Larger towns should take a larger share of developments/ Where are the sites in Barry, Penarth, Cowbridge, Llantwit Major? Larger towns will have a larger amount of brownfield development land - eg Barry Docks, Llandow. There is ample space for smaller better integrated developments in the rural vale that could be done without massive community upheaval and environmental damage.

Why are smaller communities taking the brunt of this housing drive. 1000's of houses in Rhoose, St Athan etc. Destroys community cohesion and identity and turns small communities in the Vale into identikit commuter deserts. Creating large high density (previously greenfield) estates to satisfy developers and the Authority's wish for higher planning gain should not take preference over brownfield sites in larger towns where more high rise could be considered to maximise numbers (like Cardiff & Cardiff Bay.

Scrap the existing LDP & come up with an LDP that is fair for all Vale residents & spread out smaller developments in all areas of covered by the Vale not just large developments in Barry St Athan & Rhoose.

Housing sites are concentrated around Barry, Rhoose St Athan which will create an enormous traffic problem on Port Rd West which is heavily congested at peak times.
The allocation of new housing does not take into consideration the services such as healthcare & schools which are already over subscribed.

Policy SP10 seeks to encourage a modal shift towards sustainable forms of transport through “siting new developments in sustainable and accessible locations where a range of services and facilities are within walking and cycling distance.”

Cowbridge comprises a sustainable self-contained settlement with regards to access to services such as primary and secondary schools, shops including supermarkets, medical services at the medical practice and pharmacy, sports activities including a leisure centre, a library and places of worship. Cowbridge has excellent connections to the A48 with regular bus services that provide access to Cardiff, Porthcawl and Llantwit Major. In order for the RLDP to achieve the second test of soundness (Is the Plan appropriate?), more housing growth should be located at Cowbridge owing to its sustainable location as a Service Centre Settlement.

1. Introduction
This representation is submitted on behalf of Powells as land promoters of Candidate Site CS387 at Culverhouse Cross. The representation seeks to set out our comments on the RLDP draft deposit as well as set forward the case for the allocation of the site within the Vale of Glamorgan Replacement Local Development Plan (RLDP) for residential development of up to 50 dwellings, including a minimum of 50% affordable housing.
The site presents a deliverable, sustainable and policy-aligned opportunity to address significant affordable housing need within the Wenvoe housing market area. Despite Culverhouse Cross being identified as a Primary Settlement within the RLDP settlement hierarchy, the Deposit Plan does not allocate any residential development within the settlement.
This approach results in a number of fundamental inconsistencies within the Plan including:
• A settlement hierarchy that identifies Culverhouse Cross as a Primary Settlement but provides no growth.
• Evidence of significant affordable housing need within the Wenvoe ward that is not spatially addressed.
• Policy mechanisms intended to support affordable housing delivery (HG4 and HG5) that cannot realistically operate due to Green Wedge constraints.
• A spatial strategy that places disproportionate emphasis on rail-based settlements despite national policy promoting a wider placemaking-led approach to sustainability.
The representation therefore demonstrates that the RLDP is unsound in respect of Culverhouse Cross and that Candidate Site CS387 represents a sustainable and deliverable allocation capable of addressing identified housing need.

2. Settlement Hierarchy and Spatial Strategy
2.1 Primary Settlement Status
The Deposit RLDP identifies Culverhouse Cross as a Primary Settlement outside the Strategic Growth Area within the settlement hierarchy. Under Policy SP2, Primary Settlements represent the highest tier of settlement outside the strategic growth corridor and are identified as locations capable of accommodating limited but proportionate levels of development, reflecting their relative accessibility, services, employment opportunities and role within the wider settlement network.
In spatial planning terms, the identification of a settlement as a Primary Settlement carries clear strategic implications. It indicates that the settlement performs an important functional role within the authority and that it represents one of the most sustainable locations for accommodating development outside the Strategic Growth Area. The hierarchy therefore provides the principal framework through which the Plan distributes housing growth across the authority.
However, despite this designation, the RLDP allocates no housing growth whatsoever within Culverhouse Cross.
This creates a clear inconsistency between the settlement hierarchy and the spatial distribution of development. If a settlement is identified within the hierarchy as capable of supporting development, the development plan should logically identify opportunities through which that growth can occur. The absence of any allocations, windfall capacity or clearly defined delivery mechanisms means that the designation has no practical effect within the spatial strategy.
In technical planning terms this weakens the internal coherence of the Plan. The Development Plans Manual requires that the spatial strategy and settlement hierarchy operate as a clear and consistent framework guiding the distribution of development. Where a hierarchy identifies settlements as sustainable locations for growth but the Plan subsequently provides no mechanism for that growth to occur, the hierarchy risks becoming descriptive rather than operational.
In the case of Culverhouse Cross, the RLDP acknowledges the settlement's role within the hierarchy but does not translate that role into spatial planning outcomes. The settlement was identified as a Primary Settlement largely due to its functional role as a significant retail, employment and transport hub, together with the recent residential redevelopment of the former ITV studios which has increased its residential function. Whilst the Council appears to treat this redevelopment as a one-off brownfield opportunity that does not justify further greenfield growth, the reality is that the decision to redevelop the site for housing rather than employment has established the principle that residential development is appropriate in this location. When considered alongside the settlement’s designation as a Primary Settlement, this demonstrates that the Council itself has already accepted the sustainability of residential growth at Culverhouse Cross. Despite these characteristics, the allocation strategy effectively treats Culverhouse Cross as if it were a settlement where growth is not supported, thereby failing to reflect the very factors that justified its elevation within the settlement hierarchy.
The complete absence of housing allocations at Culverhouse Cross therefore undermines the credibility of the hierarchy and creates an incoherent spatial strategy, particularly where other settlements within the same tier of the hierarchy are expected to accommodate growth. Applying unequal weight to settlements within the same settlement category introduces inconsistency into the spatial strategy and raises concerns regarding the overall soundness of the Plan.
2.2 Consequences of the Current Approach
The failure to allocate development in Culverhouse Cross has several important consequences for the effectiveness of the Plan.
• Unmet Local Housing Need – Local affordable housing needs within the Wenvoe ward are not addressed within the spatial distribution of development. The RLDP therefore fails to demonstrate how identified housing need within this part of the authority will be met.
• Ineffective Settlement Hierarchy – The settlement hierarchy fails to operate as a meaningful spatial planning tool. If Primary Settlements are not expected to accommodate any development, the distinction between settlement tiers becomes blurred and the hierarchy ceases to function as a mechanism for directing growth.
• Displacement of Development Pressure – Housing demand associated with the eastern Vale is displaced to other settlements rather than being distributed across the settlement network in accordance with the hierarchy. This results in an imbalanced spatial strategy.
• Loss of Sustainable Small-Scale Opportunities – Opportunities for small-scale affordable housing delivery in locations close to employment, services and public transport are lost. This is particularly relevant in the case of Culverhouse Cross which functions as a significant employment and retail centre.
• Policy Mechanisms That Cannot Operate – The Plan relies on affordable housing exception mechanisms to deliver housing within settlements such as Culverhouse Cross. However, the extent of Green Wedge designation means that these mechanisms cannot realistically function without explicit clarification within the Plan.
Taken together these issues demonstrate that the current spatial strategy does not fully respond to the functional role of Culverhouse Cross within the settlement hierarchy and results in a distribution of development that is neither balanced nor responsive to local housing needs.
3. Affordable Housing Need and Delivery
3.1 Evidence of Need
The Council's own housing evidence demonstrates a substantial requirement for affordable housing across the Vale of Glamorgan, including within rural settlements and the Wenvoe housing market area. The Local Housing Market Assessment identifies a significant backlog of need together with an ongoing annual requirement for additional affordable homes throughout the plan period. Whilst Welsh Government has queried the justification for elevating Culverhouse Cross to Primary Settlement status during the plan preparation process, the available evidence demonstrates that the settlement performs a clear functional role within the eastern Vale. In particular, the settlement benefits from strong bus connectivity to Cardiff and Barry together with established cycle and active travel links, and it sits within a ward where unmet affordable housing need has been clearly identified. When these factors are considered together, they reinforce the rationale for recognising Culverhouse Cross as a sustainable location capable of accommodating proportionate residential growth. This evidence confirms that the need for affordable housing is not confined to the authority’s largest settlements but exists across the wider settlement network, including rural wards.
Affordable housing need is particularly acute for smaller one to three bedroom homes, reflecting the changing composition of households and the prevalence of single person and smaller family households. Waiting list data demonstrates significant unmet demand across the authority, particularly for social rented and intermediate homes that are accessible to lower and middle income households.
Within the Wenvoe ward specifically, housing register data identifies a clear need for affordable housing that cannot currently be met through existing supply. This indicates that households with a local connection to the area are unable to access suitable housing within their own community and must either remain in unsuitable accommodation or relocate to other settlements.
Despite this evidence, the RLDP does not allocate any sites capable of delivering affordable housing within Culverhouse Cross or Wenvoe. The absence of allocations means that the Plan does not clearly demonstrate how identified affordable housing needs arising within this part of the authority will be addressed. In spatial planning terms this raises concerns regarding the effectiveness of the Plan, as development plans are expected to respond directly to evidenced housing need and ensure that opportunities for affordable housing delivery are distributed across the settlement hierarchy rather than concentrated solely within a limited number of locations.
3.2 Role of Affordable Housing in the RLDP
The RLDP identifies a requirement to deliver a significant number of affordable homes during the plan period in order to respond to the substantial backlog of need identified within the Local Housing Market Assessment. In practice the Plan relies upon several delivery mechanisms to achieve this target, including:
• Affordable housing contributions secured through Section 106 agreements on market housing sites • Affordable housing-led allocations delivering a minimum proportion of affordable homes • Affordable housing exception sites outside settlement boundaries • Windfall development opportunities that may arise during the plan period
For the overall strategy to be effective, these mechanisms must operate across the settlement hierarchy so that affordable housing delivery is not overly concentrated in a small number of locations. However, in the case of Culverhouse Cross none of these mechanisms realistically provide delivery opportunities. There are no allocated housing sites within the settlement capable of generating affordable housing contributions, no affordable housing-led allocations within the settlement boundary, and the extensive Green Wedge designation surrounding the settlement significantly constrains the realistic operation of the affordable housing exception site policy. In practical terms this means that, despite clear evidence of unmet affordable housing need within the Wenvoe ward, the RLDP does not identify any credible mechanism through which that need could be addressed locally. This further reinforces the conclusion that the spatial strategy fails to respond effectively to evidenced housing need in this part of the authority.
4. Policy HG4 and HG5 – Practical Deliverability
4.1 Affordable Housing Led Sites (HG4)
Policy HG4 identifies affordable housing-led allocations delivering a minimum of 50% affordable housing.
However these sites are located within settlement boundaries.
At Culverhouse Cross there are no available sites within the settlement boundary capable of delivering such schemes.
As a result HG4 cannot operate as an effective delivery mechanism in this settlement.
4.2 Affordable Housing Exception Sites (HG5)
Policy HG5 allows small-scale affordable housing exception sites outside settlement boundaries where a clear local need is demonstrated.
Culverhouse Cross is specifically identified as a settlement where exception sites may be appropriate.
However the majority of land surrounding the settlement is designated as Green Wedge.
The RLDP does not clearly explain how Policy HG5 should operate where land is also designated as Green Wedge.
This creates a policy ambiguity.
If Green Wedge policy prevents the operation of HG5 entirely, then the policy mechanism identified by the Council for delivering affordable housing in these settlements cannot realistically function.
If HG5 is intended to operate within Green Wedges where the strategic function of the designation is not harmed, then the Plan should make this clear.
Without this clarification the Plan risks creating theoretical delivery mechanisms that cannot be implemented in practice.
5. Green Wedge Considerations
5.1 Purpose of Green Wedges
Green Wedge designations are local planning policy tools used to manage the form of settlements and prevent inappropriate expansion of built development into open countryside. Planning Policy Wales explains that Green Wedges perform a similar function to Green Belts at a local level and are primarily intended to protect the spatial separation between settlements and maintain the distinction between urban areas and the countryside.
Green Wedges are typically designated where there is demonstrable development pressure and where reliance solely on settlement boundaries would not be sufficient to maintain the desired urban form. Their purpose is therefore strategic rather than absolute: they are intended to guide the form and direction of development rather than impose a blanket prohibition on all development.
National policy identifies five principal purposes for Green Wedges:
• Preventing the coalescence of large towns or cities with neighbouring settlements. • Managing urban form through controlled expansion of urban areas. • Assisting in safeguarding the countryside from encroachment. • Protecting the setting of urban areas. • Assisting urban regeneration by encouraging the recycling of urban land.
Planning Policy Wales also makes clear that Green Wedges should be reviewed as part of the development plan process and should only be retained where there is a demonstrable need for their continued designation.
5.2 Evidence from the Green Wedge Assessment
The Council’s own Green Wedge Background Paper (BP27) assesses the land surrounding Culverhouse Cross as part of Green Wedge MG18 (3) – North of Wenvoe. The study divides the designation into a number of parcels (NW1, NW2 and NW3) and assesses their contribution against the five Green Wedge purposes.
Importantly, the assessment demonstrates that land immediately adjoining the urban edge of Culverhouse Cross does not perform a uniformly strong Green Wedge function.
For example, Parcel NW1 – which lies adjacent to the commercial and highway infrastructure associated with Culverhouse Cross – is identified as making only a weak contribution to the purpose of preventing settlement coalescence and a weak contribution to protecting the setting of the urban area, with an overall contribution rating of Moderate.
Similarly, Parcel NW2 – which also lies adjacent to the settlement edge – is assessed as making only a moderate contribution to preventing settlement coalescence and managing urban form, while again making only a weak contribution to protecting the setting of the settlement.
The study explicitly notes that some parcels around Culverhouse Cross do not lie within a gap where coalescence between settlements would occur, and therefore make only a limited contribution to that purpose.
These findings are important because they demonstrate that the Green Wedge designation in this location performs a varied and nuanced role rather than representing land of uniformly high strategic importance.
5.3 Relationship of the Site to the Green Wedge
Candidate Site CS387 occupies a contained position immediately adjacent to the existing urban edge of Culverhouse Cross. In spatial terms the site sits within an area where the Green Wedge assessment identifies only a moderate contribution to the strategic purposes of the designation.
The Green Wedge study also recognises that the retail park, major highway infrastructure and recent residential development at the former ITV studios site exert an urbanising influence on the surrounding land.
Against this context, the development of a small and contained residential scheme adjacent to the settlement boundary would represent a logical rounding-off of the urban edge rather than a significant extension of built form into the wider countryside.
The proposal has been carefully designed to retain areas of open land and maintain visual openness across the wider Green Wedge. Landscape buffers and retained open areas would ensure that the remaining Green Wedge continues to fulfil its strategic function.
Importantly, the Green Wedge assessment itself acknowledges that the area around Culverhouse Cross experiences development pressure due to its relatively sustainable location on the western edge of Cardiff and its strong highway accessibility.
In this context, it is necessary for the development plan to strike a balance between protecting the strategic purposes of the Green Wedge and responding to identified housing needs. The limited and carefully contained development proposed at Candidate Site CS387 would achieve this balance by delivering much needed affordable housing while maintaining the wider strategic function of the Green Wedge.
5.4 Implications for the Spatial Strategy
Candidate Site CS387 occupies a contained position adjacent to the existing urban edge of Culverhouse Cross. Green Wedge in this location has been defined as performing a low function in terms of preventing coalescence which is set out within the Councils' own Green Wedge study.
Development of the site would represent a logical rounding-off of the settlement rather than an incursion into open countryside.
The proposal has been carefully designed to retain areas of open land and maintain visual openness across the wider Green Wedge.
The development would therefore not undermine the strategic objective of preventing coalescence between Culverhouse Cross and Cardiff.
6. Sustainability of Culverhouse Cross
6.1 Functional Sustainability
Culverhouse Cross functions as a significant employment, retail and service centre within the eastern Vale of Glamorgan and forms one of the principal commercial hubs on the western edge of Cardiff. Although the settlement has historically been characterised primarily by commercial uses, recent residential development has strengthened its role as a mixed-use location where people can live, work and access services within close proximity.
The settlement benefits from a number of key sustainability characteristics which support its role within the settlement hierarchy, including:
• Major retail and employment areas including the Valegate and Culverhouse Cross retail parks which provide a substantial range of jobs and services. • Frequent bus services linking the settlement with Cardiff, Barry and surrounding communities. • Access to established active travel routes connecting the settlement with nearby residential areas and employment locations. • Immediate proximity to strategic highway infrastructure including the A48 and A4232, providing direct connectivity to Cardiff and the wider regional road network.
Taken together, these characteristics mean that Culverhouse Cross operates as a highly accessible location where residents are able to access employment, retail and service opportunities within walking distance or via short public transport journeys. The presence of significant employment uses within the settlement further reduces the need for long-distance commuting and supports the creation of a more self-contained and sustainable community.
Importantly, sustainability within national planning policy is not defined solely by the presence of rail infrastructure but rather by the ability of residents to access services, employment and facilities through a range of transport modes. In this respect Culverhouse Cross performs strongly due to the combination of employment opportunities, public transport connectivity and proximity to Cardiff.
6.2 Alignment with National Policy
National planning policy promotes development in locations where people are able to access jobs, services and community facilities without the need for excessive travel. Planning Policy Wales in particular emphasises the importance of locating new housing in places that support sustainable placemaking outcomes and reduce reliance on private car travel.
Culverhouse Cross clearly meets these criteria. The settlement provides immediate access to employment, retail, healthcare and service facilities together with strong public transport connections into Cardiff and other nearby settlements. This level of accessibility is entirely consistent with the principles of sustainable development promoted through national planning policy.
The absence of a rail station does not in itself render a location unsustainable. Many settlements across Wales function successfully as sustainable communities without direct rail connectivity where other transport options and local services are available.
An approach to spatial planning which places disproportionate emphasis on rail-based settlements risks overlooking locations such as Culverhouse Cross which already function as important employment and service centres within the wider settlement network. A transport strategy focused solely on rail connectivity fails to recognise the role of bus services, active travel and proximity to employment in supporting sustainable communities.
7. Site Suitability and Deliverability
7.1 Deliverability
The site is available, viable and capable of being delivered within the early years of the Plan period. Importantly, the site does not rely on complex land assembly, strategic infrastructure investment or long lead-in times that often delay the delivery of larger strategic allocations.
Key deliverability characteristics include:
• Single land ownership – The site is controlled by a single, motivated landowner working in partnership with an experienced land promoter. This removes the risk of fragmented ownership which can frequently delay the delivery of allocated sites.
• No abnormal infrastructure requirements – The site does not require strategic highway works, major utility diversions or significant ground remediation. Development can therefore proceed without the need for substantial upfront infrastructure investment.
• Existing access arrangements – The site benefits from an established access point which currently serves the lawful dog-walking business operating on the land. This demonstrates that the site already functions as an accessible and serviced parcel of land and reduces the complexity of future development.
• Demonstrated viability – Preliminary development appraisal work indicates that the site can support a scheme delivering approximately 50 dwellings including a minimum of 50% affordable housing while remaining financially viable. This reflects realistic build costs and values within the local housing market.
Taken together, these factors demonstrate that the site represents a deliverable short-term opportunity capable of contributing to the Council’s housing supply early in the plan period. This is particularly important given the well-recognised need for development plans to allocate sites that can deliver housing quickly rather than relying solely on longer-term strategic sites.
7.2 Development Capacity
The proposed site could deliver approximately 50 dwellings, including a minimum of 50% affordable housing, in accordance with the objectives of Policy HG4 and the wider affordable housing strategy within the RLDP.
This scale of development has been carefully considered to ensure that it reflects the role of Culverhouse Cross within the settlement hierarchy while remaining proportionate to the size and character of the settlement. As a Primary Settlement outside the Strategic Growth Area, Culverhouse Cross is identified as a location capable of accommodating limited but meaningful levels of growth that support local housing needs.
A scheme of around 50 homes represents an appropriate and sustainable level of development which would:
• Provide a meaningful contribution towards meeting local affordable housing need within the Wenvoe ward. • Integrate effectively with the existing built form at the edge of Culverhouse Cross. • Avoid the need for large-scale urban expansion or major infrastructure investment. • Maintain the wider strategic function of the surrounding Green Wedge through a contained and well-designed development footprint.
Importantly, the proposed capacity reflects a small-scale extension to the existing settlement, rather than a strategic urban expansion. This approach aligns with the spatial strategy for Primary Settlements outside the Strategic Growth Area, where proportionate growth is expected to occur through modest and deliverable sites capable of meeting local needs.
The proposed allocation would therefore represent a logical and sustainable opportunity for residential development that complements the role of Culverhouse Cross within the settlement hierarchy while supporting the delivery of much-needed affordable housing.
8. Soundness of the RLDP
For a development plan to be considered sound it must satisfy the key tests set out within the Development Plans Manual and national planning policy. In summary, a sound plan must be:
• Justified – founded on a robust and credible evidence base and representing the most appropriate strategy when considered against reasonable alternatives. • Effective – deliverable over the plan period with clear and realistic mechanisms for implementation. • Consistent with national policy – aligned with the principles and objectives of Planning Policy Wales and the wider framework for sustainable placemaking.
The current RLDP approach to Culverhouse Cross raises significant concerns in relation to each of these tests.
Justified
The Plan identifies Culverhouse Cross as a Primary Settlement outside the Strategic Growth Area, recognising its accessibility, employment function and role within the wider settlement network. However, despite this designation, the RLDP allocates no housing growth whatsoever within the settlement.
This creates a clear disconnect between the evidence underpinning the settlement hierarchy and the spatial strategy that flows from it. If the evidence base demonstrates that Culverhouse Cross is sufficiently sustainable to be classified as a Primary Settlement, it logically follows that the Plan should provide opportunities for proportionate residential growth within or adjoining the settlement.
The absence of any allocations therefore raises questions as to whether the spatial strategy represents the most appropriate approach when considered against reasonable alternatives. In particular, the Plan does not adequately explain why modest growth opportunities adjacent to the settlement boundary – such as the proposed allocation of Candidate Site CS387 – have been discounted despite their potential to deliver significant levels of affordable housing.
Effective
A development plan must demonstrate that its strategy can be realistically delivered over the plan period. In this case the RLDP relies heavily on a number of policy mechanisms to deliver affordable housing, including market-led allocations, affordable housing-led sites and rural exception sites.
However, these mechanisms are not capable of operating effectively within Culverhouse Cross. There are no allocated sites within the settlement capable of generating affordable housing contributions, no affordable housing-led allocations within the settlement boundary, and the extensive Green Wedge designation surrounding the settlement severely restricts the realistic operation of affordable housing exception sites.
As a result, although the Plan identifies a clear need for affordable housing within the Wenvoe ward, it fails to identify any credible delivery mechanism through which that need could be addressed locally. This creates a clear risk that the Plan will not deliver the spatial distribution of affordable housing that its evidence base identifies as necessary.
Consistent with National Policy
Planning Policy Wales places strong emphasis on sustainable placemaking and the creation of communities where people are able to access employment, services and facilities without the need for excessive travel. National policy also promotes the efficient use of land and encourages development in locations that already benefit from strong transport connections and established infrastructure.
Culverhouse Cross performs strongly against these principles. The settlement functions as a major retail and employment hub on the western edge of Cardiff and benefits from frequent bus services, active travel links and immediate access to strategic road infrastructure.
The spatial strategy set out in the RLDP does not fully reflect these placemaking principles. By directing growth away from Culverhouse Cross despite its accessibility and service base, the Plan risks overlooking opportunities to deliver sustainable residential development in locations where people can live close to employment and services.
Taken together, these issues demonstrate that the current strategy for Culverhouse Cross is not fully justified by the evidence, cannot be shown to operate effectively in practice, and does not fully reflect the wider objectives of national planning policy. The allocation of Candidate Site CS387 would provide a practical and proportionate means of addressing these shortcomings while supporting the delivery of affordable housing within a sustainable settlement location.
9. Proposed Modification
To address the issues identified throughout this representation it is recommended that the RLDP be modified to allocate Candidate Site CS387, Land at Culverhouse Cross, for residential development. The allocation would represent a modest and proportionate extension to the existing settlement boundary and would provide a practical mechanism through which the Plan could respond to clearly identified affordable housing needs within the Wenvoe ward.
The modification would ensure that the spatial strategy properly reflects the role of Culverhouse Cross within the settlement hierarchy while maintaining the strategic purposes of the surrounding Green Wedge designation.
The allocation should provide for:
• Up to 50 dwellings delivered as a carefully planned settlement edge scheme which integrates with the existing built form at Culverhouse Cross.
• A minimum of 50% affordable housing, ensuring that the development makes a meaningful contribution towards meeting the substantial backlog of affordable housing need identified within the Local Housing Market Assessment and the housing register for the Wenvoe ward.
• Landscape buffers and retained open space, designed to maintain visual openness and ensure that the remaining Green Wedge continues to fulfil its strategic function in preventing the coalescence of settlements.
Incorporating this allocation within the RLDP would enable the Plan to:
• Address locally evidenced housing need by providing an opportunity to deliver affordable homes within the community where demand has been identified.
• Support the role of Culverhouse Cross as a Primary Settlement by allowing proportionate residential growth that reflects the settlement’s accessibility, employment base and transport connectivity.
• Deliver affordable housing in a sustainable location, close to employment areas, retail services and public transport routes.
• Provide a deliverable short-term housing site capable of contributing to housing supply early in the plan period.
• Maintain the strategic function of the Green Wedge by focusing development on a contained parcel of land adjacent to the urban edge while retaining substantial areas of open land.
• Improve the effectiveness and soundness of the RLDP by ensuring that the spatial strategy properly aligns with the settlement hierarchy and that credible delivery mechanisms exist for affordable housing within this part of the authority.
Alternative Policy Approach
In the event that the Council is not minded to allocate Candidate Site CS387, an alternative and equally effective modification would be to introduce a policy mechanism that allows affordable housing-led windfall sites within Primary Settlements located in Green Wedge designations, where it can be clearly demonstrated that development would not undermine the strategic purpose of the Green Wedge.
Such a policy could allow modest residential schemes where:
• the development is affordable housing-led, providing a significant proportion of affordable homes; • the site is adjacent to the existing settlement boundary and represents a logical rounding-off of the urban edge; • it can be demonstrated that the development would not result in unacceptable coalescence between settlements; • the scheme retains sufficient open land and landscape buffers to maintain the wider openness of the Green Wedge.
Introducing such a mechanism would provide a practical means of ensuring that affordable housing needs in settlements such as Culverhouse Cross can be addressed without undermining the strategic purpose of the Green Wedge designation. It would also resolve the current policy ambiguity whereby the Plan identifies settlements such as Culverhouse Cross as suitable locations for affordable housing exception sites but does not clearly explain how such sites can come forward where surrounding land lies within the Green Wedge.
This approach would therefore improve the effectiveness, flexibility and soundness of the RLDP by ensuring that affordable housing delivery mechanisms can operate in practice across the full settlement hierarchy.
10. Conclusion
Culverhouse Cross represents a sustainable and appropriate location for small-scale residential growth when considered against the evidence base underpinning the RLDP and the wider objectives of national planning policy. The settlement functions as an established employment, retail and service hub on the western edge of Cardiff and benefits from strong public transport connections, active travel links and direct access to strategic highway infrastructure. These characteristics have already been recognised through the Council’s decision to designate Culverhouse Cross as a Primary Settlement within the settlement hierarchy.
Despite this designation, the RLDP does not allocate any housing within the settlement and does not identify any credible mechanism through which locally arising housing needs can be addressed. This creates a clear inconsistency within the spatial strategy. A settlement which is recognised as sustainable and capable of accommodating proportionate levels of development cannot logically be treated as a location where no growth is expected to occur.
The absence of allocations also prevents the delivery of much-needed affordable housing within the Wenvoe ward, where the Council’s own evidence identifies a clear and persistent backlog of need. Without opportunities for development within or adjoining Culverhouse Cross, households with a local connection to the area are likely to be displaced to other settlements, undermining the objective of creating balanced and inclusive communities across the Vale of Glamorgan.
Candidate Site CS387 provides a deliverable and policy-compliant opportunity to address this issue. The site represents a modest and contained extension to the existing settlement boundary and is capable of delivering approximately 50 dwellings including a minimum of 50% affordable housing. The proposal has been carefully designed to integrate with the existing built form, maintain the wider function of the surrounding Green Wedge and provide a meaningful contribution towards meeting local housing needs.
Allocating the site would therefore provide a practical and proportionate means of improving the effectiveness of the RLDP. It would ensure that the spatial strategy properly reflects the role of Culverhouse Cross within the settlement hierarchy, provide a credible mechanism for delivering affordable housing within this part of the authority and support sustainable placemaking in accordance with national planning policy.
For these reasons it is considered that Candidate Site CS387 should be allocated within the RLDP. Doing so would help ensure that the Plan provides a coherent, deliverable and policy-compliant framework for guiding development across the Vale of Glamorgan over the plan period.

A modest allocation at St Nicholas would represent proportionate growth consistent with the scale and character of the settlement.

The Spinney, St Nicholas (Site Ref: 460)
Boyer have prepared the following representation on behalf of Mr Fairweather in response to the current Vale of Glamorgan Replacement Local Development Plan (RLDP) 2021-2036 Deposit Plan Consultation.

A summary of our main representations is as follows:
• Significant concern is raised regarding the lack of residential allocations within the Minor Rural Settlements, in particular St Nicholas.
• Concern regarding the overall housing requirement and the need for an increased flexibility allowance.
• Questions asked regarding the spatial distribution and the lack of other allocations to provide a range and choice of housing.
• Confirmation of the limited constraints for The Spinney, St Nicholas (Site Ref: 460).
• Review of the Candidate Site Assessment; and
• Need to review the Settlement Boundary of St Nicholas.

SP1: Sustainable Growth Strategy
Whilst Policy SP1 outlines the housing delivery requirement (addressed under the response to SP6), the main concern for Mr Fairweather is the proposed primary focus of housing growth within the Vale being within the Strategic Growth Area. Whilst it is understood and supported by Mr Fairweather that new housing developments would be concentrated in locations which are served by existing public transport routes and provide the opportunity to enhance sustainable transport connectivity, it is shortsighted to concentrate this growth specifically along the railway line. The justification being that those settlements identified as being ‘Outside of the Strategic Growth Area’ – including St Nicholas, are equally as important as those within. St Nicholas is a sustainable location and located on an important public transport route (A48) and is well served by bus transport.

The principle of locating development at sustainable settlement is supported, however Mr Fairweather considered that limiting development at suitable settlements outside the Strategic Growth Area is not the correct approach and that greater flexibility is required to deliver the housing need. Currently under Policies HG1 and HG4, the only allocations in any Minor Rural Settlements amount to 122 dwellings in total (excluding any from St Nicholas). This also needs to be considered in the context of the 1,303 dwellings expected from large and small windfall developments. Clearly there is a requirement to provide further allocations in sustainable Minor Rural settlements identified as being ‘Outside of the Strategic Growth Area’ – namely St Nicholas.

In context of above, Mr Fairweather strongly recommends that appropriate consideration is given to the widening of the Strategic Growth Areas to include St Nicholas as a sustainable settlement which is capable of accommodating a new allocation at The Spinney (Site Ref: 460).

SP2: Settlement Hierarchy
Mr Fairweather previously supported the identification of St Nicholas as a Minor Rural Settlement and acknowledged its capacity to accommodate proportionate and sustainable growth, particularly given its accessibility and relationship with Cardiff to the east and access to Bridgend to the West. The Deposit Plan retains St Nicholas within the Minor Rural Settlement tier, however, does confirm that the settlement is outside the Strategic Growth Area.

Whilst the overarching principle of directing growth to the most sustainable settlements is supported, the Plan does not clearly demonstrate why settlements that are well connected and functionally related to larger centres, such as St Nicholas, should be subject to such constrained growth.

In this context, Mr Fairweather highlights Paragraph 3.10 which indicates that Minor Rural Settlements provide an ‘important range of services and facilities that play a functional role in meeting some of the basic needs of residents within rural areas, reducing the need to travel’.
Building upon this, Policy SP2 does highlight that ‘Minor Rural Settlements identified 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’.

Furthermore, the supporting text to Policy SP2 (Paragraph 6.17) confirms that ‘those settlements that are considered to have sufficient population, services, and facilities to accommodate small scale growth without it having a detrimental impact on their existing character and local environment’.

This all buildings upon the identified importance of Minor Rural Settlements within the Preferred Strategy which outlined in Paragraph 6.50 that it is ‘essential for the LDP to balance the growth in a way that supports the need of rural communities’ and whilst it is evident that within these settlements ‘general market housing will be limited to opportunities including infill’ (Paragraph 6.51), the enabling of an element of ‘open market housing will provide opportunities for the delivery of affordable housing reflecting the aspirations of rural communities to sustain their housing needs’ (Paragraph 6.51). This importance of Minor Rural Settlements needs to be carried more strongly forward in the Deposit Plan.

Moreover, the evidence base does not sufficiently justify the degree of restriction now applied, nor does it explain why proportionate additional growth in appropriate Minor Rural Settlements would undermine the spatial strategy. As drafted, the policy risks limiting flexibility in the distribution of housing across the Vale. Accordingly, it is considered that the approach to St Nicholas under Policy SP2 is not justified.

Clearly there continues to be a disconnect between the identified role and function of St Nicholas, which is supported, and the actual ability to deliver the appropriate range and choice of dwellings in the rural settlements. For example, The Spinney, St Nicholas (Site Ref: 460) is considered to naturally round-off the existing boundary, enclosing the envelope of development, without encroaching or sprawling beyond the existing line of built form, in a sustainable location which can accommodate an appropriate allocation.

SP6: Housing Requirement
As per Mr Fairweather’s previous comments to the Preferred Strategy, the concerns regarding a need for a higher housing level and the need for development to be appropriate placed in sustainable allocations in a settlement in which people want to live is still relevant.

Currently Policy SP6 establishes the overall housing requirement and applies a 10% flexibility allowance. The Policy suggests that to meet the identified housing requirement of 7,890 dwellings, provision will be made for the delivery of 8,660 homes and this will be delivered by:
• 3,837 dwellings from the existing land supply
• 3,520 dwellings on allocated sites
• 1,303 dwellings from large and small windfall developments

As per previous representations, Mr Fairweather considers that it’s important to take account of recent guidance 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. 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.
More recently in Swansea, the Council published their LDP2 Pre-Deposit Plan (Preferred Strategy) for consultation. 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.
Applying the same approach to other current Local Development Plans, it is evident that a flexible housing allowance above the current 10% threshold will be required. Having reviewed the Council’s evidence base Mr Fairweather considered that a minimum allowance of 15% would be reflective of the County’s growth aspirations and would seek an additional circa 400 dwellings (equating to a housing requirement of 9,074 dwellings inclusive of the 15% flexibility).

To accommodate this increased in flexibility allowance and over all housing numbers, it should be outlined that smaller sites typically deliver more quickly, are less infrastructure-dependent, and increase build-out rates through diversification. The Spinney represents precisely the type of deliverable site that should form part of an enhanced flexibility allowance.

Policy SP6 should therefore be amended to increase the flexibility margin to up to 15%, with consequential allocation of additional small and medium-sized sites.
HG1: Housing Allocations Table 3 spatial distribution
Mr Fairweather does not comment on any of the proposed housing allocations, however, does highlight that the delivery in incumbent upon a number of larger strategic sites, and that to allow a greater range and choice then smaller allocations in the Minor Rural Settlements. Only 161 units are proposed on smaller allocated sites, equating to approximately 7% of newly allocated supply.
In the context of the above, there remains significant concern that the spatial strategy continues to exclude allocations within Minor Rural Settlements, including St Nicholas.

The Plan recognises that Minor Rural Settlements provide an important range of services and facilities and play a functional role in meeting the needs of residents within rural areas. It further acknowledges that it is essential for the LDP to balance growth in a way that supports rural communities. Whilst general market housing is described as being limited to infill opportunities, the Plan also recognises that enabling an element of open market housing provides opportunities for the delivery of affordable housing and helps sustain rural communities.

There is therefore a clear disconnect between the identified role and function of settlements such as St Nicholas and the absence of any allocated sites (excluding the affordable led schemes under Policy HG4) capable of delivering an appropriate range and choice of dwellings. The strategy effectively restricts development to windfall and infill, without positively identifying opportunities that would logically consolidate and strengthen the settlement.

This approach is inconsistent with the settlement’s accessibility and functional role. St Nicholas is:
• Well connected to the A48 strategic highway network.
• Served by bus routes within close proximity to the site.
• Within commuting distance of Cardiff and Cowbridge.
• A sustainable and established residential community.

Land adjoining The Spinney, St Nicholas (Site Ref: 460) represents a contained and sustainable opportunity that naturally rounds off the existing settlement boundary. The site encloses the envelope of development without encroaching into open countryside or extending beyond the established line of built form. It is well related to existing services and infrastructure and is capable of accommodating a modest allocation consistent with the scale and character of the village.

A proportionate allocation at this location would align with the stated objectives of supporting rural communities, enabling a mix of market and affordable housing, and providing genuine choice within Minor Rural Settlements. The continued absence of such allocations undermines the internal consistency of the spatial strategy.
Furthermore, the strategy places substantial emphasis on rail-based corridors. Whilst development near rail infrastructure is supported in principle, sustainable growth should not be exclusively rail-led. Strategic highway connectivity and bus accessibility also represent legitimate and sustainable locational advantages.

The complete absence of allocations in Minor Rural Settlements creates an imbalance in distribution and limits housing choice. A modest allocation at The Spinney would represent proportionate growth consistent with the scale and character of the settlement.
HG4 – Affordable Housing Allocations

It is recognised that Policy HG4 does allocate development within some Minor Rural Settlements, but in the context of them being affordable housing led sites where there will be a requirement for the provision of a minimum 50% affordable housing to meet the affordable housing needs of the local community. Mr Fairweather has no objection in principle to this but does object to the fact that there is no development in St Nicholas (despite it being sustainably located on the A48).

Furthermore, The Spinney, St Nicholas (Site Ref: 460) proposes a 40% affordable housing provision which accords with Policy SP8 of the Deposit Plan. Should the Authority consider that the site is suitable for allocation under Policy HG4 then the provision can be amended to 50% to accord with the policy.

Candidate Site Response: The Spinney, St Nicholas (Site Ref: 460)
From a review of the Background Paper (BP18 a) - Candidate Site Assessment at Preferred Strategy Stage, we are aware that the candidate site The Spinney, St Nicholas (Site Ref: 460) has not progressed beyond Stage 2: Detailed Site Assessment: Site Characteristics and Physical Constraints.

The justification provided states that ‘The development would have an adverse impact on the character and setting of the St Nicholas Conservation Area’. Whilst this is disputed and it is considered that the site should have progressed, it is important to highlight that of all the Candidate Sites within St Nicholas, The Spinney has the least issues raised.

Other sites within the assessment raised concerns regarding Best and Most Versatile Land, intrusion into the open countryside and the loss of a sites identified as providing important views. Ultimately, Site Ref: 460, is clearly the most appropriate site for any development within St Nicholas and with limited constraints raised.
Turning to the reasons for not taking the site forward, the following is reiterated in the context of the impact on the character and setting of the Conservation Area.

Conservation Area Impact
St Nicholas is described in the Conservation Area Appraisal and Management Plan as ‘a low density, linear village located on the A48’ and the candidate site is located towards the west of the village and lies partially within the current Conservation Area boundary. The Authority will be aware that the Conservation Area has been amended over the years to its current illogical designation regarding the Paddock area, similar to that of the Settlement Boundary.

The development of the Candidate Site is a clearly a logical and sensible infill development, which would have limited impact upon the Conservation Area. The majority of the site is already hidden from the A48 via mature vegetation and existing boundary features, and any proposed development would maintain this approach and minimise the visual appearance on the Conservation Area.
Listed buildings and other historic buildings of special interest are identified in the Conservation Area Appraisal as ‘County Treasures’. These are situated at the heart of the Conservation Area. The buildings and their settings establish a scale and density for the historic area of the village to the south of St Nicholas’ Church.

More modern development, away from the centre of the village at Ger-y-Llan to the northeast, Dyffryn Close to the southeast and Old Rectory Drive to the west are suburban in character with larger houses and generous gardens. These are all excluded from the Conservation Area and represent development at a lower density than the historic core of the village.

Whilst only a part of the Candidate Site is located within the Conservation Area, it has to be seen in the context of an appropriate infill site that links the southern part of the village with the more modern suburban type of development at Old Rectory Drive to the west. More significantly, the site provides an opportunity for a development to make a positive contribution to the character and appearance of the Conservation Area as well as respect or enhance the special architectural or historic interest.

This can be achieved by providing a new front boundary to the site and houses with gardens, of the type identified in the Conservation Area Appraisal and Management Plan that help define the character of the village. Whilst the Candidate Site extends to the A48, this is to allow the appropriate minimal access junction, whilst the majority of the generous grass verge will be retained, meaning that development will be clearly set back a considerable distance from the road and the opposite pavement.

Thus, the development will be totally screened when travelling along the A48 and is therefore not considered to affect the views to the north of the site. The development will complement and enhance the character of the rural and built environment surrounding the site.
In line with the objectives of the St Nicholas Conservation Appraisal and Management Plan, the boundary treatments proposed will be sympathetic and in keeping with the surrounding area, such that they do not detract from the historic assets and desired lines of view. Again, whilst detailed design has not yet been progressed, any boundary treatments proposed will avoid the use of stained close boarded timber fencing, over-elaborate modern metal railings and gates. It is reiterated that the building line for the front of the development will not encroach any further forward that the existing boundary and will be designed to be innkeeping and not detract from the existing character of the Conservation Area. Moreover, the layout of the site has been designed in such a way that the spaciousness and green infrastructure is retained and enhanced from a redundant Paddock.

Furthermore, the characteristics that give the Conservation Area its special interest, as identified in the Conservation Area Appraisal and Management Plan have been used as references for the design of the illustrative site layout.

The proposal is to use local materials and design details designed to preserve or enhance the special interest of the Conservation Area. Limestone laid as rubble external walling, slate roofs and roadside walls of varying sizes predominate. More modern houses in the area are rendered and painted white. This, according to the Conservation Area Appraisal gives ‘some cohesiveness [to the area] despite their modern details’.

Elsewhere in the appraisal the village is described as having a ‘rural character’, a character that is reinforced by the existence of mature trees, singularly or in groups and simple pavements with narrow stone curves. The use of modern railings or timber fences are considered to be detrimental to the historic character of the conservation area.

Given the sites relationship with the Conservation Area, the proposal has been designed in to ensure that the development endeavours to protect, preserve and enhance the character of the area.

The site layout has been designed to avoid having the appearance of a suburban estate by providing a range of house types on plots that vary in size thereby maintaining the open structure of the conservation area as described. Furthermore, the existing boundaries to the east and west, which are subject to TPOs, will be retained and enhanced and not detract from the character of the Conservation Area.

The site marks a transition point between the western end of the linear historic core of the village and the lower density development at Old Rectory Drive.
The landscape proposals have been designed to include sustainable drainage, and the tree planting reflects the isolated trees or groups of trees referred to in the Conservation Area Appraisal as significant areas of character.

The illustrative site layout represents an appropriate scale of development and an efficient use of land and as such the proposed development will not have any detrimental impact upon the Conservation Area.
Deposit Plan Amendments
Settlement Boundary

Given the above and the further assessment below, the strong preference would be for the site to be allocated for residential development within St Nicholas. This would form a logical amendment to the Settlement Boundary to include the western parcel (former Paddock) of Candidate Site - The Spinney, St Nicholas (Site Ref: 460). The current Settlement Boundary is illogical as the site is surrounded by development on 3 boundaries and the simple rounding off along the southern boundary would allow for an appropriate windfall infill development.
Conservation Area

Given the above then it is considered that the Conservation Area boundary would need to be amended to reflect the allocation of the site.
These amendments would be required to the Deposit Proposals Map.

Site Assessment
The site was promoted through the Candidate Site process and assessed at Preferred Strategy stage. However, it is not allocated within the Deposit Plan and thus was not subject to updated reassessment as part of this stage of plan preparation.

For completeness, and in order to clearly demonstrate the limited and proportionate nature of the site’s constraints, the previous site assessment summary table is reproduced below. This is included to highlight that the site performs favourably in sustainability and deliverability terms, and that the matters previously cited as constraints are capable of mitigation through design.

A table comparing an updated site assessment prepared by Boyer against the Council’s assessment has been provided.

This representation, submitted on behalf of Mr Fairweather in response to the current Vale of Glamorgan Council Replacement Local Development Plan (RLDP) 2021–2036 Deposit Plan Consultation, maintains that Land adjoining The Spinney, St Nicholas (Site Ref: 460) represents a logical, sustainable and deliverable parcel that should be allocated as a suitable and viable residential site within the RLDP.

Significant concern remains regarding the absence of residential allocations within Minor Rural Settlements, particularly St Nicholas, and the continued reliance on a limited flexibility allowance under Policy HG1. An increased flexibility margin of up to 15% would necessitate the identification of additional sustainable and deliverable sites. Such growth should be directed, in part, toward appropriate locations within Minor Rural Settlements to ensure a genuine range and choice of housing and to support rural community sustainability.

It is further noted that the site performs favourably in the Council’s Candidate Site Assessment, with limited constraints identified. The matters previously raised, including Conservation Area considerations, are capable of sensitive mitigation through design and have been subject to detailed review. There is no substantive evidence demonstrating that the site is unsuitable for development.

Accordingly, the site is considered to represent a suitable, available and achievable allocation capable of contributing to the housing requirement, supporting affordable housing delivery, and reinforcing the spatial objectives of the Plan.
The Deposit Plan should therefore be amended to allocate Land adjoining The Spinney, St Nicholas (Site Ref: 460), or alternatively identify it as a reserve or flexibility site, in order to ensure the Plan is justified, effective and deliverable.

The complete absence of allocations in Minor Rural Settlements creates an imbalance in distribution and limits housing choice. A further allocation in Colwinston would represent proportionate growth consistent with the scale and character of the settlement.

Land adjacent to Waterton Lodge, Colwinston (Site Ref: 409)
Boyer have prepared the following representation on behalf of Andrew Raymond regarding their land interests associated with Candidate Site 409 (Land adjacent to Waterton Lodge, Colwinston) in response to the current Vale of Glamorgan Replacement Local Development Plan (RLDP) 2021– 2036 consultation.

A summary of the main representations are as follows:
• Concern regarding the absence of proportionate residential growth opportunities within rural settlements such as Colwinston;
• Concern regarding the overall housing requirement and the need for an increased flexibility allowance within the housing trajectory;
• Questions regarding the spatial distribution of development and the limited range and choice of sites outside the Strategic Growth Area;
• Confirmation that Candidate Site 409 (Land adjacent to Waterton Lodge, Colwinston) represents a logical and sustainable opportunity for modest residential development;
• Review of the Candidate Site Assessment process and the current status of the site within the Candidate Site Register; and
• The need to consider appropriate settlement boundary adjustments to facilitate proportionate growth in sustainable rural settlements.

SP1: Sustainable Growth Strategy
Whilst Policy SP1 outlines the housing delivery requirement (addressed under the response to SP6), the principal concern in relation to the site promotion is the concentration of the majority of future housing growth within the defined Strategic Growth Area.
It is understood and supported that new housing development should be located in sustainable locations with access to public transport and services. However, the approach adopted within the RLDP places an overly narrow emphasis on growth within the Strategic Growth Area, primarily focused along rail corridors. This approach risks overlooking other sustainable rural settlements which also demonstrate appropriate connectivity and capacity to accommodate proportionate growth.

Settlements outside the Strategic Growth Area continue to perform an important role within the Vale’s settlement hierarchy and rural economy. Villages such as Colwinston provide an established residential community and contribute to the vitality and sustainability of rural areas. Restricting opportunities for modest growth within such settlements risks undermining the long-term sustainability of rural communities.

The principle of directing development to sustainable settlements is supported. However, limiting development opportunities exclusively within the Strategic Growth Area is not considered to represent the most balanced or flexible spatial strategy. Greater flexibility should be introduced to allow appropriate small-scale allocations within sustainable rural settlements.

In this context, Candidate Site 409 (Land adjacent to Waterton Lodge, Colwinston) represents a sustainable opportunity for a modest residential development that would align with the scale and character of the settlement. The site lies adjacent to existing built form and would represent a logical and contained extension to the village.
SP2: Settlement Hierarchy

Mr Raymond supports the identification of Colwinston as a Minor Rural Settlement and acknowledged its capacity to accommodate proportionate and sustainable growth, particularly given its accessibility and relationship with Bridgend to the west and Cowbridge, Barry and Cardiff to the east. The Deposit Plan retains Colwinston within the Minor Rural Settlement tier, however, does confirm that the settlement is outside the Strategic Growth Area.
Whilst the overarching principle of directing growth to the most sustainable settlements is supported, the Plan does not clearly demonstrate why settlements that are well connected and functionally related to larger centres, such as Colwinston, should be subject to such constrained growth.

In this context, Mr Raymond highlights Paragraph 3.10 which indicates that Minor Rural Settlements provide an ‘important range of services and facilities that play a functional role in meeting some of the basic needs of residents within rural areas, reducing the need to travel’.
Building upon this, Policy SP2 does highlight that ‘Minor Rural Settlements identified 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’.

Furthermore, the supporting text to Policy SP2 (Paragraph 6.17) confirms that ‘those settlements that are considered to have sufficient population, services, and facilities to accommodate small scale growth without it having a detrimental impact on their existing character and local environment’.

This all building upon the identified importance of Minor Rual Settlements within the Preferred Strategy which outlined in Paragraph 6.50 that it is ‘essential for the LDP to balance the growth in a way that supports the need of rural communities’ and whilst it is evident that within these settlements ‘general market housing will be limited to opportunities including infill’ (Paragraph 6.51), the enabling of an element of ‘open market housing will provide opportunities for the delivery of affordable housing reflecting the aspirations of rural communities to sustain their housing needs’ (Paragraph 6.51). This importance of Minor Rural Settlements needs to be carried more strongly forward in the Deposit Plan.

Moreover, the evidence base does not sufficiently justify the degree of restriction now applied, nor does it explain why proportionate additional growth in appropriate Minor Rural Settlements would undermine the spatial strategy. As drafted, the policy risks limiting flexibility in the distribution of housing across the Vale. Accordingly, it is considered that the approach to Colwinston under Policy SP2 is not justified.

Clearly there continues to be a disconnect between the identified role and function of Colwinston, which is supported, and the actual ability to deliver the appropriate range and choice of dwellings in the rural settlements. For example, a modest allocation at Land adjacent to Waterton Lodge, Colwinston (Candidate Site 409) would represent proportionate growth that reflects the scale and character of the settlement. The site sits adjacent to existing development and would consolidate the existing settlement pattern without resulting in sprawl into the open countryside.

The current approach within Policy SP2 risks constraining flexibility within the spatial strategy and limiting opportunities to support sustainable rural communities.

SP6: Housing Requirement
Concerns are raised regarding the overall housing requirement and the level of flexibility incorporated within the Plan.

Policy SP6 currently establishes a housing requirement of 7,890 dwellings over the Plan period and includes a flexibility allowance of 10%, resulting in an overall provision of 8,660 dwellings.
The proposed supply is anticipated to be delivered through:
• 3,837 dwellings from the existing land supply
• 3,520 dwellings on allocated sites
• 1,303 dwellings from large and small windfall developments
Whilst the inclusion of a flexibility allowance is supported, it is considered that a 10% allowance may not be sufficient to ensure resilience within the housing trajectory.
Recent experience from other Local Development Plans across Wales has demonstrated the importance of incorporating higher flexibility allowances to account for delivery uncertainty, infrastructure constraints and potential delays to larger strategic sites.

For example, other authorities have incorporated flexibility allowances in excess of the standard 10% to ensure the robustness of their housing supply and to provide a greater degree of adaptability should circumstances change during the Plan period.

In this context, it is considered that the Vale of Glamorgan RLDP should incorporate a flexibility allowance of at least 15%. This would provide additional resilience within the housing trajectory and reduce reliance on a limited number of larger strategic allocations.
Smaller sites such as Candidate Site 409 at Waterton Lodge, Colwinston are particularly valuable in this context. Smaller sites are typically:
• More deliverable in the short term
• Less dependent on major infrastructure investment
• Capable of contributing to early housing delivery
• Able to increase overall build-out rates
Such sites can therefore play an important role in supporting the delivery of the Plan’s housing requirement and enhancing flexibility within the supply.

HG1: Housing Allocations
Mr Raymond does not comment on any of the proposed housing allocations, however, does highlight that the delivery is incumbent upon a number of larger strategic sites, and that to allow a greater range and choice then smaller allocations in the Minor Rural Settlements are required. Only 122 units are proposed on smaller allocated sites, equating to approximately 2.6% of newly allocated supply under (E) Rural Affordable Housing Led Sites – policy HG4.

In the context of the above, there remains significant concern that the spatial strategy continues to exclude the required number of allocations within Minor Rural Settlements, including Colwinston.

The Plan recognises that Minor Rural Settlements provide an important range of services and facilities and play a functional role in meeting the needs of residents within rural areas. It further acknowledges that it is essential for the LDP to balance growth in a way that supports rural communities. Whilst general market housing is described as being limited to infill opportunities, the Plan also recognises that enabling an element of open market housing provides opportunities for the delivery of affordable housing and helps sustain rural communities.
It is agreed that the inclusion of smaller allocations can:
• Improve overall housing delivery rates
• Provide greater choice within the housing market
• Reduce delivery risk by diversifying supply
• Support rural communities through proportionate growth

Whilst it is noted that there is a proposed allocation within Colwinston – HG4 (1) – Land to the East of Colwinston for 25 units, Mr Raymond maintains that there is still a clear disconnect between the identified role and function of settlements such as Colwinston and the absence of any further allocated sites capable of delivering an appropriate range and choice of dwellings.

The strategy effectively restricts development to windfall and infill, without positively identifying opportunities that would logically consolidate and strengthen the settlement.
This approach is inconsistent with the settlement’s accessibility and functional role. Colwinston is:
• Well connected to the A48 strategic highway network;
• Served by bus routes within close proximity to the site;
• Within commuting distance of Bridgend, Cowbridge, Barry and Cardiff;
• A sustainable and established residential community.
Land adjacent to Waterton Lodge, Colwinston (Site Ref: 409) represents a contained and sustainable opportunity that naturally rounds off the existing settlement boundary. The site encloses the envelope of development without encroaching into open countryside or extending beyond the established line of built form. It is well related to existing services and infrastructure and is capable of accommodating a modest allocation consistent with the scale and character of the village.

A proportionate allocation at this location would align with the stated objectives of supporting rural communities, enabling a mix of market and affordable housing, and providing genuine choice within Minor Rural Settlements. The continued absence of such allocations undermines the internal consistency of the spatial strategy.

Furthermore, the strategy places substantial emphasis on rail-based corridors. Whilst development near rail infrastructure is supported in principle, sustainable growth should not be exclusively rail-led. Strategic highway connectivity and bus accessibility also represent legitimate and sustainable locational advantages.

The complete absence of allocations in Minor Rural Settlements creates an imbalance in distribution and limits housing choice. A modest allocation at Waterton Lodge would represent proportionate growth consistent with the scale and character of the settlement.

HG4 – Affordable Housing Allocations
It is recognised that Policy HG4 does allocate development within some Minor Rural Settlements, and in particular within Colwinston HG4 (1) – Land to the East of Colwinston for 25 units. In the context of Policy HG4 they will be affordable housing led sites where there will be a requirement for the provision of a minimum 50% affordable housing. This is to meet the affordable housing needs of the local community. Mr Raymond has no objection in principle to this but does object to the fact that there is no other development opportunities recognised in Colwinston (despite it being sustainably located on the A48).

Furthermore, Land adjacent to Waterton Lodge, Colwinston (Site Ref: 409) could be reduced in size and could be amended to offer 50% affordable housing to accord with the policy (or even 100% affordable if the Authority sought this).

A balanced approach which allows both affordable housing led schemes and modest mixed-tenure developments would provide greater flexibility and assist in delivering a broader range of housing needs.

A modest development at Land adjacent to Waterton Lodge, Colwinston (Candidate Site 409) could provide an opportunity to deliver both market and affordable housing in accordance with Policy SP8. This would support local housing needs whilst maintaining the scale and character of the settlement.

Candidate Site Response: Land adjacent to Waterton Lodge, Colwinston (Candidate Site 409)
Candidate Site 409 (Land adjacent to Waterton Lodge, Colwinston) was submitted to the Vale of Glamorgan Council during the 2022 Call for Candidate Sites as part of the preparation of the Replacement Local Development Plan (RLDP) 2021–2036.

The site is currently included within the Candidate Site Register, which represents a list of sites submitted for consideration through the plan-making process. Inclusion within the register does not in itself indicate that a site will be allocated for development, as all sites are subject to a structured assessment process.

These stages consider a range of factors including sustainability, accessibility, environmental constraints and deliverability.

As part of the ongoing plan preparation process, the Council produced an updated Candidate Site Register following the initial submissions. Sites continue to be evaluated as part of the evidence base supporting the RLDP.

In this context, Land adjacent to Waterton Lodge, Colwinston represents a sustainable and deliverable opportunity for modest residential development which could contribute positively towards the Plan’s housing supply.

The site is located adjacent to the existing settlement and is well related to the current built form. Development in this location would represent a logical and contained extension to the village, rather than an isolated incursion into open countryside.

Furthermore, the site has been promoted through the formal candidate site process and should therefore be considered fully within the Council’s site assessment framework.

Deposit Plan Considerations
Settlement Boundary

Given the location of Candidate Site 409 adjacent to the existing settlement of Colwinston, consideration should be given to whether a modest adjustment to the settlement boundary would enable the site to be appropriately integrated within the settlement.

A logical rounding-off of the existing settlement edge would allow development to occur in a manner that respects the existing built form and maintains a clear and defensible settlement boundary.

Such an approach would represent a proportionate response to the need for modest housing growth within rural settlements.

Site Assessment
The site was formally submitted through the Candidate Site process and is currently listed within the Council’s Candidate Site Register.

Given the role that smaller deliverable sites can play in supporting housing delivery, it is important that sites such as Land adjacent to Waterton Lodge, Colwinston are fully considered as part of the ongoing assessment process.
Smaller sites can provide valuable flexibility within the housing trajectory and contribute to early housing delivery within the Plan period.

Turning to the main reasons the site was not taken forward Mr Raymond provides the following response:
(a) Alleged intrusion into the open countryside
The Stage 2 Register cites “unacceptable intrusion into the open countryside”. Mr Raymond submits that this conclusion fails to reflect the site’s physical containment and relationship to the built form.
• The site directly adjoins existing dwellings at Waterton Lodge and mature boundary hedgerows; development here would constitute rounding-off rather than isolated sprawl.
• A strong landscape framework already exists, and additional planting could reinforce defensible boundaries.
Accordingly, the site’s development would not materially extend the settlement into open countryside or harm landscape character, consistent with PPW paragraph 3.60.
(b) Highways and accessibility constraints
The Council refers to “major highways constraints” but no evidence highway assessment has been published by the Authority. Mr Raymond’s preliminary review confirms that safe vehicular access can be achieved from the adjoining local highway with modest engineering works and that the scale envisaged would generate limited traffic, well within local-road capacity.
Future submission of a Transport Statement can demonstrate compliance with PPW (Section 5: Active and Socially Just Places) and LDP Policy MD2 (criteria 6 and 8).
The site lies within walking distance of Colwinston’s core facilities (village hall, public house, bus stops), enabling sustainable travel choices for residents.
(c) Scale of development
Development at a scale that represents proportionate growth for Colwinston can be provided and would be entirely consistent with the “limited expansion” envisaged for minor rural settlements under PPW and the RLDP.
This level of growth would strengthen local demographics, support the rural housing supply and modestly contribute to the Vale’s overall housing requirement, without exceeding infrastructure capacity.
(d) Ecology, landscape and agricultural land classification
The land is semi-improved grassland with no statutory designations. Preliminary review indicates no SINC coverage or protected species constraints. Detailed ecological and agricultural-land surveys can be provided to confirm that any residual impacts are minor and capable of full mitigation.

Development can achieve net biodiversity gain through buffer planting, sustainable drainage and native-hedgerow reinforcement, fully consistent with PPW and RLDP environmental objectives.

5. Sustainability and deliverability
• Availability: Mr Raymond, as landowner/promoter, confirms the site is immediately available for development.
• Deliverability: The site is modest, unconstrained by flood risk or abnormal infrastructure requirements, and can deliver homes within the early part of the plan period.
The proposal supports rural-settlement vitality, contributes to local housing choice, and allows design to embody placemaking principles (PPW Ed. 12 Section 2).

Conclusion
This representation, submitted on behalf of Mr Raymond in response to the current Vale of Glamorgan Council Replacement Local Development Plan (RLDP) 2021–2036 Deposit Plan Consultation, maintains that Land adjacent to Waterton Lodge, Colwinston (Site Ref: 409) represents a logical, sustainable and deliverable parcel that should be allocated as a suitable and viable residential site within the RLDP.

Accordingly, the site is considered to represent a suitable, available and achievable allocation capable of contributing to the housing requirement, supporting affordable housing delivery, and reinforcing the spatial objectives of the Plan.