Policy EMP4
Clarify the definition of “non‑employment proposals” so that non‑B1/B2/B8 uses capable of generating employment are properly treated as “employment uses”. Remove -duplicated criteria already controlled via other policies

Modification- Supporting Text
Update the supporting text to acknowledge that employment allocations within the Enterprise Zone should support a flexible mix of economic uses reflecting the national policy position in PPW, TAN 23 and Future Wales

These representations relate to ‘Land at Tredogan Road, Rhoose, Barry’ (the Site), owned by Amstone Developments Ltd (ADL).

Amstone Developments Limited (ADL) support the draft RLDP allocation of the Site within the ‘Major Employment Allocation – Land East of Cardiff Airport, Roose’

Requested Modifications
Policy SP14
Amend Policy SP14 and its supporting text to confirm that the Major Employment Allocation at Land East of Cardiff Airport may accommodate a broad range of employment‑generating uses, consistent with the definition of economic development in PPW and TAN 23, and not restricted solely to B1, B2 or B8 uses

Policy EMP4
Clarify the definition of “non‑employment proposals” so that non‑B1/B2/B8 uses capable of generating employment are properly treated as “employment uses”. Remove -duplicated criteria already controlled via other policies

Modification- Supporting Text
Update the supporting text to acknowledge that employment allocations within the Enterprise Zone should support a flexible mix of economic uses reflecting the national policy position in PPW, TAN 23 and Future Wales

The evidence and policy context clearly support the continued allocation of the Site for employment, enterprise and commercial use. This is consistent with the Council’s own SPG and emerging LDP policies which aim to de-risk the under-delivery of employment land and job creation and enhance the Site’s potential to attract inward investment and high-value economic activity.

Amstone Developments Limited fully support that the RLDP allocates the Site for general employment use (B1, B2, and B8) with flexibility to accommodate complementary economic development, consistent with national guidance, the Use Classes Order (Wales), and market evidence

We write to comment and seek amendments to Policy EMP4 'NON-EMPLOYMENT PROPOSALS ON EXISTING EMPLOYMENT AREAS AND PREMISES'

We note that while the the title of Policy EMP4 refers to 'existing employment areas and premises', it is clear form the text of the policy that it also applies to 'Major Employment Sites'. The Proposals Map identifies 'existing employment' and 'major employment' sites separately and with different boundaries, such that 'major employment' sites includes land which is not an existing employment location (eg land at Bro Tathan North as well as land at Cardiff Airport).

In order to avoid any confusion regarding the application of Policy EMP3, we believe it should be re-named 'NON-EMPLOYMENT PROPOSALS ON ALLOCATED AND EXISTING EMPLOYMENT AREAS AND PREMISES'.

Furthermore, the opening paragraph of text to Policy EMP4 cross refers to Policy EMP2: 'Development proposals on existing employment sites and premises identified in Policy EMP2 will be subject to the following restrictions:...' Policy EMP2 relates to MOD St Athan. We believe this cross reference should be to Policy EMP3.

It is suggested that the text is amended as suggested:

Non B1, B2 and B8 and suis generis uses will be restricted to ancillary services or facilities associated with an existing or proposed employment use that would serve employees on the wider employment site where:

ABP objects to this policy. It is overly restrictive in respect of the Use Classes set out (B1, B2 and B8).

With regards to Port land, and other employment land, many of the proposed and promoted uses within the RLDP are associated with a suis generis use, including renewable energy and sustainable development opportunities. These do not necessarily fit neatly into the stated use classes, and the text of this policy, as drafted, suggests that those uses would not be compliant. This is an unintended consequence of an effort to limit other types of uses within employment land (eg. retail).

We write on behalf of our client, Renishaw Plc, in response to the current consultation on the Vale of Glamorgan Replacement Local Development Plan (RLDP). We write to provide our comments in relation to the Vale of Glamorgan Deposit RLDP.

This letter is accompanied by the following:
• Completed Public Consultation Representation Form.

Renishaw’s comments on the Deposit RLDP policies and allocations are outlined below.

BACKGROUND

Established in 1973, Renishaw is a global leader in measurement, motion control, spectroscopy, and precision machining. The company is renowned for pioneering innovative solutions designed to enhance operational performance – optimising manufacturing efficiencies, improving product quality, advancing research capabilities, and increasing the effectiveness of medical procedures.

As part of a major redevelopment of its Miskin site in South Wales, Renishaw is investing over £50 million to expand its manufacturing capacity and reinforce its commitment to achieving net zero carbon emissions. This investment includes the construction of two new low-carbon production halls, which are designed to meet the growing domestic and international demand for its products, while also supporting research and development initiatives.

Policy SP14 – Employment Growth

Renishaw Plc supports the retention of Land to the South of Junction 34 of the M4, Hensol (36.23ha net) as a Major Employment Allocation under Policy SP14.4. The allocation of the site is crucial to ensure that the Council can meet its projected employment land needs and deliver the anticipated level of sustainable employment growth over the Plan period.

The site's continued allocation as a major employment site reflects it's importance as a key opportunity for investment and employment opportunities within the Vale of Glamorgan. The site is of strategic and regional importance as an employment site in a market where high quality, well connected industrial sites are rare.

Outline planning permission was originally granted for the proposed site (Ref no. 2014/00228/EAO) on 22 June 2016.

This permission has subsequently been renewed via a S73 application (ref: 2021/00899/EAO) which extends the period of time for the submission of reserved matters for a further 5 years from the date of the new permission (to 22 December 2030). The permission provides for the following development:

"Outline planning permission with all matters reserved except for access, for development comprising class B1, B2 and B8 uses; a hotel/residential training centre (class C1/C2); and ancillary uses within class A1, A2, A3; associated engineering and ground modelling works and infrastructure, car parking, drainage and access for all uses; provision of infrastructure (including energy centre(s)); landscaping and all ancillary enabling works) at Renishaw Plc, Miskin Business Park, Miskin."

A summary of the key elements of the outline permission are:
• Up to 151,060.99sqm of industrial floor space comprising Class B1, B2, B8 uses;
• Up to 9,290.30sqm of Hotel/Residential Training Centre (Class C1/C2);
• Up to 1,300sqm of ancillary Class A1, A2 and A3 uses;
• Up to 3,200 car parking spaces;
• 30.51ha of Green Infrastructure, comprising landscaping, water balancing areas;
• Access and servicing arrangements; and,
• Ancillary services, including power/utilities (with potential to incorporate energy centre (s)).

Reserved matters permission (reference number: 2019/01421/RES) was approved on 20 May 2021 to bring forward the first phase of the development. This phase of the development is now complete and provides 400,000 sqft of floorspace which is occupied by Renishaw as an extension to its existing operations at Miskin. In addition to employment opportunities created over the construction period, the development has created additional operational jobs for Renishaw. Significantly, many of these jobs provide high quality employment opportunities in the skilled and specialist sector, helping to create skills and provide local employment opportunities.

Renishaw will shortly bring its wider land holdings to the market with the intention of attracting major employment generating uses - further enhancing the economy of the region. The remaining phases of the site (Areas B, C and D) provide further opportunity for inward investment over the Plan period and the creation of over 1,000,000 square feet of employment space.

It is anticipated that Areas B, C and D could have the potential to create over 2,000 operational jobs. During the construction phase, the development also has the potential to create over 1,000 jobs further adding to the employment opportunities created through the development.

The recent renewal of the outline planning permission ensures that the development of the site remains deliverable over the Plan period.

EMP3 - Protection of Existing Employment Sites and Premises

Renishaw Plc support the continued allocation of the current Renishaw premises as an existing Major Employment Site under Polic EMP3.6 – Renishaw, Junction 34, M4.

The allocation of the Renishaw site recognises the importance of the established employment site for the local economy. Renishaw continue to represent an important local employer, who provide high quality, skilled and specialist employment opportunities for the local population.

The continued safeguarding of the site for B1, B2 and B8 uses is therefore supported.

EMP4 – Non-Employment Proposals on Existing Employment Areas and Premises

General support is given to Policy EMP4 which seeks to restrict the development of non-B1, B2 and B8 uses to ancillary services and facilities associated with an existing or proposed employment use.

However, the Policy should provide greater flexibility to allow for appropriate employment generating proposals which complement the existing uses and which may not clearly fall within the B1, B2 and B8 use class. This flexibility is essential in order to allow the sites to respond to changing market demand and emerging markets.

Summary

We trust that the above representations assist and are taken into account as the preparation of the Plan progresses.

We would be grateful if we could be kept informed of future stages of the emerging RLDP.

If you require any further information, please do not hesitate to contact me.

Yours sincerely