Utilise Traditional Architecture Design Codes for all new construction with a ban on demolition of all buildings constructed prior to 1950. See my PDF Umbrella Representation for additional Placemaking/ Planning and Greenery Proposals.

Provide reserves for authentic TA such as quarry stone for raw materials to drive down costs effectively for better style construction in-keeping with the are rather than contemporary quickly dating globalist schematics that have arisen from generic CAD Models.

The Policy should be amended to read -

“2 (~Favouring proposals which~) Promote the sustainable use of minerals and encourage the use of secondary and RECYCLED MATERIALS. (~alternative resources~).”

“4 Safeguarding EXISTING AND PLANNED INFRASTRUCTURE, INCLUDING railheads to allow for the potential transportation of minerals by sustainable means and wharf facilities for the landing of marine dredged sand and gravel where appropriate, TOGETHER WITH WIDER MINERALS PROCESSING INFRASTRUCTURE.

The Mineral Products Association (MPA) is the trade association for the aggregates, asphalt, cement, concrete, dimension stone, lime, mortar and industrial sand industries. MPA is the sectoral voice for mineral products, covering 100% of UK cement and lime production, 90% of GB aggregates production, 95% of asphalt and over 60% of ready-mixed concrete and precast concrete production. In 2023, the industry supplied £18.4 billion worth of materials and services to the Economy, directly generating £6.7 billion in Gross Value Added (GVA). It is the largest supplier to the construction industry, which generated £141.5 billion in GVA in 2023. Industry production represents the largest materials flow in the UK economy and is also one of the largest manufacturing sectors. For more information visit: www.mineralproducts.org.

Thank you for consulting us on the above document. Mineral supply will be critical to delivering many of the objectives identified in the preferred strategy as well as many of the national infrastructure project proposed such as floating offshore wind in the Celtic Sea. We have major concerns over the reliance on outdated reserve information and the evidence base must reflect up to date reserve and sales statistics, together with projected demand for major developments.

It is disappointing that despite previous representations in 2022 & 2024, the points highlighted have not been addressed. We have therefore, reiterated our concerns below. We have also suggested alternative wording where appropriate.

We welcome further engagement on this matter to address the concerns.

2.50 Regional Technical Statement for Aggregates (2020) Second Review
We support the reference to the RTS (2nd Review), however, as the authority should be aware, WG has commission a further review (RTS3) which is expected to be published at the end of 2026/early 2027
Note the comment as this will be a material consideration as the plan progresses.

5.35 Barry Docks – ABP Masterplan.
Support - We note ABP’s potential for rare earth processing at the Black Rocks Growth Zone and would support such a proposal.
No further comment

SP17 SUSTAINABLE WASTE MANAGEMENT
Support - We note the proposals to facilitate sustainable waste management facilities on …. operational or non-operational mineral working sites and would support this.
No further comment

SP18 Sustainable Provision of Minerals
The local and regional need for the provision of a continuous supply of minerals will be achieved through:
1 Maintaining a minimum of 10 years land bank of crushed rock throughout the plan period.
2 Favouring proposals which promote the sustainable use of minerals and encourage the use of secondary and alternative resources.
3 The safeguarding of known resources of sandstone, limestone, sand and gravel (where these occur outside settlements), from permanent development that would unnecessarily sterilise them or hinder their future extraction; and
4 Safeguarding railheads to allow for the potential transportation of minerals by sustainable means and wharf facilities for the landing of marine dredged sand and gravel where appropriate.
Object - Whilst we can support various elements in the proposed policy, we have concerns over the specific wording in it and the supporting text.
Most notably, subsection 2 does not accord with the PPW (5.11.4) in relation to the use of secondary and RECYCLED materials. It is not clear what is meant by “ALTERNATIVE RESOURCES”. This should be replaced. Secondly, PPW “PROMOTES THE USE” and does not reference “favouring proposals. Accordingly, the wording should be amended to reflect PPW
Also, in relation to subsection 4, the proposed policy does not seek to apply safeguarding to minerals infrastructure as is required by PPW (5.14.7 & 5.24.8). Minerals infrastructure is more than just transportation hubs, it includes the wider processing facilities. Subsection 4 should therefore be amended.
The Policy should be amended to read -
“2 (~Favouring proposals which~) Promote the sustainable use of minerals and encourage the use of secondary and RECYCLED MATERIALS. (~alternative resources~).”
“4 Safeguarding EXISTING AND PLANNED INFRASTRUCTURE, INCLUDING railheads to allow for the potential transportation of minerals by sustainable means and wharf facilities for the landing of marine dredged sand and gravel where appropriate, TOGETHER WITH WIDER MINERALS PROCESSING INFRASTRUCTURE.
6.373 This paragraph states “The 2nd Review of the Minerals Regional Technical Statement for the South Wales area, commonly referred to as RTS2, was published by the South Wales Regional Aggregates Working Party (SWRAWP) in September 2020. Appendix B of the RTS includes specific recommendations and guidance for each Local Planning Authority.”
While this statement is factual, we suggest an additional sentence to reflect that Welsh Government has commission a further review of the Regional Technical Statement (RTS3) which has already commenced and is scheduled for completion by the end of 2026.
Add additional sentence to reflect RTS3.

6.374 This paragraph states
“In November 2021, the Welsh Government’s Chief Planning Officer issued a Policy Clarification letter to rectify an arithmetical error within the RTS2. The clarification letter indicated that the apportionment for the Vale of Glamorgan is 17.05 million tonnes of crushed rock over 25 years. There is an existing landbank of 18.73 million tonnes of crushed rock (as of 31st December 2016), all of which relates to Carboniferous Limestone. There is no apportionment and no land bank for land-won sand and gravel.”
We have significant concerns that the evidence base for the local plan has not been updated. Whilst RTS2 is undoubtedly material, the statement that “There is an existing landbank of 18.73 million tonnes of crushed rock” is not correct. As stated in the text, this is the landbank as of 31st December 2016. The Council must update its evidence base and provide a landbank figure which reflects the current permitted reserves.
Since the publication of the RTS2, there have been numerous publications to assist in updating the evidence base including the SWRAWP reports and AM2023.
In our responses to earlier iterations and consultations on the RLDP we highlighted the need for the Council to update the reserve figures. We also highlighted that planning submissions had indicated that circa 16.5mt of permitted reserve is suitable for non-aggregate use.
It is not clear if this tonnage is included in the 18.73mt referred too.
Greater clarity and analysis is required.

6.374 The wording also states “The report concludes that in view of the slight surplus of existing permitted crushed rock reserves and the lack of sand and gravel production in the Vale of Glamorgan, no further allocations are specifically required to be identified within the RLDP.”
The “slight surplus” referred to was the position at 31st December 2016. The reserve figure needs to be updated.
Update the reserve figures to allow an accurate landbank tobe determined and the need for future allocations to be properly assessed. This should separate out projected aggregate and non-aggregate reserves to ensure clarity.

6.375 The wording states “The RTS2 requires Statements of Sub-regional Collaboration (SSRC) to be prepared by all constituent LPAs within each RTS sub-region. The Vale of Glamorgan along with Bridgend, Cardiff, Rhondda Cynon Taf, Merthyr Tydfil, Caerphilly and the Brecon Beacons National Park forms part of the Cardiff City subregion. The latest position statement for this sub-region (July 2022) indicates that while most authorities in the region, including the Vale of Glamorgan, can meet their apportionment for crushed rock, there is a shortfall of 7.475 million tonnes (Mt) within Cardiff that would require an additional RLDP allocation.”
Whilst the position statement referred to may suggest that the apportionment can be adequately met, as highlighted above, there are major concerns that the evidence base being relied upon is out of date. Further, Annex A of the RTS requires that “The LPAs involved should demonstrate, as far as possible, that the SSRC has been produced in consultation with relevant stakeholders, including the Regional Aggregate Working Party (RAWP), as part of the LDP process.” This has not been done and as such the SSRC process adopted is fundamentally flawed.
As clearly stated in our previous representations, there are major concerns over the evidence base and the process of relying upon an SSRC which has not followed the requisite protocol.

MIN1 Development in Minerals Safeguarding Areas
Whilst we support the principle of the policy, we suggest the addition of a further subsection addressing the scope for prior extraction. PPW (5.14.7) states “the potential for extraction of mineral resources prior to undertaking other forms of development, have been considered.”
Add a further subsection to address the principle of prior extraction.

MIN2 Quarry Buffer Zones
This policy states “Buffer zones have been identified around mineral working sites. Within the identified buffer zones proposals for new development will only be permitted where it is demonstrated that:
1 The proposal would not constrain the operations of the mineral site; or
(~2 The proposal is located within an existing built-up area which already encroaches into the buffer zone.”~)
Object - Proposed subsection 2 is not an exception to the national buffer zone policy PPW (5.14.44) and should therefore be deleted.
Delete Subsection 2 “Buffer zones have been identified around mineral working sites. Within the identified buffer zones proposals for new development will only be permitted where it is demonstrated that:
1 The proposal would not constrain the operations of the mineral site; or”
2 The proposal is located within an existing built-up area which already encroaches into the buffer zone.”

MIN4 Sustainable Mineral Working.
This policy states
“Proposals which prioritise the use of recycled material and secondary aggregates before new sources of primary materials are developed will be favoured where this does not have an unacceptable effect on amenity or the environment.
Proposals for the extraction of new primary minerals will only be permitted where there is a proven national, regional or local need for the mineral and where:”
Object - This policy wording does not reflect PPW (5.11) which seeks to “promote” and not “prioritise” the use of recycled material and secondary aggregates.
Further the word “only” is superfluous and should be deleted.
Reword the policy
“Proposals which PROMOTE (~prioritise~) the use of recycled material and secondary aggregates AS AN ALTERNATIVE TO (~before new sources of~) primary materials (~are developed~) will be SUPPORTED (~favoured~) where this does not have an unacceptable effect on amenity or the environment.
Proposals for the extraction of new primary minerals will (~only~) be permitted where there is a proven national, regional or local need for the mineral and where:”

6.388 The wording states “In view of the current landbank of reserves with planning permission at existing mineral working sites within the Vale of Glamorgan, there is no requirement for the Plan to allocate additional areas for limestone extraction.”
As stated above, the Evidence Base has not been updated to provide a true representation of the landbank. The permitted reserves being quoted date from 2016 and cannot provide a sound platform upon which mineral provision or requirements can be determined.
Update the evidence as required.

6.389 The wording states “Proposals which prioritise the use of recycled material and secondary aggregates before new sources of primary materials are developed will be favoured. The Council recognises there is a need for a change in the pattern of supply of minerals from primary sources to more sustainable alternatives and that overprovision of primary material as a result of extant permissions and granting new permissions would encourage the unsustainable use of resources. Therefore, the extraction of new primary minerals in addition to the landbank of permitted reserves will normally only be permitted where it can be demonstrated that there is no practicable substitute material which can be provided at less environmental cost and where there is an identified shortfall in reserves which is justified (MTAN1 Paragraph 34).” As stated above, the PPW seeks to promote the use of secondary and recycled aggregates. The council has not provided any evidence that secondary and recycled materials are not being maximised, or that primary materials are being used instead of secondary material. There is simply no evidence of “overprovision”. Further this is a misquote of MTAN1 Paragraph 34.
Amend the text accordingly.
Reword the text “Proposals which (~prioritise~) PROMOTE the use of recycled material and secondary aggregates (~before new sources of~) AS AN ALTERNATIVE TO primary materials (~are developed~) will be SUPPORTED (~favoured~). (~The Council recognises there is a need for a change in the pattern of supply of minerals from primary sources to more sustainable alternatives and that overprovision of primary material as a result of extant permissions and granting new permissions would encourage the unsustainable use of resources. Therefore~), The extraction of new primary minerals in addition to the landbank of permitted reserves will normally only be permitted where it can be demonstrated that there is no practicable substitute material which can be provided at less environmental cost and where there is an identified shortfall in reserves which is justified (~(MTAN1 Paragraph 34)~)

Add additional sentence to paragraph 6.373 to reflect RTS3.

The Mineral Products Association (MPA) is the trade association for the aggregates, asphalt, cement, concrete, dimension stone, lime, mortar and industrial sand industries. MPA is the sectoral voice for mineral products, covering 100% of UK cement and lime production, 90% of GB aggregates production, 95% of asphalt and over 60% of ready-mixed concrete and precast concrete production. In 2023, the industry supplied £18.4 billion worth of materials and services to the Economy, directly generating £6.7 billion in Gross Value Added (GVA). It is the largest supplier to the construction industry, which generated £141.5 billion in GVA in 2023. Industry production represents the largest materials flow in the UK economy and is also one of the largest manufacturing sectors. For more information visit: www.mineralproducts.org.

Thank you for consulting us on the above document. Mineral supply will be critical to delivering many of the objectives identified in the preferred strategy as well as many of the national infrastructure project proposed such as floating offshore wind in the Celtic Sea. We have major concerns over the reliance on outdated reserve information and the evidence base must reflect up to date reserve and sales statistics, together with projected demand for major developments.

It is disappointing that despite previous representations in 2022 & 2024, the points highlighted have not been addressed. We have therefore, reiterated our concerns below. We have also suggested alternative wording where appropriate.

We welcome further engagement on this matter to address the concerns.

2.50 Regional Technical Statement for Aggregates (2020) Second Review
We support the reference to the RTS (2nd Review), however, as the authority should be aware, WG has commission a further review (RTS3) which is expected to be published at the end of 2026/early 2027
Note the comment as this will be a material consideration as the plan progresses.

5.35 Barry Docks – ABP Masterplan.
Support - We note ABP’s potential for rare earth processing at the Black Rocks Growth Zone and would support such a proposal.
No further comment

SP17 SUSTAINABLE WASTE MANAGEMENT
Support - We note the proposals to facilitate sustainable waste management facilities on …. operational or non-operational mineral working sites and would support this.
No further comment

SP18 Sustainable Provision of Minerals
The local and regional need for the provision of a continuous supply of minerals will be achieved through:
1 Maintaining a minimum of 10 years land bank of crushed rock throughout the plan period.
2 Favouring proposals which promote the sustainable use of minerals and encourage the use of secondary and alternative resources.
3 The safeguarding of known resources of sandstone, limestone, sand and gravel (where these occur outside settlements), from permanent development that would unnecessarily sterilise them or hinder their future extraction; and
4 Safeguarding railheads to allow for the potential transportation of minerals by sustainable means and wharf facilities for the landing of marine dredged sand and gravel where appropriate.
Object - Whilst we can support various elements in the proposed policy, we have concerns over the specific wording in it and the supporting text.
Most notably, subsection 2 does not accord with the PPW (5.11.4) in relation to the use of secondary and RECYCLED materials. It is not clear what is meant by “ALTERNATIVE RESOURCES”. This should be replaced. Secondly, PPW “PROMOTES THE USE” and does not reference “favouring proposals. Accordingly, the wording should be amended to reflect PPW
Also, in relation to subsection 4, the proposed policy does not seek to apply safeguarding to minerals infrastructure as is required by PPW (5.14.7 & 5.24.8). Minerals infrastructure is more than just transportation hubs, it includes the wider processing facilities. Subsection 4 should therefore be amended.
The Policy should be amended to read -
“2 (~Favouring proposals which~) Promote the sustainable use of minerals and encourage the use of secondary and RECYCLED MATERIALS. (~alternative resources~).”
“4 Safeguarding EXISTING AND PLANNED INFRASTRUCTURE, INCLUDING railheads to allow for the potential transportation of minerals by sustainable means and wharf facilities for the landing of marine dredged sand and gravel where appropriate, TOGETHER WITH WIDER MINERALS PROCESSING INFRASTRUCTURE.
6.373 This paragraph states “The 2nd Review of the Minerals Regional Technical Statement for the South Wales area, commonly referred to as RTS2, was published by the South Wales Regional Aggregates Working Party (SWRAWP) in September 2020. Appendix B of the RTS includes specific recommendations and guidance for each Local Planning Authority.”
While this statement is factual, we suggest an additional sentence to reflect that Welsh Government has commission a further review of the Regional Technical Statement (RTS3) which has already commenced and is scheduled for completion by the end of 2026.
Add additional sentence to reflect RTS3.

6.374 This paragraph states
“In November 2021, the Welsh Government’s Chief Planning Officer issued a Policy Clarification letter to rectify an arithmetical error within the RTS2. The clarification letter indicated that the apportionment for the Vale of Glamorgan is 17.05 million tonnes of crushed rock over 25 years. There is an existing landbank of 18.73 million tonnes of crushed rock (as of 31st December 2016), all of which relates to Carboniferous Limestone. There is no apportionment and no land bank for land-won sand and gravel.”
We have significant concerns that the evidence base for the local plan has not been updated. Whilst RTS2 is undoubtedly material, the statement that “There is an existing landbank of 18.73 million tonnes of crushed rock” is not correct. As stated in the text, this is the landbank as of 31st December 2016. The Council must update its evidence base and provide a landbank figure which reflects the current permitted reserves.
Since the publication of the RTS2, there have been numerous publications to assist in updating the evidence base including the SWRAWP reports and AM2023.
In our responses to earlier iterations and consultations on the RLDP we highlighted the need for the Council to update the reserve figures. We also highlighted that planning submissions had indicated that circa 16.5mt of permitted reserve is suitable for non-aggregate use.
It is not clear if this tonnage is included in the 18.73mt referred too.
Greater clarity and analysis is required.

6.374 The wording also states “The report concludes that in view of the slight surplus of existing permitted crushed rock reserves and the lack of sand and gravel production in the Vale of Glamorgan, no further allocations are specifically required to be identified within the RLDP.”
The “slight surplus” referred to was the position at 31st December 2016. The reserve figure needs to be updated.
Update the reserve figures to allow an accurate landbank tobe determined and the need for future allocations to be properly assessed. This should separate out projected aggregate and non-aggregate reserves to ensure clarity.

6.375 The wording states “The RTS2 requires Statements of Sub-regional Collaboration (SSRC) to be prepared by all constituent LPAs within each RTS sub-region. The Vale of Glamorgan along with Bridgend, Cardiff, Rhondda Cynon Taf, Merthyr Tydfil, Caerphilly and the Brecon Beacons National Park forms part of the Cardiff City subregion. The latest position statement for this sub-region (July 2022) indicates that while most authorities in the region, including the Vale of Glamorgan, can meet their apportionment for crushed rock, there is a shortfall of 7.475 million tonnes (Mt) within Cardiff that would require an additional RLDP allocation.”
Whilst the position statement referred to may suggest that the apportionment can be adequately met, as highlighted above, there are major concerns that the evidence base being relied upon is out of date. Further, Annex A of the RTS requires that “The LPAs involved should demonstrate, as far as possible, that the SSRC has been produced in consultation with relevant stakeholders, including the Regional Aggregate Working Party (RAWP), as part of the LDP process.” This has not been done and as such the SSRC process adopted is fundamentally flawed.
As clearly stated in our previous representations, there are major concerns over the evidence base and the process of relying upon an SSRC which has not followed the requisite protocol.

MIN1 Development in Minerals Safeguarding Areas
Whilst we support the principle of the policy, we suggest the addition of a further subsection addressing the scope for prior extraction. PPW (5.14.7) states “the potential for extraction of mineral resources prior to undertaking other forms of development, have been considered.”
Add a further subsection to address the principle of prior extraction.

MIN2 Quarry Buffer Zones
This policy states “Buffer zones have been identified around mineral working sites. Within the identified buffer zones proposals for new development will only be permitted where it is demonstrated that:
1 The proposal would not constrain the operations of the mineral site; or
(~2 The proposal is located within an existing built-up area which already encroaches into the buffer zone.”~)
Object - Proposed subsection 2 is not an exception to the national buffer zone policy PPW (5.14.44) and should therefore be deleted.
Delete Subsection 2 “Buffer zones have been identified around mineral working sites. Within the identified buffer zones proposals for new development will only be permitted where it is demonstrated that:
1 The proposal would not constrain the operations of the mineral site; or”
2 The proposal is located within an existing built-up area which already encroaches into the buffer zone.”

MIN4 Sustainable Mineral Working.
This policy states
“Proposals which prioritise the use of recycled material and secondary aggregates before new sources of primary materials are developed will be favoured where this does not have an unacceptable effect on amenity or the environment.
Proposals for the extraction of new primary minerals will only be permitted where there is a proven national, regional or local need for the mineral and where:”
Object - This policy wording does not reflect PPW (5.11) which seeks to “promote” and not “prioritise” the use of recycled material and secondary aggregates.
Further the word “only” is superfluous and should be deleted.
Reword the policy
“Proposals which PROMOTE (~prioritise~) the use of recycled material and secondary aggregates AS AN ALTERNATIVE TO (~before new sources of~) primary materials (~are developed~) will be SUPPORTED (~favoured~) where this does not have an unacceptable effect on amenity or the environment.
Proposals for the extraction of new primary minerals will (~only~) be permitted where there is a proven national, regional or local need for the mineral and where:”

6.388 The wording states “In view of the current landbank of reserves with planning permission at existing mineral working sites within the Vale of Glamorgan, there is no requirement for the Plan to allocate additional areas for limestone extraction.”
As stated above, the Evidence Base has not been updated to provide a true representation of the landbank. The permitted reserves being quoted date from 2016 and cannot provide a sound platform upon which mineral provision or requirements can be determined.
Update the evidence as required.

6.389 The wording states “Proposals which prioritise the use of recycled material and secondary aggregates before new sources of primary materials are developed will be favoured. The Council recognises there is a need for a change in the pattern of supply of minerals from primary sources to more sustainable alternatives and that overprovision of primary material as a result of extant permissions and granting new permissions would encourage the unsustainable use of resources. Therefore, the extraction of new primary minerals in addition to the landbank of permitted reserves will normally only be permitted where it can be demonstrated that there is no practicable substitute material which can be provided at less environmental cost and where there is an identified shortfall in reserves which is justified (MTAN1 Paragraph 34).” As stated above, the PPW seeks to promote the use of secondary and recycled aggregates. The council has not provided any evidence that secondary and recycled materials are not being maximised, or that primary materials are being used instead of secondary material. There is simply no evidence of “overprovision”. Further this is a misquote of MTAN1 Paragraph 34.
Amend the text accordingly.
Reword the text “Proposals which (~prioritise~) PROMOTE the use of recycled material and secondary aggregates (~before new sources of~) AS AN ALTERNATIVE TO primary materials (~are developed~) will be SUPPORTED (~favoured~). (~The Council recognises there is a need for a change in the pattern of supply of minerals from primary sources to more sustainable alternatives and that overprovision of primary material as a result of extant permissions and granting new permissions would encourage the unsustainable use of resources. Therefore~), The extraction of new primary minerals in addition to the landbank of permitted reserves will normally only be permitted where it can be demonstrated that there is no practicable substitute material which can be provided at less environmental cost and where there is an identified shortfall in reserves which is justified (~(MTAN1 Paragraph 34)~)

As stated in the text, this is the landbank as of 31st December 2016. The Council must update its evidence base and provide a landbank figure which reflects the current permitted reserves.

In our responses to earlier iterations and consultations on the RLDP we highlighted the need for the Council to update the reserve figures. We also highlighted that planning submissions had indicated that circa 16.5mt of permitted reserve is suitable for non-aggregate use.
It is not clear if this tonnage is included in the 18.73mt referred too.

Greater clarity and analysis is required.

The Mineral Products Association (MPA) is the trade association for the aggregates, asphalt, cement, concrete, dimension stone, lime, mortar and industrial sand industries. MPA is the sectoral voice for mineral products, covering 100% of UK cement and lime production, 90% of GB aggregates production, 95% of asphalt and over 60% of ready-mixed concrete and precast concrete production. In 2023, the industry supplied £18.4 billion worth of materials and services to the Economy, directly generating £6.7 billion in Gross Value Added (GVA). It is the largest supplier to the construction industry, which generated £141.5 billion in GVA in 2023. Industry production represents the largest materials flow in the UK economy and is also one of the largest manufacturing sectors. For more information visit: www.mineralproducts.org.

Thank you for consulting us on the above document. Mineral supply will be critical to delivering many of the objectives identified in the preferred strategy as well as many of the national infrastructure project proposed such as floating offshore wind in the Celtic Sea. We have major concerns over the reliance on outdated reserve information and the evidence base must reflect up to date reserve and sales statistics, together with projected demand for major developments.

It is disappointing that despite previous representations in 2022 & 2024, the points highlighted have not been addressed. We have therefore, reiterated our concerns below. We have also suggested alternative wording where appropriate.

We welcome further engagement on this matter to address the concerns.

2.50 Regional Technical Statement for Aggregates (2020) Second Review
We support the reference to the RTS (2nd Review), however, as the authority should be aware, WG has commission a further review (RTS3) which is expected to be published at the end of 2026/early 2027
Note the comment as this will be a material consideration as the plan progresses.

5.35 Barry Docks – ABP Masterplan.
Support - We note ABP’s potential for rare earth processing at the Black Rocks Growth Zone and would support such a proposal.
No further comment

SP17 SUSTAINABLE WASTE MANAGEMENT
Support - We note the proposals to facilitate sustainable waste management facilities on …. operational or non-operational mineral working sites and would support this.
No further comment

SP18 Sustainable Provision of Minerals
The local and regional need for the provision of a continuous supply of minerals will be achieved through:
1 Maintaining a minimum of 10 years land bank of crushed rock throughout the plan period.
2 Favouring proposals which promote the sustainable use of minerals and encourage the use of secondary and alternative resources.
3 The safeguarding of known resources of sandstone, limestone, sand and gravel (where these occur outside settlements), from permanent development that would unnecessarily sterilise them or hinder their future extraction; and
4 Safeguarding railheads to allow for the potential transportation of minerals by sustainable means and wharf facilities for the landing of marine dredged sand and gravel where appropriate.
Object - Whilst we can support various elements in the proposed policy, we have concerns over the specific wording in it and the supporting text.
Most notably, subsection 2 does not accord with the PPW (5.11.4) in relation to the use of secondary and RECYCLED materials. It is not clear what is meant by “ALTERNATIVE RESOURCES”. This should be replaced. Secondly, PPW “PROMOTES THE USE” and does not reference “favouring proposals. Accordingly, the wording should be amended to reflect PPW
Also, in relation to subsection 4, the proposed policy does not seek to apply safeguarding to minerals infrastructure as is required by PPW (5.14.7 & 5.24.8). Minerals infrastructure is more than just transportation hubs, it includes the wider processing facilities. Subsection 4 should therefore be amended.
The Policy should be amended to read -
“2 (~Favouring proposals which~) Promote the sustainable use of minerals and encourage the use of secondary and RECYCLED MATERIALS. (~alternative resources~).”
“4 Safeguarding EXISTING AND PLANNED INFRASTRUCTURE, INCLUDING railheads to allow for the potential transportation of minerals by sustainable means and wharf facilities for the landing of marine dredged sand and gravel where appropriate, TOGETHER WITH WIDER MINERALS PROCESSING INFRASTRUCTURE.
6.373 This paragraph states “The 2nd Review of the Minerals Regional Technical Statement for the South Wales area, commonly referred to as RTS2, was published by the South Wales Regional Aggregates Working Party (SWRAWP) in September 2020. Appendix B of the RTS includes specific recommendations and guidance for each Local Planning Authority.”
While this statement is factual, we suggest an additional sentence to reflect that Welsh Government has commission a further review of the Regional Technical Statement (RTS3) which has already commenced and is scheduled for completion by the end of 2026.
Add additional sentence to reflect RTS3.

6.374 This paragraph states
“In November 2021, the Welsh Government’s Chief Planning Officer issued a Policy Clarification letter to rectify an arithmetical error within the RTS2. The clarification letter indicated that the apportionment for the Vale of Glamorgan is 17.05 million tonnes of crushed rock over 25 years. There is an existing landbank of 18.73 million tonnes of crushed rock (as of 31st December 2016), all of which relates to Carboniferous Limestone. There is no apportionment and no land bank for land-won sand and gravel.”
We have significant concerns that the evidence base for the local plan has not been updated. Whilst RTS2 is undoubtedly material, the statement that “There is an existing landbank of 18.73 million tonnes of crushed rock” is not correct. As stated in the text, this is the landbank as of 31st December 2016. The Council must update its evidence base and provide a landbank figure which reflects the current permitted reserves.
Since the publication of the RTS2, there have been numerous publications to assist in updating the evidence base including the SWRAWP reports and AM2023.
In our responses to earlier iterations and consultations on the RLDP we highlighted the need for the Council to update the reserve figures. We also highlighted that planning submissions had indicated that circa 16.5mt of permitted reserve is suitable for non-aggregate use.
It is not clear if this tonnage is included in the 18.73mt referred too.
Greater clarity and analysis is required.

6.374 The wording also states “The report concludes that in view of the slight surplus of existing permitted crushed rock reserves and the lack of sand and gravel production in the Vale of Glamorgan, no further allocations are specifically required to be identified within the RLDP.”
The “slight surplus” referred to was the position at 31st December 2016. The reserve figure needs to be updated.
Update the reserve figures to allow an accurate landbank tobe determined and the need for future allocations to be properly assessed. This should separate out projected aggregate and non-aggregate reserves to ensure clarity.

6.375 The wording states “The RTS2 requires Statements of Sub-regional Collaboration (SSRC) to be prepared by all constituent LPAs within each RTS sub-region. The Vale of Glamorgan along with Bridgend, Cardiff, Rhondda Cynon Taf, Merthyr Tydfil, Caerphilly and the Brecon Beacons National Park forms part of the Cardiff City subregion. The latest position statement for this sub-region (July 2022) indicates that while most authorities in the region, including the Vale of Glamorgan, can meet their apportionment for crushed rock, there is a shortfall of 7.475 million tonnes (Mt) within Cardiff that would require an additional RLDP allocation.”
Whilst the position statement referred to may suggest that the apportionment can be adequately met, as highlighted above, there are major concerns that the evidence base being relied upon is out of date. Further, Annex A of the RTS requires that “The LPAs involved should demonstrate, as far as possible, that the SSRC has been produced in consultation with relevant stakeholders, including the Regional Aggregate Working Party (RAWP), as part of the LDP process.” This has not been done and as such the SSRC process adopted is fundamentally flawed.
As clearly stated in our previous representations, there are major concerns over the evidence base and the process of relying upon an SSRC which has not followed the requisite protocol.

MIN1 Development in Minerals Safeguarding Areas
Whilst we support the principle of the policy, we suggest the addition of a further subsection addressing the scope for prior extraction. PPW (5.14.7) states “the potential for extraction of mineral resources prior to undertaking other forms of development, have been considered.”
Add a further subsection to address the principle of prior extraction.

MIN2 Quarry Buffer Zones
This policy states “Buffer zones have been identified around mineral working sites. Within the identified buffer zones proposals for new development will only be permitted where it is demonstrated that:
1 The proposal would not constrain the operations of the mineral site; or
(~2 The proposal is located within an existing built-up area which already encroaches into the buffer zone.”~)
Object - Proposed subsection 2 is not an exception to the national buffer zone policy PPW (5.14.44) and should therefore be deleted.
Delete Subsection 2 “Buffer zones have been identified around mineral working sites. Within the identified buffer zones proposals for new development will only be permitted where it is demonstrated that:
1 The proposal would not constrain the operations of the mineral site; or”
2 The proposal is located within an existing built-up area which already encroaches into the buffer zone.”

MIN4 Sustainable Mineral Working.
This policy states
“Proposals which prioritise the use of recycled material and secondary aggregates before new sources of primary materials are developed will be favoured where this does not have an unacceptable effect on amenity or the environment.
Proposals for the extraction of new primary minerals will only be permitted where there is a proven national, regional or local need for the mineral and where:”
Object - This policy wording does not reflect PPW (5.11) which seeks to “promote” and not “prioritise” the use of recycled material and secondary aggregates.
Further the word “only” is superfluous and should be deleted.
Reword the policy
“Proposals which PROMOTE (~prioritise~) the use of recycled material and secondary aggregates AS AN ALTERNATIVE TO (~before new sources of~) primary materials (~are developed~) will be SUPPORTED (~favoured~) where this does not have an unacceptable effect on amenity or the environment.
Proposals for the extraction of new primary minerals will (~only~) be permitted where there is a proven national, regional or local need for the mineral and where:”

6.388 The wording states “In view of the current landbank of reserves with planning permission at existing mineral working sites within the Vale of Glamorgan, there is no requirement for the Plan to allocate additional areas for limestone extraction.”
As stated above, the Evidence Base has not been updated to provide a true representation of the landbank. The permitted reserves being quoted date from 2016 and cannot provide a sound platform upon which mineral provision or requirements can be determined.
Update the evidence as required.

6.389 The wording states “Proposals which prioritise the use of recycled material and secondary aggregates before new sources of primary materials are developed will be favoured. The Council recognises there is a need for a change in the pattern of supply of minerals from primary sources to more sustainable alternatives and that overprovision of primary material as a result of extant permissions and granting new permissions would encourage the unsustainable use of resources. Therefore, the extraction of new primary minerals in addition to the landbank of permitted reserves will normally only be permitted where it can be demonstrated that there is no practicable substitute material which can be provided at less environmental cost and where there is an identified shortfall in reserves which is justified (MTAN1 Paragraph 34).” As stated above, the PPW seeks to promote the use of secondary and recycled aggregates. The council has not provided any evidence that secondary and recycled materials are not being maximised, or that primary materials are being used instead of secondary material. There is simply no evidence of “overprovision”. Further this is a misquote of MTAN1 Paragraph 34.
Amend the text accordingly.
Reword the text “Proposals which (~prioritise~) PROMOTE the use of recycled material and secondary aggregates (~before new sources of~) AS AN ALTERNATIVE TO primary materials (~are developed~) will be SUPPORTED (~favoured~). (~The Council recognises there is a need for a change in the pattern of supply of minerals from primary sources to more sustainable alternatives and that overprovision of primary material as a result of extant permissions and granting new permissions would encourage the unsustainable use of resources. Therefore~), The extraction of new primary minerals in addition to the landbank of permitted reserves will normally only be permitted where it can be demonstrated that there is no practicable substitute material which can be provided at less environmental cost and where there is an identified shortfall in reserves which is justified (~(MTAN1 Paragraph 34)~)

The slight surplus referred to was the position at 31st December 2016. The reserve figure needs to be updated.

Update the reserve figures to allow an accurate landbank to be determined and the need for future allocations to be properly assessed. This should separate out projected aggregate and non-aggregate reserves to ensure clarity.

The Mineral Products Association (MPA) is the trade association for the aggregates, asphalt, cement, concrete, dimension stone, lime, mortar and industrial sand industries. MPA is the sectoral voice for mineral products, covering 100% of UK cement and lime production, 90% of GB aggregates production, 95% of asphalt and over 60% of ready-mixed concrete and precast concrete production. In 2023, the industry supplied £18.4 billion worth of materials and services to the Economy, directly generating £6.7 billion in Gross Value Added (GVA). It is the largest supplier to the construction industry, which generated £141.5 billion in GVA in 2023. Industry production represents the largest materials flow in the UK economy and is also one of the largest manufacturing sectors. For more information visit: www.mineralproducts.org.

Thank you for consulting us on the above document. Mineral supply will be critical to delivering many of the objectives identified in the preferred strategy as well as many of the national infrastructure project proposed such as floating offshore wind in the Celtic Sea. We have major concerns over the reliance on outdated reserve information and the evidence base must reflect up to date reserve and sales statistics, together with projected demand for major developments.

It is disappointing that despite previous representations in 2022 & 2024, the points highlighted have not been addressed. We have therefore, reiterated our concerns below. We have also suggested alternative wording where appropriate.

We welcome further engagement on this matter to address the concerns.

2.50 Regional Technical Statement for Aggregates (2020) Second Review
We support the reference to the RTS (2nd Review), however, as the authority should be aware, WG has commission a further review (RTS3) which is expected to be published at the end of 2026/early 2027
Note the comment as this will be a material consideration as the plan progresses.

5.35 Barry Docks – ABP Masterplan.
Support - We note ABP’s potential for rare earth processing at the Black Rocks Growth Zone and would support such a proposal.
No further comment

SP17 SUSTAINABLE WASTE MANAGEMENT
Support - We note the proposals to facilitate sustainable waste management facilities on …. operational or non-operational mineral working sites and would support this.
No further comment

SP18 Sustainable Provision of Minerals
The local and regional need for the provision of a continuous supply of minerals will be achieved through:
1 Maintaining a minimum of 10 years land bank of crushed rock throughout the plan period.
2 Favouring proposals which promote the sustainable use of minerals and encourage the use of secondary and alternative resources.
3 The safeguarding of known resources of sandstone, limestone, sand and gravel (where these occur outside settlements), from permanent development that would unnecessarily sterilise them or hinder their future extraction; and
4 Safeguarding railheads to allow for the potential transportation of minerals by sustainable means and wharf facilities for the landing of marine dredged sand and gravel where appropriate.
Object - Whilst we can support various elements in the proposed policy, we have concerns over the specific wording in it and the supporting text.
Most notably, subsection 2 does not accord with the PPW (5.11.4) in relation to the use of secondary and RECYCLED materials. It is not clear what is meant by “ALTERNATIVE RESOURCES”. This should be replaced. Secondly, PPW “PROMOTES THE USE” and does not reference “favouring proposals. Accordingly, the wording should be amended to reflect PPW
Also, in relation to subsection 4, the proposed policy does not seek to apply safeguarding to minerals infrastructure as is required by PPW (5.14.7 & 5.24.8). Minerals infrastructure is more than just transportation hubs, it includes the wider processing facilities. Subsection 4 should therefore be amended.
The Policy should be amended to read -
“2 (~Favouring proposals which~) Promote the sustainable use of minerals and encourage the use of secondary and RECYCLED MATERIALS. (~alternative resources~).”
“4 Safeguarding EXISTING AND PLANNED INFRASTRUCTURE, INCLUDING railheads to allow for the potential transportation of minerals by sustainable means and wharf facilities for the landing of marine dredged sand and gravel where appropriate, TOGETHER WITH WIDER MINERALS PROCESSING INFRASTRUCTURE.
6.373 This paragraph states “The 2nd Review of the Minerals Regional Technical Statement for the South Wales area, commonly referred to as RTS2, was published by the South Wales Regional Aggregates Working Party (SWRAWP) in September 2020. Appendix B of the RTS includes specific recommendations and guidance for each Local Planning Authority.”
While this statement is factual, we suggest an additional sentence to reflect that Welsh Government has commission a further review of the Regional Technical Statement (RTS3) which has already commenced and is scheduled for completion by the end of 2026.
Add additional sentence to reflect RTS3.

6.374 This paragraph states
“In November 2021, the Welsh Government’s Chief Planning Officer issued a Policy Clarification letter to rectify an arithmetical error within the RTS2. The clarification letter indicated that the apportionment for the Vale of Glamorgan is 17.05 million tonnes of crushed rock over 25 years. There is an existing landbank of 18.73 million tonnes of crushed rock (as of 31st December 2016), all of which relates to Carboniferous Limestone. There is no apportionment and no land bank for land-won sand and gravel.”
We have significant concerns that the evidence base for the local plan has not been updated. Whilst RTS2 is undoubtedly material, the statement that “There is an existing landbank of 18.73 million tonnes of crushed rock” is not correct. As stated in the text, this is the landbank as of 31st December 2016. The Council must update its evidence base and provide a landbank figure which reflects the current permitted reserves.
Since the publication of the RTS2, there have been numerous publications to assist in updating the evidence base including the SWRAWP reports and AM2023.
In our responses to earlier iterations and consultations on the RLDP we highlighted the need for the Council to update the reserve figures. We also highlighted that planning submissions had indicated that circa 16.5mt of permitted reserve is suitable for non-aggregate use.
It is not clear if this tonnage is included in the 18.73mt referred too.
Greater clarity and analysis is required.

6.374 The wording also states “The report concludes that in view of the slight surplus of existing permitted crushed rock reserves and the lack of sand and gravel production in the Vale of Glamorgan, no further allocations are specifically required to be identified within the RLDP.”
The “slight surplus” referred to was the position at 31st December 2016. The reserve figure needs to be updated.
Update the reserve figures to allow an accurate landbank tobe determined and the need for future allocations to be properly assessed. This should separate out projected aggregate and non-aggregate reserves to ensure clarity.

6.375 The wording states “The RTS2 requires Statements of Sub-regional Collaboration (SSRC) to be prepared by all constituent LPAs within each RTS sub-region. The Vale of Glamorgan along with Bridgend, Cardiff, Rhondda Cynon Taf, Merthyr Tydfil, Caerphilly and the Brecon Beacons National Park forms part of the Cardiff City subregion. The latest position statement for this sub-region (July 2022) indicates that while most authorities in the region, including the Vale of Glamorgan, can meet their apportionment for crushed rock, there is a shortfall of 7.475 million tonnes (Mt) within Cardiff that would require an additional RLDP allocation.”
Whilst the position statement referred to may suggest that the apportionment can be adequately met, as highlighted above, there are major concerns that the evidence base being relied upon is out of date. Further, Annex A of the RTS requires that “The LPAs involved should demonstrate, as far as possible, that the SSRC has been produced in consultation with relevant stakeholders, including the Regional Aggregate Working Party (RAWP), as part of the LDP process.” This has not been done and as such the SSRC process adopted is fundamentally flawed.
As clearly stated in our previous representations, there are major concerns over the evidence base and the process of relying upon an SSRC which has not followed the requisite protocol.

MIN1 Development in Minerals Safeguarding Areas
Whilst we support the principle of the policy, we suggest the addition of a further subsection addressing the scope for prior extraction. PPW (5.14.7) states “the potential for extraction of mineral resources prior to undertaking other forms of development, have been considered.”
Add a further subsection to address the principle of prior extraction.

MIN2 Quarry Buffer Zones
This policy states “Buffer zones have been identified around mineral working sites. Within the identified buffer zones proposals for new development will only be permitted where it is demonstrated that:
1 The proposal would not constrain the operations of the mineral site; or
(~2 The proposal is located within an existing built-up area which already encroaches into the buffer zone.”~)
Object - Proposed subsection 2 is not an exception to the national buffer zone policy PPW (5.14.44) and should therefore be deleted.
Delete Subsection 2 “Buffer zones have been identified around mineral working sites. Within the identified buffer zones proposals for new development will only be permitted where it is demonstrated that:
1 The proposal would not constrain the operations of the mineral site; or”
2 The proposal is located within an existing built-up area which already encroaches into the buffer zone.”

MIN4 Sustainable Mineral Working.
This policy states
“Proposals which prioritise the use of recycled material and secondary aggregates before new sources of primary materials are developed will be favoured where this does not have an unacceptable effect on amenity or the environment.
Proposals for the extraction of new primary minerals will only be permitted where there is a proven national, regional or local need for the mineral and where:”
Object - This policy wording does not reflect PPW (5.11) which seeks to “promote” and not “prioritise” the use of recycled material and secondary aggregates.
Further the word “only” is superfluous and should be deleted.
Reword the policy
“Proposals which PROMOTE (~prioritise~) the use of recycled material and secondary aggregates AS AN ALTERNATIVE TO (~before new sources of~) primary materials (~are developed~) will be SUPPORTED (~favoured~) where this does not have an unacceptable effect on amenity or the environment.
Proposals for the extraction of new primary minerals will (~only~) be permitted where there is a proven national, regional or local need for the mineral and where:”

6.388 The wording states “In view of the current landbank of reserves with planning permission at existing mineral working sites within the Vale of Glamorgan, there is no requirement for the Plan to allocate additional areas for limestone extraction.”
As stated above, the Evidence Base has not been updated to provide a true representation of the landbank. The permitted reserves being quoted date from 2016 and cannot provide a sound platform upon which mineral provision or requirements can be determined.
Update the evidence as required.

6.389 The wording states “Proposals which prioritise the use of recycled material and secondary aggregates before new sources of primary materials are developed will be favoured. The Council recognises there is a need for a change in the pattern of supply of minerals from primary sources to more sustainable alternatives and that overprovision of primary material as a result of extant permissions and granting new permissions would encourage the unsustainable use of resources. Therefore, the extraction of new primary minerals in addition to the landbank of permitted reserves will normally only be permitted where it can be demonstrated that there is no practicable substitute material which can be provided at less environmental cost and where there is an identified shortfall in reserves which is justified (MTAN1 Paragraph 34).” As stated above, the PPW seeks to promote the use of secondary and recycled aggregates. The council has not provided any evidence that secondary and recycled materials are not being maximised, or that primary materials are being used instead of secondary material. There is simply no evidence of “overprovision”. Further this is a misquote of MTAN1 Paragraph 34.
Amend the text accordingly.
Reword the text “Proposals which (~prioritise~) PROMOTE the use of recycled material and secondary aggregates (~before new sources of~) AS AN ALTERNATIVE TO primary materials (~are developed~) will be SUPPORTED (~favoured~). (~The Council recognises there is a need for a change in the pattern of supply of minerals from primary sources to more sustainable alternatives and that overprovision of primary material as a result of extant permissions and granting new permissions would encourage the unsustainable use of resources. Therefore~), The extraction of new primary minerals in addition to the landbank of permitted reserves will normally only be permitted where it can be demonstrated that there is no practicable substitute material which can be provided at less environmental cost and where there is an identified shortfall in reserves which is justified (~(MTAN1 Paragraph 34)~)

There are major concerns over the evidence base and the process of relying upon an SSRC which has not followed the requisite protocol.

The Mineral Products Association (MPA) is the trade association for the aggregates, asphalt, cement, concrete, dimension stone, lime, mortar and industrial sand industries. MPA is the sectoral voice for mineral products, covering 100% of UK cement and lime production, 90% of GB aggregates production, 95% of asphalt and over 60% of ready-mixed concrete and precast concrete production. In 2023, the industry supplied £18.4 billion worth of materials and services to the Economy, directly generating £6.7 billion in Gross Value Added (GVA). It is the largest supplier to the construction industry, which generated £141.5 billion in GVA in 2023. Industry production represents the largest materials flow in the UK economy and is also one of the largest manufacturing sectors. For more information visit: www.mineralproducts.org.

Thank you for consulting us on the above document. Mineral supply will be critical to delivering many of the objectives identified in the preferred strategy as well as many of the national infrastructure project proposed such as floating offshore wind in the Celtic Sea. We have major concerns over the reliance on outdated reserve information and the evidence base must reflect up to date reserve and sales statistics, together with projected demand for major developments.

It is disappointing that despite previous representations in 2022 & 2024, the points highlighted have not been addressed. We have therefore, reiterated our concerns below. We have also suggested alternative wording where appropriate.

We welcome further engagement on this matter to address the concerns.

2.50 Regional Technical Statement for Aggregates (2020) Second Review
We support the reference to the RTS (2nd Review), however, as the authority should be aware, WG has commission a further review (RTS3) which is expected to be published at the end of 2026/early 2027
Note the comment as this will be a material consideration as the plan progresses.

5.35 Barry Docks – ABP Masterplan.
Support - We note ABP’s potential for rare earth processing at the Black Rocks Growth Zone and would support such a proposal.
No further comment

SP17 SUSTAINABLE WASTE MANAGEMENT
Support - We note the proposals to facilitate sustainable waste management facilities on …. operational or non-operational mineral working sites and would support this.
No further comment

SP18 Sustainable Provision of Minerals
The local and regional need for the provision of a continuous supply of minerals will be achieved through:
1 Maintaining a minimum of 10 years land bank of crushed rock throughout the plan period.
2 Favouring proposals which promote the sustainable use of minerals and encourage the use of secondary and alternative resources.
3 The safeguarding of known resources of sandstone, limestone, sand and gravel (where these occur outside settlements), from permanent development that would unnecessarily sterilise them or hinder their future extraction; and
4 Safeguarding railheads to allow for the potential transportation of minerals by sustainable means and wharf facilities for the landing of marine dredged sand and gravel where appropriate.
Object - Whilst we can support various elements in the proposed policy, we have concerns over the specific wording in it and the supporting text.
Most notably, subsection 2 does not accord with the PPW (5.11.4) in relation to the use of secondary and RECYCLED materials. It is not clear what is meant by “ALTERNATIVE RESOURCES”. This should be replaced. Secondly, PPW “PROMOTES THE USE” and does not reference “favouring proposals. Accordingly, the wording should be amended to reflect PPW
Also, in relation to subsection 4, the proposed policy does not seek to apply safeguarding to minerals infrastructure as is required by PPW (5.14.7 & 5.24.8). Minerals infrastructure is more than just transportation hubs, it includes the wider processing facilities. Subsection 4 should therefore be amended.
The Policy should be amended to read -
“2 (~Favouring proposals which~) Promote the sustainable use of minerals and encourage the use of secondary and RECYCLED MATERIALS. (~alternative resources~).”
“4 Safeguarding EXISTING AND PLANNED INFRASTRUCTURE, INCLUDING railheads to allow for the potential transportation of minerals by sustainable means and wharf facilities for the landing of marine dredged sand and gravel where appropriate, TOGETHER WITH WIDER MINERALS PROCESSING INFRASTRUCTURE.
6.373 This paragraph states “The 2nd Review of the Minerals Regional Technical Statement for the South Wales area, commonly referred to as RTS2, was published by the South Wales Regional Aggregates Working Party (SWRAWP) in September 2020. Appendix B of the RTS includes specific recommendations and guidance for each Local Planning Authority.”
While this statement is factual, we suggest an additional sentence to reflect that Welsh Government has commission a further review of the Regional Technical Statement (RTS3) which has already commenced and is scheduled for completion by the end of 2026.
Add additional sentence to reflect RTS3.

6.374 This paragraph states
“In November 2021, the Welsh Government’s Chief Planning Officer issued a Policy Clarification letter to rectify an arithmetical error within the RTS2. The clarification letter indicated that the apportionment for the Vale of Glamorgan is 17.05 million tonnes of crushed rock over 25 years. There is an existing landbank of 18.73 million tonnes of crushed rock (as of 31st December 2016), all of which relates to Carboniferous Limestone. There is no apportionment and no land bank for land-won sand and gravel.”
We have significant concerns that the evidence base for the local plan has not been updated. Whilst RTS2 is undoubtedly material, the statement that “There is an existing landbank of 18.73 million tonnes of crushed rock” is not correct. As stated in the text, this is the landbank as of 31st December 2016. The Council must update its evidence base and provide a landbank figure which reflects the current permitted reserves.
Since the publication of the RTS2, there have been numerous publications to assist in updating the evidence base including the SWRAWP reports and AM2023.
In our responses to earlier iterations and consultations on the RLDP we highlighted the need for the Council to update the reserve figures. We also highlighted that planning submissions had indicated that circa 16.5mt of permitted reserve is suitable for non-aggregate use.
It is not clear if this tonnage is included in the 18.73mt referred too.
Greater clarity and analysis is required.

6.374 The wording also states “The report concludes that in view of the slight surplus of existing permitted crushed rock reserves and the lack of sand and gravel production in the Vale of Glamorgan, no further allocations are specifically required to be identified within the RLDP.”
The “slight surplus” referred to was the position at 31st December 2016. The reserve figure needs to be updated.
Update the reserve figures to allow an accurate landbank tobe determined and the need for future allocations to be properly assessed. This should separate out projected aggregate and non-aggregate reserves to ensure clarity.

6.375 The wording states “The RTS2 requires Statements of Sub-regional Collaboration (SSRC) to be prepared by all constituent LPAs within each RTS sub-region. The Vale of Glamorgan along with Bridgend, Cardiff, Rhondda Cynon Taf, Merthyr Tydfil, Caerphilly and the Brecon Beacons National Park forms part of the Cardiff City subregion. The latest position statement for this sub-region (July 2022) indicates that while most authorities in the region, including the Vale of Glamorgan, can meet their apportionment for crushed rock, there is a shortfall of 7.475 million tonnes (Mt) within Cardiff that would require an additional RLDP allocation.”
Whilst the position statement referred to may suggest that the apportionment can be adequately met, as highlighted above, there are major concerns that the evidence base being relied upon is out of date. Further, Annex A of the RTS requires that “The LPAs involved should demonstrate, as far as possible, that the SSRC has been produced in consultation with relevant stakeholders, including the Regional Aggregate Working Party (RAWP), as part of the LDP process.” This has not been done and as such the SSRC process adopted is fundamentally flawed.
As clearly stated in our previous representations, there are major concerns over the evidence base and the process of relying upon an SSRC which has not followed the requisite protocol.

MIN1 Development in Minerals Safeguarding Areas
Whilst we support the principle of the policy, we suggest the addition of a further subsection addressing the scope for prior extraction. PPW (5.14.7) states “the potential for extraction of mineral resources prior to undertaking other forms of development, have been considered.”
Add a further subsection to address the principle of prior extraction.

MIN2 Quarry Buffer Zones
This policy states “Buffer zones have been identified around mineral working sites. Within the identified buffer zones proposals for new development will only be permitted where it is demonstrated that:
1 The proposal would not constrain the operations of the mineral site; or
(~2 The proposal is located within an existing built-up area which already encroaches into the buffer zone.”~)
Object - Proposed subsection 2 is not an exception to the national buffer zone policy PPW (5.14.44) and should therefore be deleted.
Delete Subsection 2 “Buffer zones have been identified around mineral working sites. Within the identified buffer zones proposals for new development will only be permitted where it is demonstrated that:
1 The proposal would not constrain the operations of the mineral site; or”
2 The proposal is located within an existing built-up area which already encroaches into the buffer zone.”

MIN4 Sustainable Mineral Working.
This policy states
“Proposals which prioritise the use of recycled material and secondary aggregates before new sources of primary materials are developed will be favoured where this does not have an unacceptable effect on amenity or the environment.
Proposals for the extraction of new primary minerals will only be permitted where there is a proven national, regional or local need for the mineral and where:”
Object - This policy wording does not reflect PPW (5.11) which seeks to “promote” and not “prioritise” the use of recycled material and secondary aggregates.
Further the word “only” is superfluous and should be deleted.
Reword the policy
“Proposals which PROMOTE (~prioritise~) the use of recycled material and secondary aggregates AS AN ALTERNATIVE TO (~before new sources of~) primary materials (~are developed~) will be SUPPORTED (~favoured~) where this does not have an unacceptable effect on amenity or the environment.
Proposals for the extraction of new primary minerals will (~only~) be permitted where there is a proven national, regional or local need for the mineral and where:”

6.388 The wording states “In view of the current landbank of reserves with planning permission at existing mineral working sites within the Vale of Glamorgan, there is no requirement for the Plan to allocate additional areas for limestone extraction.”
As stated above, the Evidence Base has not been updated to provide a true representation of the landbank. The permitted reserves being quoted date from 2016 and cannot provide a sound platform upon which mineral provision or requirements can be determined.
Update the evidence as required.

6.389 The wording states “Proposals which prioritise the use of recycled material and secondary aggregates before new sources of primary materials are developed will be favoured. The Council recognises there is a need for a change in the pattern of supply of minerals from primary sources to more sustainable alternatives and that overprovision of primary material as a result of extant permissions and granting new permissions would encourage the unsustainable use of resources. Therefore, the extraction of new primary minerals in addition to the landbank of permitted reserves will normally only be permitted where it can be demonstrated that there is no practicable substitute material which can be provided at less environmental cost and where there is an identified shortfall in reserves which is justified (MTAN1 Paragraph 34).” As stated above, the PPW seeks to promote the use of secondary and recycled aggregates. The council has not provided any evidence that secondary and recycled materials are not being maximised, or that primary materials are being used instead of secondary material. There is simply no evidence of “overprovision”. Further this is a misquote of MTAN1 Paragraph 34.
Amend the text accordingly.
Reword the text “Proposals which (~prioritise~) PROMOTE the use of recycled material and secondary aggregates (~before new sources of~) AS AN ALTERNATIVE TO primary materials (~are developed~) will be SUPPORTED (~favoured~). (~The Council recognises there is a need for a change in the pattern of supply of minerals from primary sources to more sustainable alternatives and that overprovision of primary material as a result of extant permissions and granting new permissions would encourage the unsustainable use of resources. Therefore~), The extraction of new primary minerals in addition to the landbank of permitted reserves will normally only be permitted where it can be demonstrated that there is no practicable substitute material which can be provided at less environmental cost and where there is an identified shortfall in reserves which is justified (~(MTAN1 Paragraph 34)~)

REPRESENTATIONS TO THE DEPOSIT VALE OF GLAMORGAN REPLACEMENT LOCAL DEVELOPMENT
PLAN 2021–2036 ON BEHALF OF SETH HILL AND SON LTD
1. Introduction
These representations are submitted on behalf of Seth Hill & Son Ltd in response to the Deposit Vale
of Glamorgan Replacement Local Development Plan 2021–2036.
They relate specifically to the treatment of Pant-y-Ffynnon Quarry / Seth Hill Quarry, Bonvilston in the
Deposit Plan and the associated candidate site assessment process.
The principal concern arises from the Council’s candidate site assessment, which states that a positive
allocation for mineral working is not included because “The 2nd Review of the Minerals Regional
Technical Statement indicates no further allocations are specifically required to be identified within
the Vale of Glamorgan RLDP.”
That explanation addresses only the narrow issue of whether a fresh minerals allocation is presently
required on RTS2 arithmetic. It does not adequately address the planning merits of Pant-y-Ffynnon
Quarry itself, nor does it justify a limited or negative treatment of the site in the Deposit RLDP.
These representations therefore object to the overly narrow basis on which the site appears to have
been discounted for positive recognition and seek a more balanced and evidence-based treatment of
Pant-y-Ffynnon Quarry within the Plan.
2. Site context
Pant-y-Ffynnon Quarry is an established quarrying location with an existing mineral planning history
and an established role within the local minerals framework.
The candidate site planning statement explains that the site comprises the full extent of the currently
consented Ffynnon Quarry, together with adjoining land to the south. It confirms that the quarry
extracts limestone and that the consented quarry element is identified in the adopted LDP as a Quarry
Site, with adjoining land within the Buffer Zone and wider Mineral Safeguarding Area. The submission
sought to retain the existing LDP status of the consented element and to safeguard the potential for
further quarrying to take place on the remainder of the site in the longer term.
The candidate site statement also recorded the continuing active planning context at the site, including
application ref. 2021/01379/FUL for the resumption of limestone extraction in the North Quarry, the
establishment of an aggregates recycling facility, and restoration of the North Quarry using inert
waste materials. That position has since been materially reinforced by the ROMP determination.
Decision notice 2024/00246/ENV is a Determination of New Working Conditions for Pantyffynnon
Quarry / Seth Hill Quarry, Bonvilston. The decision provides that the new conditions replace those
attached to permissions 97/01084/FUL and 2009/00184/ENV. Condition 1 states that “No operations
authorised by this permission, with the exception of restoration and after-treatment works approved
under these conditions shall take place after 21 February 2042.” The decision also requires a detailed
working scheme, revised working programmes every five years, and imposes an annual production
limit of 250,000 tonnes.
BP25 independently corroborates the continuing active status of the quarry. It identifies Pantyffynnon
in Table 1 as an active quarry with an extraction end date of 21.02.2042. BP25 also confirms that the
Vale of Glamorgan is an “important supplier of Carboniferous limestone for general aggregate use”.
Taken together, that evidence confirms that the site is not simply a historic quarry with uncertain
prospects. It is an active quarry with a recently updated modern conditions framework and an
extraction end date beyond the RLDP period.
3. Objection to the candidate site assessment
The Council’s candidate site assessment relies on the proposition that no further allocations are
specifically required because of the RTS2 position. That reasoning is too narrow.
The statement that no further allocations are specifically required may explain why the Council has
concluded that it does not presently need to identify a fresh minerals allocation in order to meet the
current quantitative apportionment. It does not, however, address the separate issue of how the Plan
should treat an existing quarry site such as Pant-y-Ffynnon Quarry.
The absence of a current need for a new allocation is not the same as a conclusion that an established
quarry site should cease to be positively recognised, should no longer be meaningfully safeguarded,
or should be treated as strategically unimportant.
The candidate site submission itself demonstrates why the Council’s reasoning is incomplete. The
submission did not merely seek a fresh allocation on the basis of additional tonnage need. It sought
retention of the existing quarry status of the consented element and safeguarding of the wider site for
longer-term quarrying potential.
The ROMP decision strengthens that point considerably. A site that has recently been granted updated
mineral working conditions and is authorised to continue operations until 21 February 2042 cannot
sensibly be treated as though its future role is immaterial simply because current RTS2 figures do not
require a further allocation elsewhere in the Vale.
The Council’s approach is also difficult to reconcile with national plan-making guidance. The
Development Plans Manual states that plans should be based on “robust evidence” so they can be
delivered, that candidate sites should not be purposefully excluded from assessment, and that the key
objective is whether a promoter has a serious intention to bring the site forward, which links directly
to the soundness question “Will the plan deliver?”
In those circumstances, the candidate site assessment appears to conflate two distinct questions:
whether a new specific allocation is numerically required under RTS2, and whether an established
quarry site should continue to be positively recognised and safeguarded in the Plan. Those questions
are not the same. The former may currently be answered in the negative. The latter, in the case of
Pant-y-Ffynnon Quarry, should plainly be answered in the affirmative.
4. National and local policy context
The wider policy and evidence framework supports a more positive treatment of Pant-y-Ffynnon
Quarry than is reflected in the candidate site assessment.
PPW states that it is in the interests of the minerals industry that landbanks reflect “real possibilities
for future mineral working” and adds that authorities should provide “a clear guide to where nonenergy
mineral extraction is likely to be acceptable”.
MTAN1 explains that development plans should identify “dormant reserves” separately and states that
“A more realistic landbank assessment is the aim of this process” so that a more accurate picture
emerges of reserves “that are likely to have real potential for future working”. It also states that the
future landbank should include land specifically allocated for the working of aggregates as an
“extended landbank”.
The SWRAWP RTS reinforces the point that reserve arithmetic is not the whole picture. It states that
“Caution must be exercised in using these landbank figures” because the calculation does not take
account of geographical or operational aspects, changes in planning policy, protected site
designations or other permitting constraints. This is particularly relevant given the increasingly
important role of NRW licensing and abstraction controls, including quarry dewatering considerations,
which may mean that some reserves are no longer as readily available or economically viable as
historic landbank figures imply. Accordingly, apparent reserve sufficiency in quantitative terms may overstate the extent of genuinely deliverable supply. SWRAWP also confirms that dormant reserves
“must be counted separately”.
The Deposit RLDP’s own framework is consistent with that broader policy approach. The Plan
safeguards known limestone resources and retains quarry buffer zones so that incompatible
development does not prejudice mineral operations or future working. BP25 explains that the RLDP
safeguards finite mineral resources for future generations and protects them from permanent
development that could sterilise or hinder extraction.
The Plan also provides a detailed framework for sustainable mineral working, including new workings,
extensions and the reworking or reopening of old workings. That mechanism is intended to deal with
the detailed merits of mineral proposals, including environmental effects, amenity, hydrology,
transport and restoration. There is therefore no sound policy basis for adopting an unduly negative
position toward Pant-y-Ffynnon Quarry at plan-making stage simply because no fresh allocation is
currently required.
5. Benefits of continued extraction at Pant-y-Ffynnon Quarry
Continued extraction at Pant-y-Ffynnon Quarry would give rise to a number of important site-specific
and strategic benefits.
PPW expressly recognises the planning advantages of extending established quarry sites. Paragraph
5.14.48 states that “The presence of an existing quarry should be a material consideration when
considering a proposal for an extension. There may be benefits to extending a site in terms of shared
infrastructure, for instance, as opposed to working a new greenfield site.” That principle is directly
relevant to Pant-y-Ffynnon Quarry. The site is an existing quarrying location with an established
operational and planning context, and any continued working or extension would be able to build upon
that existing quarrying footprint, associated infrastructure and minerals land use relationship. In
planning terms, that is materially preferable to directing future working to an entirely new greenfield
location, and it reinforces the case for the Deposit RLDP to continue to recognise the site positively
within the minerals strategy rather than treating it as strategically unimportant simply because no
fresh allocation is currently required.
The site is an existing quarrying location with an established mineral planning history. Continued
extraction would therefore amount to the continuation and proper management of an existing
quarrying use rather than the introduction of mineral development into a wholly new location. That is
a material land use consideration.
The candidate site statement identifies the effective use of mineral resources and the avoidance of
sterilisation of unworked reserves as clear benefits of the proposal. That carries substantial weight.
Mineral resources can only be worked where they occur, and it is generally more efficient and
sustainable to make prudent use of an established quarry resource than to disregard it while pressure
for future supply is directed elsewhere.
The site can also contribute to continuity and resilience of supply. The candidate site statement
expressly states that continued quarrying at the wider site would provide continuity in mineral supply
at this location and contribute to resilience through the provision of a consistent supply over the plan
period and beyond. Existing operational or consented sites will often provide a more realistic and
deliverable source of continuing supply than wholly new mineral sites.
Continued extraction would also support the construction industry through the provision of an
adequate and continuous supply of minerals. This sits comfortably with BP25’s recognition that the
Vale is an “important supplier of Carboniferous limestone for general aggregate use” .
There are also local economic benefits. The candidate site submission refers to the maintenance of
local economic benefits. An established quarrying operation supports employment, haulage, plant use, contractors and associated supply chains. Continued recognition of the site therefore supports local
economic activity as well as mineral supply.
Environmental and restoration benefits are also relevant. The candidate site statement refers to
benefits through new planting and habitat creation and treats restoration as part of the overall site
concept. Continued quarrying should therefore not be considered solely in terms of extraction. It also
creates the opportunity to secure restoration, habitat creation, landscape management and long-term
after-use benefits through a modern planning framework.
A further important benefit is that any continued working would proceed under modern planning
controls. The ROMP approval confirms that continued extraction has been reviewed through a
contemporary planning process, that updated conditions now regulate the site, that the quarry must
be worked in accordance with an approved working scheme, that annual production is capped at
250,000 tonnes, and that extraction may continue until 21 February 2042. That provides a robust and
sustainable planning basis for future quarrying.
Continued recognition of Pant-y-Ffynnon Quarry within the Deposit RLDP would also ensure that the
site remains properly integrated into the authority’s safeguarding, buffer and minerals policy
framework. That would provide clarity, consistency and transparency in the Plan.
6. Changes sought
The Deposit RLDP should not treat the absence of a current RTS2 requirement for further allocations
as determinative of the planning treatment of Pant-y-Ffynnon Quarry.
The Plan should continue to recognise the consented quarry element positively within the minerals
strategy.
The wider site should remain properly safeguarded within the minerals safeguarding and quarry
buffer framework.
The supporting text should make clear that the absence of a new allocation reflects only the current
RTS2 quantitative position and not any conclusion that the site is unsuitable in principle for continued
quarrying.
The Plan should rely on its existing minerals development management policies, together with the
ROMP framework and any future application process, to assess the detailed merits of continued
working, associated development and restoration proposals at the site.
That approach would better reflect the site’s planning status, the candidate site evidence, the ROMP
determination and the wider objective of maintaining a sound and effective minerals strategy in the
Vale of Glamorgan.
7. Conclusion
The Council’s reliance on the statement that the 2nd Review of the Minerals Regional Technical
Statement indicates that no further allocations are specifically required within the Vale of Glamorgan
RLDP is too narrow a basis on which to assess Pant-y-Ffynnon Quarry.
That statement may explain why the Council has not identified a new formal mineral allocation on
numerical grounds. It does not, however, justify removing or diluting positive recognition of an existing
quarry site with an established planning status, a recent ROMP approval permitting continued
extraction until 21 February 2042, and clear evidence of continuing supply, economic and restoration
benefits.
Pant-y-Ffynnon Quarry should therefore continue to be positively recognised as part of the Vale of
Glamorgan’s minerals framework. The Deposit RLDP should distinguish clearly between the absence
of a current need for a fresh allocation and the continuing strategic relevance of an established quarry
site. In the case of Pant-y-Ffynnon Quarry, the latter plainly remains.
8. Summary
 Overall minerals strategy: Support in part / Object in part.
Seth Hill & Son Ltd supports the general objective of maintaining an adequate minerals supply
and managing mineral resources through a plan-led framework. Objection is taken to the
extent that the Deposit RLDP relies too narrowly on the RTS2 conclusion that no further
allocations are specifically required, without properly reflecting the continuing role of Panty-
Ffynnon Quarry as an existing quarry site with ongoing strategic relevance.
 Strategic minerals policy / supply and safeguarding approach: Support in part / Object in part.
The strategic objective of securing a continuous supply of minerals and safeguarding mineral
resources is supported. Objection is taken insofar as that strategic approach is not properly
applied to Pant-y-Ffynnon Quarry, which should continue to be recognised positively within
the minerals framework notwithstanding the absence of a current need for a fresh allocation.
 Policy MIN1 – Mineral safeguarding areas: Support.
Support is given to the safeguarding of limestone resources from unnecessary sterilisation.
That approach is directly relevant to Pant-y-Ffynnon Quarry, particularly given that the
candidate site submission sought to retain quarry status for the consented element and to
safeguard the wider site for longer-term quarrying.
 Policy MIN2 – Quarry buffer zones: Support.
The principle of retaining quarry buffer zones is supported because it protects existing and
future quarrying operations from encroachment by incompatible development. Continued
positive recognition of Pant-y-Ffynnon Quarry sits logically alongside that buffer framework.
 Policy MIN4 – Sustainable mineral working: Support in principle.
Support is given to the policy framework for new workings, extensions and continued mineral
extraction subject to environmental safeguards, amenity protection and restoration. Pant-y-
Ffynnon Quarry is capable of being assessed under that framework, and detailed issues
should be dealt with through the policy and application process rather than by withholding
positive plan recognition now.
 Candidate Site Assessment – Pant-y-Ffynnon Quarry: Object.
Objection is taken to the candidate site assessment insofar as it relies on the statement that
no further allocations are specifically required under RTS2 as the reason for not taking the
site forward positively. That reasoning is too narrow because it fails to engage with the fact
that the site is an existing quarrying location, that the candidate submission sought retention
of quarry status as well as longer-term safeguarding, and that the site has benefited from
ROMP approval ref. 2024/00246/ENV, which permits operations until 21 February 2042.
 Status of the existing quarry site: Object to insufficient recognition.
Seth Hill & Son Ltd objects to any approach which treats Pant-y-Ffynnon Quarry as
strategically unimportant simply because no new allocation is numerically required. The
consented quarry element should continue to be positively recognised in the Plan, reflecting
its existing planning status, updated ROMP conditions and ongoing minerals planning context.
 Benefits of continued extraction at Pant-y-Ffynnon Quarry: Positive material consideration.
Continued extraction would make productive use of an existing quarry site, avoid sterilisation
of unworked reserves, provide continuity and resilience of mineral supply, support local
economic benefits and allow restoration-led environmental gains through planting, habitat
creation and long-term after-use. Those benefits weigh in favour of continued positive
recognition of the site within the Deposit RLDP.
 Soundness and evidence base: Object to insufficiently evidence-led treatment.
The Development Plans Manual requires plans to be based on “robust evidence” so they can
be delivered and links candidate sites directly to the soundness question “Will the plan deliver?” The current treatment of Pant-y-Ffynnon Quarry does not fully reflect the evidence
before the Council on the site’s planning status, deliverability and continuing operational role.
 National policy compliance – PPW, MTAN1 and SWRAWP: Support in principle / Object to
incomplete application.
The broad alignment of the Deposit RLDP with national minerals policy is supported. The
objection is that the Plan does not go far enough in applying PPW’s reference to “real
possibilities for future mineral working”, MTAN1’s requirement for a “more realistic landbank
assessment”, and SWRAWP’s warning that “Caution must be exercised in using these landbank
figures” when considering the ongoing role of Pant-y-Ffynnon Quarry.
 Overall position: Support in part / Object in part.
In overall terms, Seth Hill & Son Ltd supports the Deposit RLDP’s broad minerals framework.
The objection is a focused one: the Plan should more clearly distinguish between the absence
of a current need for a fresh mineral allocation and the continuing strategic relevance of Panty-
Ffynnon Quarry as an established quarry site with planning status, ongoing supply potential
and a recent ROMP approval extending operations beyond the plan period.

The supporting text should make clear that the absence of a new allocation reflects only the current RTS2 quantitative position.

REPRESENTATIONS TO THE DEPOSIT VALE OF GLAMORGAN REPLACEMENT LOCAL DEVELOPMENT
PLAN 2021–2036 ON BEHALF OF SETH HILL AND SON LTD
1. Introduction
These representations are submitted on behalf of Seth Hill & Son Ltd in response to the Deposit Vale
of Glamorgan Replacement Local Development Plan 2021–2036.
They relate specifically to the treatment of Pant-y-Ffynnon Quarry / Seth Hill Quarry, Bonvilston in the
Deposit Plan and the associated candidate site assessment process.
The principal concern arises from the Council’s candidate site assessment, which states that a positive
allocation for mineral working is not included because “The 2nd Review of the Minerals Regional
Technical Statement indicates no further allocations are specifically required to be identified within
the Vale of Glamorgan RLDP.”
That explanation addresses only the narrow issue of whether a fresh minerals allocation is presently
required on RTS2 arithmetic. It does not adequately address the planning merits of Pant-y-Ffynnon
Quarry itself, nor does it justify a limited or negative treatment of the site in the Deposit RLDP.
These representations therefore object to the overly narrow basis on which the site appears to have
been discounted for positive recognition and seek a more balanced and evidence-based treatment of
Pant-y-Ffynnon Quarry within the Plan.
2. Site context
Pant-y-Ffynnon Quarry is an established quarrying location with an existing mineral planning history
and an established role within the local minerals framework.
The candidate site planning statement explains that the site comprises the full extent of the currently
consented Ffynnon Quarry, together with adjoining land to the south. It confirms that the quarry
extracts limestone and that the consented quarry element is identified in the adopted LDP as a Quarry
Site, with adjoining land within the Buffer Zone and wider Mineral Safeguarding Area. The submission
sought to retain the existing LDP status of the consented element and to safeguard the potential for
further quarrying to take place on the remainder of the site in the longer term.
The candidate site statement also recorded the continuing active planning context at the site, including
application ref. 2021/01379/FUL for the resumption of limestone extraction in the North Quarry, the
establishment of an aggregates recycling facility, and restoration of the North Quarry using inert
waste materials. That position has since been materially reinforced by the ROMP determination.
Decision notice 2024/00246/ENV is a Determination of New Working Conditions for Pantyffynnon
Quarry / Seth Hill Quarry, Bonvilston. The decision provides that the new conditions replace those
attached to permissions 97/01084/FUL and 2009/00184/ENV. Condition 1 states that “No operations
authorised by this permission, with the exception of restoration and after-treatment works approved
under these conditions shall take place after 21 February 2042.” The decision also requires a detailed
working scheme, revised working programmes every five years, and imposes an annual production
limit of 250,000 tonnes.
BP25 independently corroborates the continuing active status of the quarry. It identifies Pantyffynnon
in Table 1 as an active quarry with an extraction end date of 21.02.2042. BP25 also confirms that the
Vale of Glamorgan is an “important supplier of Carboniferous limestone for general aggregate use”.
Taken together, that evidence confirms that the site is not simply a historic quarry with uncertain
prospects. It is an active quarry with a recently updated modern conditions framework and an
extraction end date beyond the RLDP period.
3. Objection to the candidate site assessment
The Council’s candidate site assessment relies on the proposition that no further allocations are
specifically required because of the RTS2 position. That reasoning is too narrow.
The statement that no further allocations are specifically required may explain why the Council has
concluded that it does not presently need to identify a fresh minerals allocation in order to meet the
current quantitative apportionment. It does not, however, address the separate issue of how the Plan
should treat an existing quarry site such as Pant-y-Ffynnon Quarry.
The absence of a current need for a new allocation is not the same as a conclusion that an established
quarry site should cease to be positively recognised, should no longer be meaningfully safeguarded,
or should be treated as strategically unimportant.
The candidate site submission itself demonstrates why the Council’s reasoning is incomplete. The
submission did not merely seek a fresh allocation on the basis of additional tonnage need. It sought
retention of the existing quarry status of the consented element and safeguarding of the wider site for
longer-term quarrying potential.
The ROMP decision strengthens that point considerably. A site that has recently been granted updated
mineral working conditions and is authorised to continue operations until 21 February 2042 cannot
sensibly be treated as though its future role is immaterial simply because current RTS2 figures do not
require a further allocation elsewhere in the Vale.
The Council’s approach is also difficult to reconcile with national plan-making guidance. The
Development Plans Manual states that plans should be based on “robust evidence” so they can be
delivered, that candidate sites should not be purposefully excluded from assessment, and that the key
objective is whether a promoter has a serious intention to bring the site forward, which links directly
to the soundness question “Will the plan deliver?”
In those circumstances, the candidate site assessment appears to conflate two distinct questions:
whether a new specific allocation is numerically required under RTS2, and whether an established
quarry site should continue to be positively recognised and safeguarded in the Plan. Those questions
are not the same. The former may currently be answered in the negative. The latter, in the case of
Pant-y-Ffynnon Quarry, should plainly be answered in the affirmative.
4. National and local policy context
The wider policy and evidence framework supports a more positive treatment of Pant-y-Ffynnon
Quarry than is reflected in the candidate site assessment.
PPW states that it is in the interests of the minerals industry that landbanks reflect “real possibilities
for future mineral working” and adds that authorities should provide “a clear guide to where nonenergy
mineral extraction is likely to be acceptable”.
MTAN1 explains that development plans should identify “dormant reserves” separately and states that
“A more realistic landbank assessment is the aim of this process” so that a more accurate picture
emerges of reserves “that are likely to have real potential for future working”. It also states that the
future landbank should include land specifically allocated for the working of aggregates as an
“extended landbank”.
The SWRAWP RTS reinforces the point that reserve arithmetic is not the whole picture. It states that
“Caution must be exercised in using these landbank figures” because the calculation does not take
account of geographical or operational aspects, changes in planning policy, protected site
designations or other permitting constraints. This is particularly relevant given the increasingly
important role of NRW licensing and abstraction controls, including quarry dewatering considerations,
which may mean that some reserves are no longer as readily available or economically viable as
historic landbank figures imply. Accordingly, apparent reserve sufficiency in quantitative terms may overstate the extent of genuinely deliverable supply. SWRAWP also confirms that dormant reserves
“must be counted separately”.
The Deposit RLDP’s own framework is consistent with that broader policy approach. The Plan
safeguards known limestone resources and retains quarry buffer zones so that incompatible
development does not prejudice mineral operations or future working. BP25 explains that the RLDP
safeguards finite mineral resources for future generations and protects them from permanent
development that could sterilise or hinder extraction.
The Plan also provides a detailed framework for sustainable mineral working, including new workings,
extensions and the reworking or reopening of old workings. That mechanism is intended to deal with
the detailed merits of mineral proposals, including environmental effects, amenity, hydrology,
transport and restoration. There is therefore no sound policy basis for adopting an unduly negative
position toward Pant-y-Ffynnon Quarry at plan-making stage simply because no fresh allocation is
currently required.
5. Benefits of continued extraction at Pant-y-Ffynnon Quarry
Continued extraction at Pant-y-Ffynnon Quarry would give rise to a number of important site-specific
and strategic benefits.
PPW expressly recognises the planning advantages of extending established quarry sites. Paragraph
5.14.48 states that “The presence of an existing quarry should be a material consideration when
considering a proposal for an extension. There may be benefits to extending a site in terms of shared
infrastructure, for instance, as opposed to working a new greenfield site.” That principle is directly
relevant to Pant-y-Ffynnon Quarry. The site is an existing quarrying location with an established
operational and planning context, and any continued working or extension would be able to build upon
that existing quarrying footprint, associated infrastructure and minerals land use relationship. In
planning terms, that is materially preferable to directing future working to an entirely new greenfield
location, and it reinforces the case for the Deposit RLDP to continue to recognise the site positively
within the minerals strategy rather than treating it as strategically unimportant simply because no
fresh allocation is currently required.
The site is an existing quarrying location with an established mineral planning history. Continued
extraction would therefore amount to the continuation and proper management of an existing
quarrying use rather than the introduction of mineral development into a wholly new location. That is
a material land use consideration.
The candidate site statement identifies the effective use of mineral resources and the avoidance of
sterilisation of unworked reserves as clear benefits of the proposal. That carries substantial weight.
Mineral resources can only be worked where they occur, and it is generally more efficient and
sustainable to make prudent use of an established quarry resource than to disregard it while pressure
for future supply is directed elsewhere.
The site can also contribute to continuity and resilience of supply. The candidate site statement
expressly states that continued quarrying at the wider site would provide continuity in mineral supply
at this location and contribute to resilience through the provision of a consistent supply over the plan
period and beyond. Existing operational or consented sites will often provide a more realistic and
deliverable source of continuing supply than wholly new mineral sites.
Continued extraction would also support the construction industry through the provision of an
adequate and continuous supply of minerals. This sits comfortably with BP25’s recognition that the
Vale is an “important supplier of Carboniferous limestone for general aggregate use” .
There are also local economic benefits. The candidate site submission refers to the maintenance of
local economic benefits. An established quarrying operation supports employment, haulage, plant use, contractors and associated supply chains. Continued recognition of the site therefore supports local
economic activity as well as mineral supply.
Environmental and restoration benefits are also relevant. The candidate site statement refers to
benefits through new planting and habitat creation and treats restoration as part of the overall site
concept. Continued quarrying should therefore not be considered solely in terms of extraction. It also
creates the opportunity to secure restoration, habitat creation, landscape management and long-term
after-use benefits through a modern planning framework.
A further important benefit is that any continued working would proceed under modern planning
controls. The ROMP approval confirms that continued extraction has been reviewed through a
contemporary planning process, that updated conditions now regulate the site, that the quarry must
be worked in accordance with an approved working scheme, that annual production is capped at
250,000 tonnes, and that extraction may continue until 21 February 2042. That provides a robust and
sustainable planning basis for future quarrying.
Continued recognition of Pant-y-Ffynnon Quarry within the Deposit RLDP would also ensure that the
site remains properly integrated into the authority’s safeguarding, buffer and minerals policy
framework. That would provide clarity, consistency and transparency in the Plan.
6. Changes sought
The Deposit RLDP should not treat the absence of a current RTS2 requirement for further allocations
as determinative of the planning treatment of Pant-y-Ffynnon Quarry.
The Plan should continue to recognise the consented quarry element positively within the minerals
strategy.
The wider site should remain properly safeguarded within the minerals safeguarding and quarry
buffer framework.
The supporting text should make clear that the absence of a new allocation reflects only the current
RTS2 quantitative position and not any conclusion that the site is unsuitable in principle for continued
quarrying.
The Plan should rely on its existing minerals development management policies, together with the
ROMP framework and any future application process, to assess the detailed merits of continued
working, associated development and restoration proposals at the site.
That approach would better reflect the site’s planning status, the candidate site evidence, the ROMP
determination and the wider objective of maintaining a sound and effective minerals strategy in the
Vale of Glamorgan.
7. Conclusion
The Council’s reliance on the statement that the 2nd Review of the Minerals Regional Technical
Statement indicates that no further allocations are specifically required within the Vale of Glamorgan
RLDP is too narrow a basis on which to assess Pant-y-Ffynnon Quarry.
That statement may explain why the Council has not identified a new formal mineral allocation on
numerical grounds. It does not, however, justify removing or diluting positive recognition of an existing
quarry site with an established planning status, a recent ROMP approval permitting continued
extraction until 21 February 2042, and clear evidence of continuing supply, economic and restoration
benefits.
Pant-y-Ffynnon Quarry should therefore continue to be positively recognised as part of the Vale of
Glamorgan’s minerals framework. The Deposit RLDP should distinguish clearly between the absence
of a current need for a fresh allocation and the continuing strategic relevance of an established quarry
site. In the case of Pant-y-Ffynnon Quarry, the latter plainly remains.
8. Summary
 Overall minerals strategy: Support in part / Object in part.
Seth Hill & Son Ltd supports the general objective of maintaining an adequate minerals supply
and managing mineral resources through a plan-led framework. Objection is taken to the
extent that the Deposit RLDP relies too narrowly on the RTS2 conclusion that no further
allocations are specifically required, without properly reflecting the continuing role of Panty-
Ffynnon Quarry as an existing quarry site with ongoing strategic relevance.
 Strategic minerals policy / supply and safeguarding approach: Support in part / Object in part.
The strategic objective of securing a continuous supply of minerals and safeguarding mineral
resources is supported. Objection is taken insofar as that strategic approach is not properly
applied to Pant-y-Ffynnon Quarry, which should continue to be recognised positively within
the minerals framework notwithstanding the absence of a current need for a fresh allocation.
 Policy MIN1 – Mineral safeguarding areas: Support.
Support is given to the safeguarding of limestone resources from unnecessary sterilisation.
That approach is directly relevant to Pant-y-Ffynnon Quarry, particularly given that the
candidate site submission sought to retain quarry status for the consented element and to
safeguard the wider site for longer-term quarrying.
 Policy MIN2 – Quarry buffer zones: Support.
The principle of retaining quarry buffer zones is supported because it protects existing and
future quarrying operations from encroachment by incompatible development. Continued
positive recognition of Pant-y-Ffynnon Quarry sits logically alongside that buffer framework.
 Policy MIN4 – Sustainable mineral working: Support in principle.
Support is given to the policy framework for new workings, extensions and continued mineral
extraction subject to environmental safeguards, amenity protection and restoration. Pant-y-
Ffynnon Quarry is capable of being assessed under that framework, and detailed issues
should be dealt with through the policy and application process rather than by withholding
positive plan recognition now.
 Candidate Site Assessment – Pant-y-Ffynnon Quarry: Object.
Objection is taken to the candidate site assessment insofar as it relies on the statement that
no further allocations are specifically required under RTS2 as the reason for not taking the
site forward positively. That reasoning is too narrow because it fails to engage with the fact
that the site is an existing quarrying location, that the candidate submission sought retention
of quarry status as well as longer-term safeguarding, and that the site has benefited from
ROMP approval ref. 2024/00246/ENV, which permits operations until 21 February 2042.
 Status of the existing quarry site: Object to insufficient recognition.
Seth Hill & Son Ltd objects to any approach which treats Pant-y-Ffynnon Quarry as
strategically unimportant simply because no new allocation is numerically required. The
consented quarry element should continue to be positively recognised in the Plan, reflecting
its existing planning status, updated ROMP conditions and ongoing minerals planning context.
 Benefits of continued extraction at Pant-y-Ffynnon Quarry: Positive material consideration.
Continued extraction would make productive use of an existing quarry site, avoid sterilisation
of unworked reserves, provide continuity and resilience of mineral supply, support local
economic benefits and allow restoration-led environmental gains through planting, habitat
creation and long-term after-use. Those benefits weigh in favour of continued positive
recognition of the site within the Deposit RLDP.
 Soundness and evidence base: Object to insufficiently evidence-led treatment.
The Development Plans Manual requires plans to be based on “robust evidence” so they can
be delivered and links candidate sites directly to the soundness question “Will the plan deliver?” The current treatment of Pant-y-Ffynnon Quarry does not fully reflect the evidence
before the Council on the site’s planning status, deliverability and continuing operational role.
 National policy compliance – PPW, MTAN1 and SWRAWP: Support in principle / Object to
incomplete application.
The broad alignment of the Deposit RLDP with national minerals policy is supported. The
objection is that the Plan does not go far enough in applying PPW’s reference to “real
possibilities for future mineral working”, MTAN1’s requirement for a “more realistic landbank
assessment”, and SWRAWP’s warning that “Caution must be exercised in using these landbank
figures” when considering the ongoing role of Pant-y-Ffynnon Quarry.
 Overall position: Support in part / Object in part.
In overall terms, Seth Hill & Son Ltd supports the Deposit RLDP’s broad minerals framework.
The objection is a focused one: the Plan should more clearly distinguish between the absence
of a current need for a fresh mineral allocation and the continuing strategic relevance of Panty-
Ffynnon Quarry as an established quarry site with planning status, ongoing supply potential
and a recent ROMP approval extending operations beyond the plan period.

REPRESENTATIONS TO THE DEPOSIT VALE OF GLAMORGAN REPLACEMENT LOCAL DEVELOPMENT
PLAN 2021–2036 ON BEHALF OF TOM PRICHARD (HOLDINGS) LTD
1. Introduction
These representations are submitted on behalf of Tom Prichard (Holdings) Ltd in respect of the Deposit
Vale of Glamorgan Replacement Local Development Plan 2021–2036. They relate specifically to the
Plan’s minerals strategy and policy framework, the treatment of dormant mineral sites, and the
candidate site assessment and supporting evidence relating to Argoed Isha Quarry, Llansannor.
The respondent supports the broad direction of the Deposit RLDP minerals framework, but contends
that the Plan is unsound in part in the way it presently treats Argoed Isha Quarry. The central point is
straightforward: the Council’s own evidence accepts that usable reserves remain at the site, that those
reserves could still be extracted if required, and that the site has the potential to be reworked. Yet that
conclusion is not carried through into a sufficiently positive and coherent plan-led position.
The objection is therefore not to the principle of maintaining a minerals strategy founded on
safeguarding, environmental protection and modern control of extraction. Nor is it suggested that the
Plan must necessarily allocate Argoed Isha as a new specific site simply because a candidate site was
submitted. Rather, the objection is that the Deposit RLDP does not properly reflect the evidential
position it has itself reached. It acknowledges that Argoed Isha should not be made subject to a
Prohibition Order, but stops short of recognising clearly that the site remains a dormant limestone
quarry with continuing mineral significance, realistic future reactivation potential and scope for future
working under modern planning controls, restoration obligations and biodiversity enhancement.
2. Site context and planning status
Argoed Isha is a long-established limestone quarry. The candidate site planning statement explains
that the site has a historic quarry planning status, that recommencement would require updated
working conditions, and that the site was promoted through the candidate site process precisely
because there remains interest in recommencing mineral extraction. The same statement records the
local planning authority’s earlier position that, in relation to a previous proposal, the Council could
only seek a Prohibition Order if it was satisfied that resumption of extraction was unlikely, but that
“this requirement is not met” at Argoed Isha because of continuing interest in re-opening the quarry.
It also records the mineral adviser’s view that “The site currently has planning permission for a quarry”
and that, absent relinquishment, “the permission to quarry remains valid”.
The candidate site material also addresses availability and deliverability. It states that the site is
available for development, that the proposal is considered viable and deliverable owing to the
underlying need for the mineral, and that the site is a brownfield / underutilised site. It further notes
that the proposal comprises mineral development within a mineral safeguarding area and within a
site which benefits from a planning permission for quarrying, such that it is considered acceptable in
principle. Those points are important because they show that Argoed Isha is not simply a theoretical
reserve detached from any realistic prospect of future use.
3. Soundness and the role of evidence
The Development Plans Manual states that plans should be based on robust evidence so they can be
delivered and that LPAs must be able to demonstrate, in broad terms, that the plan is deliverable with
no significant impediments to implementation. It also emphasises the importance of a detailed
candidate site process and of ensuring delivery and viability are embedded in that process from the
outset. Elsewhere, the Manual explains that the plan-making process should prepare more effective,
efficient and deliverable plans and refers expressly to the tests of soundness which must be satisfied
if a development plan is to be recommended for adoption.
Those principles matter here because the Council had before it a candidate site submission which set
out the site’s planning status, constraints, deliverability and rationale for retention as a mineral site.
It also had its own local evidence in BP25 and the wider regional evidence from RTS2, the sub-regional
collaboration work and SWRAWP. In those circumstances, a sound plan ought to explain clearly how
that evidence has informed the Council’s chosen strategy for Argoed Isha. In the respondent’s
submission, the Deposit RLDP presently falls short because it recognises part of the evidence, but not
its full implications. The Plan is therefore unsound in part because it is not fully justified by the
evidence and is not as effective as it should be in setting out a coherent future approach to this
dormant but still viable mineral resource.
4. National policy context – Planning Policy Wales
Planning Policy Wales establishes the national context for these representations. It requires planning
authorities to maintain landbanks for non-energy minerals in demand and states that, for crushed
rock, a minimum ten-year landbank should be maintained through the plan period unless agreement
is reached for other authorities to make a compensating increase in provision. PPW also recognises
that individual authority boundaries are not always an adequate basis for landbank policy where
environmental constraints are too important or workable resources too limited, in which case
authorities must agree a joint approach with neighbouring authorities in line with regional
arrangements.
PPW is especially important in relation to inactive sites. Paragraph 5.14.17 provides that inactive sites
with planning permission for future working which are considered unlikely to be reactivated should
be identified in the development plan and should be the subject of a suitable strategy, which could
include prohibition orders, restoration and aftercare proposals, and a suitable proposed after-use.
Paragraph 5.14.18 then states that “It is in the interests of the minerals industry that landbanks reflect
real possibilities for future mineral working” and adds that, where sites have been inactive and “there
is no prospect of future working”, authorities should consider the use of prohibition orders.
That distinction is central to the present case. The Council has not concluded that there is no prospect
of future working at Argoed Isha. Quite the contrary: BP25 states that usable reserves remain at the
site, that they could be extracted if required, and that they have the potential to be reworked. The logic
of PPW is therefore that Argoed Isha is not a site to be treated as effectively closed or exhausted. It
remains a site with continuing mineral relevance, albeit one that would require modern conditions and
a fresh scheme of workings before any extraction could recommence.
PPW is also directly relevant to areas of future working. Paragraph 5.14.19 states that “Where
necessary, planning authorities should provide a clear guide to where non-energy mineral extraction
is likely to be acceptable” and that policies and proposals should cover mineral resources “which are
currently used or which may need to be used in the foreseeable future”. It further explains that such
areas should be clearly identified on a proposals map and may take the form, in order of preference,
of specific sites, preferred areas or areas of search.
The respondent does not suggest that PPW compels the Council to identify Argoed Isha as a specific
site. However, PPW plainly supports a more positive and more explicit plan-led recognition of sites
which retain real future mineral potential. Once the Council’s own evidence accepts that Argoed Isha
is such a site, it is difficult to reconcile a largely passive policy response with the national expectation
that development plans should give a clear guide to where future mineral working may be acceptable.
5. National policy context – MTAN1
MTAN1 reinforces the need for a realistic and evidence-based approach to landbanks and dormant
sites. It explains that a landbank is composed of permitted reserves at active and inactive sites, and
that development plans should include an assessment of both the current and future landbank.
Paragraph 47 then states that development plans should identify those sites that are dormant and
count these as “dormant reserves” to be clearly shown in landbank calculations as a separate
category. Paragraph 48 continues by stating that a more realistic approach is required, observing that
extensive historic landbanks can perpetuate unsustainable supply patterns if left unaltered. MTAN1
therefore states that “A more realistic landbank assessment is the aim of this process” so that a more accurate picture is obtained of permitted reserves “that are likely to have real potential for future
working”.
That policy language is highly material. It confirms that dormant reserves are not irrelevant simply
because they are not counted within the active landbank. They are to be identified separately and
realistically assessed. That is precisely the position that should be taken with Argoed Isha. The Council
has already undertaken the essential assessment in substance through BP25 and has concluded that
usable reserves remain and that the site has the potential to be reworked. MTAN1 therefore supports
a more nuanced and more positive treatment of the site than a simple “no allocation required”
conclusion.
MTAN1 also recognises that in some authorities it may not be possible or acceptable to provide an
adequate current or extended landbank because of environmental designations, limited suitable
resources, or amenity considerations, and that RAWPs should consider the environmental capacity of
authorities to supply aggregates. This is an important reminder that reserve arithmetic is not the only
issue. Deliverability, environmental capacity, and the practical availability of reserves remain relevant.
6. Apportionment and Plan Period
The regional and sub-regional evidence does not undermine the respondent’s case. It explains why
there is no present quantitative requirement for a further minerals allocation in the Vale, but it does
not justify a negative or dismissive treatment of Argoed Isha.
BP25 records the RTS2 and Statement of Sub-Regional Collaboration position for the Cardiff City subregion.
Table 5 identifies the Vale of Glamorgan apportionment for crushed rock as 17.05 million tonnes
over 25 years, with existing permitted reserves of 18.73 million tonnes at the end of 2016 and a
minimum allocation needed of 0, alongside 13 million tonnes of additional reserves at dormant sites.
BP25 then states that, based on those figures, the SSRC identifies that the Vale of Glamorgan does not
require any allocations for future workings of crushed rock to be identified within the RLDP.
Based on the Development Plans Manual, when a plan is adopted, there should be at least 10 years of
the plan period remaining.
On the Council’s current timetable, adoption is only anticipated for August/September 2027, and those
post-Deposit stages are expressly identified in the Delivery Agreement as indicative, because they
depend on external factors including the number of representations received and the examination
process. The Deposit Plan runs only to 2036. That means that, even if the Council hits its best-case
programme and adopts in September 2027, the Plan would have only about 8 years and 3 months left
to run. That is already below the DPM expectation of at least 10 years remaining at adoption. Any
slippage would make that position worse.
Based on the current timetable, an end date of 2038 (with associated review of mineral reserves)
would therefore ensure a sound plan.
Notwithstanding our comment in respect of the Plan Period, we remain concerned of how the Plan
should treat a dormant site which the Council accepts has remaining usable reserves and realistic
reactivation potential. Nor does it justify treating Argoed Isha as though it lacked future significance.
The respondent’s case is therefore not that the RTS2 figure is wrong, but that it has been taken too
far. A conclusion that no additional formal allocation is presently required is not the same thing as a
conclusion that the site has no future role.
7. BP25 – the Council’s own minerals evidence
BP25 is the most important local evidence document for present purposes. It records that the Vale of
Glamorgan is an “important supplier of Carboniferous limestone for general aggregate use”. It then
addresses dormant mineral sites in the Vale. Paragraphs 5.48 to 5.50 explain that many dormant sites
have not been worked for many years and are considered unlikely to be worked in the future;
accordingly, the Council intends to serve Prohibition Orders on those sites, which would provide certainty for nearby residents and remove reserves which are not realistically available. BP25 also
explains that the level of reserves at dormant sites is not counted in the landbank.
Crucially, BP25 then distinguishes Argoed Isha from that general class of dormant sites. Paragraph
5.51 states: “While Argoed Isha quarry is classified as ‘dormant’, useable reserves remain at the site
and could be extracted if required.” It goes on to record that a Construction Plant Competence Training
Centre has operated at the site since 2016 and has temporary planning consent until 2030, but then
adds: “While the reserves at the site are not included in the current landbank, they have the potential
to be reworked and therefore a Prohibition Order will not be served at Argoed Isha Quarry until the
current circumstances change.”
That is a very clear evidential conclusion. BP25 does not simply refrain from prohibiting the site
without explanation. It positively explains why Argoed Isha is different: usable reserves remain, they
could be extracted if required, and they have the potential to be reworked. In the respondent’s
submission, that conclusion requires a correspondingly clearer and more positive policy response
within the Deposit RLDP than is presently provided.
BP25 is also supportive on restoration and aftercare. It states that the serving of Prohibition Orders
is intended to provide certainty and, where necessary, restoration of sites may be sought. More
broadly, the background paper recognises the importance of sustainable minerals management and
balancing mineral extraction with environmental protection and community well-being. That policy
background is entirely consistent with the respondent’s case that any future working at Argoed Isha
should be controlled through a modern framework of environmental safeguards and restoration-led
after-use.
8. SWRAWP Annual Report 2024
The SWRAWP Annual Report 2024 is also highly relevant because it warns against over-reliance on
headline landbank figures. Paragraph 4.10 states that “Caution must be exercised in using these
landbank figures” because the calculation does not take account of geographical or operational
aspects that may restrict the availability of certain reserves, nor constraints arising from changes in
planning policy, protected site designation or other non-planning permitting requirements. Paragraph
4.11 then confirms that dormant sites have not been included in landbank calculations and that local
planning authorities should carry out their own assessments of the likelihood of reactivation, but that
in any event “dormant reserves must be counted separately”.
That evidence materially supports the respondent’s case. It shows that the statement “no further
allocations are specifically required” is not, in itself, the end of the analysis. Landbank figures are a
starting point, but they do not tell the whole story. Questions of practical availability, regulatory and
environmental constraints elsewhere, and the separate role of dormant reserves remain relevant.
Argoed Isha therefore retains importance as part of the broader mineral resource picture even though
it is not part of the active landbank.
9. Response to the Council’s candidate site assessment
The Council’s candidate site assessment records that a positive allocation for mineral working is not
included because “the 2nd Review of the Minerals Regional Technical Statement indicates no further
allocations are specifically required to be identified within the Vale of Glamorgan RLDP”. That point
should be addressed directly.
The respondent accepts that the RTS2 position explains why the Council may have concluded that
there is no immediate need for a fresh mineral allocation in quantitative terms. However, that is not a
sufficient reason, on its own, to reject a more positive policy treatment of Argoed Isha or to give the
impression that the site lacks future significance. BP25 itself shows why. It records both that the Vale
does not presently require additional allocations and, separately, that Argoed Isha retains remaining
usable reserves and has the potential to be reworked. Those two propositions are not inconsistent.
They point toward a more nuanced and more accurate conclusion: namely, that Argoed Isha may not need to be allocated now to meet a current numerical shortfall, but it remains a dormant limestone
reserve of continuing strategic relevance that should be positively recognised within the Plan.
That approach is also supported by PPW, MTAN1 and SWRAWP. PPW states that landbanks should
reflect “real possibilities for future mineral working” and that prohibition orders are appropriate where
there is “no prospect of future working”. MTAN1 requires dormant reserves to be separately identified
and assessed so as to achieve “A more realistic landbank assessment”. SWRAWP says that “Caution
must be exercised” in using landbank figures and that dormant reserves must be counted separately.
Those documents all point to a need for a broader planning judgment than simple reserve arithmetic.
Accordingly, the flaw in the candidate site reasoning is not that it refers to the RTS2 position, but that
it appears to stop there. In the respondent’s submission, the sounder and more evidence-based
approach would have been either to give the site more positive recognition in the Plan’s supporting
text, or at the very least to make clear that the site was not allocated because no immediate additional
allocation was required, not because the site lacked merit, availability or future potential.
Moreover, SWRAWP reinforces the point that reserve arithmetic is not the whole picture. It states that
“Caution must be exercised in using these landbank figures” because the calculation does not take
account of geographical or operational aspects, changes in planning policy, protected site
designations or other permitting constraints. This is particularly relevant given the increasingly
important role of NRW licensing and abstraction controls, including quarry dewatering considerations,
which may mean that some reserves are no longer as readily available or economically viable as
historic landbank figures imply. Accordingly, apparent reserve sufficiency in quantitative terms may
overstate the extent of genuinely deliverable supply.
10. The existing temporary training permission does not sterilise the reserve
BP25 states that a Construction Plant Competence Training Centre has operated at the site since 2016
and has temporary planning consent until 2030. The significance of that point is not that the site has
permanently moved away from minerals. The significance is the opposite: BP25 records the temporary
training use while simultaneously concluding that usable reserves remain and may be reworked, and
that a Prohibition Order should therefore not be served.
In planning terms, a temporary training use of this kind cannot properly be treated as sterilising the
mineral reserve. PPW’s safeguarding policy is concerned with preventing sterilisation by permanent
development. A time-limited interim use, particularly one expressly acknowledged in BP25 as coexisting
with a potentially reworkable reserve, does not extinguish the underlying mineral significance
of the site. The temporary training use should therefore be understood as an interim overlay rather
than a permanent change in land use character.
11. Benefits of continued extraction at Argoed Isha Quarry
Continued extraction at Argoed Isha Quarry would give rise to a number of site-specific and strategic
benefits which the Deposit RLDP should recognise when considering the future role of the site.
The site is not a greenfield mineral proposal on an entirely undeveloped site. It is an existing quarry
with a long-established mineral planning history and extant mineral status in principle, subject to
updated modern conditions. The principle of mineral working at the site is therefore already
established in land use terms, and the future reworking of the reserve would represent the
continuation of an existing mineral use rather than the introduction of quarrying into a wholly new
location. That is a material distinction when considering the appropriateness of retaining the site as a
realistic future mineral resource.
Continued extraction would also assist in making use of a proven local limestone resource in the Vale
of Glamorgan, rather than forcing greater reliance on more distant or more constrained sources. BP25
confirms that the Vale is an “important supplier of Carboniferous limestone for general aggregate
use”. In practical terms, continued extraction at Argoed Isha would accord with the proximity principle by helping to meet demand from a comparatively well-located source close to markets in the Vale and
wider Cardiff area, rather than depending unduly on more remote sources or on supply patterns that
may become more constrained over time.
The site would also contribute to the resilience and flexibility of the wider minerals supply position.
Even if no immediate additional allocation is numerically required under RTS2, national and regional
policy make clear that landbank figures are not the only relevant consideration. A dormant quarry with
remaining usable reserves provides contingency, flexibility and productive capacity in the event that
supply circumstances change during the plan period. This is especially important where SWRAWP
warns that landbank figures do not capture geographical, operational, policy or other permitting
constraints, and where MTAN1 requires a realistic view of reserves with future potential. Argoed Isha
therefore has value not merely as a theoretical reserve, but as part of a resilient longer-term supply
position.
Continued extraction at Argoed Isha would also support local supply chains and a more diverse
quarrying sector. The candidate site submission identified the benefit of maintaining provision from a
range of operators, including smaller and medium-sized businesses, rather than relying only on a
limited number of larger established sites. In planning terms, that diversity is relevant to continuity of
supply, competition, responsiveness to local demand and the overall resilience of the minerals sector
in the Vale and wider region.
A further benefit is that any future extraction would be carried out under modern planning control
rather than being left sterilised or underused. If the site is reworked in future, that would necessarily
be through a fresh scheme of modern conditions and under the policy framework of the RLDP and
national minerals policy. Issues such as traffic, hydrology, hydrogeology, ecology, landscape, amenity,
blasting, dust, restoration and long-term aftercare would all be capable of being addressed through
a contemporary planning and environmental control regime. That is an important benefit in itself,
because it means any future extraction would not take place under outdated historic controls, but
under a modern framework designed to secure sustainable mineral working.
Continued extraction would also create the opportunity for a comprehensive restoration and aftercare
strategy delivering environmental gains. PPW recognises that restoration and aftercare proposals for
inactive sites may include natural re-vegetation for nature conservation and ecological interests.
BP25 records that restoration may be sought where necessary. In practice, any future extraction
proposal at Argoed Isha could be accompanied by a restoration-led scheme involving landform
improvement, habitat creation, ecological enhancement and long-term stewardship. The site should
therefore not be seen simply as a mineral reserve, but as a place where carefully managed extraction
could unlock biodiversity, landscape and geodiversity benefits over time.
The site also represents the productive use of an underutilised brownfield quarry. The candidate site
material identifies it as a brownfield / underutilised site. In land use terms, there is a clear logic in
making effective use of an existing quarried landscape with established mineral status, rather than
placing additional pressure on wholly undeveloped land elsewhere. In this case, the Council’s own
evidence confirms the key factor: usable reserves remain and the site has the potential to be
reworked.
There is finally a longer-term safeguarding benefit in recognising the case for continued extraction.
PPW requires mineral resources to be safeguarded to prevent sterilisation by permanent
development, and makes clear that landbanks should reflect “real possibilities for future mineral
working”. Positive recognition of the benefits of continued extraction at Argoed Isha is therefore
entirely consistent with the basic objectives of national minerals policy: prudent use of finite mineral
resources, maintenance of flexibility in supply, and avoidance of circumstances in which sites with
genuine future potential are prematurely written off.
12. Restoration, aftercare and biodiversity gain
The respondent’s case is not simply that Argoed Isha should be recognised as a future mineral source.
It is also that any future reworking can and should be subject to a modern restoration-led scheme
capable of securing environmental gains.
PPW contemplates restoration and aftercare proposals for inactive sites, including natural revegetation
for nature conservation and ecological interests. BP25 records that, where necessary,
restoration may be sought at dormant sites. The candidate site material also identifies that the site is
not close to internationally or nationally important wildlife sites, while noting the presence of existing
ecological and geological interests that could be appropriately managed through buffers, mitigation
and future planning controls. These are precisely the kinds of circumstances in which a carefully
designed extraction and restoration scheme could deliver meaningful biodiversity and geodiversity
benefits alongside the prudent working of the remaining mineral resource.
Future working at Argoed Isha should therefore not be viewed in binary opposition to environmental
enhancement. The modern policy framework envisages integrated mineral development in which
extraction, restoration and aftercare are part of a single coherent process. That is an additional reason
why the Plan should positively recognise the site’s continuing potential rather than leaving it in a policy
grey area.
13. Overall conclusion
The evidence base points clearly to a more positive and more coherent treatment of Argoed Isha than
is presently provided in the Deposit RLDP.
PPW says that landbanks should reflect “real possibilities for future mineral working” and that
prohibition orders are appropriate where there is “no prospect of future working”. MTAN1 requires a
separate assessment of “dormant reserves” and seeks “A more realistic landbank assessment”.
SWRAWP states that “Caution must be exercised in using these landbank figures”. BP25 records that
“useable reserves remain at the site and could be extracted if required” and that they “have the
potential to be reworked”. The Development Plans Manual requires plans to be based on robust
evidence and to be deliverable.
Against that background, the Council’s reliance on the proposition that the RTS2 indicates no further
allocations are specifically required does not dispose of the issue. It may explain why there is no
immediate need for a fresh mineral allocation, but it does not justify a passive or dismissive treatment
of Argoed Isha. The more sound and evidence-based approach is to recognise that, whilst no additional
formal allocation is presently required, Argoed Isha remains a dormant limestone quarry with usable
reserves and realistic future reactivation potential, capable of coming forward in future under modern
policies for sustainable working, restoration and aftercare.
14. Summary
These representations contend that, whilst the Deposit RLDP minerals strategy is broadly supported,
the Plan is unsound in part in its treatment of Argoed Isha Quarry. In particular, the objection goes
principally to whether the Plan is justified by the evidence and whether it is effective in delivery. The
objection also concerns consistency with national minerals policy to the extent that the Deposit RLDP
does not fully reflect PPW and MTAN1 in positively planning for the safeguarding and potential future
working of this identified limestone resource.
 Strategic Policy SP18 – Minerals Supply and Safeguarding: Support in part / Object in part.
The respondent supports the overarching strategy of maintaining a continuous supply of
minerals, safeguarding mineral resources and avoiding sterilisation. However, objection is
taken insofar as the strategy does not carry through the Council’s own evidence that Argoed
Isha retains usable reserves and future potential for reworking.
 Policy MIN1 – Mineral Safeguarding Areas: Support.
This policy is supported because it reflects national policy by safeguarding limestone resources from permanent development that would sterilise them or hinder future extraction.
That approach is directly relevant to Argoed Isha, which remains a safeguarded resource with
extant mineral significance.
 Policy MIN2 – Quarry Buffer Zones: Support.
The principle of protecting mineral operations from encroachment by incompatible
development is supported. If Argoed Isha is to remain a realistic future source of limestone,
the Plan should continue to avoid prejudice to its potential reactivation.
 Policy MIN3 – Dormant Mineral Sites: Support in principle / Object in part.
The respondent supports the Council’s decision not to serve a Prohibition Order at Argoed
Isha. That is plainly the correct approach because BP25 confirms that usable reserves remain
and may be reworked. However, objection is taken to the absence of stronger wording
recognising that the site remains a realistic future source of limestone.
 Policy MIN4 – Sustainable Mineral Working: Support in principle.
The respondent supports the policy framework for future reworking or reopening of old
workings, including the need for acceptable impacts, restoration and beneficial after-use.
Argoed Isha is capable of being assessed under that type of modern policy framework.
 Supporting text to the dormant quarry provisions / paragraph 6.386 equivalent approach:
Object in part.
The Plan is correct to recognise that the reserves at Argoed Isha could be reworked in future.
The objection is that this conclusion is not carried through into a fuller and more positive
policy narrative.
 Plan Period: Object.
Amend in line with the Development Plans Manual such that there are at least 10 years
remaining at adoption.
 Candidate Site 411 – Argoed Isha Quarry: Object.
The respondent objects to the candidate site assessment insofar as the site appears to have
been rejected solely or mainly because RTS2 indicates that no further allocations are
specifically required. That is too narrow an approach and does not properly reflect PPW,
MTAN1, SWRAWP or BP25’s conclusion that usable reserves remain and may be reworked.
 Minerals Background Paper BP25: Support in part / Object in part.
BP25 is supported where it correctly records that Argoed Isha is dormant, that usable
reserves remain, and that the site has the potential to be reworked. Objection is taken only
insofar as the Deposit RLDP does not fully reflect the implications of that evidence in a more
positive and coherent plan-led position.
 Temporary training use: Clarificatory comment in support of the representation.
The current training use does not sterilise the limestone reserve. BP25 records the temporary
training use until 2030 while also confirming that usable reserves remain and that the site
may be reworked. It should therefore be treated as an interim use only.
 Benefits of continued extraction at Argoed Isha: Positive material consideration.
Continued extraction at Argoed Isha would make productive use of an existing dormant quarry
with remaining usable reserves, support local and sub-regional limestone supply from a Vale
source, contribute to flexibility and resilience in the minerals strategy, and enable future
working to proceed under modern planning controls with restoration, aftercare and
biodiversity enhancement.
 Overall position on the Deposit RLDP minerals strategy: Support in part / Object in part.
In overall terms, the respondent supports the Deposit RLDP’s general minerals framework.
The objection is a precise and limited one: the Plan should more clearly and positively recognise Argoed Isha as a dormant quarry with usable reserves, realistic reactivation
potential, and scope for a future scheme of continued extraction and restoration, such that the Plan is properly justified by its evidence base and effective in delivering a resilient minerals strategy over the plan period.

REPRESENTATIONS TO THE DEPOSIT VALE OF GLAMORGAN REPLACEMENT LOCAL DEVELOPMENT
PLAN 2021–2036 ON BEHALF OF TOM PRICHARD (HOLDINGS) LTD
1. Introduction
These representations are submitted on behalf of Tom Prichard (Holdings) Ltd in respect of the Deposit
Vale of Glamorgan Replacement Local Development Plan 2021–2036. They relate specifically to the
Plan’s minerals strategy and policy framework, the treatment of dormant mineral sites, and the
candidate site assessment and supporting evidence relating to Argoed Isha Quarry, Llansannor.
The respondent supports the broad direction of the Deposit RLDP minerals framework, but contends
that the Plan is unsound in part in the way it presently treats Argoed Isha Quarry. The central point is
straightforward: the Council’s own evidence accepts that usable reserves remain at the site, that those
reserves could still be extracted if required, and that the site has the potential to be reworked. Yet that
conclusion is not carried through into a sufficiently positive and coherent plan-led position.
The objection is therefore not to the principle of maintaining a minerals strategy founded on
safeguarding, environmental protection and modern control of extraction. Nor is it suggested that the
Plan must necessarily allocate Argoed Isha as a new specific site simply because a candidate site was
submitted. Rather, the objection is that the Deposit RLDP does not properly reflect the evidential
position it has itself reached. It acknowledges that Argoed Isha should not be made subject to a
Prohibition Order, but stops short of recognising clearly that the site remains a dormant limestone
quarry with continuing mineral significance, realistic future reactivation potential and scope for future
working under modern planning controls, restoration obligations and biodiversity enhancement.
2. Site context and planning status
Argoed Isha is a long-established limestone quarry. The candidate site planning statement explains
that the site has a historic quarry planning status, that recommencement would require updated
working conditions, and that the site was promoted through the candidate site process precisely
because there remains interest in recommencing mineral extraction. The same statement records the
local planning authority’s earlier position that, in relation to a previous proposal, the Council could
only seek a Prohibition Order if it was satisfied that resumption of extraction was unlikely, but that
“this requirement is not met” at Argoed Isha because of continuing interest in re-opening the quarry.
It also records the mineral adviser’s view that “The site currently has planning permission for a quarry”
and that, absent relinquishment, “the permission to quarry remains valid”.
The candidate site material also addresses availability and deliverability. It states that the site is
available for development, that the proposal is considered viable and deliverable owing to the
underlying need for the mineral, and that the site is a brownfield / underutilised site. It further notes
that the proposal comprises mineral development within a mineral safeguarding area and within a
site which benefits from a planning permission for quarrying, such that it is considered acceptable in
principle. Those points are important because they show that Argoed Isha is not simply a theoretical
reserve detached from any realistic prospect of future use.
3. Soundness and the role of evidence
The Development Plans Manual states that plans should be based on robust evidence so they can be
delivered and that LPAs must be able to demonstrate, in broad terms, that the plan is deliverable with
no significant impediments to implementation. It also emphasises the importance of a detailed
candidate site process and of ensuring delivery and viability are embedded in that process from the
outset. Elsewhere, the Manual explains that the plan-making process should prepare more effective,
efficient and deliverable plans and refers expressly to the tests of soundness which must be satisfied
if a development plan is to be recommended for adoption.
Those principles matter here because the Council had before it a candidate site submission which set
out the site’s planning status, constraints, deliverability and rationale for retention as a mineral site.
It also had its own local evidence in BP25 and the wider regional evidence from RTS2, the sub-regional
collaboration work and SWRAWP. In those circumstances, a sound plan ought to explain clearly how
that evidence has informed the Council’s chosen strategy for Argoed Isha. In the respondent’s
submission, the Deposit RLDP presently falls short because it recognises part of the evidence, but not
its full implications. The Plan is therefore unsound in part because it is not fully justified by the
evidence and is not as effective as it should be in setting out a coherent future approach to this
dormant but still viable mineral resource.
4. National policy context – Planning Policy Wales
Planning Policy Wales establishes the national context for these representations. It requires planning
authorities to maintain landbanks for non-energy minerals in demand and states that, for crushed
rock, a minimum ten-year landbank should be maintained through the plan period unless agreement
is reached for other authorities to make a compensating increase in provision. PPW also recognises
that individual authority boundaries are not always an adequate basis for landbank policy where
environmental constraints are too important or workable resources too limited, in which case
authorities must agree a joint approach with neighbouring authorities in line with regional
arrangements.
PPW is especially important in relation to inactive sites. Paragraph 5.14.17 provides that inactive sites
with planning permission for future working which are considered unlikely to be reactivated should
be identified in the development plan and should be the subject of a suitable strategy, which could
include prohibition orders, restoration and aftercare proposals, and a suitable proposed after-use.
Paragraph 5.14.18 then states that “It is in the interests of the minerals industry that landbanks reflect
real possibilities for future mineral working” and adds that, where sites have been inactive and “there
is no prospect of future working”, authorities should consider the use of prohibition orders.
That distinction is central to the present case. The Council has not concluded that there is no prospect
of future working at Argoed Isha. Quite the contrary: BP25 states that usable reserves remain at the
site, that they could be extracted if required, and that they have the potential to be reworked. The logic
of PPW is therefore that Argoed Isha is not a site to be treated as effectively closed or exhausted. It
remains a site with continuing mineral relevance, albeit one that would require modern conditions and
a fresh scheme of workings before any extraction could recommence.
PPW is also directly relevant to areas of future working. Paragraph 5.14.19 states that “Where
necessary, planning authorities should provide a clear guide to where non-energy mineral extraction
is likely to be acceptable” and that policies and proposals should cover mineral resources “which are
currently used or which may need to be used in the foreseeable future”. It further explains that such
areas should be clearly identified on a proposals map and may take the form, in order of preference,
of specific sites, preferred areas or areas of search.
The respondent does not suggest that PPW compels the Council to identify Argoed Isha as a specific
site. However, PPW plainly supports a more positive and more explicit plan-led recognition of sites
which retain real future mineral potential. Once the Council’s own evidence accepts that Argoed Isha
is such a site, it is difficult to reconcile a largely passive policy response with the national expectation
that development plans should give a clear guide to where future mineral working may be acceptable.
5. National policy context – MTAN1
MTAN1 reinforces the need for a realistic and evidence-based approach to landbanks and dormant
sites. It explains that a landbank is composed of permitted reserves at active and inactive sites, and
that development plans should include an assessment of both the current and future landbank.
Paragraph 47 then states that development plans should identify those sites that are dormant and
count these as “dormant reserves” to be clearly shown in landbank calculations as a separate
category. Paragraph 48 continues by stating that a more realistic approach is required, observing that
extensive historic landbanks can perpetuate unsustainable supply patterns if left unaltered. MTAN1
therefore states that “A more realistic landbank assessment is the aim of this process” so that a more accurate picture is obtained of permitted reserves “that are likely to have real potential for future
working”.
That policy language is highly material. It confirms that dormant reserves are not irrelevant simply
because they are not counted within the active landbank. They are to be identified separately and
realistically assessed. That is precisely the position that should be taken with Argoed Isha. The Council
has already undertaken the essential assessment in substance through BP25 and has concluded that
usable reserves remain and that the site has the potential to be reworked. MTAN1 therefore supports
a more nuanced and more positive treatment of the site than a simple “no allocation required”
conclusion.
MTAN1 also recognises that in some authorities it may not be possible or acceptable to provide an
adequate current or extended landbank because of environmental designations, limited suitable
resources, or amenity considerations, and that RAWPs should consider the environmental capacity of
authorities to supply aggregates. This is an important reminder that reserve arithmetic is not the only
issue. Deliverability, environmental capacity, and the practical availability of reserves remain relevant.
6. Apportionment and Plan Period
The regional and sub-regional evidence does not undermine the respondent’s case. It explains why
there is no present quantitative requirement for a further minerals allocation in the Vale, but it does
not justify a negative or dismissive treatment of Argoed Isha.
BP25 records the RTS2 and Statement of Sub-Regional Collaboration position for the Cardiff City subregion.
Table 5 identifies the Vale of Glamorgan apportionment for crushed rock as 17.05 million tonnes
over 25 years, with existing permitted reserves of 18.73 million tonnes at the end of 2016 and a
minimum allocation needed of 0, alongside 13 million tonnes of additional reserves at dormant sites.
BP25 then states that, based on those figures, the SSRC identifies that the Vale of Glamorgan does not
require any allocations for future workings of crushed rock to be identified within the RLDP.
Based on the Development Plans Manual, when a plan is adopted, there should be at least 10 years of
the plan period remaining.
On the Council’s current timetable, adoption is only anticipated for August/September 2027, and those
post-Deposit stages are expressly identified in the Delivery Agreement as indicative, because they
depend on external factors including the number of representations received and the examination
process. The Deposit Plan runs only to 2036. That means that, even if the Council hits its best-case
programme and adopts in September 2027, the Plan would have only about 8 years and 3 months left
to run. That is already below the DPM expectation of at least 10 years remaining at adoption. Any
slippage would make that position worse.
Based on the current timetable, an end date of 2038 (with associated review of mineral reserves)
would therefore ensure a sound plan.
Notwithstanding our comment in respect of the Plan Period, we remain concerned of how the Plan
should treat a dormant site which the Council accepts has remaining usable reserves and realistic
reactivation potential. Nor does it justify treating Argoed Isha as though it lacked future significance.
The respondent’s case is therefore not that the RTS2 figure is wrong, but that it has been taken too
far. A conclusion that no additional formal allocation is presently required is not the same thing as a
conclusion that the site has no future role.
7. BP25 – the Council’s own minerals evidence
BP25 is the most important local evidence document for present purposes. It records that the Vale of
Glamorgan is an “important supplier of Carboniferous limestone for general aggregate use”. It then
addresses dormant mineral sites in the Vale. Paragraphs 5.48 to 5.50 explain that many dormant sites
have not been worked for many years and are considered unlikely to be worked in the future;
accordingly, the Council intends to serve Prohibition Orders on those sites, which would provide certainty for nearby residents and remove reserves which are not realistically available. BP25 also
explains that the level of reserves at dormant sites is not counted in the landbank.
Crucially, BP25 then distinguishes Argoed Isha from that general class of dormant sites. Paragraph
5.51 states: “While Argoed Isha quarry is classified as ‘dormant’, useable reserves remain at the site
and could be extracted if required.” It goes on to record that a Construction Plant Competence Training
Centre has operated at the site since 2016 and has temporary planning consent until 2030, but then
adds: “While the reserves at the site are not included in the current landbank, they have the potential
to be reworked and therefore a Prohibition Order will not be served at Argoed Isha Quarry until the
current circumstances change.”
That is a very clear evidential conclusion. BP25 does not simply refrain from prohibiting the site
without explanation. It positively explains why Argoed Isha is different: usable reserves remain, they
could be extracted if required, and they have the potential to be reworked. In the respondent’s
submission, that conclusion requires a correspondingly clearer and more positive policy response
within the Deposit RLDP than is presently provided.
BP25 is also supportive on restoration and aftercare. It states that the serving of Prohibition Orders
is intended to provide certainty and, where necessary, restoration of sites may be sought. More
broadly, the background paper recognises the importance of sustainable minerals management and
balancing mineral extraction with environmental protection and community well-being. That policy
background is entirely consistent with the respondent’s case that any future working at Argoed Isha
should be controlled through a modern framework of environmental safeguards and restoration-led
after-use.
8. SWRAWP Annual Report 2024
The SWRAWP Annual Report 2024 is also highly relevant because it warns against over-reliance on
headline landbank figures. Paragraph 4.10 states that “Caution must be exercised in using these
landbank figures” because the calculation does not take account of geographical or operational
aspects that may restrict the availability of certain reserves, nor constraints arising from changes in
planning policy, protected site designation or other non-planning permitting requirements. Paragraph
4.11 then confirms that dormant sites have not been included in landbank calculations and that local
planning authorities should carry out their own assessments of the likelihood of reactivation, but that
in any event “dormant reserves must be counted separately”.
That evidence materially supports the respondent’s case. It shows that the statement “no further
allocations are specifically required” is not, in itself, the end of the analysis. Landbank figures are a
starting point, but they do not tell the whole story. Questions of practical availability, regulatory and
environmental constraints elsewhere, and the separate role of dormant reserves remain relevant.
Argoed Isha therefore retains importance as part of the broader mineral resource picture even though
it is not part of the active landbank.
9. Response to the Council’s candidate site assessment
The Council’s candidate site assessment records that a positive allocation for mineral working is not
included because “the 2nd Review of the Minerals Regional Technical Statement indicates no further
allocations are specifically required to be identified within the Vale of Glamorgan RLDP”. That point
should be addressed directly.
The respondent accepts that the RTS2 position explains why the Council may have concluded that
there is no immediate need for a fresh mineral allocation in quantitative terms. However, that is not a
sufficient reason, on its own, to reject a more positive policy treatment of Argoed Isha or to give the
impression that the site lacks future significance. BP25 itself shows why. It records both that the Vale
does not presently require additional allocations and, separately, that Argoed Isha retains remaining
usable reserves and has the potential to be reworked. Those two propositions are not inconsistent.
They point toward a more nuanced and more accurate conclusion: namely, that Argoed Isha may not need to be allocated now to meet a current numerical shortfall, but it remains a dormant limestone
reserve of continuing strategic relevance that should be positively recognised within the Plan.
That approach is also supported by PPW, MTAN1 and SWRAWP. PPW states that landbanks should
reflect “real possibilities for future mineral working” and that prohibition orders are appropriate where
there is “no prospect of future working”. MTAN1 requires dormant reserves to be separately identified
and assessed so as to achieve “A more realistic landbank assessment”. SWRAWP says that “Caution
must be exercised” in using landbank figures and that dormant reserves must be counted separately.
Those documents all point to a need for a broader planning judgment than simple reserve arithmetic.
Accordingly, the flaw in the candidate site reasoning is not that it refers to the RTS2 position, but that
it appears to stop there. In the respondent’s submission, the sounder and more evidence-based
approach would have been either to give the site more positive recognition in the Plan’s supporting
text, or at the very least to make clear that the site was not allocated because no immediate additional
allocation was required, not because the site lacked merit, availability or future potential.
Moreover, SWRAWP reinforces the point that reserve arithmetic is not the whole picture. It states that
“Caution must be exercised in using these landbank figures” because the calculation does not take
account of geographical or operational aspects, changes in planning policy, protected site
designations or other permitting constraints. This is particularly relevant given the increasingly
important role of NRW licensing and abstraction controls, including quarry dewatering considerations,
which may mean that some reserves are no longer as readily available or economically viable as
historic landbank figures imply. Accordingly, apparent reserve sufficiency in quantitative terms may
overstate the extent of genuinely deliverable supply.
10. The existing temporary training permission does not sterilise the reserve
BP25 states that a Construction Plant Competence Training Centre has operated at the site since 2016
and has temporary planning consent until 2030. The significance of that point is not that the site has
permanently moved away from minerals. The significance is the opposite: BP25 records the temporary
training use while simultaneously concluding that usable reserves remain and may be reworked, and
that a Prohibition Order should therefore not be served.
In planning terms, a temporary training use of this kind cannot properly be treated as sterilising the
mineral reserve. PPW’s safeguarding policy is concerned with preventing sterilisation by permanent
development. A time-limited interim use, particularly one expressly acknowledged in BP25 as coexisting
with a potentially reworkable reserve, does not extinguish the underlying mineral significance
of the site. The temporary training use should therefore be understood as an interim overlay rather
than a permanent change in land use character.
11. Benefits of continued extraction at Argoed Isha Quarry
Continued extraction at Argoed Isha Quarry would give rise to a number of site-specific and strategic
benefits which the Deposit RLDP should recognise when considering the future role of the site.
The site is not a greenfield mineral proposal on an entirely undeveloped site. It is an existing quarry
with a long-established mineral planning history and extant mineral status in principle, subject to
updated modern conditions. The principle of mineral working at the site is therefore already
established in land use terms, and the future reworking of the reserve would represent the
continuation of an existing mineral use rather than the introduction of quarrying into a wholly new
location. That is a material distinction when considering the appropriateness of retaining the site as a
realistic future mineral resource.
Continued extraction would also assist in making use of a proven local limestone resource in the Vale
of Glamorgan, rather than forcing greater reliance on more distant or more constrained sources. BP25
confirms that the Vale is an “important supplier of Carboniferous limestone for general aggregate
use”. In practical terms, continued extraction at Argoed Isha would accord with the proximity principle by helping to meet demand from a comparatively well-located source close to markets in the Vale and
wider Cardiff area, rather than depending unduly on more remote sources or on supply patterns that
may become more constrained over time.
The site would also contribute to the resilience and flexibility of the wider minerals supply position.
Even if no immediate additional allocation is numerically required under RTS2, national and regional
policy make clear that landbank figures are not the only relevant consideration. A dormant quarry with
remaining usable reserves provides contingency, flexibility and productive capacity in the event that
supply circumstances change during the plan period. This is especially important where SWRAWP
warns that landbank figures do not capture geographical, operational, policy or other permitting
constraints, and where MTAN1 requires a realistic view of reserves with future potential. Argoed Isha
therefore has value not merely as a theoretical reserve, but as part of a resilient longer-term supply
position.
Continued extraction at Argoed Isha would also support local supply chains and a more diverse
quarrying sector. The candidate site submission identified the benefit of maintaining provision from a
range of operators, including smaller and medium-sized businesses, rather than relying only on a
limited number of larger established sites. In planning terms, that diversity is relevant to continuity of
supply, competition, responsiveness to local demand and the overall resilience of the minerals sector
in the Vale and wider region.
A further benefit is that any future extraction would be carried out under modern planning control
rather than being left sterilised or underused. If the site is reworked in future, that would necessarily
be through a fresh scheme of modern conditions and under the policy framework of the RLDP and
national minerals policy. Issues such as traffic, hydrology, hydrogeology, ecology, landscape, amenity,
blasting, dust, restoration and long-term aftercare would all be capable of being addressed through
a contemporary planning and environmental control regime. That is an important benefit in itself,
because it means any future extraction would not take place under outdated historic controls, but
under a modern framework designed to secure sustainable mineral working.
Continued extraction would also create the opportunity for a comprehensive restoration and aftercare
strategy delivering environmental gains. PPW recognises that restoration and aftercare proposals for
inactive sites may include natural re-vegetation for nature conservation and ecological interests.
BP25 records that restoration may be sought where necessary. In practice, any future extraction
proposal at Argoed Isha could be accompanied by a restoration-led scheme involving landform
improvement, habitat creation, ecological enhancement and long-term stewardship. The site should
therefore not be seen simply as a mineral reserve, but as a place where carefully managed extraction
could unlock biodiversity, landscape and geodiversity benefits over time.
The site also represents the productive use of an underutilised brownfield quarry. The candidate site
material identifies it as a brownfield / underutilised site. In land use terms, there is a clear logic in
making effective use of an existing quarried landscape with established mineral status, rather than
placing additional pressure on wholly undeveloped land elsewhere. In this case, the Council’s own
evidence confirms the key factor: usable reserves remain and the site has the potential to be
reworked.
There is finally a longer-term safeguarding benefit in recognising the case for continued extraction.
PPW requires mineral resources to be safeguarded to prevent sterilisation by permanent
development, and makes clear that landbanks should reflect “real possibilities for future mineral
working”. Positive recognition of the benefits of continued extraction at Argoed Isha is therefore
entirely consistent with the basic objectives of national minerals policy: prudent use of finite mineral
resources, maintenance of flexibility in supply, and avoidance of circumstances in which sites with
genuine future potential are prematurely written off.
12. Restoration, aftercare and biodiversity gain
The respondent’s case is not simply that Argoed Isha should be recognised as a future mineral source.
It is also that any future reworking can and should be subject to a modern restoration-led scheme
capable of securing environmental gains.
PPW contemplates restoration and aftercare proposals for inactive sites, including natural revegetation
for nature conservation and ecological interests. BP25 records that, where necessary,
restoration may be sought at dormant sites. The candidate site material also identifies that the site is
not close to internationally or nationally important wildlife sites, while noting the presence of existing
ecological and geological interests that could be appropriately managed through buffers, mitigation
and future planning controls. These are precisely the kinds of circumstances in which a carefully
designed extraction and restoration scheme could deliver meaningful biodiversity and geodiversity
benefits alongside the prudent working of the remaining mineral resource.
Future working at Argoed Isha should therefore not be viewed in binary opposition to environmental
enhancement. The modern policy framework envisages integrated mineral development in which
extraction, restoration and aftercare are part of a single coherent process. That is an additional reason
why the Plan should positively recognise the site’s continuing potential rather than leaving it in a policy
grey area.
13. Overall conclusion
The evidence base points clearly to a more positive and more coherent treatment of Argoed Isha than
is presently provided in the Deposit RLDP.
PPW says that landbanks should reflect “real possibilities for future mineral working” and that
prohibition orders are appropriate where there is “no prospect of future working”. MTAN1 requires a
separate assessment of “dormant reserves” and seeks “A more realistic landbank assessment”.
SWRAWP states that “Caution must be exercised in using these landbank figures”. BP25 records that
“useable reserves remain at the site and could be extracted if required” and that they “have the
potential to be reworked”. The Development Plans Manual requires plans to be based on robust
evidence and to be deliverable.
Against that background, the Council’s reliance on the proposition that the RTS2 indicates no further
allocations are specifically required does not dispose of the issue. It may explain why there is no
immediate need for a fresh mineral allocation, but it does not justify a passive or dismissive treatment
of Argoed Isha. The more sound and evidence-based approach is to recognise that, whilst no additional
formal allocation is presently required, Argoed Isha remains a dormant limestone quarry with usable
reserves and realistic future reactivation potential, capable of coming forward in future under modern
policies for sustainable working, restoration and aftercare.
14. Summary
These representations contend that, whilst the Deposit RLDP minerals strategy is broadly supported,
the Plan is unsound in part in its treatment of Argoed Isha Quarry. In particular, the objection goes
principally to whether the Plan is justified by the evidence and whether it is effective in delivery. The
objection also concerns consistency with national minerals policy to the extent that the Deposit RLDP
does not fully reflect PPW and MTAN1 in positively planning for the safeguarding and potential future
working of this identified limestone resource.
 Strategic Policy SP18 – Minerals Supply and Safeguarding: Support in part / Object in part.
The respondent supports the overarching strategy of maintaining a continuous supply of
minerals, safeguarding mineral resources and avoiding sterilisation. However, objection is
taken insofar as the strategy does not carry through the Council’s own evidence that Argoed
Isha retains usable reserves and future potential for reworking.
 Policy MIN1 – Mineral Safeguarding Areas: Support.
This policy is supported because it reflects national policy by safeguarding limestone resources from permanent development that would sterilise them or hinder future extraction.
That approach is directly relevant to Argoed Isha, which remains a safeguarded resource with
extant mineral significance.
 Policy MIN2 – Quarry Buffer Zones: Support.
The principle of protecting mineral operations from encroachment by incompatible
development is supported. If Argoed Isha is to remain a realistic future source of limestone,
the Plan should continue to avoid prejudice to its potential reactivation.
 Policy MIN3 – Dormant Mineral Sites: Support in principle / Object in part.
The respondent supports the Council’s decision not to serve a Prohibition Order at Argoed
Isha. That is plainly the correct approach because BP25 confirms that usable reserves remain
and may be reworked. However, objection is taken to the absence of stronger wording
recognising that the site remains a realistic future source of limestone.
 Policy MIN4 – Sustainable Mineral Working: Support in principle.
The respondent supports the policy framework for future reworking or reopening of old
workings, including the need for acceptable impacts, restoration and beneficial after-use.
Argoed Isha is capable of being assessed under that type of modern policy framework.
 Supporting text to the dormant quarry provisions / paragraph 6.386 equivalent approach:
Object in part.
The Plan is correct to recognise that the reserves at Argoed Isha could be reworked in future.
The objection is that this conclusion is not carried through into a fuller and more positive
policy narrative.
 Plan Period: Object.
Amend in line with the Development Plans Manual such that there are at least 10 years
remaining at adoption.
 Candidate Site 411 – Argoed Isha Quarry: Object.
The respondent objects to the candidate site assessment insofar as the site appears to have
been rejected solely or mainly because RTS2 indicates that no further allocations are
specifically required. That is too narrow an approach and does not properly reflect PPW,
MTAN1, SWRAWP or BP25’s conclusion that usable reserves remain and may be reworked.
 Minerals Background Paper BP25: Support in part / Object in part.
BP25 is supported where it correctly records that Argoed Isha is dormant, that usable
reserves remain, and that the site has the potential to be reworked. Objection is taken only
insofar as the Deposit RLDP does not fully reflect the implications of that evidence in a more
positive and coherent plan-led position.
 Temporary training use: Clarificatory comment in support of the representation.
The current training use does not sterilise the limestone reserve. BP25 records the temporary
training use until 2030 while also confirming that usable reserves remain and that the site
may be reworked. It should therefore be treated as an interim use only.
 Benefits of continued extraction at Argoed Isha: Positive material consideration.
Continued extraction at Argoed Isha would make productive use of an existing dormant quarry
with remaining usable reserves, support local and sub-regional limestone supply from a Vale
source, contribute to flexibility and resilience in the minerals strategy, and enable future
working to proceed under modern planning controls with restoration, aftercare and
biodiversity enhancement.
 Overall position on the Deposit RLDP minerals strategy: Support in part / Object in part.
In overall terms, the respondent supports the Deposit RLDP’s general minerals framework.
The objection is a precise and limited one: the Plan should more clearly and positively recognise Argoed Isha as a dormant quarry with usable reserves, realistic reactivation
potential, and scope for a future scheme of continued extraction and restoration, such that the Plan is properly justified by its evidence base and effective in delivering a resilient minerals strategy over the plan period.