I would like to object to the development of the Bryn Melin field (site 370, and adjoining sites 475 and 514)
This site is not as well suited as alternative sites (such as 455 and 367), and directly contravenes the placemaking goals and priorities of the area.
The site is within the thaw valley designated special landscape area and has uninterrupted views and access to nature. There is currently no development/suburban creep in this vicinity and developing here would destroy that. Other alternative sites (eg 455 and 367) appear better suited as they are already adjacent to suburban sprawl.
I am also particularly interested in astronomy. This area of Cowbridge, as it is a valley with no development, has significantly less light pollution than other more suburbanised areas. This is a valuable and a relatively rare resource so close to a town. Development here would destroy this.
I also do not feel the site is appropriate for a housing development. The site itself is very steep and the St Athan road is steep, narrow, with blind bends and no footpaths and no public transport. There is no easily accessible local access to jobs/amenities. Other sites (e.g 455 and 367) seem better suited to development as they have better access/transport links and already have adjacent suburban sprawl.
Please retain this site within open countryside and protect it for people to enjoy, for the wildlife and diversity that currently lives there, and to maintain the character of the area.

I would like to object to the potential classification of the Bryn Melin field (site 370 ) in terms of its development potential
I believe that this site is unsuited to development for a number of reasons
We should retain high quality open countryside.
It is in the Thaw Valley which is a highly valued open space in the neighbourhood-unspoilt countryside from Llanblethian to St Hilary. It has uninterrupted views and provides easy access to nature. Any development in this field would significantly damage the integrity of the whole valley. The public footpaths across it are important to local people
We should not increase danger on our roads
Secondly, St Athan Road, the only vehicular access to the site, is narrow with no footpaths. The road is already dangerous and any increase in traffic would make it more so. The albeit temporary construction traffic would make it much much more so again - and for how long?
Dark sky sites are to be protected for future generations
am also particularly interested in astronomy and am currently developing interest in the night sky in a local primary school. This area of Cowbridge, as it is a valley with no development, has significantly less light pollution than other more suburbanised areas. This is a valuable and a relatively rare resource so close to a town. Development here would destroy this and make it much harder for future generations to gain a view of the heavens. The Welsh Government supports Dark Sky sites; it would be bad to lose our local one

Retain Bryn Mellin as open countryside under existing rural protection policies.
• Direct future growth to locations where environmental enhancement and green infrastructure can be delivered.
• Provide transparent, up‑to‑date landscape and ecological evidence before allocating any greenfield land.
• Demonstrate clearly that alternative sites are genuinely less suitable before expanding Cowbridge’s physical footprint

A comparison of the proposed development sites around Cowbridge was included in the RLDP, yet the suitability ratings given to Bryn Mellin (Site 370) contain major inconsistencies when set against those allocated to other local sites—specifically Site 367 (South of Llantwit Major Road) and Site 455 (Primrose Hill). Although all sites were supposedly assessed through on‑site visits, the outcomes suggest that the evaluation would have been more accurate had the local council, with its direct knowledge of the area, undertaken the assessment.

BP16 states that where several sites exist within a settlement, those scoring proportionately more positively should be ranked above those with a disproportionate number of negative scores. Despite this, Bryn Mellin—located within the Thaw Valley Special Landscape Area (SLA), which the Vale of Glamorgan has a duty to protect—was scored more favourably than comparable sites. This raises the question of whether the existence of an active developer proposal influenced the assessment.

Built Form, Layout and Compatibility

• Bryn Mellin (370) was rated green for compatibility with existing built form.
• Site 367 received amber.
• Site 455 received red.

This is difficult to justify. Bryn Mellin sits within the Thaw Valley SLA, where there is no existing housing density or built form to integrate with. On this basis alone, Bryn Mellin should have been rated red, not green.
Visual and Landscape Impact

• Bryn Mellin was given an amber rating.
• Sites 367 and 455 were both rated red.


Again, this is inconsistent. Bryn Mellin lies entirely within a designated Special Landscape Area, meaning its visual impact should be considered more severe, not less. A red rating is the only reasonable outcome.

Significance of the Site to the Area

Bryn Mellin received an amber rating, while the other two sites were rated red. This is illogical given that:

• The Thaw Valley SLA is of recognised landscape importance.
• Development would significantly affect Windmill Lane, a private lane with restricted access.
• Residents’ privacy and security would be compromised by increased pedestrian movement.
• A public footpath—previously protected in a planning refusal and upheld on appeal—would be fundamentally altered and diminished in value.


The inspector previously confirmed that the footpath’s character would be “considerably diminished” once the site was built upon. This should have resulted in a red rating.

Density in Relation to Existing Development

Bryn Mellin was rated green, while Sites 367 and 455 were rated amber. This is counterintuitive. Bryn Mellin has no surrounding development to relate to, and its density would be entirely out of character with the valley landscape.

Vehicular Access and Movement

All three sites were rated amber, yet Bryn Mellin clearly presents the most severe access issues:

• St Athan Road has significant width restrictions.
• HGV traffic associated with construction would create major delays and safety risks.
• The steep gradient of the site would increase carbon emissions from vehicle movements.

These factors should have resulted in a red rating for Bryn Mellin.

Access to Public Transport and Active Travel

Bryn Mellin was rated green, while the other two sites were rated amber. This is demonstrably incorrect:

• Bryn Mellin has the worst access to bus routes, pedestrian links and cycle routes.
• There are no pavements on any approach roads.
• The Brookfield Park walkway does not meet minimum width standards.
• Sites 367 and 455 have direct access to public transport and established pedestrian/cycle networks.


Bryn Mellin should have been rated red.

Accessibility for All Users

Bryn Mellin was not given any rating at all under this category—an unacceptable omission. Given the 12% slope and poor access routes, it should clearly be rated red. Sites 367 and 455, both rated amber, are significantly more accessible.

Opportunities for Green Infrastructure and Active Travel

Bryn Mellin received a green rating, while the other sites received amber. This is again unjustified:

• Access relies on an under‑width walkway and a private lane (Windmill Lane).
• Bus services to Cardiff—the main employment centre—are limited to two per hour at peak times.
• Development here would increase car dependency and undermine sustainability goals.

If the Vale of Glamorgan wishes to support sustainable travel, development should be focused around rail‑connected settlements such as Barry or Penarth.

Placemaking Outcome Summary

Bryn Mellin was categorised as green, despite:

• Its location within a protected Special Landscape Area.
• Poor public transport access.
• High reliance on private car travel.
• Significant landscape, ecological and amenity impacts.

Cowbridge and Llanblethian Town Council unanimously opposed the inclusion of Site 370 in the RLDP, and they are responsible for the Cowbridge Placemaking Plan.

The RLDP claims that development at Bryn Mellin could “enhance the character of the area” and “respond to its setting”. This is not credible. The development would destroy landscape features, disrupt a valued public footpath, and damage local habitats.

By contrast:

• Primrose Hill (455) was rated amber, with impacts considered neutral if mitigated.
• Land South of Llantwit Major Road (367) was rated red, with likely detrimental effects.

Alignment with Emerging Placemaking Principles

The draft Cowbridge Placemaking Plan emphasises:

• Local identity
• Sustainable growth
• Protection of the town’s character and edges • Enhancement of public spaces and green infrastructure

Allocating a large greenfield site within a protected landscape directly contradicts these principles. There is little evidence that the local council’s placemaking criteria or local knowledge were meaningfully incorporated into the assessment.

Cowbridge Town Council unanimously rejected Site 370 on 24/02/2026.

Conclusion and Recommended Changes

• Retain Bryn Mellin as open countryside under existing rural protection policies.
• Direct future growth to locations where environmental enhancement and green infrastructure can be delivered.
• Provide transparent, up‑to‑date landscape and ecological evidence before allocating any greenfield land.
• Demonstrate clearly that alternative sites are genuinely less suitable before expanding Cowbridge’s physical footprint

Remove allocation.

Please accept this letter as my formal objection to the inclusion of Site 370 in the RLDP. I request that this objection be recorded in full.
The proposed development in the Thaw Valley is fundamentally incompatible with the Welsh Government’s stated commitment to safeguarding Special Landscape Areas. Proceeding with this allocation would undermine those protections and set a concerning precedent for future planning decisions.
The site is also severely constrained by its lack of public transport provision. Any development here would, by necessity, result in a substantial increase in private car use. Residents would be forced to rely on cars for commuting, shopping, leisure, healthcare, and social needs, placing unsustainable pressure on already burdened local roads.
Furthermore, Cowbridge and Llanblethian Town Council unanimously opposed the inclusion of this site in the RLDP. As the authority responsible for the Cowbridge Placemaking Plan, the council has a clear and informed understanding of the town’s needs and long term priorities. Its unequivocal opposition should carry significant weight in the decision making process.
For these reasons, I strongly urge the removal of Site 370 from the RLDP.

I formally objection to the inclusion of Site 370, Bryn Melin, Cowbridge in the RLDP as the Candidate Site Assessment Methodology has not been applied consistently with Bryn Melin being scored more generously than other sites with similar or lesser issues. Also, historical decisions regarding this site are being disregarded,


Methodology
1. Topography and site conditions should not be assessed as green but should be red. Site 370 is challenging and steep. The general gradient is 1 in 12.5 but it is steeper in places. Any development will require extensive excavation and result in a higher carbon footprint. Other sites that do not have this slope can provide the density of housing required by the Council. This site cannot. Less density and higher construction cost, equals a site with limited returns for the developer as a result the non-compliance with green sustainable measures (such no solar panels) and no funds for safe infrastructure (such no road realignment).

2. Vehicular Access for Site 370 should be red, not amber. St Athan Road has severe traffic safety issues that previously resulted in this site being rejected. Access to Site 370 is inherently unsafe due to road width and a sharp, blind bend on B4270 (St Athan Road). Council has previously judged that any development of this site would require realignment of St Athan Road. Sites 367 and 455 are also amber but do not have such serious constraints.

3. Access to public transport, pedestrian cycle routes. Sites 367 and 455 are an easy, flat walk to very close bus stops, pavements and cycle routes. These sites have an amber score. Site 370 has none of these close by yet it has been given a green score. Site 370 is much further from any paved areas and bus routes. The slope will add challenge for walkers and cyclists. The score should be red.

4, Whether the Site appears accessible to all users. This section is blank but should also be red. The slope will be difficult for the elderly, disabled, young children on bikes, pushchairs. Sites 367 and 455 are amber. They are flatter and have much better accessibility and for a larger number of users.

5. Visual Impact on landscape and Significance of Site to Area. Site 370 should be red, not amber for both categories. It is part of the Thaw Valley which is a Special Landscape Area. The Thaw Valley provides unique, high visual, dramatic valley scenery which will be lost through development. The Special Landscape status of the Thaw was provided to protect the Thaw Valley from development. This should be respected and is a requirement of the Cowbridge Placemaking principals. Contrary to the Carney Sweeney report provided by Redrow, a standard housing development (similar to many others that can be seen all over the UK) will not provide an enhancement to Cowbridge, but instead result in a huge loss of unique, open space and green fields. Sites 367 and 455 are red but are not part of The Thaw Valley, Special Landscape Area.

6. Opportunities for enhancing green infrastructure/active travel. Again there is an inconsistent scoring. Sites 367 and 455 are amber, but Site 370 is green. This makes no sense as Site 370 has more challenges and is further from facilities. As mentioned earlier. Site 370 has a steep slope and is further from shops, bus stops, medical and leisure facilities. Cowbridge has little employment. The bus takes over 50 minutes to get into Cardiff. I tried to do this for a year and it was unsustainable. The bus takes too long, it is unreliable and when it gets cancelled you are completely stuck. This development in particular will result in more cars in Cowbridge and more local traffic due to its position and the site topography. It should be red.

7. Community Facilities. This should be scored red, not green for Site 370. This site is a green field that is currently used by locals, walking groups and dog walkers for exercise, to pick blackberries and enjoy being in nature. A development on this site will be a loss to the community.


8. Placemaking outcome strategy. Site 455 is amber and 367 is red. Site 370 is green yet it is in the only site in the Thaw Valley, Special Landscape Area and it’s loss would be detrimental to local character. It would result in more car usage than 455 and 367 due to it’s position on the edge oof the town and it’s steep incline.


History
1. Site 370 has been rejected previously 3 times on expert grounds. It should no longer be considered, as per council policy which has been applied to other sites.

2. The Bryn Melin site in the current LDP is not the same as Site 370. The current LDP Bryn Melin site can only be developed if St Athan Road is realigned. This requirement is clear and necessary. What is the rational now for REMOVING this well thought through Council requirement? Access and traffic safety are a fundamental part of the Assessment Stages for including sites in an LDP. Why has this not happened for Site 370? Why has the independent traffic report from Lime Transport provided by the Thaw Valley Group been ignored? An inconsistent approach is being applied to Site 370 which ignores the Council's historical decisions.

Today I went for a beautiful walk in the sun, down Windmill Lane in Llanblethian, through a sloping field, with sheep and new spring shoots starting to poke through. The field at the bottom was still slightly flooded from the wet weather we have had. Then the friend I was with told me they are developing the field on the slope and putting 105 houses on it. Heart broken. How can this be so???? There are so many developments in the Cowbridge area at the moment, it feels like there is a total disregard for nature. Once the fields are developed that is it. They will never be home to wildlife, they will never absorb the rain that we have. This will have a knock on effect to the field below which will flood heavily due to lack of absorption on the sloping field.

All this development starts to make the area less pleasant to live in. We moved to a small town and it feels like soon we will be living in a large town, but without the benefits of the infrastructure that you would find like train links, more reliable buses, recreational facilities, restaurants, healthcare.

Here are also some points that my friend sent to me which I totally agree with.


1. Site 370 sits in the Thaw Valley, which is a designated Special Landscape Area. This designation was intended to protect open space from development. Site 370 provides unique character and this character will be lost permanently if replaced by housing.

2. Running through site 370 is a footpath that enables locals and rambling group to walk in open fields. This footpath provides access to other fields and open space, A housing development on site 370 would change the character of this public amenity severely and would restrict access to other open spaces for walking. This is not in keeping with the Council’s policies or Cowbridge’s Placemaking Plan. Housing should not result in the loss of existing public amenities,

3. Vehicular Access to site 370 via St Athan Road (the only access option) is a major RED flag due a sharp blind bend and narrow road. Site 370 does not required or allow for the realignment of St Athan Road. Realignment of St Athan Road is the only safe option for developments in this area, as determined by the Council previously. Cycling into and out of St Athan Road has the same RED flag safety issues.

4. Site 370 is not accessible for all users. This should also be a RED flag. The site has a steep gradient. The lower half of the field would not be suitable for elderly walkers, pushchairs, young children cycling. There are no pavement areas leading to this site, making access to public transport and services difficult. As a consequence, this will lead to a higher car usage than other potential sites in Cowbridge.

5. Site 370's steep gradient means the Council’s housing density requirements cannot be met and consequently green infrastructure cannot be delivered.

I write to inform you that I STRONGLY OPPOSE the Inclusion of the above SITE 370 BRYN MELIN COWBRIDGE in the RDLP

My Objections :
I am deeply concerned about the Sustainability and Validity (Soundness) of the plan

A comparison has been included with other proposed local sites within the Cowbridge area to that of Bryn Melin I am wondering What Criteria was used to measure and establish these comparisons? and who conducted this research and these observations? I truly hope that Vale Planning officers visited all sites whilst this project was undertaken.

Placemaking place and Character

In the first instance I am extremely shocked that Bryn Melin (which is actually a Beautiful Undulating Pasture Field on the edge of the quaint Old Market Town of Cowbridge) should even be considered for Inclusion in the RDLP as the THAW VALLEY as it is in a DESIGNATED SPECIAL LANDSCAPE AREA, An Area of Outstanding Beauty that the Vale of Glamorgan Council should fight to preserve and protect and should not even contemplate building houses on it A housing development will suffocate the open rural space that is very much needed on the edge the town The fact that a proposal from a housing developer was previously made should in my opinion not Influence any decisions, Bryn Melin should not be vulnerable to further inclusion in Local Development plans (RDLP} because of any previous Housing Development Interest

The RED AMBER AND GREEN Colour Rating Markers that have been given to compare the proposed sites of 370 {Bryn Melin} verses 367 {south of Llantwit Major Road} and 455 (Primrose Hill} in my opinion are flawed for the following reasons :

Visual Impact on landscape / historic environment

The rating mark for Bryn Melin Should Be Red and Not Amber as it is in a Thaw Valley Special landscape area

Relationship to and compatibility with existing built form scale types

Bryn Melin Should Be Red and Not Green There is no current density of housing in The Thaw Valley, Thaw valley special landscape area has been ignored by planners.
Significance of the site to the area- Bryn Melin this Should be Red Not Amber

The residents on Windmill lane will be significantly impacted due to proximity of the site due to it being a private lane The privacy and security of these residents would be greatly affected by pedestrians to the site using this route

Density of the proposal in relation to existing developments

Bryn Meiln should receive Red not Green

As a resident of Crescent Close whose garden backs on to St Athan road I can confirm the increase in volume of traffic using this road had trebled in recent years ! St Athan road has width restrictions which will increase risk to vehicles trying to compete with HGV SITE Traffic The corner of site entrance is on a dangerous bend where there have been numerous collisions in the past There will be delays on St Athan road with the build up of site traffic I want to add here that the impact on residents living on Crescent Close Primrose Close Hillside Drive And Vale Court will be massive it will affect access in and out of the Estate on to St Athan Road greatly ! A housing Development on Bryn Melin would give rise to a big increase in vehicles, increasing the risk to residents driving in and out of the Estate

Access to public Transport pedestrian and cycle routes

Bryn Melin Should be Red Not Green

Bryn Melyn has the worst access to Bus routes pedestrian and cycle routes of all the proposed sites Difficulty in accessing Public Transport will increase car usage massively There are no pavement areas The other proposed sites have good access to public transport and good cycle and pedestrian routes

Is the site accessible to all users

Bryn Melin has not been given a rating marker for this WHY ? It should be Red

Opportunities for enhancing green infrastructure /travel

Bryn Melln Should Be Red not Green Bryn Melyn has only access to bus services (X2 SERVICE) which runs every half hour to Cardiff and Bridgend main employment centres) which means there would be a big increase in traffic using St Athan Road from residents living on the proposed site, who would for convenience drive their cars to work instead of public transport

Placemaking Summary

Bryn Melin should be Red

The Welsh Government has a directive to protect Special Landscape areas Development of this sire in Thaw Vale contradicts this This site has no significant public transport links people would have to take their cars into surrounding towns and (indeed into Cowbridge itself as there is no safe pedestrian walkway) The increase of traffic would have a major impact on all the town which is congested daily especially at peak times

The development of this site would ruin the character and beauty of the area it would not enhance it in any way It would destroy the landscape and public footpath causing harm and destroying wildlife and habitats and the beautiful stepping stones that should also be preserved

We must protect our town edge environment We need our fields

Bryn Melin MUST be Retained and Protected as a Rural Pasture Green Field Alternative Brown field sites should alternatively be sought for development or sites that do not have major access and traffic problems Sites that don't tear up the beauty of the landscape sites that don't endanger habitats and wildlife sites that don't impact on current residents privacy and safety

On the afternoon of Thursday March 5ᵗʰ 2026 an Air Ambulance Helicopter had to land on Bryn Melin Field to air lift a resident who lives on Broadway Llanbleddian to hospital, it was an emergency situation I witnessed the Helicopter landing from my back garden that backs onto on St Athan Road We have a severe lack of safe landing areas for emergency Helicopters to land ! Especially in this area of town. Bryn Melin field played a significant crucial part in that life saving mission. This is Another Major Valid reason along with all the reasons I have mentioned above that states why I believe Bryn Melin should remain a Green Pasture Field and Should Not be included in the RLDP

We wish to object to the inclusion of site 370 Bryn melin in the deposit LDP. I base my objections on the principle of soundness and the inclusion of the site is at variance with the overall plan in terms of location within a sustainable transport corridor.
The site was included because it was stated that it was in the original LDP but the site is substantially different and probably wouldn't have been included in the original if it was in its current form having very limited or no safe access by car, cycle or pedestrian.
I would challenge the soundness of this site's inclusion on the basis of sustainability and evidence base. Many aspects of the sustainability assessment are flawed in themselves and are also questionable when compared with the assessment of the other cowbridge sites.
There are flaws in the evidence base and a distinct bias, for whatever reason, in the sustainability assessment. It is doubtful whether any of the sites in cowbridge were visited during the final assessment but it is clear that of all the sites within cowbridge this site, bryn melin, offers the worst opportunity for development.
The site is in a special landscape area and development of the site would not only destroy this scenic green agricultural field but also remove a public amenity of a public footpath used by many for walking and dog walking.
The site is a habitat for many animals and species and is a stepping stone into the wider countryside beyond.
The topography of this site is very challenging with a slope of over 11.5 percent which means that there will be substantial carbon emissions with excavation, retaining structures and infill. The topography of the site also presents substantial challenges for accessibility ,pedestrians and cyclists.
The main issue with the site is the access for all forms of transport whether car, cycle or pedestrian. There is no obvious, safe access for any of these modes of transport and the recent independent road safety audit confirmed these findings. It is not clear how any modifications to the site can make access safe and available and comply with Welsh government and local council policy requirements.
Cowbridge does not have good, economical public transportation links. This is particularly significant as most of the jobs are outside of cowbridge and require the use of cars for access. Access from this site to even local facilities will probably require the use of cars because of the topography, location and relative accessibility. It is also not clear within the evidence base that Cowbridge needs this site to meet any future housing demands within the deposit plan time frame
It is also questionable why this Cowbridge site was included in the plan especially when compared to the other available sites considered in the stage 3 assessment. .No local knowledge or placemaking assessment appears to have been carried out and the local town council and residents of Cowbridge have not been consulted adequately on the selection of this site, particularly when compared to the other considered cowbridge sites.
We conclude that on the basis of soundness, flawed evidence base and sustainability assessment this site should not be included in the deposit plan.

My primary objection of this development is the huge negative impact on a beautiful area of countryside that is easily accessible for local residents of Cowbridge to enjoy. This site is part of the Thaw Valley and is protected by being in a designated Special Landscape Area. I have belonged to a walking group and the footpath that is alongside the river is one of our favourite routes. Many walkers enjoy wonderful views of the valley with its variety of habitats for plants, trees and wildlife. The development of site 370 would threaten this special area of countryside especially during the building phase whereby HGV’s and construction vehicles would have to manoeuvre in boggy ground in an area of restricted access. As the site is on a steep slope, any environmental pollutants either in the construction phase or when the houses are inhabited, would filter into the waters of the river Thaw. Wildlife and vegetation would surely be effected negatively.
Another concern is the fact that there is currently no footpath along the St Athan road from the entrance of the site towards the traffic lights at the east end of Cowbridge (route to the secondary school). The road is narrow and winds steeply up/down a hill and the creation of a safe footpath or cycle path is not possible. The knock-on effect of this would be a huge increase of pedestrians and cyclists using the private road, Windmill Lane, instead of a public footpath in order get to Cowbridge safely.

My final concern with this site development is that it has recently come to light that a certain member of the Vale Planning committee has failed to admit to a conflict of interest in site 370 since the first planning application. In a recent Cowbridge and Llanblethian Council Meeting, this member was confronted about his failure to declare a conflict of interest. I am most disturbed that the Vale of Glamorgan Planning and Development department would be party to obvious cronyism.

Remove site and:
1. Reassess the flawed and biased sustainability assessment using an independent consultant or the local council.
2. Assess the viability of the scheme based on developers submissions.
3. Consider whether there is a requirement for additional housing within Cowbridge.
4. Consider whether the development in Cowbridge complies with Welsh government policy and TAN 18 of identifying developments within mass transport areas
5. Retain the site within open countryside, protected under relevant rural policies.
6. Focus future growth where environmental and green infrastructure enhancement can be delivered, supporting the Vale's biodiversity network and placemaking aspirations.
7. Provide clear evidence that alternative sites are less appropriate before extending Cowbridge's physical footprint.

1. Introduction & Purpose

This representation objects to the proposed allocation of Site 370 - Bryn Melin, Cowbridge/Y Bont-faen (approx. 3.89 ha agricultural land) as a housing site in the Deposit Vale of Glamorgan RLDP on the basis soundness and sustainability, in accordance with the tests set out in national planning policy and guidance.

The site is currently a "roll-forward" of an existing LDP allocation, but up-to-date evidence demonstrates significant adverse landscape, ecological, and sustainability impacts that outweigh any justification for continued allocation.

2. Summary of Grounds for Objection.

1. Inconsistent with Local Strategy and Settlement Pattern Site 370 was treated as a "roll-forward allocation" because it was previously included in the adopted 2011-2026 LDP. However, the evidence now suggests that sufficient existing housing supply exists in Cowbridge and that further expansion into greenfield land to the west of the town is not required to meet housing needs. Since the LDP was approved there has been an additional 25% additional houses in Cowbridge.

2. Environmental and Landscape Impact Bryn Melin is predominantly agricultural land on the rural edge of Cowbridge.Development here would contribute to the loss of open countryside( including a well used country footpath) undermining landscape character and local rural amenity. This farmland contributes to the local rural setting and scenic quality of Cowbridge's western edge - a setting that should be protected. The Deposit Plan includes an Integrated Sustainability Appraisal (ISA) that places significant weight on environmental protection and the prudent use of land. Allocating greenfield sites like Bryn Melin appears inconsistent with the ISA's objectives unless exceptional justification is provided. Site 370 is clearly shown on the VoG latest landscape document( supporting document evidence base) BP28 Nov 2025 Fig 2 as lying within the special landscape area of the Thaw Valley The Upper Thaw Valley and rural landform surrounding Cowbridge is recognised for its scenic quality and intervisibility with the town's historic setting. Development here would change perceptions of the transition between built and natural environments, undermining the peaceful character that local strategy seeks to protect.

3. Biodiversity & Habitat Concerns

3.1 Rich Local Biodiversity

The Bryn Melin site supports a diverse range of species and habitats, many of which are recognised as biodiversity priorities under the Local Biodiversity Action Plan. Many species have been identified and recorded including brown hares, skylarks, amphibians, bats, badgers and other species characteristic of high nature value farmland.

3.2 Habitat Networks and Connectivity

The Vale's biodiversity strategy emphasises the importance of habitat connectivity and protection of SINCs (Sites of Importance for Nature Conservation) across the rural landscape.

Allocating agricultural land at Bryn Melin will: Fragment local habitat networks that support foraging and movement of wildlife. Harm species-rich hedgerows and other features that are present Reduce resilience of ecological networks at a time when strategic habitat protection and enhancement is a planning priority.3.3 Local Biodiversity Partnership Priorities

The Vale Nature Partnership has identified habitat protection and restoration as a priority objective, including grasslands, hedgerows, watercourses and other key farmland features.

Allocating this site for housing conflicts with this biodiversity agenda unless exceptional mitigation and enhancement measures are demonstrated - which have not been adequately evidenced at the Deposit stage.

4 Planning Policy & Soundness Issues

4.1 Sustainability Tests

The RLDP must demonstrate that all allocations meet the soundness tests of being justified, effective and consistent with national policy.

The sustainability tests carried out for site 370 Bryn Melin appear to be flawed and based on an inaccurate evidence base, Furthermore when the sustainability tests for other sites in Cowbridge are compared, there appears to be comparison errors and a bias towards including the Bryn Melin site.

This summary below highlights differences in the assessment for the various sites where we believe there is an obvious error. The assessment is sometimes subjective (ie landscape etc) but in a lot of areas is specific. The headings are given a green, amber or red assessment based on no issues, issues which can be overcome or a serious impediment.

Wildlife Corridors, Green Networks or Stepping Stones.

370 Bryn Melin. Amber

Potential for adverse impact upon stepping stones, green networks or wildlife corridors but appropriate mitigation measure can be implemented to avoid significant damage. Designed with maximum retention of existing hedgerows is required and that they are unlit from street lighting.

Keeping the hedgerows and keeping them unlit is hard or impossible to achieve given the proposed location of pedestrian access.

514 Land east of St Athan Rd.This is in a similar location to Bryn Melin but has been given a Red category.

Historic Environment

367 Land South of Llantwit Major Rd.

This site has been given a red category (The same as Bryn Melin) in stark contrast to site 440 below.

The site is close to an ancient monument but is separated from it by a wide wooded area. The report states that part of the site is within the ancient monument but this does not appear to be the case from the maps of the proposed site and the ancient monument map. It mentions Cadw should be contacted and Cadw provide a permitted planning service but it appears no one has contacted Cadw.

440 Land North of Church Rd Llanblethian.

This plot is closer to the ancient monument (Hill Fort) but has been given an amber designation. Stating that Cadw should be consulted and that the site borders an ancient monument

Special Landscape area and Glamorgan Heritage Coast Designation

370 Bryn Melin. Amber

The council state the south east corner of the site is located within the Upper and lower Thaw Valley SLA but according to figure 2 of the Vale of Glamorgan Designation of Special Landscape Areas background Paper , the whole of the site is in the SLA, The amber designation means the development may result in little or no change in character and little or no effect on landscape.

This in contrast to site 367 Land east of St Athan road which they acknowledge is in the SLA and state Further Consideration required on landscape Character and visual amenity. More particularly site 455 Primrose Hill is Red. Although it is technically within the Thaw valley landscape area, development will not impact the thaw valley landscape in the same way as Bryn Melin 370 and land east of St Athan rd 367 which are both cited as Amber.

The Category for site 455 is red and the report statesThe site is located within a Special Landscape Area/The Glamorgan Heritage Coast and development is likely to result in a substantial change in character and/or significant adverse effects on landscape character and visual amenity. The Upper and Lower Thaw Valley SLA.

This statement applies equally if not more so to sites 370 Bryn Melin and 367.

The planning inspector when refusing permission previously stated about site 370 Bryn Melin

The proposal would result in an undesirable and conspicuous extension of the built-up area of Cowbridge southwards into open countryside comprising the River Thaw Valley, which area has been identified as a Special Landscape area in the Structure Plan.

The council assessment document BP16 states

Development proposals within Special Landscape Areas and the Glamorgan Heritage Coast will be required to fully consider the impact of the proposal on the designation 27 I Valeof Glamorgan Candidate Site Assessment Methodology through the submission of a Landscape and Visual Impact Assessment. The assessment must consider the site and its relationship to the designation and acceptability in terms of scale and prominence. The Council shall also undertake an assessment of sites as part of the Placemaking Site Appraisal (Section 5 below) and shall enable the Council to eliminate sites where the impacts are significant mitigation.

Topography and Site Conditions.

370 Bryn Melin. Green

The site is free from constraints.

This is not true. The site is severely sloping at 11.5% and according to the developer causes difficulties.All other sites that are sloping are defined correctly.

Tree Preservation Orders, Hedgerows and Woodlands.

370 Bryn Melin. Green

Report states. No TPOs present on site, and the proposals would not lead to significant tree loss. The site is bounded by hedgerows.

The current proposal includes the removal of a long section of hedgerow into an existing play area and the removal of trees in the play area that have not been surveyed.

514 Land south of Llantwit major road Red

The report states. A significant loss of TPOs.

This should be amber as there is only a potential loss of TPOs depending on the layout of the development. In addition the council have stated the position of the site at the deposit stage in BP18a.

It is noted that the following a historic felling of trees, the loss of protected trees would not be a significant constraint. However, it is considered that there are sufficient housing sites allocated and within the existing supply in Cowbridge and a further greenfield extension to the west of the town is not required unless other sites do not proceed.

This statement regarding trees suggests that the site should be amber for Trees.

Also with regard to the impact on the setting of the ancient monument which gives the site a red category. The monument is not visible from the site and is protected from view by a stretch of trees.

Access to Services and Facilities.

Bryn Melin site 370 has been classified as Green for access to Retail, Primary schools, community facilities and green open spaces, whereas 455 Primrose Hill has been designated Amber because of the walking distances. Because of the actual walking distances, the distances are further for Bryn Melin and all theseshould be amber with the exception of primary school which should be green for both sites.

Highway Accessibility.

Bryn Melin is given an Amber designation, the same as all of the other sites. In the original LDP inclusion for this site 370, the council specified that the development should include realignment of the highway because of the highway issues

It is obvious, that of all the sites, access is difficult or impossible to achieve to meet the guidelines on this site given the severe constraints and it should be given a red designation. The criteria in BP16 states for red.

Major highway constraints -Insurmountable safety issues and/or the or cost of mitigation measures likely to render scheme not viable. Where unsafe highway access is proposed or existing access cannot be upgraded in accordance with the Council standards, or costs of providing safe access and egress are considered to impact on site viability the site shall be excluded from further consideration..

Climate Change.

Bryn Melin 370 receives a red for this category compared to the other sites as no improvements above building regulations are proposed.

PPW states that the "The planning system should support new development that has very high energy performance, supports decarbonisation, tackles the causes of the climate emergency, and adapts to the current and future effects of climate change through the incorporation of effective mitigation and adaptation measures." (paragraph 5.8.1 refers)

Placemaking, Character and place.

These sites are supposed to have been visited by the planners to assess the following sub categories These assessments would be better carried out by the local council. BP 16 states:

Where there are a few sites within a settlement, those which score overall proportionately positively against the criteria shall be ranked above those whichresult in a disproportionate number of negative scores. If the assessment had been carried out correctly ,other sites in Cowbridge would have ranked higher.

Relationship to and compatibility with existing built form, layout, scale density, building types.

Bryn Melin 370 receives green, whereas 367 south of Llantwit major road receives amber and 455 primrose hill receives red. Why the difference?

Visual Impact on landscape/streetscape/historic environment.

Bryn Melin receives amber but sites 367 and 455 receive red. Why?

Significance of the site to the area.

Bryn Melin receives amber but sites 367 and 455 receive red. Why?

The council previously had refused permission because The development would also detract from existing local amenities by changing the character and route of a public footpath which us important to local residents in the area/ And this was endorsed on appeal by the inspector The value of the length of the footpath crossing the site would be considerably diminished once the site was built upon, whichever direction the path was to take.

Density of the proposal in relation to existing developments.

Bryn Melin receives green but sites 367 and 455 receive amber. Why?

Access to Site vehicular movement.

Bryn Melin receives amber and sites 367 and 455 receive amber also.lt is clear that vehicular access is worse for Bryn Melin than the other sites and this is another example of bias. It is also clear that highway straightening as stipulated by the council in the original LDP is required

Access to public transport, pedestrian/cycle routes.

Bryn Melin receives green but sites 367 and 455 receive amber. Why?It is clear that Bryn Melin has the worst access to pedestrian, cycle and bus routes and should probably receive a red category. Whereas sites 367 and 455 have access to public transport adjacent and good access to pedestrian and cycle routes

Whether the Site appears accessible to all users.

Bryn Melin does not have a rating for this heading , Why? It should be red because of the slope of the site and poor access. The other sites 367 and 455 are categorised as amber but are definitely more accessible than 370.

Opportunities for enhancing green infrastructure/active travel.

Bryn Melin receives green but sites 367 and 455 receive amber. Why? The independent transport report by Lime transport showed that the site does not meet safety standards and proposed access routes do not meen the Active Travel requirements

Placemaking Outcome Summary.

Bryn Melin 370 is categorised as green.

The report states:

Development of the site has the potential to enhance the character of the area and contribute positively to national sustainability and placemaking principles. A planning statement has been provided in support of the current planning permission which sets out how the proposal would respond its setting and location in relation to placemaking.

Clearly this development can't possibly enhance the character of the area when the landscape and a public footpath will be destroyed and local habitats and stepping stones will be affected. This site should receive a red assessment.

Primrose Hill 455 is Amber

Development of site is likely to have a neutral / negligible effect on local character and sense of place (subject to the development providing mitigation measures and/or meeting specific policy requirements).

Land South of Llantwit Major Road 367 is red.Development of site will likely be detrimental to local character and sense of place

4.2 Emerging Placemaking Principles for Cowbridge

The Cowbridge Placemaking Plan emphasises local identity, sustainable growth, and protection/enhancement of town character, public spaces and the town- edge environment. Allocating large greenfield land contrary to these principles undermines locally articulated placemaking ambitions. There appears to have been little or no involvement of the local council in identifying and discussing the local placemaking criteria and assessment of the various Cowbridge sites.

Recent documents from the developer have indicated that the site is not viable if the council and government policy of social housing and housing density is compied with

3. Conclusion & Proposed Changes

For the reasons set out above, this representation requests that the Council remove Site 370 - Bryn Melin from the RLDP housing allocations and instead:

1. Reassess the flawed and biased sustainability assessment using an independent consultant or the local council. 2. Assess the viability of the scheme based on developers submissions. 3. Consider whether there is a requirement for additional housing within Cowbridge. 4. Consider whether the development in Cowbridge complies with Welsh government policy and TAN 18 of identifying developments within mass transport areas 5. Retain the site within open countryside, protected under relevant rural policies. 6. Focus future growth where environmental and green infrastructure enhancement can be delivered, supporting the Vale's biodiversity network and placemaking aspirations. 7. Provide clear evidence that alternative sites are less appropriate before extending Cowbridge's physical footprint.Representation Declaration

We request that this representation be formally recorded as part of the Deposit RLDP consultation (January-March 2026) and considered in both Council decision-making and independent Examination. In accordance with the RLDP consultation procedures, we are prepared to expand on these points if requested during future stages of plan preparation.

This second letter is an explanation of a series of photographs which have been taken between 2022 and 2025 of the site 370, Bryn Melin. Cowbridge

Visual Impact on the site; ratings should be red

They are a record of the construction of the site entrance in 2022 undertaken by Redrow and the work done at the same time to fell several beautiful trees and construct fenced groundwork from the site going south towards the river. [no correct planning permission]
Dumping of hardcore into the field.
Motorway style entrance shoddily built on a steep incline, which within less than a year had to be repaired by the Vale Council and later adopted by the Council.
The proximity of the entrance on the northern edge of the entrance to the perimeter fence of a garden in Lake Hill Drive.
The annual flooding of the river plain, access road to the sewage works and footpath may be impacted by the SUDS plant that will be required.

Access; ratings should be red

The photographs of the narrow road on a steep incline and right hand bend next to the site entrance show the white lines being straddled (travelling north) and a vehicle travelling south with limited lane width. Its dangerous for large vehicles travelling in either directions. They often get stuck meeting on the bend.
The difficulty would be compounded for vehicles wishing to turn right or left out of the site
The road photos show lack of space for pavements. Pedestrians are not SAFE on the road.

Relationship to and compatibility to existing buildings; ratings should be red.

Significance of land; as a green wedge and a designated special landscape area, ratings should be red.

A photo taken, looking south from the top of LLanquian Close in Brookfield Park show the beautiful 10 acre site before construction of the entrance and the investigative work had began.
The second photo taken from the entrance looking west shows the close proximity of Brookfield houses on its northern edge and the house to the northwest in Windmill Lane.

I urge the planners and councillors to look with fresh eyes at what has already happened on this site. The visual impact of the construction of the entrance has already had a negative impact. It seems that it is not only the 10 acre site 370 which will be gobbled up by the development, but also a wide swathe of green wedge land lying next to the St Athan Road. This means that the Thaw landscape, its habitat and biodiversity and its river plain will be wrecked. This would explain the felling of trees and the construction of a roadway / pipe ditch from the site to the river in 2022.

Thank you for consulting Natural Resources Wales (NRW) on the Vale of Glamorgan Replacement Local Development Plan (RLDP) Deposit Plan, which we received on 28 January 2026.
We have reviewed the deposit plan and published documents and have recommendations on matters relating to coherence and consistency. We advise these are addressed prior to submission of the RLDP.
1. Summary
We welcome that the Vale of Glamorgan Council has declared a ‘nature emergency’ and in 2021 committed to a target of no net loss of biodiversity in the Vale of Glamorgan. The deposit plan takes this a step further through its vision, objectives and policies in seeking
the achievement of net biodiversity benefit. We also welcome the recognition within the deposit plan and supporting documents that additional growth within the Vale has the potential to lead to negative effects on nationally and locally designated biodiversity. We
appreciate that the deposit plan’s policies seek to mitigate against these potential adverse effects with detailed wording and requirements.
However, we consider that the deposit plan would benefit from more specific mention of designated conservation sites especially where these are related to specific allocations and their associated policies. We note this issue was raised within the Integrated Sustainability Assessment (ISA) (see Section 2 below) however we do not see this recommendation properly reflected within the deposit plan itself. We consider this is a gap that should be addressed to ensure clarity within the policy requirements for any future planning applications.
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 (please see our suggested amendments in Section 3 of this letter) together with addressing the meaning of “areas of high ecological value” will also go some way towards resolving the points we raise.
Master Planning
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 site
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.
Please see our detailed site-specific comments in Section 4 in order to consider where our comments may lead to adjustments in master plans. For example, the species protection issues we highlight with regard to KS3 at Readers Way, Rhoose.
Strategic Opportunity at Bro Tathan
In addition to the above points, we advise that the Bro Tathan area of the Vale includes a number of different allocations and is already known as an important ecological area for great crested newts (GCN) and dormice, in particular. Given the commitments already
made under previous planning applications at the site and the necessary requirement for future biodiversity provisions, we advise a more strategic overview of the area should be considered and either set out within the deposit plan or secured within an updated GIS.
This will ensure that development in the area:
• does not cause detriment to the maintenance of the favourable conservation status of protected species;
• results in green spaces and infrastructure that is meaningfully spatially connected and sufficient in size.
Overall, we consider piecemeal development of the St Athan area will not lead to effective conservation delivery and will make the planning process less efficient at project level.
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.
2. Integrated Sustainability Assessment (ISA)
With regards to Section 9.9 of the ISA, we agree that additional growth in the Vale has the potential to lead to negative effects on nationally and locally designated biodiversity. The ISA concludes that the housing-specific policies set out within the deposit plan work well to
mitigate the potential adverse effects, through design stipulations and policy inclusions.
The ISA then goes on to recommend that Key Site policies are updated, where appropriate, to reference specific designated sites which they are in proximity to, in
order to help establish appropriate protection and/or enhancement measures.
We agree with these recommendations and would go further in advising that all allocations and their associated policies should reference specific designated sites relevant to that site. For instance, we would advise Barry Woodlands SSSI and Walters Farm SSSI is identified in relation to Key Site 1 – Land at North West of Barry, and Barry Woodlands SSSI should also be identified for Housing Allocation HG1 (1) Land to the West of
Pencoedtre Lane. Please refer to our site-specific comments in Section 4 below.

3. Plan and Policy Wording
Strategic Policies
Strategic Policy SP19 – Green Infrastructure
We welcome that the GIS and GIA has informed the master planning of the Key Site allocations (6.395). To ensure this approach is carried forward for other development proposals, we consider there should be a stronger “policy hook” within Policy SP19 to link the content and evidence of the GI work to the policy and its influence on decision-making. Without this we consider there may be a risk of a policy gap/mismatch when determining planning applications.
This could be resolved by a new criterion such as:
“the provision of green infrastructure must have regard to any adopted or emerging guidance including the Green Infrastructure Strategy/Green Infrastructure Assessment
(and the Assets listed therein), and Green Infrastructure (Action) Plan for the Vale.”
To strengthen Policy SP19 we also recommend an addition to the wording of criterion 2 to read:
“Protect and enhance connectivity between existing green infrastructure assets and be planned wherever possible to positively support areas of high ecological value”.
We furthermore note that criterion 3 of SP19 refers to achieving net benefit for biodiversity whilst the policy overall seeks to provide, protect and enhance high quality multi-functional green infrastructure. We have previously commented that multi-functional green spaces may not always be compatible with biodiversity. It should be recognised that multifunctional uses of space can be to the detriment of the natural environment and so must be carefully considered. We recommend that paragraph 6.397 wording is updated to reflect this potential conflict so that NBB required by PPW (and as promoted by para 6.396 together with Policy SP20) is able to be prioritised and not compromised.
This point could also be raised under Policy SP4 Placemaking – at para 6.32. It should not be assumed that multifunctional spaces will also be delivering for nature in every situation and in some cases separate provision of spaces to meet biodiversity goals will be essential.
Paragraph 6.401 is welcomed regarding the opportunities that exist for the protection, maintenance and further enhancement of green infrastructure assets.
Strategic Policy 20 (SP20) – Biodiversity and Ecosystem Resilience
We welcome the inclusion of SP20 which recognises the importance of natural assets and aims to protect these. We have made comments regarding the term “high ecological value” in our Summary section at the start of this letter.
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. This issue is also reflected in our feedback to the ISA as set out in Section 2.
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. We also suggest that the placemaking strategic policy (Policy SP4) could be altered in order to highlight the Natural Environment alongside its
current reference to the Historic Environment. We note that placemaking principles (Figure 11 - Identity) includes the need for development to respond to natural physical attributes of the site. This is an issue is linked to our site-specific comments (Section 4 below) where we cite, for example, the need to buffer woodlands, hedgerows and watercourses and preserve linear corridors.
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.
As a minor point, please note that the South Central Area Statement is not hyphenated (para 2.10 and 2.11). 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.

Detailed Policies

Infrastructure
Whilst we note that the infrastructure requirements (such as sewerage capacity) have been investigated for certain key sites within the deposit plan, we consider there could be scope for a detailed policy to cover infrastructure requirements for all development.

Policy DNP7
We welcome Policy DNP7 of the deposit plan, which recognises the importance of preserving the natural darkness of the night sky and minimising light pollution, which we consider to be important in limiting adverse impacts upon local biodiversity and ecological
connectivity.

Policy DPN8
Please refer to comments made with regards to this policy under Section 6: Habitats Regulation Assessment (HRA).

Policy HG5 - Affordable Housing Exception Sites
We advise that, particularly given these sites are permissible outside of settlements and could be in countryside locations, criterion 6 should be amended to:
“There is no loss of land with significant recreational, amenity, agricultural, ecological or natural heritage value”.

EMP1 – Employment Regeneration Opportunity Areas
We note that the Former Aberthaw Power Station has been identified as an employment regeneration opportunity area. There are otter and water vole records on the site and we are aware of GCN records within the local area. We would advise against the inclusion of
the Aberthaw Nature Reserve within the allocation and advise that any application on the site would need to be supported by up-to-date ecological survey information and
appropriate conservation measures. Given the nature of the site, future applications will also need to be supported by appropriate land contamination investigations.

CC3 – Renewable Energy Local Search Areas
This policy identifies several sites where the potential for wind and solar development are the greatest (known as ‘search areas’). There are significant search areas located between Llantrithyd and St Hilary; no ecological information has been provided for these search areas, however given the records for GCN, water vole and otter local to these areas, it is likely that provision in the form of suitable habitats will need to be made for these species.
This could be substantial in scale, however without further ecological information we cannot advise further at this time. Notwithstanding, given the scale of the search area in this location and the likely ecological impacts, we advise that this area would benefit from spatial planning of biodiversity provision, at a greater than individual site scale.

Paragraph 2.81 – The Vale Nature Recovery Action Plan
We note reference to ‘6 broad habitat types’ including Woodland, Freshwater, Grassland, Coastal, Agriculture and Urban. We suggest this is amended to ‘6 broad ecosystems’ to reflect correct terminology and the State of Natural Resources Report 2025.

4. Strategic Sites
Overview
We previously provided detailed comments on the RLDP’s Strategic Sites, as set out in our response ref: CAS-234819-C1V3, dated 4th October 2023, which we refer you to. We welcome the additional information provided and note the inclusion of Green Infrastructure
Strategies for each of the Key Sites. However, we note that these do not include reference to protected species specifically and as a result we are unable to confirm that the provision for each site is appropriate. We observe that the road infrastructure for many of these sites severs woodlands and other substantial linear corridors. We advise that such sites are designed to minimise fragmentation in the landscape and advise that the road layouts and consequent severance is re-visited.

KS4 and KS5 are located within the vicinity of St Athan. This area is important for (and we are aware of) multiple records of GCN and dormice. Some of the area is already secured as compensation for impacts on these species associated with previous developments. We advise that the wider St Athan area is subject to spatial planning of biodiversity provision at a greater than individual site scale (as we have referenced in the Section 1 of this letter), in order to determine that:
• It does not cause detriment to the maintenance of the favourable conservation status of both GCN and dormice (strategic conservation plans should be established for both species);
• To ensure that green spaces and infrastructure are meaningfully spatially connected and sufficient in size;
We consider piecemeal development of these areas will not lead to effective conservation delivery and will cause the delivery of these sites to be less effective during the planning process.

Spatial Planning of Biodiversity
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).

Updated Surveys and Appropriate Buffer Zones
Further to the above comments, we welcome reference within the Infrastructure Delivery Plan for the requirement for updated ecological surveys and appropriate buffer zones to watercourses and retained habitat features for KS1 and KS2. Given the various ecological
constraints for each key site, we consider this advice should be included for each of the key sites.

Site Specific Comments
KS1 – Land at North West Barry
Protected Species – Dormice and bats are present on site. We advise that the masterplan is informed by surveys to ensure that biodiversity interests are maintained and enhanced. The site may require some areas to be retained an/or provision for habitats to support them. Dark areas and/or bespoke lighting scheme may also be required at project stage.
Protected Sites – The site is located in close proximity to Walters Farm and Barry Woodlands SSSI. As raised in our previous responses (CAS-234819-C1V3, dated: 4th
October 2023 and CAS-276923-N7H6, dated 17th April 2025), we have some concerns with the potential for increased and inappropriate use of the protected sites through recreational activities. We welcome that requirements have been detailed within HG1 KS1
under Green Infrastructure, Recreation Spaces and Biodiversity, which includes reference to emerging guidance for Suitable Alternate Natural Greenspace (SANG).

KS2 – North of Dinas Powys, off Cardiff Road
Protected Species – We note the supporting Preliminary Ecological Appraisal (PEA) (13th September 2022) which identifies potential for this site to support GCN, dormouse and bats. In the absence of species specific surveys, we are unable to advise whether the housing number aspirations for the site are realistic. We advise the scheme is designed to minimise severance of ecological corridors.

KS3 – Land at Readers Way
Protected Species – GCN are known to be present on this site (Readers Way Pond). The current masterplan indicates that the pond will be surrounded by built development and therefore built upon much of the terrestrial habitat which supports this pond. It is essential
that the masterplan provides a wide corridor from this pond to the wider countryside, other than via the closely managed grassland at Cardiff Airport. Any masterplan should make provision for this and any loss of habitat should be compensated for.

KS4 – Land at Church Farm
Protected Species - There are records of dormouse and GCN in the wider area. However, the supporting PEA indicates no direct impacts on the latter of the species. There appears to be extensive green space proposed in the illustrative masterplan, which we support.

KS5 – Land to the West of St Athan
Protected Species - The St Athan area is important area for GCN and dormouse. We would generally concur with the lower risk assessed for these species in association with this site. However, this is a substantial site and this and other sites in the St Athan area would benefit from spatial planning of biodiversity provision at a greater scale as reaffirmed elsewhere in this response.

5. Housing And Employment Allocations
Housing Allocations

HG1 (1) Land to the West of Pencoedtre Lane
Protected Sites: The site is within close proximity (200m) to Barry Woodlands Site of Special Scientific Interest (SSSI) and there is a risk from increased recreational use as a result of residential development, which could lead to impacts on the SSSI. Green space design must consider any emerging guidance for SANG to reduce recreational pressure on adjacent sites of biodiversity importance.
HG1 (2) Land at the Mole
Land Contamination: Given previous land use at site, a Preliminary Risk Assessment would be required at planning application stage to determine risk of land contamination.
Marine: An adjacent watercourse forms a hydrological link to the Severn Estuary European Marine Site (EMS). A HRA at project level will therefore be required.

HG1 (3) Land at Hayes Lane
Land Contamination: Given previous land use at site, a Preliminary Risk Assessment would be required at planning application stage to determine risk of land contamination.

HG1 (4) Land at Neptune Road
Land Contamination: Given previous land use at site, a Preliminary Risk Assessment would be required at planning application stage to determine risk of land contamination.
Marine: An adjacent watercourse forms a hydrological link to the Severn Estuary EMS. A HRA at project level will therefore be required.

HG1 (5) Land between the Northern Access Road and Eglwys Brewis Road (Site C - Central Parcel)
Flood Risk: The site is located partially within Flood Zone 2 and 3 for Rivers, with the southern area of the site located within Flood Zone 3. We refer you to Sections 10.20 and 10.21 of TAN 15, which state that highly vulnerable development in Zone 3 should be avoided. Notwithstanding, we acknowledge that at masterplanning stage, there is scope to locate residential development away from areas of flood risk. We also welcome that
Appendix B of your Infrastructure Delivery Plan notes the requirement for an FCA at project level for this site.
Watercourse: Boverton Brook (Main River) runs through the site and any development will need to ensure no adverse impacts to the watercourse with appropriate buffers and design considerations.

HG1 (6) Land adjoining St Athan Road
Land Contamination: The site is located over a principal aquifer. Any development would need to consider the hydrological setting of the site and vulnerability of pollution.

Rural Affordable Housing Led Sites
HG4 (1) Land to the East of Colwinston
Land Contamination: The site is located over a principal aquifer. Any development would need to consider the hydrological setting of the site and vulnerability of pollution.

Major Employment Allocations
SP14 (1) Land east of Cardiff Airport, Rhoose
Protected Species and Protected Sites: The site is within close proximity (360m) of Barry Woodlands SSSI and there also appears to be significant potential for the site to support dormouse, GCN, otter and water vole. There are large areas of semi-natural habitats associated with this site including woodland, mature hedgerow and watercourses. These should be retained and significantly buffered from development. Connectivity between the
site and the wider environment should also be maintained. It is therefore currently not possible to advise whether the full aspirations of the site could be fulfilled.
Land Contamination: Given previous land use at site, a Preliminary Risk Assessment would be required at planning application stage to determine risk of land contamination.

SP14 (2) Land south of Port Road (Model Farm), Rhoose
Land Contamination: Given previous land use at site, a Preliminary Risk Assessment would be required at planning application stage to determine risk of land contamination.

SP14 (3) Bro Tathan Aerospace and Business Park
Protected Species: The site is located within an important area for GCN and dormice. As mentioned, this area would benefit from spatial planning of biodiversity provision at a
greater scale to better inform allocation.
Land Contamination: Given previous land use at site, a Preliminary Risk Assessment would be required at planning application stage to determine risk of land contamination.

SP14 (4) Land to the South of Junction 34 of the M4, Hensol
Protected Sites: The site is located directly adjacent to Ely Valley SSSI. Given the biodiversity interest at the site, previous applications at the site include planning
commitments to conserve and enhance grasslands habitats on the site. These commitments have not yet materialised and the requirement for these provisions should be noted within the LDP.
Flood Risk: The site is located partially within Flood Zone 3 for Sea. We advise that an FCA will be required at project level to determine any flood risk implications at the site.

Local Employment Allocations
SP14 (5) Atlantic Trading Estate, Barry
Land Contamination: Given previous land use at site, a Preliminary Risk Assessment would be required at planning application stage to determine risk of land contamination. The site is located over a principal aquifer. Any development would need to consider the hydrological setting of the site and vulnerability of pollution.
Marine: An adjacent watercourse forms a hydrological link to the Severn Estuary EMS. A HRA at project level will therefore be required.

SP14 (6) Windmill Park, Hayes Road, Barry
Land Contamination: Given previous land use at site, a Preliminary Risk Assessment would be required at planning application stage to determine risk of land contamination. The site is located over a principal aquifer. Any development would need to consider the hydrological setting of the site and vulnerability of pollution.
Flood Risk: The site is located partially within Flood Zone 3 for Sea. We advise that an FCA will be required at project level to determine any flood risk implications at the site.
Marine: An adjacent watercourse forms a hydrological link to the Severn Estuary EMS. A HRA at project level will therefore be required.

SP14 (7) Vale Business Park, Llandow
Land Contamination: Given previous land use at site, a Preliminary Risk Assessment would be required at planning application stage to determine risk of land contamination.

SP14 (8) Land at Llandow Trading Estate
Land Contamination: Given previous land use at site, a Preliminary Risk Assessment would be required at planning application stage to determine risk of land contamination.

6. Habitats Regulations Assessment (HRA)
Marine and Coastal Physical Processes
Coastal Squeeze
We note that coastal squeeze has been screened in and taken through to Appropriate Assessment where a conclusion of no adverse effect was reached. The justification for this is that it “is unlikely that the Vale of Glamorgan RLDP will allocate many developments on
greenfield sites adjoining the estuary”.
We also note that Policy CC6 specifically relates to Coastal Defences and Shoreline Management, with reference to the Shoreline Management Plans. We recommend the use of NRW’s Assessment of Coastal Squeeze at the project level for anyone proposing to
undertake works to coastal structures.

Loss of Functionally Linked Habitat
As part of the Preferred Strategy consultation, we advised that consideration was given to potential impacts on migratory fish features of the Severn Estuary EMS. In particular, we referenced the River Ely and its tributaries providing supporting habitat for essential life cycle processes of some or all the diadromous fish species.
Within the deposit plan HRA, it is noted that likely significant effects to the migratory fish features of the Severn Estuary EMS has been ruled out, as none of the sites allocated in the RLDP lie in close proximity to the River Ely and connected watercourses. We therefore
agree with this conclusion.
In relation to bird features, Table 8 of the Appropriate Assessment identifies many key sites and allocations with high to medium potential for functional linkage to the Severn Estuary EMS. We note that loss of functionally linked habitat has been screened in and taken through to Appropriate Assessment where a conclusion of no adverse effect was reached. The justification for this is the inclusion of ‘Policy DNP8 – Severn Estuary Recreational
Pressure’ within the deposit plan.

Policy DNP8
We advise that clarification is needed in relation to this policy, as while we welcome the supporting text regarding functionally linked land outlined in paragraph 6.76 of the HRA, the policy is mainly focused on recreational pressure and is titled as such. We also note a discrepancy between the policy wording in paragraph 6.76 and Policy DNP8 in the deposit plan itself.

Visual and Noise Disturbance (During Construction)
Within the deposit plan HRA, visual and noise disturbance has been screened in and taken through to Appropriate Assessment where a conclusion of no adverse effect was reached. The justification for this is through the inclusion of recommendations outlined in 6.83 of the HRA to the supporting text of Policy SP20, which we welcome.
We also welcome the recommendation in relation to potential functionally linked land as outlined in paragraph 6.84 of the HRA.

Recreational Pressure
Within the deposit plan HRA, recreational pressure has been screened in and taken through to Appropriate Assessment where a conclusion of no adverse effect was reached. Again, the justification for this is the inclusion of ‘Policy DNP8 – Severn Estuary Recreational Pressure’ within the deposit plan, which as above, we advise needs
clarification.
We note that no visitor data has been collected from access points within the Vale of Glamorgan, but we welcome reference to the visitor surveys undertaken by
Monmouthshire and Torfaen, as well as the 2022 visitor survey commissioned by Stroud District Council.
We note that paragraph 6.25 of the HRA states that “three Key Sites and several other housing allocations lie within the 12.6km core recreational catchment that has been
deemed most appropriate for the Severn Estuary SAC/SPA/Ramsar”. However, we also note that Table 6 in the HRA only includes two Key Sites requiring mitigation, with KS3 being omitted. We advise that clarification is needed at the project level as to whether developments are situated within the 12.6km catchment area.

7. Strategic Flood Consequence Assessment (SFCA)
We have reviewed the submitted SFCA and agree with the scope of the assessment made.
We note there is currently an upper catchment Natural Flood Management (NFM) / Nature Based Solutions (NbS) project on the Cadoxton to reduce flood risk to Dinas Powys, Any updated SCFA should have regard to NFM schemes being progressed in their area and
proposals should be clearly outlined in the Development Plan (in accordance with TAN 15 2025).

8. Green Infrastructure Strategy (GIS)
We understand that the published GIS has not been updated to reflect the latest stage of the deposit plan and refers only to the preferred strategy stage (para 2.2.3). We previously provided advice on the Green Infrastructure Assessment (GIA) (re: CAS-252087-F0H1, dated 14th May 2024) which is included within the GIS. We refer you to these comments, noting that the GIS will be kept under continual review (para 1.2.5).

Vale of Glamorgan Replacement Local Development Plan (RLDP) 2022-2037
Thank you for consulting Welsh Water on the Vale of Glamorgan Deposit LDP, we appreciate and welcome the opportunity to engage in the Local Development Plan process.
Settlement boundaries
SSC1 – development within settlement boundaries
We welcome the requirement for new development to make efficient use of land and benefit from existing infrastructure provision or, where necessary, make provision for new infrastructure without any unacceptable effect on the natural environment (10).
Housing delivery
HG1 - housing allocations
A. Key sites (Policy HG1 KS1-5)
Our representation on the above sites are included in appendix 1.
B. Housing allocations (HG1 (1) to HG1 (9))
Our representation on the above sites are included in appendix 1.
C. Major landbank sites (HG2 (1) to HG2 (5))
These sites are existing commitments and Dwr Cymru Welsh Water has made representations on the planning applications submitted for these sites.
D. Housing led redevelopment opportunity (HG3 (1))
Our representation on the above site is included in appendix 1.
E. Rural affordable housing led sites (HG4 (1) to HG4(4))
Our representations on the above sites are included in appendix 1.
Our representations on the proposed allocated sites are included in appendix 1. Where planning applications have already been submitted and are pending a decision, we have made representations during the planning application consultation process regarding the capability of our infrastructure to accommodate the proposed development. If capacity does not exist within our infrastructure to accommodate the demands arising from a development site, the planning authority can make planning permission conditional upon there being adequate infrastructure available to cater for the development. A developer has a right to connect to our sewerage networks provided that a development site benefits from planning permission and there are no overriding planning conditions attached to the permission that controls the location or timing of that physical connection.
Gypsy and traveller accommodation (GT)
SP9 - gypsy and traveller site provision
Our representation on the site allocation is included in appendix 1.
Retail, commercial and service centres (RCS)
SP12 - retail floorspace provision
Our representations on the site allocations are included in appendix 2.
Community infrastructure (CI)
SP13 - community infrastructure and planning obligations
We support the provisions within the policy that the Council will secure new and improved community infrastructure where appropriate and within a timely manner, and the specific reference to utilities infrastructure. Where existing water and sewerage infrastructure requires reinforcement to serve a development it must be provided as part of the development to mitigate any adverse impacts. In circumstances where the development generates the need for infrastructure improvements that are not programmed for delivery by infrastructure providers then it must be funded by the development. Therefore, it is important for developers to engage early with relevant infrastructure providers, including the statutory sewerage and water undertaker. We welcome that the policy states that improved infrastructure must be undertaken in a timely manner. The delivery of reinforcements to the sewerage and water networks can controlled either through planning condition or a commercial agreement between the developer and Welsh Water.
Adequate potable water supply and drainage infrastructure is key to ensuring new development sites are sustainable, viable and deliverable. Hydraulic modelling assessments (HMA) may be required to determine an adequate point of connection to the water network and/or public sewers, and developers would be strongly recommended to fund investigations at pre-planning stage. Once commissioned and completed the HMA would identify suitable connection points and/or the necessary reinforcement works required to accommodate the development (for example upsizing sewers/water mains, additional storage tanks etc). In certain circumstances surface water removal could be an alternative option for allocations where foul sewer HMAs are being requested, and we would welcome early engagement with the site developer.
The reinforcements required to the network would be established by the HMA and costings would be provided at detailed design stage. The developer would need to fund a scheme by way of the requisition provisions of the Water Industry Act or via a legal/commercial agreement with Welsh Water.
Community facilities
CI3 – new community facilities
Our representations on the site allocations are included in appendix 2.
CI5 - cemetery and crematorium provision
Our representation on the site allocation is included in appendix 2.
Productive and enterprising places
SP14 - employment growth
Our representations on the site allocations are included in appendix 2.
We support sustainable economic development, however the LPA and potential developers should be aware that the obligations of a water and sewerage undertaker only extend to the ‘domestic’ supply part of an employment development (sinks, toilets, kitchen facilities etc). We are not obliged to provide potable water for use in any industrial process. Where an employment development results in higher demands of water supply and/or trade effluent discharge consent, under Section 118 of the Water Industry Act 1991, we recommend and welcome early consultation with developers. The capability of our infrastructure to service future employment allocations will be assessed when the potential demands arising from the developments are known.
EMP1 - employment regeneration opportunity areas
Our representations on the site allocations are included in appendix 2.
Climate change and transition towards net zero (CC)
SP16 - climate change mitigation and adaptation
We are supportive of this policy as the protection of water resources are key in ensuring we maintain a safe, healthy and reliable water supply. Incorporating water efficiency measures into developments will help minimise adverse impacts on localised and wider water supply networks including the quality of water resources.
We are also pleased that the policy includes particular emphasis on the importance of sustainable urban drainage systems (SuDS), in conjunction with Schedule 3 of the Flood and Water Management Act 2010. The tackling of surface water at source is a vital component of sustainable development and will mitigate against overloaded sewers which can ultimately lead to flooding. Disposing of surface water in a sustainable manner by ensuring that it does not communicate with the public sewerage network, including rainwater harvesting systems, protects the environment and assists in ensuring that there is sufficient capacity in the public sewerage network for foul-only flows from development sites.
SP19 – Green Infrastructure
In conjunction with SAB applications, under Schedule 3 of the Flood and Water Management Act 2010, we welcome provision within this policy to integrate green infrastructure with sustainable drainage systems.
Environmental protection
DNP5 – environmental protection
We welcome provisions within the policy to protect the natural environment from unacceptable impact from pollution of land, surface water, ground water and the air as well as flooding risks.
We hope that the above will assist you as you continue to progress the LDP. If you require any further information, then please do not hesitate to contact us on 0800 917 2652 or forward.plans@dwrcymru.com.

Appendix 1 – HG1 Housing Allocations, SP9 Gypsy & Traveller Site
Our representations on site allocations are provided in the table below. The following caveats are applicable to all sites:
• In accordance with the Water Industry Act 1991, Welsh Water retains rights of access to its assets at all times. Where there are sewers and/or water mains crossing sites then protection measures in respect of these assets will be required, usually in the form of an easement width or in some instances a diversion.
• Where insufficient hydraulic capacity exists within the public sewerage network or water supply network to accommodate/serve a development site, hydraulic modelling assessments (HMA) may be required, and developers would be strongly recommended to fund investigations during pre-planning stages. The findings of the HMA will identify the extent of any reinforcement required to accommodate the development, which can be procured via the requisition provisions of the Water Industry Act 1991 (as amended). If the sewerage network system in the locality is currently at capacity, there may be an opportunity to overcome our concerns by delivering a surface water removal scheme. This approach would ensure that there is no net increase in volume of flows communicating with the public sewer network, and therefore no further detriment to the public sewer network downstream of the development.
• In some instances, off-site water mains or public sewers may be required to connect to a suitable point on the existing networks at the developers’ cost. We may seek to control points of connection to the public sewerage network via appropriate planning conditions. Where assets need to be laid over private land, developers will need to comply with the requisition provisions of the Water Industry Act 1991.
• If there is limited or no capacity available at a Wastewater Treatment Works (WwTW), developers may need to fund a Developer Impact Assessment (DIA) to identify required reinforcement works. In these instances, a commercial agreement would be required between the developer and Welsh Water to deliver the necessary reinforcement works.
• Where capacity is currently available in the water supply network to accommodate development, we reserve the right to reassess our position at the time of the formal application for the provision of new water mains under Section 41 and Section 51 of the Water Industry Act (1991) to ensure there is sufficient capacity available to serve the development without causing detriment to existing customers’ supply as demands upon our water systems change continually.
• Please note the below comments are subject to change as the LDP progresses and/or as planning applications are submitted.

See tables in attachment for site specific comments.

Appendix 2 - Employment sites & other uses
Capacity comments for employment allocations can only be provided once the type of development and occupier/end-user of a site is known. Once requirements are confirmed, usually through the planning application process, further assessments will be undertaken. High-level comments are provided in the table below regarding any watermains/sewers crossing the proposed allocations, and the WwTW catchment that the sites are located within.
The following provisions are applicable to all allocated employment sites:
• the obligations of a water and sewerage undertaker extend to ‘domestic’ supplies only. We are not obliged to provide potable water for use in any industrial process. Where an employment allocation results in higher demands of water supply and/or trade effluent discharges we recommend and welcome early consultation with Welsh Water.
• The individual plots available for development can represent a substantial area of land for which the potential demands upon our assets are unknown at present. It is essential that we understand these demands to allow us to assess the impact on our assets. It may be necessary for water and/or sewerage hydraulic modelling assessments (HMAs) to be undertaken at the developer’s expense to establish where the proposed development could connect to the existing networks, and to identify any required infrastructure reinforcement works. Water mains and/or sewerage infrastructure required for any potential development site can be acquired through the requisition provisions of the Water Industry Act 1991 (as amended).
• In accordance with the Water Industry Act 1991, Welsh Water retains rights of access to its assets at all times. Where there are water mains and/or sewers crossing sites then protection measures in respect of these assets will be required, usually in the form of an easement width or in some instances a diversion of the asset.
• Where there is limited or no capacity at a WwTW, dependant on the scale and pace of development, developers may need to fund a Developer Impact Assessment (DIA) to identify required reinforcement works. In these instances, a commercial agreement would be required between the developer and Welsh Water to deliver the necessary reinforcements.
• If any development site gives rise to a new discharge (or alters an existing discharge) of trade effluent, directly or indirectly to the public sewerage system, then a Discharge Consent under Section 118 of the Water Industry Act 1991 is required from Welsh Water. Please note that the issuing of a discharge consent is independent of the planning process and a consent may be refused despite planning permission being granted.

See tables in attachments for site specific comments