Transport Modal split targets for new developments.

Protecting land from development where crops have been grown. This would include 1 2 and 3 a b and c.

This Policy should set a target for reducing the need to travel as well as a modal split target for every development site. At the moment the plan has words and lots of unsustainable development which will add to the global energy crisis.

CCR Energy welcomes the emphasis within SP16 on climate change mitigation and adaptation, including consideration of flood risk at the former Aberthaw Power Station. The proposed redevelopment of the site as the Cardiff Capital Region Aberthaw Green Energy Park will incorporate comprehensive Flood Consequence Assessments and appropriate mitigation measures to ensure safe, resilient development. By integrating sustainable drainage systems, green infrastructure, and regenerative design principles, the proposals will address tidal and fluvial flood risk, support climate resilience, and contribute to the Vale of Glamorgan’s broader zero-carbon and environmental objectives, demonstrating exemplar practice in sustainable redevelopment of previously developed land.

I support his in principle but feel many areas within the proposed LDP do not align with this policy. Many new housing developments proposed are on Greenfield sites in poor locations and will place heavy reliance on private vehicle use and associated contributions to climate change.

I fully support the ambition of VoGC to address, mitigate and adapt to anthropogenic climate change.

The wording of Policy SP16 must therefore be amended to acknowledge that the above list will apply to “All development proposals, where possible...”

The term “maximising” should also be removed entirely from Policy SP16 as the term is imprecise. Proposals should be encouraged to be efficient but to require demonstration of maximisation could also lead to viability issues.

The proposed amendments will ensure that Policy SP16 will meet the third test of soundness (Will the Plan deliver?).

It is observed that the wording of Policy SP16 states that “all development proposals” should address the causes of climate change to demonstrate policy compliance. However it is considered that it would not be feasible or even possible to provide all of the information required by Policy SP16 at the outline planning application stage and that some of the information requirements of Policy SP16 can only be expected to be provided at detailed (reserved matters/full) planning application stage. Furthermore, care needs to be taken to ensure that any additional decarbonisation policy aspirations, especially for affordable housing-led schemes, are carefully considered in terms of overall viability.

It is clear that there are some requirements in Policy SP16 that will be unachievable in many new residential developments, for example, requirements 7 relating to the optimisation of energy supply and distribution options, including provision of district heat networks.

The wording of Policy SP16 must therefore be amended to acknowledge that the above list will apply to “All development proposals, where possible...”

The term “maximising” should also be removed entirely from Policy SP16 as the term is imprecise. Proposals should be encouraged to be efficient but to require demonstration of maximisation could also lead to viability issues.

The proposed amendment will ensure that Policy SP16 will meet the third test of soundness (Will the Plan deliver?).

It is observed that the wording of Policy SP16 states that “all development proposals” should address the causes of climate change to demonstrate policy compliance. However, it is considered that it would not be feasible or even possible to provide all of the information required by Policy SP16 at the outline planning application state and that some of the information requirements of Policy SP16 can only be expected to be provided at detailed (reserved matters/full) planning application stage. Furthermore, care needs to be taken to ensure that any additional decarbonisation policy aspirations, especially for affordable housing-led schemes, are carefully considered in terms of overall viability.

It is clear that there are some requirements in Policy SP16 that will be unachievable in many new residential developments, for example, requirements 7 relating to the optimisation of energy supply and distribution options, including provision of district heat networks.

encouragement for community focussed initiatives that mitigate and help adapt to climate change.

The Vale has already recognised there’s a climate crisis. The plan gives mitigation and adaption as the 2 elements, though perhaps the draft plan feels like it focusses more on mitigation with adaption being more secondary.

For SP16 we suggest more on community-scale climate action that help with food security, carbon sequestration, biodiversity gains, social cohesion, and cooling e.g.
community gardens and orchards
local food growing
shared green spaces
local repair and reuse hubs
tree planting (but not just for green design with the aesthetic/landscaping but trees for biodiversity, shading, food)

No. 2 Circular Economy, the statement focuses on buildings and materials.
The circular economy also applies to biological nutrients and waste.
Community gardens are hubs for the circular economy—composting local green waste and recycling nutrients back into the soil. Suggest adding "community-scale resource recovery" to the circular economy principles

No. 5 & 8 Green infrastructure, the 2 statements identify only carbon sequestration and urban shading & cooling. Green infrastructure should have multifunctional roles i.e. not just be "trees to look at". For GI there should be measurable standards. Welsh Government and NRW have spent considerable resources developing Green Infrastructure toolkits and these should be used better within the LDP.
Suggestion: that "Green Infrastructure" specifically includes Community Managed Green Space. These spaces provide higher biodiversity value and better social outcomes than "standard" landscaping PLUS food especially if orchards are planted.

No. 10 Nature-Based Solutions The policy links nature-based solutions primarily to water/flooding.
Nature-based solutions can also address social heat stress and mental health during extreme weather.
Suggestion: add community gardens, community allotments and orchards, which provide cooling and permeable surfaces while simultaneously tackling the "nature deficit" in urban areas.

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.”

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.”

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

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

See tables in attachment for site specific comments.

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

See tables in attachments for site specific comments

Strong support is expressed for the proposed allocation at Land north of Westwinds, Fferm Goch of rural affordable-led housing within the Vale of Glamorgan Draft Local Development Plan (LDP) under policy HG4(4).
As part of our comments to the above policy consideration must be attributed to viability on a site specific basis. Furthermore, questions are raised over whether sufficient affordable dwellings are proposed to 2036 in the Vale given current trends and forecasts.

The inclusion of the site within the settlement boundary is logical especially when viewed in the context of the linear settlement of Fferm Goch. In addition the site is further suited to development allocation as the northern and southern boundaries are built up and the main road runs along the eastern boundary. A flexible approach is encouraged with regard to the delivery of the dwellings in relation to a variety of factors and policy provisions including the housing needs across the Vale, the limit on numbers of rural affordable led sites in minor rural settlements, viability implications relating to obligations/carbon Zero and sustainability obligations and the potential to extend the allocation if the need for homes requires.

The 3 land owners remain committed to this development and local developers are waiting to deliver the allocation.

In summary the extension to the settlement boundary of Fferm Goch, to include the allocation HG4(4) is supported. The attached representation is made under the following policies:
• Policy SP1 – Sustainable Growth Strategy
• Policy SP2 – Settlement Hierarchy
• Policy PGD2 – Residential Development Densities
• Policy SP6 – Housing Requirement
• Policy SP7 – Affordable housing provision
• Policy SP8 – Affordable housing requirements
• Policy HG4 – Rural Affordable Housing Sites
• Policy SP13 – Community Infrastructure and planning obligations
• Policy CI1 – Open space provision
• Policy SP16 – Climate change mitigation and adaptation
• Policy DNP1 – Special landscape Areas

The test of soundness for a Local Development Plan (LDP) is a critical component of the planning process to ensure that the plan is prepared in accordance with legal and procedural
requirements. It involves demonstrating that the plan is 'sound' based on three tests set out by the Welsh Government in the Development Plans Manual (Edition 3). These tests have therefore been considered in our representation, the tests include:

• Test 1: Does the plan fit? (i.e. is it clear that the LDP is consistent with other plans?)
• Test 2: Is the plan appropriate? (i.e. is the plan appropriate for the area in the light of the evidence?)
• Test 3: Will the plan deliver (i.e. is it likely to be effective?)

SP1 – Sustainable Growth Strategy

The promotion of small scale affordable housing led development outside of the SGA, as proposed by SP1 is important as this provides essential affordable and market homes in the rural locations of the Vale as well as the SGA. Their provision is critical in meeting the area’s housing needs, particularly affordable dwellings and supporting rural community stability, and ensuring that all parts of the Vale remain a place where people of all incomes are able to live and thrive during the plan period to 2036 and beyond.

The essence of Policy SP1 is supported, however it is well documented that there is a backlog in delivery of affordable homes and the need for affordable housing in the Vale is exacerbated by the high prevalence of single person households plus households comprising couples with no children, The Vale also has one of the highest affordability pressures in Wales. As stated in the 2023 Local Housing Market Assessment (LHMA) for the Vale of Glamorgan , the median house price in the Vale is around 8 times the median household income, well above the affordability threshold of 4.5 to 5 times household income for borrowing purposes. Private rents have also risen sharply in the area, commonly placing them out of reach for many low-to-middle income households. All of the above place further pressure on the need to deliver affordable homes in the locality.

The LHMA identifies a need for 1,075 affordable homes per year over the next 5 years based on principal projections (or 1,114 based on the RLDP projections). As mentioned previously past delivery rates fall significantly short and therefore a backlog is present, however despite the reported backlog the RLDP only proposes 3,070 (205/annum) affordable dwellings over the plan period to 2036. Despite the growth strategy of policy SP1 and allocations made through the RLDP, the figure of proposed affordable dwelling numbers is concerning as it falls significantly short of the demand evidenced within the most recent evidence of LHMA of 2023.

The housing figures quoted in SP1 indicate 7,890 dwellings ( including the 3,070 affordable dwellings) to 2036, however these figures overall are inadequate over the plan period when considered against the 2022 WG household projections. The 2022-based household projections provide an indication of the future number of households, and their composition, based on population projections and assumptions about households from recent censuses. The vale of Glamorgan demonstrates an increase of almost 12% in the number of households between mid-2022 and mid-2032; note this is the highest percentage increase by Local authority in Wales and way above the average for Wales as a whole (that stands at around 7% increase). The concern is whether Policy SP1 goes far enough in providing for the scale of housing ( both open market, but particularly Affordable) development across the Vale.

Without targeted allocations outside of the SGA, as outlined in Policy SP1, the gap described above will continue to widen, forcing more residents to leave the area and weakening community cohesion.

SP2 – Settlement Hierarchy

Policy SP2 states a range of rural settlements are categorised as ‘Minor Rural Settlements’. Within the
RLDP the supporting text of Policy SP2 states:
‘several of the smaller rural settlements such as Colwinston, St Nicholas and Fferm Goch include primary schools that serve a wider catchment area, whilst others also provide small scale local employment opportunities, either within or near the settlements. Due to these functional links between rural settlements, it is essential to ensure that existing services and facilities are safeguarded, supported, or enhanced where appropriate’.(Paragraph 6.16)
Fferm Goch is categorised as a Minor rural settlement within the Settlement hierarchy and given its size and range of facilities/services this is supported. It is noted however that both Fferm Goch and Colwinston are identified as serving a wider catchment due to the provision of their primary schools. The allocation of HG4 site at Fferm Goch will further support and sustain the following:
• The Llangan primary school that sits in the southern portion of the settlement boundary.
• The existing employment site of WestWinds Business Park.
• The community hall (Llangan and St Mary Hill Village Hall) to the north of the settlement.
These existing services and facilities should be supported and sustained through the new housing allocation (HG4(4) in the immediate locality. This allocation supports the Vale’s own strategic objectives for

sustainable growth. Locating affordable-led developments in areas with existing infrastructure such as primary schools will reduce car dependency, lower carbon emissions, and contribute to the Council’s climate change commitments.

Considering the above, the limit on small scale rural affordable housing led developments (RAHLD) to 25 for these settlements is questioned and further flexibility recommended on a case by case basis. It is understood the limit on numbers was imposed due to the existing scale of the settlement in which the RAHLD are located, however those allocations will only likely deliver at 50% affordable and therefore only provide 12.5 ( or 13) affordable units as a maximum (note Fferm Goch would provide 11 affordable dwellings on current figures of 22 total dwellings). Given the concerns raised in response to Policy SP1 there remains an issue of whether the numbers proposed in the RLDP can meet the demonstrable need for affordable homes and if there is scope on a RAHLD to sensitively increase unit numbers without any material harm then the policy should be flexible to accommodate this.

Wick and Culverhouse Cross have been elevated to Primary Settlements outside the SGA; this is supported given the range of facilities and services provided in these settlements. It is also supported that these settlements are able to provide affordable led residential development of up to 50 dwellings ( delivering 25 affordable units). However the provision of an increased number of units in the Primary Non SGA settlements must not be at the expense of a wider number of smaller rural sites with the ability to sustain smaller communities across the Vale, especially given the shortfall in numbers as outlined above.

PGD2 – Residential Development Densities

The best use of finite land is set out in PPW and consistent with the setting of the densities as prescribed in policy PGD2. The policy is considered to meet the 3 tests of soundness.

The approach of policy PGD2 is also supported through the proposed density of the site North of Westwinds business park, Fferm Goch in HG4 (4). This allocation that proposes to provide a density of just over 30/ha within Fferm Goch, a minor rural settlement.

SP6 – Housing Requirement

Affordable housing forms an important part of the housing requirement figures of Policy SP6. Whilst the total 122 dwellings proposed under policy HG4 is a relatively small contribution to the overall figures it provides important spatial distribution of homes across the Vale within the rural area.

Given the concerns raised with regard to Policy SP1 there is fear that the affordable housing numbers will not be sufficient to meet need. The site north of Westwinds business park, Fferm Goch has the ability to expand to the south (as per the CS Ref 398) in order to accommodate additional dwellings (both market and affordable dwellings in order to sustain the viability of the site).

SP7 – Affordable Housing Provision

In accordance with Policy SP7 the allocated site HG4(4) at Fferm Goch provides a range of tenures, types and sizes in response to the LHMA, waiting list data and Older persons housing strategy in order to provide for 11 dwelling units and contributing toward the 3,070 affordable requirement to 2036. Changes in the household composition mean more single person and small homes are required, plus older person accommodation for those wishing to downsize and stay in the area.

Please see comments for Policy SP1 / Policy SP2 above regards concern over the proposed housing numbers and supply of affordable homes against demand - this therefore brings the Deliverability of the plan in to question (Test of Soundness 3).

SP8 – Affordable Housing Requirements

Policy SP8 is supported in so far as contributing much needed affordable housing development commensurate with the size of the settlement in which it sits. We are encourage to see reference to the provision of affordable housing to be negotiated on a site by site basis considering evidenced viability fo the development.

The affordable dwellings proposed foster stability in rural areas by allowing a range of households (from single person to growing families) to stay in their local area.

Policy SP8 states 40% affordable for those developments in primary and minor settlements outside of the SGA yet 50% requirement on affordable housing led allocations in minor rural settlements ( also outside of the SGA). This appears inconsistent and penalising those smaller rural sites that will already be more delicately balanced in viability terms by virtue of their limited size of 25 units. Further viability issues covered in other policies ( such as SP20, relating to biodiversity, Net Zero and sustainability credentials must (with the required evidence submitted and assessed by the council as stated in Policy SP8) be flexibly reviewed to ensure sites are viable and deliverable as recognised by the Council, there is a danger the stringent requirements, especially for smaller sites, could render those sites unviable in the current climate with rising build costs.

HG4 – Rural affordable housing led sites

The allocation of land north of West Winds Business Park under policy HG4(4) for rural affordable housing led development of 22 units is strongly supported. Then allocation will assist in delivering homes in the rural Vale and contribute to the important stability to the settlement of Fferm Goch to 2036.

The extension of the settlement limit including the site north of West Winds Business Park is supported. The site provides an obvious infill to the small break in the built up area to both the north and south of the site, with the main road running to the eastern boundary of the site.

The inclusion of the site within the settlement of Fferm Goch is logical and in harmony with the existing linear settlement.

The proposal supports the aims of the Local Development Plan and the Welsh Government’s commitment to increasing affordable housing supply. By providing for affordable led allocations the policy aligns with the Well-being of Future Generations (Wales) Act 2015 in aiming to promote a healthier, more equal, and cohesive community.

There is concern however surrounding the number of dwellings proposed and if the Plan seeks sufficient dwellings and affordable provision given the predicted need to 2036 shown in the LMHA.

SP13 – Community infrastructure and planning obligations

Policy SP13 demonstrates the importance of community infrastructure in sustaining both the residents well being and economic growth of an area. See also the response to Policy SP2 that refers to the allocation of housing in the rural areas specifically supporting those settlements with local primary school provision.

The viability of developments however must not be compromised in order to ensure delivery of the plan. To see in Policy SP13 that ‘development viability’ is recognised as a key factor in delivering community infrastructure under planning obligations, is supported. It is recommended that this recognition is replicated in other policies of the LDP in order that the third Test of soundness can be fully met; Deliverability – ensuring the plan is likely to be effective). See comments in relation to Policies SP8/CC1/SP16/CI1.

CI1 – Open Space Provision

Provision of open space in residential developments is supported. HG4(4) promotes open space within the draft allocation.

The viability of developments however must not be compromised in order to ensure delivery of the plan. The ‘development viability’ should recognised as a key factor in delivering open space ( see comments on SP13 / SP8 where evidenced viability is specifically referenced within those policies – this approach is supported.

SP16 - Climate change Mitigation and Adaptation

The provisions of SP16 are generally supported as practical measures to ensure important sustainable development is achieved.

CC1 – Residential Operational Net Zero Carbon Development

The provisions of Policy CC1 echo the WG targets for Net Zero by 2050.
Whilst some of the supporting text to policy CC1 references viability, the ultimate viability of developments however must not be compromised in order to ensure delivery of the plan. The technical feasibility of renewable energy regeneration is referenced in the above policy however the ‘development viability’ should also be included. See comments on SP13 / SP8 where evidenced viability is specifically referenced within those policies – this approach is supported.

SP19 – Green Infrastructure

Provision of Green Infrastructure in residential, and all developments is supported.

HG4(4) retains and enhances existing and will promote green infrastructure on the draft allocation.

The viability of developments however must not be compromised through green infrastructure provision - in order to ensure delivery of the plan. The ‘development viability’ should therefore be recognised as a key factor in delivering Green Infrastructure. See comments on SP13 / SP8 where evidenced viability is specifically referenced within those policies – this approach is supported.

SP20 – Biodiversity and Ecosystem resilience

The above Policy is in accordance with Chapter 6 PPW. The approach is supported and dovetails with SP19 above.

DNP1 – Special Landscape Areas

DNP1 identified Special Landscape Areas across the Vale.

Fferm Goch is one of the settlements that remains fully within and covered by the Upper and Lower Thaw Valley Special Landscape Area (SLA). It is noted that in such settlements, while there have been amendments to the identified settlement boundary ( inclusion of HG4 (4) rural affordable led housing allocation) this has not affected the SLA designation in these areas. (Background Paper 45; Paragraph 1.16 refers).

The location of the small allocated site HG4(4) is nestled within the settlement of Fferm Goch. It is built up on both the northern and southern boundaries, with the main road running along the eastern boundary. There is no unacceptable harm to the SLA of the Upper and Lower Thaw valley.

The allocation of the site for residential development does not give rise to unacceptable harm to the special qualities and characteristics of the SLA, based on LANDMAP information, continues to be preserved.

1. Air Quality and Traffic
The RLDP has not been supported by a sufficiently robust, transparent and locally specific
evidence base in relation to traffic capacity, mitigation, air quality and sustainable transport delivery in Dinas Powys.
The Plan relies on high-level assumptions rather than detailed assessments of known local constraints, and it does not provide adequate certainty that necessary mitigation and sustainable transport measures will be delivered, funded and implemented in a timely manner.
As a result, there is a significant risk that the cumulative impacts of development will lead to increased congestion, adverse effects on air quality and a deterioration in the quality of life for existing and future residents.
Until these evidence gaps are addressed and clear, enforceable measures are put in place, the RLDP cannot be considered fully justified, effective or consistent with national policy in its application to Dinas Powys.
Traffic Capacity
I am concerned that the RLDP has not demonstrated that the existing road network in Dinas Powys can cope with the scale of development proposed. Roads and junctions within the village already experience significant congestion both at peak times and throughout the day, particularly along Cardiff Road, St Andrew’s Road and the A4055.
The Plan does not provide clear or accessible evidence, such as detailed junction capacity assessments or peak-hour traffic modelling, to show that additional development will not worsen these problems. Without this information, I cannot be confident that growth can be accommodated without unacceptable impacts on daily travel, safety and quality of life.
Questions: Can the Council confirm that the existing highway network in Dinas Powys can accommodate the growth proposed in the RLDP without causing unacceptable congestion?
Can the Council provide evidence including junction capacity assessments and peak hour traffic modelling?
Mitigation Measures
Where development in Dinas Powys is likely to increase traffic, I am concerned that the RLDP does not clearly explain how congestion will be mitigated.
Mitigation measures are described in general terms, but there is little clarity on what will actually be delivered, when it will happen, or who will pay for it. There is also no clear reassurance that mitigation will be in place before development takes place.
I am concerned that traffic conditions could deteriorate further if development proceeds without effective safeguards.
Questions: For any development allocations in Dinas Powys that may impact congestion, what measures are proposed to mitigate these effects?
Are these measures fully funded, deliverable, and enforceable?
Air Quality Impacts
Increased traffic has clear implications for local air quality, particularly in residential areas and near schools and community facilities. I am concerned that the RLDP has not clearly assessed how the proposed growth in Dinas Powys will affect air quality, especially when the cumulative impact of multiple developments is considered.
The Plan does not explain how compliance with statutory air quality standards will be monitored or maintained as traffic levels increase. This creates significant uncertainty about potential impacts on public health and the local environment.
Questions: Has the Council assessed the likely impact of the proposed growth on local air quality in Dinas Powys, including cumulative effects?
How will the Plan ensure compliance with statutory air quality standards?
Sustainable Transport
While the RLDP refers to encouraging walking, cycling and public transport, I am not convinced that realistic alternatives to car/motor use will be delivered in Dinas Powys.
There is limited detail on specific improvements, timescales or funding for sustainable transport. Without frequent, reliable public transport and safe, direct walking and cycling routes, it is unlikely that car use will reduce in practice.
As a result, traffic growth and air quality impacts may be greater than the Plan assumes.
Question: How does the Plan/Council intend to ensure that sustainable travel options (walking, cycling, public transport) will be delivered and used to reduce traffic and air quality impacts in Dinas Powys?
Evidence Gaps
Overall, I am concerned that key evidence relating to traffic and air quality in Dinas Powys is either missing or insufficiently detailed. Without clear, locally specific assessments, it is difficult to understand how the Council can be confident that the Plan is sound or that its impacts on the community are acceptable.
Question: There are limitations in the transport and air quality evidence for Dinas Powys, how does the Council justify that the RLDP remains sound in light of these uncertainties?
2. Flood risk
I am concerned about the Replacement Local Development Plan (RLDP) and its impact on Dinas Powys, in relation to flood risk.
Dinas Powys already experiences surface water flooding, overloaded drains and pressure on local watercourses. Any new development must be proven to be safe and must not make these problems worse. At present, the RLDP does not give me confidence that this has been properly addressed.
Flood Risk Has Not Been Properly Resolved
Welsh Government policy (TAN 15) says new development must be safe from flooding for its lifetime and that flood risk should be dealt with when the Plan is written, not later on.
The RLDP appears to allocate sites that are affected by flood risk without clearly showing how they can be made safe. Instead, it relies on the idea that solutions will be worked out later when planning applications are submitted. As a resident, this is worrying, as there is no guarantee that those solutions will ever work or be delivered.
Questions: Can the Council explain how allocations within [or affecting] TAN 15 flood risk areas comply with TAN 15’s requirement that development be flood-safe for its lifetime, rather than relying on mitigation to be designed later?
Where the Plan relies on mitigation to address flood risk, what evidence demonstrates that such mitigation is deliverable, funded, and capable of implementation within the Plan period?
Is it the Council’s position that compliance with TAN 15 can be deferred to the planning application stage, and if so, how does that align with the requirement for strategic flood risk to be resolved at plan-making stage?
Lack of Clear Evidence Behind Flood Assessments
The flood studies supporting the Plan are not easy for a lay person to understand and do not clearly show that the full impact of new development has been properly assessed.
In particular, it is unclear whether:
• The combined effect of multiple new developments has been considered
• The worst-case impacts of climate change and heavier rainfall have been tested
• Flood risk to existing homes and streets has been fully taken into account
Without this information, it is hard to see how the Council can be confident that new development will not increase flooding in Dinas Powys.
Questions: What level of modelling underpins the SFCA, and can the Council confirm whether it assesses downstream and off-site impacts arising from cumulative
development?
Does the SFCA test a ‘worst-case’ climate change scenario consistent with current Welsh Government guidance, and if not, why not?
How does the SFCA move beyond a desktop exercise to demonstrate that individual allocations are genuinely developable without increasing flood risk elsewhere?
Too Much Reliance on Future Drainage Solutions
The Plan relies heavily on Sustainable Drainage Systems (SuDS) to manage surface water, but there is little evidence showing that these systems can realistically work on all proposed sites.
I am concerned that:
• There may not be enough space on sites for effective drainage
• Water will still end up flowing into already stretched drains and streams
• Long-term maintenance of drainage systems is unclear
If these systems fail or are not properly maintained, flooding problems could become worse over time.
Questions: What evidence does the Plan rely on to show that SuDS can be accommodated on all relevant allocations without loss of developable area or displacement of flood risk?
Has the capacity of receiving watercourses and drainage networks been assessed at a strategic level, or is this assumed to be resolved site-by-site?
How does the Plan address the cumulative impact of multiple SuDS systems discharging into the same catchment?
What mechanisms are proposed to secure long-term maintenance of SuDS, and where is this evidenced in the Plan?
Doubts About Whether Sites Are Truly Deliverable
Some housing numbers in the Plan appear to depend on sites that may only work if major flood prevention measures are put in place, I believe that Dinas Powys is an example of this.
• It is not clear which sites depend on such measures
• There is no clear timetable or funding in place
• There is no backup plan if flood mitigation does not happen
I am concerned that the Plan may be relying on sites that cannot realistically be developed.
Question: Can the Council identify which allocations are dependent on flood mitigation infrastructure, and where the delivery, timing, and funding of that infrastructure are set out?
If mitigation fails to come forward, what contingency does the Plan provide to ensure housing delivery does not rely on undeliverable sites?
How does the Plan demonstrate that housing numbers are not inflated by sites whose flood risk constraints may ultimately prevent development?
Where NRW has expressed concerns or conditions relating to flood risk, how has the Council reflected those concerns in policy or allocations, rather than deferring them to later stages?
Has any NRW advice been departed from, and if so, what is the evidence base justifying that departure?
Climate Change and Long-Term Safety
Flooding is likely to become more frequent and severe due to climate change. The Plan does not clearly show that new development in or around Dinas Powys will remain safe for decades to come, not just during the Plan period.
Residents need reassurance that today’s decisions will not create long-term flooding problems for future generations.
Question: How does the Plan ensure resilience to increased rainfall intensity and flood frequency over the full lifetime of development, not just the Plan period itself? Does the Plan assume future flood defences or upgrades, and if so, where are those projects committed and funded?
For these reasons, I believe the RLDP has not properly resolved flood risk issues affecting Dinas Powys, I ask that the Council be required to:
• Properly address flood risk at the plan-making stage, not later
• Remove or review sites where flood risk has not been clearly resolved
• Provide stronger evidence that new development will not increase flooding for existing residents.
Until this is done, the Plan cannot be considered sound.
3. Wastewater Treatment
This objection relates to the proposed level of housing growth in Dinas Powys and whether the existing wastewater and sewerage system can safely and realistically support it.
I am concerned that the RLDP does not provide clear, settlement-specific evidence to show that wastewater treatment works and the local sewer network have enough capacity to accommodate the planned development, either now or within the Plan period.
Without this evidence, the Plan risks placing unacceptable pressure on already constrained infrastructure, increasing the risk of flooding and environmental harm.
Wastewater Treatment Capacity
The RLDP does not clearly explain whether the wastewater treatment works serving Dinas Powys has sufficient spare capacity to deal with additional development.
In particular, the Plan does not set out:
• how much wastewater the treatment works is currently allowed to treat (its “consented capacity”),
• how much spare capacity is actually available,
• when this information was last assessed, or
• whether this assessment has been formally confirmed by Dŵr Cymru Welsh Water.
Without this basic information, I lack sufficient information to understand whether the existing system is already close to capacity or whether it genuinely has room to cope with new development.
The Plan also does not clearly state how much additional wastewater would be generated by the new housing proposed for Dinas Powys, or how this compares with any available
capacity. This makes it impossible to judge whether the level of growth proposed is realistic.
There is no clear evidence that a Dinas Powys–specific assessment has been carried out. If the Council is relying on broad, county-wide modelling instead, this does not reflect local conditions or known issues within the village.
Sewer Network Constraints & Flood Risk
Many residents are already aware of problems with drainage, surface water, and sewer performance in Dinas Powys, particularly during periods of heavy rainfall.
However, the RLDP does not provide clear evidence on:
• existing sewer surcharging or flooding incidents,
• past or current problems with overloaded sewers, storm overflow activity affecting the area.
There is also no clear explanation of how the combined impact of multiple new development sites in Dinas Powys has been assessed together, rather than individually. This is especially concerning given the increasing frequency of intense rainfall linked to climate change.
Dinas Powys has known surface water and flood risk sensitivities, yet the Plan does not convincingly demonstrate that increased wastewater flows will not make flooding worse or lead to pollution of local watercourses.
I am concerned that problems will only become apparent after development has already taken place.
Deliverability & Infrastructure Planning
The RLDP does not identify any specific wastewater or sewerage upgrades needed to support the proposed growth in Dinas Powys.
Where upgrades may be required, the Plan does not explain:
• what infrastructure improvements would be needed,
• how much they would cost,
• who would pay for them, or
• when they would be delivered.
This creates significant uncertainty. I am concerned that development could go ahead before infrastructure is in place, leaving existing communities to deal with the consequences of overloaded systems.
There is also no clear explanation of how infrastructure will be phased to ensure that wastewater capacity is available before new homes are occupied, rather than relying on solutions being found later.
Role of the Statutory Undertaker – Dŵr Cymru Welsh Water
The Plan appears to rely heavily on future discussions with Dŵr Cymru Welsh Water at the planning application stage to resolve wastewater issues.
I am concerned that this approach puts off important decisions that should be made now, during the Plan-making process. National planning policy requires development plans to be based on a clear understanding of infrastructure capacity, not assumptions that problems can be fixed later.
Without clear, written confirmation from Dŵr Cymru Welsh Water that the proposed level of growth in Dinas Powys can be accommodated, I believe the Plan lacks the certainty needed to be considered sound.
Soundness & Policy Compliance
Because the RLDP does not clearly demonstrate that wastewater infrastructure:
• is available,
• can be upgraded in time, and
• has a realistic and funded delivery plan,
I do not believe the Plan is effective, which is a key test of soundness.
The Plan also appears to conflict with Planning Policy Wales, which states that development should be directed to locations where infrastructure is already in place or can be secured.
Deferring wastewater solutions to a later stage does not meet this requirement.
If wastewater capacity problems cannot be resolved within the Plan period, I question why the level of development proposed for Dinas Powys has not been reduced to reflect real infrastructure constraints.
4. Green Space & Green Infrastructure
For the reasons set out below I consider that the RLDP is unsound in relation to green space and green infrastructure in Dinas Powys because it:
• Fails to justify the loss of existing green space or show that mitigation will be delivered;
• Lacks clear evidence on the quantity, quality, and accessibility of green space;
• Does not safeguard the integrity of green infrastructure networks;
• Provides no mechanisms to ensure timely delivery of green space alongside new development;
• Does not demonstrate that alternatives were properly considered through the Sustainability Appraisal.
Until these issues are addressed, there is no clear basis to conclude that the proposed growth in Dinas Powys can be accommodated without unacceptable impacts on local green spaces and the wider environment.
I urge the Council to carefully consider these concerns and provide further evidence or modifications to ensure that the Plan is effective, sustainable, and compliant with national planning policy
Protection of Existing Green Space
The RLDP does not clearly explain why any existing green spaces in Dinas Powys might be lost, or whether the loss is unavoidable.
I am concerned that the Plan does not demonstrate:
• that all alternatives to protect existing green space have been considered, or
• that any replacement or mitigation will be provided within or near the village.
Without this evidence, there is no assurance that valued local green spaces, which are important for recreation, biodiversity, and the character of the settlement, will be preserved. This is a serious omission that makes the Plan unsound in this respect.
Question: How does the Plan justify the loss of any existing green spaces in Dinas Powys? Has an assessment been carried out demonstrating that loss is unavoidable, and that adequate replacement or mitigation will be provided within or near the settlement?
Quantity, Quality, and Accessibility of Green Space
The RLDP does not provide clear, settlement-specific information about the amount, quality, or accessibility of green space for Dinas Powys residents.
It is unclear whether the standards being applied:
• meet national policy requirements,
• reflect the needs of the local population, or
• will be sufficient to support an increased population from new housing.
Without clear evidence, I cannot be confident that new development will maintain adequate recreational and amenity space for all residents.
Question: What evidence supports the quantity, quality, and accessibility standards for green space in Dinas Powys? How do these standards compare with national policy and the needs of the local population?
Green Infrastructure Network Integrity
The Plan does not explain how green infrastructure networks—including wildlife corridors, footpaths, cycleways, and recreational routes—will remain coherent and functional as new development comes forward.
There is a real risk that the proposed growth could fragment these networks, reducing connectivity for wildlife and limiting access to recreational spaces. I am concerned that the Plan does not set out measures to prevent these negative impacts.
• Question: How does the Plan ensure that green infrastructure networks in Dinas Powys, including wildlife corridors, footpaths, and recreational routes, remain coherent and functional despite new development?
Delivery and Implementation
The RLDP does not make it clear how green space provision will be delivered at the same time as development, rather than being left to later planning agreements or discretionary decisions.
Without clear delivery mechanisms, there is no certainty that new or replacement green space will be provided when needed.
This creates risk that residents will face reduced access to recreation, wildlife habitats, and open space for years after new homes are built.
• Question: What mechanisms are in place to ensure that green space provision in Dinas Powys will be delivered alongside development, rather than deferred to later discretionary planning stages?
Consideration in the Sustainability Appraisal
It is not evident that the Plan’s Sustainability Appraisal has fully assessed the impact of proposed development on green space and green infrastructure in Dinas Powys.
There is no clear explanation of whether alternative development options were considered that would reduce the loss or fragmentation of green spaces, and if so, why these
alternatives were rejected.
I am concerned that the lack of settlement-specific analysis weakens the credibility of the Plan and its ability to safeguard local environmental assets.
Question: Has the Integrated Sustainability Appraisal fully considered the impacts of proposed development on green space and green infrastructure in Dinas Powys?
Were alternatives considered that would reduce loss or fragmentation, and if so, why were they rejected?
5. Health & Wellbeing
Alignment with RLDP Policy SP6
The RLDP does not clearly demonstrate how proposed allocations and policies affecting Dinas Powys will achieve the health and well-being objectives set out in Policy SP6.
In particular, the Plan does not provide evidence that new development will:
• maintain or enhance access to green spaces,
• support active travel (walking, cycling, public transport), or
• deliver inclusive and safe public environments for all residents.
Without clear mechanisms to ensure these outcomes, it is unclear how the Plan will contribute to the creation of healthy, inclusive communities in line with its own strategic policy.
Question: How does the Plan ensure that proposed allocations and policies affecting Dinas Powys will deliver the health and well-being objectives set out in Policy SP6, including access to green space, active travel, and inclusive public environments?
Alignment with the Vale of Glamorgan Well-Being Plan
The RLDP does not clearly show how its proposals for Dinas Powys are consistent with the objectives of the Vale of Glamorgan Public Services Board Well-Being Plan, particularly in relation to:
• physical and mental health,
• health equity, and
• equitable access to green and recreational spaces.
There is no settlement-specific evidence demonstrating that new housing or other
allocations will support these well-being objectives, leaving a gap in the Plan’s justification and effectiveness.
Question: How does the RLDP demonstrate consistency with the Vale of Glamorgan Public Services Board Well-Being Plan, particularly the objectives relating to physical and mental health, health equity, and access to green spaces in Dinas Powys?
Evidence for Health and Well-Being Outcomes
The Plan does not provide sufficient evidence that its spatial strategy, site allocations, or policies will produce measurable improvements in health outcomes for residents of Dinas Powys, particularly in areas where health needs are identified.
Without this evidence, it is impossible to determine whether the proposed development will genuinely support improved physical or mental health, reduce health inequalities, or provide accessible, high-quality spaces for recreation and social interaction.
Question: What evidence demonstrates that the Plan’s spatial strategy, allocations, and policies in Dinas Powys will produce measurable improvements in health outcomes for residents, especially in areas of identified need?
Integration with the Sustainability Appraisal
The RLDP’s Integrated Sustainability Appraisal (ISA) does not clearly demonstrate how health and well-being impacts have been addressed specifically for Dinas Powys.
There is limited information on:
• mitigation or enhancement measures to support healthy communities,
• the contribution of proposed allocations to active travel networks, or
• ways in which new development will improve access to green infrastructure or inclusive public spaces.
Without settlement-specific consideration, the ISA does not provide sufficient assurance that health and well-being outcomes will be achieved, nor does it demonstrate compliance with national planning policy on creating healthy and sustainable places.
Question: How has the Integrated Sustainability Appraisal addressed health and well-being impacts specifically for Dinas Powys, and what mitigation or enhancement measures are proposed to ensure alignment with national planning policy on healthy places?
6. Education & Medical Services
I believe that the RLDP is unsound in relation to education and healthcare services in Dinas Powys
Education Provision
The RLDP does not provide clear, settlement-specific evidence regarding school capacity in Dinas Powys.
My key concerns include:
• There is no demonstration that local primary and secondary schools have enough places for the children who will arise from the proposed housing.
• It is unclear whether the Plan relies on borough-wide estimates, which may overlook local pressures and result in shortages at specific schools.
• The Plan does not identify any specific improvements to school infrastructure (such as new classrooms, extensions, or new schools), nor does it set out funding, timing, or delivery mechanisms.
Without these assurances, there is no certainty that school places will be available before families move in, which could lead to overcrowding and diminished educational standards.
I am concerned that, in the absence of firm evidence and infrastructure commitments, the proposed scale of housing growth in Dinas Powys may be unsustainable and undeliverable.
Healthcare / Medical Services
The RLDP does not demonstrate that local healthcare services—including GP practices, dental services, and community health facilities—can accommodate the increased population.
My specific concerns include:
• There is no settlement-specific assessment of current or future healthcare capacity in Dinas Powys.
• The Plan does not indicate whether additional or expanded healthcare facilities will be provided, nor how this would be funded, phased, or secured alongside new housing.
• Without clear planning, the proposed growth could reduce access to essential health services for both existing and new residents, impacting physical and
mental health outcomes.
I am particularly concerned that increased demand without confirmed provision could lead to longer waiting times, reduced appointments, and pressure on local medical staff,
undermining the well-being of the community.
These gaps mean the Plan is not effective, justified, or consistent with national planning policy, which requires growth to be planned where infrastructure is available or can be secured.
7. Affordable Housing Allocation
I support the principle of providing affordable homes for local residents, especially young families, first-time buyers, and key workers who cannot afford market rates.
Well-planned affordable housing can help maintain a mixed and vibrant community and retain younger residents.
Affordable homes in Dinas Powys could reduce commuting pressures by allowing residents to live and work locally.
However, the RLDP does not provide clear evidence for how many affordable homes are needed in Dinas Powys or what types of homes are required for different groups (families, older residents, low-income households).
There is insufficient information about how and when affordable homes will actually be delivered alongside market housing.
Without clear delivery plans or safeguards, affordable homes may not remain genuinely affordable in the long term.
Concentrated or poorly planned affordable housing may put pressure on local schools, healthcare, transport, and green spaces, which are already constrained in Dinas Powys.
The Plan does not explain how affordable housing will be integrated with market housing to create sustainable, mixed communities rather than segregation or social imbalance.
Because of the lack of clear evidence, delivery mechanisms, and mitigation for potential negative impacts, I do not consider the Plan sound in terms of affordable housing in Dinas Powys.

8. Community Cohesion & Social Integration
I am concerned that the Plan, as currently drafted, does not ensure new growth will support strong, healthy, and inclusive communities.
Until the Council provides clear evidence and enforceable measures addressing community cohesion, housing mix, and health impacts, I cannot have confidence that the Plan is sustainable or fair.
Impact on Community Cohesion and Social Integration
I am concerned that the Plan does not explain how new housing and growth will integrate with existing communities.
There is a risk that rapid development could strain local services, schools, and community spaces, and make it harder for neighbours to get to know one another.
I would like to see evidence that social infrastructure will keep pace with population growth and that communities will remain inclusive and connected.
Risk of Over-Concentration of Affordable Housing
I am concerned that clusters of affordable housing in certain areas could lead to pockets of social exclusion or limit access to opportunities.
The Plan does not explain how it will ensure a good mix of housing types and tenures across the Vale.
I ask that the Council provide evidence that housing allocations will support socially balanced, inclusive communities.
Impacts on Mental and Physical Wellbeing
I am concerned about increased traffic, air pollution, noise, and the loss of green spaces
affecting health and wellbeing. The Plan does not provide clear commitments to protect or improve accessible green spaces or safe walking and cycling routes.
I would like to see evidence that the Plan has assessed the health impacts of growth and will take steps to mitigate them.
9. Climate Change & Sustainability
I am concerned that, as drafted, the Plan does not provide enough evidence or practical measures to ensure new development is sustainable and climate resilient. The RLDP is not fully justified, effective, or consistent with national policy on climate change and sustainability.
Key gaps include alignment with carbon reduction targets, enforceable delivery of low-carbon travel, energy-efficient homes, sustainable drainage, and climate-resilient infrastructure.
Without clear policies and enforceable commitments on low-carbon travel, energy-efficient homes, sustainable drainage, and climate-resilient infrastructure, the Plan risks harming both the environment and the wellbeing of communities.
Alignment with Welsh Government’s Carbon Reduction Targets
I am concerned that the Plan does not explain clearly how new homes, workplaces, and other development will help Wales meet its legally binding carbon reduction targets.
Without this, there is a risk that growth in the Vale could increase emissions rather than reduce them. I would like to see evidence showing how this (and each) new development contributes to lowering carbon emissions.
Promotion of Low-Carbon Travel, Energy-Efficient Homes, and Sustainable Drainage
I am worried that the Plan relies too much on people walking, cycling, or using public transport without clear plans to make this happen.
There is also little information on whether new homes will be energy-efficient or if systems to manage rainfall and reduce flooding (like sustainable drainage) will be properly installed and maintained.
I want to see clear, practical measures to make low-carbon travel, energy-efficient homes, and safe drainage a reality.
Resilience of Infrastructure to Extreme Weather Events
I am very concerned about the impacts of extreme weather, including flooding, heatwaves, and storms, on roads, utilities, and homes.
The Plan does not clearly show how new developments or existing infrastructure will be designed to cope with these risks.
I would like to have assurance that any buildings, roads, drainage, and community facilities will be climate-resilient and protect people’s health and safety.
10. Plan-making Process & Evidence Base
In my view, the RLDP is not fully justified or effective in its current form with respect to plan-making and the evidence base. Key gaps include accessibility and transparency of evidence, consideration of resident and stakeholder feedback, and robust monitoring and review
arrangements.
Without clear and accessible evidence, demonstrated consideration of local feedback, and robust monitoring and review mechanisms, residents cannot be confident that the Plan will be fair, effective, or responsive to changing circumstances.
Clarity, Transparency, and Accessibility of Evidence
The RLDP is not always clear and is not easy to access.
Technical reports, data, and assumptions are often difficult to find or understand, making it hard for residents to see why particular sites or policies were chosen.
The Council should provide accessible summaries and clear explanations so that everyone can understand and comment on the evidence.
Local Consultation and Consideration of Resident Feedback
I am concerned that residents’ views may not have been fully taken into account in shaping the Plan.
It is unclear how consultation responses have influenced allocation decisions or policy wording.
I seek assurance that feedback from local people and community groups has genuinely informed the Plan, and that future consultations will be inclusive and clearly reported.
Monitoring and Review Mechanisms
The Plan does not clearly explain how progress will be monitored or how changes will be made if things do not go as planned. For example, if housing delivery is slower than expected or infrastructure is delayed, there is little information on how allocations or policies would be adjusted.