Our main concern is the vehicle access from development onto higher end, Llantwitt RD, and the lack of pedestrian pavments on this rd which is very narrow in places. There is already an increase in speeding traffic from other housing developments using it as a short cut to access the B4265. Llantwitt rd will need traffic calming measures to restrict and deter non higher end residental vehicles in order to protect pedestrians.

The residents of the area highlighted are being squeezed between developers we have suffered the daily work load of Walter's with all it's heavy machinery for the predicted years work only to be told we have another year, we have continually ask for traffic calming to deal with speading constantly promised no action this will just add more misery. With the 25 houses also planning has suggested behind higher end we will be in a building site condition for many years to come this is totally unfair

The size of the development is completely overwhelming for the surrounding environment. The only viable access to the site will be from the main road. The use of Higher End and the rural lane over the railway bridge as access for motor vehicles for 600 dwellings is completely unachievable and unsafe.
600 dwellings would accommodate approx 1,500 more residents.
Together with the proposed Church Farm development of 532 dwellings, a total increase to St Athan's population of approx 3000 residents.
St Athan's current population of just over 4000 would make this an increase of 75% of the population.

MD4 of the old LDP and SP13 of the proposed new RLDP state the requirement of ensuring community infrastructure is not significantly compromised by new developments and ensures provision, improvement and long term maintenance of education and healthcare facilities.
Currently residents of St Athan have to regularly travel outside of St Athan to access healthcare from GPs due lack of access within the village. The proposals make no mention of improving the current resources for access to healthcare within the RLDP, and a further 3000 residents would severely impact current and future residents.
From the gov.uk website, 1000 homes typically includes 250 primary school age children and 130 secondary school age children.
There is mention of improving, developing and expanding St Athan primary school, but no mention of any further resources for Llantwit Major Comprehensive. Children from St Athan have little option for secondary education, as public transport to Cowbridge is not possible due to the nature of the rural lanes not being accessible for buses.
Along with proposed developments outlined in the RLDP for the surrounding areas, all of which are within the catchment of Llantwit Major Comprehensive, there would need to be additional development of this school in order to meet the increased needs.
"The delivery of new or improved infrastructure must be undertaken in a timely and coordinated manner to meet the needs of existing and planned communities prior to, or from the commencement of, the relevant phases of development."
This quote is taken from the proposed RLDP.
There would be a great demand for additional resources from the local council to both health care and education provision in St Athan in order to meet the requirements and mandate of the LDP, prior to any development being undertaken.

Section SSC1 of the RLDP discusses the size of the proposal to ensure the scale is appropriate and compatible with the layout, density and appearance of the existing settlement. A population increase of 75% would not be deemed appropriate or compatible with the current settlement of St Athan in terms of amenity or character of a rural village.
PGD2 Residential Development Densities
6.53 "In line with PPW, and Future Wales[7], Policy PGD2 supports the residential development at higher densities particularly where these proposals are located within urban centres and near major public transport nodes or interchanges and where these can assist in supporting local services and facilities. In such locations proposals that deliver residential densities of 50 dwellings per hectare and above will be encouraged where this would not lead to an adverse impact on the character of the area nor would undermine the wider placemaking and well-being objectives of the plan."
"Higher net densities will be supported where the development is in a location served by regular public transport and Active Travel routes, or near to services and facilities."
St Athan could not be regarded as having either regular public transport, an Active Travel route, nor has it services or facilities that could accommodate a population of over 7,000 residents.
In order to provide the services and facilities, the infrastructure would need to be in place that would change St Athan from a rural village to a town, changing the very nature of the existing settlement, in conflict with SSC1.

Settlement boundaries appear to be more mobile than in previous years with the definitions being altered and boundaries expanded.
6.25 "Settlement boundaries define the areas within which the principle of development would normally be acceptable, encouraging the efficient use and redevelopment of land and buildings and preventing the spread of new development in the open countryside."
6.26 "Settlement boundaries defined the extent of build development where development would normally be allowed, and areas of the countryside and areas of more sporadic buildings, which are considered less suitable for new development, and where a more restrictive approach will be applied. For the purposes of the plan, areas outside of the defined boundaries that are not allocated or protected for specific uses are defined as ‘countryside’, where a more restrictive approach will be applied".
Both Church Farm development and Land West of St Athan fall into the parameters of sites less suitable for new development by being areas of farmland and countryside.

Existing road from St Athan/Rhoose to Barry is already over capacity and MUST be upgraded BEFORE and more houses.

I should like to echo the concerns regarding access to this site. I am reassured that there will be no vehicular access to/from LLantwit Road in the village.

I am reassured to see that there is no planned access to Llantwit Road in the village for this development.

Utilise Traditional Architecture Design Codes for all new construction with a ban on demolition of all buildings constructed prior to 1950. See my PDF Umbrella Representation for additional Placemaking/ Planning and Greenery Proposals.

Remove site from the plan.

I live in Higher End in St. Athan. I moved here 12 years ago because I wanted to spend the rest of my life in this lovely village. I am very upset that you unfeeling people want to destroy our lovely village by building a huge estate of houses nearby which will destroy the whole character of this village. Have you considered the people who already live here?
You will take away the heart of our village and turn it into just another large soulless estate.
Please be assured I am very very concerned about what you are doing and plead with you not to go ahead with these plans.

We have grave concerns that vehicle access will, (despite not being shown on plans YET) eventually be built onto Llantwit road. This road has no continues pedestrian pavements, is VERY narrow, and currently has increasing numbers of vehicles speeding while using it as a short cut to avoid the Gileston rd. / B4265 junction. New housing will see a large increase in pedestrians from new development accessing Village via Llantwit Rd. vehicular access should ONLY be from B4265. with old Llantwit rd. being blocked and becoming access only.

No objection to this development and delighted to see land safeguarded for a potential new train station/halt with parking.

Whilst I would not object to derelict buildings being cleared. I know of at least two military type FW3/22 pillboxes with a possible third hidden by overgrowth. These were constructed in WW2 for the defence of the RAF airfield and I beleive may be listed buildings. In any case, these should be preserved as historical features of interest with educational sign board attached or errected alongside.

The scale of the proposed housing development on this site is excessive and would completely change the character and nature of St Athan from a village into a dormitory settlement. There is inadequate provision to support this level of development. Major additional facilities - shops, pharmacies, doctors, dentist, schools, public transport, leisure facilities - would be needed and are not covered in current proposals

The scale of housing development proposed for St Athan is excessive and spoils the nature of the heritage coast. Use of this site would breach the policy on the coast set out in the plan.

No objection to this development and delighted to see land safeguarded for a potential new train station/halt with parking. Having studied the plans, the intended land reserved for a station/halt is a perfect location and would be a godsend to St Athan. I'm old enough to remember the old Gilestone station being very busy with military personnel when RAF St Athan was in its heyday with some 2000 plus serving and civilian personnel. The St Athan population alone has now exceeded that so it's time to build a new rail facility.

Of course derelict buildings being cleared but I know of at least two military type FW3/22 pillboxes with a third on the road side near the airfield entrance gates. These were constructed in WW2 for the defence of the RAF airfield south side and I believe may be listed buildings. In any case, these should be preserved as historical features of interest with educational sign board attached or erected alongside. The southernmost one in the field appears to be of poured concrete construction and in visibly sound condition.

I did submit my concerns on the on-line portal but it was word limited and I wanted to expand on the matter.

I thank you and all the decision makers for your kind consideration

Objection 1 – The size of the proposed development.

The Welsh Government have stated a requirement for 8,660 additional houses to be built within the Vale of Glamorgan.
Of the 5 key sites, St Athan is most heavily targeted with proposals of 1150 new dwellings within the Church Farm sites and Land West of St Athan site, with additional dwellings at other locations within the village.

There is a heavily weighted population increased to the village of St Athan within the 2 key sites and other proposals within St Athan, compared with the other key sites.
An increase of over 1150 dwellings and the associated increase in number of residents would significantly change the existing settlement of St Athan.

Section SSC1 of the RLDP
6.27 To ensure that new development within settlement boundaries is successfully integrated, proposals will need to demonstrate that they complement the layout, scale, fabric, and appearance of the existing settlement. It will also be important to ensure that the scale and quantity of such developments is in proportion to the size of the settlement, and the range of services and community facilities that are available at the time of the application.

The proposal discusses plans to improve infrastructure, facilities and services as part of the development, recognising that there will be a need to provide additional resources to meet the needs of the increased population.
This is acknowledging that there is not the current infrastructure at the time of the application as stated in point 6.27 of the RLDP, and therefore fails to meet the criteria stated in the Vale of Glamorgan Council’s own policies.

1a. The size of the proposed development is too big for St Athan to maintain its character and will fail to provide adequate resources and infrastructure to meet the needs of the additional population. This is contravening the Vale of Glamorgan Council’s own policies within the RLPD, section SSC1 6.27.


The Vale of Glamorgan Council have suggested that St Athan is a suitable placement to justify this number of additional homes, based on the potential employment opportunities at Bro Tathan Business Park.

Section SP6
6.95 - the adjoining Bro Tathan Enterprise Zone provides a range of employment opportunities, with the delivery of a significant number of additional jobs expected over the plan period, ensuring new housing is co-located with employment opportunities

The RLDP requests new housing to be co-located with employment opportunities.
The term “expected” in relation to additional jobs is not a sufficient basis for proposing that the development ensures housing is co-located with employment opportunities if the opportunities do not currently exist.

“The delivery of new or improved infrastructure must be undertaken in a timely and coordinated manner to mee the needs of existing and planned communities prior to, or from the commencement of, the relevant phases of development.” – RLDP
“We need to pledge that employment, training and investment in the built environment is achieved before houses are built otherwise more people are using cars etc.” BP1 Engagement Report

1b. The proposal aims to build a significant number of dwellings to house employees of jobs that do not currently exist. This is not in accordance with the Vale of Glamorgan’s own policies within the RLDP, SP6 6.95 and SSC1 6.27 which states that facilities must be in place at the time of the application.


Objection/ Concern 2 – The potential traffic on Llantwit Road.

The current proposal offers a single access point onto the new development via a new roundabout off the B4265.

The Apex Transport Assessment (dated 3.7.25) comments on the lack of safe pedestrian footpaths on Llantwit Road and acknowledges that low speeds and low traffic volumes have aided minimising road accidents to date.

Section 4.2.12 states -
There may also be the potential for closing Llantwit Road to through traffic to the airfield, which will assist in providing an improved pedestrian environment for existing and potential future users.

5.2.4 The existing Llantwit Road could also be stopped up at its western end, and access through to the existing employment uses on the airfield obtained from the new roundabout / signal junction onto the B4265. There is also an option for a potential new site access onto the B4265 to facilitate access to part of the allocated Enterprise Zone to the west of the site.

5.2.5 The site can also provide a secondary or emergency access onto Llantwit Road to its north-western boundary which enables access in the event of an emergency which blocks the roundabout onto the B4265. However, this would not be accessible in ‘normal’ conditions, to ensure that vehicular traffic does not impact the route along Llantwit Road.

5.2.11 A vehicular access from Llantwit Road for ‘normal’ traffic conditions is not considered appropriate due to the width of the carriageway along Llantwit Road and to ensure it remains appropriate for walking and cycling, as currently. An access from the B4265 was therefore considered the only viable option to and from the site.


2. I would concur with all these statements and support the measures suggested above to minimise additional traffic onto Llantwit Road.


Objection 3 – The potential for using Llantwit Road as a bus route

In the Apex Transport Assessment, section 4.5.4:
“Potential diversion for the 304 bus service through the proposed development, with the option of access via a bus gate on Llantwit Road.”

Appendix I: Indicative Footway Improvement on Llantwit Road shows a diagram of the road widths along Llantwit Road incorporating the recommended 1 – 1.5m footpath.
The resulting highway measures between 6.5m at it’s maximum to 3.5m at the minimum, and does not take into account the parked cars along the road.
Using Llantwit Road as a bus route would negate the potential use for suitable and safe use for pedestrians and cyclists, as advised below in section 5.3.3 of the Apex Transport Assessment.

“The main spine road itself will be designed to accommodate buses and would route through the centre of the site, enabling buses to enter an exit from the B4265. In addition, there is an option to provide a potential route from the B4265 to the allocated employment site to the west, enabling delivery of this land. To bring forwards this connection and ensure that there is no impact from vehicle movements on Llantwit Road, Llantwit Road can be stopped up for through vehicle movements to the west of the residential area, so that all vehicle movements to and from the employment site and the potential residential development site would utilise the potential B4265 roundabout access. This would provide a benefit to existing residents along Llantwit Road by reducing vehicle movements along this route and ensuring it remained suitable and safe for shared use by walking, cycling and vehicles.”

3. The use of Llantwit Road as a bus route would not be in keeping with the potential Active Travel Route highlighted in the Apex Transport Assessment.

No development in this village

Development in this area will add to the overburdened highway on port road towards weycock cross. There is already gridlock when any incident happens on the highway, and unacceptable queuing with the existing traffic so any additional traffic will cause this to get even worse, and the proposals to mitigate this are based on outdated traffic counts and so are inadequate.

The size of the development ( along with other plans for St Athan) is disproportionate to the existing village size putting significant strain on existing infrastructure.
There are concerns about possible vehicular access onto Higher End when traffic flow along this narrow road used by many pedestrians has increased significantly since the last traffic survey. I propose the estate is a cul de sac with Higher End made into a no through road, access to Bro Tathan and the Helicopter base being provided via a new access point.

This along with other sites in St Athan is being considered for addition into the LDP before due consideration is given to public transport and roading infrastructure in the area and wider vale. This development would again in the current form and situation lead to an increased reliance on private vehicles for commuting to major centres and a resultant major negative impact on already over capacity road junctions towards Barry and Cardiff such as Weycock cross.

As the property owner which is in the Top north-west corner of the proposed development I would like to be assured that:
The planting of a green buffer zone which is mentioned for several other locations, i.e. the Heritage site to the north and the listed building on Llantwit road would also be extended to include Briarbank.

The footpath which is shown on the master plan as exiting in the Top north Northwest corner would be moved eastward so as to avoid being right next to Briarbank.

It has been proposed to block Llantwit Road on its western route, does this mean that Briarbank will have no vehicle access into St Athens.

I assume this development will take place over various stages over many years,what mitigation steps will be put in place to prevent construction noise and Windbourne pollutants from affecting existing residents?

Again this assumes there is a Proposed station - this should not be reserved space but an actual station built and operational before this development commences

This is yet another allocation for St Athan. The overdevelopment of St Athan once a village should be taken as a special impact item for overall discussion not each plot in isolation! Infrastructure is a particular concern the impact on traffic movements via B4265 are not fully planned in.

The overdevelopment of St Athan once a village should be taken as a special impact item for overall discussion not each plot in isolation! This plot is not linked directly with St Athan and would cause significant impact on the B4265 a crossing point is already an issue together with the junction at the monument.

If the construction of a new housing estate at Land West of St Athan is unavoidable, the development should have as little negative impact as possible on the existing St Athan community and residents by being a self-contained cul-de-sac accessed only from the B4265, with no vehicular access to or from Llantwit Road, to minimise the impact of additional traffic in the village.

There should be no vehicular access point on Llantwit Road for any residential development on the Land West of St Athan site.

Reduce the housing density at the above sites and re-classify St Athan as a "Minor Rural Settlement" until such time as a dedicated rail link, suitable active travel infrastructure or high-frequency public transport other than rail is fully funded and scheduled for delivery.

Representation on the Vale of Glamorgan Deposit RLDP 2021–2036
Specific Policy/Site Objection:
• Policy SP4.4: Land at Church Farm, St Athan
• Policy SP4.5: Land to the West of St Athan
• Clive Road (Additional Allocation)
• Policy EMP2: MOD St Athan / Bro Tathan
Status: Unsound
1. Introduction
I wish to formally object to the allocation of the above sites and the broader designation of St
Athan as a "Primary Settlement" for high-density growth within the Replacement Local
Development Plan (RLDP). This allocation fails the Test of Soundness regarding Consistency
(with national climate goals) and Effectiveness (deliverability of infrastructure).
2. Failure of Sustainable Transport (Policy SP7 & SP10)
The RLDP identifies St Athan as a "Strategic Hub," yet it remains the only primary settlement in
the Vale of Glamorgan without a direct rail link. Relying on the "Active Travel" aspirations of
Policy SP10 is unrealistic for a community where the majority of residents commute to Cardiff,
Bridgend, or Barry.
The proposed density at the above sites will inevitably lead to an unsustainable increase in
private car journeys on the B4265, specifically at the Gileston Road junction and Weycock
Cross, which are already at or near capacity.
Concrete infrastructure is needed to be in place prior to any development of the land. Often
intentions of infrastructure are not progressed. In addition where infrastructure is not in place
prior to housing many commuters will become accustomed to travel by car and wont switch to
public transport. It is difficult to see how developments work with Future Wales: The National
Plan 2040
Active travel should look at linking key destinations and with the western vale being spread over
longer distances more effort should be given to linking population centres with separated
bicycle paths and wide accessible pavements. Shared bike / foot paths are inherently
dangerous not allowing the safe use of wheelchairs and prams and sufficient use for children
and dog walkers. Cycling should not have to stop at every intersection which creates visibility
black spots by the way they turn away from traffic.
With current planned housing and that of additional housing in the LDP creating over 1,000 new
homes and with each household having 1-2 cars per household this will add significant
additional numbers of journeys on already poor road infrastructure. The vale lacks sufficient
north / south routes pushing vehicles towards Weycock Cross in Barry which will have its own
traffic issues or via Cowbridge with small country lanes. I personally worked in Cowbridge
travelling from St Athan where buses would take over 1 hour 10 minutes and even then not
arriving in time to start work. In contrast car travel would be 10 minutes or cycle would be 20
minutes but over dangerous roads.
Travel to Barry for meetings at peak times can take over 50 minutes from St Athan with
significant delays leading to Weycock Cross and passed the secondary schools even before
developments in the RLDP or existing planning. Public transport gets caught in the same traffic
issues.
Access into St Athan is already dangerous from the war memorial with one near fatal accident
already having taken place since the ‘improvements’ to the junction. Proposals for additional
access from B4265 onto developed land would be on a hill with poor visibility and around a
blind bend. Currently there is poor visibility leaving St Athan due to the side by side two car exit
blocking views in both directions along with more visibility issues looking westward due to
traffic furniture and signage.
While Bro Tathan (Policy EMP2) provides jobs, there is no guarantee that the people moving
into local developments will work there. If they commute elsewhere, the RLDP fails its own
climate goals (Policy SP1) by creating a "commuter colony" rather than a sustainable
community.
Reference Policy CI3 (New Community Facilities). The proposed expansion of St Athan
Primary School lacks a guaranteed timeline for when these facilities will be operational relative
to house completions. New access to the school under existing planning is only ‘proposed’ and
existing access to the school via Rock Road is a poorly surfaced and narrow one way road but is
often ignored with traffic coming via Rectory Drive which has a ‘No entry except for access’
restriction but is not enforced causing large numbers of vehicles into residential areas not built
for this type of activity.
Speeding is already a great concern in the village with the current level of vehicle traffic with
little compliance with the 20mph speed limit and no enforcement.
3. Coalescence and Loss of Settlement Identity (Policy SSC1)
The scale of development proposed for Church Farm, in conjunction with Policy SP4.5 (Land
West of St Athan), threatens the distinct character of the village. The erosion of the "Strategic
Gap" between St Athan and Eglwys Brewis violates the principles of Policy SSC1 (Settlement
Boundaries). This "urban creep" creates a continuous sprawl that permanently destroys the
rural setting of the historic Church Farm and the village’s unique sense of place.
St Athan should no longer be thought of as a village but as a small town with infrastructure to
meet the growing demands of the population and lacks facilities that are given to surrounding
towns such as fire / ambulance and police stations.
If the jobs at the Enterprise Zone (Aston Martin, Bro Tathan) do not match the demographic of
the new residents, St Athan simply becomes a "dormitory" village, increasing the carbon
footprint as people drive to Cardiff or Bridgend for work. In addition people will travel to St Athan
from other areas should they be employed at the new commercial sites.
4. Infrastructure Lag and Healthcare Capacity (Policy CI3)
Under Policy CI3, development should only proceed where adequate community facilities exist
or can be provided. Current primary healthcare services in St Athan and nearby Llantwit Major
are already oversubscribed. The RLDP provides no "Triggers for Delivery" to ensure that new
medical and educational facilities will be operational prior to the occupation of the hundreds of
homes planned for the Church Farm site. This creates a significant risk to the wellbeing of both
new and existing residents. Access to both village GP services are on a part time basis. With
new dentist rules in Wales, this will increase the need for further travel around the area to meet
simple check ups. With no A&E facilities in the county St Athan often falls between Cardiff and
Bridgend hospitals and continued poor roads together with additional traffic gives greater
concern when emergencies happen.
5. Environmental and Biodiversity Impact (Policy SP5)
The Church Farm site consists of high-quality agricultural land and vital greenfield habitats.
While Policy SP5 mandates a "Net Benefit for Biodiversity," the total loss of soil permeability
and ancient hedgerow connectivity on a site of this scale cannot be mitigated by tokenistic
landscaping. Once this valuable land is developed it is irretrievably lost for current and future
generations. Currently there are red list species using the space like Yellowhammers and
Skylarks. In addition there has been a collapse of invertebrate bio-mass over the last 40 years
and personally seen since moving the area in 1980. Net Benefit for Biodiversity plans do not
address any of these local and national concerns.
Land to the west of St Athan (SP4.5) This site consists of Grade 2 (Good) or 3a (Excellent)
agricultural land. Under Planning Policy Wales (PPW) 12, such land should only be developed
if there is an "overriding need" and no lower-grade land is available. The Vale of Glamorgan
council has not sufficiently explored brownfield alternatives in the Barry Docks or the St Athan
Enterprise Zone. The increased light pollution and "urban glow" will impact the rural character of
the Western Vale.
The invertebrate charity Buglife shows that based on citizen science monitoring data, there has
been a 75% to 79% decline in the abundance of flying insects in Wales between 2004 and 2023.
Natural Resources Wales also reported
• 79% Decrease in Flying Insects (2004–2023): Data from the "Bugs Matter" survey,
which counts insect "splats" on vehicle number plates, recorded this 79% reduction in
Wales, with 2023 showing further declines from previous years.
• Specific Invertebrate Declines: Moths, which are key pollinators, have seen an average
decline of 43% in abundance since 1970.
• Widespread Biodiversity Loss: Welsh wildlife has decreased on average by 20% since
1994, and 18% of species in Wales are at risk of extinction.
• Habitats in Peril: Over the past 50 years, many insects have suffered declines of 65% to
70% in certain areas, particularly moths, butterflies, ladybirds, and ground beetles.
• Impact on Food Chain: Invertebrates that provide food for farmland birds have seen
declines of 50-80%.
The cumulative impact of hard-standing surfaces also raises serious concerns regarding
surface water runoff into the River Thaw catchment area. Significant surface flooding already
takes place across the western Vale spilling onto roads causing travel disruption.
An increase in hard surfaces also increases ambient temperatures compared to grassland,
woodland and other green spaces necessitating increased power use for cooling and
comfortable living temperatures. Building practices can help mitigate this but only where this is
incorporated into sustainable building rules.
Replacing green fields (which act as a natural sponge) with hundreds of roofs and driveways at
Church Farm (SP4.4) and Land West of St Athan (SP4.5) will create a "funnel effect."
Dwr Cymru Welsh Water has previously noted concerns regarding the St Athan Wastewater
Treatment Works. Proof is required that the current system can handle the RLDP's projected
f
low without increasing overflow events. Further development risks "Combined Sewer
Overflows" (CSOs) into local watercourses, which contradicts the Council’s Nature Emergency
declaration.
The Vale of Glamorgan Council requires a Sustainable Drainage Systems (SuDS) Approval
Body (SAB) review. Attenuation ponds are often poorly maintained and can fail during the "1-in
100-year" storm events which are becoming more frequent.
6. Conclusion
The allocation of the above site policies are unsound. It promotes car-dependent growth in a
rural location without the necessary infrastructure "trigger points" to protect the local
environment or the B4265 road network.
Proposed Remedy: Reduce the housing density at the above sites and re-classify St Athan as a
"Minor Rural Settlement" until such time as a dedicated rail link, suitable active travel
infrastructure or high-frequency public transport other than rail is fully funded and scheduled
for delivery.

Request that the proposals for these areas be
withdrawn or fundamentally revised.

Concerns Regarding the Church Farm Development
The proposals for Church Farm raise several serious concerns that further demonstrate the unsoundness of the RLDP.

A1 Retail Unit and Risk of Change of Use
The inclusion of an A1 retail unit within the Church Farm plans is presented as a community benefit, yet there is no guarantee that this unit will ever operate as a shop. Developers routinely apply for change‑of‑use permissions after approval, and there is a legitimate concern that this “retail unit” could later be converted into additional housing. This would reduce promised community facilities while increasing housing density beyond what has been publicly consulted on. The RLDP provides no safeguards to prevent this outcome.
Unsafe and Inappropriate Access Point
The proposed entrance to the Church Farm development is extremely concerning. It is located on a narrow section of road, in close proximity to a school, and adjacent to an existing shop that already generates local traffic and pedestrian activity. Crucially, this road is the only route into the village from the east. Introducing hundreds of additional vehicle movements at peak times will create serious safety risks, particularly for children walking to and from school. The RLDP provides no evidence that this road can safely accommodate the increased traffic.
Traffic Chaos at Peak Times
Because this road is the sole eastern access into St Athan, the additional vehicles generated by the Church Farm development will cause significant bottlenecks. Morning and evening peak times will be particularly affected, with queues forming along a route that has no capacity for widening or alternative diversion. This is a clear example of development being proposed in a location where the road network is fundamentally unsuitable.

Inadequate Public Transport and Increased Car Dependency
The RLDP repeatedly claims to promote sustainable travel, yet the proposals for these villages directly contradict that aim. St Athan, Flemingston and Eglwys Brewys have no railway station, limited and unreliable bus services, and no realistic active‑travel links. Without credible, funded improvements, new development will force residents to rely almost entirely on private cars, increasing congestion, pollution, and carbon emissions. This directly undermines the Council’s own climate‑change and sustainability commitments.

Absence of Local Employment Opportunities
The RLDP proposes significant housing growth without any realistic strategy for local employment. Previous employment sites have either reduce, closed or been repurposed, leaving limited job opportunities especially in the more rural areas where the majority of the housing development seems to be proposed. Most residents must commute to Barry, Cardiff, Bridgend or further afield, and new development will only increase outward commuting. This contradicts the RLDP’s stated objective of creating balanced, self‑sustaining communities.

Increased Surface Water Flooding from Loss of Farmland
The conversion of agricultural land into housing poses a serious flood‑risk concern. Farmland currently provides natural drainage and water absorption. Replacing it with hard surfaces will increase surface water run‑off, heighten flood risk for existing homes and roads, and place additional pressure on drainage systems already known to be fragile. The RLDP does not provide robust, site‑specific drainage strategies or long‑term maintenance plans to address these risks.

No Provision for Upgraded Infrastructure or Essential Services
One of the most serious shortcomings of the RLDP is the complete absence of any provision for upgraded essential infrastructure to support the proposed population growth. The plan does not include additional GP or dental capacity, increased fire, police or emergency service provision, meaningful road network improvements, or investment in community facilities. This omission makes the RLDP fundamentally unsound, as it fails to provide the basic services required for safe, healthy, functioning communities.

Potential for Increased Anti‑Social Behaviour and Pressure on Policing
The RLDP also fails to consider the social impacts of large‑scale development in rural villages. Rapid population growth without corresponding investment in community facilities, youth services, open spaces, and policing capacity increases the risk of anti‑social behaviour. St Athan, Flemingston and Eglwys Brewys are currently served by a police force that is already stretched, with limited local presence. Additional housing without increased policing resources will place further pressure on officers, reduce the ability to respond promptly to incidents, and undermine community safety and cohesion.

If the construction of new housing estates at Site 456 Land West of St Athan and Site 462 Church Farm is unavoidable, the developments should have as little negative impact as possible on the existing St Athan community and residents by being self-contained cul-de-sacs accessed only from the B4265, with no vehicular access to or from Llantwit Road or Gileston Road respectvely, to minimise the impact of additional traffic in the village. There should be no vehicular access point on Llantwit Road or Gileston Road for any residential development on the Land West of St Athan and Church Farm sites.

1. Section of Plan to which this Representation Relates
- Sustainable Growth Strategy
- Key Housing Sites:
KS4 - Land at Church Farm, St. Athan (532 dwellings) KS5 - Land to the West of St. Athan (600 dwellings)
- Housing Allocations: HG1(7)
Former Stadium Site, adjacent to Burley Place (80 dwellings)
HG1(8) - Clive Road, St. Athan (51 dwellings)
- Transport Policy (TR)
- Community Infrastructure Policy (CI)
- Policy SP13 - Infrastructure Provision
- Green Infrastructure Policies

2. Summary of Representation
This representation raises concerns regarding:
1. The scale of housing growth in St. Athan.
2. The absence of guaranteed sustainable transport infrastructure.
3. Insufficient retail and community infrastructure provision, particularly within the ward of Flemingston.
4. The allocation of the Clive Road site (HG1(8)), which currently functions as a de facto village green.
5. The cumulative infrastructure impact of candidate and legacy site allocations.
The representation seeks modifications to ensure the Plan is infrastructure-led, deliverable, and compliant with national planning policy and the Well-being of Future Generations (Wales) Act 2015.

3. Scale of Housing Growth in St. Athan
The RLDP allocates:
- KS4 - 532 dwellings
- KS5 - 600 dwellings
- HG1(7) - 80 dwellings
- HG1(8) - 51 dwellings
This equates to 1,263 dwellings in St. Athan.
This represents a very significant expansion of the settlement and must be assessed against:
- Existing infrastructure capacity
- Transport provision
- Education and healthcare availability
- Retail and service provision
At present, St. Athan does not have a rail station and relies heavily on private car travel.
The Plan must demonstrate clearly that this level of growth is proportionate and deliverable.

4. Transport Infrastructure and Deliverability
The RLDP safeguards land for a "transport interchange" at St. Athan. However:
- There is no confirmed rail station.
- There is no confirmed funding package.
- There is no defined delivery programme.
- There are no binding occupation triggers linking housing delivery to transport delivery.

Previous references in planning documents referred to a railway station. The revised terminology of "transport interchange" reflects uncertainty.

Under Future Wales - The National Plan 2040, growth within the South East National Growth Area should align with sustainable transport infrastructure. Without guaranteed rail provision, development risks being car-dependent and inconsistent with decarbonisation objectives.

This raises concerns under the soundness test: Will the plan deliver?

5. Retail and Local Service Provision - Flemingston Ward

The Deposit RLDP does not allocate new retail units or local service provision within the ward of Flemingston.
Given the scale of proposed housing growth across St. Athan and its surrounding areas, there is:

- No corresponding neighbourhood retail allocation.
- No clear commitment to small-scale convenience retail within walking distance of new development.
- No spatial recognition of Flemingston's service deficit.

This is inconsistent with Planning Policy Wales placemaking principles, which require:

- Mixed-use neighbourhoods.
- Walkable access to daily services.
- Reduced reliance on private vehicles.

Without provision of much-needed retail units within Flemingston ward, residents will remain dependent on car travel for everyday needs.
Modification is therefore sought to require neighbourhood retail and service provision proportionate to housing growth.

6. Clive Road Site (HG1(8)) - Community Function

The Clive Road site (HG1(8), 51 dwellings) currently functions as a de facto village green.
Although not formally designated, it is:
- Used informally for recreation.
- A visual open space within the settlement.
- A valued community amenity.
Its allocation for housing would result in:
- Loss of accessible informal open space.
- Erosion of community character.
- Reduction in green infrastructure connectivity.
The Plan should:
- Reassess the allocation in light of its community use; or
- Require equivalent or superior replacement open space within immediate proximity prior to development.
This matter engages Policy on Open Space and Green Infrastructure and must be considered in accordance with the prevention and long-term principles of the Well- being Act.

7. Candidate and Legacy Sites - Cumulative Impact Several allocations in St. Athan arise from:
- The Candidate Site process.
- Rolled-forward legacy allocations.
Individually, smaller sites may appear acceptable. However, cumulatively they produce substantial growth in a settlement with constrained infrastructure.
The Plan must demonstrate:
- Why these sites were preferred over alternatives.
- That lower growth options were robustly assessed.
- That greenfield loss is justified and mitigated.

8. Infrastructure and Phasing Concerns
Policy SP13 refers to securing infrastructure through planning obligations. However, reliance on financial contributions alone does not ensure timely delivery.

There is insufficient clarity regarding:
- Education capacity expansion.
- Primary healthcare provision.
- Highway mitigation triggers.
- Public transport enhancement sequencing.

Infrastructure must be delivered ahead of, or in tandem with, housing occupation - not retrospectively.

9. Compliance with the Five Ways of Working

Long-Term: Irreversible greenfield expansion without secured sustainable transport risks embedding long-term car dependency.
Prevention: Without infrastructure-first sequencing, congestion and service strain are foreseeable.
Integration: Housing growth appears to run ahead of confirmed transport and retail provision.
Collaboration: The Plan should demonstrate binding commitments from transport and infrastructure partners.
Involvement: Community concerns regarding scale and open space loss must be properly addressed.

10. Modifications Sought

To ensure soundness and compliance with national policy, the following modifications are requested:

1. Phasing Policy for KS4 and KS5
Introduce clear occupation thresholds tied to delivery of:
- Transport interchange infrastructure.
- Highway mitigation.Education capacity.
- Healthcare provision.

2. Retail Provision Requirement
Require neighbourhood retail and service provision within the ward of Flemingston proportionate to allocated and previous housing growth.

3. Clive Road Site Review (HG1(8))
Either:
- Remove the allocation; or
- Require replacement open space of equal or greater quality delivered prior to development.

4. Strengthened Infrastructure-First Wording
Amend Policy SP13 to make infrastructure delivery a pre-condition, not solely a contribution mechanism.

5. Monitoring Framework Enhancement Include specific indicators for:
- Sustainable transport modal share.
- Retail provision delivery.
- Open space replacement.
- Infrastructure phasing compliance.

11. Conclusion

St. Athan has a role within the wider Cardiff Capital Region and the South East National Growth Area. However, the current scale of housing allocation is not sufficiently matched by guaranteed infrastructure, retail provision, or community space protection.

Without modification, the Plan risks:
- Car-dependent growth,
- Loss of valued open space,
- Insufficient local retail provision,
- Pressure on community infrastructure.
This representation therefore seeks amendments to ensure that growth in St. Athan and Flemingston is proportionate, infrastructure-led, environmentally responsible, and compliant with Welsh planning policy.

Reduce the housing density at the above sites and re-classify St Athan as a "Minor Rural Settlement" until such time as a dedicated rail link, suitable active travel infrastructure or high-frequency public transport other than rail is fully funded and scheduled for delivery.

Representation on the Vale of Glamorgan Deposit RLDP 2021–2036

Specific Policy/Site Objection:
• Policy SP4.4: Land at Church Farm, St Athan
• Policy SP4.5: Land to the West of St Athan
• Clive Road (Additional Allocation)
• Policy EMP2: MOD St Athan / Bro Tathan

Status: Unsound

1. Introduction

I wish to formally object to the allocation of the above sites and the broader designation of St Athan as a "Primary Settlement" for high-density growth within the Replacement Local Development Plan (RLDP). This allocation fails the Test of Soundness regarding Consistency (with national climate goals) and Effectiveness (deliverability of infrastructure).

2. Failure of Sustainable Transport (Policy SP7 & SP10)

The RLDP identifies St Athan as a "Strategic Hub," yet it remains the only primary settlement in the Vale of Glamorgan without a direct rail link. Relying on the "Active Travel" aspirations of Policy SP10 is unrealistic for a community where the majority of residents commute to Cardiff, Bridgend, or Barry.

The proposed density at the above sites will inevitably lead to an unsustainable increase in private car journeys on the B4265, specifically at the Gileston Road junction and Weycock Cross, which are already at or near capacity.

Concrete infrastructure is needed to be in place prior to any development of the land. Often intentions of infrastructure are not progressed. In addition where infrastructure is not in place prior to housing many commuters will become accustomed to travel by car and wont switch to public transport. It is difficult to see how developments work with Future Wales: The National Plan 2040

Active travel should look at linking key destinations and with the western vale being spread over longer distances more effort should be given to linking population centres with separated bicycle paths and wide accessible pavements. Shared bike / foot paths are inherently dangerous not allowing the safe use of wheelchairs and prams and sufficient use for children and dog walkers. Cycling should not have to stop at every intersection which creates visibility black spots by the way they turn away from traffic.

With current planned housing and that of additional housing in the LDP creating over 1,000 new homes and with each household having 1-2 cars per household this will add significant additional numbers of journeys on already poor road infrastructure. The vale lacks sufficient north / south routes pushing vehicles towards Weycock Cross in Barry which will have its own traffic issues or via Cowbridge with small country lanes. I personally worked in Cowbridge travelling from St Athan where buses would take over 1 hour 10 minutes and even then not arriving in time to start work. In contrast car travel would be 10 minutes or cycle would be 20 minutes but over dangerous roads.

Travel to Barry for meetings at peak times can take over 50 minutes from St Athan with significant delays leading to Weycock Cross and passed the secondary schools even before developments in the RLDP or existing planning. Public transport gets caught in the same traffic issues.

Access into St Athan is already dangerous from the war memorial with one near fatal accident already having taken place since the ‘improvements’ to the junction. Proposals for additional access from B4265 onto developed land would be on a hill with poor visibility and around a blind bend. Currently there is poor visibility leaving St Athan due to the side by side two car exit blocking views in both directions along with more visibility issues looking westward due to traffic furniture and signage.

While Bro Tathan (Policy EMP2) provides jobs, there is no guarantee that the people moving into local developments will work there. If they commute elsewhere, the RLDP fails its own climate goals (Policy SP1) by creating a "commuter colony" rather than a sustainable community.

Reference Policy CI3 (New Community Facilities). The proposed expansion of St Athan Primary School lacks a guaranteed timeline for when these facilities will be operational relative to house completions. New access to the school under existing planning is only ‘proposed’ and existing access to the school via Rock Road is a poorly surfaced and narrow one way road but is
often ignored with traffic coming via Rectory Drive which has a ‘No entry except for access’ restriction but is not enforced causing large numbers of vehicles into residential areas not built for this type of activity.

Speeding is already a great concern in the village with the current level of vehicle traffic with little compliance with the 20mph speed limit and no enforcement.

3. Coalescence and Loss of Settlement Identity (Policy SSC1)

The scale of development proposed for Church Farm, in conjunction with Policy SP4.5 (Land West of St Athan), threatens the distinct character of the village. The erosion of the "Strategic Gap" between St Athan and Eglwys Brewis violates the principles of Policy SSC1 (Settlement Boundaries). This "urban creep" creates a continuous sprawl that permanently destroys the rural setting of the historic Church Farm and the village’s unique sense of place.

St Athan should no longer be thought of as a village but as a small town with infrastructure to meet the growing demands of the population and lacks facilities that are given to surrounding towns such as fire / ambulance and police stations.

If the jobs at the Enterprise Zone (Aston Martin, Bro Tathan) do not match the demographic of the new residents, St Athan simply becomes a "dormitory" village, increasing the carbon footprint as people drive to Cardiff or Bridgend for work. In addition people will travel to St Athan from other areas should they be employed at the new commercial sites.

4. Infrastructure Lag and Healthcare Capacity (Policy CI3)

Under Policy CI3, development should only proceed where adequate community facilities exist or can be provided. Current primary healthcare services in St Athan and nearby Llantwit Major are already oversubscribed. The RLDP provides no "Triggers for Delivery" to ensure that new medical and educational facilities will be operational prior to the occupation of the hundreds of homes planned for the Church Farm site. This creates a significant risk to the wellbeing of both new and existing residents. Access to both village GP services are on a part time basis. With new dentist rules in Wales, this will increase the need for further travel around the area to meet simple check ups. With no A&E facilities in the county St Athan often falls between Cardiff and Bridgend hospitals and continued poor roads together with additional traffic gives greater
concern when emergencies happen.

5. Environmental and Biodiversity Impact (Policy SP5)

The Church Farm site consists of high-quality agricultural land and vital greenfield habitats. While Policy SP5 mandates a "Net Benefit for Biodiversity," the total loss of soil permeability and ancient hedgerow connectivity on a site of this scale cannot be mitigated by tokenistic landscaping. Once this valuable land is developed it is irretrievably lost for current and future generations. Currently there are red list species using the space like Yellowhammers and Skylarks. In addition there has been a collapse of invertebrate bio-mass over the last 40 years and personally seen since moving the area in 1980. Net Benefit for Biodiversity plans do not address any of these local and national concerns.

Land to the west of St Athan (SP4.5) This site consists of Grade 2 (Good) or 3a (Excellent) agricultural land. Under Planning Policy Wales (PPW) 12, such land should only be developed if there is an "overriding need" and no lower-grade land is available. The Vale of Glamorgan council has not sufficiently explored brownfield alternatives in the Barry Docks or the St Athan Enterprise Zone. The increased light pollution and "urban glow" will impact the rural character of the Western Vale.

The invertebrate charity Buglife shows that based on citizen science monitoring data, there has been a 75% to 79% decline in the abundance of flying insects in Wales between 2004 and 2023.

Natural Resources Wales also reported

• 79% Decrease in Flying Insects (2004–2023): Data from the "Bugs Matter" survey, which counts insect "splats" on vehicle number plates, recorded this 79% reduction in Wales, with 2023 showing further declines from previous years.
• Specific Invertebrate Declines: Moths, which are key pollinators, have seen an average decline of 43% in abundance since 1970.
• Widespread Biodiversity Loss: Welsh wildlife has decreased on average by 20% since 1994, and 18% of species in Wales are at risk of extinction.
• Habitats in Peril: Over the past 50 years, many insects have suffered declines of 65% to
70% in certain areas, particularly moths, butterflies, ladybirds, and ground beetles.
• Impact on Food Chain: Invertebrates that provide food for farmland birds have seen declines of 50-80%.

The cumulative impact of hard-standing surfaces also raises serious concerns regarding surface water runoff into the River Thaw catchment area. Significant surface flooding already takes place across the western Vale spilling onto roads causing travel disruption.

An increase in hard surfaces also increases ambient temperatures compared to grassland, woodland and other green spaces necessitating increased power use for cooling and comfortable living temperatures. Building practices can help mitigate this but only where this is incorporated into sustainable building rules.

Replacing green fields (which act as a natural sponge) with hundreds of roofs and driveways at Church Farm (SP4.4) and Land West of St Athan (SP4.5) will create a "funnel effect."

Dwr Cymru Welsh Water has previously noted concerns regarding the St Athan Wastewater Treatment Works. Proof is required that the current system can handle the RLDP's projected flow without increasing overflow events. Further development risks "Combined Sewer Overflows" (CSOs) into local watercourses, which contradicts the Council’s Nature Emergency declaration.

The Vale of Glamorgan Council requires a Sustainable Drainage Systems (SuDS) Approval Body (SAB) review. Attenuation ponds are often poorly maintained and can fail during the "1-in-100-year" storm events which are becoming more frequent.

6. Conclusion

The allocation of the above site policies are unsound. It promotes car-dependent growth in a rural location without the necessary infrastructure "trigger points" to protect the local environment or the B4265 road network.

Proposed Remedy: Reduce the housing density at the above sites and re-classify St Athan as a "Minor Rural Settlement" until such time as a dedicated rail link, suitable active travel infrastructure or high-frequency public transport other than rail is fully funded and scheduled for delivery.

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).

MOD recommend that any more detailed policies for these sites include wording which indicates that development should be designed to ensure that it would have no impact on the operation or capability of defence sites or assets.

It is understood that Vale of Glamorgan Council are undertaking a Deposit Plan consultation regarding their proposed replacement Local Development Plan 2021 - 2036. This consultation details the overall Strategy, development policies, areas to be protected, and specific land allocations for development (including new housing, employment) over the 15-year period
The Defence Infrastructure Organisation (DIO) Safeguarding Team represents the MOD as a statutory consultee in the UK planning system to ensure designated zones around key operational defence sites such as aerodromes, explosives storage sites, air weapon ranges, and technical sites are not adversely affected by development outside the MOD estate.
For clarity, this response relates to MOD Safeguarding concerns only and should be read in conjunction with any other submissions that might be provided by other MOD sites or departments.
The Welsh Government’s Development Management Manual as revised May 2025, identifies, at figure 7, that a number of non-site-specific directions are currently in force, the list includes the Town and Country Planning (Safeguarded aerodromes, technical sites and military explosives storage areas) Direction 2002. Through this direction the MOD is involved in the planning system as a statutory consultee. Statutory consultation occurs as a result of the provisions of the Direction, and the plans issued to Local Planning Authorities by the Welsh Government, which are provided by MOD.
The area covered by any Vale of Glamorgan Council Local Plan is partially covered by a safeguarding zone that is designated to maintain the effective operation of a MOD technical site that is retained at St Athan, at which is located a High-Resolution Direction Finder (HRDF) technical asset. This is a navigational aid which serves to maintain air traffic safety.
To illustrate the various issues that might be fundamental to MOD safeguarding assessments, a brief summary of the technical safeguarding zone is provided below. Depending on the statutory safeguarding zone within which a site allocation or proposed development falls, different considerations will apply.
The dimensions and materials used in the construction of a development may be relevant factors in assessing the impact of a given scheme. Developments that incorporate renewable energy systems may be of particular concern given their potential to introduce large expanses of metal or electrical noise interference, which may be a particular issue where solar farms are developed.
The MOD notes and welcomes the intentions of Policy EMP2: MOD ST ATHAN. However, it is recommended that additional wording is added to make clear that this policy relates to the safeguarded MOD technical site. Therefore, it is recommended that wording is updated. “New development within or adjoining MOD St Athan and the safeguarded MOD technical site that is demonstrated to be required for operational defence and security purposes, and helps enhance or sustain their operational capability, will be supported in principle. Proposals for non-military or non-defence related development within or in the areas around MOD St Athan, or the safeguarded MOD technical site will not be supported where it would adversely affect military operations or capability, unless it can be demonstrated that there is no longer a defence or military need for the site.”
Where development falls outside designated safeguarding zones the MOD may have an interest where development is of a type likely to have any impact on operational capability. Usually this will be by virtue of the scale, height, or other physical property of a development. Examples these types of development include, but are not limited to:
Tall or narrow profile structures such as masts or flue stacks with a height of 50m or greater above ground level may introduce obstruction hazards to low flying military aircraft using the UK military low flying system.
The MOD also needs to be consulted on all proposals to develop wind turbines that are 11m or greater in height to blade tip or, that have a rotor diameter of 2m or greater. This is necessary to safeguard defence radar coverage across the UK used to manage MOD ranges, provide air traffic control and maintain UK air defence.
The MOD notes that Draft Policy CC3 assigns the renewable energy local search areas that have been defined in the deposit plan. This supports the generation of non-domestic renewable, low and zero carbon energy. The Renewable Energy assessment from 2023 identifies potential opportunity areas for renewable energy and provides a high-level assessment of wind and solar energy resource within the Vale of Glamorgan and identifies several sites, known as ‘search areas’ where the potential for development is greatest, and identification of 20 of the largest sites for both wind and solar.
Draft policy CC4 defines requirements that any development will need to demonstrate compatibility with. It is noted that specific reference to aviation safeguarding is included. However, the MOD considers it necessary that this is expanded to include specific reference to those technical assets which facilitate aviation safety such as navigational aids. In addition, the MOD also considers it necessary that specific mention of the need to account for defence radar coverage in relation to wind energy development is specifically identified.
In principle, the MOD has no objection to any renewable energy development occurring in the renewable energy local search areas that have been defined, subject to confirming that that it will be compatible with defence safeguarding requirements.
Some renewable energy generation infrastructure, for example wind turbine generators can, by virtue of their physical dimensions and properties, impact upon the effective operation of safeguarded defence technical installations. Solar farm developments located in proximity to safeguarded navigational aids, or other types of technical sites, can impact upon their effective operation by introducing substantial areas of metallic types of surfaces that may affect transmissions.
Where turbines are erected in line of sight to defence radars, the rotating motion of their blades can degrade and cause interference to their effective operation.
The MOD recommend that any emerging policy makes clear that, where an MOD assessment indicates that a development would have a detrimental impact on the operation and capability of defence assets or sites, that such an application would be refused or that conditions may be attached to any consent that might be issued which may include the removal of permitted development rights.
For your convenience, please find a table at Appendix A which provides a summary of the safeguarding criteria that would apply to those potential development housing allocations identified. MOD recommend that any more detailed policies for these sites include wording which indicates that development should be designed to ensure that it would have no impact on the operation or capability of defence sites or assets. The table below provides a summary of those sites and the triggers for statutory safeguarding consultation that would apply:
I trust this clearly explains our position on this update. Please do not hesitate to contact me should you wish to consider these points further.
Appendix A
Policy HG1 KS4 - MOD St Athan (technical safeguarding zone)
• Development of, or exceeding, 15.2m in height above ground level will trigger statutory consultation requirement
• Development of, or exceeding, 45.7m in height above ground level will trigger statutory consultation requirement
Policy HG1 KS5 - MOD St Athan (technical safeguarding zone)
• Development of, or exceeding, 15.2m in height above ground level will trigger statutory consultation requirement
• Development of, or exceeding, 45.7m in height above ground level will trigger statutory consultation requirement
Policy HG1(7) - MOD St Athan (technical safeguarding zone)
• Any development or change of use will trigger statutory consultation requirement
• Development of, or exceeding, 10.7m in height above ground level will trigger statutory consultation requirement
Policy HG1(8) - MOD St Athan (technical safeguarding zone)
• Any development or change of use will trigger statutory consultation requirement

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

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

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

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

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

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

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

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

Appendix A - rewording of Policy HG1 KS5