N/A

This will further impact traffic congestion at the weycock roundabout site

Rhoose, Readers Way housing development LDP

I object to the above mentioned development for the following reasons:
The population of Rhoose already exceeds the capacity of essential services such as primary schools with NO current Comprehensive school. Other local settlements within the Vale of Glamorgan have smaller populations and a Comprehensive school (e.g. Cowbridge). Appointments for doctors & dentists have become more difficult year on year and frequently unobtainable.
The roundabout joining Fontgary Rd. To Porthkerry Rd. at the Hollies is an accident waiting to happen with frequent damage seen to the railings on the corner of Rhoose Rd. that protect pedestrians. Additional heavy traffic will only exacerbate this situation. The local road infrastructure struggles at best with the current volume of vehicles with queues forming on Port Rd. every day of the week regardless of the time of day. Adding more people to the immediate area of Rhoose will cause even more chaos. If Rhoose is seen as a “Satellite” of the capital... There is NO other practical way to Cardiff/Barry than through Weycock Cross.
The existing Hollies estate has seen numerous incidents of flooding due to run off from the airfield. Additional drainage work has rectified some issues. However, the top end of Readers Way down stream of where the proposed new development is located, frequently floods. This will be made significantly worst with more run-off from a new housing estate up the road.
Surely there are brown field sites such as, what was RAF St. Athan/Picketston & the eye-saw that is, Llandow industrial estate, more suited to housing developments than destroying arable land sucessfully used for decades.
Further more, I think it would be a travesty to allow this development in Rhoose for the above reasons and I would feel both ignored/let down by my local council if it proceeds.

1, Rhoose population will increase by approx. one third, will we get better council services i.e – council leisure centre (Cowbridge has one will smaller population), full time doctors, senior school, better public transport - increase in bus services and destinations, more frequent trains?
2. The roads on Readers Way are already busy with cars always parked on the road/curb. The increase of up to 1300 cars through Readers Way will only increase this risk. Furthermore, it will turn a quiet road through an estate with many young families into a busy main road.
Visability is poor approaching the roundabout on Readers Way from Picton Close. Cars travelling too fast and view obscured by vans and cars parked along the roadside.
Additionally, the roundabout at the end of Readers Way joining Porthkerry Road is far too narrow, the bungalows on the side park their cars as do many other people along that stretch making this roundabout dangerous. The railings there are already dented due to collisions. I have witnessed many near misses at this junction
3. Drains. Readers way already has a serious problem with flooding, run off from the airfield and surrounding fields with run aways throughout the village. Removing the green fields will only cause this problem to worsen.
4. Why are we developing on fields that grow crops annually when there are brownfield sites available e.g Picketston (old RAF Camp) & Llandow.
5. The road network through Rhoose and into Barry is already over congested with frequent delays, it is already unfit for purpose.
6. Will the owners of property directly effected by the works, increase in traffic, plant machinery etc be compensated for the intrusion and devaluing of property along this road?
Ideas
A better solution I believe would be for access to the new site to be from B4265 the widen Rockshead Lane and access from the other end of the development, this would stop the massive increased volume of traffic in Rhoose. I believe readers way is not suitable for the heavy construction vehicles or the increased volume of cars, and this would be the best solution.

Create a realistic traffic plan that is not built on misinformation.

It is stated in the traffic management plan:

"7.33 In summary, the junction capacity assessment results demonstrate that each of the junctions
currently operate within the theoretical capacity in their current form and therefore the
development can be delivered without any highway interventions.
7.34 The conclusion is that the effect of the development, in terms of highway capacity, is not
significant and does not give rise to any severe residual cumulative impacts.
7.35 Due to the sustainable location of the site and in line with discussions with VoGC officers, there
will be a commitment to provide an appropriate level of active travel provision, and to undertake
further investigation for active travel links into Rhoose"

This is not true and I am very annoyed to read such comments given the traffic levels on the roads out of the rural Vale. This plan does not account for other potential developments on the RLDP and does not discuss them. A thorough traffic report has not been conducted.

Readers Way HG1 KS3

I am objecting on the grounds that this site will have a significant impact on the residents of Readers Way; Celtic Way and Fontygary Road and adjoining neighbourhood in the Rhoose Ward. The traffic from over 500 new houses would cause significant stress on an area that is restricted by size and infrastucture. The junction at Fontygary Road and Fonmon Road (Fontygary Inn) would also be compromised

Sewage: Welsh Water have already shown that capacity for sewerage is at capacity, and with raw sewage already being poured onto our beaches it can only get worse.

Wildlife: Many species of plants and animals are protected. The protection applies to the habitats of bats, otters and may other animals, as well as many plants.

Infrastructure: There is only a One Stop Tesco and although walking distance an elderly person would not be able to traverse this on safety grounds, and carry shopping, whilst the store does not have capacity to stock a variety of goods.

Health Services: There are only two Doctors and one Dentists in close proximity and are already at capacity.

Education: All local schools are at capacity. The only Secondary Education is undertaken in Cowbridge which is at capacity as is Whitmore High School.

Building on Green Wedge is generally restricted, with a strong presumption against 'inappropriate development'.

Green wedges are designed to keep areas open, maintain the character of the countryside.

Travel: There is only one bus per hour when it runs and only one train per hour. Walking time to the train station would be at least 15 minutes depending on age.

HGI-KS3 The reasons for disagreeing with this candidate site is it is located in the wrong place, and no one has taken into account the increase traffic or the increase of drainage and sewage in the area or the lack of infrastructure ie. health or dentist service and the lack of active travel, and have not taken the local residents views in to account and the amount of traffic going through Rhoose and Port Road and have not taken in to account the new college, and the amount of traffic disruption it will have on the residence of Rhoose.

According to your RLDP it saying you would be able to walk to the train station in 15 min, that will not happen if you are elderly or disabled, so your active trave proposals are ridiculous, and there are no buses going to Celtic way and Readers. And there is just 1 bus very hour and 1 train every hour, so how will people get to work if they do not drive.

You say that the to school in Rhoose would have capacity that is not true. Rhoose Primary school is full and South Point has capacity for 90 more pupils and the secondary school is full in Cowbridge so where will all the new kids go

I strongly object to the increase in housing proposed in the revised devopment plan for the following reasons.
1. Failure of "Active Travel" and Pedestrian Safety
I strongly object to the increased density on the grounds that the site fails to meet the requirements of the Active Travel (Wales) Act 2013 and Planning Policy Wales (PPW) Edition 12.
• Outdated Data: The traffic counts were baseline-tested for 450 homes, and a 15.5% increase in housing density was added without new physical monitoring of the Fontygary junction.
• Physical Bottlenecks: The route between the proposed site and key amenities (the local pub, leisure facilities, and the rail station and shops) contains "critical bottlenecks" where the road narrows to a single carriage with no footway/pavement.
• Unresolvable Danger: Increased vehicle movements from 520 homes - combined with existing traffic from the B4265 via Fonmon -and B4265 by pass road creates an unacceptable risk of pedestrian-vehicle conflict in areas where there is no physical space to retro-fit a pavement.The "offline" paths do not solve the danger for existing residents or those who still need to navigate the "pavement-free" sections of the main road toward the B4265.
• Leisure Flow: The junction at Fontygary Road is a primary access point for both residents and visitors to the coast: Increased residential traffic will lead to "junction starvation," where turning movements into the leisure park block the main arterial road.
2. Inadequate Evidence Base: Seasonal & Leisure
The Transport Assessment (TA) supporting the increase to 520 homes is fundamentally flawed as it fails to account for the unique local context of the impact of the Fontygary Leisure Park and local pub that share this crossroad
• The current monitoring uses 'neutral month' data which does not reflect the significant surge in both vehicle and pedestrian traffic during the summer months. With the increase to 520 dwellings, the junction at the Fontygary traffic lights which even now at peak capacity are pushed beyond capacity when leisure park traffic is at its peak.
• Furthermore, the safety of pedestrians navigating the 'pavement-free' zones is severely compromised when seasonal visitors are added to the residential uplift.
• The Leisure Park operates at high occupancy for 10 months of the year, not just holiday periods when there is also added traffic from touring caravans. The TA must be based on this "extended peak" rather than neutral-month averages.
3. Impact of "Rat-Running" via Fonmon
The proposal fails to mitigate the impact of traffic diverting from the B4265 through Fonmon into Rhoose.
• Technical Constraint: This route consists of narrow, winding lanes poorly suited for the increased volume.
• Cumulative Impact: The move from 450 to 520 houses is a "tipping point" that will push these minor roads beyond their safe design capacity, specifically at the narrowest points where residential dwellings front directly onto the road without a buffer.
• The modeling doesn't sufficiently account for the combined impact of this site and other nearby developments (like St Athan or Airport expansion traffic) on the Fonmon bottleneck.
4. Conclusion: "Unsound" Allocation
The plan is Unsound because it is not "Effective" or "Deliverable." The infrastructure at the Fontygary junction and the surrounding pedestrian bottlenecks cannot safely accommodate a 15% increase in housing density without significant, yet currently unplanned and unfunded, topographical changes.

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

Plans shown to date, including on the policy documents on the portal and in the public domain remain confusing and misleading. I am aware that some corrections have been made via social media but I strongly feel the Authority should demonstrate how the proposed accesses will work more accurately now, not at some future date.

HG1 KS3 LAND AT READERS WAY, RHOOSE
Any access via Celtic Way is inadequate and will cause hardship and-loss of local amenity for existing residents.

The plan shows the access to the East as the Primary access and the one leading to Celtic way as the Secondary. Given that Celtic way is unsuitable for a large increase in traffic flow due to the amount of on road parking and the fact that that some 50 houses have to reverse off their drive into the traffic flow. Local children will have to cross a busy road to access the playground. Local residents will have to contend with increased noise and air pollution severely affecting their quality of life and wellbeing. Celtic Way is a quiet, safe cul-de-sac not designed for volume traffic including (these days) increased numbers of delivery vehicles from online purchases. No doubt many applications for reductions in Council tax will follow if this is approved..

Even for a secondary access, Celtic Way is unsuitable. Access is only via two routes. First via the Fontygary Inn traffic lights which are a pinch point with width for one vehicle at a time and no public pavement for the safety of pedestrians. Traffic often backs up beyond the entrance to Celtic Way & I have photographs of this including associated queues on Fontygary Road. This is not an uncommon occurrence and will become intolerable with additional housing. Second access is via the single track road through Fonmon where there are numerous issues with reversing vehicles in the narrow lane, including some quite ugly road rage incidents.

Whilst not ideal, a completely separate access directly off the bypass should be considered. This would utilise a new roundabout at the existing Fomonn junction with a link road via the proposed solar farm site. The bypass junction has seen several accidents and even fatalities so is in need of improvement. A new access is already required for the solar farm traffic so a short extension to the Readers Way site would cause minimal additional environmental impact. Access via Readers Way and Celtic Way could then be restricted to walking/cycling only generating minimal noise & air pollution to existing residents.

Photographs of congestion / gridlock at Fontygary inn traffic lights taken on 5th March 2026 at approx 3:30PM are attached to the accompanying Email. Please link them to this representation.
Photo FRT1 shows the queue which also extended behind us up Fontygary Rd at least as far as Tesco Express. One car can be seen attempting to turn around.
Photo FRT2 Two changes of lights later, we're still queuing and no traffic has moved.
Photo FRT3 & FRT4 Waiting to turn right, queue is partially cleared but still backed up due to delivery lorry in single vehicle space clearing the lights. A school bus is waiting and will cause further queues. As you can see, the queue extends across the access to Celtic Way.

As stated above, this is not a rare occurrence, It demonstrates the complete unsuitability of introducing hundreds more cars and vans onto Celtic Way on traffic flow grounds that affect large parts of Rhoose.

Remove allocation.

The attached, in my view raises important questions regarding the potential flood risk to existing properties downstream of HG1 KS4. the Authority are required to provide evidence that the requirements of TAN15 are met. Now, not at some future date.

HG1 KS3 LAND AT READERS WAY, RHOOSE
Flood Risk to existing properties
The RLDP provides no evidence that surface water flow, SuDS capacity, exceedance routes or downstream drainage have been assessed. Without this, the Council cannot show that development would not increase flood risk to properties downhill of the site. The allocation is therefore unsound and high risk and should be removed.

The allocation is premature and unjustified
Until the Council can demonstrate—through strategic evidence rather than future planning applications—that:
• Flood risk can be fully mitigated,
• Downstream properties will not be exposed to increased hazard, and
• Drainage infrastructure can cope with additional flows,
Without the above, the allocation should not proceed.
For the reasons above, the Land at Readers Way (SP4 KS3) should be immediately removed from the RLDP on the grounds that the site is unsound, insufficiently evidenced, and poses an unacceptable and unmitigated flood risk to existing communities located downhill, including my property and dozens of others along the south western boundary.

HG1 KS3 LAND AT READERS WAY, RHOOSE
Flood Risk to existing properties - insurance implications.
As a result of the above, there are insurance implications for existing properties on the south western boundary of HG1 KS3
This proposal shows catchment basins right along our boundary. If they have any risk of overflowing, the main insurance implications fall into three areas: our own home insurance, the developer’s liability, and future insurability of our property. The specifics depend on how the basins are designed, maintained, and whether they increase the flood risk to existing properties to the south west. All remain unanswered by the LDP.
This will affect our own home insurance – and that of all existing properties along the south western boundary of the site.
Overflowing basins can change how our insurers view our property’s risk profile. As follows: -
1. Increased flood risk classification
If runoff from the basins could reach our garden or home, insurers will treat our property as being at higher flood risk. This will lead to: -
• Higher premiums
• Higher excesses for flood related claims
• In some cases, fewer insurers willing to offer cover

Increased flood risk fails the requirements of TAN15
The RLDP provides no evidence that surface water flow, SuDS capacity, exceedance routes or downstream drainage have been assessed. Without this, the Council cannot show that development would not increase flood risk to properties downhill of the site. The allocation is therefore unsound and high risk and should be removed.
I am strongly objecting to the proposed allocation of Land at Readers Way, Rhoose (SP4 KS3) within the Replacement Local Development Plan 2021–2036. My property lies downhill to the south‑west of the proposed site. This topographical relationship creates a direct and unavoidable surface water flood risk to existing homes that has not been addressed in the RLDP evidence base.
1. Natural topography creates inherent flood risk
The Readers Way site sits at a higher elevation and drains naturally toward the south‑west, directly toward existing residential areas including CF62 3FT. This means that any increase in impermeable surfaces will accelerate and concentrate surface water flows downhill. This is a structural constraint, not a design detail, and cannot be fully mitigated at plan stage.
2. Lack of evidence that flood risk can be mitigated
The RLDP does not provide: -
• A strategic flood consequences assessment for this allocation.
• Any modelling of overland flow routes toward the south‑west.
• Evidence that SuDS features can be accommodated at sufficient scale to prevent increased run‑off.
• Assessment of exceedance events (extreme storms) and where water will flow when drainage systems are overwhelmed.
• Confirmation that downstream drainage infrastructure has capacity for additional discharge.
Without this evidence, the allocation fails the requirement in TAN 15 that development must not increase flood risk to third parties.
3. Existing surface water vulnerability downstream
Natural Resources Wales surface water maps already show areas of surface water accumulation within the surrounding streets. Allocating a major housing site upstream of an area with known surface water issues is contrary to national policy and introduces unacceptable cumulative risk.
4. Exceedance routes cannot be guaranteed at LDP stage
Safe exceedance routes depend on detailed design, ground modelling, and drainage engineering. None of this is available at LDP stage. Without it, the Council cannot demonstrate that water will not be directed toward existing homes during heavy rainfall. This makes the allocation unsound under the tests of deliverability and justification.
5. The allocation is premature and unjustified
Until the Council can demonstrate—through strategic evidence rather than future planning applications—that:
• Flood risk can be fully mitigated,
• Downstream properties will not be exposed to increased hazard, and
• Drainage infrastructure can cope with additional flows,
Without the above, the allocation should not proceed.
For the reasons above, the Land at Readers Way (SP4 KS3) should be immediately removed from the RLDP on the grounds that the site is unsound, insufficiently evidenced, and poses an unacceptable and unmitigated flood risk to existing communities located downhill, including my property and dozens of others along the south western boundary.

Insurance implications for existing properties on the south western boundary of HG1 KS3
This proposal shows catchment basins right along our boundary. If they have any risk of overflowing, the main insurance implications fall into three areas: our own home insurance, the developer’s liability, and future insurability of our property. The specifics depend on how the basins are designed, maintained, and whether they increase the flood risk to existing properties to the south west. The patterns below are relevant to HG1 KS3 and remain unanswered by the LDP.
This will affect our own home insurance – and that of all existing properties along the south western boundary of the site.
Overflowing basins can change how our insurers view our property’s risk profile. As follows: -
1. Increased flood‑risk classification
If runoff from the basins could reach our garden or home, insurers will treat our property as being at higher flood risk. This will lead to: -
• Higher premiums
• Higher excesses for flood‑related claims
• In some cases, fewer insurers willing to offer cover
This aligns with UK insurance guidance emphasising that new developments must remain insurable and should not worsen flood risk for neighbours.
2. Planning and drainage obligations
This plan does not demonstrate that the new drainage systems (including basins) does not increase flood risk to neighbouring land. This is part of national planning and flood‑risk policy. See also my previous comments pn the high risk nature of this proposal..
3. Maintenance responsibilities
Catchment basins require ongoing maintenance. If the Authority fails to maintain them and overflow occurs, liability falls on them. Maintenance will be required weekly due to regular wind-blown debris on recycling days
Long‑term implications
1. Impact on property value
2. Mortgage and insurance availability - Because insurance is a prerequisite for most mortgages, anything that jeopardises insurability can affect future buyers. UK guidance stresses that developments should not create uninsurable situations.

Photographs of historic run-ff flooding and highway flooding at Fontygary Inn traffic lights. Previously forwarded, with others to the Flood and Coastal Erosion Risk Management team at their request.
Flooding at Fontygary Inn traffic lights 19.11.24, The access into Fontygary Leisure Park was also flooded, preventing access. I have no photographs of that.
Run off showing mud content which leaves a muddy slurry all over Celtic Way creating a slip hazard.
Run-off is usually over prolonged periods. This time overnight and through the following day. Essentially every time it rains. This is a regular occurrence – 12 times since Christmas and over the 35 years we’ve lived here.
The site of the proposed development HG1 KS3 is often completely waterlogged with large areas of standing water. The extreme rum-off to the south west is a result every time it rains. This is not an extreme event.

In addition to the Llanmead propose development, with 350/400 houses there are further developments planned for Rhoose Point, Weycock Cross, St Athan & Llantwit Major. In addition, there are other developments such as Barry College near Cardiff Airport & a potential further development at Model Farm.
The amount of development is far in excess what this area can cope with for the following reasons:
Traffic Congestion
What consideration have been made to improve access to Rhoose/Cardiff Airport/St Athan/Llantwit Major? I was advised at the consultative meeting at Celtic Way community centre that adjustment may be made to Weycock Cross Roundabout? Whatever adjustments are made the increased traffic will still end up on Port Road, Porthkerry Road & the A4226. Not only this but I believe the traffic congestion would deter people using the Airport. You only have to have one breakdown or roadworks on Port Road to see the congestion that builds up from Weycock Cross back to the Hotel International on occasions & this can only become worse with further potential development
Traffic in Rhoose at current pinch points, is at a maximum with lack of parking at village shops, Schools, Doctors, Dentist & Chemist where would another potential 350 to 550 cars be accommodated from the Llanmead development alone?
At the consultative meeting above, I was advised the access to the Llammead development via Celtic Way was at present designed to be and emergency entrance/exit. It is quite probable that this entrance/exit will be turned into a regular entrance/exit meaning, potentially, a further 220+ cars travelling up a built-up area. What road safety adjustment to this road would be made if this entrance/exit become a reality?
Overall, the village cannot cope with the additional traffic as well as Port Road, not even considering the other planned developments.
Infrastructure
The Village has seen many developments over the years with the Hollies, Celtic Way, Rhoose Point & Golwg Mor, there has been little improvement of the infrastructure, with the potential 550+ additional people requiring, Schooling, Dentist & Doctor. The infrastructure is already under severe pressures as well as changes being made to these services currently underway by local Welsh Government. It is impractical to put more pressure on already under resourced service with an additional 550+ people.
I would enquire what investigations have been carried out with regards to the sewage capability within the village. I believe that when there are certain weather conditions the capacity of the sewage system in the village can overflow with raw sewage being evident under the bridge, on the entrance to the Fontygary Leisure Park. If this situation exists at present, then it certainly cannot cope with a further 350/400 households wastage. It may well be that the sewage system cannot be improved & as such would indicate how impractical it would be to propose further developments in Rhoose & a reminder of the Health & Safety risk to this development.

Recently, a significant quantity of raw sewage was surfacing and pooling under the railway bridge at Fontygary. This is not the first time this has occurred. It is also becoming a more frequent occurrence. We believe it was then overflowing in front of the chip shop and onto the grass towards Fontygary Park.
Welsh Water’s response to this was to blame the Vale of Glamorgan Council. They stated that the Vale Council were aware that the present sewage system is beyond capacity and that at times of high tide and heavy rain the system cannot handle the quantities of sewage entering the system. They stated that they are authorised to release raw sewage into the sea at Fontygary Bay at these times. They stated that while the Council continues to approve further building works with subsequent sewage entering the present system the situation will only further deteriorate.
Knowing this I believe that councillors have been irresponsible to allow any development (such as the new college at Rhoose Airport) before a new sewage system is put in place.
Given the public health risks of allowing sewage to overflow in this way, by making recommendations or decisions which will considerably worsen the situation, surely councillors and planning officers are deliberately exposing themselves to legal action. My main concern here is however the health risks needlessly increasing to the public.
I therefore object to any future developments in Rhoose until such time as a new sewage system is in place and has been given time to prove to work effectively.

We would also request that a member of the planning department reply to us by email and answer two questions:
1. Are they ignorant of the sewage backup/ capacity problems in Rhoose?
2. If they are aware of the current sewage problem how can they recommend any further building development in the Rhoose area?

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

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

Detailed Policies

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

5. Housing And Employment Allocations
Housing Allocations

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

See tables in attachment for site specific comments.

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

See tables in attachments for site specific comments