My comments are specifically in relation to the Waycock Cross housing proposal. I have printed out a sheet of the key points. In summary I believe that the land in North West Barry is not a suitable location for development but I also object to errors/flaws throughout the RLDP.

HG1 KS1 - Land at North West Barry

1. Traffic and mitigation

Congestion on Port and Pontypridd Roads will worsen Emergency access will be compromised No adequate mitigation exists

Increased queueing on Pontypridd Road will directly extend blue-light response times on an identified hospital and airport route.

Traffic capacity on Pontypridd road is already at 100% at peak times there is no room for improvement.

The widening on Pontypridd road is unsuitable and encroaches on Local residents land, it will also make crossing the road to the petrol station/shop practically impossible.

SP10 - specifically in relation to distance to Barry Train station on foot, this regularly takes me 30-40 minutes and requires at least two steep hills.

2. Pressure on services (health, schools, infrastructure)

All evidence states that:

GP, dental, and school capacity is already stretched. Waiting lists and capacity limits exist. Additional housing would exacerbate this.

The development fails the test of deliverable social infrastructure, as no funded or timetabled expansion of GP, dental or school provision is identified - this would equate to policy failure in this area.

3. Housing numbers and population argument

The statistics are repeated consistently:

Housebuilding rate cited as 7.55%. Population growth cited as 4.1%. Birth rate cited as 1.38, described as declining.

The scale and type of housing proposed is not supported by demographic drivers, indicating supply-led development rather than needs-led planning.

This would constitute a clear planning objection.

4. Type of housing vs. stated needThe argument that:

The Vale of Glamorgan needs housing suited to older single people, and The proposed development does not meet that need

The proposal therefore fails to meet the stated housing mix priorities previously identified by the Vale of Glamorgan. This reinforces internal inconsistency within the council's own position.

5. Previously Refused Proposals still Stand

Similar proposals declined in 2013 and the concerns raised then are still in existence with no sensible mitigation

The persistence of identical unresolved issues since the 2013/16 refusal demonstrates a failure to address material planning objections over time. This shows a lack of understanding and willingness to consider alternatives.

This is a significant point as none of the submissions include sufficient mitigation to previous points

6. Green Wedge Land with impacts to wildlife

The proposed development would result in the irreversible loss of designated Green Wedge land, which plays a critical role in preventing urban coalescence, maintaining landscape character, and supporting biodiversity. The site currently functions as an important ecological buffer between settlements and contributes to the wider network of green and environmental spaces in the area.

DNP2 - Incorrectly assumes this is not Green Wedge Land

There is documented local concern regarding skylark activity on the site, including potential nesting within the fields affected by the proposal. Skylarks are a recognised ground-nesting farmland species that is highly sensitive to habitat loss and disturbance. The permanent development of this land would remove suitable breeding and foraging habitat, with no clear or credible mitigation identified to offset this loss.

SP19 - It feels that this has not been taken into consideration at all.

In addition, otter sightings have been reported locally, indicating the potential use of connected habitats and watercourses in and around the site. This is in direct contradiction to the point CC6 point 3 " Avoid significant adverse effects on designated habitats, species and landscape charachter".

The fragmentation, lighting, noise and increased human activity associated with the development would be likely to degrade habitat connectivity and increase disturbance risks for protected species. The proposal therefore raises serious concerns regarding compliance withenvironmental protection objectives and represents a significant and unmitigated environmental harm. Once lost, the ecological and landscape function of this Green Wedge land cannot be realistically recreated elsewhere

CC6 - Increasingly frequent pollution alerts on our local beaches will worsen with development in this area.

7. Welsh Assembly / governance position

References to criticism or lack of support from the Welsh Assembly are aligned in tone and conclusion across documents. None of the material claims formal endorsement elsewhere.

Planning Harm Summary:

Transport harm (no mitigation, emergency access risk) Social infrastructure harm (health, schools) Environmental harm (green space, ecology) Policy harm (housing mix mismatch, demographic misalignment) Governance harm (prior refusal, lack of cross-agency coordination)

Unless these harms are demonstrably mitigated, the proposal should not be approved.

I wanted to make you aware that in your plans to widen the road to 3 lanes on Pontypridd Road by integrating the road for the row of houses opposite the petrol station.
I wanted to make you aware that my Grandma lives on that side of the road and on her deeds she owns the frontage of the garden, part of the road and the grass verge that goes up to the main road.
I can send a copy of this information.
The plans cannot go ahead unless the land is bought off my grandmother and the other properties on the street! My grandma bought the house from a developer.
I wanted to make sure that you are aware of this situation.
Also I wanted to point out the increased congestion especially now with the road works and this would only get worse.
There would be a loss of privacy to existing neighbours due to new properties overlooking existing properties and the noise of development.
There is a lack of infrastructure for example schools in the area are already full, doctors are full and have no appointments.
Can someone please get back to me especially regarding my grandmothers land at the front of the property that you are looking to alter.

Objection

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

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

Detailed Policies

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

5. Housing And Employment Allocations
Housing Allocations

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

remove site from the plan

HG1 KS1 Land at North West Barry - Proposed Development at Weycock Cross
("WC")

I set out below (and within the enclosed supplemental pages) my objections and questions in respect of the proposed development at WC.

It is well documented that development plans for WC were previously refused between 2013/2016 and as such, I will not repeat the reasons as to why this site was deemed unsuitable at that time save that those reasons still stand and the concerns that were
raised are still present and have not improved with age. Indeed, the challenges facing the infrastructure within the area have only worsened and it would be disingenuous for the Council to say otherwise.

Notwithstanding that it has been over 10 years since the last proposed development for housing on WC was refused, it is difficult to comprehend the rationale for the Vale of Glamorgan Council wishing to revisit this and it is submitted that
it fails to align with the Well-being of Future Generations (Wales) Act 2015 (the “Act”).
It is averred that the proposed development at WC is not sustainable and will have both
a negative and detrimental impact on following:
• The infrastructure to include placing additional strain on the local GP Practices,
the dentist surgeries and schools.
• The wildlife and surrounding environment to include not just the green space at Weycock but to Millwood Forest and its watercourses, which lead and flow down to Porthkerry Park.
• The sewage system, which will have a direct impact on the local residents in the
surrounding area.
• The traffic and congestion, which will not just impact the local residents of Barry but also have an adverse impact on the neighbouring communities of Rhoose and
St. Athan.

Having considered the Council's responses as set out in the document known as 'Housing Growth in Barry, Report of Public Consultation (November 2025)'
("Consultation Report"), it is surprising to note the manner in which the issues and concerns raised that developing WC would cause have seemingly been dismissed.
Indeed, it gives the impression that a predetermination on this development has already been made before the Consultation Process has even finished and if that is the case, then the consultation would be fundamentally flawed. The failure to consider material factors and ignoring the genuine concerns that have and
are being raised by the constituents of Barry leaves one to question the legality of the proposed development and if there are any findings that give rise to any environmental
and/or statutory violations, the Council run a significant risk of steps being taken to explore the lawfulness of its decision to proceed with the development at WC.

OBJECTION 1 - IMPACT ON LOCAL GP SURGERIES

Within the Consultation Report at Annex 1(A1-1), the Cardiff and Vale University Health Board, stated that the development of 376 homes will bring an average of 850 new residents into the area, which equates to an increase of 10.9%.
In response, the Council simply say 'Comments are noted' with the action being to 'engage with the Cardiff and Vale UHB in the development of the RLDP and explore opportunities for health provision.'

The response provided by the Council is wholly unacceptable and completely inadequate with the presumption being that no assessment has been undertaken which clearly explains how the current three local GP surgeries would cater for the influx of 850
new residents. As the Council does not have the direct funds to recruit new doctors, the recruitment of medical staff is the responsibility of the Cardiff and Vale University Health Board and Welsh Government, not the local council. However, the Council is involved in supporting
the health infrastructure through planning, and it is noted that it faces a significant shortfall itself, having projected a £7.8 million gap in its own 2024/2025 budget.

It is noted that recruitment incentives include the Welsh Government providing incentives, such as £20,000 to encourage doctors to train in targeted areas, though
research indicates that these have recently focused on areas other than Vale of Glamorgan.

Recent reports indicate that GP practices in the Cardiff and Vale are among the lowest funded in Wales, which clearly make it much harder to attract and retain staff. In short, and as the Council does not hold the budget or the mandate to directly hire medical professionals and has no ability to influence the recruitment process, please clearly set out the following:

1. the number of fulltime new doctors that have been recruited from January 2021 to January 2026 by the Vale Group Practice, The Waterfront Practice and
West Quay Medical Practice.

2. whether the local GP surgeries have been asked by Council to opine on the number of new GPs that would be required.

3. the local GPs' views on how many new doctors would need to be recruited to service the needs of 850 new residents.

4in the event the recruitment of new doctors or medical staff is not possible and .

5. the development of WC was to proceed, please clarify whether you have undertaken an assessment of what the additional waiting times will be for residents to receive a GP appointment if these three surgeries have to try and
accommodate 850 new residents using the current staffing levels.

If the Council have not obtained the information at paragraphs (i) to (iv), please clearly explain the rationale for not obtaining this information at this stage. Given the local GP surgeries are already heavily under resourced and over worked, the Council has a duty of care to ensure that the necessary infrastructure is in place. To ignore
these concerns would be a dereliction of duty by the Council.

OBJECTION 2 – ADVERSE IMPACT ON LOCAL DENTIST SURGERIES

The current waiting list for new patient access for dentists in Barry is circa 18-24 months. I can speak directly to this on the basis that I myself have been on a waiting list
for over 2 years. Indeed, the only space that was capable of being offered was in St Athan, which is a damning indictment of how local dentists in Barry are unable to cope with servicing the current population of Barry never mind being able to service an influx of new residents to the area.
With this in mind, please answer the following:
i) clarify and set out the assessment that has been undertaken and the evidence that has been obtained from the local dentist surgeries that supports the position that they will be able to service the needs of circa 850 new residents.
ii) noting the same recruitment challenges exist in the dentist industry as they do in the GP industry, should the recruitment of new dentists not be possible regardless of any new funding that may be received from developers, please clarify whether you have undertaken an assessment of what the additional waiting times will be if a new resident wishes to be seen as an NHS patient.

Given the local dentist surgeries are already heavily over stretched and have no new openings, the Council has a duty of care to ensure that the necessary infrastructure is in place for dentist surgeries is sustainable long term. As above, to ignore these concerns and the impact that additional housing at WC would have would be a dereliction of duty by the Council.

OBJECTION 3 AND QUESTIONS PERTAINING TO THE ADVERSE IMPACT ON LOCAL SCHOOLS

Turning to schools, I strongly object to the proposed development at WC on account of the fact that it appears that little or no evidence has been collated that the necessary steps have been taken to meet and consult with each of the impacted schools to understand the challenges that that they currently face with regard to admission waiting lists/times and also ensuring that they have the ability to cater for children who have additional learning needs.

I refer to report prepared by the Auditor General for Wales dated December 2025 (website: www.audit.wales) (the “AG Report”). The primary purpose of the recent audit,
that was prepared less than three months ago, was to consider whether the Vale of Glamorgan Council has arrangements to support and challenge its schools to recover from their budget deficit positions.

At point 3, page 1 of the AG Report, it confirms the percentage of schools in deficit as at 31st March 2024 was 42% with this increasing to 53% at the end of March 2025 with the schools forecasting further overspends against their allocated funding in the next two to three years so increasing the overall deficit position. It states, ‘the Council’s Medium Term Financial Plan (MTFP) 2025-2028 states that ‘School balances are a major concern if the current level of spend in schools isn’t brought in line with budget during 2025/2026’.

At paragraph 4 (page 5) of the AG Report, it states that the Council’s own forecasts confirm that its level of usable reserves will reduce by half in 2025/2026, in part due to
schools overspending. These challenges pose a risk to the Council’s overall financial sustainability.’

At paragraph 5, page 5 of the AR Report, it states that the ‘Estyn report of the Council’s education service, published in April 2024, stated that ‘despite the authority’s support
and challenge to schools during the development of their plans, including the use of data and peer review, it has evaluated that almost all of the schools currently in deficit will be unable to return a balanced position at this time. This poses a notable on-going risk to the sustainability of the individual schools’ budgets’.

At paragraph 6, page 6 of the AR Report, its findings reveal that ‘many schools in deficit either don’t have recovery plans or the plans aren’t robust. This raises concerns about how schools will achieve the step change needed to become financially sustainable. This could impact on the Council’s overall financial sustainability. There are shortcomings in the Council’s reporting of this significant risk. This limits the effectiveness of monitoring and challenge in public committees’.

The AG Report concludes that the ‘robust recovery plans’ the Council are seeking from all 36 schools that are in a deficit position are deficient and fail to set out how they will
recover within five years and that this limits the Council’s ability to assess how well placed each school is to recover. AG Report goes on to say that this ‘presents a risk to the
Council that those school deficits might further increase challenges to its financial sustainability….’ Indeed, Exhibit 1 at page 7 of the AG Report highlights that the projected
reserve balances across all schools in the Vale of Glamorgan will continue to decrease year on year.

At paragraph 9, page 8 of the AG Report, it states that the Council have determined that 27 schools of the 36 that were in deficit and had provided recovery plans concluded that they contain ‘unexplained and sometimes unrealistic proposals to reduce staff and other cost centres’. At paragraph 13, page 9 of the AG Report, it states that the ‘poor quality of Schools’ recovery plans poses not only an on-going risk to the sustainability of individual schools’
budgets but also to the financial sustainability of the Council itself. Without robust school recovery plans, it is difficult for the Council to develop accurate Medium Term
Financial Plans and help forecast any necessary future calls on reserves. In addition, the AG Report considers that the size and trajectory of the deficit position and
quality of recovery plans, the Council’s 2024-2025 assessment does not capture entirely the significance of this issue. Neither does the Council’s quarter one budget monitoring report. This, therefore, limits awareness and understanding among members and residents of the potential impact the schools’ financial position may have on the Council’s financial sustainability. Given the lack and poor quality of the reporting of this issue, the AG Report concludes that it will not enable Committee members to challenge and assess how well the Council is mitigating this risk.

The current waiting list for the Whitmore High School for the coming year is unprecedented with the maximum intake being 180. It simply does not have the capacity
to offer spaces to the pupils in the current catchment area, and the waiting list will only continue to grow. Following a conversation with several parents, the indication at this
early stage of the year is that for new Year 7 pupils that will be attending this school from Autum 2026, is that the waiting list was significant. Given the damning nature of the AG Report and the current financial crisis and increasing pressures schools are facing particularly in the Vale of Glamorgan to meet demand for school places, please explain and provide evidence of the following:

i) If the Council is proposing to obtain funding from the developers using Section 106, please confirm the average level of funding that the Council would expect to receive to ensure that the proposed development at WC would be sustainable.

ii) That the Council has consulted with the local schools to confirm that they will be able to accommodate and cater for additional applications that will materialise should the development at WC proceed. This is especially so
given the drive to reduce the current level of deficit and budgets. If this information has not been obtained, please clearly explain why you consider this is not information that is considered necessary at this stage.

3. Given the current school waiting lists for admissions that the local schools in Barry are experiencing, please explain how the development at WC is considered to be sustainable’ in light of the findings of the AG Report,
which highlights the crisis that schools are currently facing.

4. Given the adverse consequences for children should they not be able to select a school that is appropriate for their needs, please explain and provide the evidence that that the proposed development at WC will not have a negative impact on the existing school infrastructure, which is already under severe pressure.

5. Given the lack of school spaces currently available, please explain and provide evidence that new residents would have reasonable access to attend the local schools in this area.

6. If the proposed development were to proceed, please provide evidence that each of the schools (to include Whitmore High, St. Richard Gywn) have been consulted on whether an influx of new residents will place additional
strain specifically on Specialist Education requirements and how this will impact their current deficit (if any). If this has not been completed, please explain why this is not considered necessary given the ever-increasing
need for special educational needs (SEN) places.

When considering this question, I draw your attention to the Estyn Report for St. Richard Gwyn dated May 2025, which confirmed that 19.3% of the school’s pupils were identified as having additional learning needs with it
being noted that the national average in Secondary Schools is 11.2%.

7. Despite undertaking research of the Council’s data bases, it has not been possible to locate or obtain copies of the Local Authority Reports for the capacity levels for each school. Please set out the data for each school that would be an option for the proposed development at WC and confirm the current capacity levels for 2025/2026 and the current waiting lists (projected or otherwise) for 2026 through to 2028.

Objection 4 – Adverse Impact on the wildlife and surrounding environment to include not the just the Green Wedge land at WC but also the environment impact to
Millwood Forest and its watercourses, which lead and flow directly down to Porthkerry Park

The land at WC, is still officially recognised as green wedge land with one of the main reasons for this designation being to prevent the urban sprawl between Barry and neighbouring Rhoose and to prevent an adverse impact to wildlife.

The Green Wedge at WC was preserved to ensure the following:
• Prevent the coalescence of Barry and neighbouring Rhoose.
• Manage urban form through controlled expansion.
• Safeguard the countryside from encroachment.
• Protect the setting of urban areas.

It is submitted that this parcel of land should continue to be afforded the protection it has
received to date and that the arguments that this needs to be reconsidered as a consequence of WC being viewed as a ‘suitable site’ for housing development are misleading and flawed.

Within the Consultation Report (A1-4 - A1-6), Natural Resources Wales (“NRW”) repeat their comments from 2023 on the basis that nothing has changed from their perspective. It remains that the area surrounding WC is home to several protected species to include bats, badgers, foxes, hedgehogs and the dormice and recognised for its biodiversity, which includes an ancient woodland and habitats for these animals. These species are protected by UK law and permitting this proposed development will invariably lead to the loss of and/or disturbing the habitat for these species.

Objection 5 – Adverse Impact on Millwood Forest, its wildlife and its watercourses, which lead and flow directly down to Porthkerry Park. It is noted that the Consultation Report provides that the Council will heed the NRW’s
recommendations, but what is unclear is whether any assessment has been undertaken to assess the impact that the proposed development will have on Millwood Forest.

Given the adverse impact that the proposed development will have on Millwood Forest, please confirm:

i) what assessments will be undertaken and when.

ii) with regard to the existing problem that concerns the surface water that cascades from the fields down the back of the forest and which regularly floods the footpath and causes the watercourse to rise significantly, please
explain the reasoning why it would not be prudent to undertake a flood consequences assessment at this stage to so this could be determined before further costs and expenses are incurred.
Flooding of the forest can lead to the destruction of nests and habitats and high-water levels can be seen to have submerged trees on the banks which have led to the loss of nesting cavities for birds and burrowing sites for mammals. Video footage of the water surface issues at Millwood are available and will and will be enclosed
as part of this submission.

Objection 6 – Insufficient access to travel and public transport

Within the Consultation Report, the Council state that the land at WC is being considered as it is in a sustainable location within reasonable walking and cycling distance of Barry station and a range of other services and facilities.
It is submitted that this statement is completely misleading. Whilst it is not disputed that Barry Train Station is 1.3 miles from the proposed site at WC, I note that assertion at A1
10 of the Consultation Report that it is a short 5-10 minute cycle from the train station and a 28 minute walk.

The walk from Barry Train Station to WC is a significant, sustained uphill climb. The route involves a steady, steep elevation gain, often cited as a major, challenging incline for pedestrians and cyclists moving from the lower town area to the higher Colcot/Weycock area. In addition, the route has no safe cycle lanes. Given the challenges that this route presents for pedestrians walking or cycling to the
train station, and on the basis that the Council indicate that this is one of the reasons that makes this site suitable, it is requested that the Council provide the following:

i) Evidence or the results of any survey that confirm the current number of people who walk and/cycle from WC and the immediate surrounding area to Barry Train Station.

ii. Presuming that the evidence requested at (i) above does not exist, and it is recognised that walking and cycling to and from the train station is not a viable
option, does the Council accept that the people will simply revert to travelling by car?

iii) Barry Train Station currently has a maximum parking capacity of 124 cars. If people are commuting from WC and the surrounding area, they use their car and will wish to park in train station. As such, please explain how the train station and immediate surrounding area will cope given the parking shortage if the station has to cater for additional residents commuting from WC.

Objection 7 – The adverse impact that the proposed development at WC will have on the sewage system and the impact that this will have on current local residents

The existing infrastructure regarding the sewage system is already wholly inadequate and the pumping station at Nant Talwg Way/Millwood cannot cope. This is demonstrated by
the volume of complaints that have been made to Welsh Water by the local residents of Nant Talwg Way since circa 2015.
It is well documented that the pungent and foul odours that constantly emanate from the already overloaded pumping station in this area, causes residents to have to close their
windows and not to be able to use their gardens.

The pungent odours are evidence that sewage system is not functioning correctly and poses risks to public health and the environment and causes distress and anxiety to
those who live in close proximity.

The existing drainage systems for Nant Talwg Way were designed without any Climate Change uplift, and with no allowance for any future development above the estate. As
such, any suggestion that the drainage system can simply be upgraded to cater for an additional 376 houses is wholly misleading and will lead to flood risk and foul sewer back up.

The culvert size running under the whole of the Nant Talwg Way estate is not identified anywhere within the plans and this is already backing up during heavy rainfall (videos can be provided as evidence). Despite all the mitigation measures, the building of 376 houses at WC will pose a real risk of flooding to the houses situated within Nant Talwg Way.

Objection 8 – Unacceptable and Detrimental Impact to the local residents

I refer to the Barry Town Council Meeting that took place on 2nd June 2015 at 7:00pm. Minutes of the meeting that took place are enclosed for your consideration.

During this meeting, the Council may recall that it considered and discussed Planning Application No. 2015/00470/OUT, which related to the Land at Walters Farm, Weycock Cross, Barry. The proposed development was for up to 200 residential homes along with
associated parking, access, public open space and landscaping and including the demolition of existing buildings.

Whilst the Council will be familiar with the decision that it reached in 2015, I feel it necessary to remind you of the robust and definitive language that was used when
reaching its decision to object to the application.
Within the minutes at paragraph (h), it states in black bold capital letters “STRONG OBJECTION”.

The minutes state as follows:
“Barry Town Council has previously supported the removal of sites to the northern edge of Barry from the latest deposited LDP and made strong objections to the to the previous proposals for the site (Planning Application No. 2015/00351/OUT) as it considers that the proposed development would result in the following “unacceptable consequences”:

• The development of this site would result in a development outside the established and proposed residential settlement boundary.
• Traffic studies undertaken by the Vale Council as background preparation for the most recently deposited plan indicate clearly that developments at this location would exacerbate the traffic congestion in the surrounding areas, particularly along Port Road would be overloaded by the increased traffic generated by such a development would lead to an unacceptable environment for existing residents of this area.

• The Town Council believes that the development would result in increased traffic movements to enable the new population of the site to access local services. As the area is currently severely congested with vehicular traffic
further development in this area would add to increased and unacceptable traffic congestion and pollution thereby resulting in an increasingly poor living environment for the local residents.

• The development would result in the loss of fertile agricultural land, drainage problems, increased local flood risk and would seriously damage areas of nature conservation and archaeological interest within and adjacent to the site.”

Comments and observations

1. When objecting to this application, the Council was clear and decisive in its view that this application, “would result in unacceptable consequences”. Indeed, this
was the view when the application was only to build two hundred houses and if that was deemed unacceptable, then surely the proposal to build 376 houses would be considered entirely intolerable and morally reprehensible.

2. At bullet point 2 of the Council’s objections, it confirms that it undertook its own traffic studies as ‘background preparation’ and those studies provided clear evidence that the building of additional 200 houses would exacerbate the traffic
congestion in the surrounding areas, which would lead to an “unacceptable environment for existing residnts of the area”.

3. Within the Consultation Report at A1-6/A1-7, it is noted that the Council is undertaking a Strategic Transport Assessment and that indicates that it will be possible to ‘manage’ targeted highway improvements that ‘are apable of improving traffic flow’ and that ‘the modelling shows that with these improvements, the additional site traffic would only have limited effect on how the Weycock Cross junction operates’.

Given that the Council had already commissioned evidence that in 2015 that entirely contradicts the Council’s position, it is submitted that unless the Council
is going to design and build an overpass, then the statements that this proposal could improve traffic flow are misleading and leads to serious questions being raised by the veracity of the statements that have been made within and throughout the Consultation Report regarding the suitability and sustainability of the proposed development at WC.

Questions/requests for information

In the interest of full transparency, please provide a copy of the traffic studies that were undertaken in 2015, and which were used for the purposes of the Council strongly objecting to the proposed development at WC. If you cannot provide a copy, then please provide a link or confirm where this would located.

It is noted that in 2015, the Council expressed extreme concern for the local residents and concluded that the building of 200 houses at WC would “lead to an unacceptable environment for existing residents of
this area” and lead to “unacceptable traffic congestion and pollution thereby resulting in an increasingly poor living environment for the local residents”
.
(Q) Given the Council’s comments in 2015 and noting that the current proposed development at WC is for 376 houses (almost double the 200 houses that were proposed in 2015), please confirm that the Council’s current position is that it fully accepts that in continuing to
include the development at WC within the RLDP, it now finds it acceptable to create an unacceptable, poor-quality living environment for the existing residents of the area.
Within the Consultation Report at A1-6/A1-7, it is noted that the Council is undertaking a Strategic Transport Assessment and that indicates that it will be possible to ‘manage’ targeted highway improvements that ‘are
capable of improving traffic flow’.

This is completely at odds with the previous evidence that the Council commissioned in 2015 which the Council relied upon as evidence to support its objection to the development and concluded that any development at WC would lead to ‘unacceptable traffic congestion and
pollution thereby resulting in an increasingly poor living environment for local residents’.

(Q) Given that the Council had already concluded that the
development at WC would lead to “unacceptable traffic congestion and pollution”, please confirm that if the Council continues with the development at WC, that it is accepting that it will be breaching its legally binding obligations as set out in the Well-being of Future
Generations (Wales) Act 2015 (the “Act”).

iv) I refer the Council to the Guidance Document titled ‘Well-being of Future Generations (Wales) Act 2015: the essentials’ (published 23 June 2015 and last updated on 7 January 2025 (www.gov.wales)). Within this
document, it sets out the legally binding well-being goals, which are as follows:
A prosperous Wales
A resilient Wales
A healthier Wales
A more equal Wales
A Wales of cohesive communities
A Wales of vibrant culture and thriving Welsh Language
A globally responsible Wales

Under the heading ‘Why do we need this law’ (as set out in the guidance note), it states:
‘Wales faces a number of challenges now and in the future, such as climate change, poverty, health and well-being, coronavirus, jobs and economic activity. To tackle these we need to work together. To give current and future generations a good quality of life we need to think about the long-term impact of the decisions we make.’
In addition, the guidance note goes on to explain what the Act means by “sustainable development”. It provides:
‘In this Act “sustainable development” means the process of improving the economic, social, environmental and cultural well-being of Wales by taking action, in accordance with the sustainable development principle, aimed at achieving the well-being goals’. Under the heading ‘Healthier’, it states that the aim of this well-being goal is to create a society in which people’s physical and mental well-being is maximised and in which choices and behaviours that benefit future health are understood.
Given that the Council commissioned its own evidence in 2015 that categorically concluded that any development at WC would “lead to an unacceptable environment for existing residents of this area” and lead to “unacceptable traffic congestion and pollution thereby resulting in an increasingly poor living environment for the local esidents”, please confirm that in allowing the development to proceed that this would be in breach of Council’s obligations under the Act as this would clearly impact the physical and mental well-being of the local residents.

Conclusion
The Well-being of Future Generations (Wales) Act 2015 (the “Act”) was supposed to be a ground-breaking law that requires public bodies to improve the social, economic,
environmental, and cultural well-being of Wales. It is submitted that this legislation is supposed to make public bodies think more about the long term, work better with people and communities, and take a more joined up-approach to prevent problems. As such, the Council must act in a manner that seeks to ensure the needs of the present are also met and not simply continue with this development at any cost.

v) During the Council’s meeting on 7th July 2015, it was categorical in its assessment that the development would ‘result in the loss of fertile agricultural land, drainage problems, increased local flood risk and would seriously damage areas of nature conservation and archaeological interest within and adjacent to the site’.

(Q) Given the Council is obligated to be fully transparent in this development consultation, please provide the documents and information that the Council considered in 2015 so this may be reviewed and considered alongside any subsequent reports that may be commissioned in the future (for example any flood risk assessments, drainage assessments etc).

Objection 9 – Impact of increased congestion will have in delaying emergency services being able to attend any major incidents at Cardiff International Airport (“CIA”) and MOD St. Athan. Within the Consultation Report at A1-6, it is noted that the Council’s response to queries on this topic states that the South Wales Fire Service and Rescue Service and the Welsh Ambulance Service have not objected to the principle of the development.

It is also noted that there is also no suggestion that these services are in support of this proposal either as if they were, then I am sure any comments endorsing the proposed development at WC would be included within the Consultation Report and they are not. It also appears that no actions are contained in the ‘Actions’ column regarding the Council seeking reports and/or assessments from the South Wales Fire Service and Rescue Service and the Welsh Ambulance Service in respect of how this development at WC could impact and/or delay their ability respond to any major incidents at the CIA and/or MOD St. Athan.

Questions:
i) It is well publicised that the RAF and other air force aircraft frequently use CIA for the purposes of conducting operations. As such, and given the heightened current political climate, please confirm whether a full risk
assessment has been made by the aforementioned services in respect of this issue and their ability to respond to major incidents at CIA and MOD St. Athan.

Summary
The CIA hosts various RAF and U.S Air Force military aircraft for training, operational stops and refueling. Port Road acts as the main and only route to the CIA, and given that the National Threat Level of terrorism to the UK
(England, Wales, Scotland and Northern Ireland) is recorded by the UK Government as being ‘substantial’, please explain the rationale for not undertaking an assessment in respect of how any form of congestion or
road accident could hinder/delay the emergency services from being able to respond to any major incident given that CIA regularly hosts military aircraft.

To not undertake such an assessment, would be considered a dereliction of duty. Given the conclusion that was reached by the Council in 2015 regarding the adverse and detrimental impact that any development at WC would have on the local residents and the surrounding areas and noting the rather peverse position that the Council is now seeking to rely on new evidence that disproves their original findings that this site was wholly unsuitable, it is submitted that the change in stance is irrational and unreasonable and will be subject to challenge.

Whilst it may be the case that Local Councils are permitted to change their view, this would need to be justified by new, material evidence that demonstrates that the proposed development at WC is sustainable and would not negatively impact the wellbeing of the local residents and the surrounding area. No such evidence has been provided and the reasons why the Council so strongly objected to the application in 2015 still exist today.

For all the reasons stated in Part 2 (submitted by email to ldp@valeofglamorgan.gov.uk on 10th March 2026)) and Part 3 of my objections, the correct decision would be to remove this development from the RLDP.

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.

Amend following bullet points as worded

• 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. 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.

• 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.

•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).

• A contribution towards off-site sustainable transport measures (as necessary and related to the Key Site).

•The provision of a key area of open space 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 biodiversity 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.

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.

The area of Weycock Cross is already overwhelmed with traffic. It would be prefeable if the existing system is set up to allow smooth flow especially at peak times before adding more vehicles into the chaos. I know people who arrive in work 30 to 45 mins early because leaving their homes later means they are caught up in the gridlock. This is not an option for people needing to take their children to breakfast clubs, minders or schools. Public transport serving this are is sparse and to state the train station is only a 35 min walk is derisory.

We have frequent emails from Welsh Water to advise water supply issues. Constant leaks which can take weeks to resolve. Drainage and sewerage issues can only increase with more housing. They are trying to update the pipelines at the same time as dealing with additional pressure on an old system.

The people of Barry all ready experience difficulties getting appointments for medical, inc dental. As it is probably many of the houses will not be going to current Barry residents it stands to reason these services will be stretched to breaking point.
We are constantly being told we need look after green spaces and natural habitats due to the benefits they provide to our well being. These areas help reduce air pollution and a source of mental health well-being.

The additional housing projects in Rhoose, the old college site on the Five mile lane will also have a negative impact on this are.

Most residents of Barry would agree more facilities such as doctors, public transport should be implemented before new housing is built.

Further to our conversation I am writing to ask if you can raise the concerns we spoke of regarding the ´Housing Growth in Barry’ consultation document to the Sennedd. As you know, we and a large number of residents in this north west area of Barry are very concerned about the ramifications that will ensue from a development of 370 new houses opening onto the already gridlocked Weycock Roundabout. This ´pinch point’ lies on a main route between emergency services (fire, ambulance and police) and the airport. Who in their right mind would put further pressure here?

TRAFFIC and AIR POLLUTION
will increase exponentially and the measures the council and developer are proposing will not properly address them. Extra (very narrow) lanes entering the roundabout and a few traffic lights will not stop the gridlock. In fact they could increase it. The backups would extend beyond the lengths of Pontypridd Road, Port Road and ‘Five mile Lane’. They already do - quite frequently - at the slightest traffic hiccup. Despite the council’s assertion that public transport is available, there is none from the roundabout to and from the railway station or town centre. They assert that there are buses. This is not true. If they can lie about this patent untruth, how can we trust any of their or the developer’s ‘studies’. Inevitably the new residents would use their cars to access all services, and walking or cycling from Weycock Cross to station or shops and back is not really feasible. It is a big climb back, and very few residents are capable of it.
The same lack of clear vision and honesty is true for the ‘mitigation packages’ proposed on other matters of serious concern to us:

SERVICES
GP and dental services are already at over capacity in our area. If health and wellbeing are important to this Labour administration, then increasing the load on overstretched services that we all know will not have capacity to meet that demand, would seem cavalier. There will also be need for a considerable number of school places, and those children will need to get to and from school. Secondary schoolchildren can walk if they can safely cross the roads. Traffic lights to enable this will of course cause even longer delays for road traffic. There are no easy answers. For primary pupils it is not walkable. This will mean more cars on the road at extremely busy times.

DRAINAGE and SEWERAGE for Pontypridd Road, St James Crescent and Nant Talwg Way is already inadequate, and tarmacking over a large area of ‘Green Wedge’ which currently helps to drain the heavier rains caused by climate change, will make things worse. Many of us already experience foul smells at times. The system is already failing.

The chosen developers, Persimmon, have shown themselves to be untrustworthy in honouring contracted commitments, as seen in relation to their buildings on the Barry Waterfront. They also have a dismal record on the quality of their construction countrywide. It is widely reported as shoddy. How can it be responsible for a Labour administration to even consider entrusting them not to cause real damage on what is a very sensitive site?

ECOLOGY and BIODIVERSITY
The arguments the council puts out for abandoning the Green Wedge at north west Barry would seem to be spurious, formulated to justify their own backtracking on the reasons upheld for the Wedge in 2015. The loss of green space that housing and hardcore will replace is unforgivable. There will be less uncovered land to drain the increasing heavy rainfall. The impact on biodiversity will also be felt. Loss of habitat is a main reason for the drastic decline in wildlife species countrywide. Bats, field mice, otters, owls, raptors, wood pigeons and skylarks inhabit these fields. Swallows skim them in summer for the plethora of insects. Wrens and other small birds nest in the scrub and hedges surrounding them. From my garden I hear the songs of robins, wood pigeons, blackbirds, dunnocks, tits and goldfinches. Skylarks nest in them all through spring and summer, their songs lifting up into the air above us as they rise. These are endangered red-listed birds. THIS is biodiversity. These Green Wedge fields act as a wildlife corridor, (essential for successful breeding and survival) between the country park and the further landscape. Take it away and it is gone for good. Yet more numbers of species will be lost. Wildlife is not just a luxury. It is the web that supports the health and wellbeing of all creatures on this earth, ourselves included.
(For me, as an artist and a gardener this aspect is close to my heart. Landscape, vegetation and wildlife are key inspirations.)

CONSULTATION
Others within our group, with far better digital skills than I have tell me that the data they offer is flawed and often self-contradictory. And it is here, that the real nub of our complaints becomes apparent. The quantity, complexity, inaccessibility and sheer chaotic organisation of the online consultation process makes it well-nigh impossible for the average resident to navigate and respond to. We struggle to ‘read’ or understand the thousands of pages of graphs and text. It is dispiriting and the cause of significant distress. In truth it is an information dump rather than a consultation. This makes a mockery of democracy and fairness.

I know this is a strong message, and I don’t enjoy having to write it. I and many of my neighbours, who are long time Labour voters, feel betrayed by Labour. This is desperately sad. It’s not the fact that they want to build more housing, we know that is needed, but this is not the right place for it, not for us, or the future people who would live in it. But most of all it is about how the council is so dismissively treating us.

Taylor Wimpey asserts that the current RLDP is "unsound" because it allocates a site (North West Barry) that performs poorly in sustainability and accessibility while overlooking a demonstrably stronger candidate (Land West of Swanbridge Road). They urge the council to replace the North West Barry allocation with the Sully site to better meet the region's housing and sustainability goals.

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.

Vale of Glamorgan Replacement Local Development Plan (RLDP) 2022-2037
Thank you for consulting Welsh Water on the Vale of Glamorgan Deposit LDP, we appreciate and welcome the opportunity to engage in the Local Development Plan process.
Settlement boundaries
SSC1 – development within settlement boundaries
We welcome the requirement for new development to make efficient use of land and benefit from existing infrastructure provision or, where necessary, make provision for new infrastructure without any unacceptable effect on the natural environment (10).
Housing delivery
HG1 - housing allocations
A. Key sites (Policy HG1 KS1-5)
Our representation on the above sites are included in appendix 1.
B. Housing allocations (HG1 (1) to HG1 (9))
Our representation on the above sites are included in appendix 1.
C. Major landbank sites (HG2 (1) to HG2 (5))
These sites are existing commitments and Dwr Cymru Welsh Water has made representations on the planning applications submitted for these sites.
D. Housing led redevelopment opportunity (HG3 (1))
Our representation on the above site is included in appendix 1.
E. Rural affordable housing led sites (HG4 (1) to HG4(4))
Our representations on the above sites are included in appendix 1.
Our representations on the proposed allocated sites are included in appendix 1. Where planning applications have already been submitted and are pending a decision, we have made representations during the planning application consultation process regarding the capability of our infrastructure to accommodate the proposed development. If capacity does not exist within our infrastructure to accommodate the demands arising from a development site, the planning authority can make planning permission conditional upon there being adequate infrastructure available to cater for the development. A developer has a right to connect to our sewerage networks provided that a development site benefits from planning permission and there are no overriding planning conditions attached to the permission that controls the location or timing of that physical connection.
Gypsy and traveller accommodation (GT)
SP9 - gypsy and traveller site provision
Our representation on the site allocation is included in appendix 1.
Retail, commercial and service centres (RCS)
SP12 - retail floorspace provision
Our representations on the site allocations are included in appendix 2.
Community infrastructure (CI)
SP13 - community infrastructure and planning obligations
We support the provisions within the policy that the Council will secure new and improved community infrastructure where appropriate and within a timely manner, and the specific reference to utilities infrastructure. Where existing water and sewerage infrastructure requires reinforcement to serve a development it must be provided as part of the development to mitigate any adverse impacts. In circumstances where the development generates the need for infrastructure improvements that are not programmed for delivery by infrastructure providers then it must be funded by the development. Therefore, it is important for developers to engage early with relevant infrastructure providers, including the statutory sewerage and water undertaker. We welcome that the policy states that improved infrastructure must be undertaken in a timely manner. The delivery of reinforcements to the sewerage and water networks can controlled either through planning condition or a commercial agreement between the developer and Welsh Water.
Adequate potable water supply and drainage infrastructure is key to ensuring new development sites are sustainable, viable and deliverable. Hydraulic modelling assessments (HMA) may be required to determine an adequate point of connection to the water network and/or public sewers, and developers would be strongly recommended to fund investigations at pre-planning stage. Once commissioned and completed the HMA would identify suitable connection points and/or the necessary reinforcement works required to accommodate the development (for example upsizing sewers/water mains, additional storage tanks etc). In certain circumstances surface water removal could be an alternative option for allocations where foul sewer HMAs are being requested, and we would welcome early engagement with the site developer.
The reinforcements required to the network would be established by the HMA and costings would be provided at detailed design stage. The developer would need to fund a scheme by way of the requisition provisions of the Water Industry Act or via a legal/commercial agreement with Welsh Water.
Community facilities
CI3 – new community facilities
Our representations on the site allocations are included in appendix 2.
CI5 - cemetery and crematorium provision
Our representation on the site allocation is included in appendix 2.
Productive and enterprising places
SP14 - employment growth
Our representations on the site allocations are included in appendix 2.
We support sustainable economic development, however the LPA and potential developers should be aware that the obligations of a water and sewerage undertaker only extend to the ‘domestic’ supply part of an employment development (sinks, toilets, kitchen facilities etc). We are not obliged to provide potable water for use in any industrial process. Where an employment development results in higher demands of water supply and/or trade effluent discharge consent, under Section 118 of the Water Industry Act 1991, we recommend and welcome early consultation with developers. The capability of our infrastructure to service future employment allocations will be assessed when the potential demands arising from the developments are known.
EMP1 - employment regeneration opportunity areas
Our representations on the site allocations are included in appendix 2.
Climate change and transition towards net zero (CC)
SP16 - climate change mitigation and adaptation
We are supportive of this policy as the protection of water resources are key in ensuring we maintain a safe, healthy and reliable water supply. Incorporating water efficiency measures into developments will help minimise adverse impacts on localised and wider water supply networks including the quality of water resources.
We are also pleased that the policy includes particular emphasis on the importance of sustainable urban drainage systems (SuDS), in conjunction with Schedule 3 of the Flood and Water Management Act 2010. The tackling of surface water at source is a vital component of sustainable development and will mitigate against overloaded sewers which can ultimately lead to flooding. Disposing of surface water in a sustainable manner by ensuring that it does not communicate with the public sewerage network, including rainwater harvesting systems, protects the environment and assists in ensuring that there is sufficient capacity in the public sewerage network for foul-only flows from development sites.
SP19 – Green Infrastructure
In conjunction with SAB applications, under Schedule 3 of the Flood and Water Management Act 2010, we welcome provision within this policy to integrate green infrastructure with sustainable drainage systems.
Environmental protection
DNP5 – environmental protection
We welcome provisions within the policy to protect the natural environment from unacceptable impact from pollution of land, surface water, ground water and the air as well as flooding risks.
We hope that the above will assist you as you continue to progress the LDP. If you require any further information, then please do not hesitate to contact us on 0800 917 2652 or forward.plans@dwrcymru.com.

Appendix 1 – HG1 Housing Allocations, SP9 Gypsy & Traveller Site
Our representations on site allocations are provided in the table below. The following caveats are applicable to all sites:
• In accordance with the Water Industry Act 1991, Welsh Water retains rights of access to its assets at all times. Where there are sewers and/or water mains crossing sites then protection measures in respect of these assets will be required, usually in the form of an easement width or in some instances a diversion.
• Where insufficient hydraulic capacity exists within the public sewerage network or water supply network to accommodate/serve a development site, hydraulic modelling assessments (HMA) may be required, and developers would be strongly recommended to fund investigations during pre-planning stages. The findings of the HMA will identify the extent of any reinforcement required to accommodate the development, which can be procured via the requisition provisions of the Water Industry Act 1991 (as amended). If the sewerage network system in the locality is currently at capacity, there may be an opportunity to overcome our concerns by delivering a surface water removal scheme. This approach would ensure that there is no net increase in volume of flows communicating with the public sewer network, and therefore no further detriment to the public sewer network downstream of the development.
• In some instances, off-site water mains or public sewers may be required to connect to a suitable point on the existing networks at the developers’ cost. We may seek to control points of connection to the public sewerage network via appropriate planning conditions. Where assets need to be laid over private land, developers will need to comply with the requisition provisions of the Water Industry Act 1991.
• If there is limited or no capacity available at a Wastewater Treatment Works (WwTW), developers may need to fund a Developer Impact Assessment (DIA) to identify required reinforcement works. In these instances, a commercial agreement would be required between the developer and Welsh Water to deliver the necessary reinforcement works.
• Where capacity is currently available in the water supply network to accommodate development, we reserve the right to reassess our position at the time of the formal application for the provision of new water mains under Section 41 and Section 51 of the Water Industry Act (1991) to ensure there is sufficient capacity available to serve the development without causing detriment to existing customers’ supply as demands upon our water systems change continually.
• Please note the below comments are subject to change as the LDP progresses and/or as planning applications are submitted.

See tables in attachment for site specific comments.

Appendix 2 - Employment sites & other uses
Capacity comments for employment allocations can only be provided once the type of development and occupier/end-user of a site is known. Once requirements are confirmed, usually through the planning application process, further assessments will be undertaken. High-level comments are provided in the table below regarding any watermains/sewers crossing the proposed allocations, and the WwTW catchment that the sites are located within.
The following provisions are applicable to all allocated employment sites:
• the obligations of a water and sewerage undertaker extend to ‘domestic’ supplies only. We are not obliged to provide potable water for use in any industrial process. Where an employment allocation results in higher demands of water supply and/or trade effluent discharges we recommend and welcome early consultation with Welsh Water.
• The individual plots available for development can represent a substantial area of land for which the potential demands upon our assets are unknown at present. It is essential that we understand these demands to allow us to assess the impact on our assets. It may be necessary for water and/or sewerage hydraulic modelling assessments (HMAs) to be undertaken at the developer’s expense to establish where the proposed development could connect to the existing networks, and to identify any required infrastructure reinforcement works. Water mains and/or sewerage infrastructure required for any potential development site can be acquired through the requisition provisions of the Water Industry Act 1991 (as amended).
• In accordance with the Water Industry Act 1991, Welsh Water retains rights of access to its assets at all times. Where there are water mains and/or sewers crossing sites then protection measures in respect of these assets will be required, usually in the form of an easement width or in some instances a diversion of the asset.
• Where there is limited or no capacity at a WwTW, dependant on the scale and pace of development, developers may need to fund a Developer Impact Assessment (DIA) to identify required reinforcement works. In these instances, a commercial agreement would be required between the developer and Welsh Water to deliver the necessary reinforcements.
• If any development site gives rise to a new discharge (or alters an existing discharge) of trade effluent, directly or indirectly to the public sewerage system, then a Discharge Consent under Section 118 of the Water Industry Act 1991 is required from Welsh Water. Please note that the issuing of a discharge consent is independent of the planning process and a consent may be refused despite planning permission being granted.

See tables in attachments for site specific comments

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

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

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

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

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