Reference to horticulture and farm diversification employment is needed.

We are pleased to see the Council recognises the importance of supporting a vibrant living countryside in policy EMP3 - development in the countryside , providing for local employment, supporting farming and rural businesses, enabling the provision of affordable housing to meet local needs and accommodating uses that cannot be located within a defined settlement. We would like to see more reference to the need to feed ourselves from the land we have here in Wales. Policy SP5 subsequent text and Policy EMP6 should encourage farm diversification proposals that are in line with the Sustainable Farming Scheme (there will be lots of diversification away from the traditional ways of farming and the SFS encourages this) and supports farmers to farm in a way that allows nature and biodiversity to thrive. Smaller scale farming units will become more common place and the scepticism around these businesses needs to diminish because they produce a lot more food and employment per sq. metre than what, might be considered traditional/ successful, forms of farming in Wales. This article demonstrates how sheep farming is declining in the UK. https://www.bbc.co.uk/news/articles/cgrzd72wp5zo
Therefore, the potential of horticulture to be a big employer of people in the countryside should be acknowledged under Policy EMP6. It is not just about 'B' uses in the countryside. Farm diversification and less traditional methods of farming will employ many people over the plan period and these uses should form a centre piece of this policy.

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.”

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.”

Policy EMP6 outlined should be amended to include the following additional text in brackets:

"Proposals for new rural diversification, including tourism facilities, and B1, B2 and B8 employment uses within the countryside outside of defined settlement boundaries or employment areas identified in Policy EMP3 may be appropriate where the proposal is for:

- The re-use or adaptation of [existing commercial premises or] an existing rural building[s] in association with a rural enterprise or farm diversification scheme;
- Small scale new building employment premises that are well related to a rural settlement, or lie within or immediately adjacent to an existing farm building complex;
- Employment uses where a countryside location is essential for the operational requirements that cannot be met on an existing employment area;
- Sustainable low impact tourism and leisure proposals.
- [Small-scale extensions to existing employment sites]"

# Vale of Glamorgan Replacement Local Development Plan (RLDP)

# Representations regarding the Deposit Plan Consultation – 'Crossways Estate, Cowbridge'

Please find enclosed, on behalf of and under instruction from our client, 'Woodwise Limited', representations for consideration as part of Vale of Glamorgan's RLDP Deposit Plan.

# Context to these Representations

The above site has been submitted as a Candidate Site as part of the Deposit Plan consultation. The following has been submitted as part of this process:

- Candidate Site Submission (including Sustainability Appraisal and Assessment against Candidate Site Methodology);
- Site Location Plan (dwg ref. A101);
- Illustrative Site Layout plan (dwg ref. A112);
- Development Viability Model (dated March 2026) completed by HRT.

Having regard to the above information submitted, and in summary, it is considered that the site should be considered acceptable and appropriate as an employment site allocation, in light of the following conclusions drawn:

- The Sustainability Appraisal completed for the site confirms that the site has a range of positive impacts through its allocation for employment uses, and could assist in achieving the Plan's Sustainability objectives.
- In respect of assessing the site against the Candidate Site Methodology, the site is considered available for development and has a viable prospect of coming forward in the short term, for delivering further employment land in the plan period.
- The site has limited constraints, given that it is currently partially brownfield land and doesn't include any high grade agricultural land.
- The only policy destination for the site to overcome would be in relation to the SLA, which could be addressed through a Landscape and Visual Impact Assessment submitted as part of any future application.
- The site is located in the countryside but is brownfield and already a well-established existing business which has been running as an employment site for many years. It is considered that the redevelopment of this site presents an opportunity to develop the site for further uses, in order to realise the sites full potential.
- The site already benefits from existing connections to infrastructure such as water, electricity, gas and the local highway.
- The redevelopment of the site has the ability to make a positive contribution to placemaking and wellbeing.

We consider that the site 'performs' well against the defined assessment criteria and methodology, with no evident insurmountable constraints, obstacles, or failings. It has been demonstrated above that there are no insurmountable constraints to development of the site, which would represent an appropriate existing employment site allocation, with the ability to extend this further. Moreover, the site comprises previously developed land and benefits from existing permissions for its current use. As such, the site should be considered a 'reasonable' option, and should progress to the Stage 3 assessment accordingly.

Given that the site is not currently allocated in the Deposit Plan, we would raise an objection to the Plan in its current form, on the basis of the Candidate Site submission. Further details are included below.

### Summary of these Deposit Representations – Employment Sites

In light of the Candidate Site Submission made by the site promotor, we would suggest that the site should form an employment allocation within the RLDP. As a result, the site promoter looks to raise an objection to the Deposit Plan.

Para 5.7 stats that the RLDP will make provision for "An allocation of 182 Ha of employment land across a range of sites to enable 67.8 Ha to be brought forward during the plan period and the delivery of up to 5,338 jobs". It is noted that there are currently a total of 8 sites highlighted as employment allocations in Policy SP14 'Employment Growth'. Policy EM1 also highlights two 'Employment Regeneration Opportunity Areas'.

Although there is no objection raised to the inclusion of the sites already identified within the policy in principle, it is considered that Crossways Estate site should be considered as both an existing employment site, which is located near to a sustainable settlement, but also has the ability to provide a larger area for employment, which would help to make the existing business more viable. As a result, it is considered that the site should be identified within the Policy EMP3.

Policy EMP3 'Protection of Existing Employment Sites and Premises' provides a policy which looks to safeguard existing employment allocations within the Vale. The policy states: "The following hierarchy of existing employment sites are safeguarded for B1, B2 and B8 employment uses, and will be protected from development which would compromise their role and function". These are split into Major Employment Sites, Secondary Employment Sites and Key Local Employment Sites. Although Para 6.290 highlights that "Other Premises in Employment Use" are also a type of employment site which has a role and function in the Vale. However, there are a range of smaller and more rural existing employment sites which are not identified or referenced within the policy. We consider that the policy does not go far enough to protect other more rural existing employment sites, such as Crossways Estate.

Policy EMP6 'New Rural Diversification and Employment Uses in the Countryside' provides policy mechanism to support rural employment and diversification in the Vale. However, we consider that the policy does not go far enough to protect and enhance existing employment sites or, provide for opportunities to extend smaller businesses. We would therefore suggest that the following wording is added into Policy EMP6 outlined below in red:

"Proposals for new rural diversification, including tourism facilities, and B1, B2 and B8 employment uses within the countryside outside of defined settlement boundaries or employment areas identified in Policy EMP3 may be appropriate where the proposal is for:

- The re-use or adaptation of existing commercial premises or an existing rural buildings in association with a rural enterprise or farm diversification scheme;
- Small scale new building employment premises that are well related to a rural settlement, or lie within or immediately adjacent to an existing farm building complex;
- Employment uses where a countryside location is essential for the operational requirements that cannot be met on an existing employment area;
- Sustainable low impact tourism and leisure proposals.
- Small-scale extensions to existing employment sites"

It is considered that the employment strategy for the RLDP should go further to support the delivery of smaller employment sites, which would have the effect of a more balanced and equitable distribution of employment sites apportioned across the entire Plan area – including further sites around Cowbridge. The Employment Land Study (2023) highlights that there is a strong demand for B1, B2 and B8 premises within the rural Vale beyond the traditional rural enterprise and diversification of existing agricultural businesses. The proposed changes to Policy EMP6 would provide further support for existing businesses to redevelop or expand, creating better opportunities on existing sites, where there are limited impacts of redevelopment and expansion. Equally, additional employment allocations should be identified to ensure that the overall need is met over the Plan period. Failure to make the necessary changes to the Plan would bring into question the deliverability of the Plan, and by association, its “soundness”.

## Conclusion

These representations raise objection to the Deposit Plan – for the reasons set out above.

Given the nature of these representations our clients would be happy to discuss any aspect of the submission made and credentials of the site when your Authority comes to evaluate matters.

We look forward to hearing from you in due course. In the meantime, however, we hope and trust that all is in order with this submission. Please do not hesitate to contact us in the event that further information is required or considered beneficial.

Yours sincerely