Amount of traffic. Has an air quality survey been done. Airport access. Ambulances.

Objection re: HG1 KS1: Heritage

The RLDP takes a narrow view of ‘heritage’ and I object to the plan outlined in the
Heritage Assessment commissioned by Persimmon (June 2025) because the
assessment is inadequate, does not meet national policy requirements, and therefore
should not be used as evidence to justify allocation of this land for development.
Non-compliance with PPW Edition 12 (2024)
o Failure to assess significance, contrary to PPW Chapter 6: PPW Edition 12 is
clear that planning authorities must protect, conserve and enhance the historic
environment as part of creating “Distinctive and Natural Places.” It emphasises
that heritage assets - designated or not - form part of the cultural well-being of
Wales and must be assessed in terms of significance and impact on that
significance. However the developer’s assessment:
 does not identify the significance of each affected heritage asset
 does not explain how development would affect that significance
 relies solely on distance and visibility rather than the holistic
considerations required by PPW.
This falls well below the standards set by PPW for assessing the historic environment
within the plan-making process.
o There is no consideration of cumulative or incremental harm - PPW requires a
long-term, sustainable approach to placemaking, including the protection of
historic character and the prevention of gradual landscape erosion. However, the
assessment:
 ignores previous historic encroachment on the rural setting of Barry
 does not examine whether further development contributes to
incremental loss of historic landscape
 uses past erosion as justification for more, which directly contradicts
PPW’s placemaking principles.
Non-compliance with Cadw’s “Setting of Historic Assets in Wales” Guidance
o Incorrect definition of setting - Cadw defines setting as the surroundings in
which an asset is understood, experienced, and appreciated, stating explicitly
that setting includes tranquillity, remoteness, historic relationships, topography,
and is not restricted to visibility alone. However, the developer’s assessment:
 treats “no intervisibility” as “no impact”
 ignores experiential qualities such as rural tranquillity, historic context and
landscape coherence
 does not acknowledge that setting is dynamic and may be harmed even
without direct views.
This approach is fundamentally out of step with Cadw’s definition.
Failure to apply the required four-stage setting methodology
o Cadw requires that all heritage assessments follow a structured four-stage
method:
1. Identify the asset
2. Define and analyse its setting
3. Assess the impact of change
4. Consider mitigation
The assessment does none of these, there is:
 no setting analysis for individual assets
 no asset-specific impact evaluation
 no discussion of mitigation
 no documentation of methodology as Cadw requires.
As a result, the assessment cannot be considered robust or policy-compliant.
No asset-specific evaluation despite proximity to multiple historic sites
o There are listed buildings within ~350–420m (Cwm Ciddy Farm) and numerous
designated heritage assets within 1–2 km (Scheduled Monuments, Registered
Historic Parks and Gardens, Conservation Areas). However the assessment:
 simply lists these assets without assessing their setting or sensitivity
 provides no evaluation of how suburban expansion may alter their rural
historic context
 does not recognise the role of the surrounding fields in forming the historic
approach to Barry and Porthkerry
Cadw requires each asset’s setting to be analysed individually, with evidence—this has
not been done.
Unsubstantiated dismissal of the historic landscape value
o LANDMAP identifies the area as part of a Historic Landscape Aspect Area of
“Moderate” value, with surviving regular fieldscapes. The assessment dismisses
this without evidence, claiming the field pattern is “already altered.” However:
 PPW requires recognition of the distinctive historic character of places,
whether designated or not
 Cadw confirms that setting impacts apply to all historic assets, irrespective
of designation.
The assessment provides no justification for disregarding this historic character.
Insufficient information for LDP evidence base, contrary to PPW
o Cadw states developers must provide “sufficient, but proportionate information”
to allow authorities to assess impacts. However, the assessment:
 contains no photomontages
 contains no setting diagrams
 contains no significance analysis
 presents conclusions unsupported by evidence
This is inadequate for LDP allocation and fails the PPW requirement for robust evidence.
Commissioned by the developer – risk of partiality
While it is standard for developers to commission their own heritage work, PPW and
Cadw expect balanced, transparent, and methodologically sound assessments.
Given the clear departures from both PPW and Cadw guidance, the LPA must be
cautious in relying on an assessment commissioned by a party seeking to minimise
constraints.
Conclusion: Heritage evidence is not sound and cannot support allocation
The heritage assessment:
o does not comply with PPW Edition 12 (2024)
o does not comply with Cadw’s Setting of Historic Assets guidance
o does not include adequate evidence to assess impacts
o overlooks cumulative and experiential impacts
o fails to evaluate individual assets or their significance
o presents conclusions unsupported by analysis.
On this basis, the heritage assessment does not pass the soundness test and is
insufficient justification for removal of this land from the Green Wedge, or indeed for its
inclusion for development in the RLDP.

The site should therefore not be allocated within the RLDP.

Objection re: HG1 KS1: Flood Risk and Sustainable Drainage
I object to the proposed development at Weycock Cross, Barry because the developer’s
own Preliminary Drainage Strategy (May 2025, Persimmon) shows that the site has
major flood-risks and future drainage problems that have not been resolved.
Existing surface-water flood risk remains unresolved due to missing data: Although
the site lies within Flood Zone 1, the drainage report confirms that:
o certain areas of the development land are already at risk of surface water
f
looding
o NRW flood mapping shows local watercourse flooding within parts of the
developable area
o critically, NRW’s detailed Product 6 flood data is not available, meaning there is
no numerical assessment of depth, velocity, or hazard rating.
This omission makes it impossible to determine if there is safe access/egress during a
f
lood event, whether proposed levels will displace water, or whether the attenuation
system is correctly sized. Without this essential dataset, no defensible flood-risk
assessment can be completed.
Significant inaccuracies exist between NRW flood maps and surveyed ground
levels: the drainage report acknowledges diAerences of up to 2.5 metres between the
site’s topographical survey and NRW flood model outputs. Such a discrepancy is
extreme - flood models typically operate within tolerances of 0.10–0.25 m, not 2.50 m.
This means:
o the modelled flood outlines may be wholly incorrect
o flooding could be far greater or extend into additional areas of the site
o the identified development platform may not be safe.
A site with such substantial mapping errors should not be advanced to allocation.
The central watercourse must accommodate up to 70.4 litres per second of
discharge, yet its capacity is unknown. The strategy proposes discharging all surface
water from the development into the on-site watercourse at a controlled rate of 70.4
litres per second (l/s). However:
o the downstream culvert has not been surveyed
o no hydraulic modelling has been completed
o no evidence exists to show that either the open channel or culvert(s) can take an
additional 70.4 l/s, let alone the exceedance flows during extreme rainfall.
If this watercourse lacks capacity, the result would be flooding of new homes, existing
homes, or both. Allocating a site before verifying its outfall capacity is unsafe and
contrary to PPW drainage principles.
Soil conditions make the eAectiveness of infiltration SuDS highly unlikely - forcing all
runoA into a constrained ditch. Soilscapes and strategy data show the site is comprised
of slowly permeable, seasonally wet loamy and clay soils, with impeded drainage.
As a result, infiltration rates are expected to be too low to meet BRE365 standards:
o 100% of the developable area’s runoA must be attenuated and discharged to the
watercourse. This places huge pressure on the ditch and culvert, especially
during high-intensity storms.
Reliance on a single outfall in these conditions is high-risk and non-compliant with
SuDS hierarchy best practice.
The development requires extremely large attenuation volumes: over 9,580 cubic
metres; the drainage strategy calculates the required storage for the 100-year + 40%
climate-change storm event as:
o Attenuation volume: 9,580.7 m³
o Storage basin footprint: 8,926 m² (approximately the size of a football pitch)
o Storage base dimensions: 163.6 m × 54.5 m
o Design depth: up to 1.14 m for the 200-year event
The need for such enormous attenuation demonstrates that the land naturally produces
high runoA, that the site is hydrologically sensitive and also that the developable area
must be dramatically reshaped. Such significant engineering intervention is a strong
indicator that the land is not suitable for housing development.
Overland flow from neighbouring farmland already enters the site - the report
confirms that runoA from land outside of the proposed site boundary flows onto the
development area. This means the drainage design must intercept and reroute external
water as well as onsite runoA. Any mis-calculation in flow direction, levels, or
attenuation capacity could:
o push this water towards existing housing
o increase flood risk on site
o cause contaminated exceedance flows to migrate toward sensitive receptors,
including the nearby Ancient Semi-Natural Woodland (ASNW).
This represents a major and unmanaged risk.
Foul drainage is entirely unconfirmed - with all options requiring major oA-site works.
The strategy presents multiple foul disposal options, all of which are speculative and
depend upon:
o pumping stations and rising mains as long as 650 metres
o the need for third-party land agreements
o possible network upgrades
o pending confirmation of capacity from Welsh Water.
This means that even if surface water solutions were viable (which they are not), the foul
network may be unable to support the development, creating further delays,
uncertainty and risk.
In conclusion, the flood risk management strategy is incomplete, with many
critical elements remaining “to be confirmed”.
Key required data and assessments are missing, including:
o BRE365 infiltration testing
o Downstream culvert surveys
o Watercourse capacity assessment
o Full SAB pre-application review
o Confirmation of foul capacity from Welsh Water
o Flood hazard data (NRW Product 6).
A site cannot be allocated when its fundamental drainage viability is still unproven.
The numerical evidence within the developer’s own drainage report confirms that:
o flood mapping is unreliable
o flood-risk data is missing
o outfall capacity is untested
o infiltration is unlikely
o over 9,580 m³ of attenuation is required
o a discharge rate of 70.4 l/s must be imposed on an unmodelled watercourse
o overland flows enter the site from surrounding farmland
o foul drainage has no confirmed solution.
These issues are significant, unresolved, and represent fundamental constraints
that cannot be conditioned away or resolved later. The site should therefore not be
allocated within the RLDP.

The allocation of this land for development is ecologically
unsound and should be removed from the RLDP.

Objection re: HG1 KS1: Green Infrastructure, Recreation Spaces and
Biodiversity
I object to the plan and rationale for removing the Green Wedge designation, as outlined
in Technical Briefing Note – Green Wedge and Landscape Implications of Expanded Site
(and its annexed reports). The paper broadly argues that the land at Weycock Cross is
‘not necessary’ for the Green Wedge to function.
The paper stating that the land is “not necessary” contradicts both the 2015 Inspector
and the LDP. They claim the land is not required for the Green Wedge to function,
because the gap is still 2.28–2.5 km wide. Yet the 2015 Planning Inspector explicitly
found that this site:
o forms an integral part of the pastoral landscape of the GW
o plays a key role in maintaining openness
o development here would be harmful to the Green Wedge’s purpose
PPW is clear that openness, not distance, is the core attribute of a Green Wedge.
Distance alone is not the measure of coalescence. Character, perception, openness,
and containment are. The author misinterprets national policy by reducing it to
kilometres.
The paper uses circular reasoning – it states the edge is “poor quality” so it is
acceptable to build further out. They say that the existing edge is harsh (fences,
gardens) and that moving the settlement edge 200m west would “improve” it.
However, this argument is circular and self-serving:
o They are arguing that an already eroded edge justifies eroding it further
o PPW makes clear that Green Wedges exist precisely to stop incremental outward
creep and urbanisation
o A poor edge strengthens, not weakens, the case for retaining openness and
enforcing settlement containment
It is not logical to argue that because the Green Wedge has already been weakened, it
should be weakened further.
The paper claiming the site is “contained” ignores visibility from multiple public
vantage points. They state development would be visually contained due to landform
and woodland. However their own visual appraisal confirms the opposite:
The site is clearly visible from:
o Cwm Ciddy Lane
o A4226 (major approach into Barry)
o Coed-y-Felin and other elevated residential areas
o All existing properties on the eastward boundary of the proposed development
The Inspector previously confirmed the land:
o has an open, undeveloped character
o contributes to the perception of separation
The land is not visually enclosed in any meaningful sense – it is only partially filtered.
The Technical Briefing Note likewise significantly underplays the site’s importance as
part of a wider connected landscape. They repeatedly describe the site as
“unremarkable” or “low sensitivity”. This contradicts:
o LANDMAP classifications (e.g., High value geological landscape, several
Moderate value other layers)
o The Inspector’s conclusion that the site is a meaningful part of an undeveloped
landscape corridor.
Their argument relies on minimising its landscape value and treating it as an isolated
site. It wholly ignores its role as part of a continuum of open land between Barry and
Rhoose. The Green Wedge designation protects function, not just scenic quality.
The paper also misrepresents the 2011 Green Wedge Background Paper: they argue
the 2011 paper excluded the site and therefore it is evidence the land is unnecessary.
However:
o the 2011 paper was draft evidence, not an adopted designation
o the site was reinserted into the Green Wedge in 2013 during plan refinement
o the Inspector in 2015 accepted the adopted Green Wedge boundary as valid and
sound.
The authors selectively quote from early drafts without acknowledging:
o the plan-making process
o consultation process
o evidence refinement
o Ministerial acceptance of the final boundary
Draft boundaries hold no weight compared to adopted ones and appeal decisions.
The paper’s claim that the development would be a “controlled expansion” contradicts
PPW: PPW requires that Green Wedge removal is justified where normal development
management policies cannot provide the protection needed. But the paper argues the
opposite — that normal policies can control expansion. This is self-defeating:
If normal policies can control development on this site, then Green Wedge protection is
still necessary, because PPW says the wedge should only be removed where normal
policies are insuAicient.
The paper assumes housing need automatically justifies Green Wedge deletion, but
PPW is clear: Housing need alone is not grounds to delete a Green Wedge. A Green
Wedge review must consider:
o functional contribution
o openness
o character
o long-term purpose
o defensible boundaries
Need is only relevant after demonstrating the land is no longer necessary for Green
Wedge purposes. Their justification reverses the policy sequence.
The paper statement “Still 2.5 km left” is a flawed metric. They argue the gap remaining
is still large enough. But Green Wedges do not operate on minimum distances. PPW
states wedges exist to:
o prevent perceived coalescence
o avoid incremental erosion
o maintain long-term openness
Urbanisation on one side of the wedge can significantly change perception even if
substantial distance remains. This is especially important on approach corridors like
Port Road West, and from the existing urban settlement boundary.
The paper overclaims the “logical settlement boundary” argument. They suggest
development would “round oA” Barry. But this is a flawed position:
o True rounding-oA requires strong, defensible boundaries such as roads, rivers,
ridge lines
o Here, the only “boundary” proposed is Cwm Ciddy Lane, a narrow rural lane
masked by hedgerows — not a strategic boundary
o Moving the boundary invites further pressure beyond it, undermining the wedge
in the long term.
This is precisely the pattern Green Wedges are intended to prevent.
The paper significantly downplays precedent risk. The author argues the site is
exceptional. However, if this stretch of Green Wedge is removed, it weakens the entire
designation because:
o the edge becomes arbitrary rather than principled
o cumulative erosion becomes harder to resist
o other landowners will cite this as precedent
This undermines the historic and strategic role of the Barry–Rhoose green wedge.
Harm to irreplaceable Ancient Semi-Natural Woodland (ASNW) Adjacent to the site
I am also registering a formal objection to the proposed allocation of land at North West
Barry based on the findings of the KS1 Preliminary Ecological Appraisal (May 2025,
Persimmon). The site contains multiple high-value and legally sensitive ecological
receptors - development here would result in significant, unavoidable, and
policy-contrary ecological harm, which cannot be mitigated to acceptable levels.
The eastern/southeastern boundary of the site directly adjoins the North East of Knock
Man Down Wood (Site of Importance for Nature Conservation), which is also listed as
Ancient Semi-Natural Woodland (ASNW). ASNW is classified as an irreplaceable
habitat with uniquely high biodiversity, cultural, and soil value. The PEA confirms that
this woodland supports:
o a rich canopy of Ash, Sycamore, Sessile Oak, Beech and Yew
o a structurally diverse understorey
o a strong suite of ancient woodland indicator species
The appraisal explicitly notes that the woodland must be retained and protected with a
suitable buAer and is highly vulnerable to lighting impacts, trampling and recreational
pressure, hydrological changes and surface water pollution.
Development in such immediate proximity contradicts PPW protections for ancient
woodland and would inevitably cause deterioration through edge eAects, disturbance,
drainage changes, and increased human pressure. These long-term eAects would be in
addition to the hugely detrimental impact of several years of housebuilding activity with
associated noise, dust and general disturbance.
Loss and Fragmentation of Priority Hedgerows and Ecological Corridors
The site contains a network of native hedgerows (several of them species-rich), all
classified as Priority Habitats under Section 7 of the Environment (Wales) Act 2016.
These form:
o bat commuting corridors
o dormouse movement routes
o nesting habitat for tree/shrub nesting birds
o foraging, basking and sheltering habitat for reptiles and amphibians
The PEA states that future development will require hedgerow breaches, which directly
threatens habitat connectivity across the site. Such fragmentation is explicitly contrary
to the PPW requirement to maintain and enhance ecological networks.
Significant Adverse Impacts on Bats
The appraisal identifies multiple bat species using the site, including:
o Common and Soprano Pipistrelle
o Noctule
o Whiskered, Daubenton’s and Serotine
o Brown Long-eared Bat
A day roost is located less than 50m away, and key linear features such as hedgerows,
the woodland edge and the central wet ditch act as primary commuting corridors.
Development would cause:
o Loss/breaching of critical flight lines
o Introduction of artificial lighting that disrupts foraging and commuting
o Potential loss of a mature Ash with high roost potential (PRF-M)
Lighting impacts cannot be fully mitigated within a residential estate and would severely
degrade the ecological function of the site and adjacent woodland.
Risk to Hazel Dormouse, a European Protected Species
A Dormouse nest was recorded within the site in 2013, and the appraisal confirms the
hedgerows and woodland edge:
o provide suitable food sources
o have suAicient structure
o connect directly to high-quality woodland habitat capable of supporting a
population
Any hedgerow loss, lighting spill or disturbance could compromise this species.
Dormice and their resting places are strictly protected under the Habitats Regulations.
Badger Disturbance and Habitat Fragmentation
Evidence of Badger activity included:
o A fresh latrine
o Well-used pathways
o Badger guard hairs under fences
The survey concludes the site lies within the home territory of a Badger clan and is used
for foraging and movement. Development would disrupt these routes and increase risk
of harm during construction.
Impacts on Otters and the Local Water Environment
Otters were observed (fresh footprint) in the central wet ditch and frequently recorded in
the nearby Nant Talwg watercourse. In addition, otter carcasses have been found and
photographed on or near the perimeter of the site as recently as February 2026,
indicating an ongoing and active presence at the site. The central ditch mentioned in the
report is likely used as a commuting link between the water courses bounding the
northern and southern areas of the site, despite seasonal drying.
The appraisal warns of pollution risks from construction and drainage changes, and
lighting impacts that could disturb nocturnal movement.
Any development introduces an unavoidable risk of degrading the existing active otter
habitat.
Loss of Ground-Nesting Bird Habitat (Including Skylark, a Section 7 Priority
Species)
Multiple species were recorded, including Skylark, Song Thrush and House Sparrow,
all Section 7 Priority Species. The open fields may support ground nesting birds later in
the season. Development would:
o remove nesting habitat
o increase predation and disturbance
o cause irreversible loss of farmland bird territory
Impacts on Reptiles, Amphibians and Invertebrates
Field margins, the wet ditch, hedgerows and woodland edge support:
o Slow Worm
o Common Frog
o Amphibian foraging habitat
o Priority invertebrates (in adjacent woodland)
These habitats would be permanently lost or degraded.
Conflict with the B-Lines Pollinator Network
The southern part of the site lies within the national B-Lines network, designed to
safeguard insect movement across fragmented landscapes. Development would
remove this stepping-stone habitat and break the corridor.
The Site Cannot Deliver PPW’s Required ‘Net Benefit for Biodiversity’
Under PPW Edition 12 (2024) and recent Chapter 6 updates, all development must
deliver a net benefit for biodiversity and apply the stepwise approach (avoid →
minimise → mitigate → compensate). According to the PEA:
o the most sensitive habitats are at the boundaries
o these same boundaries are where the greatest development pressure will fall
o development would inevitably cause loss and deterioration of habitat
connectivity and introduce artificial lighting and disturbance
Given the site context, it is not possible to avoid or fully mitigate harm, despite a
blithe assurance in HG1 KS1 that “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
buAer to the adjoining SINC at Mill Wood and oAer opportunities for significant
biodiversity enhancements.” To somehow suggest that simply by leaving a small
area of open space while building 376 houses on an already-biodiverse greenfield
site will in any way make a net contribution to biodiversity is utterly false.
The PEA clearly demonstrates that the site contains:
o multiple Priority Habitats
o several legally protected species
o an adjoining irreplaceable ancient woodland
o key ecological corridors of regional significance
Development would lead to unavoidable ecological harm, contrary to:
o Planning Policy Wales (PPW) Edition 12
o The Environment (Wales) Act 2016, Sections 6 & 7
o TAN 5: Nature Conservation & Planning
o Local LDP policies SP10, MG20, MG21 and MD7
For these reasons, the allocation of this land for development is ecologically
unsound and should be removed from the RLDP.

Objection re: HG1 KS1: Sustainable Transport and Highways
I object to the inclusion of land at Weycock Cross (North West Barry) being included in
the RLDP because of the impact on congestion, air and noise pollution and the lack of
viable active travel and public transport options. Review of the RLDP supporting
documents evidence base exposes clear contraventions with PPW12 (Chapter 6), TAN
18 and Well-being of Future Generations Act.
Across all three RLDP Strategic Transport Assessment documents (BP14 Strategic
Transport Assessment - Stage 1 / BP14A Strategic Transport Assessment - Stage 2 /
Persimmon Homes/Asbri Draft Transport Assessment) the data, modelling and
conclusions contained within demonstrate that:
Congestion:
o Weycock Cross already operates close to capacity (RFC >0.8) at peak times of
day and will frequently operate over capacity in future as a result of the proposed
RLDP development, even if only the North West Barry site is considered. In its
own modelling, BP14A explicitly shows critical failure in the 2036 RLDP scenario.
o Likewise, the Persimmon Draft Transport Assessment accepts that with the
committed development, traAic levels at Weycock Cross will be “extreme and
unacceptable” and “over capacity”, yet still concludes the North West Barry
site’s impact is “marginal and inconsequential” when taken in the context of the
wider RLDP traAic increase. This is a circular argument (‘more traAic elsewhere
means the negative eAect of one site is proportionately less significant’) is
patently flawed, and contradicts PPW/Future Wales policy focus on reducing
traAic growth and car dependency, not perpetually enlarging junctions.
o TAN 18 and PPW require consideration of cumulative impacts and whether the
network is already at or near capacity - the assessments use small percentage
increases in traAic load (1.3–3.4% from North West Barry alone) to downplay
impact, while ignoring that even small increases can tip an already failing
junction into severe congestion.
o Overall, there is a significant risk that the proposed traAic congestion mitigation
measures will fail to deliver the necessary benefits, nor will they be delivered
before occupation, leaving all residents (new and existing) with years of
unacceptable congestion.
Data quality and modelling validity:
o TraAic modelling data is incomplete, inadequately validated, and
methodologically inconsistent: for instance, the entire Persimmon Draft
Transport Assessment is based on a single day’s traAic data in September 2023.
Likewise, the BP14/BP14A Transport Assessments provide no details on how or
when data was gathered, questioning the validity and provenance of that data.
o The required North West Barry site signalised access junction has not been
assessed cumulatively, leaving a material evidence gap, meaning impact on
traAic congestion is likely to be significantly worse than the modelling suggests
(while the TA talks about “platooning” and better control, the linked junction
modelling indicates that signals inevitably prioritise site traAic while increasing
delays on Port Road, rapidly pushing the wider network close to or beyond
capacity).
Air Quality Assessments:
o No AQA (air quality assessments) are referenced in any of the three TA
documents, despite clear congestion and policy triggers. This directly
contravenes PPW12 (Chapter 6), TAN 18 and Well-being of Future Generations
Act and this alone means the proposed Weycock Cross development is not
suitable for inclusion in the RLDP.
Active Travel/sustainable transport:
o Active travel provision in the plan is weak, indicative, and non-compliant with
statutory requirements, and does not take into account the inherent location and
topology of the site (a long 30-40-minute uphill walking route from nearest train
station).
o The Deposit plan states that land at North West Barry has “bus stops in close
proximity providing buses to Llantwit Major, CardiA and the centre of Barry” yet it
fails to mention that none of the bus services provide a meaningful way of getting
anywhere useful for those commuting to a place of work. For example, bus
service B2 runs hourly starting at 09.42 and ending its service at 15.52.
o Likewise, no existing bus services connect Weycock Cross with Barry train
station at any times of day. Whilst developers can promise up front to fund
additional bus services in future, this is not guaranteed, and public finances will
not be able to make up the gap. How is this suitable for anyone, let alone people
commuting to and from work?
o The Draft Transport Assessment does not really test whether this greenfield,
edge-of-Barry site can genuinely support a sustainable pattern of trips
(frequency, quality and directness of bus, walk and cycle links to key
destinations, particularly the commuter hub of Barry train station). It jumps
quickly from trip rates to junction modelling; PPW and TAN 18 expect a
sequential approach: location and accessibility first, then network impacts—
especially for greenfield housing that risks locking in car-based travel patterns
and dependency.
How can it be claimed that I have been consulted on this critical issue when there
are so many gaps and clear anomalies in the strategic transport assessment
information that I am required to consider?

HG1 KS1 North West Barry (Weycock Cross)
RLDP Strategic Transport Assessments: BP14/BP14A/KS1 Draft TA (Asbri) Data-Based Objection

Ref: NWB_RLDP_JVN_008: RLDP public consulta on feedback (Data-Based Objection) on the
three key strategic transport assessments provided within the RLDP consulta on portal.
This RLDP consulta on feedback (objection letter) focuses on several key areas of contradiction
between the following documents with current transport planning policy (PPW, TAN18 etc).
 BP14 Strategic Transport Assessment – Stage 1 RLDP “Supporting Documents” (Nov 23)
 BP14A Strategic Transport Assessment – Stage 2 RLDP “Supporting Documents” (Dec 25)
 Dra Transport Assessment KS1 “Supporting Informa on” Persimmon Homes/Asbri transport
report (May 25)
This objection focuses specifically on the full strategic transport picture across all three STAs listed
above which were available for public review on the RLDP website, highlighting the following
concerns:
Weycock Cross conges on, the NWB signalised access, Active Travel provision, the quality and
reliability of traffic modelling inputs, and the absence of air-quality assessment data.
1. Severe and Quantified Congestion Impacts at Weycock Cross Roundabout (J16)
1.1 Baseline and Future Opera on (BP14/BP14A Findings):
BP14A shows that Weycock Cross is already opera ng close to capacity (even without accounting
for proposed strategic housing):
 Base RFC = 0.88 in both AM and PM peaks → “nearing practical capacity..”
When RLDP traffic, including the North West Barry (NWB) site, is added:
 RLDP RFC rises to 1.02 (AM) → over capacity = uncontrolled queueing at peak mes
 RLDP RFC rises to 0.97 (PM) → very close to failure
 Junc on delay doubles in both peaks, indica ng unstable opera on and significant
queuing..
1.2 Strategic Modelling Impacts (BP14A – SEWTM) and selective use of the TAN18 5% threshold:
SEWTM modelling (Technical Note 05) identifies significant percentage increases in total traffic
flows at Weycock Cross resulting from RLDP strategic growth:
 +7.2% AM
 +12.2% PM
These exceed the TAN18 threshold for requiring detailed modelling.
 The Dra Transport Assessment (TA) cri cises other TAs for not modelling arms with >5%
impact (quo ng TAN 18 Annex E), but then uses low percentage increases (1.3–3.4%) to
argue its own impact is negligible, despite RFCs >1.0 and acknowledged severe conges on.
 That is internally inconsistent with the focus of TAN 18, which explicitly notes that where
capacity is or nearly exceeded, even smaller increases are normally material
1.3 Conclusion – conges on modelling:
The Council’s own BP14A Stage 2 evidence directly contradicts the Dra Transport Assessment
(Persimmon Homes) and demonstrates that NWB materially worsens conges on in all directions
at the area’s most constrained junction.
The BP14/BP14A and Dra TA documents all downplay cumulative impact while acknowledging
severe future conges on
The Persimmon Dra TA accepts that with committed development, Weycock Cross will be
“extreme and unacceptable” and “over capacity”, yet still concludes the site’s impact is “marginal
and inconsequential”.
TAN 18 and PPW require consideration of cumulative impacts and whether the network is already
at or near capacity—small percentage increases can s ll be material where junctions are stressed
2. Impact of Proposed Signalised Access for NWB on the A4226
2.1 Proposed signalised junction
The Dra Transport Assessment (Persimmon Homes):
 Proposes a signalised junction
 Provides no network or corridor-wide analysis
 Provides no LinSig modelling
 Does not demonstrate compliance with the Welsh Government Roads Review (which limits
new capacity for general traffic)
2.2 Modelling Uncertainty and Omission (BP14A)
BP14A states that the interaction between the NWB access junction and Weycock Cross has not
been assessed within the TN06 modelling, because the applicant has not yet provided a full
junction design or modelling package. This omission introduces a significant gap in the cumulative
assessment.
2.3 Expected Operational Effects
A new signalised access on A4226 would:
 Introduce a new stopline on the corridor already under heavy peak pressure.
 Increase stop–start conditions, which worsens emissions (see Sec on 6).
 Alter flow profiles entering Weycock Cross, likely exacerbating queues on the A4226
eastbound and westbound arms.
Given that Weycock Cross is already over capacity, any upstream signalisation will further degrade
performance.
Conclusion: The NWB access junction has not been assessed cumulatively, and the omission likely
leads to material underestimation of network impacts.
3. Active Travel: Provision Limited, Non-Compliant, and Not Evidence-Based
3.1 BP14A Requirements
Mi ga on schemes must promote active travel in accordance with:
 Active Travel (Wales) Act 2013
 Wales Transport Strategy 2021
BP14A includes indicative active travel elements in mi ga on layouts (e.g., crossings, shared-use
links) but fails to provide any detail.
3.2 Weaknesses and Uncertainty Identified in BP14A
BP14A explicitly states that:
 Schemes are indicative only
 Subject to further design and land acquisition
 Dependent on funding and developer contributions
There is no guarantee that these facilities will be provided, or that they will be delivered before
occupation. In addition, the Weycock Cross site is in a location which is a steep uphill 30-40 minute
walk from the nearest train station, meaning any Ac ve Travel measures which are intended to
mi gate the site-generated traffic will have li le (if any) impact on commuting traffic increase.
3.3 Applicant TA Fails to Provide Active Travel ATAG-Compliant Evidence
The Persimmon Dra TA includes:
 No Active Travel Audit
 No ATAG compliance assessment
 No detailed geometric designs
 No crossing delay analysis, desire-line mapping, or route con nuity assessment
This makes it impossible to demonstrate compliance with Active Travel statutory du es.
4. Quality, Reliability and Limitations of Modelling Data
4.1 Poor quality base data used as the basis for the Dra Transport Assessment (Persimmon
Homes)
The Dra Transport Assessment (Persimmon Homes):
 Uses one day of turning counts (12 Sept 2023, 07:00–19:00)
 Uses pro-rata trip assignment
 No weekend or seasonal data
 TEMPro-only growth
 Does not include SEWTM routing
 Does not model cumulative RLDP-wide impacts
This does not satisfy modern Welsh transport appraisal requirements.
This results in a systema c underesmation of all movements at the junction.
4.2 Uncertain quality of base data used as the basis for the BP14/BP14A
BP14 and BP14A provide no details on how/when or where the base data for the reports was
gathered. This significantly reduces confidence in the outcomes and conclusions of those reports.
4.3 BP14A – Iden fied Limita ons in SEWTM Outputs
BP14A states:
 SEWTM has limited local validation in the Vale
 Some junctions are only par ally represented
 Traffic assignment may use minor links unrealistically
 The model includes no modal shift , demand suppression, or peak spreading
 Results should be interpreted with caution due to missing local constraints
These limitations lead to an under-prediction of congestion.
4.4 Data Sources Used in BP14A
 SEWTM 2022 base year data
 Supplementary traffic surveys for some junctions
 Factoring using TEMPro growth
However, key surveys for Weycock Cross came from other developments (e.g., Readers Way TA)
5. Cumulative Impacts and Risk of Infrastructure Lag
5.1 BP14A Mi ga on Costs
Mitigation measures are proposed at three junctions totals £5.2 million, with £3.8m to be funded
via developer S106 contributions. NWB is apportioned £410,835 at Weycock Cross.
5.2 Delivery Risks
BP14A states that:
 Mi ga on schemes are not yet designed,
 Claimed benefits from modelling data are not robust
 Not funded in full,
 Require land, design, statutory consulta on, and
 May not be delivered before development is occupied.
Note: Persimmon Homes, the North West Barry site developer, have a track record of failing to
deliver on promised S106 highway improvement measures at other sites, in some cases resulting in
legal enforcement ac on for years a er building work has been completed.
Therefore, there is a high risk of significant conges on long before mi ga on is operational.
6. Air Quality: No Reference to any Assessments Carried Out (Major Omission)
6.1 BP14, BP14A and Persimmon Dra TA
None of the three documents include any reference to an Air Quality Assessment (AQA).
6.2 Conflict with Policy Requirements
Under:
 PPW12 (Chapter 6)
 TAN 18
 Well-being of Future Generations Act
An AQA is required where development:
 Increases traffic,
 Worsens conges on,
 Increases stop–start condi ons,
 Produces emissions at sensi ve receptors.
BP14A shows:
 Weycock Cross → AM over-capacity, PM near-capacity
 J22 → +13.6% AM / +18.3% PM traffic increase
 Even with best-case mi ga on measures → stop–start condi ons remain
Thus, the absence of any AQA for the proposed Weycock Cross development is a fundamental
evidence gap which means the proposed Weycock Cross development is not suitable for
inclusion in the RLDP.
Overall Conclusion
Across all three RLDP Strategic Transport Assessment documents (BP14 Strategic Transport
Assessment - Stage 1 / BP14A Strategic Transport Assessment - Stage 2 / Persimmon Homes/Asbri
Dra Transport Assessment) the evidence demonstrates that:
 Weycock Cross will operate over capacity because of the cumulative development, even if
only North West Barry is considered. BP14A explicitly shows failure in the 2036 RLDP
scenario. The assessments use small percentage increases (1.3–3.4%) to downplay impact,
while ignoring that even small increases can p an already failing junction into severe
conges on.
 The North West Barry signalised access junction has not been assessed cumulatively,
leaving a material evidence gap, meaning impact on traffic conges on is likely to be even
worse than the modelling suggests.
 Ac ve travel provision in the plan is weak, indicative, and non-compliant with statutory
requirements, and does not take into account the location and topology of the site (long
uphill route from nearest train station, etc)
Traffic modelling data is incomplete, inadequately validated, and methodologically
inconsistent. The Persimmon Dra Traffic Assessment is based on a single day’s data in
September 2023. Likewise, BP14/BP14A provide no details on how or when data was
gathered.
 No air quality assessments are referenced in any of the three documents, despite clear
conges on and policy triggers. This directly contravenes PPW12 (Chapter 6), TAN 18 and
Well-being of Future Genera ons Act and this means the proposed Weycock Cross
development is not suitable for inclusion in the RLDP.
 There is a significant risk that traffic congestion mitgation will not be delivered before
occupation, leaving users with years of unacceptable conges on.
When all the above concerns are taken into account, this constitutes a robust, evidence-backed
basis for objection.

1. Infrastructure: Bottleneck would spring to mind. There is insufficient access onto Port Road from the development (Land at North West Barry). Cars will not be able to cross over onto the road site reading to Cardiff. Port Road is already heavily used by transportation from + to the airport/Rhoose village. There would be definitely be numerous accidents. 2. Doctors surgeries-over subscribed now. Over subscribed-people unable to secure now appointments. This would add more over stretched services with the added 370 houses+ residence. 3. Green Land Impact on Wildlife. DNP2-Green land wedge, not considered and the effect on the wildlife/species. 4. Land previously refused to be built on in 2013 by the local authority who objected to the proposal of 140 homes + the councillor etc. are still in power now + supposidly serving the community. 5. Schools-Schools are not equipped to take on the extra capacity of extra candidates. 6. Should be looking to build homes for the older/single generation. 7. Barry Town itself. Does not have the facilities, town/shops to offer to us let alone extra footfall, unless you want a barber or coffee. Town has been run down, and yet Barry is supposed to be the largest town in Wales. 8. The disruption of building works to residents. Lorries delivering material. Removing material. Road works/blockages/accidents. Mud on the road. Noise to the residents. Safety problems. Too many vehicles on the roads, traffic jams. Barry over subscribed with population. Facilities not in place to support the extra population. People have a right to transparency.

The allocation of land at North West Barry (HG1 KS1) is not supported by robust, policy-compliant transport evidence and should therefore be removed from the RLDP.

HG1 KS1 North West Barry (Weycock Cross)
KS1: Sustainable Transport and Highways
HG1 KS1: Sustainable Transport and Highways
Ref: NWB_RLDP_JVN_002
I object to the allocation of land at Weycock Cross (North West Barry) within the RLDP due
to the unacceptable impacts on conges on, air quality, noise, and the absence of viable
active-travel and public-transport options.
A detailed review of the transport evidence base— Persimmon Homes/Asbri Dra
Transport Assessment, BP14 Strategic Transport Assessment (Stage 1) and BP14A Strategic
Transport Assessment (Stage 2)—reveals clear inconsistencies with Planning Policy Wales
(PPW) Edi on 12, TAN 18, and the Well-being of Future Generations (Wales) Act according to
the following criteria:
1. Congestion
Weycock Cross already operates close to capacity (RFC > 0.8) during peak periods. Modelling
within BP14A demonstrates that, under the RLDP scenario, the junction will frequently
operate over capacity, with critical failure predicted even when only the contribution of the
North West Barry site is considered.
The Persimmon Dra Transport Assessment acknowledges that, with committed
development, traffic conditions at Weycock Cross will be “extreme and unacceptable” and
“over capacity”. Despite this, it concludes that the North West Barry site’s impact is
“marginal and inconsequential” when viewed in the context of wider RLDP growth. This
reasoning is circular: the presence of significant traffic growth elsewhere does not diminish
the material impact of this site. PPW and Future Wales prioritise reducing traffic growth and
car dependency, not expanding junction capacity.
TAN 18 and PPW require cumulative impacts to be assessed, particularly where the network
is already stressed. The HG1/KS1 assessments rely on small percentage increases (1.3–3.4%
from North West Barry alone) to downplay the site’s impact, while disregarding the fact that
even minor increases can push an already failing junction into severe congestion.
There is a substantial risk that proposed mi ga on measures will not deliver the required
improvements, nor will they be implemented before occupation. This would leave both new
and existing residents facing prolonged periods of unacceptable conges on.
2. Data Quality and Modelling Validity
The transport modelling is incomplete, weakly evidenced, and methodologically
inconsistent. The Persimmon Dra Transport Assessment relies entirely on a single day of
traffic data collected in September 2023, while BP14 and BP14A provide no information
regarding how or when their data was gathered, raising concerns about validity,
representativeness, and provenance.
The required signalised access junction for the North West Barry site has not been assessed
cumulatively and no network or corridor-wide analysis is included. This omission represents
a significant evidence gap; while the TA refers to “platooning” and improved control, the
linked-junction modelling indicates that signalisation will inevitably priori se site traffic and
increase delays on Port Road, pushing the wider network close to or beyond capacity.
Introduction of a signalised access junction would increase stop–start conditions, not only at
the junction but at Weycock Cross roundabout and the feeder roads beyond, leading to
increased vehicle emissions and noise.
3. Absence of Air Quality Assessment
Despite the consequential increase in pollution the development will incur, none of the
three Transport Assessments include or reference any Air Quality Assessment (AQA), despite
clear policy triggers and acknowledged existing congestion at Weycock Cross. This omission
directly contravenes PPW12 (Chapter 6), TAN 18, and the Well-being of Future Generations
Act.
The absence of air-quality assessment evidence alone renders the proposed allocation
unsound and unsuitable for inclusion in the RLDP.
4. Active Travel and Sustainable Transport Deficiencies
Active-travel provision is weak, indicative, and non-compliant with statutory requirements.
The assessments fail to account for the site’s inherent constraints, including its topography
and distance from key destinations. The nearest train station is a 30–40-minute uphill walk,
making walking a completely impractical op on for most residents.
The Deposit Plan states that the site “benefits from bus stops in close proximity providing
buses to Llantwit Major, Cardiff and the centre of Barry”. However, it omits the fact that
these services do not provide meaningful commuting options. For example, the B2 service
operates hourly, beginning at 09:42 and ending at 15:52—unsuitable for commuting to work
or education, while none of the existing bus services connect Weycock Cross with Barry train
station at any me of day. While developers may propose or even promise to fund new
services under S106 agreements, such commitments are not guaranteed, and public
finances cannot be relied upon to sustain them.
The Persimmon Dra Transport Assessment does not adequately test or evidence whether
this greenfield/Green Wedge, edge-of-town site can support a sustainable pa ern of travel.
It moves rapidly from trip rates to junction modelling without assessing the frequency,
quality, or directness of bus, walking, or cycling routes to key destinations. PPW and TAN 18
require a sequential approach: accessibility and location first, followed by network impacts.
5. Conclusion
Given the substantial gaps, inconsistencies, and methodological weaknesses in the transport
evidence base, it cannot reasonably be claimed that meaningful consulta on has taken place
on this critical issue. The allocation of land at North West Barry (HG1 KS1) is not supported
by robust, policy-compliant transport evidence and should therefore be removed from the
RLDP.

HG1 KS1 North West Barry (Weycock Cross)
KS1: Community Infrastructure
HG1 KS1: Community Infrastructure
Ref: NWB_RLDP_JVN_005
I object to the proposed allocation of Land at North West Barry (HG1 KS1) on the basis of
significant deficiencies in the RLDP’s evidence base relating to community infrastructure,
including healthcare, active travel, environmental health, social cohesion, and education. A
detailed review of BP37 – Primary, Community & Intermediate Health Care, BP3 – Rapid
Participatory HIA of the Preferred Strategy (2023), and BP3A – Rapid Participatory HIA of the
Deposit Plan (2025) demonstrates that the RLDP does not provide a credible or deliverable
strategy for supporting the level of growth proposed.
1. Healthcare Infrastructure
The Deposit RLDP does not demonstrate that sufficient primary or community healthcare
capacity will be delivered in parallel with new development. BP37 – Primary, Community &
Intermediate Health Care identifies extensive pressures within the Cardiff & Vale University
Health Board (CAVUHB) area, including:
 long secondary-care waiting times
 rising prevalence of long-term conditions
 a 24% increase in registered population since 2015
 significant growth in the 65+ population
 workforce shortages and premises constraints
 dental access challenges and mental-health pressures
Despite this, BP37 contains no mi ga on strategy, no delivery programme, and no capital
plan. It provides:
 no costs, funding sources, or commitments on capital investment
 no timelines or delivery windows
 no list of healthcare infrastructure projects
 no agreed expansion of GP practices or primary-care hubs
 no detail on S106 or CIL contribution mechanisms
 no phasing triggers linked to housing delivery
The document is descriptive rather than strategic. It identifies risks but provides no
solutions.
Cross-boundary pressures are acknowledged but not addressed. BP37 notes that residents
in eastern and western Vale frequently access healthcare in Cardiff or Cwm Taf Morgannwg,
yet there is no evidence of joint capacity modelling or agreed service expansion.
The RLDP therefore fails three key tests of soundness:
 CE2 – Coherence and Effectiveness
 CE3 – Deliverability
 CE4 – Consistency with National Policy (PPW)
The HIAs reinforce these concerns. Both BP3 (2023) and BP3A (2025) warn that if
development proceeds without simultaneous delivery of GP, social-care, open-space, and
community facili es, significant nega ve health impacts will occur and car dependency will
increase.
For North West Barry specifically, the nearest GP prac ce (Highlight Park) is already
oversubscribed. The HIAs highlight the risk that early phases of development will outpace
healthcare capacity, reducing access for both new and existing residents.
The only mi ga on referenced is a vague commitment to “an off-site financial contribution
towards the provision or enhancement of community facilities in the area”. This is
insufficient, lacks certainty, and is likely to be delivered a er need has arisen.
2. Social Cohesion
The HIAs emphasise the importance of social cohesion, community space, and safe public
realm. The constraints of the North West Barry site make these outcomes unlikely.
The 2025 HIA warns against “designing out” legitimate social interaction and stresses the
need for inclusive, intergenerational public spaces. The 2023 HIA highlights that poorly
designed developments can increase isolation and exacerbate inequality.
North West Barry is:
 a peripheral, edge-of-town site
 severed from established neighbourhoods by major roads
 weakly connected in terms of permeability and natural movement pa erns
These characteristics create a high risk of a socially disconnected, car-dependent estate.
3. Active Travel and Environmental Health Risks
The HIAs emphasise that active-travel routes must be safe, direct, continuous, and attractive.
The North West Barry site cannot meet these requirements due to:
 severance by major roads, particularly the A4226
 topography that places the site a 30–40-minute uphill walk from the nearest train
sta on
 reliance on the already-congested and unsafe Weycock Cross junc on
The 2025 HIA states that active-travel routes must be well-lit, inclusive, and designed as the
easiest and most attractive op on. The complete unsuitability of the North West Barry site
for any Active Travel links, particularly those that aim to link residents to commuter hubs
such as Barry train station, mean that car dependency is baked-in to the site from day one.
The 2023 HIA highlights that behaviour change is extremely difficult where car dependency
is entrenched.
The HIAs identify the following risks:
 major junctions without transformational redesign deter walking and cycling
 active-travel routes along high-traffic corridors expose users to air pollution and
noise
 arterial road severance undermines walkability
 cumulative environmental hazards require strong mi ga on
None of these risks can be adequately mi gated at this site. The location directly adjoins the
A4226 and Weycock Cross—one of the Vale’s most congested junctions. Exposure to
transport-related air pollution and noise is therefore inherent and unavoidable, not only for
new residents of the development, but even more so for existing residents.
Furthermore, none of the three Transport Assessments in the RLDP evidence base include
an Air Quality Assessment, despite clear policy triggers. This omission is incompatible with
PPW12, TAN 18, and the Well-being of Future Generations Act.
4. Summary
The site is structurally incapable of supporting the health-enabling placemaking required by
SP4 and the HIAs. The allocation of North West Barry conflicts with:
 Health Inequality Mi ga on: No guaranteed uplift in healthcare services.
 Environmental Health Requirements: Exposure to air pollution and noise.
 Active Travel Requirements: Inability to deliver safe, direct, attractive routes.
 Infrastructure Phasing: No certainty that healthcare, education, or community
facilities will be delivered in me.
 Social Cohesion: Severance and poor permeability undermine inclusive placemaking

HG1 KS1 North West Barry (Weycock Cross)
Objection-Transport Assessment – Modelling Addendum’
(Asbri Transport, for Persimmon Homes)
Displayed on OC2 website KS1 as: “Draft Transport Assessment” Filename on same: “Draft TA with Appendices_Redacted.pdf”

Ref: NWB_RLDP_JVN_009: RLDP public consulta on feedback on ‘North West Barry Transport
Assessment – Modelling Addendum (May 2025)’ (KS1 ‘Supporting Informa on’ Persimmon
Homes/Asbritransport report)
This RLDP consulta on feedback focuses on key areas of contradiction between this document
with current transport planning policy (PPW, TAN18 etc).
1. Overall approach: capacity-first, car-first
 Contradiction: focus on junction capacity, not demand reduction or modal shift
The Dra Transport Assessment is almost entirely framed around ratio of flow to
capacity (RFC)/degree of saturation (DoS), queues and “spare capacity” at Weycock
Cross, with success defined as accommodating extra car trips and “marginal and
inconsequential impact” on delay. PPW and TAN 18 require integra on of land use and
transport to reduce the need to travel by car, priori se sustainable modes, and use
demand management rather than simply expanding capacity.
 Contradiction: treating congestion as a problem to be ‘engineered away’
The document repeatedly treats existing conges on as something to be relieved by extra
lanes, slip roads and signalisation, rather than asking whether additional car-based
development at this location is compatible with decarbonisation and modal shift
objectives. PPW/Future Wales emphasise reducing traffic growth and car dependency,
not perpetually enlarging junctions.
2. Treatment of cumulative impact and “inconsequential” language
 Contradiction: downplaying cumulative impact while acknowledging severe future
congestion
The Draft Transport Assessment accepts that with the committed development, traffic
levels at Weycock Cross will be “extreme and unacceptable” and “over capacity”, yet s ll
concludes the site’s impact is “marginal and inconsequential”. TAN 18 and PPW require
consideration of cumulative impacts and whether the network is already at or near
capacity—small percentage increases can still be material where junctions are stressed.
 Selective use of the 5% threshold
The Dra Transport Assessment criticises other TAs for not modelling arms with >5%
impact (quo ng TAN 18 Annex E), but then uses low percentage increases (1.3–3.4%) to
argue its own impact is negligible, despite RFCs >1.0 and acknowledged severe
conges on. That’s internally inconsistent with the spirit of TAN 18, which explicitly notes
that where capacity is or nearly exceeded, even smaller increases are normally material.
3. Junction “enhancements” vs policy on induced traffic and placemaking
 Contradiction: proposing extra capacity (slip lanes, longer lanes, bypass) as primary
mi ga on
The Draft Transport Assessment’s main mitigation is more road capacity: extended left
turn lanes, a free-flow le slip, and signalised junction to facilitate safe site access. PPW
and TAN 18 stress that engineering new road capacity with the sole aim of reducing
conges on can induce traffic and is generally contrary to sustainable transport and
climate objectives.
 No real engagement with placemaking or severance
There is no discussion of how a free-flow slip and extra lanes affect pedestrian/cycle
severance, crossing quality, safety, noise, or place function at Weycock Cross, despite
PPW’s placemaking and “healthier places” requirements.
4. Active Travel: treated as an add-on, not a structuring principle
 Contradiction: Active Travel framed as a by-product of a signalised access
The Dra Transport Assessment presents “dedicated demand dependent green me for
pedestrians and cyclists” at the new signals and a link to the proposed Active Travel
route as a benefit, but only as an adjunct to a junction designed primarily for motor
traffic. The Active Travel (Wales) Act and PPW require that walking and cycling are
prioritised in scheme design, with high-quality, coherent routes and minimal delay—not
simply accommodated within a car-optimised junction.
5. Location and land use integra on
 Tension with accessibility and car-dependence tests
The Draft Transport Assessment does not really test whether this greenfield, edge-of
Barry site can support a genuinely sustainable pa ern of trips (frequency, quality and
directness of bus, walk and cycle links to key destinations). It jumps quickly from trip
rates to junction modelling.
The North West Barry site’s location and arduous uphill topology prohibit any chance of
serious uptake of Active Travel commuting (on foot or by bicycle) from the nearest
commuter hub train station.
PPW and TAN 18 expect a sequential approach: location and accessibility first, then
network impacts—especially for greenfield housing that risks locking in car-based
patterns. The site patently fails in this regard.
6. Impact on Air Quality and noise levels due to traffic conges on
North West Barry Transport Assessment – Modelling Addendum (May 2025) — there are zero
references to:
 Air quality
 Air pollution
 NO₂ / nitrogen dioxide
 PM₂.₅ / PM₁₀
 AQMA / Air Quality Management Area
 Environmental impacts of traffic
 Health impacts of emissions
 Noise impact of traffic
 Air quality assessment requirements
There is no sec on, no paragraph, and not even a passing men on of an air quality assessment
being undertaken or even considered anywhere in the document provided.
Why this absence matters (policy context)
This omission is highly significant because:
i) PPW (Planning Policy Wales) requires air quality to be assessed, and impacts considered, as
part of the strategic traffic assessment process:
“For specific proposals, particularly those genera ng significant traffic, AQA must be included as
part of the transport assessment to assess impacts on, and in conjunction with, the surrounding
transport network”
Even if AQA’s have previously been undertaken as part of the local council’s statutory activity,
the lack of inclusion of any AQA data in the report is a glaring failure of the provided RLDP STA
data to comply with PPW requirements.
ii) TAN 18 (Transport) explicitly links traffic growth to air quality impacts
Especially at congested junctions — and Weycock Cross is repeatedly described as congested or
over capacity.
iii) Future Wales and the Wales Transport Strategy priori se reducing emissions
Any development genera ng additional car trips must demonstrate how it avoids worsening air
quality.
iv) The site is adjacent to a major arterial route (A4226) with peak-hour conges on
Congested, slow-moving traffic is the worst-case scenario for NO₂ and PM emissions.
v) The Dra Transport Assessment repeatedly proposes capacity-increasing measures
But never evaluates whether these:
 Increase induced traffic
 Increase emissions and pollution
 Increase noise and disturbance
 Affect local receptors (homes, school routes, pedestrians, cyclists)
7. Conclusions:
For the reasons outlined above, I believe it is clear that the not only is the North West Barry
KS1 site unsuitable for inclusion in the RLDP based on sustainable travel criteria alone, but
also the RLDP supporting evidence in the form of this 3rd party document does not meet the
expected standards required by PPW.

My objections are
1. Not enough Gp's, Dental care, NHS cover
2. Amount of traffic that will be generated due to all these houses traffic survey incorrectly done needs to be in schools time for a month.
3. Roads not food enough to support all the extra traffic.
4. Added pollution
5.Damage to the environment (more people) green land being used.
6. Transport limits for the public
7. Added sewage, where is that going. Bristol Channel, new sewage plant needs to be built.
8. Expansion of the Police Ambulance, Fire Services, need more due to expansion of Sully, Cosmeston, Barry

The site presents fundamental and unresolved flood-risk and drainage constraints. The evidence demonstrates that the site is not hydrologically suitable for residential
development. It should therefore not be allocated within the RLDP

HG1 KS1 North West Barry (Weycock Cross)
Objection-KS1: Flood Risk and Sustainable Drainage
HG1 KS1: Flood Risk and Sustainable Drainage
Ref: NWB_RLDP_JVN_007
I object to the proposed allocation of land at Weycock Cross, Barry (HG1 KS1) on the grounds
that the developer’s own Preliminary Drainage Strategy (Persimmon, May 2025)
demonstrates unresolved, significant, and in some cases unquantified flood-risk and
drainage constraints. These issues fundamentally undermine the site’s suitability for
residential development and render the allocation unsound.
1. Surface-Water Flood Risk Remains Unresolved Due to Missing Critical Data
Although the site lies within Flood Zone 1, the drainage report confirms that:
 NRW mapping shows local watercourse flooding within the developable area
 parts of the site are already at risk of surface-water flooding
 NRW’s detailed Product 6 dataset is unavailable, meaning there is no numerical
assessment of flood depth, velocity, or hazard ra ng
Without Product 6 data, it is impossible to determine:
 whether proposed site levels will displace water onto adjacent land
 whether attenuation features are correctly sized
 whether safe access/egress can be maintained during a flood
In the absence of this essential dataset, no defensible flood-risk assessment can be
completed. Allocation of the site is therefore premature and contrary to PPW requirements
for evidence-based flood-risk management.
2. Major Discrepancies Between NRW Flood Maps and Surveyed Ground Levels
The drainage report acknowledges discrepancies of up to 2.5 metres between the site’s
topographical survey and NRW’s flood-model outputs. This level of variance is extreme;
flood models typically operate within tolerances of 0.10–0.25 m, not 2m or more.
Such discrepancies imply that:
 flooding may be more extensive than shown
 the proposed development platform may not be safe
 modelled flood outlines may be fundamentally inaccurate
A site with such substantial mapping errors should not progress to allocation without full
resolution.
3. Outfall Capacity of the Central Watercourse Is Unknown
The strategy proposes discharging all surface water into the on-site watercourse at a
controlled rate of 70.4 litres per second (l/s). However:
 no hydraulic modelling has been undertaken
 the downstream culvert has not been surveyed
 no evidence demonstrates that the open channel or culvert can accommodate 70.4
l/s, let alone exceedance flows during extreme rainfall
If the watercourse lacks capacity, the consequences include:
 increased flood risk to existing homes
 uncontrolled exceedance flows affecting sensitive ecological receptors
 flooding of new homes
Allocating a site before verifying outfall capacity is unsafe and contrary to PPW drainage
principles.
4. Soil Conditions Make Infiltration SuDS Unviable
Soilscapes data and the drainage strategy confirm that the site is comprised of soil that is:
 slowly permeable
 seasonally wet
 loamy and clay based
 exhibits impeded drainage
As a result, infiltration rates are unlikely to meet BRE365 standards. Consequently:
 100% of surface-water runoff must be attenuated and discharged to the watercourse
 this places substantial pressure on a constrained ditch and culvert system
 reliance on a single out all is high-risk and contrary to SuDS hierarchy best practice
5. Extremely Large Attenuation Volumes Required
The drainage strategy calculates that the 100-year + 40% climate-change event requires:
 Attenuation volume: 9,580.7 m³ (approximately 4 Olympic-sized swimming pools)
 Storage basin footprint: 8,926 m² (approximately the size of a football pitch)
 Base dimensions: 163.6 m × 54.5 m
 Design depth: up to 1.14 m for the 200-year event
Such extensive attenuation demonstrates:
 the land naturally produces high runoff
 the site is hydrologically sensitive
 the developable area would require substantial re-engineering
Planning for this level of intervention strongly indicates that the land is inherently
unsuitable for residential development.
6. Overland Flow from Adjacent Farmland Already Enters the Site
The drainage report confirms that runoff from neighbouring land flows onto the
development area. This means the drainage design must intercept and reroute:
 external overland flows
 internal site runoff
Any miscalculation in levels, flow direction, or attenuation capacity could:
 redirect water toward existing housing
 increase on-site flood risk
 cause contaminated exceedance flows to migrate toward sensitive receptors,
including the adjacent Ancient Semi-Natural Woodland (ASNW)
This represents a major unmanaged risk.
7. Foul Drainage Solutions Are Unconfirmed and Require Major Off-Site Works
All foul-drainage options presented are specula ve and dependent on:
 pumping stations and rising mains up to 650 metres in length
 third-party land agreements
 potential network upgrades
 confirmation of capacity from Welsh Water
Even if surface-water issues were resolved (which they are not), foul-drainage uncertainty
introduces further risk, delay, and potential undeliverability.
8. Critical Elements of the Flood-Risk Strategy Remain “To Be Confirmed”
Key missing assessments include:
 downstream culvert surveys
 watercourse capacity modelling
 BRE365 infiltration testing
 full SAB pre-application review
 NRW Product 6 flood-hazard data
 confirmation of foul-drainage capacity from Welsh Water
A site cannot be allocated when its fundamental drainage viability remains unproven.
9. The Developer’s Own Evidence Demonstrates Fundamental Unsuitability
The drainage report confirms:
 flood mapping is unreliable
 flood-risk data is missing
 outfall capacity is untested
 infiltration is unlikely
 over 9,580 m³ of attenuation is required
 a discharge rate of 70.4 l/s must be imposed on an unmodelled watercourse
 overland flows enter the site from surrounding farmland
 foul drainage has no confirmed solution
These issues are significant, unresolved, and cannot be conditioned away or deferred to later
stages.
Conclusion
The site presents fundamental and unresolved flood-risk and drainage constraints. The
evidence demonstrates that the site is not hydrologically suitable for residential
development. It should therefore not be allocated within the RLDP

The allocation of this land is ecologically unsound, contrary to national and local policy, and should be removed from the RLDP.

HG1 KS1 North West Barry (Weycock Cross)
Objection-KS1: Green Infrastructure, Recreation Spaces and Biodiversity
I object to the proposed removal of the Green Wedge designation and the allocation of land at
North West Barry (HG1 KS1), as set out in the Technical Briefing Note – Green Wedge and
Landscape Implications of Expanded Site and its annexed reports. The rationale presented is
methodologically flawed, inconsistent with national policy, and directly contradicts the findings of the 2015 Planning Inspector and the adopted LDP.
1. Misinterpretation of Green Wedge Policy and Contradiction of Inspector Findings
The Technical Briefing Note asserts that the land is “not necessary” for the Green Wedge to
function because a gap of 2.3–2.5 km would remain. This is fundamentally unsound.
The 2015 Planning Inspector explicitly concluded that this site:
 forms an integral part of the pastoral landscape of the Green Wedge
 plays a key role in maintaining openness
 would be harmed by development
Planning Policy Wales (PPW) is clear that openness, not distance, is the defining attribute of a
Green Wedge. Coalescence is assessed through character, perception, openness, and
containment—not kilometres. The Briefing Note misinterprets national policy by reducing it to
a numerical metric.
2. Circular and Self-Serving Reasoning
The Briefing Note argues that because the existing settlement edge is “poor quality” (fences,
gardens), extending the settlement boundary 200 metres west would “improve” it.
This reasoning is circular:
 it uses previous erosion of the Green Wedge to justify further erosion
 PPW states that Green Wedges exist precisely to prevent incremental outward creep
and urbanisation
 a degraded edge strengthens, rather than weakens, the case for retaining openness
It is illogical and contrary to PPW to argue that because the Green Wedge has already been
weakened, it should be weakened further.
3. Incorrect Claims of Visual Containment
The Briefing Note claims the site is visually contained due to landform and woodland.
However, its own visual appraisal confirms the opposite.
The site is clearly visible from:
 Cwm Ciddy Lane
 the A4226 (major approach into Barry)
 Coed-y-Felin and other elevated residential areas
 all existing properties on the eastern boundary
The Inspector previously confirmed that the land:
 has an open, undeveloped character
 contributes to the perception of separation
The land is not visually enclosed in any meaningful sense; it is only partially filtered.
4. Understatement of Landscape Importance
The Briefing Note repeatedly describes the site as “unremarkable” or of “low sensitivity”. This
contradicts:
 LANDMAP classifications, including a High-value geological landscape and several
Moderate-value layers
 the Inspector’s conclusion that the site forms part of a meaningful undeveloped
landscape corridor
The assessment treats the site as an isolated parcel, ignoring its role as part of a continuous
open landscape between Barry and Rhoose. Green Wedge designation protects function, not
merely scenic quality.
5. Misrepresentation of the 2011 Green Wedge Background Paper
The authors argue that because the 2011 draft paper excluded the site, it is unnecessary. This
is misleading:
 the 2011 paper was draft evidence, not an adopted designation
 the site was reinstated in 2013 during plan refinement
 the 2015 Inspector accepted the adopted Green Wedge boundary as valid and sound
Selective quoting from early drafts ignores the plan-making process, consulta on, evidence
refinement, and Ministerial approval.
6. Incorrect Applica on of PPW Tests for Green Wedge Dele on
The Briefing Note claims development would be a “controlled expansion”. This contradicts
PPW, which states that Green Wedges should only be removed where normal development
management policies are insufficient to protect openness.
The paper argues the opposite: that normal policies can control expansion. This is
self-defeating. If normal policies suffice, then Green Wedge protection remains necessary.
The paper also assumes that housing need justifies deletion. PPW is explicit: housing need
alone is not grounds for removing a Green Wedge.
7. Flawed “2.5 km Gap” Argument
The claim that “2.5 km would remain” is a flawed metric. Green Wedges do not operate on
minimum distances. PPW states that wedges exist to:
 avoid incremental erosion
 prevent perceived coalescence
 maintain long-term openness
Urbanisation on one side of a wedge can significantly alter perception even if distance
remains.
8. Weak and Non-Defensible Boundary Proposal
The Briefing Note argues that development would “round off” Barry. This is incorrect.
True rounding-off requires strong, defensible boundaries such as:
 major roads
 rivers
 ridgelines
Here, the only proposed boundary is Cwm Ciddy Lane, a narrow rural lane screened by
hedgerows. This is not a strategic boundary. Moving the boundary westwards invites further
pressure beyond it, undermining the Green Wedge in the long term.
9. Precedent Risk
If this sec on of the Green Wedge is removed:
 the boundary becomes arbitrary rather than principled
 cumulative erosion becomes harder to resist
 other landowners will cite this as precedent
This undermines the historic and strategic role of the Barry–Rhoose Green Wedge.
10. Ecological Objections
The KS1 Preliminary Ecological Appraisal (May 2025) identifies multiple high-value and legally
sensitive ecological receptors. Development would result in significant, unavoidable, and
policy-contrary ecological harm.
10.1 Harm to Irreplaceable Ancient Semi-Natural Woodland (ASNW)
The site adjoins the North East of Knock Man Down Wood, a SINC and designated ASNW. The
PEA confirms:
 a rich tree canopy (Sycamore, Ash, Yew, Sessile Oak and Beech)
 a diverse understorey
 numerous ancient woodland indicator species
The woodland is highly vulnerable to:
 hydrological changes
 surface water pollution
 lighting impacts
 trampling and recreational pressure
Development would inevitably cause deterioration through edge effects and disturbance, not
only for the long term, but also during the construction phase.
10.2 Loss and Fragmentation of Priority Hedgerows
The site contains species-rich native hedgerows, all Priority Habitats under Sec on 7 of the
Environment (Wales) Act 2016. These provide:
 nesting habitat for a variety of birds
 bat commuting corridors
 dormouse movement routes
 rep le and amphibian foraging
Development will result in hedgerow breaches and contamination, fragmenting ecological
connectivity.
10.3 Adverse Impacts on Bats
Mul ple bat species use the site, including:
 Brown Long-eared Bat
 Common and Soprano Pipistrelle
 Whiskered, Daubenton’s, Serotine
 Noctule
A day roost lies less than 50 metres away. Development would:
 introduce harmful lighting
 risk loss of mature Ash with high roost potential
 sever flight lines

10.4 Risk to Hazel Dormouse (European Protected Species)
A Dormouse nest was recorded in 2013. The PEA confirms the hedgerows:
 provide suitable food sources
 connect directly to high-quality woodland
 have sufficient structure
Any impact on hedgerows or lighting spill risks harming this strictly protected species.
10.5 Badger Disturbance
Evidence includes:
 a fresh latrine
 well-used pathways
 guard hairs under fences
The site lies within a Badger clan’s territory. Development would disrupt foraging routes and
increase risk of harm.
10.6 Impacts on Otters
Otters were recorded in the central wet ditch and nearby Nant Talwg watercourse. Carcasses
have been found on or near the site, most recently in February 2026. Men on is made in the
report of the central ditch which serves as an o er commuting link between the water courses
bounding the northern and southern areas of the site, regardless of seasonal drying.
Development introduces unavoidable risks from:
 pollution
 drainage changes
 lighting disturbance
10.7 Loss of Ground-Nesting Bird Habitat
Species recorded include:
 Skylark (Sec on 7 Priority Species)
 Song Thrush
 House Sparrow
Development would remove nesting habitat and cause irreversible loss of farmland bird
territory.
10.8 Impacts on Rep les, Amphibians and Invertebrates
Field margins, the wet ditch, hedgerows and woodland edge support:
 Slow Worm
 Common Frog
 amphibian foraging habitat
 priority invertebrates
These habitats would be permanently lost or degraded.
10.9 Conflict with the National B-Lines Pollinator Network
The southern part of the site lies within the national B-Lines network. Development would
remove stepping-stone habitat and break the corridor.
11. Failure to Deliver PPW’s Required “Net Benefit for Biodiversity”
PPW Edi on 12 requires all development to deliver a net benefit for biodiversity and follow
the stepwise approach (avoid → minimise → mi gate → compensate).
The PEA demonstrates that:
 the most sensitive habitats lie at the boundaries
 these boundaries face the greatest development pressure
 harm cannot be avoided or fully mi gated
The developer’s claim that leaving a remnant of the existing greenfield plot as an “open space
buffer” would in some way deliver “significant biodiversity enhancements” is unsubstantiated
and wholly contradicted by the ecological evidence.
Conclusion
The allocation of this land is ecologically unsound, contrary to national and local policy, and
should be removed from the RLDP.

Low density housing on the development should be concentrated along the Pontypridd Road edge.

Adjoining properties in Pontypridd Road are extremely low density. In the scheme presented at the Millwood Bowling Club last year, low density housing, was shown along CwmCiddy Lane but not along Pontypridd Road.

HG1 KS1 North West Barry (Weycock Cross)
Objection Topic: KS1: Heritage

I object to the inclusion of land at North West Barry (HG1 KS1) within the RLDP on the basis
that the Heritage Assessment commissioned by Persimmon Homes (June 2025) is
inadequate, methodologically unsound, and non-compliant with national policy
requirements. As such, it cannot be relied upon as evidence to justify allocation of this land
for development.
1. Non-Compliance with Planning Policy Wales (PPW) Edi on 12 (2024)
1.1 Failure to Assess Significance of Assets
PPW Edi on 12 requires planning authorities to protect, conserve, and enhance the historic
environment as part of creating “Distinctive and Natural Places”. Heritage assets—
designated or non-designated—must be assessed in terms of their significance and the
impact of proposed development on that significance.
The developer’s assessment fails to meet these requirements. It:
 relies almost exclusively on distance and visibility, rather than the holistic
considerations mandated by PPW
 does not identify the significance of each potentially affected heritage asset
 does not explain how the proposed development would affect that significance
This approach is materially below the standard required for plan-making.
1.2 Absence of Cumulative or Incremental Impact Assessment
PPW requires a long-term, sustainable approach to placemaking, including the prevention of
gradual landscape erosion. The assessment:
 ignores previous encroachment on the rural se ng of Barry
 fails to consider whether further development contributes to incremental loss of
historic landscape
 uses past erosion as justification for further erosion, in stark contradiction to
placemaking principles in PPW
This omission is a significant policy failure.
2. Non-Compliance with Cadw’s “Se ng of Historic Assets in Wales” Guidance
2.1 Failure to Apply the Required Four-Stage Methodology
Cadw requires a structured four-stage methodology:
1. Identify the asset
2. Define and analyse its se ng
3. Assess the impact of change
4. Consider mi ga on
The developer’s assessment does not follow this methodology. There is:
 no se ng analysis
 no asset-specific impact evaluation
 no discussion of mi ga on
 no documented methodology
2.2 Incorrect and Narrow Definition of Setting
Cadw defines se ng as the surroundings in which an asset is understood, experienced, and
appreciated. This includes tranquillity, remoteness, historic relationships, topography, and
other experiential qualities—not merely intervisibility.
The assessment is inconsistent with this definition. It:
 treats “no intervisibility” as equivalent to “no impact”
 disregards experiential qualities such as rural tranquillity and historic context
 fails to acknowledge that se ng can be harmed even without direct views
3. Lack of Asset-Specific Evaluation
There are listed buildings within approximately 350–420 metres (e.g., Cwm Ciddy Farm) and
several other designated heritage assets within 1–2 km, including Registered Historic Parks,
Scheduled Monuments, Gardens and Conservation Areas.
However, the assessment:
 merely lists these assets without analysing their se ng or sensitivity
 provides no evaluation of how suburban expansion may alter their rural historic
context
 fails to recognise the role of surrounding fields in forming the historic approach to
Barry and Porthkerry
Cadw requires each asset’s se ng to be analysed individually, supported by evidence. This
has not been undertaken.
4. Unsubstantiated Dismissal of Historic Landscape Value
LANDMAP identifies the area as part of a Historic Landscape Aspect Area of “Moderate”
value, with surviving regular fieldscapes. The assessment dismisses this without evidence,
claiming the field pa ern is “already altered”.
However:
 PPW requires recognition of distinctive historic character, whether designated or not
 Cadw confirms that se ng impacts apply to all historic assets
The assessment provides no justification for disregarding this historic character.
5. Insufficient Evidence for LDP Allocation
Cadw states that developers must provide “sufficient, but proportionate information” to
allow authorities to assess impacts. The assessment fails this test. It contains:
 no photomontages
 no se ng diagrams
 no significance analysis
 conclusions unsupported by evidence
This is inadequate for LDP allocation and fails PPW’s requirement for a robust evidence base.
6. Risk of Partiality
While it is standard practice for developers to commission their own heritage assessments,
PPW and Cadw expect such assessments to be balanced, transparent, and methodologically
sound. Given the clear departures from national guidance, the LPA must exercise caution in
relying on an assessment commissioned by a party with a vested interest in minimising
constraints.
Conclusion
The heritage assessment:
 does not comply with PPW Edi on 12
 does not comply with Cadw’s Setting of Historic Assets in Wales
 does not provide adequate evidence to assess impacts
 overlooks cumulative and experiential impacts
 fails to evaluate individual assets or their significance
 presents conclusions unsupported by analysis
On this basis, the assessment does not meet the tests of soundness and cannot justify
removal of this land from the Green Wedge or its allocation for development within the
RLDP.

HG1 KS1 North West Barry (Weycock Cross)
Objection Topic: KS1: Affordable Housing

I wish to register a formal objection to the proposals and intentions set out within the
Weycock Cross Vision Statement (Persimmon, June 2025). The document is framed
predominantly from the perspective of prospective residents and provides limited,
non-specific benefits for those already living within the established community.
The Vision Statement places primary emphasis on delivering a “high-quality… residential
extension… of up to 376 dwellings” and highlights the “significant opportunity for future
residents” to access nearby amenities. This framing marginalises the needs, expectations
and lived experience of existing residents, who will bear the immediate and long-term
impacts of the development.
Public open spaces are presented as general assets for the “wider community”, yet the
document provides no detail regarding how existing residents would benefit in practice
(e.g., access arrangements, parking, management, safety, or programming). The benefits are
articulated in terms of creating a “new neighbourhood”, rather than enhancing (or even
maintaining) the quality of life for the existing one:
“Create a distinctive new neighbourhood for Barry…” (Objectives of Good Design –
Character, p.21)
Although the Statement asserts that the development will “consider the amenity of existing
residents”, it offers no substantive commitments. There is an absence of detail regarding
buffer widths, overlooking and overshadowing distances, acoustic mitigation, or lighting
controls along the eastern boundary adjoining existing homes.
The proposal that “rear gardens [will] adjoin current development edge” is presented as a
sensitivity measure. However, this approach may reduce permeability for existing residents
and provides no clarity on boundary treatment quality, overlooking safeguards, or
measures to deter an-social behaviour. The description—
“Rear gardens to adjoin current development edge to secure boundary and provide a
sensitive response to existing residences” (Concept diagram, p.3)
—lacks the specificity required to demonstrate meaningful mi ga on.
The sections addressing noise and air quality assess conditions only in relation to the
suitability of the site for new housing. For example:
“The only part of the site sensitive to increased noise levels is the northern boundary…
Although within a reasonable proximity to Cardiff Airport… [it] does not prove to be of any
significant impact to development.” (Site & Context – p.11)
This analysis is framed around development feasibility rather than the net impact on
existing residents during both construction and operational phases.
The Vale of Glamorgan’s Healthy Placemaking Dra SPG (2025) emphasises that
placemaking must deliver health, well-being and inclusive benefits, supported by checklists
and Health Impact Assessment expectations. A vision that does not articulate tangible,
locally relevant benefits—such as improved access, safety, active travel, or inclusive open
space—risks falling short of these standards.
Given these deficiencies, this site is not an appropriate location for the proposed
development. Further consultation is required, supported by detailed assessments
addressing:
Amenity and Privacy for Existing Residents (Eastern Boundary)
 Minimum buffer width and landscape/woodland edge specification
 Overlooking and overshadowing parameters (e.g., minimum separation distances,
height transitions)
 Lighting and acoustic design standards for boundary treatments
Construction Environmental Management Plan (CEMP)
 Dust suppression measures
 Noise limits and monitoring
 HGV routing, turning arrangements and contractor parking
 Complaint response procedures and timescales
Public Open Space Provision
 Guaranteed access points for existing residents, with clear wayfinding
 Maintenance and management arrangements, including safety and lighting
 Inclusive facilities (seating, nature play, accessible paths) and opportunities for local
community use
Traffic and wider community infrastructure concerns are addressed in separate objection
submissions.

1) Outside Barry urban boundary. Move this and we would eventually join up with Rhoose. These boundaries should not move.
2) Active farmland. You may say a lower grade however, crops still grow here and cattle graze here. Build on brownfield sites!!!!
3) Transport - Barry train station bot in walking distance for workers who want to walk to five days a week. Return walk is an uphill struggle. Most people would use there cars and Barry station does not have sufficient parking now.
4) Port Road is a main road to airport. If airport gets busier then more traffic jams.
5) Not enough doctors at highlight medical centre and vale group a pain as need to drive further to St Brides
6) Flood risk, how would this be mitigated against. We already have rainwater run off from this field.

The site is not sustainable, not deliverable, and should be removed from the RLDP.

HG1 KS1 North West Barry (Weycock Cross)
Topic: KS1: Summary of Objections to Proposed Development

I object to the allocation of HG1 KS1 (North West Barry / Weycock Cross) on the grounds that the
proposed site development is unsound, unjustified, and undeliverable. The Council’s own RLDP
supporting evidence, together with the developer’s technical reports, demonstrates that the site
proposal fails key tests relating to Transport, Drainage, Biodiversity, Green Wedge protection,
Landscape Character, Heritage, and Community Infrastructure.
Transport & Air Quality:
Weycock Cross is already over capacity at peak times. The RLDP transport evidence is incomplete,
based on limited data, and omits an Air Quality Assessment entirely. Active-travel and public
transport options are weak, indirect, or impractical. The site would generate significant
car-dependent traffic growth and site-related conges on & pollution contrary to PPW/Well-being Act.
Green Wedge & Landscape:
The Technical Briefing Note misinterprets PPW by reducing Green Wedge policy to a distance test. The
2015 Inspector found this land integral to openness and separation. The site remains visually
exposed, contributes to the rural setting of Barry, and forms part of a continuous landscape corridor.
The case for moving the GW boundary is weak and would set a damaging precedent.
Biodiversity:
The Preliminary Ecological Appraisal identifies multiple high-value receptors, including ASNW, Priority
Hedgerows, bats, dormice, badgers, otters, rep les, and Red-List protected ground-nesting birds.
Impacts of the development (and building process) on these priority concerns cannot be avoided or
mi gated. The site cannot deliver PPW’s required net benefit for biodiversity.
Community Infrastructure:
The RLDP provides no deliverable strategy for GP capacity, social care, education, or community
facilities. The Council’s own Health Impact Assessments warn of negative health outcomes if
development proceeds without infrastructure in place. Vague developer assurances of off-site
financial contributions have no real bearing on strategic infrastructure provision.
Drainage & Flood Risk:
The developer’s own drainage strategy shows unresolved risks: missing NRW Product 6 data,
significant height discrepancies between flood models and ground levels, unknown outgoing
watercourse capacity, unviable SuDS infiltration due to soil type, and the need for over 9500 m³ of
attenuation (four Olympic swimming pools). Foul drainage solutions are speculative and require major
off-site works. Fundamental viability remains unproven. The site location is unsuitable.
Heritage:
The Heritage Assessment fails to comply with PPW and Cadw guidance. It does not assess
significance, se ng, cumulative impacts, or mi ga on. Conclusions are unsupported and cannot be
relied upon for plan-making.
Conclusion:
The allocation conflicts with PPW, TAN guidance, the Well-being Act, and the Council’s own evidence
base. The site is not sustainable, not deliverable, and should be removed from the RLDP.

wish to raise my objections to the development. You have not thought this through properly. Traffic is a nightmare at the best of times and adding this many houses to an already populated area is ludicrous idea. Your suggestion that people will use public transport is nonsensical. We know people don’t use public transport when it’s nearby to them. People will not walk half an hour plus to the nearest train station - they will either drive to the train station or instead drive to their destination. To suggest otherwise is crazy. Children will be taken to school in cars - you can promote sustainable choices of travel as much as you want but the reality is people don’t walk or cycle - they drive.

Secondly, I object for reasons that you have spent significant time and money restructuring the road layout at Weycock cross and that is now most likely going to be wasted and changed so you can accommodate these new houses. Yet again this appears to be a situation where you are wasting tax payers money and have no competent planning.

Thirdly, the traffic mentioned above will affect the airport. There have been numerous instances where one accident/roadworks can cause gridlock to the WHOLE of the west end of Barry. Your proposals will seek to make this worse. This will have obvious implications for anyone trying to use the airport and put people off using an already failing airport.

You might say that you will ensure the developers will implement measures to alleviate this issues. We all know that won’t happen. Once the houses are built, the developer has its money, they will leave the local residents to deal with this mess and you will do NOTHING to sort it out. You will not seek to enforce them to comply with the agreement.

Next, Barry is over populated. You are not building any additional schools, doctors, dentists etc to cope with this additional demand. Such services are already over subscribed and to say otherwise demonstrates your lack of understanding of the communities you serve.

I get very little for the council tax I pay and I’m not prepared to subsidise yet more individuals who contribute very little or nothing at all due to your council tax exemptions/discretions.

Faith in the council is at an all time low. Listen to the residents who live, know and breathe the area and know the real difficulties this development will create. Try and restore some faith back into residents that you have our best interests at heart and that you’re not in the pockets of local developers and lining your own pockets.

Please ensure my comments are taken forward as part of the proposal.

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



Key Documents Unavailable in Welsh Online

Please could I submit an objection to the proposed development at North West Barry, Waycock Cross

It is likely with this site and the other proposed sites in the vale through to Llantwit Major (a total of well over a 1000 houses) will create a significant pinch point at Waycock Cross.

The proposed new traffic light system alone at Waycock Cross will not suffice for the increased strain that will result.

How about an actual cycle path and footpath between Waycock and Rhoose. I see people walk on the road daily which is a major safety issue. It's a 50 m/h road.

The contractors Persimmon homes stated that the development at Waycock Cross would result in insignificant or inconsequential affect on traffic, however, they have not taken into account the other proposed developments and the already strained traffic at this pinch point(which is the main artery for Rhoose, St Athan /Aberthaw and Llantwit Major)

There is also already a significant strain on existing GP lists and school services which are at capacity, with children already refused places at schools.
Young people from the West End of Barry are already being declined places at Whitmore due to numbers/space even thought they’re in “catchment”.
The council claims these new homes are “affordable,” but in reality, most local people still can’t afford them. It's a misleading label. We’re constantly told this is for the greater good, but who is it really benefiting? At this rate, we’ll be left with no green land and a housing market that still doesn’t serve the people who need it most.

The site will also endanger ecosystems/wildlife e.g. Barbastelle bats which are indigenous to Mill Wood are rare and protected under uk and European law (listed as Near Threatened on the global IUCN Red List of Threatened Species). And rare birds e.g. Eurasian Jay, Bullfinch, and Collared-Dove. These are seen often flying around the outskirts of the wood.

Developments near Barry Woodlands Site of Special Scientific Interest (SSSI), could lead to the potential for unauthorised and unmanaged public access leading to damage to the SSSI.

I strongly disagree with building yet more houses on green land. Every time green space is lost to development, we damage ecosystems, displace wildlife, and move closer to an ecological crisis. These areas are vital—not just for the environment, but for the well-being of our communities.

Please can you reconsider this development or atleast mitigate further the above outlined concerns.

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

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

Green wedges should be honoured and the site excluded.

The land is currently green wedge.
Public transport there is poor, walking to town too far and uphill.
There will be more traffic congestion, pollution.
It would be an encroachment into the countryside.
The land will flood as rainfall increases. NantTalwg cannot cope at the moment.

I think Port Rd is already very congested another development on the busiest road in Barry is not going to help in any way. The land proposed for development is very precious green space that should be used for more "affordable" housing. Airport access is very poor as it is CDW could be so much better for the community if investing on new roads were more of a priority than westing valuable green space and the risking the biodiversity of the area and the effect on wildlife would be detrimental.

This plan is all sorts of wrong and should be scrapped in it’s entirety.

The area cannot support this development. It would cause chaos on already busy roads. No available school places or other infrastructure. The negative impact on the environment would be impactful to the area’s wellbeing benefits and the wildlife would inevitably suffer.
There are many brown field areas which can be used for building and using these would be far superior to decimating a semi rural environment. Why are you determined to ruin the benefits of green spaces. Also why not refurbish older vacant properties thus revitalising some urban areas.

I would suggest that the roundabout should, regardless of predicted increase in traffic flow resulting from developments in Barry, Rhoose & St. Athan, be replaced with traffic lights.

The development will cause a severe traffic problem that is already an issue at Weycock Cross and Port Road.
The proposed addition of lanes approaching Weycock Cross will do nothing to increase flow around the roundabout and hence delays will only increase with increased amount of traffic. Currently, queues are frequently encountered approaching from the Five Mile Lane and Port Road West between the Colcot roundabout and beyond the Dragon Tails roundabout.

Consultation Ref - HG1 KS1
Proposed Development Weycock Cross
Dear Sir,
In line with the requirement of the consultation period I submit my grave concerns/observations/objections as regards this misjudged and misguided proposal for North West Barry in the RLDP.
Given the magnitude of the on-line information the time permitted for public review of all documents is grossly insufficient and disrespectful.
Allowing a period of just 42 days i.e. 28 Jan to 11 March for lay people to assimilate hundreds if not thousands of pages is wholly inappropriate and disingenuous. This is especially so mindful it has taken paid officials and others months and months to compile the data.
Unless adequate timelines are permitted how can those most impacted do justice to their contribution to the consultation and effectively present their objections ??
There have been major communication shortcomings/flaws here that threaten the integrity of this initiative and require your immediate rectification :-

 Clear evidence of age discrimination for those who can’t do things on line with no obvious and straightforward way they can access hard copies of relevant documents!

 Paper copies are not readily available for analysis at home – the Head Planner did agree at the Barry Memo meeting to look into this and come back to me but has failed to deliver.


 There is no reference or regard to what caused the earlier 2015 application to fail? What happened to the 2015 proposal and why was it turned down ?

 Have the barriers from 2015 been overcome or are they still bona fide or just swept to one side?


 On the subject of the published Vision Statement that underpins the councils plans – Who instigated and paid for this presentation and/or the various supporting attachments?
 Were the supporting documents commissioned and addressed prima face to the Council or Persimmon? This needs to be clarified please.

 The suggested development area has been under the microscope for many years – now there is a rush to complete what paid officials describe as the “best option currently available”. What other areas have been explored for a Barry Site and exactly why have they not been pursued ?

 We are told that the Council appealed for available development sites rather than drive the action to acquire land/space that best fitted their needs – please can you outline, in detail, the process that was followed?

 Was this specific land acquisition developer or Council sourced/driven?

 The Revised Local Development Plan is only until 2036 !! ….that suggests it is 6 Years minimum behind the curve and will be on its last legs before any development gets underway.

 Can you please detail exactly what the Council’s vision is beyond 2036 ? Indeed, can the Council demonstrate a clear plan/picture across the next two decades?

 The choice of Weycock Cross could be said to be the route of least resistance in a builders eyes looking purely from purely a profit perspective…. Flat land and easy to build on. What other builders showed an interest in this development site and on what basis were Persimmon selected?


 Other possible sites adjoining the Weycock Roundabout seem to have been overlooked/sidelined when they offer tangible benefits e.g. Land to the left of the Five Mile Lane which has been subject to planning dialogue in the past and the former College site to the right. To what extent were these considered?

 How much money has been invested in pursuing the LDP this far?

 Can you please confirm what the Section 106 agreement for Schools, Doctors Surgery, Dental Surgery etc. will be? Experience tells us that Surgeries are overflowing, road traffic overflowing and schools full so any funding from a S106 Agreement must be sufficient to build for future needs. Local councilors inform us that this has all been agreed but seem unable to confirm the details! What exactly is the position on this matter?

 Road provision around the proposed site entrance and minimum planned highway enhancement beggars belief with MAJOR road upgrading / widening clearly needed before any ground is cut. The roads around Weycock Cross cannot cope NOW and will be even more bottlenecked with approaching well over another 1000 cars trying to get through.


 The commercial development near Cardiff Wales Airport – Model Farm land - will only add to the congestion. What traffic volumes is this site expected to add to the existing bottlenecks?

 Can/should the land at Model Farm include a mix of commercial and 376 residential developments? If not- why not?

 Local councilors verbally tell us the environmental impact would be unacceptable so why is the Weycock site not assessed similarly?

 The uplift in traffic volumes demonstrates the need for a cross-country link from the Airport to the recently upgraded Five Mile lane – what are the Councils plans on delivering such a route?

 The residential House market has seen tangible valuation slippage at present and allied to the cost of living crisis questions the sale-ability of new properties.

 Existing nearby housing stock is seeing depressed values as the risk of these new homes bites. What will the council do to compensate existing homeowners so impacted?

 Any downturn in saleability will massively impact on S106 payments – what are the council planning to do if S106 monies are depleted and insufficient funds pull through for roads, infrastructure etc?

 Persimmon’s track record at other local sites does not inspire confidence they will be compliant. What detailed assessment / examination has the council undertaken to establish that Persimmon are the right builders of choice? What do the council plan to do to ensure they deliver on their obligations?

This is very much “last chance saloon” for the Council to meet targets imposed on them by central government and smacks of an embedded lack of ownership, understanding and vision.
The recent council meeting in early December 25 failed to have the engagement of any councilors from Illtyd Ward so those residents directly impacted had “NO VOICE”– should this vote have been postponed?
Two councillors were prevented from physically attending due to illness and missed the opportunity to partake and/or vote remotely !! Allowance should have been made for their medically enforced absence.
The third abstained on political grounds and did not fairly represent the constituents!!
Had the two attended, the vote would have been 26:25 against and the proposal defeated.
One would logically think that it should have been postponed to ensure integrity, democracy and respect. What is the councils view ?

Mitigating And Adapting Climate Change & The Environment
• Huge growth in traffic at a long standing bottle neck that can’t manage at present – 20/25 minutes to travel from Hotel International to Weycock Cross now. This point, on its own, defeats this mission objective.
• Additional pressure will come from new residential development in Llantwit Major, St Athan and Rhoose and the current gridlock merely worsens.
• More car exhaust with ever longer journey times means more wasted fossil fuels in a dense residential area with significantly more air pollution and impact on people’s health.
• Nearly 800 more cars locally from Weycock development alone will be intolerable!
• Traffic light provision into and out of the development on top of a congested roundabout is sheer madness!
• Destroying green belt unnecessarily is totally unacceptable.
• Damage to the surrounding woodland will undoubtedly follow the urbanization of the fields with increased water discharge into the already environmentally challenged Millwood area!
• Impact on normal Emergency Services and those for Airport Incidents will be massive with the serious risk that lives will be lost as a consequence.

Improving Mental Health & Physical Health & Well Being
• Who exactly will see any benefit? All those who use the area will suffer badly!
• The stress / Impact on the existing residents, highways and services will be unbearable!
• The inevitable devaluation of quality owner-occupied properties will be financially devastating.
• The removal of countryside views owners paid for in their house purchase costs is totally unacceptable.
• There has been no respect or regard for the dramatic impact on existing residents when drawing these proposals together – we have been overlooked until the consultation kicked off!!

Homes for All
• Who exactly make up the “ALL”?
• Who is expected to move into the housing stock should they be built and where will they come from?
• Where does any local demand come from with published falling birth rates?
• Affordability for owner occupied properties is vital and how has this been tested??
• Will there be population drift from outside the Vale? Why can’t we just focus on our own ?
• Putting Vale resident needs front and centre must be the priority!



Place Making
• How will this help create Adaptable, Safe, Accessible and well- connected communities?
• The general area is hardly easily accessible now given reliance on present infrastructure never mind expansion? Please explain!
• The proposal is said to be offering a sustainable range of service and facilities and yet there is no defined and funded expansion for GP, Dentist or schools?
• No future proofing for these demands is evident - why?
• Unless these priority services upgrades are embedded there is every reason to sense that personal suffering will prevail and even loss of life!
• The clear absence of drastically improved road infra-structure will not make it “place making” but “place avoiding” !!

Protecting & Enhancing the Natural Environment
 Destroying natural habitat adjoining Porthkerry park and the Millwod does anything but protect and enhance the natural environment.

 Domestic waste management is problematic now and will only worsen as they often can’t collect on time now!
 Where are the renewable energy plans in this proposal?

Embracing Culture & Heritage
What has this to do with this development other than destroying the history and countryside that has stood the test of time for centuries?

Fostering Diverse, Vibrant & Connected Communites
• Fostering safe and cohesive communities- exactly how?
• The ensuing chaos such a development will bring is hardly safe, vibrant etc!
• On the contrary it brings disconnect, disharmony, dislocation and disappointment.

Promoting Active & Sustainable Travel Choices
• This will only produce more of the same on what is highly congested routes already
• Hardly a plan for active and sustainable travel as you wont be able yo get through the gridlock! More like sustainable parking for extended periods on main travel arteries into and out of town.
• Reducing the need to travel – it is anything but this – when attracting the young family types to 376 new homes, even when attracting minimum extra vehicles of say 1.5 cars each that is 564 more vehicles.

Building a Prosperous & Green Economy
• There is little if anything in this plan to manage pollution, or develop a prosperous green economy.
• The loss of prime dedicated green open space actually worsens the situation
• Job opportunities – where exactly will these come from to foster the local economy?
• The evolution of covid has driven remote working rather than local jobs?
• This development will REMOVE a massive slice of the GREEN ECONOMY with the fields built plus the undoubted damage to the Millwood.

Sustainable Tourism
• How on earth does this apply to this proposed development?

In summary this proposal is poorly thought out and completely inappropriate.
It falls down on every one of the above key drivers.
An initiative that is builder driven will lead to headaches not solutions and hugely impact local people.
Travel will come to a grinding halt across this area and the wider Vale will become a nightmare.
Existing property values will see a down turn.
Emergency services will see access to patients severely tested and lives put at risk.
Airport access will be under-mind a emergency incident management severely threatened.
Barry and the wider Vale will not be a place to visit but one to avoid.

The RLDP is simply NOT FIT FOR PURPOSE and needs to be paused IMMEDIATELY.
The idea of residential development in the Vale needs a complete rethink with properly throught out terms of reference underlining tried and tested proposals.
In similar view to the terms of the consultation process might I suggest you be kind enough to provide your detailed response within the next 42 days.
I trust common sense will prevail and THE COUNCIL makes the right decision for the whole of the Vale.

I believe the deposit RLDP should be amended to exclude this site. It is not within walking distance of the station and an additional 376 households would generate significantly more traffic in an already congested area. The A422b has its limitations which was why the assessment in 2014 concluded that the development of this Green Wedge site would be detrimental to the capacity and freeflow of traffic on this major hub road to the airport and Vale. There is no real evidence that the physical constraints of the road network have changed since that assessment and to reverse those findings without significant infrastructure improvements would be unjustified. Traffic lights at the junction and controlled pedestrian crossing will only interrupt traffic flow increasing queuing and delays.
There is a serious risk of sewage contamination to the local stream and a threat to local wildlife. Bats are very active and a protected species and urbanisation of this green wedge site would result in habitat loss, increased disturbance and long- term ecological degradation . Has a bat survey been implemented? The scale and location of this development, are inappropriate given the importance and existing pressures on the adjacent road network.

Every morning the traffic on Port Road West ( A4226) into Barry via Weycock Cross is queuing for approximately one kilometre, back to Welford Farm / Barn - this can be verified by the Highway cameras situated along the highway.

Apparently there are proposals to build 890 new houses in Rhoose and 1280 new houses in St Athan ( not sure about housing proposals for Llantwit Major ) - this will obviously add further traffic chaos and congestion to Port Road West and Weycock Cross Roundabout.

The existing infrastructure - roads and drainage (both storm and foul ) are outdated , inadequate and currently well over capacity ( as are other facilities such as healthcare and education )

The A4226 highway was constructed so many years ago - with different design criteria ( traffic volumes , traffic loadings etc) not relevant to today’s intense requirements.

The highway has seriously surpassed it’s design life by decades - the road construction materials have expired, showing signs of distress and surfacing failures due to a total lack of maintenance over the many years.

Major maintenance issues or total reconstruction will be required in the very near future causing delays , chaos , inconvenience and total gridlock .
Alternative routes are extremely limited, and therefore not an option especially for larger vehicles.

Q1: Site reference HG1 KS1 (unable to put above) The area of Weycock Cross is already overwhelmed with traffic. The system is not set up to allow smooth flow especially at peak times. We have frequent emails from Welsh Water to advise water supply issues we will escalate considerably with more housing. Residents of Barry all ready experience difficulties getting Dr & Dental appointments Loss of natural habitat for the wildlife in this area will affect all of the residents. Public transport is very limited and the train station is not a 35 min walk.
Q2: No impact.