Consider adding: “The Council will support local food markets, cooperative food retail, and initiatives that strengthen local producer supply chains
within town and service centres, in line with the Town Centres First approach.”

The overall contribution to health and wellbeing of the Deposit RLDP is positive and there are opportunities to develop further detail through the supplementary planning
guidance (SPG) proposed. We are keen to ensure that these SPG’s are progressed within the short-term and that Cardiff and Vale University Health Board (CAVUHB) are
involved in the development of some of these. The content and application of the SPG’s will be fundamental to the effectiveness of several of the policies identified in the
deposit plan. These must be supported by effective processes and relationships that ensure the intentions for positive contributions to health and wellbeing are delivered.

The Deposit RLDP provides a strong framework for placemaking, climate action, and healthy communities. Opportunities exist to further embed healthy and sustainable food systems as essential spatial infrastructure rather than solely as community
amenity or retail management issues. Strengthening policy wording in areas such as placemaking, rural diversification, employment land, green infrastructure, and community infrastructure would better align the Deposit Plan with the Well-being of Future Generations Act, Planning Policy Wales Placemaking agenda, and emerging Welsh food system strategies. This is particularly relevant as the Future Generations Commissioner named his first priority area in office being food, and the Welsh Government has recently published its Community Food Strategy. The Future Generations Office also recently produced guidance for local authorities including several planning-related recommendations.


The following comments are provided in the order they appear in the document:

Spatial strategy: SP1 - Sustainable growth: While the plan addresses overall growth distribution, it does not consider how development affects local food resilience, including the protection of agricultural land, peri-urban growing spaces, or local supply chains. There is no strategic reference to food as a component of sustainable, resilient
communities. The vision and strategic objectives currently contain no mention of ‘food’ or ‘farming’.

Request to add reference (Spatial strategy or Strategic objectives section) to supporting resilient and sustainable local food systems in spatial strategy principles, including protection of productive land and support for local supply chains. Suggested wording includes: “The Local Development Plan will support resilient and sustainable
local food systems by safeguarding productive agricultural land, promoting peri-urban food growing opportunities, and facilitating local food supply chains as an integral part
of sustainable growth.”

SP4 Placemaking: Placemaking principles are clear and it is encouraging that prioritising the determinants of health and wellbeing during the design process are included as one of the principles. The placemaking statement forming part of the Design and Access statement is welcome to ensure any proposal aligns with the principles. The placemaking SPG will be key to consolidate guidance on physical activity, transport, climate resilience, mental wellbeing, access to food and food production, and inclusive design. Whilst this section focuses on design quality, density, and public spaces it does not explicitly incorporate food production or edible landscaping. Opportunities for multifunctional green spaces that produce food are missed, which could support local
diets, biodiversity, and community engagement. Suggestion to include wording to support multi-functional green infrastructure consistent with placemaking principles:

“Development proposals, where appropriate, should incorporate productive landscapes, edible landscaping, rooftop or community growing spaces, and other
opportunities for local food production as part of multifunctional green infrastructure.”

SP5 Creating Healthy and Inclusive Places and Spaces: CAVUHB support the statement that 'Developers are required to undertake a screening assessment of their
proposal at the pre-application stage to identify the potential health impacts of their development'. CAVUHB agrees with the criteria set out in the table and would like to see examples/further guidance of 'other' developments where there is likely to be a significant impact on health and wellbeing. HIA should also consider the cumulative
impact across multiple smaller developments in the same area, and whether they trigger thresholds collectively.

6.54 We suggest adding the word 'abilities' to the sentence '...enabling people of all ages, backgrounds and abilities to live in an environment that will support them to live
full, productive and prosperous lives.'

6.60 We welcome the requirement for new developments to conduct screening at the pre-application stage using the Council's Health and Wellbeing checklist and the rapid
HIA. We are keen that CAVUHB are involved in the development of the Healthy Placemaking SPG to consider how submitted HIAs will be assessed by the Council to
ensure Developers submit a quality HIA and implement the conclusions.

6.61 Amendment to organisation titles to: Cardiff and Vale University Health Board and Wales Health Impact Assessment Support Unit (Public Health Wales).

6.62 Wales Health Impact Assessment Support Unit has recently released guidance on HIA - see https://phwwhocc.co.uk/whiasu/ for more information and toolkits to ensure most up to date is in use.

6.63 Suggestion to amend the paragraph to include reference to 'access' to services, for example 'A further role of the RLDP is to support the access to and delivery of community, health and social care and wellbeing services within the community..'.

6.65 Suggestion to change wording from 'encouraged' to 'expected' for example:
Developers are expected to engage with the Health Board at pre-application stage to enable due consideration of healthcare infrastructure requirements.' The requirement
for HIA will assist with this expectation.

Key housing sites (HG1 KS1 onwards): The Key Site requirements reference “enhancements to leisure, sport and recreation spaces”. Without quantified standards or phasing triggers, however, these requirements may be difficult to enforce consistently at the planning application stage. Clear policy hooks or supporting standards prior to submission would strengthen implementation. It is recommended that the Key Site schedules include minimum on-site provision standards and delivery
phasing obligations to ensure that both sport infrastructure and recreational space provision keep pace with the additional demand generated by future population
growth.

SP11 Retail, commercial and service centre hierarchy and RCS1 Resilient retail, commercial and service centres: This policy focuses on hierarchy and vitality of retail
centres but fails to actively support the resilience of local retail, through measures which support local food markets, small-scale fresh food retailers, or local producer
supply chains. This limits opportunities for strengthening local food economies.
It is important that the need for convenience food retail space within Barry, Penarth and Llantwit Major, recognised in SP11, is matched with this rational for ‘local affordable food’ outlined in SP5.

Consider adding: “The Council will support local food markets, cooperative food retail, and initiatives that strengthen local producer supply chains within town and service centres, in line with the Town Centres First approach.”

RCS3 - hot food takeaways: CAVUHB commends the recognition that the clustering of unhealthy food outlets is a significant health issue and supports the proposals to
consider controls on takeaway proliferation (RCS3). This will support the creation of healthy environments, a commitment within the Cardiff and Vale Good Food and
Movement Framework endorsed by RPB. Health and inclusion policies mention general wellbeing but do not specifically address access to healthy food, food deserts, or distribution of retail providing fresh/local food, especially in new or expanding residential areas.

Proposal to include criteria for equitable access to healthy food and community food infrastructure in development proposals, such as: “Major developments should demonstrate equitable access to healthy food outlets, community growing facilities, or other community food
infrastructure within walking distance of new residential areas.” This addresses diet related health inequalities, encourages healthier communities and aligns with HIA
guidance.

EMP6 Rural diversification: The plan frames food production predominantly as a community activity rather than recognising its commercial, economic, and supply
chain potential. This limits opportunities for climate-resilient rural economies in a county with such a rural character as the Vale. Policy supports general rural business diversification but does not explicitly enable
agro-ecological practices, local food processing, CSA (community-supported agriculture), or other sustainable farming models.

Proposal that the plan should explicitly support sustainable, commercially viable local food enterprises as legitimate rural employment uses - to include the following wording: “Rural diversification proposals that support agro-ecological farming, sustainable local food production,
community-supported agriculture, and short supply chain enterprises will be supported where compatible with landscape and environmental considerations.”

SP10 Sustainable transport: We support these policies, and suggest the plan is explicit that all new active travel infrastructure should meet the statutory Active Travel
Act guidance (Link: ttps://www.gov.wales/sites/default/files/publications/2022
01/active-travel-act-guidance.pdf) and also that infrastructure should be built to a specification to ensure resilience as extreme weather events increase, preventing
flooding and making use more comfortable during hot weather (such as shading from trees). We note the absence of reference to people living with disabilities and suggest adding 'wheeling' as well as walking and cycling.

SP13 Community infrastructure and planning obligations:

We want to take this opportunity to highlight the challenges that population growth places on healthcare
services. The projected level of population growth identified within the RLDP will have an impact on the CAVUHB's community healthcare facilities and infrastructure. Please refer to the information provided as part of the background evidence paper titled 'BP37
Primary, Community and Intermediate Health Care 'for more detail on the CAVUHB response which identifies there is limited scope for the current infrastructure within
existing GP premises to absorb the LDP growth. CAVUHB recognises the need to prioritise the expansion of the existing estate (where feasible) or support new
developments to take forward its strategic objectives.

Open space and recreation (CI1 and CI2): The evidence base supporting the sport and recreation elements of Policies CI1 and CI2 could be strengthened. At present
there does not appear to be a full Open Space Assessment setting locally-derived standards, nor a Playing Pitch Strategy nor Indoor Sport Facility Assessment. The Cardiff and Vale of Glamorgan Sports and Physical Activity Facilities audit report is
currently underway (with completion anticipated in May 2026), which should make a useful contribution to the evidence base once available.

Community Facilities: this policy focusses on schools, healthcare and social infrastructure, but does not include food-related community facilities such as kitchens, food hubs or education centres. Proposal to include the following information: “Community facilities should include, where appropriate, community kitchens, food hubs, educational facilities for food skills, and other infrastructure that enhances local food resilience and social cohesion.”
There is no reference to the expectation that local communities are consulted in relation to the development of community facilities. We would like to see a
requirement for community engagement and that such developments are based on a detailed understanding of existing community strengths, assets, needs and
challenges. This might be achieved as part of the HIA which includes stakeholder engagement.

SP14 Employment Growth: Employment land allocations focus on general industrial and office uses, with no explicit support for food hubs, processing, or logistics facilities
that would enable local food supply chains. Again, in an agricultural county such as the Vale, and given Wales’ push for local supply resilience, this is a major opportunity gap. Consider including the following wording:

“Employment land allocations should consider the needs of food processing, distribution, and logistics facilities that support local and regional food supply chains.” This supports local supply chain development, reduces food miles and provides local employment opportunities, Welsh Government evidence highlights the importance of food processing in local supply resilience.

SP19 Green infrastructure: this policy emphasises the biodiversity, climate adaptation and recreation, but does not explicitly recognise productive landscapes or
urban agriculture as part of the multifunctional green infrastructure.

Suggested wording: “Green infrastructure networks should recognise and integrate food productive landscapes, urban agriculture, and community growing spaces as multifunctional components contributing to biodiversity, climate adaptation, and wellbeing.”

SP16 Climate change: this policy addresses migration and adaptation but omits food systems. It also does not recognise the emissions reductions from local food
production, short supply chains or sustainable farming practices.
Consider including the following wording: “Development proposals should encourage short supply chains, low-carbon farming methods, and local food production where feasible, in order to support climate change mitigation and adaptation objectives.”

Penarth Town Council Deposit RLDP Consultation Response

Comments collated at a meeting of the Council’s Consultation Task and Finish Group on 9th February 2026

Some Members attended the RLDP consultation drop-in session in Penarth and in general found it to be very informative.

Members support the general development strategy but did note the lack of information concerning discussions with adjacent and other nearby Principal Councils in the CJC Region. In view of the forthcoming Strategic Development Plan, encompassing the ten authorities, members felt that some further commentary regarding this is warranted.1

It is clear that the approach taken in the Cardiff paper is still that ideally, each Council is self-contained and “consumes its own smoke,” which does not show any wider strategic thinking between the ten authorities in preparation for a regional Strategic Development Plan.

Members agreed with the view that infrastructure to support new housing developments was required in order to create successful developments, although they acknowledged that logistically it was difficult to pre-empt demand for some services such as travel and health services. Members also noted that predicting developmental needs and opportunities within wider context surrounding the UK’s economic, political, and social landscapes.

Members noted that there was not much focus on Penarth or identified potential future development for Penarth beyond that already underway at the location near to Cosmeston but welcomed flexibility in its approach. Members expected to be more closely involved in the decisions and planning of this, and other such developments, and provide opportunity for wider consultation where appropriate, such as pre-application consultations, as well as would expect to be included in consultations concerning sites adjacent to Llandough, Dinas Powys, and Sully given their impact upon the town.

Penarth as a town is currently developed to its boundaries, save for the development at Cosmeston. It is, therefore, more dependent than other Service Centres on windfalls of land or buildings which may arise during the currency of the Plan. In 2023, an extensive assessment of the potential of the town concluded the following:

“There is marginally less capacity in Penarth [and Llandough] than the projected figures. However, this does not mean that the projections are incorrect or unjustifiable. The reported figures have not included a significant amount of capacity on open space land, and the projected figures for conversion of existing buildings and intensifications will be surpassed if the extant consents that exist this early in the Plan period are implemented.”

The degree of flexibility, however, is substantially depending on one large site. P009, Headland School, is identified as both a potentially disused building and as a site with a capacity of 111-120 units. This special school is full to capacity and used by many Council in both Wales and England.

Members did note the inclusion of Cogan Transport Interchange under section 6.196 but would have liked to see more information about its future developments as they see it as key to increasing public transport use to Barry and further to West Wales in general.

Members wished to advise that issues with both the bridge and the platforms at Cogan have been long term, with accessibility being central to these issues. Members felt that improvements to accessibility should be a priority at this site, with planting and landscaping considered secondary to this.

Members felt it was key to consider the additional stress on Penarth from increased anticipated demand of public transport needs and emphasised the need for this to be aptly considered by bus route providers as part of development work.

Members wanted to see a strategy that actively protects the town’s heritage and culture whilst still being able to provide for current and future generations.

Members welcomed the inclusion of specific climate change mitigation and adaptation measures under SP16 and section CC1-CC6, noting the considerable attention given to Net Zero transition proposal relating to public buildings and energy. Whilst the evidence presented does not include the UK Climate Change Committee Report2, Members were pleased to see that CC1-CC6 largely reflect the Committee’s finds and are tailored to a transition which reflects what is presently feasible. This is providing that the necessary skills to understand and undertake carbon assessments within a policy implementation and regulation context are readily available.

Under CC2, it was noted that the presumption against demolition3 in favour of retrofit and reuse may constrain maximum transition to net zero as, whilst there is grant aid available for public buildings and social housing, the retrofit monies available for private stock is limited.

Additional considerations will also need to be made as part of the Third Carbon Budget (2026-2030), Local Area Energy Plans and the climate change ISA theme.

Members also felt similar about the inclusion and consideration of sustainable development through the specific strategy outlined in section 5 of the document and felt this linked in well with ongoing Placemaking work and its strategic approach as detailed in SP4.

Members were pleased to see mention of the diversification of high streets, although noted that Penarth was above average in terms of occupancy. They hoped that the RLDP would be able to support the town centre and support other ways it could be improved, such as a fishmonger or identifying a site for a new Cemetery.

With Penarth classified as a Service Centre, they are identified as having a defined role. However, the decline of in-person retailing means that defining role is not that evident, and Members felt there is potentially a need to move away from the traditional retail role of Town Centres in favour of “repurposing, creating multifunctional, commercial, and service centres that meet the needs of the communities they serve” in line with Future Wales Town Centre First Policy. The term ‘repurposing’ suggests a stronger role for the public sector in enabling these new purposes, and Members felt that Placemaking Plans could be one potential framework for this.

Members felt that potential functional support that could be provided could include:
• The appointment of a Town Centre Manager
• Using supporting interventions such as an extension or reshaping of normal services such as Neighbourhood Services.
• Using existing or emerging new powers, such as compulsory purchases.

Members wished for the RLDP to facilitate the safeguarding of essential public services, including health, policing, fire and rescue in the town, which would help to develop the defining role of a Service Centre, and felt that specific reference to these would be beneficial.

Members supported the avoidance of coalescence with adjacent settlements through the reconfirmation of Green Wedges as it allows for relevant extensions to those settlements whilst allowing them to retain their identity.

Members noted that the Quiet Area provision under DNP6 only applies to Penarth and wished to know why this was the case.

Members advised that they welcomed further opportunity for consultation, particularly in relation to developments in the neighbouring Cardiff Bay area whilst acknowledging that this is not necessarily an RLDP concern.

Footnotes

1 There is an evidence paper concerning relations with Cardiff and a Statement of Common Ground with Bridgend. However, there is only a reference in the RLDP text to discussions with other regional Councils and not the paper itself. We would be grateful if you could provide the paper as it does impact on the soundness of this Plan.

2The UK Climate Change Committee’s ‘Progress Report: Reducing Emissions in Wales’ highlighted the following aspects of import: Skills, Vehicle Charging Networks, Improving Recycling, Energy Plans, Decarbonising Public Buildings and Social Housing, and reducing Road transport Demand (Car-Kilometres).

3The UK Environmental Audit Committee (2022) noted that “the evidence we received consistently recommended that retrofit and reuse be prioritised over new build.”

The Policy text should explicitly state to include 12 months of marketing activity as a requirement as the supporting text currently reads. Criterion 5 should also define what an over-concentration of non-retail uses would be in order that the policy is clear and effective.

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

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

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

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

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

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

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