentials of the sites allocated is not disputed, and it is acknowledged that these minor rural settlements have the ability to accommodate further growth, in the form of affordable-led housing allocations. However, it is considered that the should also form an allocation as part of this policy, given its high sustainability credentials and its appropriate location to accommodate a suitable level of development. Please refer to the previous representations made to the Housing Trajectory Consultation (dated 17th October) for further, more detailed comments regarding the above sites.

The LHMA 2023 shows that there is a need for 124 affordable homes in the St Brides Major local housing market area (which Ogmore is located within). As such, there is an identified need for affordable housing in this area, something which the site could address through an allocation.

It is questionable whether Wick has the capacity to accommodate 50 new dwellings, given the sustainability and rural nature of the area. As a result, it is suggested that the number of homes allocated in Wick is reduced and that a further allocation in St Brides Major is secured, in order to facilitate supporting the delivery of affordable housing through the housing market area, rather than in one minor rural settlement. The sustainability of Ogmore has been assessed, both by the Council through the Sustainability Appraisal and again, through our assessment of the site.

Securing further delivery of Affordable Units

As set out above, the affordable housing-led allocated sites only provide 122no. affordable dwellings, which comprise 4no. allocated sites that are expected to deliver approximately between 20 – 50 dwellings. However, the RLDP sets a

target of 3,070 affordable homes to be delivered in the Plan period. This means that affordable housing-led allocations make up less than 4 % of the target provision and will only make provision for 2% of the targeted number. We would therefore object to the sites included within Policy HG4 and would suggest that more sites should be allocated as part of the policy in order to secure delivery of a higher number of affordable housing units to mere the target.

Whilst it is acknowledged that the Key Sites will provide for a significant proportion of affordable housing, as set out above in these representations, there is serious concern regarding the deliverability of these sites, which would result in a significant gap of affordable housing delivered.

A greater number of affordable housing-led sites allocated would ensure there is sufficient contingency built into the Plan, to ensure that the overall affordable housing need is met over the Plan period. Failure to do so would result in affordable housing need being unmet, with demand continuing to outstrip supply.

Previous representations to the Preferred Strategy (dated 14th February 2024) provided comment on the sustainability scoring of Ogmore and the proposed site. As outlined within these representations, it is considered that the site (ID xxx) represents a sustainable, deliverable and acceptable site. The site is within a maximum of a 22- minute bus journey to a every key service listed, due to the proximity of the site to settlements such as Bridgend. Due to the availability of frequent bus services, and active travel links, these key services are readily available to access for any residents within Ogmore By Sea without the need to travel by car. The site is located within 5 miles of Bridgend, and within a maximum 22-minute bus journey of the following services:

• St Brides Primary School;
• Brynteg Comprehensive School;
• Bridgend College;
• Riversdale Surgery; and
• Bridgend town centre for various Retail Services

Moreover, Ogmore has benefitted from the recent development of the Ogmore By Sea Village Hall, which provides space for community activities and events to take place. The hall also includes a coffee shop (Welsh Coffee Company), which only adds further to the daily services provision available within the settlement. Access to the hall and coffee shop is directly provided for pedestrians from the Main Road, which allows for direct access from the site.

Accordingly, the settlement of Ogmore represents an acceptable location to allocate an affordable housing-led site, given the access to existing services and facilities that would serve future residents of the site.

It is acknowledged that the site also lies within the Glamorgan Heritage Coast and this point is addressed further below.

To conclude, the settlement, location and site are inherently suitable and deliverable, and will make a significant contribution to achieving and realising the housing and economic development needs of Ogmore By Sea, support the surrounding settlements, and the Plan area as a whole. As such, the site should be considered further.

Comments on Specific Policies

HG5 - Affordable Housing Exception Sites

Given the unmet need and extant backlog of affordable housing, as identified within the LHMA (2023), it is noted that an Affordable Housing Exception Sites policy has been adopted in order to assist in the delivery of affordable housing. Policy HG5 sets out the specific criteria where proposals for 100% small scale affordable housing developments will be permitted outside settlement boundaries. The current policy wording for the Affordable Housing Site Exception Policy and the criteria listed out in the policy is generally supported.

That said, it is noted that a ‘cap’ of 10 dwellings (as referenced within supporting text Para 6.140) is set. This should be amended due to such a ‘cap’ limiting the flexibility of the policy, in particularly for sites coming forward as part of this policy in Minor Rural Settlements.

As such, we would suggest that supporting Para 6.140 should be amended in order to allow for further flexibility for sites in Minor Rural Settlements to come forward and to deliver affordable housing, given that the criteria set out in the policy would already protect and restrict the extent of any development as it stands. Therefore, the proposed amendments to Para 6.140 are outlined below in red:

6.140 “For the purposes of this policy, ‘small-scale’ will generally mean no more than around 10 dwellings on sites adjoining Minor Rural Settlements. In Primary Settlements outside the Strategic Growth Area, proposals for more than 10 dwellings may be acceptable where required to meet a specific need and where the number of dwellings is proportionate to the size of the settlement. In assessing the scale and extent of any proposed local needs housing, consideration should also be given to affordable housing already planned in the ward or nearby area, including sites with existing planning permissions and those allocated in the RLDP. The size and type of affordable housing proposed should reflect the identified local need in the area.”

The above suggested wording would achieve a more flexible policy, which would allow for a variety of scaled applications to secure planning permission for solely 100% affordable housing across the Authority area. This greater flexibility would enable the policy to make a significant contribution towards meeting the affordable housing need – which, as set out earlier is in considerable need.

Policy DNP3 – Glamorgan Heritage Coast

Given that the site is located in the Glamorgan Heritage Coast, it is noted that the following policy is of relevance to any future development on the site. Criteria 4 of Policy DNP3 states:

“The special environmental qualities of the Glamorgan Heritage Coast will be conserved and enhanced. New development will be restricted to:
4. Other appropriate and sustainable development that accords with National Policy.”
It is also noted that supporting Para 6.422 “In seeking to protect the Glamorgan Heritage Coast, the Council acknowledges that there are some built up areas within the boundary, including the Minor Rural Settlement of Ogmore. In addition, the Vale of Glamorgan rail line crosses part of the Heritage Coast designation in the location where a new station at St Athan is proposed. Whilst being mindful of the need to protect the special qualities of the Glamorgan Heritage Coast, the Council accepts that development within these areas is appropriate, subject to relevant policies of the Plan”(GJP emphasis).

We would offer general support for this policy, and consider this to provide flexibility which allows for certain forms of development. However, we would suggest that the policy wording should be amended to reflect that ‘housing’ should be supported in the Glamorgan Heritage Coast, providing that the policy exceptions are met. Therefore, the following amendment is proposed as part of the policy should be changed to include “small scale housing” or something similar. The proposed amendments to Policy DNP3 are outlined below in red:

“The special environmental qualities of the Glamorgan Heritage Coast will be conserved and enhanced. New development will be restricted to:
4. Other appropriate and sustainable development, including small-scale housing proposals that accords with National Policy.”

Again, this would ensure that suitable housing developments can be delivered in the Plan period, to meet the housing needs of the Vale of Glamorgan – particularly in respect of affordable housing.

SECTION 3. Suitability of the site for development

The site promoter objects to the overall assessment of the site, in that it is not considered suitable for further development in the Plan. The promoted site has undergone extensive scrutiny and appraisal at a high level to ascertain the qualities of the site, in light of all identified material considerations which relate to the proposals.

The delivery of the site will yield much needed housing (including Affordable housing) and contribute to the overall supply in the new Plan period, whilst making effective use of a suitably located site for residential development.

Moreover, as set out in ‘Annex 2’ of our representations, the site has overcome the ‘constraints’ set out in the Candidate Site Assessment undertaken for the site, which demonstrates that the proposal is both acceptable and deliverable.

SUMMARY AND CONCLUSIONS

In summary, the site promoters:

• Object to the distribution of growth proposed for the Plan area, with a more balanced and equitable distribution of housing sites required in order to meet the identified housing need;
• Object to the level of growth identified for the Plan period;
• Object to the housing trajectory that underpins the delivery of housing within the Plan period – which is considered to be unrealistic and unrobust, leading to serious uncertainty regarding the “soundness” of the Plan;
• Object to the over-reliance on Key Sites and Rolled Forward Sites in making up the Plan’s housing land supply;
• Object to the scale and timing of delivery of sites in / around St Athan – all of which are predicated on railway station provision which will not be realised in the Plan period;
• Object to the under-provision of sites under Policy HG4 – Rural Affordable Housing-Led sites, not least given their extremely limited contribution to the targeted need for affordable housing;
• Object to Policy DNP3 – Glamorgan Heritage Coast, given the lack of recognition for the potential for small-scale housing proposals;
• Object to the current wording of the HG5 Policy ‘Affordable Housing Exception Sites’ which requires greater flexibility to play an important role in delivery much-needed affordable homes across the Authority; and
• Object the Council’s assessment that the site is not considered suitable for development.

The site and proposals are consistent with the RLDP strategy, other Vale of Glamorgan strategies, and the requirements of Planning Policy Wales and Future Wales. It will make a significant contribution to the Vale’s identified housing requirement in the RLDP period and will provide for a wide range of uses that will support the wider community whilst embodying principles relating to placemaking and the well-being of future generations.

The site has no fundamental constraints and has the ability to deliver significant economic, social and environmental benefits for the benefit of future residents and the existing local community. The site is demonstrated to be viable, being able to deliver policy-compliant levels of affordable housing and given its location within a strong market area, will benefit from high delivery rates.

ANNEX 2
SECTION 4. A summary of the suitability of the site for development including a Response to the Candidate Site Assessment

This section of the overall representations to the Deposit Plan is to respond to, and address, the Council’s assessment of the site.

While the issues the Council have raised in their assessment of the site have been addressed and discussed within the representations made at the Preferred Strategy stage of the Plan, a similar ‘scoring’ exercise has been undertaken as part of the evidence base for the Deposit Plan. As such, it is still pertinent to consider and respond to the Council’s assessment of the site as part of these representations

The Detailed Site Assessment for Land at Hazelwood, Ogmore By Sea (Site ID: 3855) sets out that the position of the site at the Deposit Stage is as follows:

“The original site as ruled out as the development would represent unacceptable intrusion in to the open countryside. Whilst the site has now been identified for an affordable housing led development, the original reason for ruling it out still remains.”
In terms of the assertion that “the development would represent an unacceptable intrusion into to the open countryside”, this is strongly disputed, in that the development of the site would represent a natural rounding off of the existing settlement boundary. An extract of the site relative to the settlement boundary is provided below, which clearly shows that the development of the site would not extend beyond the existing settlement pattern that exists in Ogmore.

Site Outlined in Red and Settlement Shaded in Blue
As clearly demonstrated in the above mapping, the site would extend no further eastwards than the existing housing area to the south of the site. Equally, the site would not be extending any further north than the existing settlement pattern in Ogmore. This position is further supported by the wider aerial view of the site provided overleaf:



Wider Aerial View of Site Outlined in Red and Settlement Shaded in Blue

In summary, it is considered that the proposed allocation of the site represents a logical rounding off of the existing settlement, as depicted in the mapping provided above – where the site follows the existing envelope of the settlement. The site does not extend any further eastwards than the established built form located immediately to the south; indeed, it sits comfortably within the same development line.

As such, it cannot be considered that the site represents an ‘intrusion’ into the countryside, as the site would be visually and functionally related to the settlement. It therefore follows that the site would be read as part of the settlement, and not the wider rural landscape.

Candidate Site Assessment

The Detailed Site Assessment undertaken by the LPA includes a summary and assessment of the ‘scoring’ system used at the Preferred Strategy stage. A comparison between the site assessments undertaken at both the Preferred Strategy stage and Deposit Plan stage is provided overleaf for reference.



Site Assessment at Preferred Strategy Stage Site Assessment at Deposit Plan Stage
As demonstrated above, there are no changes to the scoring attributed to the site. Detailed submissions were made on the previous assessment undertaken by the Council at Preferred Strategy stage, and as such, should be read in conjunction with this submission (see Appendix A).

Sustainability

Notwithstanding the above, it is considered that the site represents a more sustainable location than what was previously assessed at Preferred Strategy stage, in light of the Ogmore by Sea Hall development. The Hall acts as a community facility, whereby the space is available for hire by local community groups such as birthday parties, weddings, group meetings, and other such similar uses. Moreover, a café (Welsh Coffee Co) is located within the premises which sells both food and drink.

The hall and café are within walking distance to and from the site, where new access facilities have been implemented from Main Road directly to the building, to allow access for pedestrians and cyclists. This is illustrated in the image below:

Walking and Cycling Facilities

The Tusker Rock pub and post office are also located along Main Road, all of which are within walking distance to the site.

Accordingly, the site is well served by new amenities (i.e. community hall) that comprehensively improves the sustainability of the site / settlement, and in turn, improves the sustainability credentials of the site promotion. It therefore follows that the site represents an acceptable location for residential development, and the site should be looked upon favourably accordingly.

It is also the case, as set out in previous representations, that the site is within a maximum 22-minuted bus journey of the following services and facilities:

• St Brides Primary School;
• Brynteg Comprehensive School;
• Bridgend College;
• Riversdale Surgery; and
• Bridgend town centre.

As such, key services and facilities can be access by sustainable travel over and above the existing level of provision available in Ogmore By Sea (as discussed above).

Accordingly, the relevant ‘red’ scorings in the Council’s assessment should be updated to reflect the site’s suitability and sustainability to accommodate the proposed residential development of the site.

Glamorgan Heritage Coast

Insofar as to the position regarding the site’s location within the Glamorgan Heritage Coast, detailed submissions are made not only in the Preferred Strategy representations, but also in Annex 1 of this submission. In short, given the pressing need for such development (particuarly affordable housing) to come forward in the Plan period to meet ever-increasing needs, development of this nature should be considered more favourably – not least that, as outlined in this Annex, the site would not extend any further that the existing settlement boundary.

Accordingly, the site would be perceived to form part of the settlement of Ogmore By Sea, and not the wider landscape, and therefore, would not have any detrimental impact on the Heritage Coast in any respect. The scoring should be amended accordingly to reflect this position.

Climate Change

As outlined in previous representations, the development will incorporate climate change measures, such as EV charging points, PV panels, as well as adopting sustainable materials for construction whilst maximising the potential for the dwellings to be energy efficient. Accordingly, the development will be built to high sustainable standards, and therefore, the scoring of the site should be amended as a result.

Summary and Conclusion

It has been evidenced above that there are no fundamental constraints at, or associated with the site, that would preclude the site coming forward for development in the RLDP period.

To conclude, the settlement, location and site are inherently suitable and deliverable, and will make a significant contribution to achieving and realising the housing and economic development needs of the Vale of Glamorgan.

Summary of These Representations

In short, and to summarise the case made and set out, these representations seek to object to the Housing Trajectory published as part of the consultation on the Draft Housing Trajectory For Housing Stakeholder Group (October 2025) which underpins the Plan and the delivery / realisation of its underlying strategy.

Detailed submissions and objections are raised below in respect to the trajectory information published regarding the soundness and robustness of this information (and it’s consultation), which we do not consider are adequate, robust, or sound to deliver the Plans aims and objectives.

Preface

This Submission sets out the detailed case in support of these representations. The representations are structured as follows:

1. Procedural Consultation Matters;
2. Timing Assumptions underpinning the Trajectory;
3. Housing Delivery Rate Assumptions;;
4. Status & Standing of Sites included in the Trajectory;
5. Key Sites;
6. St Athan Train Station;
7. Geographic distribution of the ‘new’ sites / provision;
8. Detailed comments in respect to ‘new’ sites;
9. Conclusions Procedural Consultation Matters
Firstly, we do not consider that the consultation on the Housing Trajectory information has been procedurally undertaken appropriately or suitably.

Only 14 days have been afforded to parties to make representations on the information provided. This is despite new sites being introduced (at this late stage) i.e. Land South of Clive Road (identified in Table 4), as well as a number of affordable housing led housing sites being introduced (i.e. those outlined in Table 5). This does not provide an adequate process or timescale for objectors to scrutinise the published content, and to make comments on sites which have been presented for the first time at a late stage in the process.

As part of these representations, we will be making brief comment on the sites which have not been previously consulted upon, namely:
Other Housing Allocations
• Land south of Clive Road, St Athan;

Affordable Housing Led Sites
• Land at Heol Fain, Wick;
• Land west of Maendy Road, Aberthin;
• Land Noth of West Winds Business Park, Fferm Goch; and
• Land to the East of Colwinston;

It is considered necessary to comment on these sites, given that they form an important and critical part of the housing trajectory, and by association in the Council and Plan reaching their targets. Moreover, these sites have not been consulted on previously. Accordingly we consider it necessary to pass comment on these in order to ensure that the consultation is fair and robust.

As well as limited time given to comment on the information contained within the Housing Trajectory, the LPA have failed to set up a Housing Stakeholder group to agree and discuss the trajectory information and data – with the cover email to the consultation (dated 3rd October 2025) stating “it is considered that it would be the best use of stakeholder time to conduct this engagement via email, particularly as many of the forecasts have been developed in consultation with site promoters including developers and their agents”.

We submit that the stakeholder consultation has not been a transparent nor robust consultation process, given that the Development Plans Manual states at Para 5.66 “A housing trajectory must be prepared to support the Deposit Plan. In order to generate a housing trajectory and associated phasing tables it will be necessary for LPAs to engage with stakeholders through a Housing Stakeholder Group. This will ensure that the timing and phasing of sites is robust and based on up to date information”. Given that this has not taken place, we would raise fundamental concerns that the consultation of the trajectory has not adequately taken place as per the relevant guidance. Afterall, the guidance stresses that a Group should be formed as a necessity. Accordingly, there has not been an adequate process and opportunity to review and comment on the information published, including in respect to the other sites have been introduced at this late stage.

Timing Assumptions underpinning the Trajectory

The assumed and factored in timescales of the various stages of bringing forward sites i.e. the pre-application stage, the planning application process, and the discharge of condition process outlined in the trajectory are considered to be fundamentally inaccurate, and result in a distorted position of the delivery of housing sites over the RLDP Plan period. The assumptions are far too ambitious, and without evidence / are not comparable with the timescales being incurred in processing such stages at the Development Management stage(s).

Specifically, we raise objection to the following timescales which are considered to be extremely ambitious and unrealistic:

• “Time period of pre-application discussions/PAC consultation” = 4 months
• “Time between submission of planning application and determination” = 6 months
• “Time taken from planning consent to the discharge of relevant conditions to enable site construction” = 4 months

In our experience, having submitted a significant number of major and other applications for housing and other forms of development in the last 1-2 years to the Council (and elsewhere in Wales and England), it is extremely unlikely that major applications can be submitted, and planning permissions granted, within the timeframes assumed by the trajectory. A wide range of stakeholders are also involved in the determination of major planning applications, which often adds to the delays associated with the determination of such applications. We would therefore consider that a time period of “6 months” given to all major applications in the housing trajectory is not feasible, and distorts the trajectory timescales for the remaining Plan period.

The assumptions in the trajectory are also solely based on expected timescales for the processing of formal submissions made to the Council, and do not factor in the timescales associated with, and needed for, the preparation of the material for submission (i.e. pre-application enquiry submissions / planning application / discharge of condition details etc). When factored in these will elongate the timescales for bringing forward schemes considerably.

Moreover, it is common practice for larger housing sites and major applications to have a range of pre-commencement conditions attached to a permission once granted. Again, we would raise concerns with the timescales indicated in the trajectory related to this part of the planning process. It is highly unusual and questionable that any technical work required by these conditions (usually relating to drainage and highways matters) would be instructed, completed and submitted within 2 months, and for these to then be signed off / approved in a further 2 months. There are also other technical matters and necessary approvals falling outside of, and over and above, the planning system, such as SAB, s.106, s.38 and s.278 agreements, timescales for which have not been accounted for – and all of which are rarely completed within “4 months” as indicated.

It is therefore highly doubtful that the timescales legislated for in the trajectory for the various stages pre-construction are achievable – with no information about these proposed timescales outlined within the supporting text of the Housing Trajectory. We would therefore raise considerable concerns and objections to these as they stand without full evidence to fully show how these have been calculated, and without there being considerable (and necessary) adjustment to the timescales indicated and factored in.

We would therefore object to the timescales indicated in the ‘Timing and Phasing of Sites’ table, given that the delivery start dates will be pushed back further into the Plan period. Accordingly, and as a result, the Plan is at risk of not delivering the level of housing expected based on the sites allocated, at least as swiftly as is set out in the trajectory.

Housing Delivery Rate Assumptions

We would also raise considerable doubt over the proposed delivery of the sites identified in the Housing Trajectory - which we do not consider are robust or reasonable.

The development trajectory bar chart set out in the consultation material (extracted below) anticipates and legislates for a number of critical events and circumstances – all of which are considered to be unrobust and unsound.

Extract of Housing Trajectory Graph (annotated by GJP – red dotted line)

Firstly, a large ‘spike’ (material increase) in housing delivery is factored in to take place in 2027 – 2028. This is a marked and pronounced step change in the rate of delivery, and envisages / relies on a significantly higher rate of delivery than previous years in The Vale of Glamorgan (2021 through 2025 - as depicted by the green columns). This is considered extremely unlikely to materialise, not least given prevailing market circumstances, past rates of delivery on the ground, and also in light of levels achieved across Wales and the UK in general.

The published trajectory shows that the average level of completions in The Vale of Glamorgan from 2021 - 2025 has been approx. 400 - 500 units. However, the chart shows that from 2027 – 2028, completions are expected to rise to approx. 1,000 units per year. The expected delivery levels in the trajectory therefore show and assume a doubling in delivery rates and unit numbers (an increase of approx. 100%relative to past rates). There is no clear evidence as to how this level of completions can be achieved let alone guaranteed. This is the case in particular given that the forthcoming years (2025-2027) are expected to see performance (yield) drop significantly (delivery rates in 2025 – 2026 and 2026 – 2027). The chart shows only approx. 200 units being delivered over these years. It is therefore unclear how completion rates are expected to rise so quickly (from 200 in 2025-26 to 1000 in 2027-28), and by such a significant amount. The assumptions in the trajectory are wholly unrobust in our view.

The anticipated delivery of housing also fails to be consistent within and across the Plan period. It is unclear as to why completions rates aren’t spread out more evenly throughout the Plan period - to ensure a robust and most realistic housing trajectory until 2036. By comparison to the marked increase in the rate of delivery between and over the

period 2027 to 2031, there is then a marked fall-off or drop in delivery towards and by the end of the Plan period. Indeed, in the final year, the level of completions are expected to be lower than the period 2021-2015.

To summarise, we consider the defined position to be wholly manufactured and unreflective of the past completion rates, as well as the recently published completion rates provided by Welsh Government recently in August 2025. In the Welsh Government Statistics Document ‘’New House Building: April 2024 to March 2025’, information on the number of new dwellings started is provided, where building has commenced and those completed for April 2024 to March 2025. Figure 1 provides a graph showing starts in the last 10 years, and it is clear that there has been a general decline in the number of new dwellings started and completed.

Description of Figure 1:.‘New House Building: April 2024 to March 2025’
In 2024-25, 4,631 new dwellings were completed, 3% fewer than in the previous year. This was the second lowest number on record, with the lowest number recorded in 2021-22, a year heavily affected by the coronavirus (COVID-19) pandemic (in 2021-22, 4,616 new dwellings were completed). The New Housing Pipeline Report Quarter 2, 2025 Report (September, 2025) published by the HBF evidenced that the number of residential units approved in the UK fell by 6% during the second quarter of 2025, continuing the decline of approval during the first three months of the year. Wales saw one of the largest declines in the UK in approvals with a decline of 29%.

Further, the HBF document ‘Increasing Housing Supply in Wales’ (4th September 2025) clearly shows that The Vale of Glamorgan has not met the housing delivery requirements in recent years in 2023 – 2024 – along with every other authority in Wales (except Newport). Accordingly, this further adds to the argument that historically The Vale (and most other authorities) have underprovided. This adds considerable uncertainty on the assumed transformation in yield and delivery as built into the trajectory.


Graph: Housing Delivery as a proportion of annual housing requirement in Wales per Authority

The Home Building Sector Skills Plan (Aug 2025) published by the HBF also identified the following issues with the workforce to bring forward built development in Wales:

• “A shortfall in numbers entering roles from the education system;
• An ageing workforce: 25% of the home building workforce is aged over 50, meaning the sector is facing an impending retirement cliff edge;
• Challenges attracting a wider talent pipeline into the sector;
• A lack of understanding of critical future skills needed, and direction from the Future Homes Standard; and
• Output within the sector fluctuating with demand and economic pressures, leading to additional pressures in recruitment and training”.

It is not considered that in the next 1-2 years that any of these issues can or will be substantially corrected – at least sufficiently so to allow for, and enable, the planned delivery rates of new housing completions to be as high as < > 1,000 homes in one year (and for four consecutive years at that).

We would therefore object to the proposed numbers of completion expected during the Plan period, given that there are a number of issues with delivering housing in Wales and given past completions rates for The Vale of Glamorgan. Again, this results in the Plan being at risk of not delivering the level of housing expected based on the sites allocated.

Status & Standing of Sites included in the Trajectory

The proposed land supply within the housing trajectory includes provision for ‘rolled forward’ LDP sites, which contribute to the total of ‘Proposed Additional Housing Allocations’ forming part of the housing supply. Specifically, a total of 1,242no. units have been identified as additional housing allocations, of which 959no. are expected to be delivered on the rolled forward LDP sites. As such, these sites are to provide for a significant proportion of additional housing in the Plan period (specifically circa 77%).

The Development Plans Manual (DPM) sets out that allocations rolled forward from a previous plan will require careful justification for inclusion in a revised plan. The DPM outlines that “there will need to be a substantial change in circumstances to demonstrate sites can be delivered and justify being included again. Clear evidence will be required that such sites can be delivered.” The below table included in the consultation document provides a breakdown of the rolled forward LDP sites, and in particular, sets out the status of each site:




The above table evidences that the current LDP has under delivered in regard to its targeted unit number of the Plan period, given that these sites did not yield any housing over the current plan period. This is further exacerbated by the Land Bank sites that have also not delivered any housing across the existing LDP period, amounting to 1,860no units. Accordingly, when considering the non-delivery of both rolled forward LDP sites and Land Bank sites, this amounts to an approximate shortfall of 2,189 homes being delivered, or 33% of the total housing supply identified for the current LDP (8,525no. dwellings).

It is therefore considered that, as a minimum, the units carried over from the LDP (without planning permission) should be a surplus to the housing supply proposed for the RLDP, as opposed to being relied on to deliver the housing need over the Plan period. This is particularly the case for the two sites (Land to the west of Pencoedtre Lane, and Land between Northern Access Road and Eglwys Brewis Road) which do not currently have any active planning application submitted for their development. These sites total an amount of 370no. units to be delivered in the Plan period, which represents more than a third of the additional housing allocations to make up the housing supply.

As such, it is considered that the unmet need deriving from the existing LDP is still present – indeed it has grown, and will continue to do so, not least when considered in conjunction with the projected population growth over the coming years to 2036, and the aspirations for growth in the Plan’s strategy.

Accordingly, in order to secure the targeted level of housing, a greater level of provision for new allocations should be applied in order to meet the housing requirement. This would bring about better certainty that the housing requirement is met by the housing supply over the Plan period, not least given that the current Plan failed in this respect. Without a re-apportioning of the housing supply, it is considered that the Plan would heavily rely on the contingency (i.e. rolled forward LDP sites) coming forward in the Plan period, yet there is uncertainty that these will yield in full over the new Plan period. This raises issues of ‘’soundness’’, and risks rendering the Plan unrobust.

On this basis, we would object to the Plan if the provision of housing is not adjusted to rebalance the provision to include new allocations in lieu of rolled forward LDP sites in the housing supply.

Key Sites

As set out in previous representations at Preferred Strategy stage, it is considered that the housing supply relies heavily on the delivery of the ‘key sites’ to deliver housing (and meet need) over the Plan period. The total number of housing units attributed to key sites amounts to 2,278, which equates to over 25% of the total provision in the Plan period.

As detailed above, we consider there to be concerns regarding the proposed ‘Timing and Phasing of Sites’ table included in the Housing Trajectory which we consider are not reflective or accurate and will therefore have the effect of delivery start dates being much later into the Plan period than anticipated. The result of this will be that the Plan will be at risk of not delivery the level of housing expected and needed. Moreover, the Housing Trajectory Graph presents an overly ambitious level of housing completions over the Plan period - which the Council consider will be markedly higher than the average levels experienced in the last five years. Again, for the reasons set out above, we consider that these rates of expected completions to have no evidence supporting them, and to be unachievable and unsound.

Insofar as to the removal of the previously proposed site ‘Land at North East Barry’, this site was expected to deliver 900no. units in the Plan period. Following its omission from the housing supply, other sites have been identified, which comprises the inclusion of a new key site (Land at North West Barry), 3no. non-strategic sites, and also affordable housing-led allocations. In terms of the quantum of development attributed to these new sites, this amounts to 659no. dwellings. This is some 250 units less than the 900no. homes that was previously attributed to ‘Land at North East Barry’. Whilst it is appreciated that the number of homes forming part of the existing supply (completions, units with planning permission etc.) have increased since Preferred Strategy stage, there will be a net loss in market housing provision and delivery.

This position is made worse and compounded as a result of accounting for the affordable-led sites in making up the housing supply.

As set out within the Preferred Strategy, these sites are expected to deliver at least 51% affordable housing. These units are not open market units, and will not / cannot contribute to the supply of such housing. These units will contribute to the provision of affordable housing, and will go some way to meeting the acute need for such housing (albeit will not eradicate / address in full the well known and accepted considerable requirement). Accordingly it is considered that these sites should be in addition to the housing supply, as opposed to forming part of the provision. In turn, there would need to be an increase in allocations for non-strategic sites, to ensure that there is sufficient market housing delivery over the Plan period.

Were such changes to be made and introduced, this would achieve and assist realise a more robust and sound housing supply, which will ensure that the identified housing need is met / addressed over the Plan period. Without these changes it is considered that the housing supply is not sufficient, and inevitably, housing need will not be met within the Plan.

St Athan Train Station

As set out in the Preferred Strategy (para A3.29), the strategy seeks to focus development around key sustainable transport nodes. The strategy outlined that a feasibility study for a station in St Athan had been undertaken, which identifies that a new station could be located in St Athan, subject to further investigation work. Accordingly, in line with the spatial strategy adopted for the RLDP (i.e. focus development around sustainable transport nodes), St Athan was identified as a ‘Strategic Opportunity Area’ to accommodate strategic growth – through the proposed allocation of two key sites : ‘Land at Church Farm’ and ‘Land West of St Athan’. These sites have been identified to deliver 532no. and 600no. units respectively in the Plan period. These are separate to, and are in addition to, the 51no. units that have now been attributed to the site ‘Land South of Clive Road’ in St Athan. Accordingly, in total, the Housing Trajectory makes a provision for a total of 1,183no. homes to be delivered in St Athan over the Plan period.

It is now the case that, subsequent to the publication of the Preferred Strategy, the proposed railway station at St Athan is not in the first phase of delivery for new stations in South Wales. The focus in the first phase of such improvements across the region is towards improving connectivity in east Cardiff, Newport, and Magor. Accordingly,

it is very unlikely that any new train station will be delivered in St Athan over the Plan period, which significantly questions the suitability and acceptability of the proposed allocations set out above.

The strategy to allocate new housing growth is predicated on focusing residential development around sustainable transport nodes, and given that St Athan will be without any railway station in the Plan period, it is not considered that these sites align with the strategy of the RLDP. Accordingly, the wider Housing Trajectory is considered to be unsound, given that a total of 1,183no. homes are expected to be delivered in St Athan within the Plan period.

It is considered that there has been an overprovision for housing growth in St Athan generally, and this issue is now further exacerbated by the lack of any forthcoming rail provision. Given this, to add a further site for housing in this location over and above the original provision is considered to be unsound. As set out above, the justification to allocate sites at St Athan has relied heavily on the railway station being delivered in the Plan period, and as such, there are serious questions marks associated with the acceptability of the proposed allocated sites - given their incompatibility with the core strategy of the RLDP.

We therefore consider the Trajectory to be both unrobust and unsound, and therefore, we object to the Trajectory in its current form accordingly.

Geographic distribution of the ‘new’ sites / provision

As a general and overarching comment in respect to the additional sites now included within the Plan, and forming part of the trajectory, (and a matter expanded upon when critiquing each of these sites in the next section to this submission), it is clear and evident that these additional sites have been positioned to settlements that have already, and recently, been attributed significant growth in the preceding Plan and plan period.

Significant allocations (which have also contributed to significant levels of affordable housing) have been realised and built out in locations (such as Wick and Colwinston). Notwithstanding this, two of the additional sites are now proposed for these recently expanded settlements. Given that the purpose of the affordable housing led allocations is to meet unmet affordable housing need, it is questioned why such new allocations are attributed to settlements that have already seen open market and affordable housing provision, as compared to other comparable settlements that have not received any growth whatsoever over a considerable period of time.

It is considered accordingly that the geographic positioning of these allocations is at odds with their underlying purpose - to meet unmet affordable housing need in communities that have seen no provision

Detailed Comments in respect to ‘new’ sites

Other Housing Allocations

Land south of Clive Road, St Athan

A summary of the Candidate Sites Assessment at Preferred Strategy Stage has been extracted below for ease:


As set out at the outset of these representations, and whilst we note the findings of the Candidate Sites Assessment at Preferred Strategy Stage (i.e. Suitable for further consideration), we do not consider that the consultation on this site has been undertaken procedurally appropriately or suitably. We therefore consider the consultation on this site is “unrobust” and “unsound”.

As set out previously, the strategy seeks to focus development around key sustainable transport nodes. The strategy outlined that a feasibility study for a station in St Athan had been undertaken, which identifies that a new station could be located in St Athan, subject to further investigation work. It is now the case that, subsequent to the publication of the Preferred Strategy, the proposed railway station at St Athan is not in the first phase of delivery for new stations in South Wales, where the focus is towards improving connectivity in east Cardiff, Newport, and Magor. Accordingly, it is very unlikely that any new train station will be delivered in St Athan over the Plan period, which significantly questions the suitability and acceptability of the proposed allocations set out above.

It is considered that there has been an overprovision for housing growth in St Athan generally, and this issue is now further exacerbated by the lack of any forthcoming rail provision. Given this, to add a further site for housing over and above the original provision is considered to be unsound. As set out above, the justification to allocate sites at St Athan has relied heavily on the railway station being delivered in the Plan period, and as such, there are serious questions marks associated with the acceptability of the proposed allocated sites – given their incompatibility with the core strategy of the RLDP.

Affordable Housing Led Allocations Land at Heol Fain, Wick
A summary of the Candidate Sites Assessment at Preferred Strategy Stage has been extracted below for ease:

Candidate Site Stage 2 Assessment (Site Ref. 404)

The findings of the Candidate Site Assessment for this site are noted. We are assuming the reason this site is proposed to be allocated is a product of the site promoters/developers heading the findings stated below, and changing the form of development to be in accord with this:

“A market housing led scheme would not be acceptable, but the site could be reconsidered as a small scale affordable housing led development subject to need and viability at a maximum of 50 dwellings. In accordance with the Settlement Appraisal Review, it is considered that Wick could potentially accommodate limited affordable housing led growth.”

Whilst no clear deficiency exists in respect to the site, it is known that Wick has been subject to significant growth and expansion in recent years – not least by virtue of significant housing allocations in the settlement as part of previous plans.

To evidence this, 35% of the 124 units approved on the ‘Rectory Field, St Brides Road’ site (i.e. circa 43 units as per site allocation ref. MG(47) and PP ref. 2014/01424/FUL) were approved as Affordable Housing units. This makes a substantial provision of such Affordable Housing units (and housing generally) in the settlement in recent years.

Other similarly sized and comparable settlements and locations have not by contrast been subject to any growth for some considerable time, and accordingly would warrant and benefit from provision as part of this new replacement plan.

Notwithstanding the location of such provision, and as set out in detail at the outset of these representations, National Planning Policy advocates the high and acute need for affordable housing, whilst recent analysis evidences that there is a housing emergency. These circumstances - coupled with the shortcomings identified and set out earlier in these submissions in respect to the adequacy of provision within the plan (rolled forward sites / inadequate provision etc) – means that notwithstanding any potential allocation at Wick, further provision ought to be made in comparable (previously unprovided for) locations, such as Ogmore By Sea.

Land West of Maendy Road, Aberthin

‘Land West of Maendy Road’ has been registered as an Affordable Housing Led Allocation candidate site for the RLDP, however as far as we know from our review, there is no assessment and critique of this site. This site has not been included in the ‘Candidate Assessment at Preferred Strategy Stage’ (October 2023). As such, with an absence of publicly available information, it is not clear how the Council has judged this site against the criteria. This raises questions accordingly in respect to the “soundness” of a site which forms part of the intended housing land supply, and by association the trajectory. Without this, and without being consulted on (as others have been prior to this) we question whether this allocation is “sound” (i.e. its allocation is considered to be “unsound”).

Land North of West Winds Business Park, Fferm Goch

The below sets out the candidate site stage two assessment of ‘Land to north and west of Westwinds Business Park’:

Candidate Site Stage 2 Assessment (Site Ref. 398)

As can be seen above, the site was not considered suitable for further consideration, with the site scoring negatively (red) in respect to a number of key factors. These include the following:

• Access to Retail;
• Access to Health Services;
• Sustainable Transport- Public Transport;
• Access/ Proximity to services and facilities conclusion;
• Climate Change; and

• Health and Wellbeing.

Given the fact the site scores red in ‘Sustainable Transport – Public Transport’, this shows the site is not served by public transport connections within 800m, as outlined in the key below:


Additionally, Policy SP7 (Sustainable Transport) of the Vale of Glamorgan Preferred Strategy states “New development must support an enhanced transport network that increases the proportion of journeys being undertaken by sustainable travel modes”. Additionally Objective 8 (Promoting Active and Sustainable Travel Choices) states “new development is directed to locations that are or can be accessible by a choice of modes of transport, including walking, cycling, and public transport.”

It is well known that residents of affordable housing are statistically less likely to own private vehicles, making access to reliable and frequent public transport essential for ensuring equitable mobility. The provision of public transport infrastructure in close proximity to such developments is therefore a critical component in supporting access to employment, education, healthcare, and other key services, while also promoting sustainable travel patterns and social inclusion.

The site also scores red in respect to Access/Proximity to services, showing the site is greater than 1200m away from key services, as seen in the key below:


In respect of the above, Preferred Strategy 6.40 states the need “To ensure that new development takes place in locations that have the best access to a wide range of services, facilities, and employment opportunities, whilst minimising the need to travel, the distribution of growth is guided by the following settlement hierarchy”. To further highlight the importance of both sustainable transport and proximity to services, the preferred strategy also states the need to “Facilitate the development of adaptable, accessible, well-connected communities that have a strong sense of identity, offer a sustainable range of services and facilities and are equipped with adequate infrastructure”. In addition, Promoting Active and Sustainable Travel Choices outlines to “Promote and encourage the use of sustainable methods of travel, particularly active modes of transport, whilst simultaneously reducing the need to travel”.

In light of the above, this site does not align with the aims and targets set out in the Preferred Strategy, as it fails to meet several key development goals set out. It should therefore not be considered suitable to be allocated for future developments. Its inclusion is therefore unsound.

Should this view be concurred with, 22 affordable units will be lost from the proposed affordable 122 units, and ultimately will be lost from the overall housing land supply. As stated in the draft housing trajectory “there is a need for small scale affordable housing led development (minimum 50% affordable) to respond to local affordable needs and help sustain services and facilities within these rural communities”. There is a clear possibility therefore that this proposed allocation is removed and/or not delivered as its inclusion is unsound as it does not align with the aims and targets set out in the Preferred Strategy - as it fails to meet several key development goals set out. A “small scale

affordable housing led development” which is needed to “respond to local affordable needs and help sustain services and facilities within these rural communities” will therefore not be provided for. This is clearly an issue.

When comparing this with ‘Land at Hazelwood, Ogmore By Sea, the following is set out:

Access to Services and Facilities

This criterion has been assessed firstly on the location of the site proposal in terms of whether it is located within, adjacent to, or outside a settlement, and secondly the ease of pedestrian and cycle access to key services listed below.



With reference to the above:

• In terms of public transport, there are two bus stops located approximately 200m (3-minute walk) from the site (‘Ogmore By Sea Post Office’), with the ‘303’ providing services between Llantwit Major and Bridgend.

• The site is located 200m (3-minute walk) from the ‘Ogmore By Sea Post Office’ which can provide basic goods to meet day-today needs such as bread, butter, milk etc.

• The site is also located 50m (1-minute walk) from a children’s park.

These services and facilities are therefore well within the best category (i.e. categorised/scored as ‘green’) - within 800m of site (10-minute walk). Accordingly, the site therefore has good access to services and facilities. This

Furthermore, the settlement of Ogmore By Sea has been ranked higher than Llangan (which the site ‘Land to north and west of Westwinds Business Park’ is located within) in the VoG Sustainable Settlements Appraisal, and therefore, is considered to constitute a more sustainable location to accommodate residential growth. Most notably, Ogmore By Sea scores ‘13’ in respect to ‘Daily Facilities’ whereas Llangan only scores ‘3’, evidencing that residents in Ogmore have much better access to services within the locality as compared to Llangan.

Given the above, ‘Land at Hazelwood, Ogmore’ does/should align with the aims and targets set out in the Preferred Strategy as it meets several of the key development goals set out. Its inclusion should therefore, in our view, be considered “sound” and therefore suitable to be allocated for future developments. The site should properly and appropriately be allocated in lieu of ‘Land to north and west of Westwinds Business Park’ – the inclusion of which is “unsound”. ‘Land at Hazelwood, Ogmore’ would therefore ensure that affordable units, where “there is a need for small scale affordable housing led development (minimum 50% affordable) to respond to local affordable needs and help

sustain services and facilities within these rural communities”, are provided for. As such the proposed housing trajectory would be maintained.

Land to the East of Colwinston, Colwinston

A summary of the Candidate Sites Assessment at Preferred Strategy Stage has been extracted below:


As outlined above, the site was rejected and considered not suitable for further consideration. In fact, and unlike ‘Land at Heol Fain, Wick’ and ‘Land to north and west of Westwinds Business Park’ it was stated that this site “could not be considered as a suitable affordable housing led development site”. Despite this, this site is identified to be allocated as an Affordable Housing Led Allocation. As such, the inclusion of this site is “unsound”.

It is known that Colwinston has been subject to significant housing allocations in the settlement as part of previous plans. To evidence this, 25% of the 64 units (i.e. 16 units) were approved on the site allocation ref. MG2(41) and PP ref.

2014/00242/FUL. This makes a substantial provision of such Affordable Housing units (and housing generally) in the settlement in recent years.

Other similarly sized and comparable settlements and locations have not by contrast been subject to any growth for some considerable time, and accordingly would warrant and benefit from provision as part of this new replacement plan.

Notwithstanding the location of such provision, and as set out in detail at the outset of these representations, National Planning Policy advocates the high and acute need for affordable housing, whilst recent analysis evidences that there is a housing emergency. These circumstances - coupled with the shortcomings identified and set out earlier in these submissions in respect to the adequacy of provision within the plan (rolled forward sites / inadequate provision etc) – means that notwithstanding any potential allocation at Colwinston, further provision ought to be made in comparable (previously unprovided for) locations, such as Ogmore By Sea.

Summary of These Representations

To re-iterate, and to summarise the case made and set out, these representations seek to object to the Housing Trajectory published as part of the consultation on the Draft Housing Trajectory For Housing Stakeholder Group (October 2025) which underpins the Plan and the delivery / realisation of its underlying strategy.

Detailed submissions and objections are raised above in respect to the trajectory information published regarding the soundness and robustness of this information (and it’s consultation), which we do not consider are adequate, robust, or sound to deliver the Plans aims and objectives.

Strong support is expressed for the proposed allocation at Land north of Westwinds, Fferm Goch of rural affordable-led housing within the Vale of Glamorgan Draft Local Development Plan (LDP) under policy HG4(4).
As part of our comments to the above policy consideration must be attributed to viability on a site specific basis. Furthermore, questions are raised over whether sufficient affordable dwellings are proposed to 2036 in the Vale given current trends and forecasts.

The inclusion of the site within the settlement boundary is logical especially when viewed in the context of the linear settlement of Fferm Goch. In addition the site is further suited to development allocation as the northern and southern boundaries are built up and the main road runs along the eastern boundary. A flexible approach is encouraged with regard to the delivery of the dwellings in relation to a variety of factors and policy provisions including the housing needs across the Vale, the limit on numbers of rural affordable led sites in minor rural settlements, viability implications relating to obligations/carbon Zero and sustainability obligations and the potential to extend the allocation if the need for homes requires.

The 3 land owners remain committed to this development and local developers are waiting to deliver the allocation.

In summary the extension to the settlement boundary of Fferm Goch, to include the allocation HG4(4) is supported. The attached representation is made under the following policies:
• Policy SP1 – Sustainable Growth Strategy
• Policy SP2 – Settlement Hierarchy
• Policy PGD2 – Residential Development Densities
• Policy SP6 – Housing Requirement
• Policy SP7 – Affordable housing provision
• Policy SP8 – Affordable housing requirements
• Policy HG4 – Rural Affordable Housing Sites
• Policy SP13 – Community Infrastructure and planning obligations
• Policy CI1 – Open space provision
• Policy SP16 – Climate change mitigation and adaptation
• Policy DNP1 – Special landscape Areas

The test of soundness for a Local Development Plan (LDP) is a critical component of the planning process to ensure that the plan is prepared in accordance with legal and procedural
requirements. It involves demonstrating that the plan is 'sound' based on three tests set out by the Welsh Government in the Development Plans Manual (Edition 3). These tests have therefore been considered in our representation, the tests include:

• Test 1: Does the plan fit? (i.e. is it clear that the LDP is consistent with other plans?)
• Test 2: Is the plan appropriate? (i.e. is the plan appropriate for the area in the light of the evidence?)
• Test 3: Will the plan deliver (i.e. is it likely to be effective?)

SP1 – Sustainable Growth Strategy

The promotion of small scale affordable housing led development outside of the SGA, as proposed by SP1 is important as this provides essential affordable and market homes in the rural locations of the Vale as well as the SGA. Their provision is critical in meeting the area’s housing needs, particularly affordable dwellings and supporting rural community stability, and ensuring that all parts of the Vale remain a place where people of all incomes are able to live and thrive during the plan period to 2036 and beyond.

The essence of Policy SP1 is supported, however it is well documented that there is a backlog in delivery of affordable homes and the need for affordable housing in the Vale is exacerbated by the high prevalence of single person households plus households comprising couples with no children, The Vale also has one of the highest affordability pressures in Wales. As stated in the 2023 Local Housing Market Assessment (LHMA) for the Vale of Glamorgan , the median house price in the Vale is around 8 times the median household income, well above the affordability threshold of 4.5 to 5 times household income for borrowing purposes. Private rents have also risen sharply in the area, commonly placing them out of reach for many low-to-middle income households. All of the above place further pressure on the need to deliver affordable homes in the locality.

The LHMA identifies a need for 1,075 affordable homes per year over the next 5 years based on principal projections (or 1,114 based on the RLDP projections). As mentioned previously past delivery rates fall significantly short and therefore a backlog is present, however despite the reported backlog the RLDP only proposes 3,070 (205/annum) affordable dwellings over the plan period to 2036. Despite the growth strategy of policy SP1 and allocations made through the RLDP, the figure of proposed affordable dwelling numbers is concerning as it falls significantly short of the demand evidenced within the most recent evidence of LHMA of 2023.

The housing figures quoted in SP1 indicate 7,890 dwellings ( including the 3,070 affordable dwellings) to 2036, however these figures overall are inadequate over the plan period when considered against the 2022 WG household projections. The 2022-based household projections provide an indication of the future number of households, and their composition, based on population projections and assumptions about households from recent censuses. The vale of Glamorgan demonstrates an increase of almost 12% in the number of households between mid-2022 and mid-2032; note this is the highest percentage increase by Local authority in Wales and way above the average for Wales as a whole (that stands at around 7% increase). The concern is whether Policy SP1 goes far enough in providing for the scale of housing ( both open market, but particularly Affordable) development across the Vale.

Without targeted allocations outside of the SGA, as outlined in Policy SP1, the gap described above will continue to widen, forcing more residents to leave the area and weakening community cohesion.

SP2 – Settlement Hierarchy

Policy SP2 states a range of rural settlements are categorised as ‘Minor Rural Settlements’. Within the
RLDP the supporting text of Policy SP2 states:
‘several of the smaller rural settlements such as Colwinston, St Nicholas and Fferm Goch include primary schools that serve a wider catchment area, whilst others also provide small scale local employment opportunities, either within or near the settlements. Due to these functional links between rural settlements, it is essential to ensure that existing services and facilities are safeguarded, supported, or enhanced where appropriate’.(Paragraph 6.16)
Fferm Goch is categorised as a Minor rural settlement within the Settlement hierarchy and given its size and range of facilities/services this is supported. It is noted however that both Fferm Goch and Colwinston are identified as serving a wider catchment due to the provision of their primary schools. The allocation of HG4 site at Fferm Goch will further support and sustain the following:
• The Llangan primary school that sits in the southern portion of the settlement boundary.
• The existing employment site of WestWinds Business Park.
• The community hall (Llangan and St Mary Hill Village Hall) to the north of the settlement.
These existing services and facilities should be supported and sustained through the new housing allocation (HG4(4) in the immediate locality. This allocation supports the Vale’s own strategic objectives for

sustainable growth. Locating affordable-led developments in areas with existing infrastructure such as primary schools will reduce car dependency, lower carbon emissions, and contribute to the Council’s climate change commitments.

Considering the above, the limit on small scale rural affordable housing led developments (RAHLD) to 25 for these settlements is questioned and further flexibility recommended on a case by case basis. It is understood the limit on numbers was imposed due to the existing scale of the settlement in which the RAHLD are located, however those allocations will only likely deliver at 50% affordable and therefore only provide 12.5 ( or 13) affordable units as a maximum (note Fferm Goch would provide 11 affordable dwellings on current figures of 22 total dwellings). Given the concerns raised in response to Policy SP1 there remains an issue of whether the numbers proposed in the RLDP can meet the demonstrable need for affordable homes and if there is scope on a RAHLD to sensitively increase unit numbers without any material harm then the policy should be flexible to accommodate this.

Wick and Culverhouse Cross have been elevated to Primary Settlements outside the SGA; this is supported given the range of facilities and services provided in these settlements. It is also supported that these settlements are able to provide affordable led residential development of up to 50 dwellings ( delivering 25 affordable units). However the provision of an increased number of units in the Primary Non SGA settlements must not be at the expense of a wider number of smaller rural sites with the ability to sustain smaller communities across the Vale, especially given the shortfall in numbers as outlined above.

PGD2 – Residential Development Densities

The best use of finite land is set out in PPW and consistent with the setting of the densities as prescribed in policy PGD2. The policy is considered to meet the 3 tests of soundness.

The approach of policy PGD2 is also supported through the proposed density of the site North of Westwinds business park, Fferm Goch in HG4 (4). This allocation that proposes to provide a density of just over 30/ha within Fferm Goch, a minor rural settlement.

SP6 – Housing Requirement

Affordable housing forms an important part of the housing requirement figures of Policy SP6. Whilst the total 122 dwellings proposed under policy HG4 is a relatively small contribution to the overall figures it provides important spatial distribution of homes across the Vale within the rural area.

Given the concerns raised with regard to Policy SP1 there is fear that the affordable housing numbers will not be sufficient to meet need. The site north of Westwinds business park, Fferm Goch has the ability to expand to the south (as per the CS Ref 398) in order to accommodate additional dwellings (both market and affordable dwellings in order to sustain the viability of the site).

SP7 – Affordable Housing Provision

In accordance with Policy SP7 the allocated site HG4(4) at Fferm Goch provides a range of tenures, types and sizes in response to the LHMA, waiting list data and Older persons housing strategy in order to provide for 11 dwelling units and contributing toward the 3,070 affordable requirement to 2036. Changes in the household composition mean more single person and small homes are required, plus older person accommodation for those wishing to downsize and stay in the area.

Please see comments for Policy SP1 / Policy SP2 above regards concern over the proposed housing numbers and supply of affordable homes against demand - this therefore brings the Deliverability of the plan in to question (Test of Soundness 3).

SP8 – Affordable Housing Requirements

Policy SP8 is supported in so far as contributing much needed affordable housing development commensurate with the size of the settlement in which it sits. We are encourage to see reference to the provision of affordable housing to be negotiated on a site by site basis considering evidenced viability fo the development.

The affordable dwellings proposed foster stability in rural areas by allowing a range of households (from single person to growing families) to stay in their local area.

Policy SP8 states 40% affordable for those developments in primary and minor settlements outside of the SGA yet 50% requirement on affordable housing led allocations in minor rural settlements ( also outside of the SGA). This appears inconsistent and penalising those smaller rural sites that will already be more delicately balanced in viability terms by virtue of their limited size of 25 units. Further viability issues covered in other policies ( such as SP20, relating to biodiversity, Net Zero and sustainability credentials must (with the required evidence submitted and assessed by the council as stated in Policy SP8) be flexibly reviewed to ensure sites are viable and deliverable as recognised by the Council, there is a danger the stringent requirements, especially for smaller sites, could render those sites unviable in the current climate with rising build costs.

HG4 – Rural affordable housing led sites

The allocation of land north of West Winds Business Park under policy HG4(4) for rural affordable housing led development of 22 units is strongly supported. Then allocation will assist in delivering homes in the rural Vale and contribute to the important stability to the settlement of Fferm Goch to 2036.

The extension of the settlement limit including the site north of West Winds Business Park is supported. The site provides an obvious infill to the small break in the built up area to both the north and south of the site, with the main road running to the eastern boundary of the site.

The inclusion of the site within the settlement of Fferm Goch is logical and in harmony with the existing linear settlement.

The proposal supports the aims of the Local Development Plan and the Welsh Government’s commitment to increasing affordable housing supply. By providing for affordable led allocations the policy aligns with the Well-being of Future Generations (Wales) Act 2015 in aiming to promote a healthier, more equal, and cohesive community.

There is concern however surrounding the number of dwellings proposed and if the Plan seeks sufficient dwellings and affordable provision given the predicted need to 2036 shown in the LMHA.

SP13 – Community infrastructure and planning obligations

Policy SP13 demonstrates the importance of community infrastructure in sustaining both the residents well being and economic growth of an area. See also the response to Policy SP2 that refers to the allocation of housing in the rural areas specifically supporting those settlements with local primary school provision.

The viability of developments however must not be compromised in order to ensure delivery of the plan. To see in Policy SP13 that ‘development viability’ is recognised as a key factor in delivering community infrastructure under planning obligations, is supported. It is recommended that this recognition is replicated in other policies of the LDP in order that the third Test of soundness can be fully met; Deliverability – ensuring the plan is likely to be effective). See comments in relation to Policies SP8/CC1/SP16/CI1.

CI1 – Open Space Provision

Provision of open space in residential developments is supported. HG4(4) promotes open space within the draft allocation.

The viability of developments however must not be compromised in order to ensure delivery of the plan. The ‘development viability’ should recognised as a key factor in delivering open space ( see comments on SP13 / SP8 where evidenced viability is specifically referenced within those policies – this approach is supported.

SP16 - Climate change Mitigation and Adaptation

The provisions of SP16 are generally supported as practical measures to ensure important sustainable development is achieved.

CC1 – Residential Operational Net Zero Carbon Development

The provisions of Policy CC1 echo the WG targets for Net Zero by 2050.
Whilst some of the supporting text to policy CC1 references viability, the ultimate viability of developments however must not be compromised in order to ensure delivery of the plan. The technical feasibility of renewable energy regeneration is referenced in the above policy however the ‘development viability’ should also be included. See comments on SP13 / SP8 where evidenced viability is specifically referenced within those policies – this approach is supported.

SP19 – Green Infrastructure

Provision of Green Infrastructure in residential, and all developments is supported.

HG4(4) retains and enhances existing and will promote green infrastructure on the draft allocation.

The viability of developments however must not be compromised through green infrastructure provision - in order to ensure delivery of the plan. The ‘development viability’ should therefore be recognised as a key factor in delivering Green Infrastructure. See comments on SP13 / SP8 where evidenced viability is specifically referenced within those policies – this approach is supported.

SP20 – Biodiversity and Ecosystem resilience

The above Policy is in accordance with Chapter 6 PPW. The approach is supported and dovetails with SP19 above.

DNP1 – Special Landscape Areas

DNP1 identified Special Landscape Areas across the Vale.

Fferm Goch is one of the settlements that remains fully within and covered by the Upper and Lower Thaw Valley Special Landscape Area (SLA). It is noted that in such settlements, while there have been amendments to the identified settlement boundary ( inclusion of HG4 (4) rural affordable led housing allocation) this has not affected the SLA designation in these areas. (Background Paper 45; Paragraph 1.16 refers).

The location of the small allocated site HG4(4) is nestled within the settlement of Fferm Goch. It is built up on both the northern and southern boundaries, with the main road running along the eastern boundary. There is no unacceptable harm to the SLA of the Upper and Lower Thaw valley.

The allocation of the site for residential development does not give rise to unacceptable harm to the special qualities and characteristics of the SLA, based on LANDMAP information, continues to be preserved.

Strong support is expressed for the proposed allocation at Land north of Westwinds, Fferm Goch of rural affordable-led housing within the Vale of Glamorgan Draft Local Development Plan (LDP) under policy HG4(4).
As part of our comments to the above policy consideration must be attributed to viability on a site specific basis. Furthermore, questions are raised over whether sufficient affordable dwellings are proposed to 2036 in the Vale given current trends and forecasts.

The inclusion of the site within the settlement boundary is logical especially when viewed in the context of the linear settlement of Fferm Goch. In addition the site is further suited to development allocation as the northern and southern boundaries are built up and the main road runs along the eastern boundary. A flexible approach is encouraged with regard to the delivery of the dwellings in relation to a variety of factors and policy provisions including the housing needs across the Vale, the limit on numbers of rural affordable led sites in minor rural settlements, viability implications relating to obligations/carbon Zero and sustainability obligations and the potential to extend the allocation if the need for homes requires.

The 3 land owners remain committed to this development and local developers are waiting to deliver the allocation.

In summary the extension to the settlement boundary of Fferm Goch, to include the allocation HG4(4) is supported. The attached representation is made under the following policies:
• Policy SP1 – Sustainable Growth Strategy
• Policy SP2 – Settlement Hierarchy
• Policy PGD2 – Residential Development Densities
• Policy SP6 – Housing Requirement
• Policy SP7 – Affordable housing provision
• Policy SP8 – Affordable housing requirements
• Policy HG4 – Rural Affordable Housing Sites
• Policy SP13 – Community Infrastructure and planning obligations
• Policy CI1 – Open space provision
• Policy SP16 – Climate change mitigation and adaptation
• Policy DNP1 – Special landscape Areas

The test of soundness for a Local Development Plan (LDP) is a critical component of the planning process to ensure that the plan is prepared in accordance with legal and procedural
requirements. It involves demonstrating that the plan is 'sound' based on three tests set out by the Welsh Government in the Development Plans Manual (Edition 3). These tests have therefore been considered in our representation, the tests include:

• Test 1: Does the plan fit? (i.e. is it clear that the LDP is consistent with other plans?)
• Test 2: Is the plan appropriate? (i.e. is the plan appropriate for the area in the light of the evidence?)
• Test 3: Will the plan deliver (i.e. is it likely to be effective?)

SP1 – Sustainable Growth Strategy

The promotion of small scale affordable housing led development outside of the SGA, as proposed by SP1 is important as this provides essential affordable and market homes in the rural locations of the Vale as well as the SGA. Their provision is critical in meeting the area’s housing needs, particularly affordable dwellings and supporting rural community stability, and ensuring that all parts of the Vale remain a place where people of all incomes are able to live and thrive during the plan period to 2036 and beyond.

The essence of Policy SP1 is supported, however it is well documented that there is a backlog in delivery of affordable homes and the need for affordable housing in the Vale is exacerbated by the high prevalence of single person households plus households comprising couples with no children, The Vale also has one of the highest affordability pressures in Wales. As stated in the 2023 Local Housing Market Assessment (LHMA) for the Vale of Glamorgan , the median house price in the Vale is around 8 times the median household income, well above the affordability threshold of 4.5 to 5 times household income for borrowing purposes. Private rents have also risen sharply in the area, commonly placing them out of reach for many low-to-middle income households. All of the above place further pressure on the need to deliver affordable homes in the locality.

The LHMA identifies a need for 1,075 affordable homes per year over the next 5 years based on principal projections (or 1,114 based on the RLDP projections). As mentioned previously past delivery rates fall significantly short and therefore a backlog is present, however despite the reported backlog the RLDP only proposes 3,070 (205/annum) affordable dwellings over the plan period to 2036. Despite the growth strategy of policy SP1 and allocations made through the RLDP, the figure of proposed affordable dwelling numbers is concerning as it falls significantly short of the demand evidenced within the most recent evidence of LHMA of 2023.

The housing figures quoted in SP1 indicate 7,890 dwellings ( including the 3,070 affordable dwellings) to 2036, however these figures overall are inadequate over the plan period when considered against the 2022 WG household projections. The 2022-based household projections provide an indication of the future number of households, and their composition, based on population projections and assumptions about households from recent censuses. The vale of Glamorgan demonstrates an increase of almost 12% in the number of households between mid-2022 and mid-2032; note this is the highest percentage increase by Local authority in Wales and way above the average for Wales as a whole (that stands at around 7% increase). The concern is whether Policy SP1 goes far enough in providing for the scale of housing ( both open market, but particularly Affordable) development across the Vale.

Without targeted allocations outside of the SGA, as outlined in Policy SP1, the gap described above will continue to widen, forcing more residents to leave the area and weakening community cohesion.

SP2 – Settlement Hierarchy

Policy SP2 states a range of rural settlements are categorised as ‘Minor Rural Settlements’. Within the
RLDP the supporting text of Policy SP2 states:
‘several of the smaller rural settlements such as Colwinston, St Nicholas and Fferm Goch include primary schools that serve a wider catchment area, whilst others also provide small scale local employment opportunities, either within or near the settlements. Due to these functional links between rural settlements, it is essential to ensure that existing services and facilities are safeguarded, supported, or enhanced where appropriate’.(Paragraph 6.16)
Fferm Goch is categorised as a Minor rural settlement within the Settlement hierarchy and given its size and range of facilities/services this is supported. It is noted however that both Fferm Goch and Colwinston are identified as serving a wider catchment due to the provision of their primary schools. The allocation of HG4 site at Fferm Goch will further support and sustain the following:
• The Llangan primary school that sits in the southern portion of the settlement boundary.
• The existing employment site of WestWinds Business Park.
• The community hall (Llangan and St Mary Hill Village Hall) to the north of the settlement.
These existing services and facilities should be supported and sustained through the new housing allocation (HG4(4) in the immediate locality. This allocation supports the Vale’s own strategic objectives for

sustainable growth. Locating affordable-led developments in areas with existing infrastructure such as primary schools will reduce car dependency, lower carbon emissions, and contribute to the Council’s climate change commitments.

Considering the above, the limit on small scale rural affordable housing led developments (RAHLD) to 25 for these settlements is questioned and further flexibility recommended on a case by case basis. It is understood the limit on numbers was imposed due to the existing scale of the settlement in which the RAHLD are located, however those allocations will only likely deliver at 50% affordable and therefore only provide 12.5 ( or 13) affordable units as a maximum (note Fferm Goch would provide 11 affordable dwellings on current figures of 22 total dwellings). Given the concerns raised in response to Policy SP1 there remains an issue of whether the numbers proposed in the RLDP can meet the demonstrable need for affordable homes and if there is scope on a RAHLD to sensitively increase unit numbers without any material harm then the policy should be flexible to accommodate this.

Wick and Culverhouse Cross have been elevated to Primary Settlements outside the SGA; this is supported given the range of facilities and services provided in these settlements. It is also supported that these settlements are able to provide affordable led residential development of up to 50 dwellings ( delivering 25 affordable units). However the provision of an increased number of units in the Primary Non SGA settlements must not be at the expense of a wider number of smaller rural sites with the ability to sustain smaller communities across the Vale, especially given the shortfall in numbers as outlined above.

PGD2 – Residential Development Densities

The best use of finite land is set out in PPW and consistent with the setting of the densities as prescribed in policy PGD2. The policy is considered to meet the 3 tests of soundness.

The approach of policy PGD2 is also supported through the proposed density of the site North of Westwinds business park, Fferm Goch in HG4 (4). This allocation that proposes to provide a density of just over 30/ha within Fferm Goch, a minor rural settlement.

SP6 – Housing Requirement

Affordable housing forms an important part of the housing requirement figures of Policy SP6. Whilst the total 122 dwellings proposed under policy HG4 is a relatively small contribution to the overall figures it provides important spatial distribution of homes across the Vale within the rural area.

Given the concerns raised with regard to Policy SP1 there is fear that the affordable housing numbers will not be sufficient to meet need. The site north of Westwinds business park, Fferm Goch has the ability to expand to the south (as per the CS Ref 398) in order to accommodate additional dwellings (both market and affordable dwellings in order to sustain the viability of the site).

SP7 – Affordable Housing Provision

In accordance with Policy SP7 the allocated site HG4(4) at Fferm Goch provides a range of tenures, types and sizes in response to the LHMA, waiting list data and Older persons housing strategy in order to provide for 11 dwelling units and contributing toward the 3,070 affordable requirement to 2036. Changes in the household composition mean more single person and small homes are required, plus older person accommodation for those wishing to downsize and stay in the area.

Please see comments for Policy SP1 / Policy SP2 above regards concern over the proposed housing numbers and supply of affordable homes against demand - this therefore brings the Deliverability of the plan in to question (Test of Soundness 3).

SP8 – Affordable Housing Requirements

Policy SP8 is supported in so far as contributing much needed affordable housing development commensurate with the size of the settlement in which it sits. We are encourage to see reference to the provision of affordable housing to be negotiated on a site by site basis considering evidenced viability fo the development.

The affordable dwellings proposed foster stability in rural areas by allowing a range of households (from single person to growing families) to stay in their local area.

Policy SP8 states 40% affordable for those developments in primary and minor settlements outside of the SGA yet 50% requirement on affordable housing led allocations in minor rural settlements ( also outside of the SGA). This appears inconsistent and penalising those smaller rural sites that will already be more delicately balanced in viability terms by virtue of their limited size of 25 units. Further viability issues covered in other policies ( such as SP20, relating to biodiversity, Net Zero and sustainability credentials must (with the required evidence submitted and assessed by the council as stated in Policy SP8) be flexibly reviewed to ensure sites are viable and deliverable as recognised by the Council, there is a danger the stringent requirements, especially for smaller sites, could render those sites unviable in the current climate with rising build costs.

HG4 – Rural affordable housing led sites

The allocation of land north of West Winds Business Park under policy HG4(4) for rural affordable housing led development of 22 units is strongly supported. Then allocation will assist in delivering homes in the rural Vale and contribute to the important stability to the settlement of Fferm Goch to 2036.

The extension of the settlement limit including the site north of West Winds Business Park is supported. The site provides an obvious infill to the small break in the built up area to both the north and south of the site, with the main road running to the eastern boundary of the site.

The inclusion of the site within the settlement of Fferm Goch is logical and in harmony with the existing linear settlement.

The proposal supports the aims of the Local Development Plan and the Welsh Government’s commitment to increasing affordable housing supply. By providing for affordable led allocations the policy aligns with the Well-being of Future Generations (Wales) Act 2015 in aiming to promote a healthier, more equal, and cohesive community.

There is concern however surrounding the number of dwellings proposed and if the Plan seeks sufficient dwellings and affordable provision given the predicted need to 2036 shown in the LMHA.

SP13 – Community infrastructure and planning obligations

Policy SP13 demonstrates the importance of community infrastructure in sustaining both the residents well being and economic growth of an area. See also the response to Policy SP2 that refers to the allocation of housing in the rural areas specifically supporting those settlements with local primary school provision.

The viability of developments however must not be compromised in order to ensure delivery of the plan. To see in Policy SP13 that ‘development viability’ is recognised as a key factor in delivering community infrastructure under planning obligations, is supported. It is recommended that this recognition is replicated in other policies of the LDP in order that the third Test of soundness can be fully met; Deliverability – ensuring the plan is likely to be effective). See comments in relation to Policies SP8/CC1/SP16/CI1.

CI1 – Open Space Provision

Provision of open space in residential developments is supported. HG4(4) promotes open space within the draft allocation.

The viability of developments however must not be compromised in order to ensure delivery of the plan. The ‘development viability’ should recognised as a key factor in delivering open space ( see comments on SP13 / SP8 where evidenced viability is specifically referenced within those policies – this approach is supported.

SP16 - Climate change Mitigation and Adaptation

The provisions of SP16 are generally supported as practical measures to ensure important sustainable development is achieved.

CC1 – Residential Operational Net Zero Carbon Development

The provisions of Policy CC1 echo the WG targets for Net Zero by 2050.
Whilst some of the supporting text to policy CC1 references viability, the ultimate viability of developments however must not be compromised in order to ensure delivery of the plan. The technical feasibility of renewable energy regeneration is referenced in the above policy however the ‘development viability’ should also be included. See comments on SP13 / SP8 where evidenced viability is specifically referenced within those policies – this approach is supported.

SP19 – Green Infrastructure

Provision of Green Infrastructure in residential, and all developments is supported.

HG4(4) retains and enhances existing and will promote green infrastructure on the draft allocation.

The viability of developments however must not be compromised through green infrastructure provision - in order to ensure delivery of the plan. The ‘development viability’ should therefore be recognised as a key factor in delivering Green Infrastructure. See comments on SP13 / SP8 where evidenced viability is specifically referenced within those policies – this approach is supported.

SP20 – Biodiversity and Ecosystem resilience

The above Policy is in accordance with Chapter 6 PPW. The approach is supported and dovetails with SP19 above.

DNP1 – Special Landscape Areas

DNP1 identified Special Landscape Areas across the Vale.

Fferm Goch is one of the settlements that remains fully within and covered by the Upper and Lower Thaw Valley Special Landscape Area (SLA). It is noted that in such settlements, while there have been amendments to the identified settlement boundary ( inclusion of HG4 (4) rural affordable led housing allocation) this has not affected the SLA designation in these areas. (Background Paper 45; Paragraph 1.16 refers).

The location of the small allocated site HG4(4) is nestled within the settlement of Fferm Goch. It is built up on both the northern and southern boundaries, with the main road running along the eastern boundary. There is no unacceptable harm to the SLA of the Upper and Lower Thaw valley.

The allocation of the site for residential development does not give rise to unacceptable harm to the special qualities and characteristics of the SLA, based on LANDMAP information, continues to be preserved.

Representation on the Vale of Glamorgan Deposit RLDP 2021–2036
Specific Policy/Site Objection:
• Policy SP4.4: Land at Church Farm, St Athan
• Policy SP4.5: Land to the West of St Athan
• Clive Road (Additional Allocation)
• Policy EMP2: MOD St Athan / Bro Tathan
Status: Unsound
1. Introduction
I wish to formally object to the allocation of the above sites and the broader designation of St
Athan as a "Primary Settlement" for high-density growth within the Replacement Local
Development Plan (RLDP). This allocation fails the Test of Soundness regarding Consistency
(with national climate goals) and Effectiveness (deliverability of infrastructure).
2. Failure of Sustainable Transport (Policy SP7 & SP10)
The RLDP identifies St Athan as a "Strategic Hub," yet it remains the only primary settlement in
the Vale of Glamorgan without a direct rail link. Relying on the "Active Travel" aspirations of
Policy SP10 is unrealistic for a community where the majority of residents commute to Cardiff,
Bridgend, or Barry.
The proposed density at the above sites will inevitably lead to an unsustainable increase in
private car journeys on the B4265, specifically at the Gileston Road junction and Weycock
Cross, which are already at or near capacity.
Concrete infrastructure is needed to be in place prior to any development of the land. Often
intentions of infrastructure are not progressed. In addition where infrastructure is not in place
prior to housing many commuters will become accustomed to travel by car and wont switch to
public transport. It is difficult to see how developments work with Future Wales: The National
Plan 2040
Active travel should look at linking key destinations and with the western vale being spread over
longer distances more effort should be given to linking population centres with separated
bicycle paths and wide accessible pavements. Shared bike / foot paths are inherently
dangerous not allowing the safe use of wheelchairs and prams and sufficient use for children
and dog walkers. Cycling should not have to stop at every intersection which creates visibility
black spots by the way they turn away from traffic.
With current planned housing and that of additional housing in the LDP creating over 1,000 new
homes and with each household having 1-2 cars per household this will add significant
additional numbers of journeys on already poor road infrastructure. The vale lacks sufficient
north / south routes pushing vehicles towards Weycock Cross in Barry which will have its own
traffic issues or via Cowbridge with small country lanes. I personally worked in Cowbridge
travelling from St Athan where buses would take over 1 hour 10 minutes and even then not
arriving in time to start work. In contrast car travel would be 10 minutes or cycle would be 20
minutes but over dangerous roads.
Travel to Barry for meetings at peak times can take over 50 minutes from St Athan with
significant delays leading to Weycock Cross and passed the secondary schools even before
developments in the RLDP or existing planning. Public transport gets caught in the same traffic
issues.
Access into St Athan is already dangerous from the war memorial with one near fatal accident
already having taken place since the ‘improvements’ to the junction. Proposals for additional
access from B4265 onto developed land would be on a hill with poor visibility and around a
blind bend. Currently there is poor visibility leaving St Athan due to the side by side two car exit
blocking views in both directions along with more visibility issues looking westward due to
traffic furniture and signage.
While Bro Tathan (Policy EMP2) provides jobs, there is no guarantee that the people moving
into local developments will work there. If they commute elsewhere, the RLDP fails its own
climate goals (Policy SP1) by creating a "commuter colony" rather than a sustainable
community.
Reference Policy CI3 (New Community Facilities). The proposed expansion of St Athan
Primary School lacks a guaranteed timeline for when these facilities will be operational relative
to house completions. New access to the school under existing planning is only ‘proposed’ and
existing access to the school via Rock Road is a poorly surfaced and narrow one way road but is
often ignored with traffic coming via Rectory Drive which has a ‘No entry except for access’
restriction but is not enforced causing large numbers of vehicles into residential areas not built
for this type of activity.
Speeding is already a great concern in the village with the current level of vehicle traffic with
little compliance with the 20mph speed limit and no enforcement.
3. Coalescence and Loss of Settlement Identity (Policy SSC1)
The scale of development proposed for Church Farm, in conjunction with Policy SP4.5 (Land
West of St Athan), threatens the distinct character of the village. The erosion of the "Strategic
Gap" between St Athan and Eglwys Brewis violates the principles of Policy SSC1 (Settlement
Boundaries). This "urban creep" creates a continuous sprawl that permanently destroys the
rural setting of the historic Church Farm and the village’s unique sense of place.
St Athan should no longer be thought of as a village but as a small town with infrastructure to
meet the growing demands of the population and lacks facilities that are given to surrounding
towns such as fire / ambulance and police stations.
If the jobs at the Enterprise Zone (Aston Martin, Bro Tathan) do not match the demographic of
the new residents, St Athan simply becomes a "dormitory" village, increasing the carbon
footprint as people drive to Cardiff or Bridgend for work. In addition people will travel to St Athan
from other areas should they be employed at the new commercial sites.
4. Infrastructure Lag and Healthcare Capacity (Policy CI3)
Under Policy CI3, development should only proceed where adequate community facilities exist
or can be provided. Current primary healthcare services in St Athan and nearby Llantwit Major
are already oversubscribed. The RLDP provides no "Triggers for Delivery" to ensure that new
medical and educational facilities will be operational prior to the occupation of the hundreds of
homes planned for the Church Farm site. This creates a significant risk to the wellbeing of both
new and existing residents. Access to both village GP services are on a part time basis. With
new dentist rules in Wales, this will increase the need for further travel around the area to meet
simple check ups. With no A&E facilities in the county St Athan often falls between Cardiff and
Bridgend hospitals and continued poor roads together with additional traffic gives greater
concern when emergencies happen.
5. Environmental and Biodiversity Impact (Policy SP5)
The Church Farm site consists of high-quality agricultural land and vital greenfield habitats.
While Policy SP5 mandates a "Net Benefit for Biodiversity," the total loss of soil permeability
and ancient hedgerow connectivity on a site of this scale cannot be mitigated by tokenistic
landscaping. Once this valuable land is developed it is irretrievably lost for current and future
generations. Currently there are red list species using the space like Yellowhammers and
Skylarks. In addition there has been a collapse of invertebrate bio-mass over the last 40 years
and personally seen since moving the area in 1980. Net Benefit for Biodiversity plans do not
address any of these local and national concerns.
Land to the west of St Athan (SP4.5) This site consists of Grade 2 (Good) or 3a (Excellent)
agricultural land. Under Planning Policy Wales (PPW) 12, such land should only be developed
if there is an "overriding need" and no lower-grade land is available. The Vale of Glamorgan
council has not sufficiently explored brownfield alternatives in the Barry Docks or the St Athan
Enterprise Zone. The increased light pollution and "urban glow" will impact the rural character of
the Western Vale.
The invertebrate charity Buglife shows that based on citizen science monitoring data, there has
been a 75% to 79% decline in the abundance of flying insects in Wales between 2004 and 2023.
Natural Resources Wales also reported
• 79% Decrease in Flying Insects (2004–2023): Data from the "Bugs Matter" survey,
which counts insect "splats" on vehicle number plates, recorded this 79% reduction in
Wales, with 2023 showing further declines from previous years.
• Specific Invertebrate Declines: Moths, which are key pollinators, have seen an average
decline of 43% in abundance since 1970.
• Widespread Biodiversity Loss: Welsh wildlife has decreased on average by 20% since
1994, and 18% of species in Wales are at risk of extinction.
• Habitats in Peril: Over the past 50 years, many insects have suffered declines of 65% to
70% in certain areas, particularly moths, butterflies, ladybirds, and ground beetles.
• Impact on Food Chain: Invertebrates that provide food for farmland birds have seen
declines of 50-80%.
The cumulative impact of hard-standing surfaces also raises serious concerns regarding
surface water runoff into the River Thaw catchment area. Significant surface flooding already
takes place across the western Vale spilling onto roads causing travel disruption.
An increase in hard surfaces also increases ambient temperatures compared to grassland,
woodland and other green spaces necessitating increased power use for cooling and
comfortable living temperatures. Building practices can help mitigate this but only where this is
incorporated into sustainable building rules.
Replacing green fields (which act as a natural sponge) with hundreds of roofs and driveways at
Church Farm (SP4.4) and Land West of St Athan (SP4.5) will create a "funnel effect."
Dwr Cymru Welsh Water has previously noted concerns regarding the St Athan Wastewater
Treatment Works. Proof is required that the current system can handle the RLDP's projected
f
low without increasing overflow events. Further development risks "Combined Sewer
Overflows" (CSOs) into local watercourses, which contradicts the Council’s Nature Emergency
declaration.
The Vale of Glamorgan Council requires a Sustainable Drainage Systems (SuDS) Approval
Body (SAB) review. Attenuation ponds are often poorly maintained and can fail during the "1-in
100-year" storm events which are becoming more frequent.
6. Conclusion
The allocation of the above site policies are unsound. It promotes car-dependent growth in a
rural location without the necessary infrastructure "trigger points" to protect the local
environment or the B4265 road network.
Proposed Remedy: Reduce the housing density at the above sites and re-classify St Athan as a
"Minor Rural Settlement" until such time as a dedicated rail link, suitable active travel
infrastructure or high-frequency public transport other than rail is fully funded and scheduled
for delivery.

Representation on the Vale of Glamorgan Deposit RLDP 2021–2036

Specific Policy/Site Objection:
• Policy SP4.4: Land at Church Farm, St Athan
• Policy SP4.5: Land to the West of St Athan
• Clive Road (Additional Allocation)
• Policy EMP2: MOD St Athan / Bro Tathan

Status: Unsound

1. Introduction

I wish to formally object to the allocation of the above sites and the broader designation of St Athan as a "Primary Settlement" for high-density growth within the Replacement Local Development Plan (RLDP). This allocation fails the Test of Soundness regarding Consistency (with national climate goals) and Effectiveness (deliverability of infrastructure).

2. Failure of Sustainable Transport (Policy SP7 & SP10)

The RLDP identifies St Athan as a "Strategic Hub," yet it remains the only primary settlement in the Vale of Glamorgan without a direct rail link. Relying on the "Active Travel" aspirations of Policy SP10 is unrealistic for a community where the majority of residents commute to Cardiff, Bridgend, or Barry.

The proposed density at the above sites will inevitably lead to an unsustainable increase in private car journeys on the B4265, specifically at the Gileston Road junction and Weycock Cross, which are already at or near capacity.

Concrete infrastructure is needed to be in place prior to any development of the land. Often intentions of infrastructure are not progressed. In addition where infrastructure is not in place prior to housing many commuters will become accustomed to travel by car and wont switch to public transport. It is difficult to see how developments work with Future Wales: The National Plan 2040

Active travel should look at linking key destinations and with the western vale being spread over longer distances more effort should be given to linking population centres with separated bicycle paths and wide accessible pavements. Shared bike / foot paths are inherently dangerous not allowing the safe use of wheelchairs and prams and sufficient use for children and dog walkers. Cycling should not have to stop at every intersection which creates visibility black spots by the way they turn away from traffic.

With current planned housing and that of additional housing in the LDP creating over 1,000 new homes and with each household having 1-2 cars per household this will add significant additional numbers of journeys on already poor road infrastructure. The vale lacks sufficient north / south routes pushing vehicles towards Weycock Cross in Barry which will have its own traffic issues or via Cowbridge with small country lanes. I personally worked in Cowbridge travelling from St Athan where buses would take over 1 hour 10 minutes and even then not arriving in time to start work. In contrast car travel would be 10 minutes or cycle would be 20 minutes but over dangerous roads.

Travel to Barry for meetings at peak times can take over 50 minutes from St Athan with significant delays leading to Weycock Cross and passed the secondary schools even before developments in the RLDP or existing planning. Public transport gets caught in the same traffic issues.

Access into St Athan is already dangerous from the war memorial with one near fatal accident already having taken place since the ‘improvements’ to the junction. Proposals for additional access from B4265 onto developed land would be on a hill with poor visibility and around a blind bend. Currently there is poor visibility leaving St Athan due to the side by side two car exit blocking views in both directions along with more visibility issues looking westward due to traffic furniture and signage.

While Bro Tathan (Policy EMP2) provides jobs, there is no guarantee that the people moving into local developments will work there. If they commute elsewhere, the RLDP fails its own climate goals (Policy SP1) by creating a "commuter colony" rather than a sustainable community.

Reference Policy CI3 (New Community Facilities). The proposed expansion of St Athan Primary School lacks a guaranteed timeline for when these facilities will be operational relative to house completions. New access to the school under existing planning is only ‘proposed’ and existing access to the school via Rock Road is a poorly surfaced and narrow one way road but is
often ignored with traffic coming via Rectory Drive which has a ‘No entry except for access’ restriction but is not enforced causing large numbers of vehicles into residential areas not built for this type of activity.

Speeding is already a great concern in the village with the current level of vehicle traffic with little compliance with the 20mph speed limit and no enforcement.

3. Coalescence and Loss of Settlement Identity (Policy SSC1)

The scale of development proposed for Church Farm, in conjunction with Policy SP4.5 (Land West of St Athan), threatens the distinct character of the village. The erosion of the "Strategic Gap" between St Athan and Eglwys Brewis violates the principles of Policy SSC1 (Settlement Boundaries). This "urban creep" creates a continuous sprawl that permanently destroys the rural setting of the historic Church Farm and the village’s unique sense of place.

St Athan should no longer be thought of as a village but as a small town with infrastructure to meet the growing demands of the population and lacks facilities that are given to surrounding towns such as fire / ambulance and police stations.

If the jobs at the Enterprise Zone (Aston Martin, Bro Tathan) do not match the demographic of the new residents, St Athan simply becomes a "dormitory" village, increasing the carbon footprint as people drive to Cardiff or Bridgend for work. In addition people will travel to St Athan from other areas should they be employed at the new commercial sites.

4. Infrastructure Lag and Healthcare Capacity (Policy CI3)

Under Policy CI3, development should only proceed where adequate community facilities exist or can be provided. Current primary healthcare services in St Athan and nearby Llantwit Major are already oversubscribed. The RLDP provides no "Triggers for Delivery" to ensure that new medical and educational facilities will be operational prior to the occupation of the hundreds of homes planned for the Church Farm site. This creates a significant risk to the wellbeing of both new and existing residents. Access to both village GP services are on a part time basis. With new dentist rules in Wales, this will increase the need for further travel around the area to meet simple check ups. With no A&E facilities in the county St Athan often falls between Cardiff and Bridgend hospitals and continued poor roads together with additional traffic gives greater
concern when emergencies happen.

5. Environmental and Biodiversity Impact (Policy SP5)

The Church Farm site consists of high-quality agricultural land and vital greenfield habitats. While Policy SP5 mandates a "Net Benefit for Biodiversity," the total loss of soil permeability and ancient hedgerow connectivity on a site of this scale cannot be mitigated by tokenistic landscaping. Once this valuable land is developed it is irretrievably lost for current and future generations. Currently there are red list species using the space like Yellowhammers and Skylarks. In addition there has been a collapse of invertebrate bio-mass over the last 40 years and personally seen since moving the area in 1980. Net Benefit for Biodiversity plans do not address any of these local and national concerns.

Land to the west of St Athan (SP4.5) This site consists of Grade 2 (Good) or 3a (Excellent) agricultural land. Under Planning Policy Wales (PPW) 12, such land should only be developed if there is an "overriding need" and no lower-grade land is available. The Vale of Glamorgan council has not sufficiently explored brownfield alternatives in the Barry Docks or the St Athan Enterprise Zone. The increased light pollution and "urban glow" will impact the rural character of the Western Vale.

The invertebrate charity Buglife shows that based on citizen science monitoring data, there has been a 75% to 79% decline in the abundance of flying insects in Wales between 2004 and 2023.

Natural Resources Wales also reported

• 79% Decrease in Flying Insects (2004–2023): Data from the "Bugs Matter" survey, which counts insect "splats" on vehicle number plates, recorded this 79% reduction in Wales, with 2023 showing further declines from previous years.
• Specific Invertebrate Declines: Moths, which are key pollinators, have seen an average decline of 43% in abundance since 1970.
• Widespread Biodiversity Loss: Welsh wildlife has decreased on average by 20% since 1994, and 18% of species in Wales are at risk of extinction.
• Habitats in Peril: Over the past 50 years, many insects have suffered declines of 65% to
70% in certain areas, particularly moths, butterflies, ladybirds, and ground beetles.
• Impact on Food Chain: Invertebrates that provide food for farmland birds have seen declines of 50-80%.

The cumulative impact of hard-standing surfaces also raises serious concerns regarding surface water runoff into the River Thaw catchment area. Significant surface flooding already takes place across the western Vale spilling onto roads causing travel disruption.

An increase in hard surfaces also increases ambient temperatures compared to grassland, woodland and other green spaces necessitating increased power use for cooling and comfortable living temperatures. Building practices can help mitigate this but only where this is incorporated into sustainable building rules.

Replacing green fields (which act as a natural sponge) with hundreds of roofs and driveways at Church Farm (SP4.4) and Land West of St Athan (SP4.5) will create a "funnel effect."

Dwr Cymru Welsh Water has previously noted concerns regarding the St Athan Wastewater Treatment Works. Proof is required that the current system can handle the RLDP's projected flow without increasing overflow events. Further development risks "Combined Sewer Overflows" (CSOs) into local watercourses, which contradicts the Council’s Nature Emergency declaration.

The Vale of Glamorgan Council requires a Sustainable Drainage Systems (SuDS) Approval Body (SAB) review. Attenuation ponds are often poorly maintained and can fail during the "1-in-100-year" storm events which are becoming more frequent.

6. Conclusion

The allocation of the above site policies are unsound. It promotes car-dependent growth in a rural location without the necessary infrastructure "trigger points" to protect the local environment or the B4265 road network.

Proposed Remedy: Reduce the housing density at the above sites and re-classify St Athan as a "Minor Rural Settlement" until such time as a dedicated rail link, suitable active travel infrastructure or high-frequency public transport other than rail is fully funded and scheduled for delivery.

Dinas Powys Community Council submits this technical objection to the proposed allocation of the Eastbrook site within the Vale of Glamorgan Replacement Local Development Plan (RLDP). While the Council recognises and welcomes several positive changes in the revised RLDP, the Eastbrook allocation remains fundamentally unsound due to unresolved constraints relating to:
• Flood risk and hydrology
• Highways and transport capacity
• Environmental and landscape impact
• Infrastructure limitations
• Deliverability and viability

The Eastbrook site lies within a complex hydrological catchment characterised by:
• Groundwater emergence
• Overland flow routes
• Low-permeability soils
• A history of significant flood events, including the 2020 incident
• Interactions between surface water, groundwater, and existing drainage systems
Natural Resources Wales (NRW) has repeatedly identified flood-risk concerns at this location, and the Council’s own evidence base acknowledges the need for detailed catchment-wide modelling before any development can be considered.

The RLDP currently lacks:
• Mandatory policy wording to secure pre-delivery of mitigation
• Requirements for catchment-wide modelling
• Guarantees that development will not increase flood risk elsewhere
• Mechanisms to ensure that mitigation is viable, deliverable, and enforceable

Without these safeguards, the allocation is unsound under the tests of:
• Soundness Test CE2 (coherence and effectiveness)
• Soundness Test CE4 (deliverability)
• Soundness Test CE3 (environmental protection)
This objection sets out:
1. The positive changes recognised in the revised RLDP
2. The continued reasons why the Eastbrook allocation remains unsound
3. A full technical hydrology and flood-risk chapter
4. Mandatory policy wording required to make the allocation sound
5. A formal request for written confirmation from the Vale of Glamorgan Council
6. Supporting diagrams (ASCII + placeholders)


SECTION 1. EXECUTIVE SUMMARY
Dinas Powys Community Council submits this technical objection to the proposed allocation of the Eastbrook site within the Vale of Glamorgan Replacement Local Development Plan (RLDP). While the Council recognises and welcomes several positive changes in the revised RLDP, the Eastbrook allocation remains fundamentally unsound due to unresolved constraints relating to:
• Flood risk and hydrology
• Highways and transport capacity
• Environmental and landscape impact
• Infrastructure limitations
• Deliverability and viability
The Eastbrook site lies within a complex hydrological catchment characterised by:
• Groundwater emergence
• Overland flow routes
• Low-permeability soils
• A history of significant flood events, including the 2020 incident
• Interactions between surface water, groundwater, and existing drainage systems
Natural Resources Wales (NRW) has repeatedly identified flood-risk concerns at this location, and the Council’s own evidence base acknowledges the need for detailed catchment-wide modelling before any development can be considered.
The RLDP currently lacks:
• Mandatory policy wording to secure pre-delivery of mitigation
• Requirements for catchment-wide modelling
• Guarantees that development will not increase flood risk elsewhere
• Mechanisms to ensure that mitigation is viable, deliverable, and enforceable
Without these safeguards, the allocation is unsound under the tests of:
• Soundness Test CE2 (coherence and effectiveness)
• Soundness Test CE4 (deliverability)
• Soundness Test CE3 (environmental protection)
This objection sets out:
1. The positive changes recognised in the revised RLDP
2. The continued reasons why the Eastbrook allocation remains unsound
3. A full technical hydrology and flood-risk chapter
4. Mandatory policy wording required to make the allocation sound
5. A formal request for written confirmation from the Vale of Glamorgan Council
6. Supporting diagrams (ASCII + placeholders)

The Community Council urges the Vale of Glamorgan Council to either:
• Remove the Eastbrook allocation from the RLDP, or
• Incorporate the mandatory policy wording and evidence requirements set out in this document.
Failure to do so will leave the RLDP vulnerable to challenge at Examination.

Examination.

SECTION 2 - INTRODUCTION
Dinas Powys Community Council (DPCC) submits this formal objection to the proposed allocation of the Eastbrook site (HG1 - KS2) within the Vale of Glamorgan Replacement Local Development Plan (RLDP). The Council recognises the importance of delivering sustainable housing across the Vale, and it acknowledges some of the positive changes made in the revised RLDP. However, the Eastbrook allocation remains fundamentally unsound due to unresolved and significant constraints relating to:
• Flood risk and hydrology
• Highways and transport capacity
• Environmental and landscape impact
• Infrastructure limitations
• Deliverability and viability
The Eastbrook site occupies a sensitive position within a complex hydrological catchment. The area is characterised by groundwater emergence, overland flow routes, low-permeability soils, and a history of significant flood events — most notably the 2020 incident, which affected properties downstream. Natural Resources Wales (NRW) has repeatedly highlighted concerns regarding flood risk at this location, and the Council’s own evidence base acknowledges the need for detailed catchment-wide modelling before any development can be considered.
Despite these known constraints, the RLDP does not currently include:
• Mandatory policy wording to secure pre-delivery of mitigation
• Requirements for catchment-wide modelling
• Guarantees that development will not increase flood risk elsewhere
• Mechanisms to ensure that mitigation is viable, deliverable, and enforceable
This objection sets out the failure to follow legal Consultation Procedural Soundness, the technical evidence, policy requirements, and mandatory safeguards necessary to make the RLDP sound. Without these safeguards, the allocation fails the tests of soundness, particularly:
• CE2 — Coherence and effectiveness
• CE3 — Environmental protection
• CE4 — Deliverability
This Council therefore requests either:
1. Removal of the Eastbrook allocation from the RLDP, or
2. Inclusion of the mandatory policy wording and evidence requirements set out in this document
Failure to address these issues will leave the RLDP vulnerable to challenge at Examination.

CHANGES IN THE REVISED RLDP
Dinas Powys Community Council (DPCC) recognises and welcomes some improvements made in the revised Replacement Local Development Plan (RLDP). These changes demonstrate a more balanced approach to growth and a clearer acknowledgement of environmental and infrastructure constraints across the Vale. DPCC considers the following amendments to be positive and constructive:
3.1 Reduction in Overall Housing Numbers
The reduction in the total housing requirement reflects a more realistic assessment of demographic trends, household formation rates, and deliverability across the plan period. This reduces pressure on constrained settlements such as Dinas Powys.
3.2 Greater Emphasis on Sustainable Locations
The revised RLDP places stronger emphasis on locating development where sustainable transport options exist. This aligns with national policy and reduces reliance on private car travel.
3.3 Strengthened Climate-Change and Flood-Risk Policies
The Council welcomes the enhanced policy framework relating to:
• Climate-change adaptation
• Flood-risk management
• Sustainable drainage (SuDS)
• Nature-based solutions
These changes reflect national guidance and NRW expectations.
3.4 Recognition of Infrastructure Constraints
The revised evidence base acknowledges that certain settlements – including Dinas Powys -face:
• Highway capacity limitations
• Public transport constraints
• Limited school and healthcare capacity
This recognition is essential for sound plan-making.

3.5 Improved Evidence Base
The updated background papers, including the Settlement Sustainability Assessment and the Infrastructure Assessment, provide a clearer picture of constraints and opportunities across the Vale.

SECTION 4 — CONTINUED OBJECTION TO THE EASTBROOK ALLOCATION
Despite recognising positive changes in the revised RLDP, Dinas Powys Community Council (DPCC) maintains a clear and evidence-based objection to the proposed allocation of the Eastbrook site (HG1 – KS2). DPCC email asked for clarification from the Vale planning office on the fact that the planning policy (dated 17 December 2025) stated ‘feedback received has helped to refine proposals for the sites in the deposit plan’. When asked at the consultation at Murchfield what the refinements were, the response was ‘there has not been any’.
The allocation remains unsound because the fundamental constraints affecting the site have not been resolved, mitigated, or fully understood.
DPCC’s objection is based on the following core issues:
4.1 Flood Risk and Hydrology
The Eastbrook site sits within a complex and sensitive hydrological catchment. Key concerns include:
• Groundwater emergence during prolonged wet periods
• Overland flow routes that cross the site and discharge toward existing residential areas
• Low-permeability soils that limit infiltration
• A history of significant flood events, including the 2020 incident
• Interactions between surface water, groundwater, and existing drainage systems
NRW has repeatedly raised concerns about flood risk at this location. The Council’s own evidence base acknowledges that catchment-wide modelling is required before any development can be considered. This modelling has not been undertaken.
4.2 Highways and Transport Capacity
Dinas Powys already experiences:
• Congestion on Cardiff Road
• Limited capacity at key junctions
• Insufficient public transport frequency
• High dependency on private car travel
The Eastbrook allocation would exacerbate these issues. No deliverable or funded mitigation has been identified.
4.3 Environmental and Landscape Impact
The site contributes to:
• Local landscape character
• Biodiversity connectivity
• Air quality
• Green infrastructure
• Natural drainage functions
Development would result in the loss of greenfield land that currently performs essential hydrological and ecological roles.
4.4 Infrastructure Limitations
Local infrastructure is already under pressure, including:
• Schools
• Healthcare provision
• Utilities
• Surface-water drainage systems
No evidence has been provided to demonstrate that these constraints can be resolved within the plan period.
4.5 Deliverability and Viability
The RLDP does not demonstrate that:
• Required flood-risk mitigation is technically feasible
• Mitigation is financially viable
• Mitigation can be delivered before development
• Mitigation will not increase flood risk elsewhere
Without this evidence, the allocation fails Soundness Test CE4 (deliverability).
Finally, there are questionable processes in the Consultation procedure that DPCC would like to question. These include:
Lack of Formalised Documentation and Transparent Feedback Loops: The consultation process currently lacks procedural transparency, specifically regarding the recording of public participation and the subsequent analysis of feedback. There is no evidence of formalised record-keeping for public attendance at engagement events, nor a transparent ledger of how individual resident comments were synthesised into the current Plan. Without clear feedback loops, it remains entirely unclear to stakeholders how local consultation responses have influenced site allocation decisions, compromising the Plan's legitimacy and accountability.
Significant Digital Barriers and Technical Complexity: The Council’s primary reliance on an "online-first" engagement strategy, through its consultation portal, has created substantial barriers to participation. The technical reports and modelling assumptions provided are often not easily interpretable by laypersons, limiting the ability of the community to effectively scrutinise the evidence base. The complexity of the account-creation process and the technical nature of the guidance notes have resulted in a disproportionate administrative burden that discourages meaningful public response.
Digital Exclusion and Demographic Disparity: The current consultation framework fails to adhere to the requirement that engagement must be "inclusive and accessible to all local groups", particularly those less likely to participate. Residents in Dinas Powys, specifically non-digitally native demographics and the elderly, face significant digital exclusion due to the lack of accessible summaries and the high level of technical literacy required to complete online forms. This lack of equitable access undermines the Council's duty to ensure a robust and representative evidence base.
Inflexible Scheduling and Inequitable Engagement Windows: The timing of the consultation periods has been identified as a factor that alienated or excluded significant portions of the local community. Despite formal requests from the DPCC for more accessible scheduling to facilitate wider public attendance, these requests were refused. Furthermore, there is a perceived pre-determination in the process, where preferred strategies and site directions appear to be announced prior to effectively engaging public opinion, rendering the subsequent consultation window a mere formality rather than a meaningful opportunity for influence.
Conclusion on Soundness: Due to these systemic failures in the Plan-making process, the RLDP fails the test of Effectiveness (CE2). Until the Council can demonstrate a fully transparent, accessible, and documented consultation process that genuinely reflects the lived experience of the community, the Plan cannot be considered fully justified or consistent with national policy regarding community involvement.
SECTION 5 — TRANSPORT AND HIGHWAYS

CONSTRAINTS

Transport and highways capacity remain a critical constraint for Dinas Powys and a central reason why the Eastbrook allocation is unsound. The settlement already experiences significant congestion with increasing air pollution (around critical areas such as schools), limited public transport provision, and constrained junction capacity. The RLDP does not demonstrate that these issues can be resolved within the plan period, nor does it provide evidence that the Eastbrook allocation can be delivered without exacerbating existing problems.

5.1 Existing Congestion and Network Stress

Dinas Powys suffers from chronic congestion, particularly along:

Cardiff Road The approach to the Merrie Harrier junction The route toward Penarth The route toward Barry

Peak-time delays are well-documented, and queueing frequently extends through residential areas. The network operates close to or at capacity during peak hours, leaving little room for additional traffic generated by new development.

5.2 Limited Public Transport Provision

Public transport options are constrained by:

Infrequent bus services Limited rail capacity at Eastbrook Station Poor integration between modes Lack of reliable alternatives to private car travel

The RLDP does not identify any committed or funded improvements that would materially increase public transport capacity.

5.3 Junction Capacity Constraints

Key junctions in and around Dinas Powys are already operating at or near capacity. These include:

Merrie Harrier junction Cardiff Road / Penlan Road Cardiff Road / Millbrook Road

No evidence has been provided to demonstrate that these junctions can accommodate additional traffic from the Eastbrook allocation.

5.4 Lack of Deliverable Mitigation

The RLDP does not include:

Funded highway improvements Committed public transport enhancements A deliverable transport strategy for Dinas Powys Evidence that mitigation is viable or achievable within the plan period

Without deliverable mitigation, the allocation fails Soundness Test CE4 (deliverability).

5.5 Cumulative Impact

The cumulative impact of, existing congestion, committed developments, background traffic growth and the Eastbrook allocation has not been assessed in a robust or comprehensive manner.

a. Unresolved Chronic Congestion on the A4055 Corridor:

The RLDP fails to demonstrate that the primary highway network serving Dinas Powys can accommodate the proposed level of growth without resulting in unacceptable congestion.

Existing Network Stress: The A4055 (Cardiff Road) and the approach to the Merrie Harrier junction are already characterized by "chronic congestion". Peak-time delays are well-documented, with queuing frequently extending through residential areas as the network operates at or near capacity.

Absence of Modelling: The Plan lacks transparent, settlement-specific junction capacity assessments or peak-hour traffic modelling for these key constraints. Without this evidence, the Council's assumption that an additional 250 units can be absorbed is technically unjustified.

The RLDP Preferred strategy requires the developer to provide "improvements to infrastructure, including the upgrading of highways. and utility networks" and provide "on and off-site measures" to provide safe linkages to Eastbrook Station and "upgrading of highways". It is unclear what if any specific and definitive instruction will be given to the developer and how the Council will monitor and ensure that appropriate objectives are achieved.

VOG Highways say that Persimmon cannot pencil in the 'secondary' or emergency access. Persimmon failed to do a traffic study to contest Highways' view. Another is no proposal to bring pedestrian/cycle access up to the Welsh Government standard. The suggested George's Row and Seel Park routes to Eastbrook Station and Camms Corner shopping area do not work. Highways point out this is a Welsh Government requirement for new developments.

In reference to Welsh Government's policies;

Policy conflict Fails PPW11 TAN 18, and the Fire and Rescue Services Act duty to maintain effective response capability. The proposal's reliance on a single access for a development of 250 dwellings is;

Contrary to PPW11 (safe, resilient access) Contrary to Tan 18 (avoid single points of failure) Contrary to Fire and Rescue operational requirements in Wales Contrary to Manual for Streets principles Contrary to established Welsh LHA practice Unsupported by appeal precedent.

The development therefore presents an unacceptable and avoidable risk to residents and emergency responders. A second access, or at minimum a fully engineered emergency only route, is essential to make the scheme safe and policy compliant.

b. Cumulative Traffic Flows from Regional RLDP Growth:

The RLDP directs a significant portion of the 7,890 required dwellings to settlements east of Dinas Powys, including major allocations in Barry and Penarth.

Impact of Neighbouring Allocations: Developments such as Upper Cosmeston Farm in Penarth (576 units) and the proposed growth in Barry (686 units) will significantly increase commuter volumes along the A4055, which serves as the primary arterial route to Cardiff.

Commuter Dependency: Data identifies Cardiff as the destination for 63.6% of all commuters from the Vale traveling by car. The RLDP fails to robustly assess the cumulative impact of background traffic growth, committed developments, and the Eastbrook allocation on the Dinas Powys road network. The Eastbrook allocation is fundamentally car-dependent due to infrequent bus services and limited modal integration. Furthermore, the RLDP does not identify any funded or committed highway improvements for the A4055 (Cardiff Road) or the Merrie Harrier junction, both of which are already operating at or near capacity. This lack of deliverable mitigation contradicts the transport objectives.

c. Failure of Active Travel and Pedestrian Infrastructure: The Plan relies on "sustainable transport options" to justify the Eastbrook site, yet the physical infrastructure is fundamentally non-compliant with inclusive design standards: Pavement Capacity and Safety: Existing pedestrian routes connecting the site to the village centre, are insufficient in width to accommodate double buggies or wheelchairs. These routes are further obstructed weekly by refuse collection and recycling bags, forcing vulnerable pedestrians - including those with single buggies or small children - to navigate restricted and unsafe spaces.

During the consultation (6th February 2026) Vale officers were asked if they had walked the proposed active travel route along Cardiff Road. We were told they had not. Photos below show how narrow the pavement is and this does not meet with the Active Travel Guidelines. There is no capacity to widen this route. In addition, the other proposed route via Powys Gardens involves a very steep hill. Would this be accessible for people with mobility scooters or mobility issues. It would also be a hazard in icy weather. This route also incorporates an alleyway which is not visible from start to finish with a 90 degree angle and no lighting. This is a safety concern. Another route is via some garages which are off George's Row. This is not and adopted road by the Vale and therefore not within their remit to propose it as an active travel route.

Eastbrook Railway Station Accessibility: While the station is within a 10-minute walk, it suffers from a critical "accessibility gap." Only one platform is accessible to residents with limited mobility, prams, or cycles. Due to the absence of a lift to the opposite platform, these residents must undertake a one-mile detour via local roads to access rail services, rendering the "sustainable" rail link effectively inaccessible to a significant portion of the demographic. Feedback from the Vale drop in session (6th February 2026), revealed that when residents mentioned that mothers with prams and people with mobility issues can't use the Eastbrook station, The response was 'it's fine for the majority'. When asked about the minority and about them being discriminated against there was no response. When looking at Active Travel Guidelines it references the Equality Act 2010. What dialogue has the Vale had with organisations representing people with protected characteristics.
d. Deficiencies in Public Transport Provision: The reliance on "good bus links" is not supported by current service levels:

Infrequent Bus Services: Dinas Powys is characterized by infrequent bus services that do not provide a reliable alternative to private car travel.

Lack of Mitigation: The RLDP does not identify any committed or funded improvements to bus frequency or capacity, ensuring that the Eastbrook development will remain car- dependent and exacerbate existing A4055 corridor failures. Without a committed and funded scheme to address the documented "chronic congestion" at the Merrie Harrier junction and A4055, the allocation fails the deliverability standards outlined in the RLDP Section 7.8.

Mandatory Policy Wording Required for Soundness: to address these obstacles and ensure they are not sidelined during the development process, the RLDP must include the following:

Enforceable policy wording to meet Soundness Tests CE2 (Effectiveness) and CE4 (Deliverability): Policy TR-DNP: Enforceable Transport and Accessibility Mitigation

Development at Eastbrook (HG1 - KS2), in the opinion of DPCC, should not be permitted unless the following criteria are met and delivered in advance of occupation:

1. Corridor Capacity and Cumulative Modelling: A comprehensive Cumulative Transport Assessment is completed and approved, demonstrating that the A4055 and Merrie Harrier junction can accommodate traffic from Eastbrook in combination with committed growth in Barry and Penarth without exceeding statutory capacity or safety limits. During the consultation Vale officers admitted that the road is already over capacity.

2. Eastbrook Station Bilateral Access: Legally binding funding and a delivery program are secured for the installation of a lift or accessible bridge at Eastbrook Railway Station to ensure bilateral platform access for all users, removing the current one-mile detour requirement.

However, having been in discussion with the Department of Transport, they have no plans to make any improvements to the station with regard to access.

3. Statutory Inclusive Pedestrian Widths: All off-site pedestrian linkages to the village centre and station are widened to meet statutory inclusive design standards, ensuring a minimum effective width for simultaneous passage of double buggies and wheelchairs. In line with the Active Travel Act has the Vale carried out an Equality impact assessment (EQIAs). Proposed active travel routes do not meet the criteria.

4. Operational Access Management: A Pedestrian Management Plan is approved, demonstrating how safe passage for prams and wheelchairs will be maintained during weekly refuse and recycling collections.

5. Secured Bus Enhancements: Written confirmation and funding are secured to increase bus service frequency to provide a genuine, high-frequency alternative to private car travel for Cardiff-bound commuters. Has a WelTAG survey has been carried out? Due to the volume of traffic through Dinas Powys a bus service is thinking of reducing the service as so much time is spent in static traffic. Evidence that these routes can be preserved or managed safely including evidence of Equality Impact Assessment (EQIAs). Evidence of the Active Travel Wales Act 2013. What reasonable measures have you taken to include children and young people in the planning and implementation and review of the decision-making process? Conclusion: In the absence of this 'mandatory wording' and the required 'technical modelling', the Eastbrook allocation is unsound. It ignores the physical reality of the infrastructure, the lived experience of residents on the A4055, and the cumulative traffic pressures generated by the RLDP's own regional growth strategy. Based on a review of the Vale of Glamorgan RLDP Preferred Strategy and the Final Review Report, the following technical objection focuses on the proposed delivery of 250 houses at the Eastbrook site. This objection highlights the failure to align the housing mix with local demographic needs, the lack of transparency regarding infrastructure funding, and the questionable justification for further large-scale growth in Dinas Powys. 5.6 Summary

The transport and highways evidence base does not demonstrate that the Eastbrook allocation can be delivered without causing severe impacts on the local network. The RLDP therefore fails to meet the requirements of national planning policy, which requires development to be located where sustainable transport options exist and where the impact on the transport network can be effectively mitigated.

SECTION 6 — ENVIRONMENTAL AND LANDSCAPE IMPACT

The Eastbrook allocation sits within a sensitive landscape setting that performs important ecological, visual, and hydrological functions. Development of this site would result in the permanent loss of greenfield land that currently contributes to the environmental quality and character of Dinas Powys. The RLDP does not demonstrate that these impacts can be acceptably mitigated.

6.1 Landscape Character and Visual Impact

The site forms part of the green corridor that separates Eastbrook from adjoining areas. It contributes to:

The semi-rural character of the settlement edge Views from public rights of way The visual transition between built form and open countryside The sense of openness and separation between neighbourhoods

Development would introduce built form into an area that currently provides visual relief and contributes to local identity.

6.2 Biodiversity and Habitat Connectivity

The site supports:

Hedgerows Grassland habitats Mature trees Wildlife corridors connecting to wider green infrastructure

These features provide habitat for a range of species and contribute to ecological connectivity across the settlement. Development would fragment these habitats and reduce biodiversity value.

6.3 Green Infrastructure Functions

The land performs several important green-infrastructure functions, including:

Natural drainage and infiltration Groundwater recharge Overland flow conveyance Urban cooling Carbon sequestration

These functions are particularly important given the site's hydrological sensitivity.

6.4 Impact on Local Amenity

The site provides informal amenity value for local residents, including:

Views Open space character A sense of separation between built areas

Development would reduce these qualities and alter the character of the local environment.

6.5 Lack of Robust Mitigation Evidence

The RLDP does not provide:

A landscape and visual impact assessment A biodiversity net-gain strategy A green-infrastructure plan Evidence that ecological impacts can be mitigated or compensated A clear demonstration that the site can deliver net environmental benefits

Without this evidence, the allocation fails Soundness Test CE3 (environmental protection).

Statutory Ecological and Environmental Impacts: The development will cause detrimental impacts on protected European sites and irreplaceable local habitats like Ancient Woodland.

Independent Source Verification:

The HRA of the Preferred Strategy (2023) explicitly flags Site 440 (HG1 - KS2 Land North of Dinas Powys) as being only 2.6km from the Severn Estuary SAC/SPA/Ramsar.

The HRA concludes that "Mitigation is Required" for this site because it falls within the core recreational catchment of the Estuary. It recommends that the RLDP must contribute to Strategic Access Management and Monitoring (SAMM) and the provision of alternative green spaces (SANG) to protect the integrity of the Estuary.

NRW's ECOR documents that previous attempts to build flood storage in the area were opposed by the Woodland Trust because they would threaten Ancient Woodland, which is described as an "irreplaceable natural resource".

Prematurity regarding Green Infrastructure (Policy SP10 / MG18): Section 7.10 of the Review Report mandates a new Green Infrastructure Assessment (GIA) to comply with updated national policy (PPW) and the Section 6 duty to enhance biodiversity.

Grounds for Objection: The Review Report highlights that this GIA is intended to "inform plan policies and policy wording". Furthermore, independent evidence confirms the Eastbrook area is subject to Policy MG18 (Green Wedge), where development that prejudices the "open nature of the land" is prohibited. Allocating Eastbrook before the completion of the settlement-specific GIA and a formal review of the Green Wedge's integrity contradicts the sequential approach described in Section 7.

To prevent irreversible damage to the environment and ensure the ecological integrity of Dinas Powys, the RLDP must move beyond high-level assumptions. Based on the evidence in the sources, the following measures are strictly necessary to protect the local and regional environment from the impacts of the proposed Eastbrook development:

1. Mandatory Hydrological Safeguards: The Eastbrook site sits within a complex catchment characterized by groundwater emergence and low-permeability soils. To prevent increased flood risk to the environment and existing properties, the following must be delivered:

Catchment-Wide Hydraulic Modelling: A full model, agreed with Natural Resources Wales (NRW), must be completed to assess surface water, groundwater, and overland flow. This model must specifically incorporate data from the 2020 flood event to demonstrate "no increase in flood risk" to any property within the catchment.

Preservation of Natural Drainage: Existing overland flow routes and groundwater pathways must be preserved, enhanced, or appropriately managed to prevent the displacement of water into sensitive habitats or residential areas.

Proven SuDS Feasibility: A detailed study is required to prove that Sustainable Drainage Systems (SuDS) can operate effectively given the site's documented high groundwater levels and limited infiltration capacity.

2. Protection of Irreplaceable Habitats: The development area includes and is adjacent to Ancient Woodland and Sites of Importance for Nature Conservation (SINC), such as Coed Clwyd-Gwyn and Case Hill Wood.

Avoidance of Loss: Ancient woodland is an "irreplaceable natural resource". To prevent environmental damage, the Council must demonstrate that development will not result in its loss or deterioration, as "no amount of tree planting" can replace the unique biodiversity and interactions developed over centuries in these woods.

Connectivity and Resilience: The Plan must secure a Green Infrastructure Plan that maintains wildlife corridors and prevents the fragmentation of habitats for protected species, including bats, otters, and dormice.

Hydrological Stability: Measures must ensure that the development does not cause nutrient enrichment or pollution of woodland soils via sediment-heavy floodwaters, which can destabilize trees and kill overwintering species.

3. Mitigation for European Protected Sites: The Habitats Regulations Assessment (HRA) confirms that the Eastbrook site (Site 440 - HG1 - KS2) has "medium-high suitability" as off-site supporting habitat for the Severn Estuary SPA/Ramsar. To prevent an adverse effect on the integrity of this site, the following is necessary:

Bird Surveys and Evidence: The applicant must provide non-breeding bird surveys covering autumn, winter, and spring to determine if the site constitutes "functionally linked habitat" (supporting >1% of a qualifying population). Enforceable Mitigation: If significant populations are identified, the development must include avoidance measures and be assessed through a project-specific HRA.
4. Air Quality and Carbon Mitigation: Dinas Powys suffers from chronic congestion on the A4055, yet location-specific air quality modelling is absent from the evidence base. Cumulative Impact Modelling: To prevent harm to human health and the environment, the Council must conduct detailed air quality modelling that tests the cumulative effect of growth in Eastbrook alongside regional growth in Barry and Penarth. Decarbonisation Standards: New development must contribute to the Council's Net Zero 2030 ambition through siting and design that prioritizes active travel over car dependency, thereby reducing vehicle emissions.
5. Infrastructure Pre-Delivery: To prevent environmental harm from overloaded systems, essential infrastructure must be phased correctly: Wastewater Capacity: A settlement-specific assessment must prove the consented capacity of local wastewater treatment works is sufficient to prevent sewer surcharging and the discharge of untreated water into local watercourses. Phasing Requirements: All required infrastructure upgrades-including drainage, utilities, and highways mitigation-must be delivered and operational in advance of occupation. Conclusion: Without these mandatory policy safeguards and the completion of the required technical evidence base, the Eastbrook allocation remains unsound and poses a significant risk of irreparable damage to the environment of Dinas Powys.

SECTION 7 — INFRASTRUCTURE CAPACITY AND SERVICE LIMITATIONS

Infrastructure capacity is a critical determinant of whether a site is suitable and deliverable within the RLDP period. In the case of Eastbrook, the evidence demonstrates that essential infrastructure in Dinas Powys is already under significant pressure. The RLDP does not provide clear, funded, or deliverable solutions to these constraints, nor does it demonstrate that the Eastbrook allocation can be supported without unacceptable impacts on existing residents.

7.1 Education Capacity

Local schools are operating at or near capacity. Key issues include:

Limited availability of primary school places Pressure on secondary school capacity within the wider catchment. No identified funding or land for expansion No evidence that developer contributions would be sufficient or timely

The RLDP does not demonstrate that additional demand generated by the Eastbrook allocation can be accommodated.

Education Provision and School Oversubscription: The RLDP identifies Dinas Powys as a sustainable location for growth, yet it fails to provide settlement-specific evidence that local schools can absorb the additional demand from 250 new homes.

Capacity Deficit: Local primary and secondary schools are already operating at or near peak capacity. Existing data indicates limited availability of primary school places and significant pressure on secondary school capacity within the wider catchment area.

Lack of Expansion Capability: There is no identified land or secured funding for the physical expansion of these schools. The Plan provides no evidence that developer contributions (Section 106) would be sufficient or timely enough to resolve these standard-of-service deficits prior to the occupation of new homes.

Policy Inconsistency: Proceeding with the allocation without a confirmed delivery plan for school places is contrary to Planning Policy Wales, which requires growth to be directed only where essential infrastructure is available or can be secured.

To ensure that education capacity is not "overridden" by strategic regional data, the following enforceable requirement should be incorporated into Policy SP4 KS2: Policy ED-DNP: Mandatory Local Education Capacity Confirmation "Development at Eastbrook will not be permitted unless:

1. Direct Local School Consultation: A formal School Capacity Impact Report is submitted, based on direct consultation with the Headteachers and Governing Bodies of the specific schools within the Dinas Powys catchment area.

2. Verified Local Headroom: The report must provide written confirmation from these local institutions that they have the physical classroom space and staff capacity to accommodate the projected pupil yield from the development without increasing class sizes beyond statutory limits or compromising educational standards.

3. Local vs. Authority Primacy: High-level strategic projections from the Education Authority shall be deemed insufficient evidence of deliverability if they are contradicted by the operational data and physical constraints identified by the local schools themselves.

4. Pre-commencement Delivery: Any required physical expansions or new school infrastructure must be fully funded, completed, and operational prior to the occupation of the first dwelling to ensure places are available when needed

7.2 Healthcare Provision

Healthcare services in Dinas Powys and the surrounding area face:

Limited GP medical centre capacity Long waiting times Pressure on community health services No committed investment to expand provision

The medical services serving Dinas Powys are currently at capacity, and the RLDP fails to identify a mechanism to expand provision in line with population growth. Whilst it's understood that the Vale Council have spoken with the local health board. Unfortunately, there has been no consultation with single medical centre in Dinas Powys. They would be best placed to comment on the significant impact of additional housing on their provision of healthcare which is already stretched well beyond its limits.

GP and Dental Strain: Local residents already experience limited medical GP capacity and long waiting times. Existing community health services are under "significant pressure," and there is no committed investment to expand these facilities across Dinas Powys.

Lack of Local Consultation: While the Council claims to work at a high level with the Cardiff and Vale University Health Board, there has been no direct consultation with the local Health Centre serving Dinas Powys. Consequently, the Plan does not account for the technical and operational realities of a surgery that is already at capacity and cannot absorb the projected increase in patient numbers. A direct operational capacity verification from the Dinas Powys Medical Centre - current patient list size is around 11k which has increased significantly due to the closure of a nearby practice and therefore the practice is experiencing a reduced operational capacity. Any additional housing would put further strain on the practice demands and waiting times for local residents and would mean the practice moves further outside the idealised UK average (1 GP per 1,400-1,600 patients).

Health Inequality Risk: Without settlement-specific planning and confirmed provision, the proposed growth risks reducing access to healthcare for both existing and new residents, directly undermining the health and well-being objectives set out in Policy SP6.

7.3 Utilities and Drainage

Utility networks in the area face known constraints:

Surface-water drainage systems are already under pressure Foul drainage capacity is limited Welsh Water has previously raised concerns about network capacity in the settlement No evidence has been provided to demonstrate that upgrades are deliverable within the plan period

Given the site's hydrological sensitivity, drainage capacity is a critical issue.

7.4 Emergency Services and Community Infrastructure

The Eastbrook allocation would place additional pressure on:

Emergency services Community facilities Local open space Recreational infrastructure

No evidence has been provided to demonstrate that these services can absorb additional demand.

7.5 Funding and Deliverability

The RLDP does not identify:

Committed funding a delivery programme a mechanism to secure timely infrastructure upgrades Evidence that developer contributions would be viable or sufficient

Without this, the allocation fails Soundness Test CE4 (deliverability).

7.6 Summary

Reference Environment and Regeneration Scrutiny Committee 14 January 2025 it states. 'Produce sustainable Urban Drainage Solutions'. No progress due to funding and competing priorities. Infrastructure in Dinas Powys is already excessively stretched. The RLDP does not demonstrate that the Eastbrook allocation can be supported without a significant adverse impact on existing residents. Nor does it provide evidence that required upgrades are viable, deliverable, or fundable within the plan period.

SECTION 8 — HYDROLOGY AND FLOOD-RISK ANALYSIS (FULL TECHNICAL CHAPTER)

The Eastbrook site lies within a hydrologically sensitive catchment characterised by complex interactions between surface water, groundwater, overland flow, and existing drainage infrastructure. The site has a documented history of flooding, including the significant 2020 event, and Natural Resources Wales (NRW) has repeatedly raised concerns about the potential for development to increase flood risk elsewhere. At the Vale Council's drop-in session (6th Feb), there was a lack of knowledge that there is a Holy Well on the Eastbrook site, referenced in the NRW report on flooding (NRW Dinas Powys Flood Risk Management Scheme OBC page 10).

This section provides a technical assessment of the hydrological constraints affecting the site and sets out the evidence required to ensure that any development does not exacerbate flood risk to existing properties.
8.1 Catchment Overview
The Eastbrook site forms part of a small but highly responsive catchment. Key characteristics include: Low-permeability soils, resulting in rapid surface-water runoff Groundwater emergence during prolonged wet periods Overland flow routes crossing the site and discharging toward existing residential areas Limited infiltration capacity, reducing the effectiveness of SuDS Downstream constraints within the existing drainage network The catchment responds quickly to rainfall, with limited storage capacity and a high risk of exceedance during intense or prolonged events.

8.2 Hydrological Function of the Site

The site currently performs several important hydrological functions:

Attenuation of surface water during storm events Conveyance of overland flow along natural depressions Groundwater emergence and dissipation Reduction of peak flows entering downstream drainage systems Natural infiltration, albeit limited by soil type

Development would significantly alter these functions, increasing runoff rates and volumes unless substantial mitigation is provided.

8.3 Overland Flow Routes

Multiple overland flow routes cross the site. These routes convey water:

From higher ground to the north and east Across the site during heavy rainfall Toward existing residential areas downstream

Below is an ASCII-style conceptual diagram illustrating the simplified flow pattern:

Code [Higher Ground]

V

Overland Flow Across Site

V [Existing Residential Area] (Downstream Flood Receptors)

Diagrammatic representation for illustrative purposes only - not to scale.

These routes are active during moderate and heavy rainfall events and were observed during the 2020 flood incident.

8.4 Groundwater Emergence

Groundwater emergence has been recorded on and around the site during:

Prolonged wet periods High antecedent moisture conditions Winter months

This groundwater emergence contributes to:

Saturated ground conditions Reduced infiltration capacity Increased surface-water runoff Localised flooding

Any development must demonstrate that it will not alter groundwater pathways or increase groundwater-related flood risk.

8.5 The 2020 Flood Event

The 2020 flood event provides clear evidence of the site's hydrological sensitivity. During this event:

Overland flow crossed the site Groundwater emergence contributed to saturated conditions Downstream properties experienced flooding Existing drainage systems were overwhelmed

The event demonstrated that:

The catchment is highly responsive The site plays a critical role in attenuating and conveying water Development could increase flood risk unless carefully managed

The RLDP does not include any analysis of the 2020 event, nor does it require developers to assess its implications.

8.6 NRW Position and Evidence Requirements

NRW has consistently raised concerns about:

Surface-water flood risk Groundwater interactions Overland flow routes Downstream flood receptors Lack of catchment-wide modelling

NRW has advised that catchment-wide hydraulic modelling is required to:

Understand baseline conditions Assess the impact of development Identify necessary mitigation Ensure no increase in flood risk elsewhere

This modelling has NOT been undertaken.

The RLDP flood risk evidence base is functionally obsolete. It relies on the 2013 Local Flood Risk Management Strategy and a September 2020 NRW decision to abandon capital mitigation. Both of these were rendered technically invalid by the scale of the December 2020 flood event. NRW has not formally reviewed or updated a mitigation strategy for this catchment in the 11 years since the original LFRMS was published. NRW's last formal review of flood mitigation for this area was the September 2020 ECOR, which predates the 2020 flood. No post-flood mitigation review or catchment modelling incorporating the 2020 data has been undertaken.

8.7 Limitations of SuDS on This Site

While SuDS are a national requirement, their effectiveness on this site is constrained by:

Low-permeability soils High groundwater levels Limited infiltration potential Steep localised gradients Overland flow pathways that cannot be obstructed

SuDS alone cannot mitigate the hydrological impacts of development without:

Catchment-wide modelling Detailed design Pre-delivery of mitigation Long-term maintenance arrangements

8.8 Required Mitigation Measures

To ensure no increase in flood risk, the following mitigation measures would be required:

Catchment-wide hydraulic modelling Preservation of overland flow routes On-site attenuation with exceedance routing Groundwater management measures Upgrades to downstream drainage systems Pre-delivery of mitigation before development commences

The RLDP does not secure any of these measures.

8.9 Summary

The Eastbrook site is hydrologically complex and highly sensitive. Without detailed catchment-wide modelling and enforceable mitigation, development would increase flood risk to existing properties. The RLDP does not provide the evidence or policy framework required to ensure that the allocation is sound.

Natural Resources Wales (NRW) has not formally reviewed or updated its flood mitigation plans for Dinas Powys since the major flood event on December 23, 2020. The evidence base reveals a critical gap between the last strategic planning and the reality of the 2020 disaster:

1. The "2013 Strategy" Precedent: The Local Flood Risk Management Strategy (LFRMS) for the Vale of Glamorgan is dated December 2013. While this document identified Dinas Powys as being at "significant future risk," it is now over a decade old and predates both the 2020 flood and updated climate change projections. Reference Environment and Regeneration Scrutiny Committee 14 January 2025 it states. 'Implement a flood risk management plan and shoreline management plan'. No progress due to funding and competing priorities.

The above shows that the concerns of residents and flood issues in Dinas Powys are not being taken seriously.

2. Pre-Flood Rejection of Mitigation (September 2020): The most recent formal NRW assessment regarding a strategic flood scheme for Dinas Powys - the Environmental Constraints and Opportunities Record (ECOR) - was completed in September 2020, just three months before the major flood event.

A "Walkaway" Conclusion: In that pre-flood report, NRW concluded it was "unable to justify a capital flood scheme" for Dinas Powys because it was deemed only "marginally cost-beneficial".

Status Quo: NRW stated they would continue only with "business as usual" (manual channel clearing) rather than any new structural mitigation.

3. No Post-Flood Review of Mitigation: While NRW conducted "flood reconnaissance" in January 2021 and contributed to the Section 19 Flood Investigation Report (published in November 2021), these were investigative documents rather than updated mitigation plans. Missing Evidence Base: The sources explicitly state that "no catchment-wide hydraulic modelling has been undertaken" that incorporates the actual data and observations from the December 2020 event.

Outstanding Recommendations: The Section 19 report concluded by recommending that NRW "consider the viability of options to reduce flood risk," which confirms that such a review had not yet taken place as of late 2021.

4. RLDP Soundness Failure: The current RLDP is being challenged because it relies on high- level strategic data that ignores the 2020 flood event entirely.

The objection drafts note that the RLDP "does not include any analysis of the 2020 event" nor does it require developers to assess its implications.

Without an NRW-approved model that accounts for the 98 internal property floodings observed in 2020, the Council cannot technically prove that 250 additional houses will not increase flood risk elsewhere.

In conclusion, in this respect, the RLDP is unsound because its flood evidence base is functionally obsolete. It relies on a 2013 Strategy and a September 2020 NRW decision to abandon mitigation-both of which were rendered invalid by the scale of the December 2020 flood. NRW has not reviewed or modelled a new mitigation strategy for the catchment since that event occurred, leaving the settlement and the proposed site without any verified protection.

SECTION 9 — MANDATORY POLICY WORDING REQUIRED TO MAKE THE RLDP SOUND

To ensure that the Eastbrook allocation is sound, the RLDP must include explicit, enforceable, and unambiguous policy wording that secures the necessary hydrological, environmental, and infrastructure safeguards. Without this wording, the allocation fails the tests of soundness - particularly CE2 (coherence and effectiveness), CE3 (environmental protection), and CE4 (deliverability).

The following policy wording is mandatory to ensure that development does not increase flood risk elsewhere and that mitigation is viable, deliverable, and enforceable.

9.1 Mandatory Flood-Risk Policy Wording

The RLDP must include the following:

Policy FR-X: Catchment-Wide Flood-Risk Assessment (Mandatory Requirement) Development at Eastbrook (HG1 - KS2) will not be permitted unless:

1. A full catchment-wide hydraulic model has been prepared, agreed with Natural Resources Wales (NRW), and approved by the Local Planning Authority (LPA). 2. The model demonstrates no increase in flood risk to any existing property within the catchment for all relevant storm events, including climate-change allowances. 3. All required mitigation measures are: Technically feasible Financially viable Deliverable within the plan period Secured through planning conditions or legal agreement 4. All mitigation measures are delivered prior to the commencement of development. 5. Overland flow routes, groundwater pathways, and natural drainage functions are preserved, enhanced, or appropriately managed. 6. A long-term management and maintenance plan for all SuDS and flood-risk infrastructure is secured.

9.2 Mandatory Groundwater and Overland Flow Policy Wording Policy FR-Y: Groundwater and Overland Flow Protection Development proposals must:

Demonstrate that groundwater emergence will not be exacerbated Preserve all existing overland flow routes Provide exceedance routing that avoids existing residential areas Incorporate groundwater-resilient design measures Avoid any obstruction of natural drainage pathways

No development will be permitted unless these requirements are met in full.

9.3 Mandatory SuDS Policy Wording

Policy SuDS-X: Sustainable Drainage Requirements

All development must:

Provide SuDS designed in accordance with national standards Demonstrate that infiltration-based SuDS are viable, or provide alternatives where infiltration is not feasible Include attenuation sized using catchment-wide modelling outputs Provide exceedance routing that avoids downstream receptors Secure long-term maintenance arrangements

SuDS must be operational before any dwelling is occupied.

9.4 Mandatory Infrastructure Delivery Policy Wording

Policy INF-X: Infrastructure Delivery and Phasing

Development at Eastbrook (HG1 - KS2) will not be permitted unless:

All required infrastructure upgrades (education, healthcare, utilities, drainage, highways) are identified Funding is secured Delivery is guaranteed within the plan period Infrastructure is delivered in advance of occupation

The RLDP must demonstrate that infrastructure delivery is viable and enforceable.

9.5 Summary

Without the mandatory policy wording set out above, the RLDP:

Does not secure the evidence required to assess flood risk Does not guarantee that mitigation will be delivered Does not ensure that development will not increase flood risk elsewhere Does not demonstrate deliverability Fails multiple tests of soundness

The inclusion of this wording is essential to ensure that the Eastbrook allocation is sound, effective, and compliant with national policy.

SECTION 10 - HOUSING DELIVERY AND

DEMOGRAPHIC MISALIGNMENT

While Section 4 of the review of the RLDP focuses on high-level data across the Vale, DPCC utilises these specific evidence base shifts to argue that the Eastbrook allocation is no longer justified under the new planning context. The Vale Council have removed S106 affordable housing money (£1m) from Dinas Powys, as we were told there are no housing developments planned and the funds were reallocated to Myrtle Close which negates the suggestion in the RLDP that there is a need for affordable housing in Dinas Powys. Therefore the development should be removed from the RLDP or the S106 moved back to Dinas Powys.

Mapping Section 4 Evidence to Dinas Powys Objections:

1. Review Report Ref: 4.1.1 4.1.11 (Population and Household Projections): Review Report Context: This section details the transition from 2011-based projections to the more recent 2018-based Welsh Government projections, noting a "significant departure" from the evidence that underpinned the original LDP.

Relationship to Dinas Powys: DPCC explicitly links this update to their objection in Ref: this response section 3.1 (Reduction in Overall Housing Numbers). We argue that the more realistic assessment of demographic trends and the subsequent reduction in the total housing requirement for the Vale should "reduce pressure on constrained settlements such as Dinas Powys". We maintain that with lower overall demand, the "unnecessary" and high-risk allocation at Eastbrook should be the first to be removed.

2. Review Report Ref: 4.2.1 - 4.2.15 (Economic Considerations and Employment): Review Report Context: This section reviews the employment land supply and economic growth scenarios for the 2021-2036 period. It lists major strategic employment sites, none of which are located within Dinas Powys.

Relationship to Dinas Powys: In the Preferred Strategy and subsequent objections, Dinas Powys is categorised as a Primary Settlement. DPCC points out that since the Review Report identifies economic and employment growth as being concentrated in the "Strategic Growth Area" (Barry, Rhoose, St Athan), allocating 250 houses in Dinas Powys creates a car-dependent commuter settlement. This contradicts the Review Report's emphasis on aligning housing with major employment hubs to reduce private car travel.

3. Review Report Ref: 4.3.1 (Conclusion on Evidence Base Changes): Review Report Context: The report concludes that the updated population, economic, and legislative evidence represents a "significant departure from that which informed the existing LDP" and supports the need for a full replacement plan.

Relationship to Dinas Powys: DPCC uses this conclusion to support their Ref: this response section 3.5 (Improved Evidence Base) objection. We argue that because the Vale Council's own Review Report acknowledges a "significant departure" in the evidence base, the Council must also acknowledge that the previous assumptions
regarding the deliverability of Eastbrook are now invalid. Specifically, they point to the "improved picture of constraints" (such as the 2020 flood event) that must be re- evaluated under the "robust and transparent" evidence standards called for in Section 4 of this response. Summary of Evidence Linkage: Section 4 of the Review Report provides the technical justification for a "Realistic assessment" of growth. DPCC's position is that if the Vale Council follows its own evidence in Section 4 - which shows lower housing need and a concentration of employment elsewhere - it cannot logically justify a large-scale housing development on a high-flood-risk greenfield site in a "constrained settlement" like Dinas Powys.

SECTION 11 - REQUIRED EVIDENCE FROM THE VALE OF GLAMORGAN COUNCIL

For the Eastbrook allocation to be considered sound, DPCC request that the Vale of Glamorgan Council must provide clear, transparent, and technically robust evidence demonstrating that the site is:

Deliverable Developable Environmentally acceptable Hydrologically safe Supported by adequate infrastructure

At present, this evidence is absent from the RLDP. The following items are required before the allocation can be considered sound.

11.1 Catchment-Wide Hydraulic Modelling

The Council must provide:

A full catchment-wide hydraulic model Prepared in consultation with NRW Covering surface water, groundwater, and overland flow Including climate-change allowances Assessing the 2020 flood event Demonstrating no increase in flood risk to existing properties

This modelling is essential to understand baseline conditions and the impact of development.

11.2 Groundwater Assessment

A detailed groundwater assessment is required to:

Map groundwater emergence zones Assess seasonal variations Identify groundwater pathways Determine the impact of development on groundwater levels Demonstrate that development will not exacerbate groundwater flooding

No such assessment has been provided.

11.3 Overland Flow Route Mapping

The Council must provide:

High-resolution mapping of overland flow routes Assessment of exceedance pathways Identification of downstream receptors

This is particularly important given the 2020 flood event.

11.4 SuDS Feasibility Study

A SuDS feasibility study must be provided to:

Assess infiltration potential Identify viable SuDS options Determine attenuation requirements Demonstrate that SuDS can operate effectively given soil and groundwater constraints

Without this, SuDS cannot be assumed to mitigate flood risk.

11.5 Downstream Drainage Capacity Assessment

The Council must provide:

A full assessment of downstream drainage capacity Identification of constraints Required upgrades Funding mechanisms Delivery timescales

This is essential to ensure that development does not overload existing systems.

11.6 Infrastructure Delivery Plan (IDP) Evidence

The IDP must demonstrate:

Education capacity solutions Healthcare capacity solutions Utilities upgrades Drainage improvements Highways mitigation Funding sources Delivery timescales Viability

At present, the IDP does not provide this level of detail.

11.7 Transport Assessment

A comprehensive transport assessment is required to: Assess cumulative impacts Model peak-time flows Identify junction constraints Provide deliverable mitigation Demonstrate that sustainable transport options exist No such assessment has been provided. 11.8 Landscape and Ecology Evidence

The Council must provide: A landscape and visual impact assessment A biodiversity net-gain strategy A green-infrastructure plan Evidence that ecological impacts can be mitigated These are essential to comply with national policy.
11.9 Summary

The RLDP currently lacks the evidence required to demonstrate that the Eastbrook allocation is: Safe Deliverable Environmentally acceptable Supported by adequate infrastructure Until this evidence is provided, the allocation remains unsound.

SECTION 12 — SCHEMATIC DIAGRAMS (ASCII + PLACEHOLDERS)

This section provides conceptual diagrams to support the hydrological and technical evidence presented earlier. These are illustrative only, not to scale, and intended to help the Inspector and Vale of Glamorgan officers visualise the key issues. Each diagram includes:

An ASCII sketch for immediate clarity A placeholder label for later replacement with a formal graphic in the final PDF

12.1 Diagram 1 — Catchment Overview (Placeholder: FIG-01)

Code [Higher Ground] /\ / \ / V V

Eastbrook Site (Low permeability I soils)

V [Downstream Residential Area]

Placeholder: FIG-01 - Catchment Overview Diagram

12.2 Diagram 2 - Overland Flow Routes (Placeholder: FIG-02)

Code Rainfall I V

Field <-- Overland flow entering site

V

Eastbrook Site Natural flow path I

V [Existing Properties]

Placeholder: FIG-02 - Overland Flow Route Mapping

3712.3 Diagram 3 — Groundwater Emergence Zones (Placeholder: FIG-03)

Code Subsurface Water Table

^ ^ ^ I (Groundwater emergence)

| Eastbrook Site I Saturated ground I

Placeholder: FIG-03 - Groundwater Emergence Conceptual Diagram

12.4 Diagram 4 - SuDS Limitations (Placeholder: FIG-04)

Code [Rainfall]

V [SuDS Basin]

I (Low infiltration) V [Standing Water] I V Risk of exceedance flow I V [Downstream Properties]

Placeholder: FIG-04 - SuDS Feasibility Constraints Diagram

12.5 Diagram 5 - Required Mitigation Sequence (Placeholder: FIG-05)

Code Step 1: Catchment-wide model I V Step 2: Identify mitigation I V Step 3: Secure funding & delivery

V Step 4: Construct mitigation | V Step 5: Only then permit development

Placeholder: FIG-05 - Mitigation Delivery Sequence Diagram

SECTION 13 — FORMAL REQUEST FOR WRITTEN CONFIRMATION FROM THE VALE OF GLAMORGAN COUNCIL

Given the significant unresolved constraints associated with the Eastbrook allocation, Dinas Powys Community Council formally requests written confirmation from the Vale of Glamorgan Council addressing the following matters. These confirmations are essential to demonstrate that the allocation is sound, deliverable, and compliant with national policy.

The Council requests that the Vale of Glamorgan provides a written response to each point below.

13.1 Confirmation of Catchment-Wide Modelling

Please confirm:

Whether a catchment-wide hydraulic model has been commissioned Whether NRW has been consulted on the scope Whether the model includes surface water, groundwater, and overland flow Whether the model assesses the 2020 flood event Whether the model demonstrates no increase in flood risk to existing properties

If no such model exists, please confirm:

When it will be commissioned When it will be completed Whether the RLDP will be updated to include its findings

13.2 Confirmation of Groundwater Assessment

Please confirm:

Whether a detailed groundwater assessment has been undertaken Whether groundwater emergence zones have been mapped Whether development will alter groundwater pathways Whether mitigation is technically feasible

If no assessment exists, please confirm when it will be prepared.

13.3 Confirmation of Overland Flow Route Mapping

Please confirm:

Whether high-resolution overland flow mapping has been completed Whether exceedance routes have been identified Whether these routes can be preserved within the development layout

If not, please confirm when this work will be undertaken.

13.4 Confirmation of SuDS Feasibility

Please confirm:

Whether infiltration testing has been undertaken Whether infiltration-based SuDS are viable Whether attenuation volumes have been calculated Whether SuDS can operate effectively given soil and groundwater constraints

If not, please confirm when a SuDS feasibility study will be completed.

13.5 Confirmation of Downstream Drainage Capacity

Please confirm:

Whether downstream drainage capacity has been assessed Whether upgrades are required How upgrades will be funded When upgrades will be delivered Whether upgrades will be delivered before development begins

If no assessment exists, please confirm when it will be undertaken.

13.6 Confirmation of Infrastructure Delivery

Please confirm:

How education capacity will be increased How healthcare capacity will be expanded How utilities and drainage upgrades will be funded How highways mitigation will be delivered Whether all required infrastructure is viable and deliverable within the plan period

If not, please confirm when the Infrastructure Delivery Plan will be updated.

13.7 Confirmation of Transport Assessment

Please confirm:

Whether a cumulative transport assessment has been undertaken Whether junction capacity constraints have been modelled Whether deliverable mitigation has been identified Whether sustainable transport improvements are committed and funded

If not, please confirm when this work will be completed.

13.8 Confirmation of Environmental and Landscape Evidence

Please confirm:

Whether a landscape and visual impact assessment has been prepared Whether a biodiversity net-gain strategy exists Whether a green-infrastructure plan has been completed Whether location-specific modelling to assess air quality, specifically, near schools at peak times has been undertaken.

If not, please confirm when these assessments will be undertaken.

13.9 Summary

The Vale of Glamorgan Council must provide written confirmation addressing each of the above points. Without this information, the Eastbrook allocation remains unsupported by evidence and therefore fails multiple tests of soundness.

13.10 Key objections

1. Procedural and Consultation Failures

Lack of Transparency: There is no evidence of formal record-keeping for public attendance at events or a transparent ledger showing how resident feedback was synthesized into the Plan.

Digital Barriers and Exclusion: The "online-first" strategy and complex account- creation process created a disproportionate burden for residents, particularly non-digitally native and elderly demographics who lacked accessible summaries.

Pre-determination: The requests, by DPCC, for more accessible scheduling were refused, leading to a perception that strategies were fixed prior to engaging public opinion.

When asked about the revised plans as stated in an email to DPCC we were told there were none. 2. Hydrology and Unresolved Flood Risk

The 2020 Flood Precedent: On December 23, 2020, a storm caused internal flooding to 98 properties in Dinas Powys. The Section 19 Flood Investigation Report confirmed "hydraulic locking" occurred, where elevated river levels prevented surface water systems from discharging, causing sewer surcharging.

Obsolete Evidence Base: The RLDP relies on a 2013 Strategy and a September 2020 NRW decision that predates the major 2020 flood. No catchment-wide modelling incorporating 2020 data has been undertaken.

SuDS Infeasibility: High groundwater (as shallow as 1.83m) and shallow bedrock render standard infiltration-based Sustainable Drainage Systems (SuDS) unproven and high-risk for this site.

3. Transport and Highways Constraints

Chronic Congestion: The A4055 (Cardiff Road) and Merrie Harrier junction are already at capacity. The Plan fails to assess the cumulative impact of major regional growth in Barry (376 units) and Penarth (576 units) on these local corridors.

Active Travel and Accessibility Failures: Eastbrook Station lacks bilateral access; residents with limited mobility or prams must undertake a one-mile detour to reach the Cardiff-bound platform because there is no lift.

Safety Issues: Existing pedestrian routes are too narrow for double buggies and are frequently obstructed by weekly refuse collections, forcing vulnerable pedestrians into the carriageway.

4. Exhausted Social and Utility Infrastructure

Healthcare Strain: The Dinas Powys Medical Centre is at full capacity with a list size of approximately 11,000 patients, far exceeding idealized UK GP-to- patient ratios.

Education Capacity: Local schools are operating at or near peak capacity with no identified land or funding for expansion.

Wastewater Capacity: There is no settlement-specific evidence that the consented capacity of local treatment works can accommodate 250 additional dwellings without risk of sewer surcharging.

5. Environmental and Ecological Impact

Irreplaceable Habitats: The site is adjacent to Ancient Woodland (Coed Clwyd-Gwyn and Case Hill Wood), which cannot be mitigated by new planting.

European Protected Sites: The HRA confirms the site is within 2.6km of the Severn Estuary SAC/SPA/Ramsar and explicitly concludes that "Mitigation is Required".

Air Quality: The Dinas Powys Roadside monitoring station was closed in 2016, and the Plan lacks location-specific modelling to assess the impact of increased peak-time idling near schools.

6. Housing Delivery and Demographic Misalignment Lack of Downsizing Options: Despite an aging population, the Plan contains no mandatory requirement for single-story bungalows, which are needed to free up family-sized housing stock. Affordable Housing Viability: The Community Council argues that high un- costed infrastructure burdens (flood and highway mitigation) make the 40% affordable housing target financially unviable.

S106 Transparency: £1M in S106 affordable housing funds from previous developments was diverted away from Dinas Powys because we were told there were no housing developments in Dinas Powys. Therefore the money has to be refunded or the 250 houses removed from the RLDP.

SECTION 14 — INITIAL E-MAIL FROM DPCC TO VALE OF GLAMORGAN COUNCIL (dated 29/01/2026)

The Local Development Team confirmed receipt of a formal email from Dinas Powys Community Council on 3 February 2026. This email was also sent to Senior Planning Officer, lan Robinson and CEO, Rob Thomas. It is appended below:

'Dear Sir / Madam,

Re: Formal Objection to the Proposed Allocation of Eastbrook (DNP-H1) in the Replacement Local Development Plan (RLDP)

Dinas Powys Community Council submits this formal objection to the proposed allocation of the Eastbrook site (SP4 KS2) within the Vale of Glamorgan Replacement Local Development Plan (RLDP). The Eastbrook allocation remains fundamentally flawed due to unresolved constraints relating to:

Flood risk and hydrology Highways and transport capacity Environmental and landscape impact Infrastructure limitations Deliverability and viability

The site lies within a hydrologically sensitive catchment characterised by groundwater emergence, overland flow routes, low-permeability soils, and a history of significant flood events, including the 2020 incident. Natural Resources Wales (NRW) has repeatedly raised concerns about flood risk at this location, and the Council's own evidence base acknowledges the need for catchment-wide modelling before any development can be considered.

The RLDP does not currently include:

Mandatory policy wording to secure pre-delivery of mitigation Requirements for catchment-wide modelling Guarantees that development will not increase flood risk elsewhere Evidence that mitigation is viable, deliverable, and enforceable

Without these safeguards, the allocation fails several tests of soundness, including CE2, CE3, and CE4.

Eastbrook in Dinas Powys is considered to be in a high-risk flood area. It is located within the catchment of the Cadoxton River and its tributary, the East Brook, which have a history of overflowing, causing significant, frequent flooding to homes and roads.

River and Surface Water Flooding: The area experiences flooding from the East Brook and the River Cadoxton. Intense rainfall can also overwhelm the surface water and sewerage systems, causing additional property flooding.

High Water Levels: The ground in the area, particularly in fields adjacent to existing properties, is often described as "totally waterlogged" for significant portions of the year, indicating a high- water table.

Key details regarding flood risk in this area include: High Risk Area: Natural Resources Wales (NRW) has identified a significant risk of flooding from the Cadoxton River and East Brook, affecting areas like St Cadocs Avenue, Greenfield Avenue, Elm Grove Place, and Cardiff Road.

Significant History: The area has experienced multiple flooding events, including major incidents in 1948, 1986, 1998, 1999, 2008, 2012, 2013, and a severe event in December 2020 where approximately 40-100+ properties were affected.

Future Risk: Due to climate change, the number of properties at risk of flooding in the area is expected to increase from nearly 200 to over 350 by 2117.

Causes: The area suffers from rapid runoff from the surrounding hillsides, which overwhelms the capacity of the river channels and drains. NRW has been exploring options for a flood management scheme, including natural flood management and potential engineering solutions, to reduce the risk to the community. It is recommended to check the specific, up-to-date flood map for any particular property on the NRW website.

The Dinas Powys Community Council formally requests written confirmation from the Vale of Glamorgan Council addressing the following matters:

1. Has a catchment-wide hydraulic model has been commissioned, completed, and agreed with NRW? If so, does the model demonstrate no increase in flood risk to existing properties? 2. Have groundwater emergence, overland flow routes, and the 2020 flood event have been assessed? 3. Are SuDS viable given soil and groundwater constraints? 4. Has downstream drainage capacity been assessed and, if necessary, upgraded? 5. Will education, healthcare, utilities, and highways infrastructure be expanded to support the allocation? a) Has consultation taken place with the GP surgery/Local schools? b) What additional services will be provided? 6. Have deliverable and funded mitigation for transport and highways impacts been identified? a) Please provide figures of air pollution and traffic flow surveys along Cardiff Road. What is the capacity along Cardiff Road? b) Department of transport will not be investing in Eastbrook station. Therefore, no lift/ramp to address the needs of the community. Yet it is being used to form a decision about the housing. Please explain the reason behind this?

7. Have landscape, biodiversity, and green-infrastructure assessments been completed? a) Apparently the placemaking workshop has helped refine proposals. What are the refinements and when can we see the results from the surveys people completed at the Murchfield consultation?

In the opinion of Dinas Powys Community Council these confirmations are essential to demonstrate that the allocation is sound and that development will not increase flood risk or place unacceptable pressure on local infrastructure.

The Vale Council state that millions of pounds of Dinas Powys S106 funding could be moved to Myrtle Close in Penarth as 'there are no developments' in Dinas Powys. If this is the case Eastbrook needs to be removed from the RLDP or the money should stay allocated to Dinas Powys.

The Vale Council allocated 900-1500 houses for Argae lane. But once the site was considered not viable the figures were reviewed and they were reduced in number and moved to another site.

Where is the evidence that 250 houses are needed in Eastbrook? The Eastbrook site was turned down before. Why? What has changed to make it viable now? Have the Vale Council exhausted all the key sites outlined in the previous LDP and if not why? Have the Vale Council used all of their rolled forward housing sites? Have the Vale Council carried out a Sequential Test? Proving there are no lower risk sites available? Has the Exception test been carried out? Ensuring the development will be made safe throughout its lifetime without increasing floor risks elsewhere? Out of the 250 houses 40% will be affordable housing. Managed by housing associations according to Persimmon glossy proposal. What is classed as affordable housing? Birth rate has fallen for a number of years, and the elderly population is increasing. How do you justify these figures? What proportion of the proposed 250 houses will be age friendly?

In the appendix to the Homes and Safe Communities Scrutiny Committee report (6th January 2024), there is a comment regarding the need for bungalows. Residents and councillors enquired about bungalows enabling people to downsize and free up family homes. We were told they are providing what the Vale has requested. We met with housing and they said, 'it won't happen'. So knowing there is a need for elderly accommodation what is the plan to address this need?

By 2034, 1 in 4 will be over the age of 65. This is an increase of 75% from 9.3% in 2018 to 13.7% in 2038.

The Vale indicates 70% of the housing need is in Barry/Penarth and Llandough. Of the remaining 30% what percentage is allocated to Dinas Powys? You state greatest areas of demand are Penarth/Barry and Llandough but there is no mention of Dinas Powys.

In conclusion, in the absence of the required evidence and mandatory policy safeguards, the Eastbrook allocation remains unsound. The Dinas Powys Community Council therefore requests that the Vale of Glamorgan Council: Removes the Eastbrook allocation from the RLDP, or Incorporates the mandatory policy wording and evidence requirements set out above. We look forward to receiving your written response. Yours faithfully, Clerk on behalf of Dinas Powys Community Council'

SECTION 15 — CONCLUSION OF THE

TECHNICAL OBJECTION

Dinas Powys Community Council recognises the importance of delivering sustainable, well-planned growth across the Vale of Glamorgan. The revised RLDP contains some positive and constructive changes, and the Council welcomes the improved emphasis on sustainability, climate resilience, and infrastructure capacity. However, despite these improvements, the proposed allocation of the Eastbrook site (HG1 - KS2) remains fundamentally unsound.

The evidence presented in this objection demonstrates that:

The site lies within a highly sensitive hydrological catchment Flood risk is influenced by surface water, groundwater, and overland flow The 2020 flood event provides clear evidence of the site's vulnerability NRW has repeatedly raised concerns that have not been resolved No catchment-wide hydraulic modelling has been undertaken SuDS feasibility is unproven due to soil and groundwater constraints Downstream drainage capacity has not been assessed Transport and highways impacts remain unmitigated Education, healthcare, and utilities infrastructure are already under pressure No evidence demonstrates that required mitigation is viable, fundable, or deliverable The RLDP lacks mandatory policy wording needed to secure mitigation and ensure no increase in flood risk elsewhere

As a result, the allocation fails multiple tests of soundness, including:

CE2 - Coherence and effectiveness CE3 - Environmental protection CE4 - Deliverability

Until the Vale of Glamorgan Council provides the required evidence and incorporates the mandatory policy wording set out in this document, the Eastbrook allocation cannot be considered sound. The Dinas Powys Community Council therefore respectfully requests that the Vale of Glamorgan Council:

1. Removes the Eastbrook allocation from the RLDP, or 2. Incorporates the mandatory policy wording, evidence requirements, and safeguards detailed in this objection

Failure to address these issues will leave the RLDP vulnerable to challenge at Examination and may result in development that increases flood risk to existing residents, places unacceptable pressure on local infrastructure, and undermines the environmental quality of Dinas Powys.

Dinas Powys Community Council remains committed to constructive engagement and looks forward to receiving the Vale of Glamorgan Council's written response to the matters raised.