Thank you for consulting the Welsh Government on the Vale of Glamorgan Council Replacement Local Development Plan (LDP) – Deposit Plan. It is essential the authority is covered by an up-to-date LDP to give certainty to local communities and businesses and provide a robust basis for decision making.
Without prejudice to the Minster’s powers, the Welsh Government is committed to assisting Local Planning Authorities (LPAs) minimise the risk of submitting unsound plans by making comments at the earliest stages of plan preparation. The Welsh Government looks for clear evidence that the plan is in general conformity with Future Wales: The National Development Framework, aligns with Planning Policy Wales (PPW) and the tests of soundness, as set out in the LDP Manual.
National planning policies are set out in Planning Policy Wales (PPW) Edition 12 and seek to deliver high quality, sustainable places through a place-making approach (the LDP should ensure it takes into account any further iterations of PPW prior to the examination). The implementation of the core policy areas in PPW, such as adopting a sustainable spatial strategy, appropriate housing and economic growth levels, infrastructure delivery and place-making, are articulated in more detail in the LDP Manual (Edition 3). We expect the core elements of the Manual, in particular Chapter 5 and the ‘De-risking Checklist(s)’ to be followed. Failure to comply with these key requirements may result in unnecessary delays later in the plan making process. The development planning system in Wales is evidence-led and demonstrating how a plan is shaped by the evidence is a key requirement of the LDP examination.
After considering the key issues and policies in Future Wales, the Welsh Government is of the opinion that the Replacement Deposit Plan is in general conformity with Future Wales: The National Development Framework. Specific comments are set out in the Statement of General Conformity (Annex 1 of this letter). Annex 2 highlights a range of issues that need to be addressed for the plan to align with PPW and the DPM. Collectively, our comments highlight a range of issues that need to be addressed for the plan to be considered ‘sound’ as follows:
Annex 1 – General Conformity with Future Wales
• No significant concerns
Annex 2 – Core matters that need to be/have been addressed (PPW and the DPM)
• Spatial Strategy and Primary Settlements
• Housing and Economic Growth Levels – Regional Collaboration
• Maximising Affordable Housing Provision
• Delivery & Implementation – General
• Gypsy and Travellers
• Renewable Energy
• Minerals
• Best and Most Versatile Agricultural Land (BMV)
• Welsh Language

I would urge you to seek your own legal advice to ensure you have met all the procedural requirements, including the Sustainability Appraisal (SA), Strategic Environmental Assessment (SEA) and Habitats Regulation Assessment (HRA), as responsibility for these matters’ rests with your authority. A requirement to undertake a Health Impact Assessment (HIA) arising from the Public Health (Wales) Act 2017, if appropriate, should be carried out to assess the likely effect of the proposed development plan on health, mental well-being and inequality.
My colleagues and I look forward to meeting you and the team to discuss matters arising from this response.
Yours sincerely,
Neil Hemington
Chief Planner Welsh Government

Annex 1 - Statement of General Conformity
The Welsh Government is of the opinion that the Vale of Glamorgan Council Replacement Local Development Plan (2021-2036) Deposit Plan is in general conformity with the National Development Framework: Future Wales, as set out in paragraphs 2.16 – 2.18 of the Development Plans Manual (Edition 3).
There is a joint position statement on the relationship between Bridgend, Cardiff and the Vale of Glamorgan (BP20A), which considers population growth, migration patterns, housing completions, employment characteristics, demographics, commuting and transport links between the three adjoining authorities. The Welsh Government supports the principle of this work which demonstrates how change in the Vale of Glamorgan relates and complements growth in adjoining local authorities. This approach illustrates a good mechanism for other local authorities to follow.
Reasons
Future Wales places emphasis on the development of National Growth Areas in a sustainable manner. Growth areas must be sustainably planned, reduce the need to travel by car, encourage walking and cycling (active travel), maximise public transport usage and incorporate green infrastructure. Growth areas must embed these principles within a wider regional consensus, focussing on the opportunities they bring to promote social and economic benefits across a broader geographical area. The Welsh Government supports sustainable growth in National Growth Areas to respond to the climate change and biodiversity emergencies, making the best use of resources.
Policy 1 and Policy 33 of Future Wales states that Cardiff, Newport, and the Valleys will be the main focus for growth and investment in the region. The strategic diagram (p163) also identifies the Vale of Glamorgan within the National Growth Area. The Vale of Glamorgan RLDP, specifically BP20A, provides robust evidence on the interrelationship and key issues with adjoining authorities, including their interaction and how they have shaped and influenced the scale/location of growth in the RLDP. This is set out in the three Joint Position Statements (JPSs).
BP45 ‘Regional Assessment of Future Growth and Migration for the Cardiff Capital Region (CCR), May 2024, provides further evidence on how the scale of growth indicated for the region has shaped the scale of future economic growth within the Vale of Glamorgan. This results in a higher level of employment growth in the Vale of Glamorgan primarily to increase self-containment and reduce out-flows to adjoining urban areas. Two key areas for future economic growth are identified at Cardiff Airport/Bro Tathan Enterprise Zone and Aberthaw Power Station.
The result is a Sustainable Transport Orientated Growth spatial strategy focusing on the Cardiff – Bridgend railway line and A48 corridor, with the key settlement for growth at Barry, followed by service centres on public transport corridors. On balance, the Welsh Government considers the Deposit Plan is in general conformity with key policies in Future Wales namely (not exhaustive):
Policy 1: Where will Wales grow
Policy 2: Shaping Urban Growth and Regeneration – Strategic Placemaking
Policy 6: Town Centre First
Policy 10: International Connectivity – Cardiff Airport
Policy 12 Regional Connectivity
Policy 33: National Growth Area – Cardiff, Newport and the Valleys
Policy 36: South-East Metro
Future Wales brings a new perspective that all LDPs have to embrace on how each LDP sits within the region as a whole and the relationship to other LDPs, in essence, a strategic approach to cross boundary relationships. There is evidence to support that approach in advance of an SDP. 4

Annex 2 – Core matters that need to be addressed (PPW and the DPM)
Spatial Strategy - Location of Growth
The Council tested 4 spatial options:
Option 1 – Continuation of the adopted LDP growth strategy
Option 2 – Dispersed Growth
Option 3 – Focused Growth
Option 4 – Sustainable Transport Orientated Growth
The Council has chosen Option 4: Sustainable Transport Orientated Growth for its Deposit Plan. The strategy seeks to locate most of the new growth in those settlements well served by existing/proposed rail infrastructure along the Vale of Glamorgan/Penarth branch lines. This will encourage and maximise the use of sustainable transport modes in the plans designated Strategic Growth Area (SGA). The SGA encompasses most of the Council’s largest and more sustainable settlements and the Council considers that focussing development here will reduce the need to travel and will co-locate housing with employment opportunities, services, and community facilities.
With a significant proportion of the Council’s brownfield land already developed/committed, there are limited opportunities for brownfield development moving forward. The existing land bank is stated as 5,140 dwellings (land supply 3,837 + windfall assumptions 1,303), to meet a proposed housing requirement 7,890 (provision 8,660). The authority has allocated 3,520 dwellings on new sites (Policy SP6, Table 2). As a result, the plan has adopted a predominantly greenfield strategy allocating the majority of new development on five key sites (Policy HG1, Sites KS1-5 totalling 2,278 dwellings) well-connected edge of settlement sites, close to existing or proposed rail stations. We note the Council has used TfW data in the site assessment process to assess sites and their proximity to transport nodes. The remaining sites are mainly ‘rolled’ forward from the adopted LDP. The Welsh Government supports the spatial strategy, which accords with Planning Policy Wales (PPW) and is in general conformity with Future Wales.
Spatial Strategy - Primary Settlements
The Council’s settlement hierarchy allocates circa 92% of all housing development (committed and proposed) to settlements in the top three tiers of the hierarchy. The Welsh Government does not object to this approach. The recognition that Culverhouse Cross with few facilities on site and the presence of BMV Land, the expectation for limited growth (paragraph 6.14 & 6.15) is welcomed. Similarly, it is noted that Wick benefits from a primary school and has some scope for future growth, albeit in keeping with the scale and accessibility of the settlement. The Welsh Government is content that the scale of growth reflected in these two locations will reflect the availability of local facilities and services.
The Level of Growth - Homes and Jobs
The Deposit Plan (Policy SP1 & SP6) makes provision for 8,660 homes to deliver a housing requirement of 7,890 new homes (526 p/a) over the plan period 2021-2036, of which a minimum of 3,070 homes will be affordable. The flexibility allowance proposed by the Council is 9.8%. The delivery of new jobs is for 5,388 over the plan period (Policy SP14).
Homes: The 2018 WG Principal Projection results in a requirement of 431 units p/a, or 6,465 units over the plan period. The housing growth proposed in the plan (requirement) is around +1,425 units (22%) above the WG 2018 principal projection, the provision being +2,195 (34%) above. The Council consider the 10 year average housing completions to represent a more realistic level of growth to deliver the key issues the plan is seeking to address. The Council considers that a lower level of growth (2018 projection) is not appropriate because the projections do not take account of 5

any policy decisions and were prepared in advance of the Covid-19 pandemic with implications for migration patterns and fewer jobs proposed.
BP8A (November 2025) considers the latest 2022 Welsh Government population and housing projections, noting they are higher than the 2018 based projections. The projections for the Vale of Glamorgan show significant variation in internal migration in particular which the Council considers should be treated with caution. The projections are trend based and are affected by specific factors that may have occurred within the previous 5 years. The 5 years in question included a period of high housebuilding associated with a newly adopted LDP, as well as the Covid 19 pandemic, where many students returned to home from term-time addresses and re-registered with GPs in the Vale.
Given the fluctuation in recent migration figures, the Council consider longer-term trends are more appropriate, and it is noted that the population change identified in the 10-year migration variant is of a similar level to that proposed under the RLDP projection. In conclusion, for the reasons identified above, despite the updated projections, the Council considers the RLDP housing requirement continues to represent a robust basis to deliver a sustainable and deliverable level of growth over the plan period. The Welsh Government does not object to the scale of housing contained within the plan.
The demographic evidence (February 2023, Edge Analytics) tested 12 growth scenarios comprising: demographic-led, dwelling-led, and employment-led scenarios. The preferred housing requirement is based on a 10-year dwelling-led scenario (526 dpa) that would result in a population growth of 9.7% over the plan period with an annual net in-migration of 1,009 persons. The Council considers this level of housing growth is deliverable with a large proportion met through existing commitments (51%) and a jobs total (4,875 jobs) that broadly aligns with the level of new jobs forecast in the Employment Land Study (5,338 jobs). Moreover, the scale of growth is considered by the Council to be compatible with Future Wales and the role the authority plays within the wider southeast region. With inward migration to the Vale of Glamorgan from Cardiff expected to slow as Cardiff’s strategic sites deliver higher levels of housing and with employment opportunities in the Vale co-located with housing sites, there are further opportunities to reduce the high levels of out-commuting into Cardiff. Overall, this approach is proposed by the Council to deliver a level of growth that is balanced with the emerging Cardiff LDP and wider southeast region. The Welsh Government does not object to the level of growth proposed in the plan.
We note that historic completion rates in the Vale of Glamorgan have fluctuated considerably over recent years. The past 10-year (2011-2021) average completion rate is 526 dwellings p/a. This has been exceeded over the last 5-years (2016-2021) with 698 dwellings constructed p/a. Build rates in recent years are in part attributed to the delivery of the current adopted LDP strategy that has more of a ‘rural settlement' focus, with multiple sites across many settlements being built out. Replicating this approach going forward (10,470 dwellings) would not comply with FW/PPW in terms of sustainable development and transport, potentially adversely impacting on Cardiff’s growth strategy. On this basis, the Council considers that achieving 526 dwellings p/a in the preferred 10-year dwelling-led scenario is sustainable and deliverable and would provide a level of job growth (5,338 jobs) that is balanced with the housing requirement. The Welsh Government does not object to the level of housing proposed in the plan but demonstrating delivery of the key housing sites will be essential.
The Welsh Government notes that BP0A identifies small and large windfalls, based on historic trends of 53/yr and 80/yr respectively. Also, the large windfalls are not included in the first two years of the trajectory, as per the DPM. A non-delivery allowance of 5% is identified, which reflects local characteristics in the Vale of Glamorgan. A flexibility allowance of 9.8% has been factored into the provision. The Welsh Government supports this approach, although whilst Appendix 1 contains a housing trajectory, there is no table to mirror that of Table 21, DPM. This should be included in Appendix 1. 6

Jobs: The Council’s 10-year dwelling-led growth option results in a requirement for 4,875 new jobs (325 p/a) over the plan period. This broadly aligns with the projected growth for 5,338 (355 p/a) new jobs in the Employment Land Review (BP12) and as set out in Policy SP14.
The level of employment growth proposed (5,338 jobs) over the plan period is below the target in the currently adopted plan (7,610-10,610 jobs). The lower target is considered by the Council to more accurately reflect the cohort of working aged people in the Vale of Glamorgan and would support a continuation of long-term housing delivery trends that takes into account lower housing growth post-recession and a shorter period of historically high dwelling completions (2016-2021). The Welsh Government does not object to the level of job growth proposed in the plan.
In summary, (and subject to the above clarification), the Welsh Government has no significant concerns with the level of homes and jobs proposed in the plan, which is in general conformity with Future Wales.
Affordable Housing Provision
The Local Housing Market Assessment 2023 (LHMA) (BP10B) calculates affordable housing need over the replacement plan period using the ‘policy neutral’ Welsh Government 2018 Principal Projection and the preferred growth option. The LHMA provides the latest evidence on affordable housing need, identifying a net annual need for 1,075 affordable units per annum for the next five-years and a further 154 units per annum over the following 10 years (BP10B, Executive Summary), resulting in a requirement for 6,915 affordable homes over the plan period (461 p/a) with a tenure split of 65% social rent and 35% intermediate. The Welsh Government note that the RLDP housing requirement is higher than the 2018 projections. Accordingly, to take this into account the affordable housing need for the RLDP is 502/yr which equates to a need of 7,530 over the plan period (RLDP, paragraph 6.116, Table 4).
Policy SP7 identifies a target of delivering a minimum of 3,070 affordable homes, the housing need being across all 13 Housing Market Areas, albeit it is more acute in Barry, Penarth, and Llantwit Major for 1-bed properties. The Welsh Government notes that most of the new housing development (51%) is proposed in the Key Settlement of Barry and Service Centre Settlements, which include Penarth and Llantwit Major.
The Welsh Government has no significant concerns regarding the relationship between the LHMA and the Deposit Plan.
Affordable Housing Led Sites
To deliver additional affordable housing above that which market led housing can provide, the authority proposes (Policy SP3 & HG4) to permit small scale affordable housing-led developments that provide a minimum of 50% affordable housing on sites up to 25 dwellings in minor rural settlements and 50 dwellings in primary settlements. The principle of this approach is supported.
Paragraph 6.137 of the plan states:
“Policy HG4 makes provision for affordable housing-led sites in locations outside the Strategic Growth Area. These sites, which are allocated for a minimum of 50% affordable housing, are included within the settlement boundary.”
The reference to being within the settlement boundary is not referenced in policy HG4. It would be beneficial to either include such a reference or demonstrate that settlement boundaries do include those sites listed in policy HG4 for clarity.
These sites must be in addition to the market housing led requirement and identified in the LDP. This policy approach is justified by the high level of affordable housing need evidence by the LHMA and must be accompanied by additional control over the land by the local planning authority to 7

ensure effective delivery. Evidence should include ownership of the land, a binding legal agreement where the land is in private ownership or a resolution of the council to use compulsory purchase powers. RLDP, paragraph 6.133 references to such controls, however, should such controls be contained within the policy?
Affordable Housing Exceptions Sites
Policy HG5, states 100% affordable housing exception sites can be located outside a settlement boundary where they comply with PPW/TAN2 and any threshold/policy requirements set in the Deposit Plan. The Welsh Government supports this approach.
Employment Land
The Council’s Employment Land Study (BP12, March 2023) identifies a requirement for 67.80ha of employment land, which includes a 5-year buffer. The requirement is based on rolling forward past trends (over 25 years) and is of a sufficient scale to meet the 5,338 jobs forecast. However, Policy SP14 identifies employment land allocations totalling 182ha, which is an increase of around 114ha above the employment land requirement. The sites that make-up this supply are largely major employment allocations that attract significant regional inward investment at Cardiff Airport and Bro Tathan Enterprise Zone totalling 127.85ha (70%) of the total provision. The Welsh Government does not object to the over-provision of employment land in the plan. The Enterprise Zone designation must be identified and the allocations within it (SP14: 1-3).
Delivery and Implementation
PPW and the DPM (Chapter 5) contain guidance on the requirements in respect of the delivery and implementation of plans. The Deposit Plan should set out site-specific details for Key Sites that includes general phasing timescales, key infrastructure requirements, placemaking principles (including concept / schematic masterplan frameworks), constraints, and developer requirements, where appropriate. We note the Deposit Plan has included emerging master planning/infrastructure work on key sites.
The phasing, timing, funding, and delivery of Key Sites will be critical to ensure the plan delivers the scale of growth required over the plan period. This includes the relationship between the two Key Sites in St Athan (KS4 and KS5) totalling up to 1,150 units and the delivery of a new rail station in St Athan to meet the objectives of the strategy and encourage a modal shift to more sustainable forms of public transport.
The development sites may also impact on the trunk road network, in particular the M4 J34 and there will need to be a suitable level and form of traffic assessment to accompany the plan. (The transport case may consider the South East Wales Traffic Model as part of any masterplan impacts on the Strategic Road Network (SRN) (Wales Regional Transport Models | TfW)). The Council will also need to demonstrate that all housing components are deliverable through a housing trajectory prepared by the Council and Housing Stakeholder Group. Statements of Common Ground for key allocations, especially those that have ‘rolled over’ from the adopted plan, would be advantageous to demonstrate the sites are deliverable in the timescales set out.
The Deposit plan is supported by a high-level affordable housing study and site-specific viability appraisals for Key Sites. All viability work and must be prepared in conjunction with the Viability Steering Group and site-specific promoters.
It will be for the Council to justify deliverability supported by robust financial viability.
Gypsy and Travellers
The Gypsy and Traveller Accommodation Assessment GTAA (June 2022, approved June 2024) identifies a total need for 11 pitches over the plan period up to 2036, of which 9 pitches are ‘immediate’ by 2026. WG note that 4 pitches have since gained planning permission, reducing the remaining need over the plan period being 7 pitches. 8

Policy SP9 identifies a site at Llangan (0.76Ha) to accommodate the 7 pitches needed. It will be for the Council to demonstrate the appropriate site selection assessment process has been followed and that the site complies with requirements in PPW (4.2.35), Circular 005/2018 (paragraph 35) any relevant guidance and the DPM (5.80-5.85) to allocate a deliverable site in the plan period. The views of the relevant statutory bodies must also be agreed with no outstanding objections to the delivery of the site. The Welsh Government has no objection in terms of meeting the numerical need for gypsy traveller accommodation.
Renewable Energy
Future Wales: The National Plan 2040 identifies Barry as a District Heat Network (DHN) Priority Area. The Renewable Energy Assessment (BP15) explores the opportunity for a DHN using waste heat from Barry Biomass, but as there is some uncertainty on the future of the plant, the study concludes there is considerable risk to using the plant as a source waste heat. Could the Council provide an update on alternative options for a DHN in Barry?
It is welcome that the Renewable Energy Assessment (REA) has considered BMV policy, specifically for solar PV, and use of the Predictive ALC Map. The assessment has only considered non-BMV land (Subgrade 3b, Grade 4 and 5). The assessment would benefit from referencing the clarification provided in the DCPO letter of 1st March 2022 in respect of solar PV and BMV agricultural land for completeness.
The study identifies that in the Vale of Glamorgan solar development is more suitable than wind energy because of the flight path of aircraft in the south of the County Borough. However, there are some opportunities for wind sites, but these are likely to be small (<10MW) where aviation risks are lower and there is some grid access. Conversely, there are large expanses of land suitable for solar areas (>10MW) to the West of the County Borough, where there is little existing development. The study identifies 20 large-scale solar areas but recognises that grid constraints may impact the ability of sites to come forward.
Solar and wind search areas (where appropriate) below the 10MW Developments of National Significance (DNS) have been identified (Policy CC3). The plan also includes a criteria-based policy for all renewable energy proposals, particularly wind development, under 10MW (Policy CC4). Policy CC3 makes reference to adhering to the criteria in Policy CC4. However, would it not be the case that if search areas have been identified in Policy CC3 have they not already met the criteria? If they would not, should they be identified in the first place? Clarity would be beneficial. The Welsh Government supports the approach but seeks clarity on the point raised.
The Welsh Government notes the proposed search areas for wind energy near Morfa Ystrad Owen/Nant Rhydhalog, according to the Peatlands of Wales Evidence Score Map, the search area includes areas of peatland (Evidence Score 4). The site is also a SINC. This raises concerns as to how the inclusion of this search areas meets the policy test in PPW 6.4.15, 1a and 1b (Stepwise) regarding avoidance of irreplaceable peatland habitats and PPW 6.4.34.
Policy CC4 refers to Developments of National Significance (DNS) in 6.344 and 6.346. This should now refer to Strategic Infrastructure Projects (SIP) which replaced DNS.
Minerals
The Regional Technical Statement (RTS 2nd Review) identifies a nil apportionment for land-won sand and gravel provision in the Vale of Glamorgan. The Welsh Government policy clarification letter (dated 11 November 2021) identifies a surplus of 1.68mt of crushed rock. As there is a surplus of crushed rock reserves and a lack of sand and gravel production in the Vale, no specific allocations are required in the replacement plan. It is unclear whether a Statement of Sub-Regional Collaboration with adjoining authorities in the Cardiff City sub-region been agreed, or does the latest Position Statement (July 2022) explain how any shortfall will be met across 9

the region, particularly for crushed rock, of which the Vale has a surplus? Clarification would be beneficial.
BMV Agricultural Land
The Welsh Government has engaged with the Council for land quality advice, survey advice and ALC survey validation for candidate sites. The LPA has produced a specific topic paper on BMV policy application. BP23A. The Deposit RLDP allocates 188 hectares of housing land, 5.62 ha is identified as BMV land (under 3% of total housing allocations). The RLDP:
• Has sought to avoid BMV land wherever possible;
• Uses the Predictive ALC Map as a core evidence layer to inform: The spatial strategy;
• Settlement hierarchy decisions; and
• Candidate site assessments.
•
• Directs strategic growth to areas with least BMV land
• Removes or avoids allocations where BMV impacts were significant or unjustified.
• Quantifies total BMV loss and demonstrates it is minimal (5.62ha) and proportionate at plan level.
• Applies a sequential approach through: Preference for brownfield and non-BMV sites;
• Replacement of higher-BMV sites with lower-grade alternatives where possible.
•
• Requires site-specific ALC surveys to verify actual land quality before allocation.
• Demonstrates that allocated BMV land is: Often small, fragmented, or constrained;
• Sometimes previously disturbed or incapable of being farmed differently from surrounding lower-grade land; and
• Necessary to deliver the Plan’s housing strategy where reasonable alternatives are unavailable.
•

In conclusion, the Welsh Government consider the Authority has demonstrated a sensible and pragmatic approach to considering BMV loss in the context of national planning policy, and on that basis no objection is offered.
Green Infrastructure
Policy SP19 should explicitly reference the need for development to be accompanied by a Green Infrastructure Statement.
PPW12 requires decision makers to apply the step wise approach to GI, with enhancement secured at every stage where possible, there is no distinction made between the quality of the GI assets – the qualification in the policy statement that states proposals will incorporate measures that protect and enhance high quality multi-functional green infrastructure should be redrafted to remove the quality reference. The need to avoid an impact in the first instance should also be explicitly incorporated into the policy.
Criterion 1 (Policy SP20) should be redrafted – the stepwise approach in PPW 12 6.4.15 1a - does not distinguish between relative ecological value – the avoidance step applies to biodiversity in its widest sense (i.e. the variety of species and habitats and their abundance) and ecosystem functioning.
Welsh Language
There is limited reference to the Welsh language in the plan, either potential adverse impacts arising through development, or mechanisms via a policy framework to support and grow the use of the language. There are references to a number of Welsh-medium schools (3.26) and the increase in the number of people able to speak Welsh according to the 2011 census (3.52) but there is no mention of the authority's Welsh Language Strategy or promoting or cross-referencing to the aims of 10

Cymraeg 2050: A million Welsh-speakers. Paragraph 6.81 of the plan refers to development north west of Barry:
“Land at North West Barry is allocated for a residential development of up to 376 dwellings and public open space. The site is in a sustainable location on the edge of the Barry, a key settlement, in a location that is well served by services and facilities, including a major supermarket, GP surgery, community centre, three primary schools (English Medium, Welsh Medium and Church in Wales) and two high schools (English and Welsh Medium) all located in reasonable walking distance. There is an active travel route along Port Road West, bus stops in close proximity providing buses to Llantwit Major, Cardiff and the centre of Barry. Barry station is 1.3 miles from the site entrance.”
There is no mention that the Council want to undertake a Welsh Language Impact Assessment (WLIA) so there appears no attempt to measure the impact on the Welsh schools resulting from housing development? Could the Council clarify if such implications have already been covered in the WLIA for the plan, ISA, or are any specific policies necessary?

The policy needs to consider visual aspects more greatly and developers of solar farms need to be held to higher standards in terms of vegetation to shield the sites from view. The sites should also be more carefully considered and be required to use topographical relief to shield the sites from public view to a greater extent.

This policy is good in the main but greater weighting should be given to visual aspects as well. Many of the new solar farms within the vale are too visible from major roads and are negatively impacting on the visual aesthetics of the area. residents and visitors well being is negatively affected when whilst travelling around they vale they feel as if they are living within a giant power generation scheme.

We would like to thank you for consulting with South Wales Police in respect of the Replacement Local Development Plan 2021 to 2036.
We welcome working with The Vale of Glamorgan Council in respect of The Vale of Glamorgan Replacement Local Development Plan 2021 – 2036: Deposit Plan to ensure the future needs and community safety is addressed within the plan and supporting documents.
We would respectfully ask that our comments are taken into consideration, and included in the plan, and that we can work in partnership to develop the specific planning guidance documents mentioned below.
The replacement development plan outlines its Vision and objectives of the RLDP as follows:
‘By 2036’:
The Vale of Glamorgan is a healthy and inclusive place for everyone, with equitable access to services and facilities both physically and digitally. Residents are proud of where they live and have access to the homes they need. Housing growth has delivered homes which caters for all, including affordable homes and older person’s housing; contributing towards diverse and cohesive communities where residents can maintain their independence.
Through placemaking, places and spaces are safe, accessible and socially inclusive. Development respects local character and sense of place is valued by residents and contributes positively towards health and wellbeing. Positive improvements have been achieved in narrowing the disparities in Integrated Sustainability Appraisal (ISA) for the Replacement Local Development Plan Prepared for: Vale of Glamorgan Council AECOM 5 the quality of life and health outcomes for residents living in the most deprived areas through improved access to employment, education, training, services, and investment in the built environment.
The Vale enjoys a network of connected, multi-functional and accessible green and blue spaces, providing a range of enhanced leisure and health benefits within and between towns, villages, and the countryside. More residents participate in active and healthy lifestyles. Investment in green infrastructure has produced a net biodiversity benefit with the creation of new habitats, enhanced connectivity and Planting providing carbon storage and contributing towards Climate Change resilience and adaptation.
Objectives:
1. Mitigating and adapting to climate change
2. Improving mental and physical health and well-being
3. Homes for all
4. Placemaking
5. Protecting and enhancing the natural environment
Policies that support the role of a Designing Out Crime Officer and Secured by Design are as follows:
Secured by Design (SBD) is the official police security initiative that works to improve the security of buildings and their immediate surroundings to provide safe places to live, work, shop, and visit.
Planning Policy Wales (PPW) states that crime and prevention and fear of crime are social considerations to which regard must be given by local planning authorities in the preparation of development plans. They should be reflected in any supplementary planning guidance and may be material considerations in the determination of planning applications. The aim should be to produce safe environments through good design.
Technical Advice Note (TAN) 12: Design, provides advice for all those involved in the design of development on how good sustainable design can be facilitated through the planning system. TAN 12 reminds practitioners that local authorities (including National Park Authorities) are required to have due regard to crime and disorder prevention in the exercise of their functions under Section 17 of the Crime and Disorder Act 1998.
TAN 12 recognises the Secured by Design initiative as a standard that has been shown to reduce crime.
TAN 12, paragraph states that ‘Local authorities are advised to consult Designing out Crime Officers on pre-applications and planning applications for those developments where there is potential to eliminate or reduce crime through the adoption of suitable measures at the design stage. This is especially important for major developments such as new housing estates, industrial estates, shopping centres, leisure complexes, schools, and car parks. It is important to consult Designing out Crime Officers at as early stage as possible – by the time a formal application is submitted, the opportunity to take account of advice may already be limited.’
Section 17 of the Crime and Disorder Act 1988 requires local authorities to consider crime and disorder implications in all their authorities and functions and do all that they reasonably can do all they can do to reduce these problems.
Violence against women and Girls:
Crime has a major impact on people’s lives in the Vale of Glamorgan and impacts on the health of the public especially those who have been victims of crime and anti-social behaviour and vulnerable groups such as Women and Girls.
In spring 2023, the Home Secretary announced Violence Against Women and Girls as a national threat and included it within the 9 Strategic Policing Requirement (SPR) alongside terrorism, serious and organised crime, and child sexual abuse.
Secured by Design can assist with ensuring that the built environment in all its forms is designed to reduce the opportunity of Violence Against Women and Girls (VAWG) and contribute to such places feeling safe, to live, work and socialise, for all. The importance of this is outlined within the National Police Chiefs’ Council’s (NPCC) ‘Policing Violence Against Women and Girls – The National Framework for Delivery: 2024 – 2027’ under the ‘Prevent’ element of the strategy; outlining the need for building safer spaces and places. Further information is available at: https://www.npcc.police.uk/SysSiteAssets/media/downloads/our-work/vawg/vawg-framework-fordelivery.pdf
In Wales, planning is devolved. Planning Policy Wales and Future Wales: The National Plan 2040 set out the Welsh Government’s national planning policy, where new developments are proposed. Planning Policy Wales explains: “A clear rationale behind the design decisions made […] should be sought throughout the development process and expressed, when appropriate, in a design and access statement.”
76 The guidance for design and access statements for Wales categorises five key objectives of good design (Access, Character, Community Safety, Environmental Sustainability and Movement) and explains how meeting these objectives should ensure that both design quality and inclusive access are given sufficient consideration in the planning process.
77 Design and access statements have been required in Wales for many planning applications since 2009 and have been part of legislative requirements since the Planning (Wales) Act 2015.
The Angiolini Inquiry Part 2 First Report: Prevention of sexually motivated crimes against women in public Ordered by the House of Commons to be printed on 2 December
In Wales, local authorities are under legal obligation to consider and address crime while in the process of planning: “Local authorities [in Wales] are under a legal obligation to consider the need to prevent and reduce crime and disorder in all decisions that they take. Crime prevention and fear of crime are social considerations to which regard should be given in the preparation of development plans and taking planning decisions. The aim should be to produce safe environments that do not compromise on design quality in accordance with the cohesive communities’ wellbeing goal.”
The Inquiry considers that there would be an opportunity to place a greater focus on preventing sexually motivated crimes against women in public spaces if this priority were reflected in planning guidance and principles.
For instance, neither the English nor the Welsh documentation contains specific reference to considering how design can help prevent violence against women in public spaces. The Inquiry saw evidence of this being discussed: “Under public spaces in the National Model Design Guide it mentioned well located, attractive public spaces. But there is no mention of violence against women and girls. There is minimal mention of crime reduction, just that amenity spaces should make people feel safe, help overcome crime, reduce the fear of crime.”
The Terrorism (protection of premises)Act 2025 (Martyn’s Law)
This Act became legislation on the 3rd of April 2025. This legislation is to improve protective security and preparedness across the United Kingdom for certain premises.
South Wales Police and Counter Terrorism Policing Wales would ask that where this legislation applies that early consultation takes place with the Designing out crime officers and Counter Terrorism Policing Wales.
If a premises falls within the scope of the The Terrorism (Protection of Premises) Act 2025, the development plans should be referred to South Wales Police Designing Out Crime Officers who will in turn will take advice from Counter Terrorism Policing Wales. This consultation should take place at the pre planning stage.
Standard Tier- will drive good preparedness outcomes. Locations with a maximum occupancy of greater than two hundred people will be required to have appropriate public protection procedures in place to ensure effective protective security and preparedness if an act of terrorism were to occur in their premises or immediate vicinity.
Enhanced Tier- focused on high-capacity locations in recognition of the potential consequences of a successful attack. Locations with an occupancy of eight hundred plus at any time will be required to have in place as reasonably practicable, appropriate public protection procedures and measures that can be expected to reduce the vulnerability of the premises, and the risk of physical harm being caused to individuals if an attack was to occur there or nearby.
Premises will fall within scope of The Terrorism (protection of premises)Act 2025 where “qualifying activities” take place. This will include activities such as entertainment, leisure, retail, food and drink, museums and galleries, sports grounds, public areas of local and central Government buildings (e.g. town halls), visitor attractions, temporary events, Places of Worship, health, and education.
The legislation applies to eligible locations which are either: a building (including collections of buildings used for the same purposes, e.g. a campus); or location/event (including a temporary event) that has a defined boundary, allowing capacity to be known. Eligible locations whose maximum occupancy meets the above specified thresholds will be then drawn into the relevant tier.
Public Spaces:
It should be borne in mind that the development of public spaces which are either owned, managed or they have influence over should also include protected security and preparedness at the concept stage of the planning process.
South Wales Police recommendations:
Our recommendations are set out below in relation the objectives and specifically to preventing crime and disorder and enhancing community safety:
1. Mitigating and adapting to climate change Secured by Design Residential Guide 2025 states:
Crime committed in 2011 in England and Wales is estimated to have given rise to over 4 million tonnes CO2e, equivalent to emissions of around 900,000 UK homes. Burglary resulted in the largest proportion of the total footprint (30%) due to large volume of offences and the carbon associated with replacing stolen or damaged goods.
Source: “Addressing the Carbon-Crime Blind Spot - A Carbon Footprint Approach” (2016). Helen Skudder, Professor Angela Druckman, Jon Cole, Alan McInnes, Dr Ian Brunton-Smith, Dr Gian Paolo Ansalon.
Secured by Design states ‘The environmental benefits of SBD are supported by independent academic research consistently proving that SBD housing developments experience up to 87% less burglary, 25% less vehicle crime and 25% less criminal damage (Note 1.5). It also has a significant impact on anti-social behaviour.
Therefore, there are substantial carbon cost savings associated with building new homes and refurbishing existing homes to the SBD standard i.e. less replacement of poor-quality doors, windows and the stolen property from within the home as a result of criminal acts. This has been achieved through adherence to well-researched and effective design solutions, innovative and creative product design coupled with robust manufacturing standards.’
Research documentation can be found on the SBD website at: https://www.securedbydesign.come
Recommendations:
• SP 6 - Ensure early consultation with the Designing Out Crime Officer and to achieve Secured by Design on all new developments and refurbishments.
• CC5 - Heat Networks – Advice should be sought from the Designing Out Crime officer to ensure the safe placement of heat pump devices.
• CC5 – Consultation should take place with the Designing Out Crime Officer in respect of wind or solar farms, so Secured by Design can be achieved.
• DNP7 – DARK SKIES – Secured by Design can assist with ensuring that the built environment in all its forms is designed to reduce the opportunity of Violence Against Women and Girls (VAWG) and contribute to such places feeling safe, to live, work and socialise. South Wales Police would ask that Designing Out Crime Officers are involved at the pre planning stage to discuss and be able to make recommendations in relation to lighting.
Reason: To reduce the carbon footprint of development.
2. Improving mental and physical health and well-being
• PGD1 – Creating well designed and inclusive places states:
Development must demonstrate that the following:
Ensuring no unacceptable impacts on public and residential amenity, particularly regarding privacy, overbearing, security, noise and disturbance
Ensuring that public open space, private amenity space and cycle and car parking in accordance with the Council’s standards.
Secured by Design Residential Guide states:
Poorly designed and specified public realm and communal areas, such as playgrounds, roof gardens, communal gardens, community dining rooms, toddler play areas, seating facilities have the potential to generate crime, the fear of crime and anti-social behaviour.
The design and layout of play spaces will vary depending on the age requirements. The provision of inclusively designed public amenity/play spaces as an integral part of residential developments, should make a valuable contribution towards the quality of the development and the character of the neighbourhood.
Recommendations:
• PGD 1 - Facilities shall be designed to allow natural surveillance from nearby dwellings with safe and accessible routes for users to come and go. Boundaries between public and private space shall be clearly defined and open spaces must have features which prevent unauthorised vehicular access. Communal spaces as described above should not immediately abut residential buildings.
• SP 5 - South Wales Police would recommend that all new public space is designed to Secured by Design standards (Residential) Guide. Use the ‘Safer Parks’ document (research by ‘Make Space for Girls’) to design safe communal spaces. Designing Out Crime officers should be consulted at pre planning stage to give their recommendations for communal space.
Reason: To enhance community safety and prevent antisocial behaviour.
3. Homes for all
Policy 7- Delivering Affordable Homes
The Vale of Glamorgan Housing Strategy 2021-2026
The strategy includes a long-term vision for housing in the Vale where “All residents in the Vale of Glamorgan have access to good quality, suitable housing and can live happily and independently in vibrant, sustainable communities.”
• Aim 1: More Homes, More Choice.
• Aim 2: Improved homes and communities.
• Aim 3: Better housing advice and support.
• Aim 4: Equality of access to housing and housing services.
‘The Vale has a significant need for affordable homes, with affordable housing need remaining one of the highest in Wales, even though the Vale is one of highest performing authorities in Wales in terms of affordable housing delivery. Using the principal projections, the Council’s 2023 Local Housing Market Assessment (LHMA)
identifies a need for 1,075 affordable homes per annum over the 5-year period 2023-2028 and 154 affordable homes per annum for the following 10 years.’
Ensure that all new residential developments provide high quality housing that includes the right mix, tenure and type of homes that respond to the changing needs of the Vale’s population. This includes homes that are affordable, accessible and adaptable for people of all ages and that address the identified accommodation needs of all the Vale’s communities through all stages of life.
The Vale of Glamorgan Older Persons Housing Strategy
2.84 The Council’s Older Persons Housing Strategy ‘Creating Homes and Neighbourhoods for Later Life 2022-2036’ sets out a vision for the Vale of Glamorgan which seeks: ‘to secure the best quality of life for older people to live as independently as possible in later life. This means delivering a range of accommodation that enables older people to live fulfilling lives and enjoy good health in attractive homes that meet their needs and allow them to retain their independence as they age.”
All Welsh Government grant funded housing refurbishments must comply with the Development Quality Requirement (DQR) and achieve Secured by Design Silver award.
South Wales Police would ask that all new developments are designed and built to Secured by Design standards this includes roads, paths, lighting, defensible space and house types/ standards. We would ask that at the pre planning advice is sought from the Designing Out Crime Officer to advise on crime prevention through environmental design.
Violence Against Women and Girls:
The harm caused to victims and society by violence against women and girls (VAWG) in all its forms, including but not limited to, harassment, stalking, rape, sexual assault, murder, honour-based abuse and coercive control is incalculable. While men and boys also suffer from many of these forms of abuse, they disproportionately affect women.
In spring 2023, the Home Secretary announced Violence Against Women and Girls as a national threat and included it within the 9 Strategic Policing Requirement (SPR) alongside terrorism, serious and organised crime, and child sexual abuse.
Secured by Design can assist with ensuring that the built environment in all its forms is designed to reduce the opportunity of Violence Against Women and Girls (VAWG) and contribute to such places feeling safe, to live, work and socialise, for all. The importance of this is outlined within the National Police Chiefs’ Council’s (NPCC) ‘Policing Violence Against Women and Girls – The National Framework for Delivery: 2024 – 2027’ under the ‘Prevent’ element of the strategy; outlining the need for building safer spaces and places. Further information is available at:
https://www.npcc.police.uk/SysSiteAssets/media/downloads/our-work/vawg/vawg-framework-fordelivery.pdf
South Wales Police recommendations:
• SP 6 - All Welsh Government grant funded homes MUST meet Secured by Design Gold or in the case of a refurbishment Silver. Consultation with the Designing Out crime Officer should take place at the pre planning stage when an application for Secured by Design should also be made.
• SP6 - HOUSING REQUIREMENT - Where a change of use/ mixed use retail, community leisure and active travel routes are planned Secured by Design Residential and Commercial guides should be applied. Early consultation with Designing out crime officers particularly in the Town Centres is recommended.
• SP6 - HOUSING REQUIREMENT - Designing Out Crime Officers should be consulted at the concept stage of a development, where there are 10 or more housing units and in the case of commercial space 1000 square metres.
• SP6/ HG 7 - HOUSING REQUIREMENT - South Wales Police Designing Out Crime Officers to work in partnership with the Vale of Glamorgan Council Planning Department to compile a specific planning guidance in relation to Houses of multiple occupancy.
• SP6 - HOUSING REQUIREMENT- South Wales Police would ask that all flats/ apartments’ conversions meet WDQR (Welsh Design Quality Standards) and achieve at least a Secured by Design silver award.
• SP6 - Housing Requirement - In the case of the change of use of residential land or properties, South Wales Police would ask that any change of use application is sent to South Wales Police Designing out crime officers.
• SP 6 - South Wales Police are involved in discussion with the Vale of Glamorgan Planning Department and the compilation of Specific planning guidance to cover co-living and similar shared facility developments.
• SP6 - HOUSING REQUIREMENT -Where co- living developments are proposed to deliver a balanced housing mix. South Wales Police would ask that the pre planning discussions take place with the Designing Out Crime officer and that the development is built to Secured by Design standards as set out in the most current Secured by Design Residential Guide.
• SP3 – DEVELOPMENT IN THE COUNTRYSIDE (Policy GT1/ SP9 – Gypsy and Traveller Site Provision). The site is reasonably accessible to essential services and facilities such as healthcare, education, employment, and public transport. Safe and appropriate vehicular access can be provided from the highway network, and the site layout affords adequate provision for parking, turning, servicing and emergency vehicle. South Wales Police would ask that they consulted to provide Secured by Design advice at the pre planning stage of any such development.
• HG6 – PROVISION OF SPECIALIST ACCOMMODATION
The accommodation is appropriately designed to meet the specific needs of the intended residents, including older people, people with disabilities, those with mental health needs, and other vulnerable groups. The development is located in an accessible and sustainable location, with good access to public transport, community facilities, health services, and local amenities –
-All specialist housing is built to Secured by Design and South Wales Police are involved at the pre planning stage of specialist developments.
• The Vale of Glamorgan Older Persons Housing Strategy:
‘To secure the best quality of life for older people to live as independently as possible in later life. This means delivering a range of accommodation that enables older people to live fulfilling lives and enjoy good health in attractive homes that meet their needs and allow them to retain their independence as they age.”
HG 6 - All older person’s housing to be built to Secured by Design standards and pre application consultation with Designing Out Crime Officers.
• HG7 - HOUSES IN MULTIPLE OCCUPATION (HMO’s)
South Wales Police would ask that they work in partnership with The Vale of Glamorgan Planning Department, to develop a specific planning Guidance in relation to Houses of Multiple Occupancy.
• SP3 - Development in the Countryside Affordable Housing (Policy HG5) – Consultation takes place. Where, developments are planned outside the specific main areas South Wales Police would ask that they are consulted about the proposed infrastructure and design of such developments. - Early consultation is recommended with Designing Out Crime officers and South Wales Police Traffic Management.
• PGD 2 /SP 4 - ‘Ensure major new development is directed to locations that are or will be by the time of initial occupation easily accessible by walking, cycling, and public transport.’- Early consultation with South Wales Police Designing Out Crime Officers and South Wales Police Road Traffic Management Department where roads and pathways are planned to be built.
• SP5 – Creating Healthy and Inclusive Places and spaces: Ensuring development proposals are designed to facilitate accessible healthy environments to address relevant determinants of health positively, particularly in response to local health needs; • Ensuring that all places and developments are as inclusive as possible, capable of adapting to a broad range of changing needs and delivering a high quality of life. – Designing Out Crime Officers are consulted at pre planning to ensure public space is designed to ensure the space is safe and inclusive for all and especially vulnerable groups. (Safer Parks Document, Angelini Enquiry).
• SP 4 - Supporting the provision of new and enhanced community and healthcare facilities: Where Health care facilities are proposed South Wales Police would ask that Secured by Design Commercial Guide /Hospitals Guide are followed and that the Designing Out Crime officer is consulted at the pre planning stage.
• SP19 – Waste management: Secured by Design guides give guidance in respect of waste management and storage. South Wales Police would ask that pre Planning advice is sought in respect of new developments and waste management.
Reason: To enhance community safety especially vulnerable groups.
4. Placemaking and Good Design
Future Wales - The National Plan 2040 (Welsh Government, February 2021)
Policy 2 - Shaping Urban Growth and Regeneration - Strategic Placemaking
The Placemaking Charter and Placemaking Plans:
Signatories to the Charter agree to promote the following principles in the planning, design and management of new and existing places:
• People and community.
• Location.
• Movement.
• Mix of uses.
• Public Realm
• Identity.
SP4 – PLACEMAKING
Development will be required to follow Placemaking principles by:
1 Ensuring high quality sustainable design that reflects local distinctiveness, character, and cultural identity.
2 Prioritising the determinants of health and well-being during the design process.
3 Creating a diverse mix of uses and multi-functional spaces.
4 Contributing to a vibrant, safe and inclusive public realm that encourages Active Travel, supports public transport use and reduces car dependency.
5 Strategically integrating Green Infrastructure networks and open space into development, delivering social, environmental and ecological benefits.
6 Providing a range of housing types and tenure.
7 Locating development appropriately where homes, local services and facilities are accessible and well connected and integrated with existing communities.
8 Developing high densities where appropriate, making the most efficient use of land and supporting mixed uses.
9 Protecting or enhancing the Historic Environment and its setting. Placemaking Statements will be required for all major developments setting out how the proposal accords with Placemaking Principles. In the towns of Barry, Cowbridge, Llantwit Major and Penarth Placemaking Statements should also have regard to the adopted Placemaking Plans for the area.
Designing Out Crime officers’ recommendations:
• SP 4 / PGD 1/ CC 4 - Research shows that Secured by Design developments are sustainable and reduce the carbon footprint. The environmental benefits of SBD are supported by independent academic research consistently proving that SBD housing developments experience up to 87% less burglary, 25% less vehicle crime and 25% less criminal damage It also has a significant impact on anti-social behaviour. South Wales Police ask that all new developments are built to Secured by Design standards and that they are work with The Vale of Glamorgan planning Department at the pre planning stage.
• SP 4 / PGD 1 -When designing developments road, paths and green space, South Wales Police would ask that the developments are built to Secured by Design standards. We would ask that Designing Out Crime Officers and South Wales Police Traffic Management Department are involved in the pre planning stage.
• PGD 2 /SP 4 - It is important when designing roads and footpaths to maximise the benefits of passive surveillance, and furthermore, when addressing safety and security of street layouts, public realm, and footpaths, that Secured by Design guidance is followed, this includes landscape design, lighting, layout of buildings, etc. to ensure that all roads and footpaths (including public rights of way) are safe, secure, and accessible for all, in support of the Violence Against Women and Girls (VAWG) agenda. Where a mix development e.g. housing and retail/other use (with ten or more units) applications should be referred the designing out crime at the pre planning stage.
• SP4/ PGD1 - Contributing to a vibrant, safe and inclusive public realm - Where active travel routes are being planned, South Wales Police Traffic Management Team should be consulted throughout the planning process.
• PGD1- Ensuring no unacceptable impacts on public and residential amenity, particularly regarding privacy, overbearing, security, noise and disturbance. Secured by Design considers natural surveillance and the placing of communal spaces and provision provided. All mixed uses and multi-functional) developments should be discussed at the pre- planning stage with the Designing Out Crime Officer.
• PGD 2/ SP 4 - Developing high densities where appropriate, making the most efficient use of land and supporting mixed uses. Work in partnership with Designing out crime officers to write a ‘Houses of multiple occupancy’ Specific Planning Guidance.
• SP 4 - Strategically integrating Green Infrastructure networks and open space into development, delivering social, environmental and ecological benefits. Where public realm is being planned to include active travel routes, designing out crime officers and Counter Terrorism Security Advisors should be consulted if the space falls under The Terrorism (protection of premises)Act 2025 .
• SP 4 -When planning parks and community space. Public consultation should took place, and the plans referred to the designing out crime officer. (The ‘Safer Parks’ research by Making space for women is a document that can offer up to date advice in relation to safety/ and inclusivity).
• SP 1- When designing new schools early consultation with the South Wales Police Designing out crime officer and Traffic Management officers is prudent to ensure the safety of pupils. Achieving Secured By Design accreditation for the school will ensure that the school is planned and built with safety in mind from the outset. All schools should achieve SBD GOLD.
• HG 6 - The Vale of Glamorgan Older Persons Housing Strategy 2.84 The Council’s Older Persons Housing Strategy ‘Creating Homes and Neighbourhoods for Later Life 2022-2036’ sets out a vision for the Vale of Glamorgan which seeks: ‘to secure the best quality of life for older people to live as independently as possible in later life. This means delivering a range of accommodation that enables older people to live fulfilling lives and enjoy good health in attractive homes that meet their needs and allow them to retain their independence as they age.”
• The Vale of Glamorgan Older Persons Housing Strategy 2.84 The Council’s Older Persons Housing Strategy ‘Creating Homes and Neighbourhoods for Later Life 2022-2036’ sets out a vision for the Vale of Glamorgan which seeks: ‘to secure the best quality of life for older people to live as independently as possible in later life. This means delivering a range of accommodation that enables older people to live fulfilling lives and enjoy good health in attractive homes that meet their needs and allow them to retain their independence as they age.” - Developments, for older residents are built to Secured by Design standards as per the Secured by Design Residential Guide.
• SP4 - Protecting or enhancing the Historic Environment and its setting: Secured by Design can be applied to historic building, contact should be made at the pre planning with the Designing Out Crime Officer.
• PGD1- Creating safe, accessible, integrated, inclusive and active environments that make efficient use of land and promote opportunities for Active Travel, and promote sustainable transport choices – Early liaison with South Wales Police and South Wales Police Traffic Management Officers so that designs can be agreed and are safe.
• SP 1 - A number of new primary and secondary schools have been developed across the Vale as part of the Sustainable Communities for Learning Programme (previously known as 21st Century Schools), with further plans as part of the programme progressing – Consultation should be sought from South Wales Police Designing Out Crime Officers and Road Traffic Management Officers at the pre planning stage planning stage with the Vale of Glamorgan Council.
• PGD 1 Incorporating sustainable design and construction solutions to maximise energy efficiency and positively contributing towards climate change resilience and adaptation. The environmental benefits of SBD are supported by independent academic research consistently proving that SBD housing developments experience up to 87% less burglary, 25% less vehicle crime and 25% less criminal damage (Note 1.5). It also has a significant impact on anti-social behaviour. Therefore, there are substantial carbon cost savings associated with building new homes and refurbishing existing homes to the SBD standard i.e. less replacement of poor-quality doors, windows and the stolen property from within the home as a result of criminal acts. - All developments are built to secured by Design to reduce the carbon footprint.
• PGD1 Ensuring no unacceptable impacts on public and residential amenity, particularly regarding privacy, overbearing, security, noise and disturbance - Facilities shall be designed to allow natural surveillance from nearby dwellings with safe and accessible routes for users to come and go. Boundaries between public and private space shall be clearly defined and open spaces must have features which prevent unauthorised vehicular access. Communal spaces as described above should not immediately abut residential buildings – Consultation with Designing Out Crime Officers and the community should take place at the pre planning stage to develop safe, inclusive spaces.
• C I3/SP13 – NEW COMMUNITY FACILITIES – Consultation should be sought from Designing out crime officers where schools/ colleges are proposed and they should meet Secured by Design Gold.
• Town Centre First SP11 - The town centre of Holton Road in Barry and the District Centre of High Street had higher than average vacant units. There is a need to ensure that future policies allow for flexibility for a greater range of uses that would be acceptable within a town centre, in line with the town centre first principle and the need to create vibrant places. South Wales Police would ask that they are consulted and are able to give advice where policies are developed for town centres. We would also ask that Designing Out Crime Officers are consulted at the pre planning stage.
• PGD1/SP 11 - Making a positive contribution to the character of the area, responding to the local context and character through building forms and scale; materials and features, mix of uses, landscape, density, and connectivity of streets and spaces to create and/or enhance locally distinctive design and character - Designing out crime officers should be consulted at pre planning stage to ensure safe spaces.
• PGD1/SP11/SP13 - Demonstrating that traffic movements to and from the development can be accommodated, resolved, or mitigated to an acceptable degree, and where car parking is provided, this must be sensitivity integrated into the development so that it does not dominate the layout of the development: South Wales Police Traffic Management Department to be consulted by the Vale of Glamorgan Highways Department in respect of road layout/active travel routes at the pre planning stage.
• PGD1- Ensuring that public open space, private amenity space and cycle and car parking in accordance with the Council’s standards – Where Public open space is being designed, the duty from The Terrorism (protection of premises)Act 2025 should be applied where a premises meets the standard as above. South Wales Police Designing out crime officer should be consulted at the pre planning stage to advice.
• SSC 1/ PG 1 - Car parks are designed and built to ‘Park Mark’ standards as per Secured by Design Non – Residential (Commercial)Guide.
• PGD1/CC1/ SP19 – Creating well designed and inclusive facilities - ‘Providing high quality multi-functional green open spaces which can provide a choice and range of activities, including play, that also deliver enhanced biodiversity and flood mitigation and are designed to be resilient to climate change and adaptable overtime.’: Consultation with the community should be sought from the outset. Parks and green spaces must be designed with safety being the key driver especially for vulnerable groups such as women and girls (Safer Parks document). Designing Out Crime Officers should be consulted at the pre planning stage to achieve this.
• PGD1 Ensuring no unacceptable impacts on public and residential amenity, particularly regarding privacy, overbearing, security, noise and disturbance.
(As above)
• PGD1: Demonstrating that traffic movements to and from the development can be accommodated, resolved, or mitigated to an acceptable degree, and where car parking is provided, this must be sensitivity integrated into the development so that it does not dominate the layout of the development – South Wales Police Designing out crime officers and Traffic Management Officers to be consulted on the layout of developments at pre planning stage.
• TR1/SP 10: Future plans for the continued regeneration of the Waterfront include the redevelopment of the Mole for apartments, a linear park and water sports centre – South Wales Police would ask that Designing Out Crime and Road Safety Management Officers are involved where redevelopment is to take place, consultation should be sought at the pre planning stage.
• RC52 – Edge of town centre retailing: South Wales Police would ask that the Designing out crime and traffic management officers are contacted in respect of new developments and the travel routes to them.
• EMP2 - MOD St Athan - New development within or adjoining MOD St Athan that is demonstrated to be required for operational defence and security purposes, and helps enhance or sustain their operational capability, will be supported in principle. – Advice should be sought from Counter Terrorism Wales and Designing Out Crime officers where redevelopment of/ adjacent to MOD St Athan is planned.
• SP15 – Sustainable Tourism: Promoting opportunities for visitors to engage in forms of tourism that have a low impact on the environment; 2 Protecting and enhancing existing tourism attractions and leisure facilities; 3 Enhancing the visitor economy, attracting local investment, providing local employment opportunities and contributing to rural diversification; 4 Recognising and protecting the Vale’s distinct local identity, built and natural environment as assets to tourism; Providing a variety of tourism opportunities, particularly through all year round facilities and a range of appropriately located visitor accommodation; and 6 Encouraging tourism visits to be made by active and sustainable transport modes – Designing Out Crime Officers advice and advice in respect of Crowded Places to be sought at the pre planning state of any event.
• CI4 – Protecting and enhancing existing community facilities: Proposals for new community facilities or proposals which seek to retain, enhance or maintain existing community facilities will be supported. This includes the provision of multi-use community facilities, including the colocation of healthcare, schools, libraries and leisure facilities – South Wales Police would ask that all new community facilities plans are referred to the Designing Out Crime Officer and Counter Terrorism Wales for early consultation.
Reason: To ensure all public realm is safe, espcially for vulnable groups such as women and girls.
5. Protecting and enhancing the natural environment
Ecological Networks and Green Infrastructure
Project Zero - The Vale of Glamorgan Council’s Climate Change Challenge Plan 2021-2030
The Vale of Glamorgan Local Area Energy Plan (2024)
Maximise reduction in carbon emissions across all activity. • Improve efficiency to reduce energy demand.
Work towards new and existing buildings becoming low carbon prioritising inclusivity, equality, and fairness.
The LAEP is a live document which should be updated every 5 years. It identifies the following priority areas that will be the focus in the short term to assist in setting the Vale on the pathway to net zero: • Making homes low carbon.
Crime committed in 2011 in England and Wales is estimated to have given rise to over 4 million tonnes CO2e, equivalent to emissions of around 900,000 UK homes. Burglary resulted in the largest proportion of the total footprint (30%) due to large volume of offences and the carbon associated with replacing stolen or damaged goods.
Source: “Addressing the Carbon-Crime Blind Spot - A Carbon Footprint Approach” (2016). Helen Skudder, Professor Angela Druckman, Jon Cole, Alan McInnes, Dr Ian Brunton-Smith, Dr Gian Paolo Ansalon.
The environmental benefits of SBD are supported by independent academic research consistently proving that SBD housing developments experience up to 87% less burglary, 25% less vehicle crime and 25% less criminal damage (Note 1.5). It also has a significant impact on anti-social behaviour. Therefore, there are substantial carbon cost savings associated with building new homes and refurbishing existing homes to the SBD standard i.e. less replacement of poor-quality doors, windows and the stolen property from within the home as a result of criminal acts. This has been achieved through adherence to well-researched and effective design solutions, innovative and creative product design coupled with robust manufacturing standards.
Research documentation can be found on the SBD website at: https://www.securedbydesign.com
South Wales Police would ask that Designing Out Crime Officers are consulted to work in partnership with the Vale of Glamorgan Council to reduce the carbon emissions through building to Secured by Design Standards.
Policy 12 - Regional Connectivity
A feasibility study for a new station at St Athan was completed in 2022, which identified four potential site locations for a new station to the south of St Athan.
South Wales Police Recommendations:
• SP10 – Sustainable transport - Ensuring that the design of new developments encourage walking, cycling and public transport use as alternatives to private car use, as well as encouraging options such as mobility hubs and shared car use – South Wales Police Traffic Management Department should be consulted to ensure that sustainable transport links are safe. If these links are rail, then the British Transport Police Designing out crime officer should be contacted at the pre planning stage.
• SP16/CC1 – Net zero carbon developments: pre application consultation from South Wales Police and all new developments to meet Secured by Design.
• CI1/CC1/ SP19 – Open Space Provision: Areas of open space will normally be required to be provided on-site as part of new development proposals. Where it is not practical to make provision on-site, appropriate off-site provision or financial contributions for improvements to existing facilities will be required in lieu of on-site play, outdoor sports provision, or amenity greenspace.
• DNP7 – DARK SKIES: Secured by Design can assist with ensuring that the built environment in all forms, is designed to reduce the opportunity of Violence Against Women and Girls (VAWG) and contribute to such places feeling safe, to live, work and socialise. South Wales Police would ask that Designing Out Crime Officers are involved at the pre planning stage with the Highways Department at The Vale of Glamorgan Council and developer to discuss and be able to make recommendations in relation to lighting.

The MOD recommend that any emerging policy makes clear that, where an MOD assessment indicates that a development would have a detrimental impact on the operation and capability of defence assets or sites, that such an application would be refused or that conditions may be attached to any consent that might be issued which may include the removal of permitted development rights.

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

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.”