Include policies to safeguard land and encourage food production especially horticulture - recognising the need for encouragement for small scale food production farms which add to food security and enhance biodiversity.

SF&G recognise the importance of green wedges and other countryside land, for food production and suggest safeguarding land accordingly, aligned with housing growth. Our communities face challenges like poor health, climate change, and inequality, with a fragile food system vulnerable to shocks. The Welsh Government Community Food Strategy (2025) aims to develop diverse local food networks that work with nature not against it. Supportive policies are needed for small-scale horticultural farms to enable essential infrastructure, moving away from strict scrutiny and towards recognising genuinely necessary structures for agriculture, ensuring resilient and sustainable local food businesses.

Due to the outdated nature of TAN 6 it is incumbent on local authorities to include more up to date policy in their local development plans.
We know Wales is not producing enough fruit and vegetables to feed ourselves in the future when we are likely to need it. see here - https://www.wcpp.org.uk/wp-content/uploads/2023/07/How-could-Wales-feed-itself-in-2035.pdf. Social Farms & Gardens is very concerned that Technical Advice Note 6 – Planning for Sustainable Rural Communities is considerably out of date (July 2010) and no longer delivering sustainable rural communities. It therefore falls on local authorities delivering replacement local development plan, to consider the latest evidence, trends, previous decisions and other written approaches. The Practice Guidance on Rural Enterprise Dwellings, although only considered an exemplar approach, has the potential to be used too prescriptively and in a way that is out of line with the needs of our rural economy and communities, especially given the climate and nature emergencies that have been declared.
We ask the Vale of Glamorgan Council to consider adopting planning guidance on Rural Enterprise Dwellings for horticulture - like Powys Council have done. see here - https://en.powys.gov.uk/article/16407/Rural-Enterprise-Dwellings-for-Small-Scale-Horticulture. This guidance can be more or less copied from Powys version like Bannau Brynchieniog have done. Therefore it is important that the RLDP provides positive wording in policies to encourage development in association horticultural enterprises including rural enterprise dwellings. We have an abundance of of evidence to support this approach and would be keen to collaborate on any potential wording or approaches.

Provide additional or amended Planning policies [either free standing or within SP3 or HG5] to allow for single unit/micro development, by companies or individuals, of
appropriate, affordable housing units within all communities including ‘Hamlets and Smaller Rural Settlements’ [in the Countryside] where this is supported by the local community and meets the requirements of SSC1.

These new/amended policy statements [alongside the existing requirements of SSC1 and HG5] could then be applied across all existing settlements and communities
currently classified as undefined ‘Hamlets and Smaller Rural Settlements’ and hence ‘Countryside’ to allow for controlled appropriate development of affordable homes to
meet the aspirations of Para 5.24. and the local Community.

Provide additional or amended Planning policies [either free standing or within SP3 or HG5] to allow for single unit/micro development, by companies or individuals, of
appropriate, affordable housing units within all communities including ‘Hamlets and Smaller Rural Settlements’ [in the Countryside] where this is supported by the local community and meets the requirements of SSC1.

These new/amended policy statements [alongside the existing requirements of SSC1 and HG5] could then be applied across all existing settlements and communities
currently classified as undefined ‘Hamlets and Smaller Rural Settlements’ and hence ‘Countryside’ to allow for controlled appropriate development of affordable homes to
meet the aspirations of Para 5.24. and the local Community.

We would like to thank you for consulting with South Wales Police in respect of the Replacement Local Development Plan 2021 to 2036.
We welcome working with The Vale of Glamorgan Council in respect of The Vale of Glamorgan Replacement Local Development Plan 2021 – 2036: Deposit Plan to ensure the future needs and community safety is addressed within the plan and supporting documents.
We would respectfully ask that our comments are taken into consideration, and included in the plan, and that we can work in partnership to develop the specific planning guidance documents mentioned below.
The replacement development plan outlines its Vision and objectives of the RLDP as follows:
‘By 2036’:
The Vale of Glamorgan is a healthy and inclusive place for everyone, with equitable access to services and facilities both physically and digitally. Residents are proud of where they live and have access to the homes they need. Housing growth has delivered homes which caters for all, including affordable homes and older person’s housing; contributing towards diverse and cohesive communities where residents can maintain their independence.
Through placemaking, places and spaces are safe, accessible and socially inclusive. Development respects local character and sense of place is valued by residents and contributes positively towards health and wellbeing. Positive improvements have been achieved in narrowing the disparities in Integrated Sustainability Appraisal (ISA) for the Replacement Local Development Plan Prepared for: Vale of Glamorgan Council AECOM 5 the quality of life and health outcomes for residents living in the most deprived areas through improved access to employment, education, training, services, and investment in the built environment.
The Vale enjoys a network of connected, multi-functional and accessible green and blue spaces, providing a range of enhanced leisure and health benefits within and between towns, villages, and the countryside. More residents participate in active and healthy lifestyles. Investment in green infrastructure has produced a net biodiversity benefit with the creation of new habitats, enhanced connectivity and Planting providing carbon storage and contributing towards Climate Change resilience and adaptation.
Objectives:
1. Mitigating and adapting to climate change
2. Improving mental and physical health and well-being
3. Homes for all
4. Placemaking
5. Protecting and enhancing the natural environment
Policies that support the role of a Designing Out Crime Officer and Secured by Design are as follows:
Secured by Design (SBD) is the official police security initiative that works to improve the security of buildings and their immediate surroundings to provide safe places to live, work, shop, and visit.
Planning Policy Wales (PPW) states that crime and prevention and fear of crime are social considerations to which regard must be given by local planning authorities in the preparation of development plans. They should be reflected in any supplementary planning guidance and may be material considerations in the determination of planning applications. The aim should be to produce safe environments through good design.
Technical Advice Note (TAN) 12: Design, provides advice for all those involved in the design of development on how good sustainable design can be facilitated through the planning system. TAN 12 reminds practitioners that local authorities (including National Park Authorities) are required to have due regard to crime and disorder prevention in the exercise of their functions under Section 17 of the Crime and Disorder Act 1998.
TAN 12 recognises the Secured by Design initiative as a standard that has been shown to reduce crime.
TAN 12, paragraph states that ‘Local authorities are advised to consult Designing out Crime Officers on pre-applications and planning applications for those developments where there is potential to eliminate or reduce crime through the adoption of suitable measures at the design stage. This is especially important for major developments such as new housing estates, industrial estates, shopping centres, leisure complexes, schools, and car parks. It is important to consult Designing out Crime Officers at as early stage as possible – by the time a formal application is submitted, the opportunity to take account of advice may already be limited.’
Section 17 of the Crime and Disorder Act 1988 requires local authorities to consider crime and disorder implications in all their authorities and functions and do all that they reasonably can do all they can do to reduce these problems.
Violence against women and Girls:
Crime has a major impact on people’s lives in the Vale of Glamorgan and impacts on the health of the public especially those who have been victims of crime and anti-social behaviour and vulnerable groups such as Women and Girls.
In spring 2023, the Home Secretary announced Violence Against Women and Girls as a national threat and included it within the 9 Strategic Policing Requirement (SPR) alongside terrorism, serious and organised crime, and child sexual abuse.
Secured by Design can assist with ensuring that the built environment in all its forms is designed to reduce the opportunity of Violence Against Women and Girls (VAWG) and contribute to such places feeling safe, to live, work and socialise, for all. The importance of this is outlined within the National Police Chiefs’ Council’s (NPCC) ‘Policing Violence Against Women and Girls – The National Framework for Delivery: 2024 – 2027’ under the ‘Prevent’ element of the strategy; outlining the need for building safer spaces and places. Further information is available at: https://www.npcc.police.uk/SysSiteAssets/media/downloads/our-work/vawg/vawg-framework-fordelivery.pdf
In Wales, planning is devolved. Planning Policy Wales and Future Wales: The National Plan 2040 set out the Welsh Government’s national planning policy, where new developments are proposed. Planning Policy Wales explains: “A clear rationale behind the design decisions made […] should be sought throughout the development process and expressed, when appropriate, in a design and access statement.”
76 The guidance for design and access statements for Wales categorises five key objectives of good design (Access, Character, Community Safety, Environmental Sustainability and Movement) and explains how meeting these objectives should ensure that both design quality and inclusive access are given sufficient consideration in the planning process.
77 Design and access statements have been required in Wales for many planning applications since 2009 and have been part of legislative requirements since the Planning (Wales) Act 2015.
The Angiolini Inquiry Part 2 First Report: Prevention of sexually motivated crimes against women in public Ordered by the House of Commons to be printed on 2 December
In Wales, local authorities are under legal obligation to consider and address crime while in the process of planning: “Local authorities [in Wales] are under a legal obligation to consider the need to prevent and reduce crime and disorder in all decisions that they take. Crime prevention and fear of crime are social considerations to which regard should be given in the preparation of development plans and taking planning decisions. The aim should be to produce safe environments that do not compromise on design quality in accordance with the cohesive communities’ wellbeing goal.”
The Inquiry considers that there would be an opportunity to place a greater focus on preventing sexually motivated crimes against women in public spaces if this priority were reflected in planning guidance and principles.
For instance, neither the English nor the Welsh documentation contains specific reference to considering how design can help prevent violence against women in public spaces. The Inquiry saw evidence of this being discussed: “Under public spaces in the National Model Design Guide it mentioned well located, attractive public spaces. But there is no mention of violence against women and girls. There is minimal mention of crime reduction, just that amenity spaces should make people feel safe, help overcome crime, reduce the fear of crime.”
The Terrorism (protection of premises)Act 2025 (Martyn’s Law)
This Act became legislation on the 3rd of April 2025. This legislation is to improve protective security and preparedness across the United Kingdom for certain premises.
South Wales Police and Counter Terrorism Policing Wales would ask that where this legislation applies that early consultation takes place with the Designing out crime officers and Counter Terrorism Policing Wales.
If a premises falls within the scope of the The Terrorism (Protection of Premises) Act 2025, the development plans should be referred to South Wales Police Designing Out Crime Officers who will in turn will take advice from Counter Terrorism Policing Wales. This consultation should take place at the pre planning stage.
Standard Tier- will drive good preparedness outcomes. Locations with a maximum occupancy of greater than two hundred people will be required to have appropriate public protection procedures in place to ensure effective protective security and preparedness if an act of terrorism were to occur in their premises or immediate vicinity.
Enhanced Tier- focused on high-capacity locations in recognition of the potential consequences of a successful attack. Locations with an occupancy of eight hundred plus at any time will be required to have in place as reasonably practicable, appropriate public protection procedures and measures that can be expected to reduce the vulnerability of the premises, and the risk of physical harm being caused to individuals if an attack was to occur there or nearby.
Premises will fall within scope of The Terrorism (protection of premises)Act 2025 where “qualifying activities” take place. This will include activities such as entertainment, leisure, retail, food and drink, museums and galleries, sports grounds, public areas of local and central Government buildings (e.g. town halls), visitor attractions, temporary events, Places of Worship, health, and education.
The legislation applies to eligible locations which are either: a building (including collections of buildings used for the same purposes, e.g. a campus); or location/event (including a temporary event) that has a defined boundary, allowing capacity to be known. Eligible locations whose maximum occupancy meets the above specified thresholds will be then drawn into the relevant tier.
Public Spaces:
It should be borne in mind that the development of public spaces which are either owned, managed or they have influence over should also include protected security and preparedness at the concept stage of the planning process.
South Wales Police recommendations:
Our recommendations are set out below in relation the objectives and specifically to preventing crime and disorder and enhancing community safety:
1. Mitigating and adapting to climate change Secured by Design Residential Guide 2025 states:
Crime committed in 2011 in England and Wales is estimated to have given rise to over 4 million tonnes CO2e, equivalent to emissions of around 900,000 UK homes. Burglary resulted in the largest proportion of the total footprint (30%) due to large volume of offences and the carbon associated with replacing stolen or damaged goods.
Source: “Addressing the Carbon-Crime Blind Spot - A Carbon Footprint Approach” (2016). Helen Skudder, Professor Angela Druckman, Jon Cole, Alan McInnes, Dr Ian Brunton-Smith, Dr Gian Paolo Ansalon.
Secured by Design states ‘The environmental benefits of SBD are supported by independent academic research consistently proving that SBD housing developments experience up to 87% less burglary, 25% less vehicle crime and 25% less criminal damage (Note 1.5). It also has a significant impact on anti-social behaviour.
Therefore, there are substantial carbon cost savings associated with building new homes and refurbishing existing homes to the SBD standard i.e. less replacement of poor-quality doors, windows and the stolen property from within the home as a result of criminal acts. This has been achieved through adherence to well-researched and effective design solutions, innovative and creative product design coupled with robust manufacturing standards.’
Research documentation can be found on the SBD website at: https://www.securedbydesign.come
Recommendations:
• SP 6 - Ensure early consultation with the Designing Out Crime Officer and to achieve Secured by Design on all new developments and refurbishments.
• CC5 - Heat Networks – Advice should be sought from the Designing Out Crime officer to ensure the safe placement of heat pump devices.
• CC5 – Consultation should take place with the Designing Out Crime Officer in respect of wind or solar farms, so Secured by Design can be achieved.
• DNP7 – DARK SKIES – Secured by Design can assist with ensuring that the built environment in all its forms is designed to reduce the opportunity of Violence Against Women and Girls (VAWG) and contribute to such places feeling safe, to live, work and socialise. South Wales Police would ask that Designing Out Crime Officers are involved at the pre planning stage to discuss and be able to make recommendations in relation to lighting.
Reason: To reduce the carbon footprint of development.
2. Improving mental and physical health and well-being
• PGD1 – Creating well designed and inclusive places states:
Development must demonstrate that the following:
Ensuring no unacceptable impacts on public and residential amenity, particularly regarding privacy, overbearing, security, noise and disturbance
Ensuring that public open space, private amenity space and cycle and car parking in accordance with the Council’s standards.
Secured by Design Residential Guide states:
Poorly designed and specified public realm and communal areas, such as playgrounds, roof gardens, communal gardens, community dining rooms, toddler play areas, seating facilities have the potential to generate crime, the fear of crime and anti-social behaviour.
The design and layout of play spaces will vary depending on the age requirements. The provision of inclusively designed public amenity/play spaces as an integral part of residential developments, should make a valuable contribution towards the quality of the development and the character of the neighbourhood.
Recommendations:
• PGD 1 - Facilities shall be designed to allow natural surveillance from nearby dwellings with safe and accessible routes for users to come and go. Boundaries between public and private space shall be clearly defined and open spaces must have features which prevent unauthorised vehicular access. Communal spaces as described above should not immediately abut residential buildings.
• SP 5 - South Wales Police would recommend that all new public space is designed to Secured by Design standards (Residential) Guide. Use the ‘Safer Parks’ document (research by ‘Make Space for Girls’) to design safe communal spaces. Designing Out Crime officers should be consulted at pre planning stage to give their recommendations for communal space.
Reason: To enhance community safety and prevent antisocial behaviour.
3. Homes for all
Policy 7- Delivering Affordable Homes
The Vale of Glamorgan Housing Strategy 2021-2026
The strategy includes a long-term vision for housing in the Vale where “All residents in the Vale of Glamorgan have access to good quality, suitable housing and can live happily and independently in vibrant, sustainable communities.”
• Aim 1: More Homes, More Choice.
• Aim 2: Improved homes and communities.
• Aim 3: Better housing advice and support.
• Aim 4: Equality of access to housing and housing services.
‘The Vale has a significant need for affordable homes, with affordable housing need remaining one of the highest in Wales, even though the Vale is one of highest performing authorities in Wales in terms of affordable housing delivery. Using the principal projections, the Council’s 2023 Local Housing Market Assessment (LHMA)
identifies a need for 1,075 affordable homes per annum over the 5-year period 2023-2028 and 154 affordable homes per annum for the following 10 years.’
Ensure 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. This includes homes that are affordable, accessible and adaptable for people of all ages and that address the identified accommodation needs of all the Vale’s communities through all stages of life.
The Vale of Glamorgan Older Persons Housing Strategy
2.84 The Council’s Older Persons Housing Strategy ‘Creating Homes and Neighbourhoods for Later Life 2022-2036’ sets out a vision for the Vale of Glamorgan which seeks: ‘to secure the best quality of life for older people to live as independently as possible in later life. This means delivering a range of accommodation that enables older people to live fulfilling lives and enjoy good health in attractive homes that meet their needs and allow them to retain their independence as they age.”
All Welsh Government grant funded housing refurbishments must comply with the Development Quality Requirement (DQR) and achieve Secured by Design Silver award.
South Wales Police would ask that all new developments are designed and built to Secured by Design standards this includes roads, paths, lighting, defensible space and house types/ standards. We would ask that at the pre planning advice is sought from the Designing Out Crime Officer to advise on crime prevention through environmental design.
Violence Against Women and Girls:
The harm caused to victims and society by violence against women and girls (VAWG) in all its forms, including but not limited to, harassment, stalking, rape, sexual assault, murder, honour-based abuse and coercive control is incalculable. While men and boys also suffer from many of these forms of abuse, they disproportionately affect women.
In spring 2023, the Home Secretary announced Violence Against Women and Girls as a national threat and included it within the 9 Strategic Policing Requirement (SPR) alongside terrorism, serious and organised crime, and child sexual abuse.
Secured by Design can assist with ensuring that the built environment in all its forms is designed to reduce the opportunity of Violence Against Women and Girls (VAWG) and contribute to such places feeling safe, to live, work and socialise, for all. The importance of this is outlined within the National Police Chiefs’ Council’s (NPCC) ‘Policing Violence Against Women and Girls – The National Framework for Delivery: 2024 – 2027’ under the ‘Prevent’ element of the strategy; outlining the need for building safer spaces and places. Further information is available at:
https://www.npcc.police.uk/SysSiteAssets/media/downloads/our-work/vawg/vawg-framework-fordelivery.pdf
South Wales Police recommendations:
• SP 6 - All Welsh Government grant funded homes MUST meet Secured by Design Gold or in the case of a refurbishment Silver. Consultation with the Designing Out crime Officer should take place at the pre planning stage when an application for Secured by Design should also be made.
• SP6 - HOUSING REQUIREMENT - Where a change of use/ mixed use retail, community leisure and active travel routes are planned Secured by Design Residential and Commercial guides should be applied. Early consultation with Designing out crime officers particularly in the Town Centres is recommended.
• SP6 - HOUSING REQUIREMENT - Designing Out Crime Officers should be consulted at the concept stage of a development, where there are 10 or more housing units and in the case of commercial space 1000 square metres.
• SP6/ HG 7 - HOUSING REQUIREMENT - South Wales Police Designing Out Crime Officers to work in partnership with the Vale of Glamorgan Council Planning Department to compile a specific planning guidance in relation to Houses of multiple occupancy.
• SP6 - HOUSING REQUIREMENT- South Wales Police would ask that all flats/ apartments’ conversions meet WDQR (Welsh Design Quality Standards) and achieve at least a Secured by Design silver award.
• SP6 - Housing Requirement - In the case of the change of use of residential land or properties, South Wales Police would ask that any change of use application is sent to South Wales Police Designing out crime officers.
• SP 6 - South Wales Police are involved in discussion with the Vale of Glamorgan Planning Department and the compilation of Specific planning guidance to cover co-living and similar shared facility developments.
• SP6 - HOUSING REQUIREMENT -Where co- living developments are proposed to deliver a balanced housing mix. South Wales Police would ask that the pre planning discussions take place with the Designing Out Crime officer and that the development is built to Secured by Design standards as set out in the most current Secured by Design Residential Guide.
• SP3 – DEVELOPMENT IN THE COUNTRYSIDE (Policy GT1/ SP9 – Gypsy and Traveller Site Provision). The site is reasonably accessible to essential services and facilities such as healthcare, education, employment, and public transport. Safe and appropriate vehicular access can be provided from the highway network, and the site layout affords adequate provision for parking, turning, servicing and emergency vehicle. South Wales Police would ask that they consulted to provide Secured by Design advice at the pre planning stage of any such development.
• HG6 – PROVISION OF SPECIALIST ACCOMMODATION
The accommodation is appropriately designed to meet the specific needs of the intended residents, including older people, people with disabilities, those with mental health needs, and other vulnerable groups. The development is located in an accessible and sustainable location, with good access to public transport, community facilities, health services, and local amenities –
-All specialist housing is built to Secured by Design and South Wales Police are involved at the pre planning stage of specialist developments.
• The Vale of Glamorgan Older Persons Housing Strategy:
‘To secure the best quality of life for older people to live as independently as possible in later life. This means delivering a range of accommodation that enables older people to live fulfilling lives and enjoy good health in attractive homes that meet their needs and allow them to retain their independence as they age.”
HG 6 - All older person’s housing to be built to Secured by Design standards and pre application consultation with Designing Out Crime Officers.
• HG7 - HOUSES IN MULTIPLE OCCUPATION (HMO’s)
South Wales Police would ask that they work in partnership with The Vale of Glamorgan Planning Department, to develop a specific planning Guidance in relation to Houses of Multiple Occupancy.
• SP3 - Development in the Countryside Affordable Housing (Policy HG5) – Consultation takes place. Where, developments are planned outside the specific main areas South Wales Police would ask that they are consulted about the proposed infrastructure and design of such developments. - Early consultation is recommended with Designing Out Crime officers and South Wales Police Traffic Management.
• PGD 2 /SP 4 - ‘Ensure major new development is directed to locations that are or will be by the time of initial occupation easily accessible by walking, cycling, and public transport.’- Early consultation with South Wales Police Designing Out Crime Officers and South Wales Police Road Traffic Management Department where roads and pathways are planned to be built.
• SP5 – Creating Healthy and Inclusive Places and spaces: Ensuring development proposals are designed to facilitate accessible healthy environments to address relevant determinants of health positively, particularly in response to local health needs; • Ensuring that all places and developments are as inclusive as possible, capable of adapting to a broad range of changing needs and delivering a high quality of life. – Designing Out Crime Officers are consulted at pre planning to ensure public space is designed to ensure the space is safe and inclusive for all and especially vulnerable groups. (Safer Parks Document, Angelini Enquiry).
• SP 4 - Supporting the provision of new and enhanced community and healthcare facilities: Where Health care facilities are proposed South Wales Police would ask that Secured by Design Commercial Guide /Hospitals Guide are followed and that the Designing Out Crime officer is consulted at the pre planning stage.
• SP19 – Waste management: Secured by Design guides give guidance in respect of waste management and storage. South Wales Police would ask that pre Planning advice is sought in respect of new developments and waste management.
Reason: To enhance community safety especially vulnerable groups.
4. Placemaking and Good Design
Future Wales - The National Plan 2040 (Welsh Government, February 2021)
Policy 2 - Shaping Urban Growth and Regeneration - Strategic Placemaking
The Placemaking Charter and Placemaking Plans:
Signatories to the Charter agree to promote the following principles in the planning, design and management of new and existing places:
• People and community.
• Location.
• Movement.
• Mix of uses.
• Public Realm
• Identity.
SP4 – PLACEMAKING
Development will be required to follow Placemaking principles by:
1 Ensuring high quality sustainable design that reflects local distinctiveness, character, and cultural identity.
2 Prioritising the determinants of health and well-being during the design process.
3 Creating a diverse mix of uses and multi-functional spaces.
4 Contributing to a vibrant, safe and inclusive public realm that encourages Active Travel, supports public transport use and reduces car dependency.
5 Strategically integrating Green Infrastructure networks and open space into development, delivering social, environmental and ecological benefits.
6 Providing a range of housing types and tenure.
7 Locating development appropriately where homes, local services and facilities are accessible and well connected and integrated with existing communities.
8 Developing high densities where appropriate, making the most efficient use of land and supporting mixed uses.
9 Protecting or enhancing the Historic Environment and its setting. Placemaking Statements will be required for all major developments setting out how the proposal accords with Placemaking Principles. In the towns of Barry, Cowbridge, Llantwit Major and Penarth Placemaking Statements should also have regard to the adopted Placemaking Plans for the area.
Designing Out Crime officers’ recommendations:
• SP 4 / PGD 1/ CC 4 - Research shows that Secured by Design developments are sustainable and reduce the carbon footprint. The environmental benefits of SBD are supported by independent academic research consistently proving that SBD housing developments experience up to 87% less burglary, 25% less vehicle crime and 25% less criminal damage It also has a significant impact on anti-social behaviour. South Wales Police ask that all new developments are built to Secured by Design standards and that they are work with The Vale of Glamorgan planning Department at the pre planning stage.
• SP 4 / PGD 1 -When designing developments road, paths and green space, South Wales Police would ask that the developments are built to Secured by Design standards. We would ask that Designing Out Crime Officers and South Wales Police Traffic Management Department are involved in the pre planning stage.
• PGD 2 /SP 4 - It is important when designing roads and footpaths to maximise the benefits of passive surveillance, and furthermore, when addressing safety and security of street layouts, public realm, and footpaths, that Secured by Design guidance is followed, this includes landscape design, lighting, layout of buildings, etc. to ensure that all roads and footpaths (including public rights of way) are safe, secure, and accessible for all, in support of the Violence Against Women and Girls (VAWG) agenda. Where a mix development e.g. housing and retail/other use (with ten or more units) applications should be referred the designing out crime at the pre planning stage.
• SP4/ PGD1 - Contributing to a vibrant, safe and inclusive public realm - Where active travel routes are being planned, South Wales Police Traffic Management Team should be consulted throughout the planning process.
• PGD1- Ensuring no unacceptable impacts on public and residential amenity, particularly regarding privacy, overbearing, security, noise and disturbance. Secured by Design considers natural surveillance and the placing of communal spaces and provision provided. All mixed uses and multi-functional) developments should be discussed at the pre- planning stage with the Designing Out Crime Officer.
• PGD 2/ SP 4 - Developing high densities where appropriate, making the most efficient use of land and supporting mixed uses. Work in partnership with Designing out crime officers to write a ‘Houses of multiple occupancy’ Specific Planning Guidance.
• SP 4 - Strategically integrating Green Infrastructure networks and open space into development, delivering social, environmental and ecological benefits. Where public realm is being planned to include active travel routes, designing out crime officers and Counter Terrorism Security Advisors should be consulted if the space falls under The Terrorism (protection of premises)Act 2025 .
• SP 4 -When planning parks and community space. Public consultation should took place, and the plans referred to the designing out crime officer. (The ‘Safer Parks’ research by Making space for women is a document that can offer up to date advice in relation to safety/ and inclusivity).
• SP 1- When designing new schools early consultation with the South Wales Police Designing out crime officer and Traffic Management officers is prudent to ensure the safety of pupils. Achieving Secured By Design accreditation for the school will ensure that the school is planned and built with safety in mind from the outset. All schools should achieve SBD GOLD.
• HG 6 - The Vale of Glamorgan Older Persons Housing Strategy 2.84 The Council’s Older Persons Housing Strategy ‘Creating Homes and Neighbourhoods for Later Life 2022-2036’ sets out a vision for the Vale of Glamorgan which seeks: ‘to secure the best quality of life for older people to live as independently as possible in later life. This means delivering a range of accommodation that enables older people to live fulfilling lives and enjoy good health in attractive homes that meet their needs and allow them to retain their independence as they age.”
• The Vale of Glamorgan Older Persons Housing Strategy 2.84 The Council’s Older Persons Housing Strategy ‘Creating Homes and Neighbourhoods for Later Life 2022-2036’ sets out a vision for the Vale of Glamorgan which seeks: ‘to secure the best quality of life for older people to live as independently as possible in later life. This means delivering a range of accommodation that enables older people to live fulfilling lives and enjoy good health in attractive homes that meet their needs and allow them to retain their independence as they age.” - Developments, for older residents are built to Secured by Design standards as per the Secured by Design Residential Guide.
• SP4 - Protecting or enhancing the Historic Environment and its setting: Secured by Design can be applied to historic building, contact should be made at the pre planning with the Designing Out Crime Officer.
• PGD1- Creating safe, accessible, integrated, inclusive and active environments that make efficient use of land and promote opportunities for Active Travel, and promote sustainable transport choices – Early liaison with South Wales Police and South Wales Police Traffic Management Officers so that designs can be agreed and are safe.
• SP 1 - A number of new primary and secondary schools have been developed across the Vale as part of the Sustainable Communities for Learning Programme (previously known as 21st Century Schools), with further plans as part of the programme progressing – Consultation should be sought from South Wales Police Designing Out Crime Officers and Road Traffic Management Officers at the pre planning stage planning stage with the Vale of Glamorgan Council.
• PGD 1 Incorporating sustainable design and construction solutions to maximise energy efficiency and positively contributing towards climate change resilience and adaptation. The environmental benefits of SBD are supported by independent academic research consistently proving that SBD housing developments experience up to 87% less burglary, 25% less vehicle crime and 25% less criminal damage (Note 1.5). It also has a significant impact on anti-social behaviour. Therefore, there are substantial carbon cost savings associated with building new homes and refurbishing existing homes to the SBD standard i.e. less replacement of poor-quality doors, windows and the stolen property from within the home as a result of criminal acts. - All developments are built to secured by Design to reduce the carbon footprint.
• PGD1 Ensuring no unacceptable impacts on public and residential amenity, particularly regarding privacy, overbearing, security, noise and disturbance - Facilities shall be designed to allow natural surveillance from nearby dwellings with safe and accessible routes for users to come and go. Boundaries between public and private space shall be clearly defined and open spaces must have features which prevent unauthorised vehicular access. Communal spaces as described above should not immediately abut residential buildings – Consultation with Designing Out Crime Officers and the community should take place at the pre planning stage to develop safe, inclusive spaces.
• C I3/SP13 – NEW COMMUNITY FACILITIES – Consultation should be sought from Designing out crime officers where schools/ colleges are proposed and they should meet Secured by Design Gold.
• Town Centre First SP11 - The town centre of Holton Road in Barry and the District Centre of High Street had higher than average vacant units. There is a need to ensure that future policies allow for flexibility for a greater range of uses that would be acceptable within a town centre, in line with the town centre first principle and the need to create vibrant places. South Wales Police would ask that they are consulted and are able to give advice where policies are developed for town centres. We would also ask that Designing Out Crime Officers are consulted at the pre planning stage.
• PGD1/SP 11 - Making a positive contribution to the character of the area, responding to the local context and character through building forms and scale; materials and features, mix of uses, landscape, density, and connectivity of streets and spaces to create and/or enhance locally distinctive design and character - Designing out crime officers should be consulted at pre planning stage to ensure safe spaces.
• PGD1/SP11/SP13 - Demonstrating that traffic movements to and from the development can be accommodated, resolved, or mitigated to an acceptable degree, and where car parking is provided, this must be sensitivity integrated into the development so that it does not dominate the layout of the development: South Wales Police Traffic Management Department to be consulted by the Vale of Glamorgan Highways Department in respect of road layout/active travel routes at the pre planning stage.
• PGD1- Ensuring that public open space, private amenity space and cycle and car parking in accordance with the Council’s standards – Where Public open space is being designed, the duty from The Terrorism (protection of premises)Act 2025 should be applied where a premises meets the standard as above. South Wales Police Designing out crime officer should be consulted at the pre planning stage to advice.
• SSC 1/ PG 1 - Car parks are designed and built to ‘Park Mark’ standards as per Secured by Design Non – Residential (Commercial)Guide.
• PGD1/CC1/ SP19 – Creating well designed and inclusive facilities - ‘Providing high quality multi-functional green open spaces which can provide a choice and range of activities, including play, that also deliver enhanced biodiversity and flood mitigation and are designed to be resilient to climate change and adaptable overtime.’: Consultation with the community should be sought from the outset. Parks and green spaces must be designed with safety being the key driver especially for vulnerable groups such as women and girls (Safer Parks document). Designing Out Crime Officers should be consulted at the pre planning stage to achieve this.
• PGD1 Ensuring no unacceptable impacts on public and residential amenity, particularly regarding privacy, overbearing, security, noise and disturbance.
(As above)
• PGD1: Demonstrating that traffic movements to and from the development can be accommodated, resolved, or mitigated to an acceptable degree, and where car parking is provided, this must be sensitivity integrated into the development so that it does not dominate the layout of the development – South Wales Police Designing out crime officers and Traffic Management Officers to be consulted on the layout of developments at pre planning stage.
• TR1/SP 10: Future plans for the continued regeneration of the Waterfront include the redevelopment of the Mole for apartments, a linear park and water sports centre – South Wales Police would ask that Designing Out Crime and Road Safety Management Officers are involved where redevelopment is to take place, consultation should be sought at the pre planning stage.
• RC52 – Edge of town centre retailing: South Wales Police would ask that the Designing out crime and traffic management officers are contacted in respect of new developments and the travel routes to them.
• EMP2 - MOD St Athan - New development within or adjoining MOD St Athan that is demonstrated to be required for operational defence and security purposes, and helps enhance or sustain their operational capability, will be supported in principle. – Advice should be sought from Counter Terrorism Wales and Designing Out Crime officers where redevelopment of/ adjacent to MOD St Athan is planned.
• SP15 – Sustainable Tourism: Promoting opportunities for visitors to engage in forms of tourism that have a low impact on the environment; 2 Protecting and enhancing existing tourism attractions and leisure facilities; 3 Enhancing the visitor economy, attracting local investment, providing local employment opportunities and contributing to rural diversification; 4 Recognising and protecting the Vale’s distinct local identity, built and natural environment as assets to tourism; Providing a variety of tourism opportunities, particularly through all year round facilities and a range of appropriately located visitor accommodation; and 6 Encouraging tourism visits to be made by active and sustainable transport modes – Designing Out Crime Officers advice and advice in respect of Crowded Places to be sought at the pre planning state of any event.
• CI4 – Protecting and enhancing existing community facilities: Proposals for new community facilities or proposals which seek to retain, enhance or maintain existing community facilities will be supported. This includes the provision of multi-use community facilities, including the colocation of healthcare, schools, libraries and leisure facilities – South Wales Police would ask that all new community facilities plans are referred to the Designing Out Crime Officer and Counter Terrorism Wales for early consultation.
Reason: To ensure all public realm is safe, espcially for vulnable groups such as women and girls.
5. Protecting and enhancing the natural environment
Ecological Networks and Green Infrastructure
Project Zero - The Vale of Glamorgan Council’s Climate Change Challenge Plan 2021-2030
The Vale of Glamorgan Local Area Energy Plan (2024)
Maximise reduction in carbon emissions across all activity. • Improve efficiency to reduce energy demand.
Work towards new and existing buildings becoming low carbon prioritising inclusivity, equality, and fairness.
The LAEP is a live document which should be updated every 5 years. It identifies the following priority areas that will be the focus in the short term to assist in setting the Vale on the pathway to net zero: • Making homes low carbon.
Crime committed in 2011 in England and Wales is estimated to have given rise to over 4 million tonnes CO2e, equivalent to emissions of around 900,000 UK homes. Burglary resulted in the largest proportion of the total footprint (30%) due to large volume of offences and the carbon associated with replacing stolen or damaged goods.
Source: “Addressing the Carbon-Crime Blind Spot - A Carbon Footprint Approach” (2016). Helen Skudder, Professor Angela Druckman, Jon Cole, Alan McInnes, Dr Ian Brunton-Smith, Dr Gian Paolo Ansalon.
The environmental benefits of SBD are supported by independent academic research consistently proving that SBD housing developments experience up to 87% less burglary, 25% less vehicle crime and 25% less criminal damage (Note 1.5). It also has a significant impact on anti-social behaviour. Therefore, there are substantial carbon cost savings associated with building new homes and refurbishing existing homes to the SBD standard i.e. less replacement of poor-quality doors, windows and the stolen property from within the home as a result of criminal acts. This has been achieved through adherence to well-researched and effective design solutions, innovative and creative product design coupled with robust manufacturing standards.
Research documentation can be found on the SBD website at: https://www.securedbydesign.com
South Wales Police would ask that Designing Out Crime Officers are consulted to work in partnership with the Vale of Glamorgan Council to reduce the carbon emissions through building to Secured by Design Standards.
Policy 12 - Regional Connectivity
A feasibility study for a new station at St Athan was completed in 2022, which identified four potential site locations for a new station to the south of St Athan.
South Wales Police Recommendations:
• SP10 – Sustainable transport - Ensuring that the design of new developments encourage walking, cycling and public transport use as alternatives to private car use, as well as encouraging options such as mobility hubs and shared car use – South Wales Police Traffic Management Department should be consulted to ensure that sustainable transport links are safe. If these links are rail, then the British Transport Police Designing out crime officer should be contacted at the pre planning stage.
• SP16/CC1 – Net zero carbon developments: pre application consultation from South Wales Police and all new developments to meet Secured by Design.
• CI1/CC1/ SP19 – Open Space Provision: Areas of open space will normally be required to be provided on-site as part of new development proposals. Where it is not practical to make provision on-site, appropriate off-site provision or financial contributions for improvements to existing facilities will be required in lieu of on-site play, outdoor sports provision, or amenity greenspace.
• DNP7 – DARK SKIES: Secured by Design can assist with ensuring that the built environment in all forms, is designed to reduce the opportunity of Violence Against Women and Girls (VAWG) and contribute to such places feeling safe, to live, work and socialise. South Wales Police would ask that Designing Out Crime Officers are involved at the pre planning stage with the Highways Department at The Vale of Glamorgan Council and developer to discuss and be able to make recommendations in relation to lighting.

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.

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.

Draft RCS2 sets out three criteria for new A1, A2 or A3 uses on new sites or existing retail areas which are as follows:
1. “It can be demonstrated that there is an additional need for the proposal which cannot be provided within an existing retail, commercial and service centre; and
2. The proposal would not either individually or cumulatively with other recent or proposed consented developments have an unacceptable impact on the trade, turnover, vitality and viability of the retail, commercial and service centres.
3. The proposal would serve local needs in a neighbourhood or rural village.”
We consider the policy should read as follows:
“1 It can be demonstrated that there is an additional need for the proposal which, when applying the sequential approach to locating development as outlined in national guidance, it has been demonstrated that the site is sequentially preferable; and
2 The proposal would not either individually or cumulatively with other recent or proposed consented developments have an unacceptable impact on the trade, turnover, vitality and viability of the retail, commercial and service centres.
3 Proposals serving only local needs should be of a scale and type which does not undermine the vibrancy, attractiveness and viability of neighbourhood centres.”

The settlement boundary, defined by Policy SP2, excludes allocation site SP12 ‘Land at Bridge House Farm, Llanmaes, Llantwit Major’ which is for a retail foodstore. Instead, the draft allocation abuts, but lies outside, the settlement boundary as currently drawn. Although draft Policy SP3 states that “Areas outside settlement boundaries that are not allocated or protected for a specific use will be defined as countryside we consider the settlement boundary must be extended at this location to include the allocation. Its exclusion is illogical and would fail to reflect the ‘on the ground’ position when this allocation is delivered. Moreover, its exclusion could confuse and may constrain any future minor development changes at the site (e.g. those needed to meet operational needs the subject of any planning application).
The draft proposals map shows the allocation as a dot which does not cover the full extent of the allocation. See below:
See plan in attachment
By not including the extent of the site/allocation within the defined settlement boundary, the draft plan fails to recognise the allocation will form an important part of the settlement, the delivery of which is crucial to meeting identified needs. Accordingly, we believe this fails Test 2 (Is the plan appropriate?), and it may fail Test 3 (Will the plan deliver) as its exclusion from the boundary may unduly impact the future site operation.

Lidl Great Britain Ltd objects to draft policy SP11 (Retail, commercial and service centre hierarchy) as worded as it fails to meet Test 2 (Is the plan appropriate?). Draft Policy SP11 sets out the proposed retail hierarchy (See extract below), but it does not accord with the settlement hierarchy as set out in draft Policy SP2 and it is not justified.
The adopted LDP Settlement Hierarchy lists:
Key Settlement: Barry
Service Centre Settlements: Cowbridge, Llantwit Major and Penarth
The adopted LDP Retail hierarchy lists:
Town centres: Barry
District centres: Barry (high street/broad street), Cowbridge, Llantwit Major, Penarth
Draft SP2 of the Deposit Plan identifies Cowbridge, Llantwit Major and Penarth as Service Centre Settlements in the Settlement Hierarchy.
However, draft SP11 lists a retail hierarchy as follows:
Town Centres – Barry (Holton Rd), Penarth, Cowbridge
District Centres – Barry (High Street), Llantwit Major
It is unexplained and unjustified that the SP11 retail hierarchy upgrades Cowbridge to Town Centre status, while Llantwit Major and Barry High Street remain District Centres.
The Deposit Plan includes two retail allocations, neither are intended to directly serve Penarth or Cowbridge. Cowbridge is not a focus for growth. It is therefore unjustified that Llantwit Major, which is served by a train station, is a settlement roughly twice the size of Cowbridge (by population) and is a manifestly more sustainable location and more appropriate focus for growth, is proposed to rank below Cowbridge in the retail hierarchy. Barry, Penarth and Llantwit Major should rank as Town Centres as the most sustainable locations for growth.
Penarth is an accessible settlement and an appropriate focus for growth. Indeed, the Council’s BP13 (Retail and Commercial Leisure Study (June 2023)) recommends a medium to large supermarket to serve Penarth (Zone 5) but the Deposit Plan is absent of any food retail allocation for Penarth/Llandough. In addition to Llantwit Major and St Athan (Deposit Policy SP12) Penarth should be a focus for additional convenience provision over the plan period.

SP12 – RETAIL FLOORSPACE PROVISION
Lidl Great Britain Ltd firmly supports the allocation within draft Policy SP12 (Retail Floorspace Provision) for 1,251sqm of convenience floorspace at Land at Bridge House Farm, Llanmaes, Llantwit Major. This allocation is needed to ensure the plan is sound, by addressing unmet need at Llantwit Major which is a Service Centre and focus for growth. This should be made clear in the reasoned justification.
In respect to Penarth, Policy SP12, together with supporting paragraphs 6.208–6.210, do not, however, adequately reflect the findings of the Council’s Retail & Leisure Study (BP13). Policy SP12 should also plan positively for the identified convenience retail needs within Zone 5 (Penarth/ Llandough). BP13 confirms that Penarth District Centre is not served by a medium to larger supermarket (para. 9.2). The BP13 Study finds quantitative and qualitative capacity for a medium to larger supermarket by 2036 in Penarth (paras. 9.23, 12.24).
It finds overall quantitative convenience capacity of up to c.5,862sqm net floorspace (assuming deep discounter operators). In qualitative terms the following Centres have been identified in potential need for a medium to larger supermarket: Barry Holton Road town centre; Penarth district centre and Llantwit Major district centre. Quantitative and qualitative need is identified.
Despite the evidence of unmet need, the Deposit LDP Policy SP12 allocates only two sites for convenience retail totalling c. 3,109sqm net; one site at Llanwit Major and a second site at St Athan. This is below the overall (up to 4,282–5,862sqm net) requirement identified in BP13. The allocation of land at Llantwit Major aligns with the evidence base, has been thoroughly tested at application stage and this is fully supported.
Policy SP12 is silent on the need for additional floorspace at Penarth/Llandough (Zone 5) and as such does not reflect the evidence base findings and address identified need in Penarth, with a ‘residual’ quantitative capacity of c.1,173–2,753sqm net unmet/unallocated. We note Policy SP12 states that any additional convenience and comparison retail floorspace beyond that provided by the identified sites should be directed towards the town and district centres outlined in Policy SP11. However, this merely reflects national guidance in respect to directing growth to town/district centres (i.e. applying a sequential approach). The Policy should go further and seek to allocate the residual unmet need to Penarth/ Llandough. We note the BP13 is silent on additional need at St Athan.
Planning Policy Wales (PPW) 12 requires LPAs to identify the appropriate form, scale and location to meet retail needs (para. 4.3.8) and emphasises ensuring communities have access to adequate retail provision (para. 4.3.13). PPW therefore places a duty on LPAs to plan positively for evidenced retail needs. In respect to Penarth/Llandough Policy SP12 should seek to address this requirement.
Under PPW and TAN4, LPAs must apply the sequential test, directing new retail development to locations that are:
• In-centre,
• Edge-of-centre, and only then,
• Out-of-centre locations that are accessible and well-connected to the catchment.
Penarth Centre is physically constrained. In the absence of any in-centre or edge-of-centre sites capable of accommodating a medium/larger supermarket, the next sequentially preferable option is the most accessible, well-connected site within the same catchment, capable of meeting identified need and reducing expenditure leakage.
Policy SP12 should plan positively for needs in Zone 5 (Penarth/Llandough) and include provision for a medium to large convenience foodstore in Zone 5 in accordance with BP13.
Enclosed with this representation is a separate representation (Under 8. New site submission) promoting a site for food retail development to meet identified needs within the Zone 5 Penarth/Llandough catchment. The site is considered accessible and sequentially preferable to meeting identified needs in Penarth.
The policy should be clear that identified need should be delivered in accordance with the sequential approach as set out in national guidance. As set out in Policy SP12 any additional convenience and comparison retail floorspace beyond that provided by identified sites should be directed towards the town and district centres in accordance with the sequential approach. We support that the inclusion of retail floorspace as part of a mix of uses on allocated sites will also be supported.

POLICY DNP2 – GREEN WEDGES
Lidl objects to the inclusion of land at Penlan Road, Llandough (see Site Location Plan, drawing no. 3744 F420) within the Green Wedge designation under Policy DNP2. The site forms a distinct and enclosed parcel of land on the north-eastern edge of the designated Green Wedge, and its physical characteristics demonstrate that it does not serve the strategic purposes of the wider designation.
The northern and western boundaries are formed by Llandough Hospital, including the hospital access road and surface car parking, which clearly separate the site from the wider Green Wedge. The southern boundary is defined by residential properties along Corbett Road and the Merrier Harrier public house. The south-western and western boundaries are formed by further residential properties within Llandough. As such, built development extends beyond the site in multiple directions, meaning it does not contribute to the open land between settlements that Green Wedges are intended to protect.
The site is physically and visually contained with strong, defensible boundaries. Its close association with existing
built form means that it does not exhibit the level of openness required for Green Wedge designation under PPW or BP27. BP27 requires Green Wedge boundaries to include only land that must remain open in the long term. When assessed against the four-stage SE Wales Green Wedge methodology, the site performs weakly. In terms of
openness (Stage A), the site has low perceived openness as it is enclosed by development. Under development
pressure (Stage B), the influence of surrounding built form means the site is already urban in character. In relation
to Green Wedge purposes (Stage C), the site does not materially contribute to preventing coalescence, safeguarding open countryside, or protecting the setting of an urban area. The conclusion (Stage D) is therefore that the site’s inclusion within the Green Wedge is anomalous.
Recent decisions in the emerging RLDP, such as the allocation of HG1 KS2, demonstrate that selective Green Wedge boundary amendments are acceptable where supported by evidence. Not all areas within the current designation are equally sensitive, and the site represents one of the least sensitive parts.
The Council’s own evidence further supports the suitability of the land for development. The site does not lie within
the Special Landscape Area that covers much of the remaining Green Wedge, highlighting its lower landscape
sensitivity. The Candidate Site Assessment (BP18a examined the wider parcel (Site ID 400) for housing and concluded that it would form a natural extension to the Llandough settlement boundary. It noted that the land would represent an incursion only if less sensitive sites could not be delivered and discounted the site solely because housing need had been met elsewhere, not due to landscape or Green Wedge harm. This confirms the Council recognises the land is capable of development. The same land can therefore appropriately meet other evidenced needs, including retail provision.
In separate representations, Lidl is promoting land to the south of Llandough Hospital via ‘RDLP New site
submissions’. It is considered that the site can be developed in a low-impact, landscape-led and sensitively designed manner that respects its transitional position between the urban edge and the wider Green Wedge. A modest single storey medium sized foodstore delivers a built form that can sit comfortably below surrounding tree lines and hospital structures. A comprehensive landscape strategy, including reinforced boundary planting, native woodland edge enhancement, and carefully designed building can soften building edges, strengthen the site’s defensible boundaries, and integrate the scheme with its surroundings. The development would therefore appear as an infill of the existing urban area, rather than any intrusion into the open countryside, and can be designed to maintain the wider Green Wedge’s openness and character by delivering a strong defensible physical boundary which prevents any further development beyond the site.
As set out in separate representations the Council’s Retail and Leisure Study (BP13) identifies a clear quantitative
and qualitative need for a medium to larger supermarket within Zone 5, alongside notable levels of convenience
expenditure leakage to Zone 3 (Cardiff). The promoted site is well positioned to intercept this leakage, meet the
identified convenience floorspace requirement, and provide improved local convenience retail provision for
Llandough/Penarth. There is, therefore, a clear needs-based justification for release of this parcel of land from the Green Wedge designation.
The Green Wedge boundary should be amended at this location to remove the promoted site from Policy DNP2
(Green Wedge designation) and from the Proposals Map. In parallel, the settlement boundary defined by Policy SP2
should be realigned to include the promoted site, reflecting the site’s physical relationship with existing
development, its defensible boundaries, and its suitability to meet an evidenced strategic retail need.

The Policy text should be changed as follows:
“Proposals involving the change of use at ground floor level uses from A1 retail use within Service Centres will permitted where the proposal would:…”
The Policy RCS1 (Resilient retail, commercial and service centres) supporting text adds new policy requirements which are not within the draft policy. Paragraph 6.214 states that:
“Changes of use class in Retail, Commercial and Service Centres must be justified by evidence that the property has been affected by a sustained period of long-term vacancy and that proactive marketing has been undertaken by a property agent for a minimum of 12 months in an effort to secure tenants. The marketing report should include:
• Details of the existing use or previous use if vacant;
• The length of time the unit has been vacant, if applicable;
• The type of use which the unit has been marketed for, what the marketing strategy involved and its duration;
• The amount of interest in the unit during the marketing period – this should detail the number of queries, the type of uses sought, and if known, the reason for not pursuing any initial enquiries.”
However, nowhere in the draft policy wording does it explicitly state to include 12 months of marketing activity. The draft supporting text reads as though this is a policy requirement, rather than supportive guidance. This is contrary to caselaw which confirms that supporting text cannot be used to expand the policy beyond its wording (R (Cherkley Campaign Ltd) v Mole Valley District Council). A proposal could meet the requirements of the criteria sets out in draft policy RCS1 without being marketed for a minimum of 12 months. If the Plan is adopted as currently set out, there is a risk of internal inconsistency between policy RSC1 and the supporting text. Accordingly, this would fail Test 2 (Is the plan appropriate?) as it is not coherent or consistent.
We also have concerns with criterion 5 which states to “Avoid an over-concentration of non-retail uses that would undermine the retail function of the centre”. This is because ‘over-concentration’ has not been defined within the draft policy. This contrasts with draft policy RCS3 which includes a definition of what an over-concentration of hot food takeaways would be. Without a definition of what an over-concentration of non-retail uses is, the draft policy will remain and lack clarity. Additionally, without a definition, the draft policy may fail Tests 2 and 3 as it is currently unclear (Test 2: Is the plan appropriate?) and cannot be effective (Test 3: Will the plan deliver?).

At present, we consider the Deposit Plan inadequately supports the Welsh language. Although the Welsh Language is included within Objective 6 (Embracing Culture and Heritage), the Deposit Plan does not contain a policy which seeks to promote the Welsh language, nor is the promotion of the Welsh language referenced in other Deposit Plan policies where this may be appropriate. Without a clear policy, applicants do not need to explicitly consider impact on the Welsh language so the role of the RLDP will be limited.
Local Development Plans should accord with national policy and guidance. For instance, the supporting text to Policy 1 of Future Wales states that “Key issues, including … the Welsh language, are core elements of policy 1 and are common threads underpinning all Future Wales policies.” However, we believe that the Welsh language is not currently underpinning the policies within the Deposit Plan.
Additionally, paragraph 3.25 of PPW states that “The Welsh language is part of the social and cultural fabric and its future well being will depend upon a wide range of factors, particularly education, demographic change, community activities and a sound economic base to maintain thriving sustainable communities and places. The land use planning system should take account of the conditions which are essential to the Welsh language and in so doing contribute to its, use and the Thriving Welsh Language well being goal.” Paragraph 3.29 goes on to suggest language impact assessments are required for “large developments not allocated in a development plan which are proposed in areas of particular sensitivity or importance for the language” with these areas defined in the LDP. In this instance, PPW sets out guidance for developers which is not present in the Deposit Plan.
The Vale of Glamorgan Council commissioned AECOM to produce the Integrated Sustainability Appraisal (ISA) for the Replacement Local Development Plan (November 2025). Paragraph 9.5.9 recommends including a specific policy that supports and protects the Welsh language within the Deposit Plan. This contrasts with the Welsh Language (November 2025) Background paper, produced by the VoGC, which concludes that a specific Welsh Language policy is not warranted, albeit it does acknowledge the Plan’s statutory duty to consider the Welsh language and embed relevant provisions within broader thematic policies. However, this is currently lacking as the Deposit Plan does not reference the Welsh language within other policies. Although the Background Paper considers that the RLDP is “unlikely to adversely affect the existing patterns of Welsh language use within the Vale of Glamorgan”, the Plan should seek to promote the Welsh language.
Developers should be encouraged to promote the Welsh language where this may be reasonable and appropriate e.g. bilingual signage and announcements. Lidl actively promotes the Welsh language through their business. The Deposit Plan should be amended to strengthen the importance of the Welsh language, helping to meet Objective 6 over the RLDP period. Overall, without clear Welsh Language policy promotion, the Deposit Plan cannot positively impact the Welsh language. The Deposit Plan needs to go further.