SP20 - BIOAMRYWIAETH A GWYDNWCH ECOSYSTEMAU

Yn dangos sylwadau a ffurflenni 1 i 14 o 14

Gwrthwynebu

1 Ymgynghoriad ar Cynllun Datblygu Lleol Newydd

ID sylw: 5178

Derbyniwyd: 04/03/2026

Respondent ID: 2386

Ymatebydd: Welsh Government (Planning Division)

Cadarn? Heb nodi

Crynodeb o'r Gynrychiolaeth:

Criterion 1 (Policy SP20) should be redrafted – the stepwise approach in PPW 12 6.4.15 1a - does not distinguish between relative ecological value – the avoidance step applies to biodiversity in its widest sense (i.e. the variety of species and habitats and their abundance) and ecosystem functioning.

Atodiadau:

Cefnogi

1 Ymgynghoriad ar Cynllun Datblygu Lleol Newydd

ID sylw: 5540

Derbyniwyd: 09/03/2026

Respondent ID: 2309

Ymatebydd: Mrs Hilary May

Crynodeb o'r Gynrychiolaeth:

This is very important, developments must allow and improve connectivity for species across the wider landscape - wildlife corridors etc. Avoiding sensitive sites by a good buffer margin to avoid disturbance by development.

Gwrthwynebu

1 Ymgynghoriad ar Cynllun Datblygu Lleol Newydd

ID sylw: 5723

Derbyniwyd: 10/03/2026

Respondent ID: 3264

Ymatebydd: Mr David Entwistle

Cadarn? Heb nodi

Crynodeb o'r Gynrychiolaeth:

I support this in principle but feel it is too vague and weak. The council should be pushing for protection of species beyond statutory requirements and hold itself to a higher standard. There are always ways that local/on site nature based solutions can be incorporated and the statement saying off site measures can be considered is too weak and gives developers too much scope to bypass their requirements.

Gwrthwynebu

1 Ymgynghoriad ar Cynllun Datblygu Lleol Newydd

ID sylw: 5941

Derbyniwyd: 11/03/2026

Respondent ID: 538

Ymatebydd: HBF

Cadarn? Heb nodi

Effeithiau ar y Gymraeg:

None

Crynodeb o'r Gynrychiolaeth:

The HBF suggests that the words 'functionally related' should be removed from the bold text at the end of the policy. Although the principle of this final paragraph is supported, the flexibility which it provides to developers is, in part, removed by the wording above. It is accepted planning practice that where something can not be provided on site, an off-site alternative can be acceptable, subject to the appropriate controls. However, limiting this to 'functionally relates' is onerous and unnecessary to achieve the aims of the policy.

Cefnogi

1 Ymgynghoriad ar Cynllun Datblygu Lleol Newydd

ID sylw: 6049

Derbyniwyd: 11/03/2026

Respondent ID: 2669

Ymatebydd: Barratt Redrow Homes

Asiant : Lichfields

Effeithiau ar y Gymraeg:

N/A

Crynodeb o'r Gynrychiolaeth:

The proportionate approach to biodiversity mitigation and compensation, that provides allowance for planning obligations towards off-site habitat improvement and maintenance is consistent with Chapter 6 of PPW and therefore meets the first test of soundness (Does the Plan fit?). It is essential that options are retained to provide biodiversity mitigation off site as well as on site.

Cefnogi

1 Ymgynghoriad ar Cynllun Datblygu Lleol Newydd

ID sylw: 6082

Derbyniwyd: 11/03/2026

Respondent ID: 2669

Ymatebydd: Barratt Redrow Homes

Asiant : Lichfields

Effeithiau ar y Gymraeg:

N/A

Crynodeb o'r Gynrychiolaeth:

The proportionate approach to biodiversity mitigation and compensation, that provides allowance for planning obligations towards off-site habitat improvement and maintenance is consistent with Chapter 6 of PPW and therefore meets the first test of soundness (Does the Plan fit?). It is essential that options are retained to provide biodiversity mitigation off site as well as on site.

Sylw

1 Ymgynghoriad ar Cynllun Datblygu Lleol Newydd

ID sylw: 6140

Derbyniwyd: 11/03/2026

Respondent ID: 3452

Ymatebydd: Mr Michael Priaulx

Crynodeb o'r Gynrychiolaeth:

The Green Infrastructure policies are welcome but overlook building-dependent species such as bats and red-listed endangered birds such as swifts, house sparrows and house martins.

Wales does not yet have planning guidance for these species but England has guidance based on British Standard BS 42021 for Integral Nest Boxes.

Therefore, please implement the equivalent of England national planning policy guidance (NPPG) Natural Environment 2025 paragraph 017, with regard to at least one swift brick per dwelling on average for new developments as these are a universal nest brick for small bird species, not included in quantitative biodiversity calculations so a separate policy is needed.

Please add, as house martins are a significant species in the Vale of Glamorgan with good availability of vegetated and waterside areas for foraging:

"Artificial nest cups for house martins may be specified as an alternative to swift bricks, where recommended by a suitably qualified ecologist."

Please also add the following, to ensure effective implementation:
"Post-construction stage confirmation of installation is required through photographs or verification by a suitably qualified ecologist."

Existing nest sites in buildings should be protected and retained where possible, and equivalent mitigation provided where this is not possible.

Gwrthwynebu

1 Ymgynghoriad ar Cynllun Datblygu Lleol Newydd

ID sylw: 6175

Derbyniwyd: 11/03/2026

Respondent ID: 2506

Ymatebydd: Ms Lucie Taylor

Cadarn? Nac Ydi

Effeithiau ar y Gymraeg:

only positive.

Crynodeb o'r Gynrychiolaeth:

SF&G believe that food growing initiatives have multifaceted benefits, including contributing to the biodiversity goals under the Environment Wales Act, supporting wellbeing and net zero targets by 2035. The Vale of Glamorgan’s Biodiversity Forward Plan aims to meet obligations to enhance biodiversity and ecosystem resilience. SF&G has experienced poor biodiversity provision in new school and housing developments through collaboration with KWT LPFN package delivery. Policies should ensure spaces for nature are integrated into developments. Furthermore, communities should be encouraged to include food growing sites in their Place Plans to enhance biodiversity and help address food security amidst global challenges.

Gwrthwynebu

1 Ymgynghoriad ar Cynllun Datblygu Lleol Newydd

ID sylw: 6642

Derbyniwyd: 11/03/2026

Respondent ID: 692

Ymatebydd: Natural Resources Wales (NRW)

Cadarn? Heb nodi

Crynodeb o'r Gynrychiolaeth:

General Approach to Designated Sites
In line with our role in development planning and our consultation remit, we advise that where new development may occur within or be likely to affect statutory designated sites including Special Areas of Conservation (SAC), Special Protection Areas (SPA), Sites of Special Scientific Interest (SSSI), National Nature Reserves (NNR) and Marine Conservation Zones (MCZ) this could be more clearly identified as a key consideration especially with respect to site allocations (housing and employment). We consider that the issue of avoiding or mitigating potential impacts and utilising opportunities for supporting and enhancing these sites (as noted by para 6.401 of the deposit plan) could have more substantial recognition across the deposit plan and its supporting documents. This would improve the clarity of approach.
We have furthermore noted that Policy SP20 (Biodiversity and Ecosystem Resilience) currently excludes specific mention of designated sites (although it does refer to protected species and habitats) and we suggest that this is addressed – our comments on SP20 are set out in Section 3 of this letter.
By across the plan, we mean there is scope to include mention of relevant statutorily designated sites within the constraints text for the sites listed in Appendix B of document BP44 Infrastructure Delivery Plan (perhaps summarising in line with the approach taken to the Historic Environment Record) and within document BP32A Green Infrastructure Assessment of Key Sites, evidence which can then be reflected as appropriate in Key Sites Policies (HG1 KS1 to KS5) to inform their master planning. The Preliminary Ecological Appraisals already undertaken for Key Sites (Key Site Supporting Information) would appear to hold relevant information in this respect.
We note that document BP32A has a useful general paragraph on biodiversity assets at paras 3.7-3.8 linked to the evidence collated in the Green Infrastructure Assessment (GIA).
In short, where designated sites are identified in proximity to allocated sites it would be helpful to make clear reference to them in a consistent manner. This would bring the deposit plan more fully into alignment with the ISA findings. For any employment sites within proximity of designated sites, we consider that the employment background paper BP12A could potentially be updated to similar effect.
With reference to omissions on this matter, we refer you to our comments on sites set out in Section 4 of this letter, including sites KS1, HG1 (1), SP14 1. and SP14 4.
Overall, we consider that the recognition of designated sites appears somewhat inconsistent in the deposit plan, although we recognise that much of this is done by the
Green Infrastructure Strategy (GIS) which incorporates the GIA.
It may be that Policy SP20 (together with addressing the meaning of “areas of high ecological value” will also go
some way towards resolving the points we raise.

Atodiadau:

Gwrthwynebu

1 Ymgynghoriad ar Cynllun Datblygu Lleol Newydd

ID sylw: 6643

Derbyniwyd: 11/03/2026

Respondent ID: 692

Ymatebydd: Natural Resources Wales (NRW)

Cadarn? Heb nodi

Crynodeb o'r Gynrychiolaeth:

We welcome the inclusion of SP20 which recognises the importance of natural assets and aims to protect these. We also note that whilst reference is made to sites and areas of European, national and local importance (para. 6.402), this is not distinctly carried through within SP20 or within a specific detailed policy in the deposit plan. We advise that a more detailed policy for the Natural Environment (similar to DNP4 for the Historic Environment) could be included within the deposit plan and this should include reference to the protection of statutorily designated sites. Alternatively, SP20 itself could be updated to include reference to these in a similar manner to the approach taken to non-statutory designated sites provided by criterion 5 of SP20. We consider this would strengthen the deposit plan’s alignment to section 6.4.3 of PPW12.

By adding a detailed policy for the wider protection of the natural environment, there is scope to ensure a clearer message within the deposit plan regarding the need for natural resources (including land, air, water and soils) in the Vale to be protected for themselves and the essential ecosystem services they deliver. This is opposed to merely preventing pollution (deposit plan Policy DNP5). Taking such an approach would enable an opportunity to add the consideration of Sustainable Management of Natural Resources (SMNR) into the plan policy framework rather than confining this to the deposit plan context (para 2.11) and the policy context of the GIS (page 53).

We note that Policy CC4: Renewable, Low and Zero Carbon Energy Generation is more distinct in seeking to safeguard a range of assets (including nature conservation interests and soil conservation interests) and we consider a similar policy approach may be useful for all development proposals.

Ensuring an SMNR approach will impact positively on the ground to safeguard and improve ecological networks and protect and enhance ecosystems, essential to meeting the nature emergency.

Topics we draw your attention to include river restoration where, in particular, the removal/remediation of physical modifications can make a significant impact upon water quality. The GIS provides scope to capture various projects and wider initiatives, including those based on catchment scale improvements and we welcome the opportunity to be continually involved in this work.

We note and welcome the recognition of nature-based solutions within Policies SP16, SP19 and SP20 and in detailed Policy CC6.

With regards to natural assets and water resources, we consider that specific reference to water quality is lacking within the strategic and/or detailed policies. Whilst we note that water quality is mentioned within criterion 9 of Policy SP16, we consider the deposit plan should include more direct reference to the Water Framework Directive.

We consider there is an opportunity for SP20 to be updated to ensure developments protect water quality and quantity. Alternatively, as mentioned above, this could fit within a detailed policy for the protection of the natural environment. Please note also that, referring to paragraph 6.404 and 6.405, the requirements for developments to demonstrate NBB is based on PPW12, rather than The Environment (Wales) Act 2016.

We welcome the illustrative master plans included in the deposit plan but would caveat that at the detailed stages schemes must be able to adapt, where necessary, to sites specific environmental constraints (including protected sites, species and habitats), for example in response to updated ecological appraisals or detailed species surveys. Designs need to be flexible enough to ensure compliance with the stepwise approach (avoid, minimise, mitigate) in achieving Net Biodiversity Benefit (NBB) and improving the resilience of ecosystems as required by Planning Policy Wales, edition 12 (PPW12) and Policy 9 of Future Wales, the National Plan. We note the plan has good reference to this within Policy SP20 and supporting paragraph 6.405, thus enabling thorough consideration at the project/planning application level and in master planning.

Atodiadau:

Sylw

1 Ymgynghoriad ar Cynllun Datblygu Lleol Newydd

ID sylw: 6652

Derbyniwyd: 11/03/2026

Respondent ID: 692

Ymatebydd: Natural Resources Wales (NRW)

Crynodeb o'r Gynrychiolaeth:

KEY SITES
A masterplan or spatial biodiversity or GI plan should demonstrate the retention, provision and enhancement of essential areas for protected species. It should ensure that individual site-based habitat provisions are not designed in isolation but considered in association with nearby sites to demonstrate how habitat connectivity and resilience will be provided both across the site and to the wider landscape. Note that functional separation of public open space and areas for biodiversity compensation may be required. Suitable buffers will need to be applied to any woodland and retained or created habitats on site. A sensitive lighting strategy will also likely be required for these sites. This point was raised previously during our review of the strategic candidate sites (ref: CAS-234819-C1V3, dated 4th October 2023).

Atodiadau:

Sylw

1 Ymgynghoriad ar Cynllun Datblygu Lleol Newydd

ID sylw: 6790

Derbyniwyd: 11/03/2026

Respondent ID: 1068

Ymatebydd: Persimmon Homes (East Wales)

Asiant : Boyer Planning

Crynodeb o'r Gynrychiolaeth:

In principle, Persimmon support the objective of Policy SP20 which intends to protect and enhance biodiversity and ecosystem resilience. However, in the interests of soundness we believe the proposed requirement relating to biodiversity enhancement should be reframed to ensure it remains consistent with national policy. In particular, the policy should clarify that development proposals are expected to deliver biodiversity betterment in a manner that is proportionate to the scale and nature of development and consistent with national guidance. The wording should avoid introducing a requirement for a specific or quantified biodiversity net gain approach that goes beyond the national policy framework. Ensuring that the policy reflects the approach set out in Planning Policy Wales 12 will provide greater certainty for applicants and decision-makers while still providing sufficient comfort in securing the requisite biodiversity improvements.

Atodiadau:

Sylw

1 Ymgynghoriad ar Cynllun Datblygu Lleol Newydd

ID sylw: 7034

Derbyniwyd: 11/03/2026

Respondent ID: 692

Ymatebydd: Natural Resources Wales (NRW)

Crynodeb o'r Gynrychiolaeth:

Areas of High Ecological Value
As previously noted within our preferred strategy response (Ref: CAS-244275-Q4F4, dated: 14th February 2024), the deposit plan continues to make reference to avoiding areas of ‘High Ecological Value’ (criterion 1 of SP20). We have not been able to establish where these areas are or how their ecological value is being determined. We consider this issue needs to be clarified and ideally a definition provided.

Atodiadau:

Cefnogi

1 Ymgynghoriad ar Cynllun Datblygu Lleol Newydd

ID sylw: 7202

Derbyniwyd: 11/03/2026

Respondent ID: 3741

Ymatebydd: H Jones, L Sungur and P John

Asiant : Herbert R Thomas Commercial Agents Cardiff

Crynodeb o'r Gynrychiolaeth:

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

Atodiadau: