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.

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 We have major concerns over the reliance on outdated reserve information and the evidence base must reflect up to date reserve and sales statistics, together with projected demand for major developments.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 site at Swn Y Coed should be removed from the
safeguarding area.

1. INTRODUCTION
1.1 These representations build upon the responses previously provided to the Call for Sites Consultation, additional information submission, and more recently the Barry Growth Paper in July 2025. For the avoidance of doubt these representations relate to Barratt Redrow Homes’ land interest know as ‘Swn Y Coed, Wenvoe’. The site has previously been identified as Ref No 437 within the Council’s Candidate Site Assessments including the Preferred Strategy Stage, which has been published as part of the technical evidence base and background papers alongside the Deposit Plan.
1.2 Having reviewed the Deposit Plan it is evident that the document is structured around a number of key sections including:
• Section 3 – The Vale of Glamorgan Key Characteristics;
• Section 4 – RLDP Key Themes, Vision, and Objectives;
• Section 5 – Sustainable Growth Strategy; and
• Section 6 – Policy Framework.

1.3 For completeness this submission shall discuss each section in turn.
1.4 The overarching purpose of which shall be to respond to the relevant draft Replacement Local Development Plan policies, with particular consideration given to the Welsh Government’s tests of soundness as set out within the Development Plan Manual for Wales (Third Edition) March 2020)):
• Test 1 – Does the Plan Fit?
• Test 2 – Is the Plan Appropriate?
• Test 3 – Will the Plan Deliver?

2. THE VALE OF GLAMORGAN KEY CHARACTERISTICS
Settlement Pattern
2.1 Barratt Redrow support, in principle, the Settlement Pattern as set out in Section 3 of the Deposit Plan and in particular the identification of Wenvoe as a Primary Settlement.
2.2 Paragraph 3.9 explains that primary settlements “offer several key services and facilities, which are vital to their role as sustainable communities, as they reduce the need to travel to Barry or the Service Centre Settlements to address day-to-day needs”.
2.3 The importance of the Primary Settlements in supporting the Service Centre Settlements is noted, however Barratt Redrow consider that Wenvoe, in particular, is capable of a higher role and function and can accommodate a higher level of growth over and above affordable led exception sites, which can be accommodated at Candidate Site Ref. No 437. This is particularly relevant given the fact that the Service Centres at Cowbridge, Llantwit Major and Penarth are generally more constrained physically and environmentally.
Housing Need
2.4 In light of the Vale of Glamorgan’s strategic location in-between Cardiff and Bridgend, and the significant employment opportunities associated with these areas, the Deposit RLDP should seek to maximise housing provision to ensure a more sustainable balance is achieved between homes and jobs, and in turn reduce commuting distances/ carbon emissions.
2.5 Paragraph 3.18 clearly acknowledges the scale of affordable housing need, identifying a requirement for 1,075 affordable homes per annum between 2023–2028 and 154 per annum thereafter. Yet it remains unclear whether existing unmet need has been fully factored into the overall housing requirement presented within the Deposit RLDP. This is particularly importance in the context of the Welsh Government’s 2025-based estimates which identify 9,400 units of unmet need at a national level and a requirement for 8,700 additional homes per annum over the next five years simply to address newly arising need.
2.6 Accordingly, there is a compelling justification for a further uplift in housing numbers to ensure the Plan proactively addresses both existing and emerging need. Increasing the overall housing requirement would directly enhance the overall delivery rate for affordable homes which is crucial in a local authority area with the highest affordability ratio in Wales. Paragraph 3.17 confirms that in the Vale average house prices are 9.7 times average workplace earnings compared to the Wales average of 6.1, therefore a step change in housing targets is needed to support a more balanced housing market across the region.
3. RLDP KEY THEMES, VISION, AND OBJECTIVES
3.1 Section 4 of the Deposit RLDP sets out the Council’s vision over the emerging plan period. The vision establishes a series of strategic goals the Council intends to work towards and in doing so provides an insight into how the Vale of Glamorgan is envisioned to develop up to 2036.
Key Themes
3.2 Barratt Redrow supports the theme ‘Homes for all’ and the need for the housing supply to respond to the growing population and provided in appropriate locations, with a mix of tenure and types. In that respect the site at Swn Y Coed, Wenvoe offers a sustainable and deliverable opportunity to ensure future residential development aligns with such objectives to deliver high quality housing development in a sustainable location.
3.3 In principle, Barratt Redrow support the ‘Placemaking’ theme and consider that development in Swn Y Coed, Wenvoe would ensure a strong sense of identity and that the scheme is capable of providing a well designed and sustainable development.
3.4 Barratt Redrow also support the theme of ‘Promoting active travel and sustainable transport choices’, and in particular the need to ensure that the new development will be in a highly sustainable location with very good access to alternative transport, such as bus services, rather than a reliance on the rail network. This is clearly evident at Swn Y Coed, Wenvoe.
Vision
3.5 In general, Barratt Redrow support the RLDP Vision, however highlight that whilst Barry and other Sustainable Service Centres are identified as playing a vital role in delivering the strategy, the importance of the ability for Primary Settlements, such as Wenvoe, to deliver sustainable and high-quality residential development also needs to be suitably recognised.
3.6 The allocation of Swn Y Coed (Candidate Site Ref: 437) is capable of providing a comprehensive residential development in a highly sustainable location and within an important Primary Settlement. The principle of which aligns with the Council’s ambition to ensure future growth delivers homes which caters for all (including affordable homes) and are prioritised in areas of greatest demand.
3.7 In light of the above it is considered that Wenvoe plays a significant part in delivering the Council’s strategy and the role, function, and ability of this settlement to accommodate growth needs to be significantly reinforced. The settlement is capable of accommodating more growth in a highly sustainable location we believe warrants greater recognition within the vision itself.
Strategic Objectives
Objective 3 – Home for All

3.8 Barratt Redrow supports the principle of Objective 3, in particular the provision of high quality housing which includes the right mix, tenure and type. Barratt Redrow supports the notion of providing residential development in places which people want to live, and in particular Wenvoe as a Primary Settlement.
Objective 4 – Placemaking
3.9 As above, in principle Barratt Redrow support the Council’s placemaking objectives which seeks to ensure all development will contribute positively toward creating a sense of place. Most notably this involves prioritising future growth in sustainable locations which are placed to create attractive, safe and accessible schemes that are equally effective from a functional standpoint.
3.10 The proposed allocation at Swn Y Coed (Ref 437) at Wenvoe aligns with such principles whilst also providing an opportunity to facilitate a high quality, mixed tenure residential development of circa 80+ open market & affordable homes, with a high-quality distinct character responding to the site context and creating a sense of place.
Objective 8 – Promoting Active and Sustainable Travel Choices
3.11 Barratt Redrow supports the principle of promoting active and sustainable travel choices and highlight that their residential development at Wenvoe has been designed to ensure accessibility it’s at the heart of the scheme with regards to walking, cycling and connectivity to public transport.
3.12 Given the site abuts the defined urban area of Wenvoe it represents a logical extension to the existing settlement and is well served by a range of local amenities and public transport. In terms of the latter the nearest bus stop is located within 100 meters of the site whilst the majority of local amenities are situated within 1.2 kilometres walking distance. Together these factors naturally promote the principle of linked trips which fully accords with the Chartered Institution of Highways and Transportations (CIHT) guidelines and reinforces the fact the site is a sustainable location for residential development.
3.13 Therefore, the site provides an opportunity to promote a modal shift towards more active forms of travel and consequently reducing dependency on private vehicle and associated carbon emissions. From a plan-making standpoint allocating further growth in this highly sustainable location would help achieve greater connect at both a regional and local level.

4. SUSTAINABLE GROWTH STRATEGY
Growth Strategy
4.1 RLDP Sustainable Growth Strategy comprises six key elements as follows:
1. Delivering a sustainable level of housing and employment growth supported by appropriate infrastructure that accords with the Vale’s position within the Cardiff Capital Region (CCR).
4.2 In order to meet the overarching Vision, the Vale have identified a need to deliver at least 8,679 new dwellings over the proposed plan period which responds to the identified housing requirement of 7,890 homes (526 per annum) and incorporates a 10% flexible allowance. Barratt Redrow acknowledge the proposed approach, however, maintain it should be considered a minimum figure with aspirations to achieve greater levels of growth in sustainable locations across the district.
4.3 Whilst Barratt Redrow appreciate these figures are based on average completion rates over the first ten years of the adopted Local Development Plan, it is important to recognise that a higher rate of housing delivery is demonstrably achievable. Annual completion rates peaked at 917 dwellings, with six of the ten monitoring years exceeding the 526 per annum figure currently relied upon. This demonstrates that delivery capacity within the Vale has historically operated well above the proposed requirement and should therefore provide confidence that a higher housing target could realistically be achieved over the emerging plan period.
4.4 Furthermore, the Council’s own evidence base (BP7 - Housing and Employment Growth Options) identifies a five-year average build rate of 780 units per annum between 2016 and 2021. Again, this figure exceeds the annual delivery rate currently proposed within the emerging RLDP and reinforces the fact that the proposed housing requirement should not be unduly constrained by a lower long-term average.
4.5 Whilst Paragraph 5.8 explains that the proposed figures are based on a ten-year average delivery rate, it fails to acknowledge that this period included the Covid-19 pandemic and at a time where construction costs experienced significant inflation. These factors had a material impact on the housebuilding industry nationally and inevitably suppressed delivery rates during those years. From an objective perspective, basing the future housing requirement on an average that includes these exceptional circumstances risks skewing the figures and underestimates the district’s true delivery potential for the Vale.
4.6 In light of the above Barratt Redrow believe a sensible response would be to incorporate a greater flexible allowance of 15% within the RLDP to demonstrate an appropriate level of growth will be achieved. Whilst also ensuring there is sufficient supply of sites to come forward early on during the plan period to proactively address housing need from the point of adoption up to 2036.
4.7 From a procedural standpoint it is also important to note that the currently adopted plan predates the publication of Future Wales: The National Plan 2040 and the Vale’s position within a national growth area. As such, pursuing an approach which seeks to maintain historic delivery rates is not considered to reflect this enhanced role and arguably lacks the level ambition set out at a national level. The proposed housing requirement should therefore be uplifted to positively respond to such matters in order to ensure conformity with Future Wales and regional aspirations.
4.8 Increasing the overall housing target would also act as a catalyst to enhance the delivery of affordable housing which is identified as a key objective for the RLDP. Each proposed site allocation is subject to a policy-compliant percentage contribution, therefore a higher level of market housing would proportionately generate a greater number of affordable homes to meet local need across the region.
2. Aligning locations for new housing, employment, services and facilities to reduce the need to travel.
4.9 Barratt Redrow supports the Vale’s objective to locate new major development in areas of the region best served by existing infrastructure and supporting services. The Settlement Appraisal Review (BP5) identifies Wenvoe as primary settlement in the region with suitable local services to accommodate future growth which remains in keeping with the overall function of the existing settlement.
4.10 Whilst the settlements of Barry, Penarth, Llantwit Major and Cowbridge are deemed to score higher on certain criteria it is clear that Wenvoe has a role and function providing both local key facilities and also acceptable linkages and distance to wider key and daily facilities.
3. Focusing development at locations that are well served by existing and proposed rail stations as part of the South Wales Metro and in areas with good bus links.
4.11 The Deposit RLDP explains that whilst reducing the need to travel is a key policy objective, it is recognised that there are journeys that will need to be made by other modes of transport, particularly due to the strong relationship with Cardiff as a designation for employment, retail and entertainment. As such the proposed growth strategy seeks to locate development in places that are inherently well served by sustainable transport in line with the Vale of Glamorgan’s transport hierarchy.
4.12 Barratt Redrow supports these principles and recognises the importance of prioritising development in sustainable locations across the regions, particular those well connected to Cardiff city centre. Paragraph 5.18 of the Deposit Plan states that “Targeting new development to the settlements that are served by the rail network is a key part of the strategy, as it will facilitate journeys being made by means other than the car”. Barratt Redrow consider that the rail network is an important way to facilitate journeys other than by car, however it is not the only option available and that other sustainable sites, such as Swn Y Coed, are also accessible by public transport – namely bus services.
4.13 Whilst Barratt Redrow support the principle of prioritising growth within the Council’s sustainable transport corridor, it is important to recognise that there is not an infinite supply of land within close proximity to railway stations across the Vale of Glamorgan. Physical constraints, settlement patterns and environmental designations mean that the availability of suitable and deliverable sites within immediate walking distance of rail infrastructure is somewhat limited. Therefore, relying solely on these locations risks unnecessarily constraining the overall supply of land for housing and may limit the Council’s ability to maintain a consistent supply of homes up to 2036.
4.14 In this context, Barratt Redrow believe the RLDP should be updated to also identify opportunities for growth in locations that are well served by the strategic bus network. From a procedural standpoint this approach would remain consistent with the overarching objective of a transport-orientated growth strategy, whilst recognising the wider role bus corridors can play in facilitating a sustainable pattern of development. The benefits of which would provide greater certainty that local housing needs can be met over the proposed plan period and in turn strengthen the council’s ability to demonstrate the plan has been soundly prepared.
4.15 By directing development to locations well served by existing bus infrastructure, the proposal would help reduce the need for commuting via private vehicles, particularly for journeys to key employment and service destinations. In doing so, it would make a positive contribution towards the Council’s climate change targets through the reduction of carbon emissions and promoting a modal shift within the local community.
4.16 In relation to Swn Y Coed, bus stops are conveniently located at Walston Castle and Station Road approximately 95m and 440m from the site off the A4050, providing regular services to Cardiff City and surrounding settlements.
4.17 Furthermore, to the north of the site Culverhouse Cross is easily accessed by cycling, walking or via bus routes which can be caught just 100m east of the site. Culverhouse Cross Retail Park has an extensive range of facilities and employment opportunities that are within 2km of the site (easy walking and cycling distance).
4.18 Overall, it is considered that the site is in a relatively sustainable location and is within easy walking distance of public transport and Wenvoe village centre, which provides some basic facilities approximately 600m south of the site. For the reasons set out above, the site is considered to offer an opportunity for residential development in a suitable location that would facilitate and encourage sustainable travel, with no major highway related concerns.
4.19 Focussing further growth in well-connected, sustainable locations such Wenvoe will therefore support the Council’s transport-led placemaking approach. These principles fully align with the Welsh Governments strategic objectives as set out within the Future Wales – the National Plan 2040, Planning Policy Wales Edition 12 and Llwybr Newydd: The Wales Transport Strategy, which in turn shall contribute towards achieving a more sustainable pattern of development within the RLDP.

5. POLICY FRAMEWORK
5.1 Section 6 of the Deposit Plan outlines the policy framework for delivering the plan, including both Strategic and Development Management Policies following revisions pursuant to the Preferred Strategy consultation.
5.2 The Deposit Plan has arranged these policies into the four themes of Planning Policy Wales as follows:
• Strategic and Spatial Choices
• Active and Social Places
• Productive and Enterprising Places
• Distinctive and Natural Places
5.3 Whilst some of the technical details overlap, each of the policies considered to be of relevance are discussed in further detail below.
Policy SP1 – Sustainable Growth Strategy (& Policy SP6 – Housing Requirements)

5.4 This policy states that in order to deliver the Sustainable Growth Strategy for the Vale, the emerging RLDP will make provision for 7,890 dwellings and 5,338 jobs over the plan period. In order to achieve the former Policy SP6 explains that to meet the identified housing requirement of 7,890 dwellings, provision will be made for the delivery of 8,660 homes in the Plan Period 2021 to 2036 which incorporates a 10% flexible allowance. In turn this will be distributed as follows: i) 3,837 dwellings from the existing land supply; ii) 3,520 dwellings on allocated sites; & iii) 1,303 dwellings from large and small windfall developments.
5.5 Barratt Redrow acknowledge the Council’s conclusion that in principle the ‘Medium’ growth option reflected in Policy SP1 generally accords with the Welsh Government’s aspirations for the Vale of Glamorgan within the Future Wales national growth area, which is identified as a focus for strategic economic and housing growth. Given the Vale forms part of the Cardiff Capital Region, it is equally important that the overall level of growth remains suitably ambitious to support the region’s economic aspirations and continues to complement Cardiff which remains the nearest neighbouring authority.
5.6 Although we understand the proposed approach uses the Dwelling-led 10 Year scenario, which is based on the average annual build rate for the first 10 years of the adopted plan and equates to a total of 7,890 new homes or 526 dwellings per annum over the emerging plan period. The overarching intention is to ensure the projected level of growth is deliverable whilst recognising the fact there is sufficient capacity within the Vale to support further growth towards the higher end of the ‘medium’ range.
5.7 As noted, Barratt Redrow are wholly in support of providing additional sites, such as Swn Y Coed, Wenvoe, which would provide a logical extension to the defined urban area of Wenvoe and which will facilitate the delivery of much needed full market and affordable housing to help address the significant level of demand identified across the Vale.
5.8 Swn Y Coed is promoted in the context of the concerns raised regarding the current figure of 8,660 new dwellings which is underpinned by a 10% flexible allowance in relation to housing delivery. Barratt Redrow consider it relevant to take account of recent evidence provided to other Local Planning Authorities in Wales which have either adopted or are in the latter stages of bringing forward a new Local Development Plan.
5.9 For example, in Bridgend the Council recently adopted their new Local Development Plan (covering the period 2018 to 2033) which is underpinned by a flexibility allowance of 14% equating to an additional 1,053 dwellings. This level of provision was required in order to demonstrate the Anticipated Annual Build Rate (AABR) were deliverable and ensure that the Plan remains effective in the event of changing circumstances. During the examination process the Inspector explained that an increase beyond the standard 10% was fundamental to enable the plan and its housing trajectory to be resilient and sufficiently adaptable. The overarching purpose of which is to account for any unforeseen changes and potential shortfalls/ delays to the strategic site allocations whilst still enabling the overall housing requirement to be delivered.
5.10 For Swansea, the Council published their LDP2 Pre-Deposit Plan (Preferred Strategy) for consultation last year. In terms of housing delivery this incorporates a 20% flexible allowance above the proposed housing requirement and is predicated on the basis of needing to account for certain sites not coming forward as anticipated and other unforeseen factors affecting delivery. Similar to the Vale, Swansea City Council’s latest Annual Monitoring Report (6th Edition) (October 2025) confirms that since adoption of the current LDP in February 2019 they have not met their annual housing target for any of the past six years. To date this has resulted in a shortfall of approximately 3,767 homes which is predominantly attributed to delays associated with larger strategic allocations. Therefore, in order to avoid having similar implications next time around the Council have uplifted the proposed flexible allowance within LDP2 and intend to incorporate a more diverse portfolio of sites going forward. The main purpose of which is to build in an additional margin of flexibility above the standard 10% threshold and therefore enable other sites to come forward to account for potential slippage elsewhere to ensure the plan is effective in meeting local need.
5.11 More recently in Monmouthshire, the Council submitted their proposed RLDP to PEDW in November 2025. As part of which they have identified a requirement of 6,210 homes which incorporates a 15% flexible allowance. Similar to above an increase beyond the standard 10% threshold has been justified to account for potential shortfalls/ delays due to longer lead in times needed for strategic site allocations whilst proactively addressing any historic unmet need.
5.12 Whilst Barratt Redrow appreciate that the Council intends to prioritise growth towards the higher end of the ‘medium’ range, having reviewed the Deposit Plan evidence base Barratt Redrow believe a minimum allowance of 15% would be more reflective of the Vale’s strategic position and would seek an additional 395 dwellings to the medium growth option equating to a total of 9,074 homes. The benefits of which are evident above and justification well-established from a plan-making perspective to ensure the RLDP is underpinned by a robust evidence base which incorporates a suitable level of flexibility to effectively meet local housing need from the outset.
5.13 In addition to the above the importance of increasing the RLDP’s housing target, by virtue of uplifting the proposed flexible allowance, has recently been highlighted by the findings of data published by the Welsh Government (WG). Most notably that includes the 2022-based Local authority household projections (Dated 20th November 2025) and 2025-based estimates of additional housing need (Dated 12th February 2026).
5.14 Upon publishing the former superseded the previous 2018-based demographic projections and provides updated figures from mid-2022 to mid-2032. The results show that whilst the overall number of households in Wales is projected to increase by around 98,500/ 7.2%, to a total of 1.46 million. The local authorities projected to see the largest percentage increases are the Vale of Glamorgan (up 11.7%) and Cardiff (up 11.1%).
5.15 In turn these trends are carried through into WG’s 2025-based estimates of additional housing need, which identifies an existing unmet need of 9,400 homes. This is supplemented by a requirement to deliver an average of 8,700 new homes annually over the next five years to account for newly arising need alone. The combination of which demonstrates that there is an urgent need to increase delivery rates on both a national and local level, and therefore it’s imperative that the latest position with regards to the need for affordable and full market homes are accurately reflected within the Council’s housing figures.
5.16 In terms of considering the level of housing provision for a plan, Paragraph 5.34 of the DPM is explicit in that the most up-to date suite of Welsh Government Population and Household Projections must form the foundation of any evidence base. LPAs are then required to use a household conversion factor when translating households to dwellings to establish overall need. Once again, the DPM explains that failure to include a robust conversion rate from the outset is a high-risk strategy and may undermine the overall soundness of any emerging plan. To avoid such circumstances, we believe it’s essential the LMNA is updated to reflect the latest WG datasets, which in turn is likely to provide grounds to warrant extending the proposed 15% threshold further. Ultimately this approach intends to ensure the emerging RLDP more effectively meet local need over the entire plan period and thus soundly prepared.
5.17 As mentioned above, Policy SP6 provides a high-level breakdown of how the Council’s housing growth is expected to be delivered over the plan period. For completeness this includes: i) 3,837 dwellings from the existing land supply; ii) 3,520 dwellings on allocated sites; & iii) 1,303 dwellings from large and small windfall developments.
5.18 Whilst we do not dispute those relating to proposed site allocations and/ or windfall developments. The proportion of dwellings set to be accounted for within the Vale of Glamorgan’s existing landbank (3,837 units) is considered excessive given it represents 44.3% of the Council’s overall housing requirement.
5.19 Although Barratt Redrow acknowledge that this is partly derived on the basis that emerging plan period has technically already commenced (2021 to 2036) and therefore is made up of


Figure 2. Extract of the Welsh Government’s Calculation Method for Total Dwellings as per the Development Plan Manual Vale of Glamorgan Deposit Plan Representations | Swn Y Coed, Wenvoe – Site 437


sites at various different stages of planning process (i.e. either already built out, being constructed or secured consent - as shown below). It is important to recognise the potential implications this approach has in terms of stifling opportunities for growth, which is contrary to the Welsh Government’s aspirations for the Vale of Glamorgan as part of a National Growth Area within Future Wales: The National Plan 2040.
5.20 From an objective standpoint this means there is only a need for 2,561 additional dwellings (3,520 dwellings minus 959 units rolled forward) to be delivered from new allocations over the emerging plan period. This reinforces the point that in reality the overall quantum of new homes will be significantly lower than the figure set out within the RLDP’s vision and strategic objectives. In turn this prevent opportunities for new sites to come forward as part of the plan-making process and in doing so hinder the Council’s ability to account for historic unmet need. Collectively this substantiates Barratt Redrow’s position that in order for the plan to be considered sound the Council must accommodate a greater flexible allowance, optimising sites such as Swn Y Coed, Wenvoe, to ensure the emerging local plan complies with the Welsh Government’s aspirations set out within Future Wales.
5.21 As illustrated above, the Council anticipate 1,303 dwellings coming forward in the form of windfall sites. This accounts for both small and large sites which in turn represents around 15% of the Council’s overall housing requirement. Once again, whilst we do not contest the overall windfall provision or the projected delivery rate of 87 dwellings per annum up to 2036. It is important to recognise that based on past trends the annual number of homes which comes forward on windfall sites varies significantly year on year.
5.22 Table 18 of the Development Plan Manual is explicit in that respect and explains that although due regard must be attributed to analysis of past delivery rates, periods of abnormally high or low completions should be considered inappropriate/anomalies when extrapolating future rates of windfall sites. On that basis ensuring the RLDP incorporates a greater flexible allowance will not only provide certainty that any shortfalls/fallow periods are offset but also enable a more consistent supply of homes to be achieved over the plan period as a whole.
5.23 Lastly, in terms of overall growth Paragraph 5.8 of the Deposit Plan states that the level of growth they have identified ‘’has been demonstrated to be deliverable and is sufficiently ambitious to reflect the Vale’s position in the Future Wales national growth area.’’ It also notes that this level of growth has been chosen so that it is ‘’complementary to, rather than competing with, the neighbouring authority of Cardiff and the wider Cardiff Capital Region (CCR).’’.
5.24 Whilst it is agreed that the level of growth may be realistic based on past trends, the claim that this is sufficiently ambitious and needs to be at this level to avoid competing with Cardiff is not substantiated by evidence to suggest that a higher level of growth could not also achieve these principles.
5.25 Cardiff, as the capital city of Wales, also demonstrated historic under delivery when publishing its deposit plan for consultation in February 2025, which was the case for allocated sites as well as generally for annual delivery rates over the adopted plan period. This resulted in a failure to meet targets over the last 10 years of their adopted plan. Whilst Cardiff has made progress in more recent years, the latest Annual Monitoring Report published in October 2025 notes that to date the region has met just 58% of its overall dwelling requirements over the plan period from 2006-2025.
5.26 Accordingly, with Cardiff opting to continue with a medium growth option for their RLDP despite these shortfalls, there is no sound basis to suggest that adopting a higher growth level within the Vale would detrimentally impact upon housing delivery or ‘compete’ with Cardiff.
5.27 In summary, Barratt Redrow acknowledge the overall medium growth strategy, however given the Vale’s position within the Cardiff Capital Region and its designation as a national growth area, Barratt Redrow maintain that the proposed RLDP should be more ambitious when it comes to housing targets. Drawing on examples from Bridgend (14% flexibility), Swansea (20%), and Monmouthshire (15%), alongside evidence of historic under-delivery and recent Welsh Government household projections, there are sufficient grounds to warrant increasing the proposed flexibility allowance to a minimum of 15%, equating to a total requirement of 9,074 homes up to 2036.
5.28 These steps would help account for any potential overreliance on existing landbanks and variable windfall delivery rates which could in theory limit the plan’s ability to address unmet housing need. Overall, we conclude that a higher flexibility allowance and additional site allocations, such as Swn Y Coed, Wenvoe, are necessary to ensure the RLDP is able to effectively meet local need over the plan period. The benefits of which shall also demonstrate the emerging RLDP is supported by a robust, proportionate and credible evidence base to accord with the requirements of the Development Plan Manual for Wales and national growth objectives.
Policy SP2 – Settlement Hierarchy
5.29 Policy SP2 highlights that development will be focused with the Strategic Growth Area and that its distribution will be shaped by settlement hierarchy and seeks to direct ‘growth to locations that will provide the greatest opportunities for delivering housing to meet affordable needs, community infrastructure and enhanced sustainable transport provision’.
5.30 Accordingly, despite Wenvoe being identified as a primary settlement, Policy SP2 notes that development in this location will be limited to ‘the efficient and sustainable use of existing buildings, infill opportunities, small-scale affordable housing led schemes, and rural enterprise/ agricultural related developments.’ Similarly, it is noted that Policy SP2 does not consider Wenvoe to be an appropriate location for ‘’substantial additional growth’’.
5.31 Barratt Redrow object to the approach to Primary Settlements as set out under this Policy, as Wenvoe is inherently sustainable and the explanation for discounting it as an area to accommodate growth is considered unjustified.
5.32 First of all, the Deposit Plan acknowledges that it performs a similar function to the Primary Settlements located within the Strategic Growth Area and it is described as one of the ‘sustainable communities’ in The Vale of Glamorgan Key Characteristics section, as noted previously in Section 3.
5.33 Likewise, the site benefits from excellent accessibility the local public transport network, active travel routes and local services. These characteristics fully accord with Welsh Government’s strategic objectives and emphasise the fact that Swn Y Coed constitutes an appropriate location for future housing.
5.34 With regard to Policy SP2 discounting Wenvoe as a location to accommodate growth, this is due to the Vales’s stance that the settlement is ‘’significantly limited by the presence of Best and Most Versatile (BMV) agricultural land on the edge’’. Barratt Redrow do not consider this to be sufficient justification to discount the site from allocation as there would be limited impact on BMW agricultural land arising from the development of Swn Y Coed.




5.35 For example, as set out in the ALC report prepared by Kernon CCL and provided as part of the Candidate Submission Ref 437, the highest grade on site would be Subgrade 3a, with the site comprising a mix of Subgrades 3a and 3b. This means that in National Policy terms, development of the site would be in accordance with paragraph 3.59 of PPW 12 as the lowest grade available.
5.36 Furthermore, any perceived harm in terms of agricultural land is not considered to outweigh the benefits brought by the development in terms of contributing to both affordable and market housing need over the plan period, not least given the historic shortfalls identified earlier in this submission.
Policy SP4 - Placemaking
5.37 Policy SP4 is recognised as a key Policy in the emerging RLDP to ensure that new proposals align with existing communities and placemaking principles across the county.
5.38 Policy SP4 also requires all major development to provide a ‘Placemaking Statement’. It should be made clear in the Policy, as per Paragraph 6.34 of the Deposit Plan, that this is not expected to be a standalone statement, but will form part of a Design and Access Statement. We recommend the policy is amended as follows:
5.39 Nonetheless, the development of Swn Y Coed is considered to coincide with the objectives of Policy SP4, where the illustrative masterplan submitted as part of previous representations demonstrates its capability to deliver a range of housing types and tenures, whilst integrating key green infrastructure features.
5.40 Local services and facilities are also accessible from this location, tying in with criteria 7, and supports public transport use (as per criteria 4) given the close proximity to a frequent bus route.
5.41 Likewise, the quantum of units proposed demonstrates efficient use of the land based on the net developable area and site constraints in line with emerging Polic PGD2.
5.42 In principle Barratt Redrow supports Policy SP4 and the aim of ensuring all new development is of high-quality sustainable design.
Policy PGD1 – Creating Well Designed and Inclusive Places
5.43 Barratt Redrow question the need for both Policies SP4 and PGD1 as there is repetition. In principle the criteria as set out is as to be expected, however there is a need to recognise that not all criteria can always be accommodated on development sites. There are other environmental and economic factors need to be considered. However, if Policy PGD1 remains, then the text needs to be updated to suggest a site by site basis rather than the current blanket approach suggested.
Policy PGD2 – Residential Development Densities
5.44 Residential densities are supported as a principle, however, should not be so prescriptive as to unnecessarily restrict development. Policy PGD2 outlines that residential development over 0.5ha will be permitted where the residential density is a minimum of 35 dwellings per net hectare within Key, Service Centre and Primary Settlements and 30 dwellings per net hectare in Minor Rural Settlements.
5.45 A minor point in relation to the policy wording is the ‘dwellings per net hectare’ and the removal of non-developable space in any calculations. Whilst this is normal, the increased requirements relating to SAB, green infrastructure requirements and increased ecological mitigation all have a direct impact on the remaining available land and it is positive to see there is an allowance for some flexibility.
5.46 The density requirement appears to be reasonable in approach, and the flexibility to allow individual site adjustments (as per the remaining text within the Policy) is supported. There will be occasions where the density will need to be considered due to other on-site factors.
5.47 Policy SP5 is supported in principle insofar as it seeks to promote healthier and more inclusive places, consistent with the objectives of Planning Policy Wales and the Well-being of Future Generations (Wales) Act 2015. However, to ensure the policy is robust and effective, it is important that it is supported by an up-to-date and clearly evidenced policy framework. In this regard, the supporting evidence base, particularly BP36 – Planning Healthy Places (June 2024), should be reviewed to ensure that the datasets referenced reflect the most recent available information. For example, life expectancy data currently cited (2018–2020) and indicators based on the Welsh Index of Multiple Deprivation 2019 should be updated where possible to reflect the most recent datasets, including the Welsh Index of Multiple Deprivation 2025 and any updated public health, active travel, air quality and demographic data. Ensuring that the evidence base reflects the latest available information is necessary to demonstrate that the policy is justified and based on an accurate understanding of local health conditions and inequalities.
5.48 The policy framework should also be updated to reflect the Health Impact Assessment (Wales) Regulations 2025, which were approved by the Senedd in November 2025 and will come into force on 6 April 2027. At present, these forthcoming statutory requirements are not referenced within Policy SP5 or the supporting guidance. Given that the regulations will establish a statutory framework for the preparation of Health Impact Assessments in Wales, it will be important for the RLDP and supporting documents to clarify how the policy’s screening, checklist and Rapid HIA requirements will interact with the statutory regime once implemented. Including reference to the regulations would help ensure that the policy remains aligned with national legislation and is future-proofed over the plan period.
5.49 The supporting Rapid Participatory HIA of the Deposit RLDP (BP3, September 2025) provides useful background regarding the Council’s engagement with stakeholders in preparing the plan. However, it would be beneficial for the Council to clearly explain how the findings of that work have informed the specific requirements contained within Policy SP5. Providing a clearer link between the outcomes of the participatory HIA and the policy approach adopted in the RLDP would improve transparency and demonstrate that the policy has been shaped by the evidence gathered through the stakeholder engagement process.


Policy SP5 - Creating Healthy and Inclusive Places and Spaces


5.50 The emerging Health Placemaking Supplementary Planning Guidance (SPG) is broadly welcomed as a practical tool to support implementation of the policy. Nevertheless, a number of matters require further clarification prior to its adoption. In particular, whilst the SPG provides greater clarity regarding the use of the Healthy Placemaking Checklist and Rapid HIAs, it does not clearly identify the circumstances in which a comprehensive (full) HIA would be required. The SPG should also be updated to reflect forthcoming guidance from the Welsh Health Impact Assessment Support Unit (WHIASU) expected in 2026, and ensure alignment with other relevant policies and guidance, including those relating to design, travel plans, public transport accessibility and open space provision. Given the number of cross-references within the SPG, it will be important that these documents are fully aligned and consistent.
5.51 Finally, any requirement for a Health Impact Assessment should be applied on a proportionate basis, reflecting the scale, nature and likely impacts of the development proposed. The policy should therefore make clear that the scope and level of detail required for HIAs will be proportionate to the scale and type of development. Subject to these amendments and clarifications, the policy would provide a clearer and more effective framework for integrating health considerations into the planning process.
5.52 Please refer to Policy SP1 as written response also accounts for information proposed under this particular policy.


Policy SP6 – Housing Requirements
Policy HG1 – Housing Allocations
Policy HG1 (B) – Housing Allocations
• HG1 (3) Barry - Land at Hayes Lane 5.53 Barratt Redrow question the suitability of allocating residential development on the site known as Land at Hayes Lane, The Bendricks. These concerns are centred on the following:
• 5.54 Whilst the site is technically identified within the settlement boundary, it is clearly not a sustainable location for residential development. This is evident by virtue of the fact that Land at Hayes Lane is situated within an existing industrial estate and lacks any supporting facilities. The former reinforces the principle that as a whole the area is characterised by a mix of light industrial and heavy industrial uses which naturally conflicts with the prospect of future residential housing. Moreover, it is reasonable to assume vehicles using the local highway network will be larger in nature (such as HGV’s) and given the majority of streets do not contain dedicated pedestrian footpaths/ cycleways, this raises concerns from a highway safety perspective.
• 5.55 Although we note the Transport Statement from AECOM suggests access can theoretically be achieved to Barry and Sully. Both of these settlements remain over 2km from the site and lie outside of the distances deemed acceptable by Transport for Wales (TfW) to support resident development.
•

Unsustainable Location & Poor Connectivity Vale of Glamorgan Deposit Plan Representations | Swn Y Coed, Wenvoe – Site 437


• 5.56 Allocating housing on Land at Hayes Lane which therefore does not comply with such criteria would clearly undermine the Council’s objective of pursuing a Transport Orientated Growth approach and by virtue of which risk promoting an unsustainable pattern of development within the emerging RLDP.
• 5.57 As outlined above given the nature of the area there are almost no existing active travel routes in this part of the region. This lack of provision would ultimately lead to future residents using alterative options and many of which would require residents to overcome physical barriers in order to travel in a more sustainable manner. For instance, due to the level of infrastructure associated with the port, the site is effectively detached from the main urban area of Barry and would involve crossing an active railway line halfway along Wimborne Road without sufficient mitigation measures in place. On the other hand, whilst Hayes Road extends further west towards Sully, it follows the southern boundary of the Polaris Industrial Estate which contains various access points that are in regular use throughout the day. Collectively these characteristics would prevent future occupants travelling in a more active manner which is in direct conflict with both local and national planning policy objectives.
• 5.58 The site’s geographic isolation means that access to modes of public transport are extremely limited. Most notably that includes railway stations with the nearest being Cadoxton Station which is located circa 3.8km north of the site. By AECOM’s own accord this is considered to equate to a minimum walking distance of 52 minutes which exceeds TFW’s standards for residential development. Again, this reinforces the fact future residents would be overly reliant on private vehicles to access local services (such as employment opportunities, schools, doctor surgeries etc) which in turn shall achieve an unsustainable pattern of growth and increase associated carbon emissions.
• 5.59 Crucially, the site remains allocated in the adopted LDP for B1/B8 employment uses. These intended to facilitate small industrial and workshop units as part of the Atlantic Trading Estate’s expansion and in turn support opportunities for local businesses/ enterprise ventures. The council’s latest Employment Land Review confirms a clear demand for such uses in Barry, with Land at Hayes Lane representing the most logical location for further growth. Reallocating this land for housing would therefore diminish the Vale of Glamorgan’s ability to attract sufficient economic investment to support the requisite levels of growth over the emerging plan period, and potentially displace businesses to other less suitable parts of the region which would not be in the interests of good placemaking as per PPW12.
• 5.60 Although the RLDP’s evidence base suggests there are other development opportunities within the region that could compensate for the proposed loss of employment land. Upon further review it is apparent these are in less favourable locations from both a strategic and operational standpoint. Reassigning Land at Hayes Lane from employment to residential would therefore undermine the Council’s objective of safeguarding existing employment land and prioritising business/ industrial uses in area’s well served by infrastructure designed to accommodate such activities (such as Barry Docks). Furthermore, it would also set a precedent for other potential losses and in doing so impact the Council’s ability to meet the region’s employment needs up to 2036.
•

Loss of Allocated Employment Land Vale of Glamorgan Deposit Plan Representations | Swn Y Coed, Wenvoe – Site 437


• 5.61 By virtue of the above, Barratt Redrow object to the proposed allocation of residential development on Land at Hayes Lane. The principle of which is in direct conflict with the Welsh Government’s objectives set out within PPW12 & Future Wales: The National Plan 2040 and the need to ensure existing employment land is suitably protected. The latter is crucial in attracting future investment to the region and shall act as a catalyst to enable housing to be delivered elsewhere, in more sustainable locations better connected to local services/ facilities, such as Wenvoe.
• 5.62 Whilst we do not oppose the overall principle of residential development at Site C (Central Parcel), this position must be considered in the context of the wider allocation. Applications for Sites A and B (2020/00351/OUT (Site A) & 2020/00352/OUT (Site B)) are currently pending subject to respective Section 106 Agreements, with prolonged negotiations resulting in significant delays to delivery. This experience clearly demonstrates that development within this allocation is complex and subject to extended viability and legal discussions, which inevitably impacts the rate at housing is able to come forward.
• 5.63 According to the Council’s register we understand Site C has not been subject to any formal planning application, and therefore there is no detailed evidence available regarding the proposed layout design, infrastructure requirements, viability, or anticipated submission and determination timeframes. Despite this, the Council’s housing trajectory assumes development commencing in 2028/29, with 35 units initially and 45 units annually thereafter. Given the absence of a live application and the precedent of delays on Sites A and B, these delivery assumptions appear overly optimistic based on current evidence.
• 5.64 On that basis we maintain that the Council should reassess the trajectory assumptions for this particular site and identify other alternatives to help account for any unforeseen slippage on Site C. The provision of Swn Y Coed, Wenvoe represents an ideal opportunity to absorb the fallout in terms of housing numbers whilst ensuring the RLDP incorporates sufficient flexibility to consistently meet housing need over the entire plan period.
• 5.65 Although we do not necessarily dispute this sites progression, given Wates have submitted a full planning application (Ref 2024/01152/FUL) which is currently under consideration.
• 5.66 It is important to recognise that, according to the Council’s online planning register, two substantive consultation concerns remain outstanding. Firstly, the Highways response raises fundamental layout issues; and secondly, the Ecology department maintains a holding objection on the basis of insufficient supporting evidence. To date we understand both matters remain unresolved and may well require extensive design amendments, additional technical work, and potentially further consultation before the application can ultimately be determined.
• 5.67 In the absence of confirmed solutions to these issues, there remains uncertainty regarding the timeframe for determining the planning permission. Furthermore, even if consent is secured, there will be a need to discharge conditions and address any pre-commencement requirements, which will inevitably impact the lead-in time before development gets underway.
•

• HG1 (5) Llantwit Major - Land between the Northern Access Road and Eglwys Brewis Road (Site C – Central Parcel)
• HG1 (7) St Athan - Former Stadium Site, adjacent to Burley Place
Vale of Glamorgan Deposit Plan Representations | Swn Y Coed, Wenvoe – Site 437


• 5.68 Given these outstanding matters, the assumption that development will commence in 2027/28 appears optimistic at this stage. Delivery timescales may be extended depending on the scale of amendments required and the duration of condition discharge processes. With this in mind, we believe it is prudent for the emerging RLDP to identify a broader and more diverse portfolio of site allocations to support housing delivery earlier on in the plan period. Ensuring flexibility through additional deliverable sites (such as Swn Y Coed) will reduce the Council’s overreliance on sites such as this one and provide greater certainty in maintaining a more consistent supply of homes over the plan period irrespective of potential delays that may arise on this site.
• 5.69 Whilst we understand that the proposed developer, Edenstone Homes, has recently engaged with the Council through its pre-application service. According to the Council’s planning register, no formal planning application has been submitted to date. As such, there remains no confirmed development proposal, agreed technical evidence base, or indicative determination timeframe associated with the allocation.
• 5.70 In the absence of a live application, there is a considerable degree of uncertainty surrounding the anticipated delivery programme. The housing trajectory assumes development commencing in 2027/28; however, this appears optimistic given that an application has yet to be submitted, validated or determined. Even following any grant of planning permission, there would be a requirement to discharge pre-commencement conditions and satisfy any relevant planning obligations before development could lawfully begin. From experience these processes can be time-consuming and may result in significant delays with regards to lead-in times prior to first completions.
• 5.71 Given this uncertainty, reliance on the site to deliver within the early phases of the plan period carries risk. It is therefore important that the emerging RLDP identifies a broader and more diverse portfolio of deliverable site allocations to support housing delivery, particularly in the earlier years of the plan. Incorporating additional sites with stronger prospects of short-term delivery will provide flexibility, resilience, and greater confidence in maintaining a robust housing land supply should delays arise on this allocation.
• 5.72 Barratt Redrow acknowledges the Council’s position in respect of Site HG3 (1) – Former Eagleswell Primary School, including the temporary five-year consent (2024–2029) for 90 units of short-term accommodation and their inclusion within housing completions for monitoring purposes.
• 5.73 Given their expressly temporary nature and planned relocation to other sites within the Vale by 2029, it is essential that these units are not double counted in a way. As the risk of doing so would artificially inflate the Vale’s housing numbers, thereby preventing delivery opportunities elsewhere over the plan period.
• 5.74 Although Barratt Redrow welcome the clarification provided at paragraph 6.111 which states that once the temporary units are removed and the site is redeveloped for permanent accommodation, any future dwellings will not be included within the RLDPs housing supply
•

• HG1 (8) St Athan - Clive Road, St Athan

Policy HG3 – Housing Led Redevelopment Opportunity Vale of Glamorgan Deposit Plan Representations | Swn Y Coed, Wenvoe – Site 437


• figures. In the interest of soundness, we believe this should explicitly set out within the proposed wording of Policy HG3 to avoid any potential ambiguity and thus ensure no additional net housing contributions will arise from the site upon its redevelopment later down the line.
• 5.75 This approach is critical given the Vale’s substantial existing landbank and the number of allocations being rolled forward, as cumulatively factoring in additional units from this site would further constrain opportunities to accommodate genuine growth elsewhere. Thereby limiting the Council’s ability to effectively meet local housing need up to 2036.
• 5.76 In principle, Barratt Redrow support Policy SP7’s objective to secure a minimum of 3,070 affordable homes over the plan period. That said, given the level of affordable housing is directly proportionate to the total housing provision within RLDP we believe there is scope for further uplifts in that respect.
• 5.77 As mentioned above Barratt Redrow maintain that there is sufficient evidence to justify increasing the proposed housing requirements through the Vale’s flexibility allowance in order to maximise opportunities for growth. In turn this would prevent artificially capping affordable housing provision at 3,070 homes to ensure the plan is positively prepared by incorporating measures that proactively address demand across the region.
• 5.78 National policy clearly supports this approach. Planning Policy Wales requires development plans to be positively prepared and to maximise the delivery of affordable housing as a key component of sustainable placemaking. The Development Plan Manual reinforces the need for plans to be aspirational, evidence-led and sufficiently flexible to ensure delivery. Furthermore, the Welsh Government 2025-based estimates of additional housing need report highlights the need for a step change in affordable housing delivery across Wales, recognising that continuation of past trends will not address the current affordability challenges. Collectively, this provides a clear direction of travel in that it’s imperative to uplift housing provision where affordability pressures are acute such as the Vale of Glamorgan.
• 5.79 To ensure the RLDP is sound, the Council should increase the overall housing requirement by apply a meaningful flexibility allowance that ensure sufficient contingency measures are in place to consistently meet local need over the plan period. This would directly increase the quantum of affordable housing secured through policy mechanisms, thereby aligning the Plan with national policy objectives. The latter goes to the heart of the tests of soundness within the Development Plan Manual in ensuring the plan is not only appropriate but capable of delivering the step change required to address affordable housing needs up to 2036.
• 5.80 Similarly, it is considered that Policy SP7 should be updated to allow flexibility and avoid the risk of contradicting Policy SP8. At present the blanket approach to affordable provision does not allow for site-specific delivery or viability requirements which may arise and as such, the amplification text should also include a note similar to the following:
•

Policy SP7 – Affordable Housing Provision
‘Where the target affordable housing percentage is considered unviable due to physical, financial, or other constraints, sites will be reviewed on an individual basis following submission of a detailed viability assessment and any supporting evidence as necessary’. Vale of Glamorgan Deposit Plan Representations | Swn Y Coed, Wenvoe – Site 437


• 5.81 Barratt Redrow supports the position that residential development should help meet affordable housing need. Although to ensure Policy SP8 is effective its important the percentage requirements and site thresholds proposed must be viable across a range of site types and market areas to ensure they do not inadvertently suppress delivery.
• 5.82 On that basis we believe it would be prudent for the Deposit Plan to clarify that affordable housing targets are subject to site-specific viability considerations and can be adjusted in circumstances where comply with such parameters would render the sites viable and thus prevent delivery. Greater flexibility is also needed in tenure and mix to better reflect evolving local needs over the entire plan period including the point when planning applications are formally submitted. This would help ensure that the approach is consistent with paragraph 4.2.32 of PPW 12 which suggests that ‘site specific targets are indicative affordable housing targets which should be established for each residential site…’.
• 5.83 As noted above, the blanket approach to affordable housing requirements based on the Council’s latest needs evidence does not have due consideration for the event of unique technical complexities that many sites could face, nor viability considerations which may affect delivery, particularly early on in the plan period. As such, re-wording of the policy text to allow for sites to be reviewed on an individual basis where such circumstances apply is considered necessary for soundness.
• 5.84 Barratt Redrow support the overall objective of Policy SP10 in seeking to promote sustainable transport, increase active travel opportunities and reduce reliance on the private car in accordance with national placemaking objectives. Encouraging development in accessible locations such as Wenvoe and enhancing connectivity between settlements is welcomed. However, for soundness its important the policy recognises the different physical characteristics across the Vale of Glamorgan, particularly in edge-of-settlement and rural contexts where flexibility is necessary to ensure sustainable growth is not unduly constrained.
• 5.85 In this regard, the Swn Y Coed, Wenvoe site (Ref 437) represents a sustainable and deliverable opportunity that aligns fully with the objectives of Policy SP10.
• 5.86 The Candidate Site submission was accompanied by a Technical Note prepared by Lime Transport. Seen as the site abuts the defined urban area of Wenvoe it represents a logical extension to the existing settlement and is well served by a range of local amenities and public transport. In terms of the latter the nearest bus stop is located within 100 meters of the site whilst the majority of local amenities are situated within 1.2 kilometres walking distance. Together these factors naturally promote the principle of linked trips which fully accords with the Chartered Institution of Highways and Transportations (CIHT) guidelines and reinforces the fact the site is a sustainable location for residential development.
• 5.87 As shown within the latest illustrative masterplan the proposed site will be served by a new junction off Old Port Road. This is confirmed as being the most appropriate arrangement from a highway safety perspective and would be supported by other technical analysis to demonstrate that sufficient visibility can be achieved on to the road for all potential users.
•

Policy SP8 – Affordable Housing Requirements
Policy SP10 – Sustainable Transport Vale of Glamorgan Deposit Plan Representations | Swn Y Coed, Wenvoe – Site 437


• 5.88 The accompanying Transport Assessment also demonstrates that there is sufficient capacity within the local highway network to accommodate the projected level of demand associated with this level of development. Where necessary, any future scheme would also facilitate other improvements which may well include widening the highway along Old Port Road and/ or Walston Road to accommodate two-way traffic and providing a dedicated pedestrian/ cycle junction to connect on to the existing active travel route which leads into the centre of Wenvoe. The existing field access would also be blocked up to create a more cohesive layout. However as shown within the latest masterplan the existing public right of way which crosses the site shall be retained and enhanced to promote better pedestrian connectivity throughout the local area.
• 5.89 In terms of active travel, dedicated pedestrian footpaths and cycleways will be incorporated throughout the scheme before filtering into the surrounding area. The site is also situated within an area which benefits from good access on to existing active travel routes and a number of which have also been identified for further improvements which reinforces the schemes sustainability. These principles fully accord with the relevant placemaking objectives set out within the National Plan 2040 and PPW12, and demonstrates that safe and suitable access can be achieved for all users.
• 5.90 Subject to proportionate application of Policy SP10 and recognition of the robust mitigation proposed, the site clearly supports and advances the sustainable transport objectives of the emerging RLDP.
• 5.91 Barratt Redrow object to Policy CC1 on the basis that it duplicates and potentially exceeds Welsh Government’s Future Homes Standard (FHS), which is intended to ensure all new homes are “zero-carbon ready” through a consistent national Building Regulations framework. Introducing a separate and more onerous operational net zero requirement at the local level risks imposing additional cost and complexity that undermines site viability and deliverability. The Development Plans Manual for Wales is clear that development plans must avoid repeating national policy and should not introduce requirements that are more appropriately addressed through other regulatory regimes. In this respect, Policy CC1 conflicts with the principle that plans should be clear, proportionate and not duplicate national controls, raising concerns under the tests of soundness relating to coherence and consistency with national policy (Test 2) and whether the plan is justified (Test 3).
• 5.92 The proposed step change in standards from 1 April 2030 — particularly the reduction in space heating demand from 40 kWh/m²/year to 15 kWh/m²/year — represents a significant and abrupt escalation in performance expectations. Whilst reference is made to initiatives such as Tai ar y Cyd and AECB CarbonLite, these have largely been associated with grant-funded affordable housing schemes. There is no clear evidence that equivalent standards can be viably delivered across mainstream private housing schemes without public subsidy. The Development Plans Manual requires policies to be underpinned by robust evidence and deliverable over the plan period. In the absence of clear viability evidence across different site typologies and market conditions, the policy fails to demonstrate that it is justified and effective (Tests 3 and 4).
•

Policy CC1 - Residential Operational Net Zero Carbon Development Vale of Glamorgan Deposit Plan Representations | Swn Y Coed, Wenvoe – Site 437


• 5.93 Policy CC1 also risks creating fragmented energy performance standards across different Local Planning Authorities in Wales. This undermines the benefit of a consistent national approach through Building Regulations and makes it more difficult for volume housebuilders operating across multiple authority areas to deliver homes efficiently at scale. The Manual emphasises that development plans should facilitate delivery and avoid unnecessary complexity. By introducing bespoke operational monitoring requirements, energy modelling thresholds and potential financial offset mechanisms, the policy blurs the boundary between planning and Building Control functions. This raises concerns as to whether the policy is effective and capable of consistent implementation (Test 4).Finally, the Council’s own Viability Assessment (BP42, paragraph 6.60) acknowledges uncertainty pending Welsh Government’s consultation outcome and suggests that, if national regulation progresses, it may be more appropriate for such matters to be addressed through Building Control rather than planning policy. This reinforces the concern that Policy CC1 is premature and may quickly become misaligned with national policy. As drafted, the policy risks undermining housing supply, affordable housing delivery and overall plan implementation. For these reasons, it fails to satisfy the tests of soundness in respect of coherence with national policy, justification and effectiveness, and should be deleted or fundamentally amended to align fully with the national regulatory framework.
• 5.94 Alternatively, if Policy CC1 is kept in the RLDP, there must be some flexibility introduced for the requirements of Policy CC1 to fall away should Building Regulations catch up or exceed or require different provisions than the requirements of Policy CC1 during the lifetime of the RLDP. To not provide this flexibility would mean that the ability of the RLDP to deliver the new homes in VoG needs could be compromised. Clarification is also required on how the contribution to the Council’s Project Zero fund is to be calculated and whether the timeframes in Policy CC1 relate to the date of planning approval.
• 5.95 Furthermore, the demands of Policy CC1 have to be considered in the context of all of the other demands that impact on development viability (e.g. affordable housing). The Council must provide evidence that an assessment has been undertaken to demonstrate that development, specifically the housing allocations in Policy HG1, can bear the cumulative policy costs of the RLDP, including Policy CC1.
• 5.96 The policy wording should be amended so that the performance requirements apply based on the date of planning permission rather than the RLDP adoption date. Changes in energy performance requirements can significantly affect site layout, building orientation, and design considerations. Without this amendment, approved schemes could unnecessarily require variations via Section 73 or Non Material Amendment applications.
• 5.97 As such, Policy CC1 should be amended to ensure that it is precise, measurable and enforceable and achieves the three tests of soundness. The proposed amended wording is as follows:
•

Developments that secure a planning permission from RLDP adoption to 31st March 2030 will be required to meet the following criteria:
i. Space heating demand less than or equal to 40kWh/m2/year;
ii. Energy use intensity less than or equal to 75kWh/m2/year; and Vale of Glamorgan Deposit Plan Representations | Swn Y Coed, Wenvoe – Site 437


• 5.98 Barratt Redrow do not consider that Policy SP13 – Community Infrastructure and Planning Obligations is required. This is predicated on the basis that such matters are dealt with under separate legislative and policy frameworks. Therefore, as currently drafted the proposed policy (and supporting text) do not add anything further information for planning purposes and risk unnecessary duplication.
• 5.99 Whilst there are no comments regarding the principle, thresholds and use of the FIT standards in terms of the open space provision, Barratt Redrow do question the requirement for an Open Space Strategy for all sites that meet the thresholds.
• 5.100 The requirement within emerging Policy CI1 for applicants to prepare or submit an Open Space Strategy is not considered to be sufficiently justified or proportionate when assessed against Planning Policy Wales, which promotes access to open space and recreational provision but does not prescribe the preparation of standalone Open Space Strategies for individual planning applications. There is a lack of clarification as to what it proposed and also how the level of detail would be proportional to the size of the site, which would be addressed comprehensively in a DAS or Green Infrastructure Statement in any event.
• 5.101 Furthermore, the proposed 62.2 m² per dwelling requirement is overly prescriptive and not aligned with FiT’s methodology, which is per person and intended to be applied strategically across different open space typologies, not as a uniform per dwelling metric. FiT’s approach emphasises flexibility, multifunctionality and local context, meaning that applying a rigid per dwelling standard oversimplifies the guidance and risks generating disproportionate land take and unnecessary design constraints. When combined with the wider cumulative policy burdens of the RLDP, such an approach has the potential to impact development viability and reduce delivery.
• 5.102 In principle Barratt Redrow support the aim of this policy in ensuring proposed development incorporate measures that protect and enhance green infrastructure provision.
• 5.103 For completeness Swn Y Coed, Wenvoe exhibits a landscape led design that sensitively responds to its existing features, and provides an attractive, landscaped and high-quality public realm throughout. A number of priority habitats including a network of hedgerows have been retained throughout. Extensive landscape buffers and a continued natural edge will be provided to the site to accommodate root protection zones of existing trees and hedgerows which visually screen the development from adjacent uses. Moreover, a dedicated area of Public Open Space and Local Equipped Area of Play (LEAP) is proposed to the south of the site.
•

Developments that secure a planning permission from 1st April 2030 onwards will require:
i. Space heating demand less than or equal to 15kWh/m2/year;
ii. Energy use intensity less than or equal to 40kWh/m2/year; and
Policy SP13 - Community Infrastructure and Planning Obligations
Policy CI1 – Open Space Provision
Policy SP19 – Green Infrastructure Vale of Glamorgan Deposit Plan Representations | Swn Y Coed, Wenvoe – Site 437


• 5.104 Barratt Redrow object to the continued inclusion of Swn Y Coed within the Dyffryn Basin & Ridge Slopes - 5 Special Landscape Area (SLA) under Policy DNP1.
• 5.105 As highlighted in Background Paper BP28 – Special Landscape Areas, Paragraph 1.8, the Council considers that the SLA as defined in the 2008 ‘Designation of Special Landscape Areas - Final Report’ remain relevant, up-to-date, and based on current best practise and have therefore not undertake a review of the report to inform the emerging Replacement Local Development Plan (RLDP).
• 5.106 Whilst the Authority have not sufficiently updated their evidence base, the site was subject to a detailed review as part of the Candidate Site submission by Soltys Brewester Landscape which highlighted that the site is located on the edge of land subject to Dyffryn Basin and Ridge Slopes SLA. This designation is ‘underpinned’ by LANDMAP Areas St Nicholas and Bonvilston Ridge Slopes, (VLFGLVS614) and St Nicholas and Bonvilston Ridge Crest (VLFGLVS271), both evaluated as High.
• 5.107 However, the vast majority of the designated land will fall outside the visual envelope for the Swn Y Coed site and there will be no change to the key characteristics of the SLA or the LANDMAP areas to the west or to the north of the site boundary.
• 5.108 A noted characteristic of the SLA relates to the prominence of the sloping edge, (i.e. St Nicholas and Bonvilston Ridge Slopes, (VLFGLVS614), within views from Wenvoe Valley to the east. The visual appraisal establishes that site development has the potential to partially change the appearance of this edge within available views.
• 5.109 However, opportunities for GI provision within the site including retention and enhancement of the existing boundary hedges and trees which has the potential to minimise any visible change. Furthermore, as illustrated on the submitted masterplan, the existing hedges and field pattern within and around the site will be key structural elements guiding and sub-dividing the development form.
• 5.110 When considered in the context of the extensively wooded nature of the slopes visible to the east, any visible change to valley slope characteristics is likely to be very marginal and visually insignificant within the study area.
• 5.111 Moreover, the illustrative masterplan includes measures that will assist with GI mitigation and enhancement, including SUDs features, accessible landscape buffers and green spaces.
• 5.112 Therefore, it was concluded that from a landscape and visual perspective the site has the ability to suitably incorporate residential development and include GI enhancements, to assist with its visual integration, as a visually appropriate extension to Wenvoe, and should be removed from the Dyffryn Basin & Ridge Slopes - 5 Special Landscape Area under Policy DNP1.
•

Policy DNP1 - Special Landscape Areas Vale of Glamorgan Deposit Plan Representations | Swn Y Coed, Wenvoe – Site 437


• 5.113 Barratt Redrow object to the site at Swn Y Coed, Wenvoe still forming part of Green Wedge 3 - North of Wenvoe within Policy DNP2, which seeks to prevent coalescence between the western edge of Cardiff and Wenvoe.
• 5.114 Barratt Redrow have reviewed BP27 Green Wedges and consider that the assessment under NW2 does not consider nor reference the fact that the site at Swn Y Coed relates to the context of built development at Wenvoe and is very well-contained by both mature woodland and landform and possesses strong intervisibility with the northern edge of Wenvoe. Instead, BP27 looks to discuss the southern boundary of Culverhouse Cross and the association with the wider countryside.
• 5.115 As previously states Barratt Redrow consider that the site boundaries are well-defined and would provide a strong established ‘defensible’ limit to development. The topography connects with the main settlement to the extent that any new development would appear well connected to the existing settlement, physically and visually. This is a similar situation to the adjoining former Wenvoe Quarry and Vale of Glamorgan Council Depot which are considered to be ‘largely shielded from view by woodland blocks/strips’.
• 5.116 Furthermore, the existing dispersed housing and the hotel/pub along Old Port Road also provide some precedent for ‘infilling’ the site. Proposed development should seek to reflect the low density, height and well-treed character of Wenvoe to help ensure it has a coherent and visually connected relationship. GI mitigation and enhancement benefits likely to result from the site development, including placemaking, value or integration in relation to landscape and visual considerations.
• 5.117 The proposed development of the small area of the Green Wedge would not undermine the principles and would still prevent the coalescence of Wenvoe with Cardiff by maintaining a minimum 0.7km separation and would not significantly impact upon the openness of land.
• 5.118 Moreover, the illustrative masterplan provided as part of Candidate Site 437 includes measures that will assist with GI mitigation and enhancement, including SUDs features, accessible landscape buffers and green spaces. Further recommendations to maximise opportunities to reinforce GI, including placemaking, value or integration are outlined below:
• 5.119 Overall, Barratt Redrow maintain their objection to the inclusion of the Swn Y Coed site within Green Wedge 3 - North of Wenvoe under Policy DNP2. From a landscape and visual
•

Policy DNP2 – Green Wedges
• Retention, management and strengthening of structural green corridors and boundaries to the site, including the overgrown hedges and trees;
• More visible areas on elevated sections of the site should include a higher proportion of trees, including gardens and street trees and woodland to more visually integrate the development when viewed from the Wenvoe Valley to the east; and
• Footpath corridors through the site could be integrated with the development through appropriate hedge and garden vegetation to ensure attractive recreational corridors are provided. Similarly informal routes around the perimeter could continue to offer amenity value through sympathetic boundary treatments and informal planting.
Vale of Glamorgan Deposit Plan Representations | Swn Y Coed, Wenvoe – Site 437


• perspective, the site has the ability to suitably incorporate residential development and include GI enhancements, to assist with its visual integration, as a visually appropriate extension to Wenvoe. Moreover, the development of the site immediately adjoining the existing settlement boundary at Wenvoe would not detract from the purpose of the wider Green Wedge.
• 5.120 Policy DNP8 seeks to address recreational pressure on the Severn Estuary Special Area of Conservation, Special Protection Area and Ramsar Site. Whilst Barratt Redrow appreciate the overarching purpose in its current form the proposed policy lacks sufficient supporting information explaining how it will operate in practice. The supporting text suggests that key details relating to mitigation delivery, including mechanisms such as Suitable Alternative Natural Greenspace and wider access management measures, will be set out in future Supplementary Planning Guidance. Deferring these important details until later down the line creates uncertainty at the plan-making stage and makes it difficult to assess whether the policy is sound, effective and/ or capable of being implemented on a consistent basis.
• 5.121 The policy also provides no clear threshold or criteria for determining what level of activity would constitute “visitor pressure” or an “adverse impact” on the integrity of the designated sites. Similarly, the evidence demonstrating what level of impact residents moving into new homes across the Vale of Glamorgan will generate additional recreational pressure on the Severn Estuary does not appear to have been quantified to date. While a 12.6 km recreational catchment is referenced (in which Swn Y Coed, Wenvoe would technically sit within), the supporting text does not clearly explain the evidence or methodology underpinning this distance. Moreover, the proposed text also fails to set out how new residential development will be assessed in terms of measurable impacts on the European site and thus the scope of mitigation that would subsequently be required.
• 5.122 From a practical standpoint this level of uncertainty is concerning given the implication of this policy are unable to be fully assessed due to the lack of evidence. For instance, if development sites within the catchment are expected to contribute financially towards mitigation measures, then the scale and mechanism of those contributions must be clearly established as part of the plan-making process. Without this clarity, there is a risk that Policy DNP8 could introduce unforeseen costs and extensive time delays, potentially affecting the viability and overall deliverability of proposed housing sites. The cumulative impact of which would then undermining the plan’s ability to meet its housing requirements and risk finding the RLDP unsound.
• 5.123 Barratt Redrow understand the need for a sustainable provision of minerals, as per Policy SP18, however object to the continued inclusion of Swn Y Coed, Wenvoe within an area that is designated as a Category 1 Limestone mineral resource. The site should not be safeguarded from permanent development as detailed in response to Policy MIN1.
•

Policy DNP8 – Severn Estuary Recreational Pressure
SP18 - Sustainable Provision of Minerals Vale of Glamorgan Deposit Plan Representations | Swn Y Coed, Wenvoe – Site 437


• 5.124 Barratt Redrow object to the continued inclusion of the land at Swn Y Coed as a Category 1 Limestone mineral resource safeguarding area.
• 5.125 A Mineral Resource Assessment, undertaken by Wardell Armstrong, was provided as part of the Candidate Site Assessment and considered the proposed development against the four criteria of Policy MG 22 of the current Adopted Local Development Plan and National Policy. Those criteria are carried forward into Policy MIN1 and the following conclusions are reiterated:
• 5.126 As the resource is constrained by sensitive development any prior extraction would have an unacceptable impact on environmental and amenity considerations.
• 5.127 Limestone extraction has the potential to give rise to unacceptable impact to the immediate residential properties and would be wholly inappropriate.
• 5.128 The extraction of limestone resources beneath the Site has the potential to have an unacceptable impact upon:
•

MIN1 - Development in Minerals Safeguarding Areas
• Criterion 1: Prior extraction of economic minerals prior to development
• Criterion 2: Demonstrating extraction would have unacceptable impact

a) Ambient noise levels,
b) Air quality,
c) Ground vibration and air overpressure from blasting,
d) Limited site access/egress onto the Old Port Road would be problematic, and
e) Increased traffic generation by HGVs.
• Criterion 3: Development would have no significant impact on the possible working of the resource by reason of its nature or size 5.129 Development would not have significant impact on mineral resources
•
• Criterion 4: Poor quality resource 5.130 The quality and quantity of the mineral resources have not been assessed given the resource is already constrained by sensitive development and any testing or extraction would not be viable nor possible.
• 5.131 As already demonstrated the Category 1 resources cannot be extracted under Criteria 1 and 2 (due to the impact upon amenity) and the proposed residential development would not have a significant impact upon the wider mineral resource (Criterion 3).
• 5.132 Therefore, it is considered unnecessary to undertake site investigations by boreholes and trial pits to determine the ratio of overburden to mineral resource, mineral quality and estimation of the gross mineral resource affected by the proposed development.
• 5.133 Overall, Barratt Redrow consider that the presence of the mineral resource does not preclude the allocation and development of the site as any extraction does not accord with the criteria
•
Vale of Glamorgan Deposit Plan Representations | Swn Y Coed, Wenvoe – Site 437


• requirements in MIN1. Therefore, the site at Swn Y Coed should be removed from the safeguarding area.
• 5.134 Barratt Redrow acknowledge the need to retain buildings in some circumstances, however consider that the wording of Policy CC2 is overly restrictive in the sense that a presumption against demolition could impact upon delivery timescales for sites, particularly those including farm buildings.
• 5.135 Accordingly, it is considered necessary to re-word the policy to allow for the demolition of buildings where they are no longer used or needed in the event that a site is proposed to be developed for residential purposes, to assist in meeting the housing need over the plan period.
• 5.136 An additional point should be added to the list of 4 criteria, to note that demolition will be acceptable where it is demonstrated that ‘The existing building occupies a minority portion of the site, and to not demolish the building would prevent and/or restrict the delivery of the wider land for the provision of housing’.
•

CC2 – Presumption Against Demolition Vale of Glamorgan Deposit Plan Representations | Swn Y Coed, Wenvoe – Site 437


• 6.1 In summary, Barratt Redrow, remain committed to the development opportunities at ‘Swn Y Coed, Wenvoe’. By virtue of its location the site represents a sustainable extension to the existing settlement of Wenvoe, and we maintain that its inclusion within the emerging RLDP would help promote a more sustainable pattern of development in line with the Council’s vision for the VoG.
• 6.2 Although we understand the Council have opted to pursue a ‘medium growth option’. Having reviewed the accompanying evidence base there is clear justification to warrant higher levels of growth, particularly in respect of housing over the emerging plan period. This would better accommodate the identified housing requirements and align with the Welsh Government’s aspirations to prioritise future development within a National Growth Area. These principles fully accord with PPW12 and Future Wales, whilst also enabling the VoG to proactively take action in order to account for historic unmet need across the county as shown within the latest Annual Monitoring Report (7th Edition).
• 6.3 Barratt Redrow Homes’ most pertinent comments on the consultation document are summarised below:
•

6. CONCLUSION
• Barratt Redrow fully supports the proposed approach to prioritise development in sustainable locations near existing rail and bus infrastructure as depicted by the strategic growth area within the RLDP Key Diagram. However, to optimise the effectiveness of this strategy growth should be focused in areas of high demand, such as Wenvoe, which is near to Cardiff but also inherently well connected by the existing bus network.
• Barratt Redrow support the principle of the Settlement Hierarchy and the identification of Wenvoe as a Primary Settlement. Whilst the importance of which is noted, Barratt Redrow maintain that Wenvoe, in particular, is capable of a higher role and function which can be accommodated at Candidate Site Ref. No 437. This is particularly relevant given the fact that the Service Centres at Cowbridge, Llantwit Major and Penarth are generally more constrained physically and environmentally.
• Barratt Redrow maintain that a higher growth option should be followed. Given the Vale’s position within the Cardiff Capital Region and its designation as a national growth area, we maintain that the proposed RLDP should be more ambitious when it comes to overall housing targets. Drawing on examples from Bridgend (14% flexibility), Swansea (20%), and Monmouthshire (15%), alongside evidence of historic under-delivery and recent Welsh Government household projections, there are sufficient grounds to warrant increasing the proposed flexibility allowance to a minimum of 15%, equating to a total requirement of 9,074 homes up to 2036.
• In the interests of soundness these changes shall help account for any potential overreliance on existing landbanks and variable windfall delivery rates which could in theory limit the plan’s ability to address unmet housing need. Barratt Redrow therefore conclude that a higher flexibility allowance and additional site allocations, such as the land at Swn Y Coed, are necessary to ensure the RLDP is able to effectively meet
Vale of Glamorgan Deposit Plan Representations | Swn Y Coed, Wenvoe – Site 437


local need over the plan period. The benefits of which shall also demonstrate the emerging RLDP is supported by a robust, proportionate and credible evidence base to accord with the requirements of the Development Plan Manual for Wales and national growth objectives.
• Whilst Barratt Redrow welcome the majority of the proposed planning policies from a development management perspective. They strongly object to Policy CC1 (Residential Operational Net Zero Carbon Development) on the basis that it duplicates Welsh Government’s Future Homes Standard (FHS), which is intended to ensure all new homes are “zero-carbon ready” through a consistent national Building Regulations framework.
• Although Barratt Redrow support the requirements for affordable housing in new development. In its current form the proposed policies SP7 and SP8 lack sufficient flexibility for site specific circumstances and physical constraints which may impact upon delivery. This inevitably creates uncertainty for a number of sites, where the blanket approach to affordable housing requirements based on the Council’s latest needs evidence does not have due consideration for the event of unique technical complexities.
• From a planning perspective it is also important to recognise the additional benefits the site (Candidate Site Ref No. 437) could provide in accommodating the increased housing need generated by the suggested 15% flexibility allowance within a highly sustainable location. The principles of which clearly align with the Council’s aspirations and would maximise opportunities for linked trips, enabling residents to meet a greater proportion of their daily needs locally while benefiting from high-quality public transport

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.