MOD recommend that any more detailed policies for these sites include wording which indicates that development should be designed to ensure that it would have no impact on the operation or capability of defence sites or assets.

It is understood that Vale of Glamorgan Council are undertaking a Deposit Plan consultation regarding their proposed replacement Local Development Plan 2021 - 2036. This consultation details the overall Strategy, development policies, areas to be protected, and specific land allocations for development (including new housing, employment) over the 15-year period
The Defence Infrastructure Organisation (DIO) Safeguarding Team represents the MOD as a statutory consultee in the UK planning system to ensure designated zones around key operational defence sites such as aerodromes, explosives storage sites, air weapon ranges, and technical sites are not adversely affected by development outside the MOD estate.
For clarity, this response relates to MOD Safeguarding concerns only and should be read in conjunction with any other submissions that might be provided by other MOD sites or departments.
The Welsh Government’s Development Management Manual as revised May 2025, identifies, at figure 7, that a number of non-site-specific directions are currently in force, the list includes the Town and Country Planning (Safeguarded aerodromes, technical sites and military explosives storage areas) Direction 2002. Through this direction the MOD is involved in the planning system as a statutory consultee. Statutory consultation occurs as a result of the provisions of the Direction, and the plans issued to Local Planning Authorities by the Welsh Government, which are provided by MOD.
The area covered by any Vale of Glamorgan Council Local Plan is partially covered by a safeguarding zone that is designated to maintain the effective operation of a MOD technical site that is retained at St Athan, at which is located a High-Resolution Direction Finder (HRDF) technical asset. This is a navigational aid which serves to maintain air traffic safety.
To illustrate the various issues that might be fundamental to MOD safeguarding assessments, a brief summary of the technical safeguarding zone is provided below. Depending on the statutory safeguarding zone within which a site allocation or proposed development falls, different considerations will apply.
The dimensions and materials used in the construction of a development may be relevant factors in assessing the impact of a given scheme. Developments that incorporate renewable energy systems may be of particular concern given their potential to introduce large expanses of metal or electrical noise interference, which may be a particular issue where solar farms are developed.
The MOD notes and welcomes the intentions of Policy EMP2: MOD ST ATHAN. However, it is recommended that additional wording is added to make clear that this policy relates to the safeguarded MOD technical site. Therefore, it is recommended that wording is updated. “New development within or adjoining MOD St Athan and the safeguarded MOD technical site that is demonstrated to be required for operational defence and security purposes, and helps enhance or sustain their operational capability, will be supported in principle. Proposals for non-military or non-defence related development within or in the areas around MOD St Athan, or the safeguarded MOD technical site will not be supported where it would adversely affect military operations or capability, unless it can be demonstrated that there is no longer a defence or military need for the site.”
Where development falls outside designated safeguarding zones the MOD may have an interest where development is of a type likely to have any impact on operational capability. Usually this will be by virtue of the scale, height, or other physical property of a development. Examples these types of development include, but are not limited to:
Tall or narrow profile structures such as masts or flue stacks with a height of 50m or greater above ground level may introduce obstruction hazards to low flying military aircraft using the UK military low flying system.
The MOD also needs to be consulted on all proposals to develop wind turbines that are 11m or greater in height to blade tip or, that have a rotor diameter of 2m or greater. This is necessary to safeguard defence radar coverage across the UK used to manage MOD ranges, provide air traffic control and maintain UK air defence.
The MOD notes that Draft Policy CC3 assigns the renewable energy local search areas that have been defined in the deposit plan. This supports the generation of non-domestic renewable, low and zero carbon energy. The Renewable Energy assessment from 2023 identifies potential opportunity areas for renewable energy and provides a high-level assessment of wind and solar energy resource within the Vale of Glamorgan and identifies several sites, known as ‘search areas’ where the potential for development is greatest, and identification of 20 of the largest sites for both wind and solar.
Draft policy CC4 defines requirements that any development will need to demonstrate compatibility with. It is noted that specific reference to aviation safeguarding is included. However, the MOD considers it necessary that this is expanded to include specific reference to those technical assets which facilitate aviation safety such as navigational aids. In addition, the MOD also considers it necessary that specific mention of the need to account for defence radar coverage in relation to wind energy development is specifically identified.
In principle, the MOD has no objection to any renewable energy development occurring in the renewable energy local search areas that have been defined, subject to confirming that that it will be compatible with defence safeguarding requirements.
Some renewable energy generation infrastructure, for example wind turbine generators can, by virtue of their physical dimensions and properties, impact upon the effective operation of safeguarded defence technical installations. Solar farm developments located in proximity to safeguarded navigational aids, or other types of technical sites, can impact upon their effective operation by introducing substantial areas of metallic types of surfaces that may affect transmissions.
Where turbines are erected in line of sight to defence radars, the rotating motion of their blades can degrade and cause interference to their effective operation.
The MOD recommend that any emerging policy makes clear that, where an MOD assessment indicates that a development would have a detrimental impact on the operation and capability of defence assets or sites, that such an application would be refused or that conditions may be attached to any consent that might be issued which may include the removal of permitted development rights.
For your convenience, please find a table at Appendix A which provides a summary of the safeguarding criteria that would apply to those potential development housing allocations identified. MOD recommend that any more detailed policies for these sites include wording which indicates that development should be designed to ensure that it would have no impact on the operation or capability of defence sites or assets. The table below provides a summary of those sites and the triggers for statutory safeguarding consultation that would apply:
I trust this clearly explains our position on this update. Please do not hesitate to contact me should you wish to consider these points further.
Appendix A
Policy HG1 KS4 - MOD St Athan (technical safeguarding zone)
• Development of, or exceeding, 15.2m in height above ground level will trigger statutory consultation requirement
• Development of, or exceeding, 45.7m in height above ground level will trigger statutory consultation requirement
Policy HG1 KS5 - MOD St Athan (technical safeguarding zone)
• Development of, or exceeding, 15.2m in height above ground level will trigger statutory consultation requirement
• Development of, or exceeding, 45.7m in height above ground level will trigger statutory consultation requirement
Policy HG1(7) - MOD St Athan (technical safeguarding zone)
• Any development or change of use will trigger statutory consultation requirement
• Development of, or exceeding, 10.7m in height above ground level will trigger statutory consultation requirement
Policy HG1(8) - MOD St Athan (technical safeguarding zone)
• Any development or change of use will trigger statutory consultation requirement

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

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

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

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

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

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

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


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


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




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


Policy SP5 - Creating Healthy and Inclusive Places and Spaces


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


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

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


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

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


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

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


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

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

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


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

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


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


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

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


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

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


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

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


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

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


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

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


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

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


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

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

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


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

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


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

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


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

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

ANNEX 1
Preface

This Annex sets out the detailed case in support of these representations, and by association the case for allocation of the site.

The representations are structured into the following sections:

1. Response to the Deposit Plan;
2. Comments on specific policies; and
3. A summary of the suitability of the site for development.

SECTION 1. Response to the Deposit Plan

Distribution of Growth

We object to the distribution of growth within the Deposit Plan. Specifically, we object to the strategy that underpins the Deposit Plan, which seeks to introduce the proposed ‘Strategic Growth Area’ which is expected to contain the majority of housing growth in the Vale over the Plan period, or rather the over-reliance on this defined area, and the associated absence of growth in other parts of the Plan area.

As outlined in our previous representations, the allocation of housing and the location of strategic growth neglects the Rural Vale, and in our view, overprovides in the Strategic Growth Area. For example, with limited housing stock and average house sales at over £500,000 over the last 12 months, there is a clear and established need for new homes in the Ystradowen area, particularly at an affordable level. This is reinforced by the Local Housing Market Assessment that identified a need for over 1,114 new affordable homes per annum over the next five years throughout the county, and 196 units per annum thereafter (average of 502 units per annum over 15 years). Further to this, it is widely known that the rural Vale comprises the majority of the county’s ageing population, which, as a demographic, has and will continue to grow rapidly over the Plan period. This is evident in the ‘Population Change’ chart below – which is taken from the Deposit Plan:
VofG Deposit Plan: Figure 4 Population Change 2011 to 2021

It is clearly the case that younger populations are migrating to other Authorities, where access to housing is typically cheaper and more affordable, whilst more older populations are significantly migrating into the Authority. This trend will result in an extremely unbalanced demographic, given that the working-age population have sought housing elsewhere.

Without a suitable supply of affordable housing delivered over the Plan period, this trend will only worsen. Accordingly, it is not considered that the RLDP takes into account the lack of supply of affordable homes within the rural Vale, as well as increased housing to support the growing ageing population within these areas.

Para 3.19 of the Deposit Plan clearly outlines that affordable housing is required in the short term, in order to meet pressing needs. Specifically, it outlines the following: “There is significant pressure on temporary accommodation in the Vale, for a variety of reasons including increased homelessness presentations… The need for sufficient permanent affordable housing to assist in moving people out of temporary accommodation is critical and the planning system has a vital role in assisting in new affordable housing delivery.”
Accordingly, the distribution of growth within the Authority must be proportionate, to ensure that populations / areas are not left behind where they must seek access to housing elsewhere.

The RLDP Sustainable Growth Strategy sets out 6 objectives. Objective 4 states: “Allowing for small scale affordable housing led development in settlements outside the Strategic Growth Area at a scale proportionate to the size of settlement.” (Page 66)
Para 5.25 states “Therefore, a key part of the strategy is to allow for affordable housing led developments within sustainable primary and minor rural settlements outside of the Strategic Growth Area, at a scale that is appropriate to the size of the community it is serving. An ‘affordable housing led’ scheme is one where a minimum of 50% of the dwellings would need to be affordable, although this could increase to a maximum of 100% if the site is brought forward by a social landlord”.

In terms of the definition / explanation of what the affordable housing-led development sites are seeking to achieve, paragraph 6.132 of the Deposit Plan outlines the following:

“Accordingly, to ensure that new developments respond to the high demand for smaller properties, as identified in the LHMA, priority will be given to affordable homes that are small to medium-sized, typically comprising one to three bedrooms. Representations received from the local community through the RLDP process also highlighted a desire for new housing developments to offer opportunities for accessing smaller market homes. This is particularly relevant in the rural Vale, where housing choices are more limited. Providing smaller, more affordable market homes may assist first-time buyers and enable older residents to downsize to more manageable properties within their local area. Affordable housing-led sites will therefore need to demonstrate that an appropriate range of both affordable and market dwellings has been provided.”

Despite the acknowledgement within this strategic objective, we do not consider that the RLDP goes far enough to meet this objective, nor are its provisions and allocations adequate.

It is considered that this objective is undermined by the allocations set out by the RLDP (not least the absence of allocations in the rural Vale). Notwithstanding the Vision’s clear acknowledgement of the benefit of the growth of the rural Vale, these areas have not been supported through the plan due to the lack of growth which has been attributed to these areas in terms of further housing, employment and sustainable transport. All growth options have been selected on the basis of being in either a Key Settlement, Service Centre Settlement or Primary Settlement, all of which are already sustainable areas served by rail. As a result, it is not clear how this objective can be achieved, without the allocation of further sites within the Minor Rural Settlements, such as Ystradowen. The Vale is characteristically ‘rural’, and as such, there needs to be a stronger emphasis on supporting and delivering new development in order to bolster the rural economy. This includes enabling opportunities to provide employment and business premises within / near to rural settlements, as well as focusing housing growth in these areas to reduce travel time, and promote the use of sustainable transport.

It is considered that the current Strategy does not provide adequately for all residents across the Vale, only those within the Strategic Growth Area. The underlying Vision and Objectives set out in the emerging Plan are accordingly wholly un-provided for by the detail of the Plan. This brings into question the “soundness” of the Plan.

The Strategic Growth Area does not take into account the important role and proximity of Bridgend to the West and/or the Principal Settlement and Strategic Growth Area of Talbot Green / Pontyclun / Llantrisant to the north (as defined in the RCTCBC LDP). The Minor Rural Settlements to the west are more likely to be supported by job opportunities and employment in Bridgend than further east in Barry or Cardiff. Similarly, those in the north align with, and function in association with, the Principal Settlement and Strategic Growth Area of Talbot Green / Pontyclun / Llantrisant to the north. These settlements are served by existing bus services that provide sustainable modes of travel to key employment locations in and around Bridgend. This is acknowledged in Paragraph 3.3 of the Strategy which states “The greatest number of residents who travel outside of the Vale for work purposes travel to Cardiff followed by Bridgend and Rhondda Cynon Taf, whilst a smaller proportion commute into the Vale from these neighbouring authorities”. The Demographic Evidence (Feb 2023) estimates the Vale as being a net importer of workers from RCT and Caerphilly (Para 3.6) - as shown in Figure 10 in the Preferred Strategy.

The current Strategy does not support any improvement of sustainable travel or further investment in settlements linked more closely to these areas - given that Growth has been apportioned in only the Key Service Centre and Primary Settlements. It is considered that this will fail to support and facilitate the current (and any future) employment coming into the Vale, nor will it support any employment which is located outside of the Vale to the West and North. The Growth Option is too heavily reliant on access to railway stations as the key and sole sustainable transport method, whereas access to bus services should also be appropriately assessed and focused on in terms of promoting sustainable development. It is unreasonable to devise a strategy that hinges on directing growth to areas that are accessible to railway facilities, where it is recognised in the Plan that the Vale is inherently rural. The delivery and soundness of the Plan is therefore questioned and we continue to object to the spatial growth strategy as set out in the Deposit Plan.

Housing Supply

RLDP Allocations - Key Sites

As set out in representations made throughout the Plan preparation process, we consider that the Plan is too reliant on the delivery of ‘key sites’ to meet the housing need over the Plan period. Specifically, the Plan makes provision for 2,278 units in these Key Sites, which equates to circa 65% of RLDP allocations in the housing supply. The 5 key sites that are allocated in the Deposit Plan are as follows:

• Land at North West Barry – 376no. units;
• North of Dinas Powys – 250no. units;
• Land at Readers Way, Rhoose – 520no. units;
• Land at Church Farm, St Athan – 532no. units; and
• Land to the West of St Athan – 600no. units.

We object to the current housing supply to allocate 2,278no. (65%) of units across strategic sites, as this makes for a risky and unrobust strategy for delivering housing, and in turn, meeting the identified housing need over the Plan period.

As stated in previous representations, there is concern that the proposed timing and phasing of the proposed Key Sites is unrealistic and unrobust, and in turn, undermines the soundness of the Plan, given the heavy reliance on Key Sites delivering new homes across the Plan period. Whilst it is not disputed that the sites would have gone through rigorous assessment to inform their proposed allocation, the timescales for securing planning permission (with all associated conditions discharged) is considered to be unachievable. This is particularly the case for the following timescales that are set out in the Housing Trajectory that underpin the Plan:

• “Time period of pre-application discussions/PAC consultation” – 4 months
• “Time between submission of planning application and determination” – 6 months
• “Time taken from planning consent to the discharge of relevant conditions to enable site construction” – 4 months

It is considered that the above timescales are fundamentally unrobust, and result in a distorted position of housing sites over the RLDP Plan period. It is not considered that these reflect or are informed by the timescales that are currently being incurred for planning applications submitted for major housing sites across Wales. It is rather the case that such applications would typically be determined 1-2 years following submission, given that there are a wide range of stakeholders involved in the determination of major planning applications – which often adds to the delays associated with the determination of such applications.

It is equally the case that the assumptions in the trajectory are solely based on expected timescales for processing formal submissions made to the Council, and do not factor in the timescales associated with, and needed for, the preparation of the material for submission.

It is assumed that these timescales have not considered that such major developments can be subject to the need to undertaking and submitting an Environmental Impact Assessment (EIA), which adds another layer to the determination of any planning application – given the additional considerations that form part of this process. As such, any site subject to EIA would very likely result in further delays extending beyond the timescales set out in the trajectory. Equally, as set out above, the preparation of an application subject to an EIA requires even more detail and assessment, which only further adds to the preparation stage (which has not been factored into as part of the trajectory). Accordingly, it is not considered that the trajectory contains any contingency if any site is required to undertake EIA as part of their application.

For the reasons stated above, it is unlikely that the sites will yield in full, particularly those sites which are expected to deliver housing right up to the final year of the Plan period (‘Land at Readers Way’ and ‘Land to the West of St Athan’). These sites do not allow for any ‘slippage’ should any delays arise through the development management process (which for the reasons set out above, will very likely be the case), and as such, a gap in housing delivery will be brought about as a result of these sites not yielding in full.

Given the proposed ambitious timescales set out for the delivery of the Key Sites, it is considered the housing trajectory is unrobust, and in turn, undermines the soundness of the Plan as a result. A change in strategy should be pursued whereby a greater proportion of small to medium sites are allocated for housing in the Plan period, which are more likely to fully yield given that such sites are subject to less assessment and consideration compared to strategic sites. This would make for a more robust strategy, where a greater number of small to medium sites can deliver housing in the short and medium term of the Plan period, whereas the strategic sites represent a more longer-term strategy to deliver housing – which would then spill into the next Plan period.

Accordingly, we object to the Deposit Plan in its current form, where there is an overreliance on housing need to be met through the delivery of the Key Sites, which we consider to be unrobust, and undermine the integrity and soundness of the Plan. The current strategy of the Plan is at significant risk of not delivering the level of housing expected based on the sites allocated, as least as swifty as identified in the housing trajectory. Should no change be made to the Plan to address the above issues, then it is extremely likely that the Plan would ‘fail’ in meeting the identified housing need.

Windfall Sites

It is noted that the RLDP is made up of the following:

• Existing land supply (3,838 units)
• Windfall sites (1,303 units)
• Allocated sites (3,521 units)

Para 6.69 states that “Analysis of historical delivery of housing indicates that on average small windfall sites (sites of less than 10 dwellings) have provided some 53 dwelling completions per year, and large windfall sites (10 dwellings or greater) contributed on average 80 dwellings per year. Overall, it is projected that windfall sites could contribute a further 1,303 dwellings over the remainder of the plan”.

As set out in our previous representations to the Housing Trajectory, we would object to the expected numbers of completions expected during the Plan period, given that there are a number of issues with delivering housing in Wales and given past completions rates for The Vale of Glamorgan – which is discussed in greater detail later in this submission. Again, this results in the Plan being at risk of not delivering the level of housing expected based on the sites allocated – including any windfall sites.

St Athan Train Station

The RLDP Sustainable Growth Strategy comprises six key elements, of which the following is set out in respect to the allocation of new housing growth in the Authority:

“3. Focusing development at locations that are well served by existing and proposed rail stations as part of the South Wales Metro and in areas with good bus links.”

The strategy outlines that a feasibility study for a station in St Athan had been undertaken in 2022, which identifies that a new station could be located in St Athan, subject to further investigation work. Accordingly, in line with the spatial strategy adopted for the RLDP (i.e. focus development around sustainable transport nodes), St Athan was identified as a ‘Strategic Opportunity Area’ to accommodate strategic growth – through the proposed allocation of two key sites : ‘Land at Church Farm’ and ‘Land West of St Athan’. These sites have been identified to deliver 532no. and 600no. units respectively in the Plan period. These are separate to, and are in addition to, the 51no. units that have now been attributed to the site ‘Land South of Clive Road’ and 80no. units attributed to ‘Former Stadium Site, adjacent to Burley Place’ in St Athan. Accordingly, in total, the Housing Trajectory makes a provision for a total of 1,263no. homes to be delivered in St Athan over the Plan period.

It is now the case, however, that the proposed railway station at St Athan is not in the first phase of delivery for new stations in South Wales – as confirmed in the ‘Today, Tomorrow, Together: A vision for rail across Wales and Borders’ (February 2026) recently published by Transport For Wales. This paper acknowledges that a new railway station at St Athan would represent a longer term opportunity, and therefore, will not be delivered in the short term / within the Plan period of the emerging Plan. Equally the Council have not provided any evidence to contradict this, and therefore, it is very unlikely that any new train station will be delivered in St Athan over the Plan period. This brings about significant questions regarding the suitability and acceptability of the proposed allocations set out above.

The strategy to allocate new housing growth is predicated on focusing residential development around sustainable transport nodes, and given that St Athan will be without any railway station in the Plan period, it is not considered that the sites align with the strategy of the RLDP. Accordingly, the wider Housing Trajectory is considered to be unsound, given that a total of 1,263no. homes (36% of the Plan’s new housing allocations) are expected to be delivered in St Athan within the Plan period.

It is considered that there has been an overprovision for housing growth in St Athan generally, and this issue is now further exacerbated by the lack of any forthcoming rail provision. Given this, to add further sites for housing in this location over and above the original provision is considered to be unsound. As set out above, the justification to allocate sites at St Athan has relied heavily on the railway station being delivered in the Plan period, and as such, there are serious questions marks associated with the acceptability of the proposed allocated sites - given their incompatibility with the core strategy of the RLDP.

In terms of the expected delivery of the Key Sites in St Athan, it is noted that the trajectory identifies that for the majority of the Plan period, both sites will be delivering 80no. dwellings per annum on each site (equating to 160no units in total). Whilst these are two separate sites, we seriously question the realistic prospects of the significant number of homes being built simultaneously on two sites in proximity to one another – given the considerable logistical issues that would be brought about.

Accordingly, it remains that there are serious questions regarding the suitability and acceptability of the proposed allocations at St Athan, which do not accord with the strategy adopted for the RLDP – to focus housing growth on settlements that are supported by railway stations. Moreover, the scale of development proposed at St Athan is also not considered to be proportionate, with a significant number of homes delivered in a location not served by a railway station.

Rolled forward LDP Sites

The proposed land supply within the housing trajectory includes provision for ‘rolled forward’ LDP sites, which contribute to the total of ‘Proposed Additional Housing Allocations’ forming part of the housing supply. Specifically, a total of 1,242no. units have been identified as additional housing allocations, of which 959no. are expected to be delivered on the rolled forward LDP sites. As such, these sites are to provide for a significant proportion of additional housing in the Plan period (specifically circa 77%).

The Development Plans Manual (DPM) sets out that allocations rolled forward from a previous plan will require careful justification for inclusion in a revised plan. The DPM outlines that “there will need to be a substantial change in circumstances to demonstrate sites can be delivered and justify being included again. Clear evidence will be required that such sites can be delivered.” The below table included in the consultation document provides a breakdown of the rolled forward LDP sites, and in particular, sets out the status of each site:
Table 6: Existing LDP allocations to be carried forward

The above table evidences that the current LDP has under delivered in regard to its targeted unit number of the Plan period, given that these sites did not yield any housing over the current Plan period. This is further exacerbated by the Land Bank sites that have also not delivered any housing across the existing LDP period, amounting to 1,860no units. Accordingly, when considering the non-delivery of both rolled forward LDP sites and Land Bank sites, this amounts to an approximate shortfall of 2,189 homes being delivered, or 33% of the total housing supply identified for the current LDP (8,525no. dwellings).

It is therefore considered that, as a minimum, the units carried over from the LDP (without planning permission) should be a surplus to the housing supply proposed for the RLDP, as opposed to being relied on to deliver the housing need over the Plan period. This is particularly the case for the two sites (Land to the west of Pencoedtre Lane, and Land between Northern Access Road and Eglwys Brewis Road) which do not currently have any active planning application submitted for their development. These sites total an amount of 370no. units to be delivered in the Plan period, which represents more than a third of the additional housing allocations to make up the housing supply.

As such, it is considered that the unmet need deriving from the existing LDP is still present – indeed it has grown, and will continue to do so, not least when considered in conjunction with the projected population growth over the coming years to 2036, and the aspirations for growth in the Plan’s strategy.

Accordingly, in order to secure the targeted level of housing, a greater level of provision for new allocations should be applied in order to meet the housing requirement. This would bring about better certainty that the housing requirement is met by the housing supply over the Plan period, not least given that the current Plan failed in this respect. Without a re-apportioning of the housing supply, it is considered that the Plan would heavily rely on the contingency (i.e. rolled forward LDP sites) coming forward in the Plan period, yet there is uncertainty that these will yield in full over the new Plan period. This raises issues of ’soundness’, and risks rendering the Plan unrobust.

Housing Delivery Rate Assumptions

As set out in our previous representations to the Housing Trajectory consultation, we have considerable concerns in relation to the proposed delivery of the sites identified in the trajectory – which we do not consider are robust or reasonable.

Appendix 1 of the Deposit Plan sets out the development trajectory bar chart – which illustrates the proposed delivery of housing, on a per annum basis, over the Plan period.
Extract of Housing Trajectory (annotated by GJP - red dotted line)

It is our view that the trajectory makes for an unrealistic and unrobust delivery rate of housing, which does not reflect the pattern of housing completions in the Vale of Glamorgan. We therefore have concerns regarding the soundness of the trajectory, not least that there remain significant uncertainties as to the delivery of the Key Sites (as discussed earlier in these representations).

Firstly, the graph / trajectory illustrates a large ‘spike’ in terms of housing delivery in the year 2027-28, which is considered to be a marked and pronounced step change in the rate of delivery. This envisages / relies on a significantly higher rate of delivery than previous years in the Vale of Glamorgan (2021 through 2021 – as depicted by the green columns). It is considered that this level of delivery is unlikely to materialise, not least given prevailing market circumstances, past rates of delivery on the ground, and also in light of levels achieved across Wales and the UK in general.

The published trajectory shows that the average level of completions from 2021 - 2025 has been approx. 400 - 500 units, however, the chart shows that from 2027 – 2028, completions are expected to rise to approx. 1,000 units per year. The expected delivery levels in the trajectory therefore show and assume a doubling in delivery rates and unit numbers (an increase of approx. 100% relative to past rates). There is no clear evidence as to how this level of completions can be achieved let alone guaranteed. This is the case in particular given that the forthcoming years (2025-2027) are expected to see performance (yield) drop significantly (delivery rates in 2025 – 2026 and 2026 – 2027). The chart shows only approx. 200 units being delivered over these years. It is therefore unclear how completion rates are expected to rise so quickly (from 200 in 2025-26 to 1000 in 2027-28), and by such a significant amount. The assumptions in the trajectory are wholly unrobust in our view.

It is also the case that the anticipated delivery of housing fails to be consistent within and across the Plan period. It is unclear as to why completions rates aren’t spread out more evenly throughout the Plan period - to ensure a robust and most realistic housing trajectory until 2036. By comparison to the marked increase in the rate of delivery between and over the period 2027 to 2031, there is then a marked fall-off or drop in delivery towards and by the end of the Plan period. Indeed, in the final year, the level of completions are expected to be lower than the period 2021-2025.

Accordingly, we consider that the housing trajectory, as proposed, is entirely manufactured and unreflective of the past completion rates, as well as the recent published completion rates provided by Welsh Government recently in August 2025. As set out in our previous representations, it has been evidenced that there has been a general decline in the number of new dwellings started and completed.
Description of Figure 1: ‘New House Building: April 2024 to March 2025’
As identified in the graph above, in 2024-25, 4,631 new dwellings were completed, which represents 3% fewer than the previous year. This figure represented the second lowest number on record, with the lowest number recorded in 2021-22, a year heavily affected by the coronavirus (COVID-19) pandemic (in 2021-22, 4,616 new dwellings were completed) The New Housing Pipeline Report Quarter 3, 2025 Report (December 2025) published by the HBF evidenced that the number of residential units approved in the UK fell by 7% during the third quarter of 2025, extending the decline seen during the first half of the year. At 45,075, the number of units approved was 34% down on the third quarter of 2024 and the lowest quarterly total since 2012 Q2. At 146,798, the overall number of units approved during the first nine months of 2025 was 25% lower than a year ago.
HBF Graph Illustrating Residential Approvals (2006-2025)

The above graph clearly shows a pronounced downward trend in the number of residential planning approvals over the period, particuarly with a sharp decrease seen since 2020. Further, the HBF document ‘Increasing Housing Supply in Wales’ (4th September 2025) clearly shows that The Vale of Glamorgan has not met the housing delivery requirements in recent years in 2023 – 2024 – along with every other authority in Wales (except Newport). Accordingly, this further adds to the argument that historically The Vale (and most other authorities) have underprovided. This adds considerable uncertainty on the assumed transformation in yield and delivery as built into the trajectory.
Graph: Housing Delivery as a proportion of annual housing requirement in Wales per Authority

More recently, the Welsh Government has released its new estimates of housing need (Estimates of Additional Hosing Need: 2025-based – February 2026). The estimates show how many new homes need to be built over the next twenty years to address existing unmet need as well as newly arising need. The figures set out that around 8,700no. new homes a year are needed over the next Senedd term up to 2030 to meet new housing need. Additionally, there is an unmet need for 9,400 affordable homes.

Overall, this represents more than double 2024/25 levels of supply, where just 4,638 new homes were built.

HBF: Estimates of Housing Need

HBF: Actual Delivery vs Estimates of Need

The above graphs unequivocally evidence that historical rates of delivery of housing in Wales has remained low, and moreover, significant numbers of housing need to be allocated in order to meet the estimate of need. It is not considered that the housing trajectory, in its current form, is robust to meet the housing need over the Plan period, given the uncertainties of the Key Sites, and the level of housing delivery that has been identified for the Plan.

Affordable Housing-Led Sites

HG4 - Rural Affordable Housing Led Sites

Policy HG4 of the Deposit Plan identifies four sites to be allocated as affordable housing-led sites, totalling approximately 122 dwellings within the plan period. Given the target levels of achieving 3,070 affordable dwellings over the course of the Plan period (up to 2036), it is not considered that this policy goes far enough to address the target and level of affordable housing need.
It is noted that the number of units identified for each site relate to the ‘total’ number of units delivered, as opposed to the affordable housing provision. Accordingly, it can be assumed that circa 50% of each allocation will comprise affordable units (given each site is affordable-led), which would equate to a total provision of circa 61no. units. The contribution from the affordable housing-led sites would only equate to 2% of the total need (3,070no. units). Even when coupled with the affordable housing provision from open market sites and 100% exception sites, the total delivery of affordable housing will still be nowhere near enough to meet the overall affordable housing need over the Plan period. Accordingly, it is considered that inadequate provision has been made for such sites.

Insofar as to the sites chosen and allocated are concerned, it is clear from reviewing the Stage 1 and Stage 2 Candidate Site Assessment that the allocated sites HG4(1) – (4) were not considered acceptable due to being outside the strategic growth areas, and were considered to be unacceptable intrusions into the open countryside. After being resubmitted as affordable housing-led sites, the sites were allocated, some with a smaller area in order to accommodate less dwellings in total.

The sustainable credentials of the sites allocated is not disputed, and it is acknowledged that these minor rural settlements have the ability to accommodate further growth, in the form of affordable-led housing allocations. However, it is considered that Land at Ystradowen (Site ID: 430 / 4060) should also form an allocation as part of this policy, given its high sustainability credentials and its appropriate location to accommodate a suitable level of development. Please refer to the previous representations made to the Housing Trajectory Consultation (dated 17th October) and Annex 2 for further, more detailed comments regarding the above sites.

The LHMA 2023 shows that there is a need for 230 affordable homes in the Cowbridge housing market area / ward - which Ystradowen is located within. As such, there is an identified need for affordable housing in this area, something which the site could address through an allocation – see Annex 2.

Securing further delivery of Affordable Units

As set out above, the affordable housing-led allocated sites only provide 122no. affordable dwellings, which comprise 4no. allocated sites that are expected to deliver approximately between 20 – 50 dwellings. However, the RLDP sets a target of 3,070 affordable homes to be delivered in the Plan period. This means that affordable housing-led allocations make up less than 4% of the target provision and will only make provision for 2% of the targeted number. We would therefore object to the sites included within Policy HG4 and would suggest that more sites should be allocated as part of the policy in order to secure delivery of a higher number of affordable housing units to mere the target.
Whilst it is acknowledged that the Key Sites will provide for a significant proportion of affordable housing, as set out above in these representations, there is serious concern regarding the deliverability of these sites, which would result in a significant gap of affordable housing delivered.

A greater number of affordable housing-led sites allocated would ensure there is sufficient contingency built into the Plan, to ensure that the overall affordable housing need is met over the Plan period. Failure to do so would result in affordable housing need being unmet, with demand continuing to outstrip supply.

Previous representations to the Preferred Strategy (dated 14th February 2024) provided comment on the sustainability scoring of Ystradowen and the proposed site. As outlined within these representations, it is considered that the site (ID 430) represents a sustainable, deliverable and acceptable site. The site is located within 2.7 miles Cowbridge and
2.8 miles of Pontyclun. Due to the availability of frequent bus services, and active travel links, key services are readily available to access for any residents within Ystradowen without the need to travel by car. The site is within a maximum 9- and 14-minute bus journey (respectively) of the following key services:

• Cowbridge and ‘Y Pant’ Comprehensive Schools;
• Cowbridge Health Centre and Old School Surgery; and
• Cowbridge Town Centre, and Talbot Green / Pontyclun / Llantrisant (Strategic Growth Area), for various Retail Services.

Accordingly, the settlement of Ystradowen represents an acceptable location to allocate an affordable housing-led site, given the access to existing services and facilities that would serve future residents of the site.

To conclude, the settlement, location and site are inherently suitable and deliverable, and will make a significant contribution to achieving and realising the housing and economic development needs of Ystradowen, support the surrounding settlements, and the Plan area as a whole. As such, the site should be considered further.

Comments on Specific Policies

HG5 - Affordable Housing Exception Sites

Given the unmet need and extant backlog of affordable housing, as identified within the LHMA (2023), it is noted that an Affordable Housing Exception Sites policy has been adopted in order to assist in the delivery of affordable housing. Policy HG5 sets out the specific criteria where proposals for 100% small scale affordable housing developments will be permitted outside settlement boundaries. The current policy wording for the Affordable Housing Site Exception Policy and the criteria listed out in the policy is generally supported.

That said, it is noted that a ‘cap’ of 10 dwellings (as referenced within supporting text Para 6.140) is set. This should be amended due to such a ‘cap’ limiting the flexibility of the policy, in particularly for sites coming forward as part of this policy in Minor Rural Settlements.
As such, we would suggest that supporting Para 6.140 should be amended in order to allow for further flexibility for sites in Minor Rural Settlements to come forward and to deliver affordable housing, given that the criteria set out in the policy would already protect and restrict the extent of any development as it stands. Therefore, the proposed amendments to Para 6.140 are outlined below in red:

6.140 “For the purposes of this policy, ‘small-scale’ will generally mean no more than around 10 dwellings on sites adjoining Minor Rural Settlements. In Primary Settlements outside the Strategic Growth Area, proposals for more than 10 dwellings may be acceptable where required to meet a specific need and where the number of dwellings is proportionate to the size of the settlement. In assessing the scale and extent of any proposed local needs housing, consideration should also be given to affordable housing already planned in the ward or nearby area, including sites with existing planning permissions and those allocated in the RLDP. The size and type of affordable housing proposed should reflect the identified local need in the area.”
The above suggested wording would achieve a more flexible policy, which would allow for a variety of scaled applications to secure planning permission for solely 100% affordable housing across the Authority area. This greater flexibility would enable the policy to make a significant contribution towards meeting the affordable housing need – which, as set out earlier is in considerable need.
SECTION 3. Suitability of the site for development

The site promoter objects to the overall assessment of the site, in that it is not considered suitable for further development in the Plan. The promoted site has undergone extensive scrutiny and appraisal at a high level to ascertain the qualities of the site, in light of all identified material considerations which relate to the proposals.

The delivery of the site will yield much needed housing (including Affordable housing) and contribute to the overall supply in the new Plan period, whilst making effective use of a suitably located site for residential development.

Moreover, as set out in ‘Annex 2’ of our representations, the site has overcome the ‘constraints’ set out in the Candidate Site Assessment undertaken for the site, which demonstrates that the proposal is both acceptable and deliverable.

Deliverability of the Site

In summary, the site seeks to deliver the following key elements:

• Provision of circa 67 new-build residential dwellings (including 50% affordable housing provision);
• A mix of house-types and tenures across the site to cater for a variety of needs;
• Creation of a new primary access into the site;
• Connection to pedestrian links within the wider area;
• Public open space; and
• Green Infrastructure; and
SUMMARY AND CONCLUSIONS

In summary, the site promoters:

• Object to the distribution of growth proposed for the Plan area, with a more balanced and equitable distribution of housing sites required in order to meet the identified housing need;
• Object to the level of growth identified for the Plan period;
• Object to the housing trajectory that underpins the delivery of housing within the Plan period – which is considered to be unrealistic and unrobust, leading to serious uncertainty regarding the “soundness” of the Plan;
• Object to the over-reliance on Key Sites and Rolled Forward Sites in making up the Plan’s housing land supply;
• Object to the scale and timing of delivery of sites in / around St Athan – all of which are predicated on railway station provision which will not be realised in the Plan period;
• Object to the under-provision of sites under Policy HG4 – Rural Affordable Housing-Led sites, not least given their extremely limited contribution to the targeted need for affordable housing;
• Object to the current wording of the HG5 Policy ‘Affordable Housing Exception Sites’ which requires greater flexibility to play an important role in delivery much-needed affordable homes across the Authority; and
• Object the Council’s assessment that the site is not considered suitable for development.

The site and proposals are consistent with the RLDP strategy, other Vale of Glamorgan strategies, and the requirements of Planning Policy Wales and Future Wales. It will make a significant contribution to the Vale’s identified housing requirement in the RLDP period and will provide for a wide range of uses that will support the wider community whilst embodying principles relating to placemaking and the well-being of future generations.

The site has no fundamental constraints and has the ability to deliver significant economic, social and environmental benefits for the benefit of future residents and the existing local community. The site is demonstrated to be viable, being able to deliver policy-compliant levels of affordable housing and given its location within a strong market area, will benefit from high delivery rates.

ANNEX 2
SECTION 4. A summary of the suitability of the site for development including a Response to the Candidate Site Assessment

Land at Ystradowen (Site ID: 4060)

This section of the overall representations to the Deposit Plan is to respond to, and address, the Council’s assessment of the site. The ‘Candidate Sites Assessment Deposit Plan Stage v2’ for ‘Land at Ystradowen (Site ID: 4060)’ sets out that the position of the site at the Deposit Stage is as follows:

“Amendment of proposed use from housing to affordable housing led. Previous site reference 430. The original assessment concluded that whilst the site was adjoining the existing LDP settlement boundary this is by virtue of an existing adopted plan LDP allocation this is currently under review. Notwithstanding this the site would represent unacceptable intrusion in to the open countryside.
The LDP site in question has subsequently been granted planning permission for housing. This site will serve the future needs of residents in the area and it is not considered that additional land should be allocated in this location.”

In terms of the first paragraph, the assessment/conclusion implies and suggests that ‘Land at Ystradowen’ (4060)’ does not adjoin the existing LDP settlement boundary as the allocated site (‘Land off Sandy Lane, Ystradowen’) has not been built out – “by virtue of an existing adopted plan LDP allocation this is currently under review”. Detailed representations have been made and submitted previously at the Housing Trajectory (see Appendix B& C) that outlines that this is fundamentally incorrect. This is not repeated in full here, with just the main points re-iterated.

First and foremost, ‘Land at Ystradowen (4060)’ directly adjoins the existing LDP settlement boundary. Secondly, there has been a significant change in the position and circumstances. The allocated site (‘Land off Sandy Lane, Ystradowen’) is currently being “built out”, with work commencing on site (see photographic evidence in Appendix C)
- post the implementation of the planning permission ref. 2023/00948/FUL (post approval on 9th December 2024). Accordingly, the site no longer adjoins “the existing LDP settlement boundary … by virtue of an existing adopted plan LDP allocation … currently under review”. Given this, the ‘Land at Ystradowen’ site boundary therefore directly adjoins/is adjoining the LDP settlement boundary and the site promoted herein.

With regards to the second paragraph, the assessment/conclusion outlines that “The LDP site … will serve the future needs of residents in the area and it is not considered that additional land should be allocated in this location”. The arguments and case presented in Appendix B & C. There is a clear overreliance on ‘rolled forward’ sites / existing allocated sites. A total of 1,242no. units have been identified as additional housing allocations, of which 959no. are expected to be delivered on the rolled forward LDP sites. As such, these sites are to provide for a significant proportion of additional housing in the Plan period (specifically circa 77%). We believe that a greater level of growth is achievable and should be considered. Not least as there is an approximate shortfall of 2,189 homes being delivered, or 33% of the total housing supply identified for the current LDP (8,525no. dwellings). As such, it is considered that the unmet need deriving from the existing LDP is still present – indeed it has grown, and will continue to do so, not least when considered in conjunction with the projected population growth over the coming years to 2036, and the aspirations for growth in the Plan’s strategy. Accordingly, in order to secure the targeted level of housing, a greater level of provision for new allocations should be applied in order to meet the housing requirement. The provision of housing should be adjusted to rebalance the provision to include new allocations in lieu of rolled forward LDP sites in the housing supply. The “future needs of residents in the area” will therefore not be met/served by just this site, and it is considered that additional land should be allocated in this location.

Furthermore, to reinforce, illustrate, and evidence the point in specific reference to the site the subject to this representation (located in Ystradowen), reference is made to application ref. 2013/00856/OUT – ‘Land off Badgers Brook Rise, Ystradowen’. The Final Report of the application states that “Ystradowen is considered a sustainable settlement for further housing development” – i.e. “additional land should be allocated in this location”.

While the issues the Council have raised in their assessment of the site have been addressed and discussed within the representations made at the Preferred Strategy stage of the Plan (see Appendix B), a similar ‘scoring’ exercise has been undertaken as part evidence base for the Deposit Plan. As such, it is still pertinent to consider and respond to the Council’s assessment of the site as part of these representations. A comparison between the site assessments undertaken at both the Preferred Strategy stage and Deposit Plan stage can be seen below for reference:
BP18 Candidate Ste Assessment at Preferred Strategy Stage
As demonstrated above, there has been a positive change to the scoring attributed to the site (‘Land at Ystradowen’). The change is a positive change to the ‘Infrastructure Availability’ section changing from: ‘Grey’ (no score) to ‘Amber’. Infrastructure Availability is outlined as: “Existing or proposed services would be suitable subject to local improvements without impacting on development viability and/or delivery timescales” (see below):
The explanation for the scoring provided by the Vale sets out that “Sites will be assessed against the availability of water connections to the site, in addition to the method of foul sewage disposal from the site. Consultation shall be undertaken with DCWW to determine whether there is sufficient capacity to the wastewater treatments works, and how it links into DCWW’s Capital Investment Programme.
Where consultation indicates limited capacity, or the site is located away from a viable connection this may impact on the deliverability/viability of a site should this require significant connection costs or upgrades. Consequently, the Council shall require site proposers to undertake detailed site viability assessment to determine the impact that additional cost shall have on development cost and deliverability timescales.”

As set out above, this is a positive change. This is most likely derived from the allocated site (‘Land off Sandy Lane, Ystradowen’) currently being “built out”, with work commencing on site that would facilitate and improve the ‘Infrastructure Availability’. This re-iterates the point made previously re the incorrect assessment reached, and the ever changing position of this site – which will only improve given the neighbouring allocated site (‘Land off Sandy Lane, Ystradowen’) being “built out”.

Land West of Maendy Road, Aberthin (Site ID: 2299)

There are material similarities between ‘Land West of Maendy Road, Aberthin (Site ID: 2299)’ and the site the subject of these representations. It is therefore considered pertinent to assess and compare the suitability of ‘Land West of Maendy Road, Aberthin’. Not least as ‘Land at Ystradowen (Site ID: 4060)’ is for a “small-scale affordable housing led development in a minor rural settlement”, within “the ward of Cowbridge”.

The site ‘Land West of Maendy Road (Site ID: 2299)’ has been registered as an Affordable Housing Led Allocation candidate site for the RLDP, however from our review of the evidence base submitted as part of the Housing Trajectory consultation, there was no assessment and critique of this site at this stage. This raises questions regarding the “soundness” of this site, given it appears this sites acceptability and inclusion was pre-determined.

The site (‘Land West of Maendy Road’) has since had a detailed assessment and critique published, however concerns still remain regarding the “soundness” of the site which forms part of the intended housing land supply. The ‘Stage 2 Detailed Site Assessment’ summary undertaken for ‘Land West of Maendy Road’ has been extracted below:

“The site is proposed for a small-scale affordable housing led development in a minor rural settlement, which would accord in principle with the strategy. Aberthin itself has limited services and facilities, but is within reasonable walking distance of primary and secondary school provision with the wider range of services and facilities in Cowbridge just over 2000m away. The settlement is also served by public transport, although this is relatively infrequent.
The 2023 LHMA indicated that the ward of Cowbridge has a need for 230 additional affordable units over the next 15 years and this site could make an important contribution in meeting that.”

As mentioned previously, there are material similarities between ‘Land West of Maendy Road, Aberthin (Site ID: 2299)’ and ‘Land at Ystradowen (Site ID: 4060)’ (the subject of these representations). Firstly ‘Land at Ystradowen (Site ID: 4060)’ is also for a “small-scale affordable housing led development”, that is “in a minor rural settlement” (Ystradowen). Accordingly, it should follow that as ‘Land West of Maendy Road, Aberthin (Site ID: 2299)’ “would accord in principle with the strategy”, ‘Land at Ystradowen (Site ID: 4060)’ would also “accord in principle with the strategy”.

Furthermore, there is no material difference between the following assessment of Aberthin and Ystradowen:

“Aberthin itself has limited services and facilities, but is within reasonable walking distance of primary and secondary school provision with the wider range of services and facilities in Cowbridge just over 2000m away. The settlement is also served by public transport, although this is relatively infrequent.”

There is no material difference between ‘Land West of Maendy Road’ and ‘Land at Ystradowen’ in sustainability terms.

As set out in our representations to the Preferred Strategy, we reviewed the key services in proximity to the site. The following services were identified as part of that review:

• In terms of public transport, there are two bus stops located approximately 0.2 miles (4-minute walk) from the site (‘Land West of Maendy Road’), with the 321 providing services between Llantwit Major and Talbot Green;

• In terms of public transport, there are two bus stops located approximately 400m (7-minute walk) from the site (‘Ty Mawr Close’), with the ‘321 Nat Group Service’ providing services between Llantwit Major and Talbot Green. The 321 service is the same bus service that serves ‘Land West of Maendy Road’ / Aberthin;

• The site is also located 0.2 miles (4-minute walk) from The Farmers Arms Pub and 0.2 miles (4-minute walk) from The Hare and Hounds Inn; and

• The site is located 0.2 miles (5-minute walk) from Aberthin Village Hall.

Given the above, “The settlement (Ystradowen) is also served by public transport”.
Furthermore, Ystradowen is located only 2.7 miles from Cowbridge (9-minute bus journey). The “primary and secondary school provision with the wider range of services and facilities in Cowbridge” mentioned in relation to Aberthin are therefore also in close proximity to Ystradowen.

Given the above, any candidate site at ’Land at Ystradowen’ (the subject of these representations – Site ID: 430 / 4060) is no less sustainable than the site at Aberthin (Site ID: 2299).

Not least as the following additional key services are located within Ystradowen and therefore in close proximity to the promoted site:

• The site is also located 300m (3-minute walk) and 600m (10-minute walk) from Sports Pitches/Playing Fields such as ‘Ystradowen Children’s Park’, and the 3/4G Sports Pitch at ‘Ystradowen Petanque Club’; and
• Furthermore, the site is located 480m (7-minute walk) from the ‘Murco – Tudor Garage’ which can provide basic goods to meet day-today needs such as bread, butter, milk etc.

Furthermore it is important to note that the above scoring criteria is very limiting, and does not take into account the important role and proximity of settlements in a wider context. For example, it does not take into account the important role and proximity of the Principal Settlement and Strategic Growth Area (as defined in the RCTCBC LDP) of Talbot Green / Pontyclun / Llantrisant which is 2.8 miles to the north (14-minute bus journey). Ystradowen would also naturally align, and function, in association with this Principal Settlement and Strategic Growth Area (of Talbot Green / Pontyclun / Llantrisant) – see Appendix B for full details.

In addition, as set out within the representations made in relation to the House Trajectory (Appendix C), the following extracts have been taken from the Officer’s Reports associated with the applications for the site that directly adjoins the western boundary of the promoted site 430 - ‘Land off Sandy Lane, Ystradowen’ (Housing Allocation 48). An aerial view extract is outlined below to give spatial context:
As set out above, it is important to note that the Final Report of application ref. 2013/00856/OUT states that “Ystradowen is considered a sustainable settlement for further housing development”, due to “the sustainable nature of the settlement”. Furthermore, the Final Report of app ref. 2023/00948/FUL states:

• “Notwithstanding this, the site is located in close proximity to local services and there is a bus stop located nearby. Whilst the comments relating to the reliance and frequency of the bus services have been considered, there still remains a bus service in the area”; and
• “Firstly, as aforementioned, many neighbouring comments refer to the site as unsustainable and have commented on the suitability of public transport and cycle routes etc. This has been addressed above.”

The above clearly evidences that the location has previously been endorsed as, and is currently still found to be, sustainable.

Accordingly, it can be considered therefore that if the proposed allocated site ‘Land West of Maendy Road, Aberthin (Site ID: 2299)’ is considered sustainable and by association suitable to be an Affordable Housing Led Allocation, ‘Land at Ystradowen (Site ID: 430 / 4060)’ is equally suitable to be an Affordable Housing Led Allocation.

The second section/paragraph of the assessment states:

“The 2023 LHMA indicated that the ward of Cowbridge has a need for 230 additional affordable units over the next 15 years and this site could make an important contribution in meeting that.”
‘Land at Ystradowen (Site ID: 4060)’ is also located within “the ward of Cowbridge”. As per the above and outlined by the Authority, there is “a need for 230 additional affordable units over the next 15 years”. It is clear therefore that there is a need for additional affordable units in this ward, and this site would therefore also help to alleviate this need.

This position is a direct contradiction of course of the assessment/conclusion for ‘Land at Ystradowen (Site ID: 4060)’ which stated “it is not considered that additional land should be allocated in this location”. It is clear from the above however that “additional land should be allocated in this location” to satisfy this “need for 230 additional affordable units over the next 15 years” – which ‘Land at Ystradowen (Site ID: 4060)’ can do. This is not least the case given the detailed arguments, case and representations presented and evidenced previously above and in Appendix B & C.
To briefly reiterate there is a clear overreliance on ‘rolled forward’ sites / existing allocated sites which has resulted in the unmet need deriving from the existing LDP being still present. A greater level of provision for new allocations should therefore be applied in order to meet the housing requirement. The provision of housing should be adjusted to rebalance the provision to include new allocations in lieu of rolled forward LDP sites in the housing supply, so these can “make an important contribution in meeting” the “need for 230 additional affordable units over the next 15 years” in “the ward of Cowbridge” – which ‘Land at Ystradowen (Site ID: 4060)’ can do.

As set out within the representations made in relation to the housing trajectory (see Appendix C), a further key consideration to note and one which does differentiate between the relative merits of the ‘Land at Maendy Road, Aberthin’ and ‘Land at Ystradowen’ is that the LDP Proposals Map demonstrates that ‘Land West of Maendy Road’ is within a Special Landscape Area - see below:
Vale of Glamorgan Proposals Map (Land West of Maendy Road outlined in red
Under Policy MG17 ‘Special Landscape Areas’ it is considered that development in SLA could pose an “unacceptable harm to the important landscape of the area”. Accordingly, this development and proposed allocation could therefore cause “unacceptable harm to the important landscape of the area”.

‘Land at Ystradowen’ by contrast does not sit within a SLA (see below). This site would therefore not pose any potential concern in this respect as it would ultimately not cause any “unacceptable harm to the important landscape of the area”.
Vale of Glamorgan Proposals Map (Land at Ystradowen in red)
It is noted that the detailed assessment scores the site ‘amber’ in respect to Special Landscape Area (refer to / see later section for full details), with the assessment methodology setting out that “the site is located within a Special Landscape Area/The Glamorgan Heritage Coast and the development may result in little or no change in character and little or no significant effect on landscape character and visual amenity.”
A detailed assessment of the impact upon the SLA in respect to the development of ‘Land West of Maendy Road, Aberthin’ should therefore be, and will need to be, undertaken as part of any planning application. If it is found that the site causes “unacceptable harm to the important landscape of the area”, this will lead to this proposed allocation being at risk of not being delivered. This will be as a result of its impacts and acceptability at the planning application stage that the landscape and visual impact of development of the site is unacceptable. As such, these proposed affordable units are at a potential considerable risk of being lost and not satisfying the “need for 230 additional affordable units over the next 15 years” in “the ward of Cowbridge” – which ‘Land at Ystradowen (Site ID: 4060)’ can do as it is not located in an SLA.

In addition the draft housing trajectory set out that “there is a need for small scale affordable housing led development (minimum 50% affordable) to respond to local affordable needs and help sustain services and facilities within these rural communities”. There is a clear possibility therefore that this proposed allocation is not delivered (as it is located in a SLA), and so a “small scale affordable housing led development” which is needed to “respond to local affordable needs and help sustain services and facilities within these rural communities” is not provided for. This is clearly an issue. Given however ‘Land at Ystradowen’ does not sit within a SLA – and so not pose any potential concern or cause any “unacceptable harm to the important landscape of the area” – the allocation of this site would be more suitable and “safer” - as there would be no concerns over this proposed allocation being removed and/or not being delivered in this respect (as it is not located in a SLA). This would ensure that affordable units, where “there is a need for small scale affordable housing led development (minimum 50% affordable) to respond to local affordable needs and help sustain services and facilities within these rural communities”, are provided for, and the need for 230 additional affordable units over the next 15 years” in “the ward of Cowbridge” would be satisfied.

As mentioned previously, a detailed assessment and critique has now been undertaken of ‘Land West of Maendy Road, Aberthin (Site ID: 2299)’ as part evidence base for the Deposit Plan using the similar ‘scoring’ exercise. As such, it is again pertinent to consider and respond to the Council’s ‘scoring’ exercise assessment of the site ‘Land West of Maendy Road, Aberthin (Site ID: 2299)’ as part of these representations.

The ‘Summary of Assessment of New Candidate Sites’ table can be seen overleaf for reference:
BP18A Candidate Site Assessment at Deposit Plan Stage
A comparison between the site assessments undertaken for both ‘Land West of Maendy Road, Aberthin (Site ID: 2299)’ (on the left), and ‘Land at Ystradowen (Site ID: 4060)’ (on the right) has been undertaken, and can be seen below for reference:

Having undertaken a review of the scoring for both ‘Land West of Maendy Road, Aberthin (Site ID: 2299)’ and ‘Land at Ystradowen (Site ID: 4060)’, it is clear that ‘Land at Ystradowen (Site ID: 4060)’ scores higher/more positively (i.e. green) than ‘Land West of Maendy Road, Aberthin (Site ID: 2299)’:

• ‘Land at Ystradowen (Site ID: 4060)’: 17/33 criteria are scored green = 52%

• ‘Land West of Maendy Road, Aberthin (Site ID: 2299)’: 12/34 criteria are scored green = 36%

It is clear therefore given the above that ‘Land at Ystradowen (Site ID: 4060)’ is a better site, and should be allocated accordingly.

One key example to note is how the criterion ‘Access to Services and Facilities’ has been scored. For ‘Land at Ystradowen (Site ID: 4060)’ this has been scored green, yet for ‘Land West of Maendy Road, Aberthin (Site ID: 2299)’, this has been scored red. Given this, this corroborates the position outlined previously above that, if the proposed allocated site ‘Land West of Maendy Road, Aberthin (Site ID: 2299)’ is considered sustainable and by association suitable to be an Affordable Housing Led Allocation, ‘Land at Ystradowen (Site ID: 430 / 4060)’ is equally as sustainable – in fact considered more suitable (given its higher scoring in this respect).

Furthermore, we question the “soundness” of the assessment of ‘Land West of Maendy Road, Aberthin (Site ID: 2299)’, given that 7/34 (21%) of the criteria do not appears to have not been assessed – i.e. 7/34 (21%) of the criteria are scored grey. This raises questions regarding the “soundness” of this site, given it appears this sites acceptability and inclusion was pre-determined.

It is clear therefore that if ‘Land West of Maendy Road, Aberthin (Site ID: 2299)’ has been deemed acceptable for allocation, yet ‘Land at Ystradowen (Site ID: 4060)’ scores higher/more positively (i.e. green) than this site, ‘Land at Ystradowen (Site ID: 4060)’ should also be deemed acceptable and be allocated. Not least as the site is “proposed for a small-scale affordable housing led development in a minor rural settlement … would accord in principle with the strategy”, and “could make an important contribution in meeting “a “need for 230 additional affordable units over the next 15 years” in “the ward of Cowbridge”.

Summary and Conclusion

To re-iterate, and to summarise the case made and set out, these representations seek to object to the Deposit Plan published as part of the consultation.

In terms of SECTION 4, and a response to the Candidate Site Assessment at Deposit Plan Stage, the following key points have been made:

• The Council’s ‘Stage 2 Detailed Site Assessment’ justification for ‘Land at Ystradowen (Site ID: 4060)’ is fundamentally incorrect;

• Given the material positive similarities between ‘Land at Ystradowen (Site ID: 4060)’ and ‘Land West of Maendy Road, Aberthin (Site ID: 2299)’, which has been deemed acceptable and allocated, ‘Land at Ystradowen (Site ID: 4060)’ should also be deemed acceptable and allocated accordingly;

• ‘Land at Ystradowen (Site ID: 4060)’ would help to alleviate and satisfy “a need for 230 additional affordable units over the next 15 years” within “the ward of Cowbridge”; and
• ‘Land at Ystradowen (Site ID: 4060)’ scores higher/more positively (i.e. green) than ‘Land West of Maendy Road, Aberthin (Site ID: 2299)’, and so should also be deemed acceptable and be allocated;

Ultimately, ‘Land at Ystradowen (Site ID: 4060)’ is “proposed for a small-scale affordable housing led development in a minor rural settlement”, and as such “would accord in principle with the strategy”. It would therefore “make an important contribution in meeting“ the “need for 230 additional affordable units over the next 15 years” in “the ward of Cowbridge”.

We would therefore object the Council’s assessment that the site is not considered suitable for development.

Summary of These Representations

In short, and to summarise the case made and set out, these representations seek to object to the Housing Trajectory published as part of the consultation on the Draft Housing Trajectory For Housing Stakeholder Group (October 2025) which underpins the Plan and the delivery / realisation of its underlying strategy.

Detailed submissions and objections are raised below in respect to the trajectory information published regarding the soundness and robustness of this information (and it’s consultation), which we do not consider are adequate, robust, or sound to deliver the Plans aims and objectives.

Preface

This Submission sets out the detailed case in support of these representations. The representations are structured as follows:

1. Procedural Consultation Matters;
2. Timing Assumptions underpinning the Trajectory;
3. Housing Delivery Rate Assumptions;;
4. Status & Standing of Sites included in the Trajectory;
5. Key Sites;
6. St Athan Train Station;
7. Geographic distribution of the ‘new’ sites / provision;
8. Detailed comments in respect to ‘new’ sites;
9. Credentials of this site subject to this submission; and
10. Conclusions Procedural Consultation Matters
Firstly, we do not consider that the consultation on the Housing Trajectory information has been procedurally undertaken appropriately or suitably.

Only 14 days have been afforded to parties to make representations on the information provided. This is despite new sites being introduced (at this late stage) i.e. Land South of Clive Road (identified in Table 4), as well as a number of affordable housing-led housing sites being introduced (i.e. those outlined in Table 5). This does not provide an adequate process or timescale for objectors to scrutinise the published content, and to make comments on sites which have been presented for the first time at a late stage in the process.

As part of these representations, we will be making brief comment on the sites which have not been previously consulted upon, namely:
Other Housing Allocations
• Land south of Clive Road, St Athan;

Affordable Housing Led Sites
• Land at Heol Fain, Wick;
• Land west of Maendy Road, Aberthin;
• Land Noth of West Winds Business Park, Fferm Goch; and
• Land to the east of Coliwinston, Colwinston.

It is considered necessary to comment on these sites, given that they form an important and critical part of the housing trajectory, and by association in the Council and Plan reaching their targets. Moreover, these sites have not been consulted on previously. Accordingly we consider it necessary to pass comment on these in order to ensure that the consultation is fair and robust.

As well as limited time given to comment on the information contained within the Housing Trajectory, the LPA have failed to set up a Housing Stakeholder group to agree and discuss the trajectory information and data – with the cover email to the consultation (dated 3rd October 2025) stating “it is considered that it would be the best use of stakeholder time to conduct this engagement via email, particularly as many of the forecasts have been developed in consultation with site promoters including developers and their agents”.

We submit that the stakeholder consultation has not been a transparent nor robust consultation process, given that the Development Plans Manual states at Para 5.66 “A housing trajectory must be prepared to support the Deposit Plan. In order to generate a housing trajectory and associated phasing tables it will be necessary for LPAs to engage with stakeholders through a Housing Stakeholder Group. This will ensure that the timing and phasing of sites is robust and based on up to date information”. Given that this has not taken place, we would raise fundamental concerns that the consultation of the trajectory has not adequately taken place as per the relevant guidance. Afterall, the guidance stresses that a Group should be formed as a necessity. Accordingly, there has not been an adequate process and opportunity to review and comment on the information published, including in respect to the other sites have been introduced at this late stage.

Timing Assumptions underpinning the Trajectory

The assumed and factored in timescales of the various stages of bringing forward sites i.e. the pre-application stage, the planning application process, and the discharge of condition process outlined in the trajectory are considered to be fundamentally inaccurate, and result in a distorted position of the delivery of housing sites over the RLDP Plan period. The assumptions are far too ambitious, and without evidence / are not comparable with the timescales being incurred in processing such stages at the Development Management stage(s).

Specifically, we raise objection to the following timescales which are considered to be extremely ambitious and unrealistic:

• “Time period of pre-application discussions/PAC consultation” = 4 months
• “Time between submission of planning application and determination” = 6 months
• “Time taken from planning consent to the discharge of relevant conditions to enable site construction” = 4 months

In our experience, having submitted a significant number of major and other applications for housing and other forms of development in the last 1-2 years to the Council (and elsewhere in Wales and England), it is extremely unlikely that major applications can be submitted, and planning permissions granted, within the timeframes assumed by the trajectory. A wide range of stakeholders are also involved in the determination of major planning applications, which often adds to the delays associated with the determination of such applications. We would therefore consider that a time period of “6 months” given to all major applications in the housing trajectory is not feasible, and distorts the trajectory timescales for the remaining Plan period.

The assumptions in the trajectory are also solely based on expected timescales for the processing of formal submissions made to the Council, and do not factor in the timescales associated with, and needed for, the preparation of the material for submission (i.e. pre-application enquiry submissions / planning application / discharge of condition details etc). When factored in these will elongate the timescales for bringing forward schemes considerably.

Moreover, it is common practice for larger housing sites and major applications to have a range of pre-commencement conditions attached to a permission once granted. Again, we would raise concerns with the timescales indicated in the trajectory related to this part of the planning process. It is highly unusual and questionable that any technical work required by these conditions (usually relating to drainage and highways matters) would be instructed, completed and submitted within 2 months, and for these to then be signed off / approved in a further 2 months. There are also other technical matters and necessary approvals falling outside of, and over and above, the planning system, such as SAB, s.106, s.38 and s.278 agreements, timescales for which have not been accounted for – and all of which are rarely completed within “4 months” as indicated.

It is therefore highly doubtful that the timescales legislated for in the trajectory for the various stages pre-construction are achievable – with no information about these proposed timescales outlined within the supporting text of the Housing Trajectory. We would therefore raise considerable concerns and objections to these as they stand without full evidence to fully show how these have been calculated, and without there being considerable (and necessary) adjustment to the timescales indicated and factored in.

We would therefore object to the timescales indicted in the ‘Timing and Phasing of Sites’ table, given that the delivery start dates will be pushed back further into the Plan period. Accordingly, and as a result, the Plan is at risk of not delivering the level of housing expected based on the sites allocated, at least as swiftly as is set out in the trajectory.

Housing Delivery Rate Assumptions

We would also raise considerable doubt over the proposed delivery of the sites identified in the Housing Trajectory - which we do not consider are robust or reasonable.

The development trajectory bar chart set out in the consultation material (extracted below) anticipates and legislates for a number of critical events and circumstances – all of which are considered to be unrobust and unsound.
Extract of Housing Trajectory Graph (annotated by GJP – red dotted line)

Firstly, a large ‘spike’ (material increase) in housing delivery is factored in to take place in 2027 – 2028. This is a marked and pronounced step change in the rate of delivery, and envisages / relies on a significantly higher rate of delivery than previous years in The Vale of Glamorgan (2021 through 2025 - as depicted by the green columns). This is considered extremely unlikely to materialise, not least given prevailing market circumstances, past rates of delivery on the ground, and also in light of levels achieved across Wales and the UK in general.

The published trajectory shows that the average level of completions in The Vale of Glamorgan from 2021 - 2025 has been approx. 400 - 500 units. However, the chart shows that from 2027 – 2028, completions are expected to rise to approx. 1,000 units per year. The expected delivery levels in the trajectory therefore show and assume a doubling in delivery rates and unit numbers (an increase of approx. 100%relative to past rates). There is no clear evidence as to how this level of completions can be achieved let alone guaranteed. This is the case in particular given that the forthcoming years (2025-2027) are expected to see performance (yield) drop significantly (delivery rates in 2025 – 2026 and 2026 – 2027). The chart shows only approx. 200 units being delivered over these years. It is therefore unclear how completion rates are expected to rise so quickly (from 200 in 2025-26 to 1000 in 2027-28), and by such a significant amount. The assumptions in the trajectory are wholly unrobust in our view.
The anticipated delivery of housing also fails to be consistent within and across the Plan period. It is unclear as to why completions rates aren’t spread out more evenly throughout the Plan period - to ensure a robust and most realistic housing trajectory until 2036. By comparison to the marked increase in the rate of delivery between and over the period 2027 to 2031, there is then a marked fall-off or drop in delivery towards and by the end of the Plan period. Indeed, in the final year, the level of completions are expected to be lower than the period 2021-2015.

To summarise, we consider the defined position to be wholly manufactured and unreflective of the past completion rates, as well as the recently published completion rates provided by Welsh Government recently in August 2025. In the Welsh Government Statistics Document ‘’New House Building: April 2024 to March 2025’, information on the number of new dwellings started is provided, where building has commenced and those completed for April 2024 to March 2025. Figure 1 provides a graph showing starts in the last 10 years, and it is clear that there has been a general decline in the number of new dwellings started and completed.
Description of Figure 1:.‘New House Building: April 2024 to March 2025’
In 2024-25, 4,631 new dwellings were completed, 3% fewer than in the previous year. This was the second lowest number on record, with the lowest number recorded in 2021-22, a year heavily affected by the coronavirus (COVID-19) pandemic (in 2021-22, 4,616 new dwellings were completed). The New Housing Pipeline Report Quarter 2, 2025 Report (September, 2025) published by the HBF evidenced that the number of residential units approved in the UK fell by 6% during the second quarter of 2025, continuing the decline of approval during the first three months of the year. Wales saw one of the largest declines in the UK in approvals with a decline of 29%.

Further, the HBF document ‘Increasing Housing Supply in Wales’ (4th September 2025) clearly shows that The Vale of Glamorgan has not met the housing delivery requirements in recent years in 2023 – 2024 – along with every other authority in Wales (except Newport). Accordingly, this further adds to the argument that historically The Vale (and most other authorities) have underprovided. This adds considerable uncertainty on the assumed transformation in yield and delivery as built into the trajectory.
Graph: Housing Delivery as a proportion of annual housing requirement in Wales per Authority

The Home Building Sector Skills Plan (Aug 2025) published by the HBF also identified the following issues with the workforce to bring forward built development in Wales:

• “A shortfall in numbers entering roles from the education system;
• An ageing workforce: 25% of the home building workforce is aged over 50, meaning the sector is facing an impending retirement cliff edge;
• Challenges attracting a wider talent pipeline into the sector;
• A lack of understanding of critical future skills needed, and direction from the Future Homes Standard; and
• Output within the sector fluctuating with demand and economic pressures, leading to additional pressures in recruitment and training”.

It is not considered that in the next 1-2 years that any of these issues can or will be substantially corrected – at least sufficiently so to allow for, and enable, the planned delivery rates of new housing completions to be as high as < > 1,000 homes in one year (and for four consecutive years at that).

We would therefore object to the proposed numbers of completion expected during the Plan period, given that there are a number of issues with delivering housing in Wales and given past completions rates for The Vale of Glamorgan. Again, this results in the Plan being at risk of not delivering the level of housing expected based on the sites allocated.

Status & Standing of Sites included in the Trajectory

The proposed land supply within the housing trajectory includes provision for ‘rolled forward’ LDP sites, which contribute to the total of ‘Proposed Additional Housing Allocations’ forming part of the housing supply. Specifically, a total of 1,242no. units have been identified as additional housing allocations, of which 959no. are expected to be delivered on the rolled forward LDP sites. As such, these sites are to provide for a significant proportion of additional housing in the Plan period (specifically circa 77%).

The Development Plans Manual (DPM) sets out that allocations rolled forward from a previous plan will require careful justification for inclusion in a revised plan. The DPM outlines that “there will need to be a substantial change in circumstances to demonstrate sites can be delivered and justify being included again. Clear evidence will be required that such sites can be delivered.” The below table included in the consultation document provides a breakdown of the rolled forward LDP sites, and in particular, sets out the status of each site:
Table 6: Existing LDP allocations to be carried forward
The above table evidences that the current LDP has under delivered in regard to its targeted unit number of the Plan period, given that these sites did not yield any housing over the current plan period. This is further exacerbated by the Land Bank sites that have also not delivered any housing across the existing LDP period, amounting to 1,860no units. Accordingly, when considering the non-delivery of both rolled forward LDP sites and Land Bank sites, this amounts to an approximate shortfall of 2,189 homes being delivered, or 33% of the total housing supply identified for the current LDP (8,525no. dwellings).

It is therefore considered that, as a minimum, the units carried over from the LDP (without planning permission) should be a surplus to the housing supply proposed for the RLDP, as opposed to being relied on to deliver the housing need over the Plan period. This is particularly the case for the two sites (Land to the west of Pencoedtre Lane, and Land between Northern Access Road and Eglwys Brewis Road) which do not currently have any active planning application submitted for their development. These sites total an amount of 370no. units to be delivered in the Plan period, which represents more than a third of the additional housing allocations to make up the housing supply.

As such, it is considered that the unmet need deriving from the existing LDP is still present – indeed it has grown, and will continue to do so, not least when considered in conjunction with the projected population growth over the coming years to 2036, and the aspirations for growth in the Plan’s strategy.

Accordingly, in order to secure the targeted level of housing, a greater level of provision for new allocations should be applied in order to meet the housing requirement. This would bring about better certainty that the housing requirement is met by the housing supply over the Plan period, not least given that the current Plan failed in this respect. Without a re-apportioning of the housing supply, it is considered that the Plan would heavily rely on the contingency (i.e. rolled forward LDP sites) coming forward in the Plan period, yet there is uncertainty that these will yield in full over the new Plan period. This raises issues of ‘’soundness’’, and risks rendering the Plan unrobust.

On this basis, we would object to the Plan if the provision of housing is not adjusted to rebalance the provision to include new allocations in lieu of rolled forward LDP sites in the housing supply.
Key Sites

As set out in previous representations at Preferred Strategy stage, it is considered that the housing supply relies heavily on the delivery of the ‘key sites’ to deliver housing (and meet need) over the Plan period. The total number of housing units attributed to key sites amounts to 2,278, which equates to over 25% of the total provision in the Plan period.

As detailed above, we consider there to be concerns regarding the proposed ‘Timing and Phasing of Sites’ table included in the Housing Trajectory which we consider are not reflective or accurate and will therefore have the effect of delivery start dates being much later into the Plan period than anticipated. The result of this will be that the Plan will be at risk of not delivery the level of housing expected and needed. Moreover, the Housing Trajectory Graph presents an overly ambitious level of housing completions over the Plan period - which the Council consider will be markedly higher than the average levels experienced in the last five years. Again, for the reasons set out above, we consider that these rates of expected completions to have no evidence supporting them, and to be unachievable and unsound.

Insofar as to the removal of the previously proposed site ‘Land at North East Barry’, this site was expected to deliver 900no. units in the Plan period. Following its omission from the housing supply, other sites have been identified, which comprises the inclusion of a new key site (Land at North West Barry), 3no. non-strategic sites, and also affordable housing-led allocations. In terms of the quantum of development attributed to these new sites, this amounts to 659no. dwellings. This is some 250 units less than the 900no. homes that was previously attributed to ‘Land at North East Barry’. Whilst it is appreciated that the number of homes forming part of the existing supply (completions, units with planning permission etc.) have increased since Preferred Strategy stage, there will be a net loss in market housing provision and delivery.

This position is made worse and compounded as a result of accounting for the affordable-led sites in making up the housing supply.

As set out within the Preferred Strategy, these sites are expected to deliver at least 51% affordable housing. These units are not open market units, and will not / cannot contribute to the supply of such housing. These units will contribute to the provision of affordable housing, and will go some way to meeting the acute need for such housing (albeit will not eradicate / address in full the well known and accepted considerable requirement). Accordingly it is considered that these sites should be in addition to the housing supply, as opposed to forming part of the provision. In turn, there would need to be an increase in allocations for non-strategic sites, to ensure that there is sufficient market housing delivery over the Plan period.

Were such changes to be made and introduced, this would achieve and assist realise a more robust and sound housing supply, which will ensure that the identified housing need is met / addressed over the Plan period. Without these changes it is considered that the housing supply is not sufficient, and inevitably, housing need will not be met within the Plan.

St Athan Train Station

As set out in the Preferred Strategy (para A3.29), the strategy seeks to focus development around key sustainable transport nodes. The strategy outlined that a feasibility study for a station in St Athan had been undertaken, which identifies that a new station could be located in St Athan, subject to further investigation work. Accordingly, in line with the spatial strategy adopted for the RLDP (i.e. focus development around sustainable transport nodes), St Athan was identified as a ‘Strategic Opportunity Area’ to accommodate strategic growth – through the proposed allocation of two key sites : ‘Land at Church Farm’ and ‘Land West of St Athan’. These sites have been identified to deliver 532no. and 600no. units respectively in the Plan period. These are separate to, and are in addition to, the 51no. units that have now been attributed to the site ‘Land South of Clive Road’ in St Athan. Accordingly, in total, the Housing Trajectory makes a provision for a total of 1,183no. homes to be delivered in St Athan over the Plan period.

It is now the case that, subsequent to the publication of the Preferred Strategy, the proposed railway station at St Athan is not in the first phase of delivery for new stations in South Wales. The focus in the first phase of such improvements across the region is towards improving connectivity in east Cardiff, Newport, and Magor. Accordingly, it is very unlikely that any new train station will be delivered in St Athan over the Plan period, which significantly questions the suitability and acceptability of the proposed allocations set out above.

The strategy to allocate new housing growth is predicated on focusing residential development around sustainable transport nodes, and given that St Athan will be without any railway station in the Plan period, it is not considered that these sites align with the strategy of the RLDP. Accordingly, the wider Housing Trajectory is considered to be unsound, given that a total of 1,183no. homes are expected to be delivered in St Athan within the Plan period.

It is considered that there has been an overprovision for housing growth in St Athan generally, and this issue is now further exacerbated by the lack of any forthcoming rail provision. Given this, to add a further site for housing in this location over and above the original provision is considered to be unsound. As set out above, the justification to allocate sites at St Athan has relied heavily on the railway station being delivered in the Plan period, and as such, there are serious questions marks associated with the acceptability of the proposed allocated sites - given their incompatibility with the core strategy of the RLDP.

We therefore consider the Trajectory to be both unrobust and unsound, and therefore, we object to the Trajectory in its current form accordingly.

Geographic distribution of the ‘new’ sites / provision

As a general and overarching comment in respect to the additional sites now included within the Plan, and forming part of the trajectory, (and a matter expanded upon when critiquing each of these sites in the next section to this submission), it is clear and evident that these additional sites have been positioned to settlements that have already, and recently, been attributed significant growth in the preceding Plan and plan period.

Significant allocations (which have also contributed to significant levels of affordable housing) have been realised and built out in locations such as Wick and Colwinston). Notwithstanding this, two of the additional sites are now proposed for these recently expanded settlements. Given that the purpose of the affordable housing led allocations is to meet unmet affordable housing need, it is questioned why such new allocations are attributed to settlements that have already seen open market and affordable housing provision, as compared to other comparable settlements that have not received any growth whatsoever over a considerable period of time.

It is considered accordingly that the geographic positioning of these allocations is at odds with their underlying purpose - to meet unmet affordable housing need in communities that have seen no provision.
Detailed Comments in respect to ‘new’ sites

Other Housing Allocations

Land south of Clive Road, St Athan

A summary of the Candidate Sites Assessment at Preferred Strategy Stage has been extracted below for ease:
As set out at the outset of these representations, and whilst we note the findings of the Candidate Sites Assessment at Preferred Strategy Stage (i.e. Suitable for further consideration), we do not consider that the consultation on this site has been undertaken procedurally appropriately or suitably. We therefore consider the consultation on this site is “unrobust” and “unsound”.
As set out previously, the strategy seeks to focus development around key sustainable transport nodes. The strategy outlined that a feasibility study for a station in St Athan had been undertaken, which identifies that a new station could be located in St Athan, subject to further investigation work. It is now the case that, subsequent to the publication of the Preferred Strategy, the proposed railway station at St Athan is not in the first phase of delivery for new stations in South Wales, where the focus is towards improving connectivity in east Cardiff, Newport, and Magor. Accordingly, it is very unlikely that any new train station will be delivered in St Athan over the Plan period, which significantly questions the suitability and acceptability of the proposed allocations set out above.

It is considered that there has been an overprovision for housing growth in St Athan generally, and this issue is now further exacerbated by the lack of any forthcoming rail provision, and as such, to add a further site for housing over and above the original provision is considered to be unsound. As set out above, the justification to allocate sites at St Athan has relied heavily on the railway station being delivered in the Plan period, and as such, there are serious questions marks associated with the acceptability of the proposed allocated sites – given their incompatibility with the core strategy of the RLDP.

Affordable Housing Led Allocations

Land at Heol Fain, Wick
A summary of the Candidate Sites Assessment at Preferred Strategy Stage has been extracted below for ease:
Candidate Site Stage 2 Assessment (Site Ref. 404)
The findings of the Candidate Site Assessment for this site are noted. We are assuming the reason this site is proposed to be allocated is a product of the site promoters/developers heading the findings stated below, and changing the form of development to be in accord with this:
“A market housing led scheme would not be acceptable, but the site could be reconsidered as a small scale affordable housing led development subject to need and viability at a maximum of 50 dwellings. In accordance with the Settlement Appraisal Review, it is considered that Wick could potentially accommodate limited affordable housing led growth.”

Whilst no clearly evident deficiency exists in respect to the site, it is known that Wick has been subject to significant growth and expansion in recent years – not least by virtue of significant housing allocations in the settlement as part of previous plans.

To evidence this, 35% of the 124 units approved on the ‘Rectory Field, St Brides Road’ site (i.e. circa 43 units as per site allocation ref. MG(47) and PP ref. 2014/01424/FUL) were approved as Affordable Housing units. This makes a substantial provision of such Affordable Housing units (and housing generally) in the settlement in recent years.

Other similarly sized and comparable settlements and locations have not by contrast been subject to any growth for some considerable time, and accordingly would warrant and benefit from provision as part of this new replacement plan.

Notwithstanding the location of such provision, and as set out in detail at the outset of these representations, National Planning Policy advocates the high and acute need for affordable housing, whilst recent analysis evidences that there is a housing emergency. These circumstances - coupled with the shortcomings identified and set out earlier in these submissions in respect to the adequacy of provision within the plan (rolled forward sites / inadequate provision etc) – means that notwithstanding any potential allocation at Wick, further provision ought to be made in comparable (previously unprovided for) locations, such as Ystradowen.
Land West of Maendy Road, Aberthin

‘Land West of Maendy Road’ has been registered as an Affordable Housing Led Allocation candidate site for the RLDP, however as far as we know from our review, there is no assessment and critique of this site. This site has not been included in the ‘Candidate Assessment at Preferred Strategy Stage’ (October 2023). As such, with an absence of publicly available information, it is not clear how the Council has judged this site against the criteria. This raises questions accordingly in respect to the “soundness” of a site which forms part of the intended housing land supply, and by association the trajectory. Without this, and without being consulted on (as others have been prior to this) we question whether this allocation is “sound” (i.e. its allocation is considered to be “unsound”).

Despite the absence of site-specific assessment criteria, as the RLDP preferred strategy states a key objective guiding site selection is that the Plan will “provide for vital and vibrant rural communities whilst protecting the countryside through the delivery of growth in sustainable locations related to the settlement hierarchy alongside the provision of supporting infrastructure” (Objective 7 ‘Fostering Diverse Vibrant and Connected Communities’), it is reasonable to assume that the Council considers ‘Land West of Maendy Road’ to be a ‘sustainable’ location.

Given this, we have reviewed the key services in proximity to the site. The following services were identified:

• In terms of public transport, there are two bus stops located approximately 0.2 miles (4-minute walk) from the site (‘Land West of Maendy Road’), with the 321 providing services between Llantwit Major and Talbot Green.

• The site is also located 0.2 miles (4-minute walk) from The Farmers Arms Pub and 0.2 miles (4-minute walk) from The Hare and Hounds Inn.

• The site is located 0.2 miles (5-minute walk) from Aberthin Village Hall.

Aberthin is in close proximity (1.2 miles/14-minute walk) to the key settlement of Cowbridge - which is identified as a sustainable location, and is ranked 4th place for services and facilities within the Vale of Glamorgan. The following key services are found in Cowbridge, and are therefore in close proximity to ‘Land West of Maendy Road’:

• Cowbridge Comprehensive Schools;
• Cowbridge Health Centre; and
• Cowbridge Town Centre for various Retail Services.

Considering this, there is no material difference between ‘Land West of Maendy Road’ and ‘Land at Ystradowen’ in sustainability terms. Given that Ystradowen is located only 2.7 miles from Cowbridge (9- minute bus journey), the candidate site at ’Land at Ystradowen’ is no less sustainable than the site at Aberthin. The following key services are within Ystradowen and therefore in close proximity to the promoted site:

• In terms of public transport, there are two bus stops located approximately 400m (7-minute walk) from the site (‘Ty Mawr Close’), with the ‘321 Nat Group Service’ providing services between Llantwit Major and Talbot Green. The 321 service is the same bus service that serves ‘Land West of Maendy Road’ / Aberthin.
• The site is also located 300m (3-minute walk) and 600m (10-minute walk) from Sports Pitches/Playing Fields such as ‘Ystradowen Children’s Park’, and the 3/4G Sports Pitch at ‘Ystradowen Petanque Club’.

• Furthermore, the site is located 480m (7-minute walk) from the ‘Murco – Tudor Garage’ which can provide basic goods to meet day-today needs such as bread, butter, milk etc.

Accordingly, it can be considered therefore that if the proposed allocated site ‘Land West of Maendy Road, Aberthin’ is considered sustainable and by association suitable to be an Affordable Housing Led Allocation, ‘Land at Ystradowen’ is equally suitable to be an Affordable Housing Led Allocation.
Furthermore, to reinforce the above position and to illustrate and evidence the site’s sustainability, the following has been taken from the Officer’s Reports associated with the applications for the site that directly adjoins the western boundary of the promoted site 430 - ‘Land off Sandy Lane, Ystradowen’ (Housing Allocation 48). An aerial view extract is outlined below to give spatial context:
Reference is made in the Final Report of app ref. 2013/00856/OUT which states that “Ystradowen is considered a sustainable settlement for further housing development”, due to “the sustainable nature of the settlement”.

Furthermore, the Final Report of app ref. 2023/00948/FUL states:

• “Notwithstanding this, the site is located in close proximity to local services and there is a bus stop located nearby. Whilst the comments relating to the reliance and frequency of the bus services have been considered, there still remains a bus service in the area.”
• “Firstly, as aforementioned, many neighbouring comments refer to the site as unsustainable and have commented on the suitability of public transport and cycle routes etc. This has been addressed above.”

The above clearly evidences that the location has previously been endorsed as, and is currently still found to be, sustainable.

A further key consideration to note and one which does differentiate between the relative merits of the ‘Land at Maendy Road, Aberthin’ and ‘Land at Ystradowen’ is that the LDP Proposals Map demonstrates that ‘Land West of Maendy Road’ is within a Special Landscape Area - see overleaf:
Vale of Glamorgan Proposals Map (Land West of Maendy Road outlined in red)
Under Policy MG17 ‘Special Landscape Areas’ it is considered that development in SLA could pose an “unacceptable harm to the important landscape of the area”. Accordingly, this development and proposed allocation could therefore cause “unacceptable harm to the important landscape of the area”.

‘Land at Ystradowen’ by contrast does not sit within a SLA (see below). This site would therefore not pose any potential concern in this respect as it would ultimately not cause any “unacceptable harm to the important landscape of the area”.
Vale of Glamorgan Proposals Map (Land at Ystradowen in red)

This is a significant factor to consider. ‘Land West of Maendy Road, Aberthin’ causing “unacceptable harm to the important landscape of the area” will lead to this proposed allocation being at risk of not being delivered by virtue of detailed assessments of its impacts and acceptability at planning application stage holding that the landscape and visual impact of development of the site is unacceptable. As such 25 affordable units will be lost from the proposed affordable 122 units, and ultimately being lost from the overall housing land supply. As stated in the draft housing trajectory “there is a need for small scale affordable housing led development (minimum 50% affordable) to respond to local affordable needs and help sustain services and facilities within these rural communities”. There is a clear possibility therefore that this proposed allocation is not delivered (as it is located in a SLA), and so a “small scale affordable housing led development” which is needed to “respond to local affordable needs and help sustain services and facilities within these rural communities” is not provided for. This is clearly an issue. Given however ‘Land at Ystradowen’ does not sit within a SLA – and so not pose any potential concern or cause any “unacceptable harm to the important landscape of the area” – the allocation of this site would be more suitable and “safer” - as therefore would be no concerns over this proposed allocation being removed and/or not being delivered in this respect (as it is not located in a SLA). This would ensure that affordable units, where “there is a need for small scale affordable housing led development (minimum 50% affordable) to respond to local affordable needs and help sustain services and facilities within these rural communities”, are provided for. As such the proposed housing trajectory would be maintained.
Land North of West Winds Business Park, Fferm Goch

The below sets out the candidate site stage two assessment of ‘Land to north and west of Westwinds Business Park’:

Candidate Site Stage 2 Assessment (Site Ref. 398)
As can be seen above, the site was not considered suitable for further consideration, with the site scoring negatively (red) in respect to a number of key factors. These include the following:

• Access to Retail;
• Access to Health Services;
• Sustainable Transport- Public Transport;
• Access/ Proximity to services and facilities conclusion;
• Climate Change; and
• Health and Wellbeing.

Given the fact the site scores red in ‘Sustainable Transport – Public Transport’, this shows the site is not served by public transport connections within 800m, as outlined in the key below:
Additionally, Policy SP7 (Sustainable Transport) of the Vale of Glamorgan Preferred Strategy states “New development must support an enhanced transport network that increases the proportion of journeys being undertaken by sustainable travel modes”. Additionally Objective 8 (Promoting Active and Sustainable Travel Choices) states “new development is directed to locations that are or can be accessible by a choice of modes of transport, including walking, cycling, and public transport.”

It is well known that residents of affordable housing are statistically less likely to own private vehicles, making access to reliable and frequent public transport essential for ensuring equitable mobility. The provision of public transport infrastructure in close proximity to such developments is therefore a critical component in supporting access to employment, education, healthcare, and other key services, while also promoting sustainable travel patterns and social inclusion.

The site also scores red in respect to Access/Proximity to services, showing the site is greater than 1200m away from key services, as seen in the key below:
In respect of the above, Preferred Strategy 6.40 states the need “To ensure that new development takes place in locations that have the best access to a wide range of services, facilities, and employment opportunities, whilst minimising the need to travel, the distribution of growth is guided by the following settlement hierarchy”. To further highlight the importance of both sustainable transport and proximity to services, the preferred strategy also states the need to “Facilitate the development of adaptable, accessible, well-connected communities that have a strong sense of identity, offer a sustainable range of services and facilities and are equipped with adequate infrastructure”. In addition, Promoting Active and Sustainable Travel Choices outlines to “Promote and encourage the use of sustainable methods of travel, particularly active modes of transport, whilst simultaneously reducing the need to travel”.

In light of the above, this site does not align with the aims and targets set out in the Preferred Strategy, as it fails to meet several key development goals set out. It should therefore not be considered suitable to be allocated for future developments. Its inclusion is therefore unsound.

Should this view be concurred with, 22 affordable units will be lost from the proposed affordable 122 units, and ultimately will be lost from the overall housing land supply. As stated in the draft housing trajectory “there is a need for small scale affordable housing led development (minimum 50% affordable) to respond to local affordable needs and help sustain services and facilities within these rural communities”. There is a clear possibility therefore that this proposed allocation is removed and/or not delivered as its inclusion is unsound as it does not align with the aims and targets set out in the Preferred Strategy - as it fails to meet several key development goals set out. A “small scale affordable housing led development” which is needed to “respond to local affordable needs and help sustain services and facilities within these rural communities” will therefore not be provided for. This is clearly an issue.

When comparing this with ‘Land at Ystradowen’, the following is set out:

Access to Services and Facilities

This criterion has been assessed firstly on the location of the site proposal in terms of whether it is located within, adjacent to, or outside a settlement, and secondly the ease of pedestrian and cycle access to key services listed below.
With reference to the above:

• In terms of public transport, there are two bus stops located approximately 400m (7-minute walk) from the site (‘Ty Mawr Close’), with the ‘321 Nat Group Service’ providing services between Llantwit Major and Talbot Green.

• The site is also located 300m (3-minute walk) and 600m (10-minute walk) from Sports Pitches/Playing Fields such as ‘Ystradowen Children’s Park’, and the 3/4G Sports Pitch at ‘Ystradowen Petanque Club’.

• Furthermore, the site is located 480m (7-minute walk) from the ‘Murco – Tudor Garage’ which can provide basic goods to meet day-today needs such as bread, butter, milk etc.

These services and facilities are therefore well within the best category (i.e. categorised/scored as ‘green’) - within 800m of site (10-minute walk). Accordingly, the site therefore has good access to services and facilities.

Furthermore, the settlement of Ystradowen has been ranked highly in the VoG Sustainable Settlements Appraisal, scoring a total of 14 points according to the distance to key services and facilities available. This places Ystradowen 26th out of a total of 87 settlements. As a result, this would be deemed a suitable area to accommodate growth.

As stated above the key settlement of Cowbridge is located in close proximity being only 2.7 miles to the south and a 9- minute bus journey. Cowbridge is identified as a sustainable location, and is ranked 4th place for services and facilities within the Vale of Glamorgan. The following key services are found in Cowbridge, and are therefore in close proximity to ‘Land West of Maendy Road’:

• Cowbridge Comprehensive Schools;
• Cowbridge Health Centre; and
• Cowbridge Town Centre for various Retail Services.

Furthermore, it is important to note that the above criteria does not take into account the important role and proximity of the Principal Settlement and Strategic Growth Area (as defined in the RCTCBC LDP) of Talbot Green / Pontyclun / Llantrisant which is 2.8 miles to the north (14-minute bus journey). Ystradowen would also naturally align, and function, in association with this Principal Settlement and Strategic Growth Area (of Talbot Green / Pontyclun / Llantrisant). These areas comprise for example the following key services:

• Cowbridge and ‘Y Pant’ Comprehensive Schools;
• Cowbridge Health Centre and Old School Surgery; and
• Cowbridge Town Centre, and Talbot Green / Pontyclun / Llantrisant (Strategic Growth Area), for various Retail Services.

Given the above, ‘Land at Ystradowen’ does/should align with the aims and targets set out in the Preferred Strategy as it meets several of the key development goals set out. Its inclusion should therefore, in our view, be considered “sound” and therefore suitable to be allocated for future developments. The site should properly and appropriately be allocated in lieu of ‘Land to north and west of Westwinds Business Park’ – the inclusion of which is “unsound”. ‘Land at Ystradowen’ would therefore ensure that affordable units, where “there is a need for small scale affordable housing led development (minimum 50% affordable) to respond to local affordable needs and help sustain services and facilities within these rural communities”, are provided for. As such the proposed housing trajectory would be maintained.
Land to the East of Colwinston, Colwinston

A summary of the Candidate Sites Assessment at Preferred Strategy Stage has been extracted below:

As outlined above, the site was rejected and considered not suitable for further consideration. In fact, and unlike ‘Land at Heol Fain, Wick’ and ‘Land to north and west of Westwinds Business Park’ it was stated that this site “could not be considered as a suitable affordable housing led development site”. Despite this, this site is identified to be allocated as an Affordable Housing Led Allocation. As such, the inclusion of this site is “unsound”.

It is known that Colwinston has been subject to significant housing allocations in the settlement as part of previous plans. To evidence this, 25% of the 64 units (i.e. 16 units) were approved on the site allocation ref. MG2(41) and PP ref. 2014/00242/FUL. This makes a substantial provision of such Affordable Housing units (and housing generally) in the settlement in recent years.
Other similarly sized and comparable settlements and locations have not by contrast been subject to any growth for some considerable time, and accordingly would warrant and benefit from provision as part of this new replacement plan.

Notwithstanding the location of such provision, and as set out in detail at the outset of these representations, National Planning Policy advocates the high and acute need for affordable housing, whilst recent analysis evidences that there is a housing emergency. These circumstances - coupled with the shortcomings identified and set out earlier in these submissions in respect to the adequacy of provision within the plan (rolled forward sites / inadequate provision etc) – means that notwithstanding any potential allocation at Colwinston, further provision ought to be made in comparable (previously unprovided for) locations, such as Ystradowen.
Credentials of this site subject to this submission

There has been a significant change in the position and circumstances since the promoted site herein was assessed at Candidate Site Stage and the Assessment undertaken. The Stage 2 Assessment of the site concluded the following: ‘Whilst adjoining the existing LDP settlement boundary this is by virtue of an existing adopted plan LDP allocation this is currently under review. Notwithstanding this the site would represent unacceptable intrusion in to the open countryside.’
The assessment/conclusion implies that as this site (‘Land off Sandy Lane, Ystradowen’) has not been built out and is “currently under review”, it suggests that ‘Land at Ystradowen’ (430) does not adjoin the existing LDP settlement boundary. Given recent developments however associated with the implementation of the planning permission ref. 2023/00948/FUL (post approval on 9th December 2024) and the site being currently being “built out” and work commencing on site, the site no longer adjoins “the existing LDP settlement boundary … by virtue of an existing adopted plan LDP allocation … currently under review”. Accordingly, and given this, the ‘Land at Ystradowen’ site boundary therefore directly adjoins/is adjoining the LDP settlement boundary and the site promoted herein.
The following specific photo evidences ‘Land off Sandy Lane, Ystradowen’ (Housing Allocation 48) is being built out the western boundary of the promoted Site ID 430. This therefore clearly highlights that the site’s boundary is representing the existing settlement limit in the existing development plan. Accordingly, the ‘Land at Ystradowen’ site boundary therefore directly adjoins/is adjoining the existing LDP settlement boundary.
Summary of These Representations

To re-iterate, and to summarise the case made and set out, these representations seek to object to the Housing Trajectory published as part of the consultation on the Draft Housing Trajectory For Housing Stakeholder Group (October 2025) which underpins the Plan and the delivery / realisation of its underlying strategy.

Detailed submissions and objections are raised above in respect to the trajectory information published regarding the soundness and robustness of this information (and it’s consultation), which we do not consider are adequate, robust, or sound to deliver the Plans aims and objectives.

ANNEX 1
Preface

This Annex sets out the detailed case in support of these representations, and by association the case for allocation of the site.

The representations are structured into the following sections:

1. Response to the Deposit Plan;
2. Comments on specific policies; and
3. A summary of the suitability of the site for development.

SECTION 1. Response to the Deposit Plan

Distribution of Growth

We object to the distribution of growth within the Deposit Plan. Specifically, we object to the strategy that underpins the Deposit Plan, which seeks to introduce the proposed ‘Strategic Growth Area’ which is expected to contain the majority of housing growth in the Vale over the Plan period, or rather the over-reliance on this defined area, and the associated absence of growth in other parts of the Plan area.

As outlined in our previous representations, the allocation of housing and the location of strategic growth neglects the Rural Vale, and in our view, overprovides in the Strategic Growth Area. For example, with limited housing stock and average house sales at over £800,000 over the last 12 months, there is a clear and established need for new homes in the Bonvilston area, particularly at an affordable level. This is reinforced by the Local Housing Market Assessment that identified a need for over 1,114 new affordable homes per annum over the next five years throughout the county, and 196 units per annum thereafter (average of 502 units per annum over 15 years). Further to this, it is widely known that the rural Vale comprises the majority of the county’s ageing population, which, as a demographic, has and will continue to grow rapidly over the Plan period. This is evident in the ‘Population Change’ chart below – which is taken from the Deposit Plan:

VofG Deposit Plan: Figure 4 Population Change 2011 to 2021

It is clearly the case that younger populations are migrating to other Authorities, where access to housing is typically cheaper and more affordable, whilst more older populations are significantly migrating into the Authority. This trend will result in an extremely unbalanced demographic, given that the working-age population have sought housing elsewhere.

Without a suitable supply of affordable housing delivered over the Plan period, this trend will only worsen. Accordingly, it is not considered that the RLDP takes into account the lack of supply of affordable homes within the rural Vale, as well as increased housing to support the growing ageing population within these areas.

Para 3.19 of the Deposit Plan clearly outlines that affordable housing is required in the short term, in order to meet pressing needs. Specifically, it outlines the following: “There is significant pressure on temporary accommodation in the Vale, for a variety of reasons including increased homelessness presentations… The need for sufficient permanent affordable housing to assist in moving people out of temporary accommodation is critical and the planning system has a vital role in assisting in new affordable housing delivery.”
Accordingly, the distribution of growth within the Authority must be proportionate, to ensure that populations / areas are not left behind where they must seek access to housing elsewhere.

The RLDP Sustainable Growth Strategy sets out 6 objectives. Objective 4 states: “Allowing for small scale affordable housing led development in settlements outside the Strategic Growth Area at a scale proportionate to the size of settlement.” (Page 66)
Para 5.25 states “Therefore, a key part of the strategy is to allow for affordable housing led developments within sustainable primary and minor rural settlements outside of the Strategic Growth Area, at a scale that is appropriate to the size of the community it is serving. An ‘affordable housing led’ scheme is one where a minimum of 50% of the dwellings would need to be affordable, although this could increase to a maximum of 100% if the site is brought forward by a social landlord”.

In terms of the definition / explanation of what the affordable housing-led development sites are seeking to achieve, paragraph 6.132 of the Deposit Plan outlines the following:

“Accordingly, to ensure that new developments respond to the high demand for smaller properties, as identified in the LHMA, priority will be given to affordable homes that are small to medium-sized, typically comprising one to three bedrooms. Representations received from the local community through the RLDP process also highlighted a desire for new housing developments to offer opportunities for accessing smaller market homes. This is particularly relevant in the rural Vale, where housing choices are more limited. Providing smaller, more affordable market homes may assist first-time buyers and enable older residents to downsize to more manageable properties within their local area. Affordable housing-led sites will therefore need to demonstrate that an appropriate range of both affordable and market dwellings has been provided.”

Despite the acknowledgement within this strategic objective, we do not consider that the RLDP goes far enough to meet this objective, nor are its provisions and allocations adequate.

It is considered that this objective is undermined by the allocations set out by the RLDP (not least the absence of allocations in the rural Vale). Notwithstanding the Vision’s clear acknowledgement of the benefit of the growth of the rural Vale, these areas have not been supported through the plan due to the lack of growth which has been attributed to these areas in terms of further housing, employment and sustainable transport. All growth options have been selected on the basis of being in either a Key Settlement, Service Centre Settlement or Primary Settlement, all of which are already sustainable areas served by rail. As a result, it is not clear how this objective can be achieved, without the allocation of further sites within the Minor Rural Settlements, such as Bonvilston. The Vale is characteristically ‘rural’, and as such, there needs to be a stronger emphasis on supporting and delivering new development in order to bolster the rural economy. This includes enabling opportunities to provide employment and business premises within / near to rural settlements, as well as focusing housing growth in these areas to reduce travel time, and promote the use of sustainable transport.

It is considered that the current Strategy does not provide adequately for all residents across the Vale, only those within the Strategic Growth Area. The underlying Vision and Objectives set out in the emerging Plan are accordingly wholly un-provided for by the detail of the Plan. This brings into question the “soundness” of the Plan.

The Strategic Growth Area does not take into account the important role and proximity of Bridgend to the West and/or the Principal Settlement and Strategic Growth Area of Talbot Green / Pontyclun / Llantrisant to the north (as defined in the RCTCBC LDP). The Minor Rural Settlements to the west are more likely to be supported by job opportunities and employment in Bridgend than further east in Barry or Cardiff. Similarly, those in the north align with, and function in association with, the Principal Settlement and Strategic Growth Area of Talbot Green / Pontyclun / Llantrisant to the north. These settlements are served by existing bus services that provide sustainable modes of travel to key employment locations in and around Bridgend. This is acknowledged in Paragraph 3.3 of the Strategy which states “The greatest number of residents who travel outside of the Vale for work purposes travel to Cardiff followed by Bridgend and Rhondda Cynon Taf, whilst a smaller proportion commute into the Vale from these neighbouring authorities”. The Demographic Evidence (Feb 2023) estimates the Vale as being a net importer of workers from RCT and Caerphilly (Para 3.6) - as shown in Figure 10 in the Preferred Strategy.

The current Strategy does not support any improvement of sustainable travel or further investment in settlements linked more closely to these areas - given that Growth has been apportioned in only the Key Service Centre and Primary Settlements. It is considered that this will fail to support and facilitate the current (and any future) employment coming into the Vale, nor will it support any employment which is located outside of the Vale to the West and North. The Growth Option is too heavily reliant on access to railway stations as the key and sole sustainable transport method, whereas access to bus services should also be appropriately assessed and focused on in terms of promoting sustainable development. It is unreasonable to devise a strategy that hinges on directing growth to areas that are accessible to railway facilities, where it is recognised in the Plan that the Vale is inherently rural. The delivery and soundness of the Plan is therefore questioned and we continue to object to the spatial growth strategy as set out in the Deposit Plan.

Housing Supply

RLDP Allocations - Key Sites

As set out in representations made throughout the Plan preparation process, we consider that the Plan is too reliant on the delivery of ‘key sites’ to meet the housing need over the Plan period. Specifically, the Plan makes provision for 2,278 units in these Key Sites, which equates to circa 65% of RLDP allocations in the housing supply. The 5 key sites that are allocated in the Deposit Plan are as follows:

• Land at North West Barry – 376no. units;
• North of Dinas Powys – 250no. units;
• Land at Readers Way, Rhoose – 520no. units;
• Land at Church Farm, St Athan – 532no. units; and
• Land to the West of St Athan – 600no. units.

We object to the current housing supply to allocate 2,278no. (65%) of units across strategic sites, as this makes for a risky and unrobust strategy for delivering housing, and in turn, meeting the identified housing need over the Plan period.

As stated in previous representations, there is concern that the proposed timing and phasing of the proposed Key Sites is unrealistic and unrobust, and in turn, undermines the soundness of the Plan, given the heavy reliance on Key Sites delivering new homes across the Plan period. Whilst it is not disputed that the sites would have gone through rigorous assessment to inform their proposed allocation, the timescales for securing planning permission (with all associated conditions discharged) is considered to be unachievable. This is particularly the case for the following timescales that are set out in the Housing Trajectory that underpin the Plan:

• “Time period of pre-application discussions/PAC consultation” – 4 months

• “Time between submission of planning application and determination” – 6 months
• “Time taken from planning consent to the discharge of relevant conditions to enable site construction” – 4 months

It is considered that the above timescales are fundamentally unrobust, and result in a distorted position of housing sites over the RLDP Plan period. It is not considered that these reflect or are informed by the timescales that are currently being incurred for planning applications submitted for major housing sites across Wales. It is rather the case that such applications would typically be determined 1-2 years following submission, given that there are a wide range of stakeholders involved in the determination of major planning applications – which often adds to the delays associated with the determination of such applications.

It is equally the case that the assumptions in the trajectory are solely based on expected timescales for processing formal submissions made to the Council, and do not factor in the timescales associated with, and needed for, the preparation of the material for submission.

It is assumed that these timescales have not considered that such major developments can be subject to the need to undertaking and submitting an Environmental Impact Assessment (EIA), which adds another layer to the determination of any planning application – given the additional considerations that form part of this process. As such, any site subject to EIA would very likely result in further delays extending beyond the timescales set out in the trajectory. Equally, as set out above, the preparation of an application subject to an EIA requires even more detail and assessment, which only further adds to the preparation stage (which has not been factored into as part of the trajectory). Accordingly, it is not considered that the trajectory contains any contingency if any site is required to undertake EIA as part of their application.

For the reasons stated above, it is unlikely that the sites will yield in full, particularly those sites which are expected to deliver housing right up to the final year of the Plan period (‘Land at Readers Way’ and ‘Land to the West of St Athan’). These sites do not allow for any ‘slippage’ should any delays arise through the development management process (which for the reasons set out above, will very likely be the case), and as such, a gap in housing delivery will be brought about as a result of these sites not yielding in full.

Given the proposed ambitious timescales set out for the delivery of the Key Sites, it is considered the housing trajectory is unrobust, and in turn, undermines the soundness of the Plan as a result. A change in strategy should be pursued whereby a greater proportion of small to medium sites are allocated for housing in the Plan period, which are more likely to fully yield given that such sites are subject to less assessment and consideration compared to strategic sites. This would make for a more robust strategy, where a greater number of small to medium sites can deliver housing in the short and medium term of the Plan period, whereas the strategic sites represent a more longer-term strategy to deliver housing – which would then spill into the next Plan period.

Accordingly, we object to the Deposit Plan in its current form, where there is an overreliance on housing need to be met through the delivery of the Key Sites, which we consider to be unrobust, and undermine the integrity and soundness of the Plan. The current strategy of the Plan is at significant risk of not delivering the level of housing expected based on the sites allocated, as least as swifty as identified in the housing trajectory. Should no change be made to the Plan to address the above issues, then it is extremely likely that the Plan would ‘fail’ in meeting the identified housing need.

Windfall Sites

It is noted that the RLDP is made up of the following:

• Existing land supply (3,838 units)
• Windfall sites (1,303 units)
• Allocated sites (3,521 units)

Para 6.69 states that “Analysis of historical delivery of housing indicates that on average small windfall sites (sites of less than 10 dwellings) have provided some 53 dwelling completions per year, and large windfall sites (10 dwellings or greater) contributed on average 80 dwellings per year. Overall, it is projected that windfall sites could contribute a further 1,303 dwellings over the remainder of the plan”.

As set out in our previous representations to the Housing Trajectory, we would object to the expected numbers of completions expected during the Plan period, given that there are a number of issues with delivering housing in Wales and given past completions rates for The Vale of Glamorgan – which is discussed in greater detail later in this submission. Again, this results in the Plan being at risk of not delivering the level of housing expected based on the sites allocated – including any windfall sites.

St Athan Train Station

The RLDP Sustainable Growth Strategy comprises six key elements, of which the following is set out in respect to the allocation of new housing growth in the Authority:

“3. Focusing development at locations that are well served by existing and proposed rail stations as part of the South Wales Metro and in areas with good bus links.”

The strategy outlines that a feasibility study for a station in St Athan had been undertaken in 2022, which identifies that a new station could be located in St Athan, subject to further investigation work. Accordingly, in line with the spatial strategy adopted for the RLDP (i.e. focus development around sustainable transport nodes), St Athan was identified as a ‘Strategic Opportunity Area’ to accommodate strategic growth – through the proposed allocation of two key sites : ‘Land at Church Farm’ and ‘Land West of St Athan’. These sites have been identified to deliver 532no. and 600no. units respectively in the Plan period. These are separate to, and are in addition to, the 51no. units that have now been attributed to the site ‘Land South of Clive Road’ and 80no. units attributed to ‘Former Stadium Site, adjacent to Burley Place’ in St Athan. Accordingly, in total, the Housing Trajectory makes a provision for a total of 1,263no. homes to be delivered in St Athan over the Plan period.

It is now the case, however, that the proposed railway station at St Athan is not in the first phase of delivery for new stations in South Wales – as confirmed in the ‘Today, Tomorrow, Together: A vision for rail across Wales and Borders’ (February 2026) recently published by Transport For Wales. This paper acknowledges that a new railway station at St Athan would represent a longer term opportunity, and therefore, will not be delivered in the short term / within the Plan period of the emerging Plan. Equally the Council have not provided any evidence to contradict this, and therefore, it is very unlikely that any new train station will be delivered in St Athan over the Plan period. This brings about significant questions regarding the suitability and acceptability of the proposed allocations set out above.

The strategy to allocate new housing growth is predicated on focusing residential development around sustainable transport nodes, and given that St Athan will be without any railway station in the Plan period, it is not considered that the sites align with the strategy of the RLDP. Accordingly, the wider Housing Trajectory is considered to be unsound, given that a total of 1,263no. homes (36% of the Plan’s new housing allocations) are expected to be delivered in St Athan within the Plan period.

It is considered that there has been an overprovision for housing growth in St Athan generally, and this issue is now further exacerbated by the lack of any forthcoming rail provision. Given this, to add further sites for housing in this location over and above the original provision is considered to be unsound. As set out above, the justification to allocate sites at St Athan has relied heavily on the railway station being delivered in the Plan period, and as such, there are serious questions marks associated with the acceptability of the proposed allocated sites - given their incompatibility with the core strategy of the RLDP.

In terms of the expected delivery of the Key Sites in St Athan, it is noted that the trajectory identifies that for the majority of the Plan period, both sites will be delivering 80no. dwellings per annum on each site (equating to 160no units in total). Whilst these are two separate sites, we seriously question the realistic prospects of the significant number of

homes being built simultaneously on two sites in proximity to one another – given the considerable logistical issues that would be brought about.

Accordingly, it remains that there are serious questions regarding the suitability and acceptability of the proposed allocations at St Athan, which do not accord with the strategy adopted for the RLDP – to focus housing growth on settlements that are supported by railway stations. Moreover, the scale of development proposed at St Athan is also not considered to be proportionate, with a significant number of homes delivered in a location not served by a railway station.

Rolled forward LDP Sites

The proposed land supply within the housing trajectory includes provision for ‘rolled forward’ LDP sites, which contribute to the total of ‘Proposed Additional Housing Allocations’ forming part of the housing supply. Specifically, a total of 1,242no. units have been identified as additional housing allocations, of which 959no. are expected to be delivered on the rolled forward LDP sites. As such, these sites are to provide for a significant proportion of additional housing in the Plan period (specifically circa 77%).

The Development Plans Manual (DPM) sets out that allocations rolled forward from a previous plan will require careful justification for inclusion in a revised plan. The DPM outlines that “there will need to be a substantial change in circumstances to demonstrate sites can be delivered and justify being included again. Clear evidence will be required that such sites can be delivered.” The below table included in the consultation document provides a breakdown of the rolled forward LDP sites, and in particular, sets out the status of each site:


The above table evidences that the current LDP has under delivered in regard to its targeted unit number of the Plan period, given that these sites did not yield any housing over the current Plan period. This is further exacerbated by the Land Bank sites that have also not delivered any housing across the existing LDP period, amounting to 1,860no units. Accordingly, when considering the non-delivery of both rolled forward LDP sites and Land Bank sites, this amounts to an approximate shortfall of 2,189 homes being delivered, or 33% of the total housing supply identified for the current LDP (8,525no. dwellings).

It is therefore considered that, as a minimum, the units carried over from the LDP (without planning permission) should be a surplus to the housing supply proposed for the RLDP, as opposed to being relied on to deliver the housing need over the Plan period. This is particularly the case for the two sites (Land to the west of Pencoedtre Lane, and Land between Northern Access Road and Eglwys Brewis Road) which do not currently have any active planning application

submitted for their development. These sites total an amount of 370no. units to be delivered in the Plan period, which represents more than a third of the additional housing allocations to make up the housing supply.

As such, it is considered that the unmet need deriving from the existing LDP is still present – indeed it has grown, and will continue to do so, not least when considered in conjunction with the projected population growth over the coming years to 2036, and the aspirations for growth in the Plan’s strategy.

Accordingly, in order to secure the targeted level of housing, a greater level of provision for new allocations should be applied in order to meet the housing requirement. This would bring about better certainty that the housing requirement is met by the housing supply over the Plan period, not least given that the current Plan failed in this respect. Without a re-apportioning of the housing supply, it is considered that the Plan would heavily rely on the contingency (i.e. rolled forward LDP sites) coming forward in the Plan period, yet there is uncertainty that these will yield in full over the new Plan period. This raises issues of ’soundness’, and risks rendering the Plan unrobust.

Housing Delivery Rate Assumptions

As set out in our previous representations to the Housing Trajectory consultation, we have considerable concerns in relation to the proposed delivery of the sites identified in the trajectory – which we do not consider are robust or reasonable.

Appendix 1 of the Deposit Plan sets out the development trajectory bar chart – which illustrates the proposed delivery of housing, on a per annum basis, over the Plan period.

Extract of Housing Trajectory Graph (annotated by GJP – red dotted line)
It is our view that the trajectory makes for an unrealistic and unrobust delivery rate of housing, which does not reflect the pattern of housing completions in the Vale of Glamorgan. We therefore have concerns regarding the soundness of the trajectory, not least that there remain significant uncertainties as to the delivery of the Key Sites (as discussed earlier in these representations).

Firstly, the graph / trajectory illustrates a large ‘spike’ in terms of housing delivery in the year 2027-28, which is considered to be a marked and pronounced step change in the rate of delivery. This envisages / relies on a significantly higher rate of delivery than previous years in the Vale of Glamorgan (2021 through 2021 – as depicted by the green columns). It is considered that this level of delivery is unlikely to materialise, not least given prevailing market

circumstances, past rates of delivery on the ground, and also in light of levels achieved across Wales and the UK in general.

The published trajectory shows that the average level of completions from 2021 - 2025 has been approx. 400 - 500 units, however, the chart shows that from 2027 – 2028, completions are expected to rise to approx. 1,000 units per year. The expected delivery levels in the trajectory therefore show and assume a doubling in delivery rates and unit numbers (an increase of approx. 100% relative to past rates). There is no clear evidence as to how this level of completions can be achieved let alone guaranteed. This is the case in particular given that the forthcoming years (2025-2027) are expected to see performance (yield) drop significantly (delivery rates in 2025 – 2026 and 2026 – 2027). The chart shows only approx. 200 units being delivered over these years. It is therefore unclear how completion rates are expected to rise so quickly (from 200 in 2025-26 to 1000 in 2027-28), and by such a significant amount. The assumptions in the trajectory are wholly unrobust in our view.

It is also the case that the anticipated delivery of housing fails to be consistent within and across the Plan period. It is unclear as to why completions rates aren’t spread out more evenly throughout the Plan period - to ensure a robust and most realistic housing trajectory until 2036. By comparison to the marked increase in the rate of delivery between and over the period 2027 to 2031, there is then a marked fall-off or drop in delivery towards and by the end of the Plan period. Indeed, in the final year, the level of completions are expected to be lower than the period 2021-2025.

Accordingly, we consider that the housing trajectory, as proposed, is entirely manufactured and unreflective of the past completion rates, as well as the recent published completion rates provided by Welsh Government recently in August 2025. As set out in our previous representations, it has been evidenced that there has been a general decline in the number of new dwellings started and completed.

Description of Figure 1: ‘New House Building: April 2024 to March 2025’
As identified in the graph above, in 2024-25, 4,631 new dwellings were completed, which represents 3% fewer than the previous year. This figure represented the second lowest number on record, with the lowest number recorded in 2021-22, a year heavily affected by the coronavirus (COVID-19) pandemic (in 2021-22, 4,616 new dwellings were completed) The New Housing Pipeline Report Quarter 3, 2025 Report (December 2025) published by the HBF evidenced that the number of residential units approved in the UK fell by 7% during the third quarter of 2025, extending the decline seen during the first half of the year. At 45,075, the number of units approved was 34% down on the third quarter of 2024 and the lowest quarterly total since 2012 Q2. At 146,798, the overall number of units approved during the first nine months of 2025 was 25% lower than a year ago.



HBF Graph Illustrating Residential Approvals (2006-2025)

The above graph clearly shows a pronounced downward trend in the number of residential planning approvals over the period, particuarly with a sharp decrease seen since 2020. Further, the HBF document ‘Increasing Housing Supply in Wales’ (4th September 2025) clearly shows that The Vale of Glamorgan has not met the housing delivery requirements in recent years in 2023 – 2024 – along with every other authority in Wales (except Newport). Accordingly, this further adds to the argument that historically The Vale (and most other authorities) have underprovided. This adds considerable uncertainty on the assumed transformation in yield and delivery as built into the trajectory.

Graph: Housing Delivery as a proportion of annual housing requirement in Wales per Authority

More recently, the Welsh Government has released its new estimates of housing need (Estimates of Additional Hosing Need: 2025-based – February 2026). The estimates show how many new homes need to be built over the next twenty years to address existing unmet need as well as newly arising need. The figures set out that around 8,700no. new homes a year are needed over the next Senedd term up to 2030 to meet new housing need. Additionally, there is an unmet need for 9,400 affordable homes.

Overall, this represents more than double 2024/25 levels of supply, where just 4,638 new homes were built.

HBF: Estimates of Housing Need

HBF: Actual Delivery vs Estimates of Need

The above graphs unequivocally evidence that historical rates of delivery of housing in Wales has remained low, and moreover, significant numbers of housing need to be allocated in order to meet the estimate of need. It is not

considered that the housing trajectory, in its current form, is robust to meet the housing need over the Plan period, given the uncertainties of the Key Sites, and the level of housing delivery that has been identified for the Plan.

Affordable Housing-Led Sites

HG4 - Rural Affordable Housing Led Sites

Policy HG4 of the Deposit Plan identifies four sites to be allocated as affordable housing-led sites, totalling approximately 122 dwellings within the plan period. Given the target levels of achieving 3,070 affordable dwellings over the course of the Plan period (up to 2036), it is not considered that this policy goes far enough to address the target and level of affordable housing need.


It is noted that the number of units identified for each site relate to the ‘total’ number of units delivered, as opposed to the affordable housing provision. Accordingly, it can be assumed that circa 50% of each allocation will comprise affordable units (given each site is affordable-led), which would equate to a total provision of circa 61no. units. The contribution from the affordable housing-led sites would only equate to 2% of the total need (3,070no. units). Even when coupled with the affordable housing provision from open market sites and 100% exception sites, the total delivery of affordable housing will still be nowhere near enough to meet the overall affordable housing need over the Plan period. Accordingly, it is considered that inadequate provision has been made for such sites – not least given that 3 of the 4 allocated affordable housing-led sites are located west of Cowbridge.

Insofar as to the sites chosen and allocated are concerned, it is clear from reviewing the Stage 1 and Stage 2 Candidate Site Assessment that the allocated sites HG4(1) – (4) were not considered acceptable due to being outside the strategic growth areas, and were considered to be unacceptable intrusions into the open countryside. After being resubmitted as affordable housing-led sites, the sites were allocated, some with a smaller area in order to accommodate less dwellings in total.

The sustainable credentials of the sites allocated is not disputed, and it is acknowledged that these minor rural settlements have the ability to accommodate further growth, in the form of affordable-led housing allocations. However, it is considered that Land South of A48, Bonvilston (Site ID: 435 / 3857) should also form an allocation as part of this policy, given its high sustainability credentials and its appropriate location to accommodate a suitable level of development. Please refer to the previous representations made to the Housing Trajectory Consultation (dated 17th October) for further, more detailed comments regarding the above sites.

The LHMA 2023 shows that there is a need for 77 affordable homes in the St Nicholas & Llancarfan housing market area (which Bonvilston is located within), and a need for 242 affordable homes in the Wenvoe housing market area. As such, there is an identified need for affordable housing in this area, something which the site could address through an allocation.

Securing further delivery of Affordable Units

As set out above, it can be assumed that the affordable housing-led allocated sites only provide 61no. affordable dwellings, which comprise 4no. allocated sites that are expected to deliver approximately between 20 – 50 dwellings (including both affordable and market housing). However, the RLDP sets a target of 3,070 affordable homes to be delivered in the Plan period. This means that affordable housing-led allocations make up less than 4% of the target provision and will only make provision for 2% of the targeted number. We would therefore object to the sites included

within Policy HG4 and would suggest that more sites should be allocated as part of the policy in order to secure delivery of a higher number of affordable housing units to meet the target.
Whilst it is acknowledged that the Key Sites will provide for a significant proportion of affordable housing, as set out above in these representations, there is serious concern regarding the deliverability of these sites, which would result in a significant gap of affordable housing delivered.

A greater number of affordable housing-led sites allocated would ensure there is sufficient contingency built into the Plan, to ensure that the overall affordable housing need is met over the Plan period. Failure to do so would result in affordable housing need being unmet, with demand continuing to outstrip supply.

Previous representations to the Preferred Strategy (dated 14th February 2024) provided comment on the sustainability scoring of Bonvilston and the proposed site. As outlined within these representations, it is considered that the site (ID 435 / 3857) represents a sustainable, deliverable and acceptable site. This proposed allocation is situated in proximity to Cowbridge, Culverhouse Cross and Cardiff, which comprise all key services. Given that the site is located within 4 miles of both Cowbridge and St Nicholas, the site is within a maximum 20-minute bus journey of the following key services:

• Cowbridge Comprehensive School;
• St Nicholas Primary School;
• Cowbridge Health Centre; and
• Cowbridge town centre for various Retail Services.

Accordingly, the settlement of Bonvilston represents an acceptable location to allocate an affordable housing-led site, given the access to existing services and facilities that would serve future residents of the site.

To conclude, the settlement, location and site are inherently suitable and deliverable, and will make a significant contribution to achieving and realising the housing and economic development needs of Bonvilston, support the surrounding settlements, and the Plan area as a whole. As such, the site should be considered further.

Comments on Specific Policies

HG5 - Affordable Housing Exception Sites

Given the unmet need and extant backlog of affordable housing, as identified within the LHMA (2023), it is noted that an Affordable Housing Exception Sites policy has been adopted in order to assist in the delivery of affordable housing. Policy HG5 sets out the specific criteria where proposals for 100% small scale affordable housing developments will be permitted outside settlement boundaries. The current policy wording for the Affordable Housing Site Exception Policy and the criteria listed out in the policy is generally supported.

That said, it is noted that a ‘cap’ of 10 dwellings (as referenced within supporting text Para 6.140) is set. This should be amended due to such a ‘cap’ limiting the flexibility of the policy, in particularly for sites coming forward as part of this policy in Minor Rural Settlements.

As such, we would suggest that supporting Para 6.140 should be amended in order to allow for further flexibility for sites in Minor Rural Settlements to come forward and to deliver affordable housing, given that the criteria set out in the policy would already protect and restrict the extent of any development as it stands. Therefore, the proposed amendments to Para 6.140 are outlined below in red:

6.140 “For the purposes of this policy, ‘small-scale’ will generally mean no more than around 10 dwellings on sites adjoining Minor Rural Settlements. In Primary Settlements outside the Strategic Growth Area, proposals for more than 10 dwellings may be acceptable where required to meet a specific need and where the number of dwellings is proportionate to the size of the settlement. In assessing the scale and extent of any proposed local needs housing, consideration should also be given to affordable housing already planned in the ward or nearby area, including sites

with existing planning permissions and those allocated in the RLDP. The size and type of affordable housing proposed should reflect the identified local need in the area.”

The above suggested wording would achieve a more flexible policy, which would allow for a variety of scaled applications to secure planning permission for solely 100% affordable housing across the Authority area. This greater flexibility would enable the policy to make a significant contribution towards meeting the affordable housing need – which, as set out earlier is in considerable need.

SECTION 3. Suitability of the site for development

The site promoter objects to the overall assessment of the site, in that it is not considered suitable for further development in the Plan. The promoted site has undergone extensive scrutiny and appraisal at a high level to ascertain the qualities of the site, in light of all identified material considerations which relate to the proposals.

The delivery of the site will yield much needed housing (including Affordable housing) and contribute to the overall supply in the new Plan period, whilst making effective use of a suitably located site for residential development.

Moreover, as set out in ‘Annex 2’ of our representations, the site has overcome the ‘constraints’ set out in the Candidate Site Assessment undertaken for the site, which demonstrates that the proposal is both acceptable and deliverable.

Deliverability of the Site

In summary, the site seeks to deliver the following key elements:

• In summary, the opportunity of the site seeks to deliver:
• Residential development comprising up to 25 dwellings, with at least 50% affordable housing in accordance with Policy SP2,
• Highways infrastructure within the site;
• Upgraded access to the site;
• Strong legible pedestrian and cycle connections throughout the site and with the existing settlement;
• Green Infrastructure; and
• Sustainable Drainage Systems (SuDS).

SUMMARY AND CONCLUSIONS

In summary, the site promoters:

• Object to the distribution of growth proposed for the Plan area, with a more balanced and equitable distribution of housing sites required in order to meet the identified housing need;
• Object to the level of growth identified for the Plan period;
• Object to the housing trajectory that underpins the delivery of housing within the Plan period – which is considered to be unrealistic and unrobust, leading to serious uncertainty regarding the “soundness” of the Plan;
• Object to the over-reliance on Key Sites and Rolled Forward Sites in making up the Plan’s housing land supply;
• Object to the scale and timing of delivery of sites in / around St Athan – all of which are predicated on railway station provision which will not be realised in the Plan period;
• Object to the under-provision of sites under Policy HG4 – Rural Affordable Housing-Led sites, not least given their extremely limited contribution to the targeted need for affordable housing;
• Object to the current wording of the HG5 Policy ‘Affordable Housing Exception Sites’ which requires greater flexibility to play an important role in delivery much-needed affordable homes across the Authority; and
• Object the Council’s assessment that the site is not considered suitable for development.

The site and proposals are consistent with the RLDP strategy, other Vale of Glamorgan strategies, and the requirements of Planning Policy Wales and Future Wales. It will make a significant contribution to the Vale’s identified housing requirement in the RLDP period and will provide for a wide range of uses that will support the wider community whilst embodying principles relating to placemaking and the well-being of future generations.

The site has no fundamental constraints and has the ability to deliver significant economic, social and environmental benefits for the benefit of future residents and the existing local community. The site is demonstrated to be viable, being able to deliver policy-compliant levels of affordable housing and given its location within a strong market area, will benefit from high delivery rates.

ANNEX 2
SECTION 4. A summary of the suitability of the site for development including a Response to the Candidate Site Assessment

This section of the overall representations to the Deposit Plan is to respond to, and address, the Council’s assessment of the site.

While the issues the Council have raised in their assessment of the site have been addressed and discussed within the representations made at the Preferred Strategy stage of the Plan, a similar ‘scoring’ exercise has been undertaken as part of the evidence base for the Deposit Plan. As such, it is still pertinent to consider and respond to the Council’s assessment of the site as part of these representations

The Detailed Site Assessment for Land South of the A48, Bonvilston (Site ID: 3857) sets out that the position of the site at the Deposit Stage is as follows:

“Notwithstanding the amendment from a market led to an affordable housing led scheme (original CS 435), the other reasons why the site was previously discounted still remain.
The development would have an adverse impact on the character and setting of the Bonvilston Conservation Area. Development of the site would require major highway mitigation works to enable safe vehicular access on to the A48.
The Predictive ALC Maps indicates that site is Grade 2 Best and Most Versatile Land. Development of the site would lead to the loss of BMV land. BMV land should only be developed if there is an overriding need for the development and either previously developed land or land is lower agricultural grades is unavailable. There is housing land available within the ward of St Nicholas and Llancarfan that can support the delivery of affordable housing.”
Conservation Area
In terms of the assertion that “The development would have an adverse impact on the character and setting of the Bonvilston Conservation Area, this is strongly disputed.

Whilst it is acknowledged that the site lies within the Bonvilston Conservation Area, the conclusion that it would be adversely affected is not considered to be accurate. Firstly, the site as it currently stands, consists of an open field. This does not match the conservation area which is characterised primarily by residential dwellings of varying densities, and as such, it is considered that development of the site with sensitively designed buildings would enhance as opposed to harming its surroundings.

Secondly, the large residential development to the north of the site, ‘Land at Sycamore Cross’ ref. 2015/00960/FUL encroaches on the Bonvilston Conservation area but was deemed acceptable by the LPA. Although not all of the site is within the Conservation Area, it’s encroachment and presence adjoining and surrounding a large proportion of the area is considerable and was deemed acceptable by Officers in 2017. Given this, a development at the Land South of the A48 should be deemed acceptable, as it follows the same principles albeit at a much smaller scale.

Highways
As for the statement that “Development of the site would require major highway mitigation works to enable safe vehicular access on to the A48”, this is also strongly disputed.

The site is located immediately adjacent to the adopted highway where it is proposed to upgrade and enhance the existing gated access point. Due to the existing access point, it is not considered that ‘major’ highway mitigation works would be needed, rather this would be enhanced and improved as part of the proposed development. Furthermore, given the nature of the road, with long views extending in both directions, it is anticipated that appropriate visibility

splays could be achieved to enable safe access and egress. As such, it is considered that the site would achieve appropriate highway access within the need for “major” highway mitigation works.

Agricultural Land Classification
The Detailed Site Assessment also sets out that “The Predictive ALC Maps indicates that site is Grade 2 Best and Most Versatile Land. Development of the site would lead to the loss of BMV land. BMV land should only be developed if there is an overriding need for the development and either previously developed land or land is lower agricultural grades is unavailable.” This is strongly disputed.

A review of the Agricultural Land Classification Predictive Map indicates that the site lies primarily within ‘Grade 2: Very good quality agricultural land’ but no Grade 1 land is present. Further assessment and tests to establish the quality would therefore be undertaken in due course to confirm the quality of the land. However, it is not considered that it would be suitable to farm in any event given the location immediately adjoining existing residential development and the fact that it is within private ownership. Overall, given that the site is relatively small with a gross area of 0.88 hectares, it is not considered that its development would result in a detrimental or significant loss of agricultural land – not least given that site is not capable of beneficial agricultural production due to its limited size.

Housing / Housing Land
Further to the above, it is also set out that “There is housing land available within the ward of St Nicholas and Llancarfan that can support the delivery of affordable housing”, however, this is not considered to be entirely accurate.

The LHMA 2023 shows that there is a need for 77 affordable homes in the St Nicholas & Llancarfan housing market area and a need for 242 affordable homes in the Wenvoe housing market area. This need has not been met through the allocations of sites within the RLDP, nor has it been met through outstanding commitments.

As outlined in Annex 1, it can be assumed that the affordable housing-led allocated sites will only provide for 61no. affordable dwellings within the Rural Vale, comprising 4no. sites that are expected to deliver approximately 20 – 50 dwellings (including both affordable and market housing). However, the RLDP sets a target of 3,070 affordable homes to be delivered in the Plan period. This means that affordable housing-led allocations make up less than 4% of the target provision and will only make provision for 2% of the targeted number. Therefore, more sites should be allocated in order to secure the delivery of a higher number of affordable housing units to meet the target.

As set out within Annex 1, it is acknowledged that the Key Sites will provide for a significant proportion of affordable housing, however, there is serious concern regarding the deliverability of these sites, which would result in a significant gap in the total affordable housing that is delivered. Therefore, allocating a greater number of affordable housing-led sites would ensure there is sufficient contingency built into the Plan, to ensure that the overall affordable housing need is met over the Plan period. Failure to do so would result in the both the overall affordable housing need, and the need for the St Nicholas & Llancarfan housing market area, being unmet, with demand continuing to outstrip supply.

The LHMA 2023 sets out the existing stock and planned supply of affordable housing over the next 5 years (up until 2028). This assessment found that the housing market area of St Nicholas & Llancarfan has a committed supply of 4no. one beds, 11no. two beds, and 3no. three beds, with 2 no. three beds as expected re-lets. The assessment also identifies a committed supply of 39no. units for intermediate housing.

The LHMA also sets out the existing stock and planned supply for Wenvoe, identifying the committed supply of social rent homes to be 12no. one beds, 11no. two beds, and 5no. three beds, with 7no. one beds and 8no. two beds as expected re-lets. There is no committed supply for intermediate housing in Wenvoe.

It should be noted that the development of ‘Land East of Nicholas’ (Campbell Court and Cae Newydd), has now been completed, and as such, can not form part of the housing land available. The latest Pre-Application Response for the site subject to these representations (Land South of the A48, Bonvilston) accounted for the development of the site in

St Nicholas, stating that “even after the developments at St Nicholas and Culverhouse Cross, there was the need in the Wenvoe ward for 1 Bed 71, 2 Bed 49, 3 Bed 29, 4 Bed 7, 5 Bed 5, Total 161".

It should also be noted that there are existing commitments within the Bonvilston area (‘Land to the east of Bonvilston’), however, the deliverability of the existing commitment is seriously questioned. Application Ref. 2015/00960/FUL was approved in July 2017, with the Housing Land Supply and Housing Trajectory Report (December 2025) confirming that of the total 120 units permitted, only 40 had completed by 1st April 2025, with the remaining 80 units not started by this same date. Of the 80 units not started, 25 units are affordable homes.

It is well known that phase 1 of the development at ‘Land to the east of Bonvilston’ has faced difficulties which has led to the development remaining incomplete. This does of course put into question the overall deliverability of the site, and raises concerns about the units that were, and still are, required within the Bonvilston area.

The allocation of the site promoted herein would not only help in the short term in meeting the overall affordable housing target for the Plan, but would also assist in meeting the unmet needs of affordable housing within Bonvilston – not least given the serious concern regarding the deliverability of the committed supply of housing within the St Nicholas & Llancarfan housing market area.

For the reasons set out above, and in light of the information provided within the LHMA 2023 and the Housing Land Supply and Housing Trajectory Report (December 2025), it is evident that there is considerable need for affordable housing within Bonvilston, and accordingly, the housing market areas of St Nicholas & Llancarfan, and Wenvoe. There have not been any sites allocated to assist within meeting the local need, and more sites should be allocated in order to secure delivery of a higher number of affordable housing units to meet the overall target of the Plan.

The contention that “There is housing land available within the ward of St Nicholas and Llancarfan that can support the delivery of affordable housing” is therefore strongly disputed – not least given that there is a clear and evident need to allocate more affordable housing-led sites in order to meet the target set out in the Plan.

Interim Summary

In summary, it is considered that the site subject to these representations would not have an adverse impact on the character and setting of the Bonvilston Conservation Area, nor would major highway mitigation works be required to enable safe vehicular access on to the A48. Moreover, it is considered that the site’s classification as BMV Agricultural Land does not pose a fundamental constraint to development – as the site represents a relatively small parcel with a gross area of 0.88 hectares, which is not capable of beneficial agricultural production due to its limited size.

There is also a considerable need for the affordable housing in Bonvilston and the housing market area of St Nicholas & Llancarfan. The site promoted herein would assist in meeting these local needs and should be allocated accordingly.

Candidate Site Assessment

The Detailed Site Assessment undertaken by the LPA includes a summary and assessment of the ‘scoring’ system used at the Preferred Strategy stage. A comparison between the site assessments undertaken at both the Preferred Strategy stage and Deposit Plan stage is provided overleaf for reference.



Site Assessment at Preferred Strategy Stage Site Assessment at Deposit Plan Stage

As demonstrated above, there has only been one change to the scoring attributed to the site, this being a change from ‘red’ to ‘amber’ for ‘Developer Interest’. Detailed submissions were made on the previous assessment undertaken by the Council at Preferred Strategy stage, and as such, should be read in conjunction with these representations accordingly (see Appendix B).

Whilst detailed submissions were made on the previous assessment, it is considered pertinent for the scoring of the key criteria’s to be addressed as part of these representations. As such, these have also been discussed below.
Developer Interest

As set out above, the Detailed Site Assessment for ‘Developer Interest’ has changed from ‘red’ to ‘amber’. The assessment methodology for this section of the assessment has been extracted below for reference.


As set out above, ‘amber’ refers to there being no development interest identified at this stage, however, there is evidence to indicate that the site is being actively promoted by the owners.

The representations made to the Preferred Strategy (Appendix B) sets out that whilst the site does not yet have an agreement with a developer to take on the land, it is considered that this would be achieved should the site be allocated, and planning permission granted. Newydd Housing association have been engaged previously and had agreed to take the site forward as a 100% affordable scheme, albeit is also considered that they could take on the affordable units as part of a mixed tenure scheme.

In addition to Newydd, the site promoter has also received an offer from a private social housing provider who would be prepared to support the site as a mixed tenure scheme.

This position has not changed since the Preferred Strategy stage, and is considered that there is continued developer interest for the site. This is not considered to change at any point – not least given the discussions held between the owners of the site in questions and developers of interest.

Environmental and Physical Constraints

As set out at the Pre-Application Stage. the site underwent a Preliminary Ecological Appraisal in September 2022 which identified that whilst some precautionary measures were recommended in terms of protecting priority habitats and reptiles, the site is not fundamentally constrained from development on ecological terms. Given this, it is considered that further ecological surveys would be undertaken at the planning stage to inform any development proposals and ensure the safeguarding of the natural environment.

Access to Key Services (Retail, Primary Schools, and Health Services) and to Services and Facilities

As set out within the representations made to the Preferred Strategy, the site is located within a maximum of a 20-minute bus journey to a version of every key service listed, due to the proximity of the site to settlements such as Cowbridge, Culverhouse Cross and St Nicholas. Due to the availability of frequent bus services, and active travel links, these key services are readily available to access for any residents within Bonvilston without the need to travel by car.

To reiterate, the site ‘Land South of the A48, Bonvilston’ is situated in proximity to Cowbridge, Culverhouse Cross and Cardiff, which comprise all key services. Concluding this allocation as ‘unsustainable’ in regard to ‘availability of local facilities in and around settlements’ is not accurate. Given that the site is located within 4 miles of both Cowbridge and St Nicholas, the site is within a maximum 20-minute bus journey of the following key services:

• Cowbridge Comprehensive School;
• St Nicholas Primary School;
• Cowbridge Health Centre; and
• Cowbridge town centre for various Retail Services.

It should also be noted that Bonvilston contains a number of facilities within a short and level walking distance of the site, including the village shop and Café, as well as the Red Lion Public House.

Given the accessibility of the site to other settlements, and the fact that these are made accessible by bus and active travel routes, it is considered that the site should be concluded as sustainable in regard to access to key services.

Summary and Conclusion

As evidenced above, and within the representations made to the Preferred Strategy (Appendix B), there are no fundamental constraints at, or associated with the site, that would preclude the site coming forward for development in the RLDP period.

To conclude, the settlement, location, and site, are inherently suitable and deliverable, and will make a significant contribution to achieving and realising the housing and economic development needs of the Vale of Glamorgan.

Summary of These Representations

In short, and to summarise the case made and set out, these representations seek to object to the Housing Trajectory published as part of the consultation on the Draft Housing Trajectory For Housing Stakeholder Group (October 2025) which underpins the Plan and the delivery / realisation of its underlying strategy.

Detailed submissions and objections are raised below in respect to the trajectory information published regarding the soundness and robustness of this information (and it’s consultation), which we do not consider are adequate, robust, or sound to deliver the Plans aims and objectives.

Preface

This Submission sets out the detailed case in support of these representations. The representations are structured as follows:

1. Procedural Consultation Matters;
2. Timing Assumptions underpinning the Trajectory;
3. Housing Delivery Rate Assumptions;;
4. Status & Standing of Sites included in the Trajectory;
5. Key Sites;
6. St Athan Train Station;
7. Geographic distribution of the ‘new’ sites / provision;
8. Detailed comments in respect to ‘new’ sites;
9. Conclusions Procedural Consultation Matters
Firstly, we do not consider that the consultation on the Housing Trajectory information has been procedurally undertaken appropriately or suitably.

Only 14 days have been afforded to parties to make representations on the information provided. This is despite new sites being introduced (at this late stage) i.e. Land South of Clive Road (identified in Table 4), as well as a number of affordable housing led housing sites being introduced (i.e. those outlined in Table 5). This does not provide an adequate process or timescale for objectors to scrutinise the published content, and to make comments on sites which have been presented for the first time at a late stage in the process.

As part of these representations, we will be making brief comment on the sites which have not been previously consulted upon, namely:
Other Housing Allocations
• Land south of Clive Road, St Athan;

Affordable Housing Led Sites
• Land at Heol Fain, Wick;
• Land west of Maendy Road, Aberthin;
• Land Noth of West Winds Business Park, Fferm Goch; and
• Land to the East of Colwinston.

It is considered necessary to comment on these sites, given that they form an important and critical part of the housing trajectory, and by association in the Council and Plan reaching their targets. Moreover, these sites have not been consulted on previously. Accordingly we consider it necessary to pass comment on these in order to ensure that the consultation is fair and robust.

As well as limited time given to comment on the information contained within the Housing Trajectory, the LPA have failed to set up a Housing Stakeholder group to agree and discuss the trajectory information and data – with the cover email to the consultation (dated 3rd October 2025) stating “it is considered that it would be the best use of stakeholder time to conduct this engagement via email, particularly as many of the forecasts have been developed in consultation with site promoters including developers and their agents”.

We submit that the stakeholder consultation has not been a transparent nor robust consultation process, given that the Development Plans Manual states at Para 5.66 “A housing trajectory must be prepared to support the Deposit Plan. In order to generate a housing trajectory and associated phasing tables it will be necessary for LPAs to engage with stakeholders through a Housing Stakeholder Group. This will ensure that the timing and phasing of sites is robust and based on up to date information”. Given that this has not taken place, we would raise fundamental concerns that the consultation of the trajectory has not adequately taken place as per the relevant guidance. Afterall, the guidance stresses that a Group should be formed as a necessity. Accordingly, there has not been an adequate process and opportunity to review and comment on the information published, including in respect to the other sites have been introduced at this late stage.

Timing Assumptions underpinning the Trajectory

The assumed and factored in timescales of the various stages of bringing forward sites i.e. the pre-application stage, the planning application process, and the discharge of condition process outlined in the trajectory are considered to be fundamentally inaccurate, and result in a distorted position of the delivery of housing sites over the RLDP Plan period. The assumptions are far too ambitious, and without evidence / are not comparable with the timescales being incurred in processing such stages at the Development Management stage(s).

Specifically, we raise objection to the following timescales which are considered to be extremely ambitious and unrealistic:

• “Time period of pre-application discussions/PAC consultation” = 4 months
• “Time between submission of planning application and determination” = 6 months
• “Time taken from planning consent to the discharge of relevant conditions to enable site construction” = 4 months

In our experience, having submitted a significant number of major and other applications for housing and other forms of development in the last 1-2 years to the Council (and elsewhere in Wales and England), it is extremely unlikely that major applications can be submitted, and planning permissions granted, within the timeframes assumed by the trajectory. A wide range of stakeholders are also involved in the determination of major planning applications, which often adds to the delays associated with the determination of such applications. We would therefore consider that a time period of “6 months” given to all major applications in the housing trajectory is not feasible, and distorts the trajectory timescales for the remaining Plan period.

The assumptions in the trajectory are also solely based on expected timescales for the processing of formal submissions made to the Council, and do not factor in the timescales associated with, and needed for, the preparation of the material for submission (i.e. pre-application enquiry submissions / planning application / discharge of condition details etc). When factored in these will elongate the timescales for bringing forward schemes considerably.

Moreover, it is common practice for larger housing sites and major applications to have a range of pre-commencement conditions attached to a permission once granted. Again, we would raise concerns with the timescales indicated in the trajectory related to this part of the planning process. It is highly unusual and questionable that any technical work required by these conditions (usually relating to drainage and highways matters) would be instructed, completed and submitted within 2 months, and for these to then be signed off / approved in a further 2 months. There are also other technical matters and necessary approvals falling outside of, and over and above, the planning system, such as SAB, s.106, s.38 and s.278 agreements, timescales for which have not been accounted for – and all of which are rarely completed within “4 months” as indicated.

It is therefore highly doubtful that the timescales legislated for in the trajectory for the various stages pre-construction are achievable – with no information about these proposed timescales outlined within the supporting text of the Housing Trajectory. We would therefore raise considerable concerns and objections to these as they stand without full evidence to fully show how these have been calculated, and without there being considerable (and necessary) adjustment to the timescales indicated and factored in.

We would therefore object to the timescales indicated in the ‘Timing and Phasing of Sites’ table, given that the delivery start dates will be pushed back further into the Plan period. Accordingly, and as a result, the Plan is at risk of not delivering the level of housing expected based on the sites allocated, at least as swiftly as is set out in the trajectory.

Housing Delivery Rate Assumptions

We would also raise considerable doubt over the proposed delivery of the sites identified in the Housing Trajectory - which we do not consider are robust or reasonable.

The development trajectory bar chart set out in the consultation material (extracted below) anticipates and legislates for a number of critical events and circumstances – all of which are considered to be unrobust and unsound.

Extract of Housing Trajectory Graph (annotated by GJP – red dotted line)

Firstly, a large ‘spike’ (material increase) in housing delivery is factored in to take place in 2027 – 2028. This is a marked and pronounced step change in the rate of delivery, and envisages / relies on a significantly higher rate of delivery than previous years in The Vale of Glamorgan (2021 through 2025 - as depicted by the green columns). This is considered extremely unlikely to materialise, not least given prevailing market circumstances, past rates of delivery on the ground, and also in light of levels achieved across Wales and the UK in general.

The published trajectory shows that the average level of completions in The Vale of Glamorgan from 2021 - 2025 has been approx. 400 - 500 units. However, the chart shows that from 2027 – 2028, completions are expected to rise to approx. 1,000 units per year. The expected delivery levels in the trajectory therefore show and assume a doubling in delivery rates and unit numbers (an increase of approx. 100%relative to past rates). There is no clear evidence as to how this level of completions can be achieved let alone guaranteed. This is the case in particular given that the forthcoming years (2025-2027) are expected to see performance (yield) drop significantly (delivery rates in 2025 – 2026 and 2026 – 2027). The chart shows only approx. 200 units being delivered over these years. It is therefore unclear how completion rates are expected to rise so quickly (from 200 in 2025-26 to 1000 in 2027-28), and by such a significant amount. The assumptions in the trajectory are wholly unrobust in our view.

The anticipated delivery of housing also fails to be consistent within and across the Plan period. It is unclear as to why completions rates aren’t spread out more evenly throughout the Plan period - to ensure a robust and most realistic housing trajectory until 2036. By comparison to the marked increase in the rate of delivery between and over the

period 2027 to 2031, there is then a marked fall-off or drop in delivery towards and by the end of the Plan period. Indeed, in the final year, the level of completions are expected to be lower than the period 2021-2015.

To summarise, we consider the defined position to be wholly manufactured and unreflective of the past completion rates, as well as the recently published completion rates provided by Welsh Government recently in August 2025. In the Welsh Government Statistics Document ‘’New House Building: April 2024 to March 2025’, information on the number of new dwellings started is provided, where building has commenced and those completed for April 2024 to March 2025. Figure 1 provides a graph showing starts in the last 10 years, and it is clear that there has been a general decline in the number of new dwellings started and completed.

Description of Figure 1:.‘New House Building: April 2024 to March 2025’
In 2024-25, 4,631 new dwellings were completed, 3% fewer than in the previous year. This was the second lowest number on record, with the lowest number recorded in 2021-22, a year heavily affected by the coronavirus (COVID-19) pandemic (in 2021-22, 4,616 new dwellings were completed). The New Housing Pipeline Report Quarter 2, 2025 Report (September, 2025) published by the HBF evidenced that the number of residential units approved in the UK fell by 6% during the second quarter of 2025, continuing the decline of approval during the first three months of the year. Wales saw one of the largest declines in the UK in approvals with a decline of 29%.

Further, the HBF document ‘Increasing Housing Supply in Wales’ (4th September 2025) clearly shows that The Vale of Glamorgan has not met the housing delivery requirements in recent years in 2023 – 2024 – along with every other authority in Wales (except Newport). Accordingly, this further adds to the argument that historically The Vale (and most other authorities) have underprovided. This adds considerable uncertainty on the assumed transformation in yield and delivery as built into the trajectory.



Graph: Housing Delivery as a proportion of annual housing requirement in Wales per Authority

The Home Building Sector Skills Plan (Aug 2025) published by the HBF also identified the following issues with the workforce to bring forward built development in Wales:

• “A shortfall in numbers entering roles from the education system;
• An ageing workforce: 25% of the home building workforce is aged over 50, meaning the sector is facing an impending retirement cliff edge;
• Challenges attracting a wider talent pipeline into the sector;
• A lack of understanding of critical future skills needed, and direction from the Future Homes Standard; and
• Output within the sector fluctuating with demand and economic pressures, leading to additional pressures in recruitment and training”.

It is not considered that in the next 1-2 years that any of these issues can or will be substantially corrected – at least sufficiently so to allow for, and enable, the planned delivery rates of new housing completions to be as high as < > 1,000 homes in one year (and for four consecutive years at that).

We would therefore object to the proposed numbers of completion expected during the Plan period, given that there are a number of issues with delivering housing in Wales and given past completions rates for The Vale of Glamorgan. Again, this results in the Plan being at risk of not delivering the level of housing expected based on the sites allocated.

Status & Standing of Sites included in the Trajectory

The proposed land supply within the housing trajectory includes provision for ‘rolled forward’ LDP sites, which contribute to the total of ‘Proposed Additional Housing Allocations’ forming part of the housing supply. Specifically, a total of 1,242no. units have been identified as additional housing allocations, of which 959no. are expected to be delivered on the rolled forward LDP sites. As such, these sites are to provide for a significant proportion of additional housing in the Plan period (specifically circa 77%).

The Development Plans Manual (DPM) sets out that allocations rolled forward from a previous plan will require careful justification for inclusion in a revised plan. The DPM outlines that “there will need to be a substantial change in circumstances to demonstrate sites can be delivered and justify being included again. Clear evidence will be required that such sites can be delivered.” The below table included in the consultation document provides a breakdown of the rolled forward LDP sites, and in particular, sets out the status of each site:




The above table evidences that the current LDP has under delivered in regard to its targeted unit number of the Plan period, given that these sites did not yield any housing over the current plan period. This is further exacerbated by the Land Bank sites that have also not delivered any housing across the existing LDP period, amounting to 1,860no units. Accordingly, when considering the non-delivery of both rolled forward LDP sites and Land Bank sites, this amounts to an approximate shortfall of 2,189 homes being delivered, or 33% of the total housing supply identified for the current LDP (8,525no. dwellings).

It is therefore considered that, as a minimum, the units carried over from the LDP (without planning permission) should be a surplus to the housing supply proposed for the RLDP, as opposed to being relied on to deliver the housing need over the Plan period. This is particularly the case for the two sites (Land to the west of Pencoedtre Lane, and Land between Northern Access Road and Eglwys Brewis Road) which do not currently have any active planning application submitted for their development. These sites total an amount of 370no. units to be delivered in the Plan period, which represents more than a third of the additional housing allocations to make up the housing supply.

As such, it is considered that the unmet need deriving from the existing LDP is still present – indeed it has grown, and will continue to do so, not least when considered in conjunction with the projected population growth over the coming years to 2036, and the aspirations for growth in the Plan’s strategy.

Accordingly, in order to secure the targeted level of housing, a greater level of provision for new allocations should be applied in order to meet the housing requirement. This would bring about better certainty that the housing requirement is met by the housing supply over the Plan period, not least given that the current Plan failed in this respect. Without a re-apportioning of the housing supply, it is considered that the Plan would heavily rely on the contingency (i.e. rolled forward LDP sites) coming forward in the Plan period, yet there is uncertainty that these will yield in full over the new Plan period. This raises issues of ‘’soundness’’, and risks rendering the Plan unrobust.

On this basis, we would object to the Plan if the provision of housing is not adjusted to rebalance the provision to include new allocations in lieu of rolled forward LDP sites in the housing supply.

Key Sites

As set out in previous representations at Preferred Strategy stage, it is considered that the housing supply relies heavily on the delivery of the ‘key sites’ to deliver housing (and meet need) over the Plan period. The total number of housing units attributed to key sites amounts to 2,278, which equates to over 25% of the total provision in the Plan period.

As detailed above, we consider there to be concerns regarding the proposed ‘Timing and Phasing of Sites’ table included in the Housing Trajectory which we consider are not reflective or accurate and will therefore have the effect of delivery start dates being much later into the Plan period than anticipated. The result of this will be that the Plan will be at risk of not delivery the level of housing expected and needed. Moreover, the Housing Trajectory Graph presents an overly ambitious level of housing completions over the Plan period - which the Council consider will be markedly higher than the average levels experienced in the last five years. Again, for the reasons set out above, we consider that these rates of expected completions to have no evidence supporting them, and to be unachievable and unsound.

Insofar as to the removal of the previously proposed site ‘Land at North East Barry’, this site was expected to deliver 900no. units in the Plan period. Following its omission from the housing supply, other sites have been identified, which comprises the inclusion of a new key site (Land at North West Barry), 3no. non-strategic sites, and also affordable housing-led allocations. In terms of the quantum of development attributed to these new sites, this amounts to 659no. dwellings. This is some 250 units less than the 900no. homes that was previously attributed to ‘Land at North East Barry’. Whilst it is appreciated that the number of homes forming part of the existing supply (completions, units with planning permission etc.) have increased since Preferred Strategy stage, there will be a net loss in market housing provision and delivery.

This position is made worse and compounded as a result of accounting for the affordable-led sites in making up the housing supply.

As set out within the Preferred Strategy, these sites are expected to deliver at least 51% affordable housing. These units are not open market units, and will not / cannot contribute to the supply of such housing. These units will contribute to the provision of affordable housing, and will go some way to meeting the acute need for such housing (albeit will not eradicate / address in full the well known and accepted considerable requirement). Accordingly it is considered that these sites should be in addition to the housing supply, as opposed to forming part of the provision. In turn, there would need to be an increase in allocations for non-strategic sites, to ensure that there is sufficient market housing delivery over the Plan period.

Were such changes to be made and introduced, this would achieve and assist realise a more robust and sound housing supply, which will ensure that the identified housing need is met / addressed over the Plan period. Without these changes it is considered that the housing supply is not sufficient, and inevitably, housing need will not be met within the Plan.

St Athan Train Station

As set out in the Preferred Strategy (para A3.29), the strategy seeks to focus development around key sustainable transport nodes. The strategy outlined that a feasibility study for a station in St Athan had been undertaken, which identifies that a new station could be located in St Athan, subject to further investigation work. Accordingly, in line with the spatial strategy adopted for the RLDP (i.e. focus development around sustainable transport nodes), St Athan was identified as a ‘Strategic Opportunity Area’ to accommodate strategic growth – through the proposed allocation of two key sites : ‘Land at Church Farm’ and ‘Land West of St Athan’. These sites have been identified to deliver 532no. and 600no. units respectively in the Plan period. These are separate to, and are in addition to, the 51no. units that have now been attributed to the site ‘Land South of Clive Road’ in St Athan. Accordingly, in total, the Housing Trajectory makes a provision for a total of 1,183no. homes to be delivered in St Athan over the Plan period.

It is now the case that, subsequent to the publication of the Preferred Strategy, the proposed railway station at St Athan is not in the first phase of delivery for new stations in South Wales. The focus in the first phase of such improvements across the region is towards improving connectivity in east Cardiff, Newport, and Magor. Accordingly,

it is very unlikely that any new train station will be delivered in St Athan over the Plan period, which significantly questions the suitability and acceptability of the proposed allocations set out above.

The strategy to allocate new housing growth is predicated on focusing residential development around sustainable transport nodes, and given that St Athan will be without any railway station in the Plan period, it is not considered that these sites align with the strategy of the RLDP. Accordingly, the wider Housing Trajectory is considered to be unsound, given that a total of 1,183no. homes are expected to be delivered in St Athan within the Plan period.

It is considered that there has been an overprovision for housing growth in St Athan generally, and this issue is now further exacerbated by the lack of any forthcoming rail provision. Given this, to add a further site for housing in this location over and above the original provision is considered to be unsound. As set out above, the justification to allocate sites at St Athan has relied heavily on the railway station being delivered in the Plan period, and as such, there are serious questions marks associated with the acceptability of the proposed allocated sites - given their incompatibility with the core strategy of the RLDP.

We therefore consider the Trajectory to be both unrobust and unsound, and therefore, we object to the Trajectory in its current form accordingly.

Geographic distribution of the ‘new’ sites / provision

As a general and overarching comment in respect to the additional sites now included within the Plan, and forming part of the trajectory, (and a matter expanded upon when critiquing each of these sites in the next section to this submission), it is clear and evident that these additional sites have been positioned to settlements that have already, and recently, been attributed significant growth in the preceding Plan and plan period.

Significant allocations (which have also contributed to significant levels of affordable housing) have been realised and built out in locations (such as Wick and Colwinston). Notwithstanding this, two of the additional sites are now proposed for these recently expanded settlements. Given that the purpose of the affordable housing led allocations is to meet unmet affordable housing need, it is questioned why such new allocations are attributed to settlements that have already seen open market and affordable housing provision, as compared to other comparable settlements that have not received any growth whatsoever over a considerable period of time.

It is considered accordingly that the geographic positioning of these allocations is at odds with their underlying purpose - to meet unmet affordable housing need in communities that have seen no provision

Detailed Comments in respect to ‘new’ sites

Other Housing Allocations

Land south of Clive Road, St Athan

A summary of the Candidate Sites Assessment at Preferred Strategy Stage has been extracted below for ease:


As set out at the outset of these representations, and whilst we note the findings of the Candidate Sites Assessment at Preferred Strategy Stage (i.e. Suitable for further consideration), we do not consider that the consultation on this site has been undertaken procedurally appropriately or suitably. We therefore consider the consultation on this site is “unrobust” and “unsound”.

As set out previously, the strategy seeks to focus development around key sustainable transport nodes. The strategy outlined that a feasibility study for a station in St Athan had been undertaken, which identifies that a new station could be located in St Athan, subject to further investigation work. It is now the case that, subsequent to the publication of the Preferred Strategy, the proposed railway station at St Athan is not in the first phase of delivery for new stations in South Wales, where the focus is towards improving connectivity in east Cardiff, Newport, and Magor. Accordingly, it is very unlikely that any new train station will be delivered in St Athan over the Plan period, which significantly questions the suitability and acceptability of the proposed allocations set out above.

It is considered that there has been an overprovision for housing growth in St Athan generally, and this issue is now further exacerbated by the lack of any forthcoming rail provision. Given this, to add a further site for housing over and above the original provision is considered to be unsound. As set out above, the justification to allocate sites at St Athan has relied heavily on the railway station being delivered in the Plan period, and as such, there are serious questions marks associated with the acceptability of the proposed allocated sites – given their incompatibility with the core strategy of the RLDP.

Affordable Housing Led Allocations Land at Heol Fain, Wick
A summary of the Candidate Sites Assessment at Preferred Strategy Stage has been extracted below for ease:

Candidate Site Stage 2 Assessment (Site Ref. 404)

The findings of the Candidate Site Assessment for this site are noted. We are assuming the reason this site is proposed to be allocated is a product of the site promoters/developers heading the findings stated below, and changing the form of development to be in accord with this:

“A market housing led scheme would not be acceptable, but the site could be reconsidered as a small scale affordable housing led development subject to need and viability at a maximum of 50 dwellings. In accordance with the Settlement Appraisal Review, it is considered that Wick could potentially accommodate limited affordable housing led growth.”

Whilst no clear deficiency exists in respect to the site, it is known that Wick has been subject to significant growth and expansion in recent years – not least by virtue of significant housing allocations in the settlement as part of previous plans.

To evidence this, 35% of the 124 units approved on the ‘Rectory Field, St Brides Road’ site (i.e. circa 43 units as per site allocation ref. MG(47) and PP ref. 2014/01424/FUL) were approved as Affordable Housing units. This makes a substantial provision of such Affordable Housing units (and housing generally) in the settlement in recent years.

Other similarly sized and comparable settlements and locations have not by contrast been subject to any growth for some considerable time, and accordingly would warrant and benefit from provision as part of this new replacement plan.

Notwithstanding the location of such provision, and as set out in detail at the outset of these representations, National Planning Policy advocates the high and acute need for affordable housing, whilst recent analysis evidences that there is a housing emergency. These circumstances - coupled with the shortcomings identified and set out earlier in these submissions in respect to the adequacy of provision within the plan (rolled forward sites / inadequate provision etc) – means that notwithstanding any potential allocation at Wick, further provision ought to be made in comparable (previously unprovided for) locations, such as Ogmore By Sea.

Land West of Maendy Road, Aberthin

‘Land West of Maendy Road’ has been registered as an Affordable Housing Led Allocation candidate site for the RLDP, however as far as we know from our review, there is no assessment and critique of this site. This site has not been included in the ‘Candidate Assessment at Preferred Strategy Stage’ (October 2023). As such, with an absence of publicly available information, it is not clear how the Council has judged this site against the criteria. This raises questions accordingly in respect to the “soundness” of a site which forms part of the intended housing land supply, and by association the trajectory. Without this, and without being consulted on (as others have been prior to this) we question whether this allocation is “sound” (i.e. its allocation is considered to be “unsound”).

Land North of West Winds Business Park, Fferm Goch

The below sets out the candidate site stage two assessment of ‘Land to north and west of Westwinds Business Park’:

Candidate Site Stage 2 Assessment (Site Ref. 398)

As can be seen above the site was not considered suitable for further consideration with the site scoring negatively (red) in a number of key factors. These include the following:

• Access to Retail;
• Access to Health Services;
• Sustainable Transport- Public Transport;
• Access/ Proximity to services and facilities conclusion;
• Climate Change; and
• Health and Wellbeing.

Given the fact the site scores red in ‘Sustainable Transport – Public Transport’, this shows the site is not served by public transport connections within 800m, as outlined in the key below:


Additionally, Policy SP7 (Sustainable Transport) of the Vale of Glamorgan Preferred Strategy states “New development must support an enhanced transport network that increases the proportion of journeys being undertaken by sustainable travel modes”. Additionally Objective 8 (Promoting Active and Sustainable Travel Choices) states “new development is directed to locations that are or can be accessible by a choice of modes of transport, including walking, cycling, and public transport.”

It is well known residents of affordable housing are statistically less likely to own private vehicles, making access to reliable and frequent public transport essential for ensuring equitable mobility. The provision of public transport infrastructure in close proximity to such developments is therefore a critical component in supporting access to employment, education, healthcare, and other key services, while also promoting sustainable travel patterns and social inclusion.

The site also scores red in Access/Proximity to services, showing the site is greater than 1200m away from key services, as seen in the key below:


In respect of the above, Preferred Strategy 6.40 states the need “To ensure that new development takes place in locations that have the best access to a wide range of services, facilities, and employment opportunities, whilst minimising the need to travel, the distribution of growth is guided by the following settlement hierarchy”. To further highlight the importance of both sustainable transport and proximity to services, the preferred strategy also states the need to “Facilitate the development of adaptable, accessible, well-connected communities that have a strong sense of identity, offer a sustainable range of services and facilities and are equipped with adequate infrastructure”. In addition, Promoting Active and Sustainable Travel Choices outlines to “Promote and encourage the use of sustainable methods of travel, particularly active modes of transport, whilst simultaneously reducing the need to travel”.

In light of the above, this site does not align with the aims and targets set out in the Preferred Strategy as it fails to meet several key development goals set out. It should therefore not be considered suitable to be allocated for future developments. Its inclusion is therefore unsound.

Should this view be concurred with, 22 affordable units will be lost from the proposed affordable 122 units, and ultimately will be lost from the overall housing land supply. As stated in the draft housing trajectory “there is a need for small scale affordable housing led development (minimum 50% affordable) to respond to local affordable needs and help sustain services and facilities within these rural communities”. There is a clear possibility therefore that this proposed allocation is removed and/or not delivered as its inclusion is unsound as it does not align with the aims and targets set out in the Preferred Strategy - as it fails to meet several key development goals set out. A “small scale

affordable housing led development” which is needed to “respond to local affordable needs and help sustain services and facilities within these rural communities” will therefore not be provided for. This is clearly an issue.

Land to the East of Colwinston, Colwinston

A summary of the Candidate Sites Assessment at Preferred Strategy Stage has been extracted below:


As outlined above the site was rejected and considered not suitable for further consideration. In fact, and unlike ‘Land at Heol Fain, Wick’ and ‘Land to north and west of Westwinds Business Park’ it was stated that this site “could not be considered as a suitable affordable housing led development site”. Despite this, this site has been outlined as an Affordable Housing Led Allocation. As such, the inclusion of this site is “unsound”.

It is known that Colwinston has been subject to significant housing allocations in the settlement as part of previous plans. To evidence this, 25% of the 64 units (i.e. 16 units) were approved on the site allocation ref. MG2(41) and PP ref.

2014/00242/FUL. This makes a substantial provision of such Affordable Housing units (and housing generally) in the settlement in recent years.

Other similarly sized and comparable settlements and locations have not by contrast been subject to any growth for some considerable time, and accordingly would warrant and benefit from provision as part of this new replacement plan.

Notwithstanding the location of such provision, and as set out in detail at the outset of these representations, National Planning Policy advocates the high and acute need for affordable housing, whilst recent analysis evidences that there is a housing emergency. These circumstances - coupled with the shortcomings identified and set out earlier in these submissions in respect to the adequacy of provision within the plan (rolled forward sites / inadequate provision etc) – means that notwithstanding any potential allocation at Colwinston, further provision ought to be made in comparable (previously unprovided for) locations, such as Land South of A48, Bonvilston.

Summary of These Representations

To re-iterate, and to summarise the case made and set out, these representations seek to object to the Housing Trajectory published as part of the consultation on the Draft Housing Trajectory For Housing Stakeholder Group (October 2025) which underpins the Plan and the delivery / realisation of its underlying strategy.

Detailed submissions and objections are raised above in respect to the trajectory information published regarding the soundness and robustness of this information (and it’s consultation), which we do not consider are adequate, robust, or sound to deliver the Plans aims and objectives.

ANNEX 1
Preface

This Annex sets out the detailed case in support of these representations, and by association the case for allocation of the site.

The representations are structured into the following sections:

1. Response to the Deposit Plan;
2. Comments on specific policies; and
3. A summary of the suitability of the site for development.

SECTION 1. Response to the Deposit Plan

Distribution of Growth

We object to the distribution of growth within the Deposit Plan. Specifically, we object to the strategy that underpins the Deposit Plan, which seeks to introduce the proposed ‘Strategic Growth Area’ which is expected to contain the majority of housing growth in the Vale over the Plan period, or rather the over-reliance on this defined area, and the associated absence of growth in other parts of the Plan area.

As outlined in our previous representations, the allocation of housing and the location of strategic growth neglects the Rural Vale, and in our view, overprovides in the Strategic Growth Area. For example, with limited housing stock and average house sales at over £500,000 over the last 12 months, there is a clear and established need for new homes in the Ogmore By Sea area, particularly at an affordable level. This is reinforced by the Local Housing Market Assessment that identified a need for over 1,114 new affordable homes per annum over the next five years throughout the county, and 196 units per annum thereafter (average of 502 units per annum over 15 years). Further to this, it is widely known that the rural Vale comprises the majority of the county’s ageing population, which, as a demographic, has and will continue to grow rapidly over the Plan period. This is evident in the ‘Population Change’ chart below – which is taken from the Deposit Plan:

VofG Deposit Plan: Figure 4 Population Change 2011 to 2021

It is clearly the case that younger populations are migrating to other Authorities, where access to housing is typically cheaper and more affordable, whilst more older populations are significantly migrating into the Authority. This trend will result in an extremely unbalanced demographic, given that the working-age population have sought housing elsewhere.

Without a suitable supply of affordable housing delivered over the Plan period, this trend will only worsen. Accordingly, it is not considered that the RLDP takes into account the lack of supply of affordable homes within the rural Vale, as well as increased housing to support the growing ageing population within these areas.

Para 3.19 of the Deposit Plan clearly outlines that affordable housing is required in the short term, in order to meet pressing needs. Specifically, it outlines the following: “There is significant pressure on temporary accommodation in the Vale, for a variety of reasons including increased homelessness presentations… The need for sufficient permanent affordable housing to assist in moving people out of temporary accommodation is critical and the planning system has a vital role in assisting in new affordable housing delivery.”
Accordingly, the distribution of growth within the Authority must be proportionate, to ensure that populations / areas are not left behind where they must seek access to housing elsewhere.

The RLDP Sustainable Growth Strategy sets out 6 objectives. Objective 4 states: “Allowing for small scale affordable housing led development in settlements outside the Strategic Growth Area at a scale proportionate to the size of settlement.” (Page 66)
Para 5.25 states “Therefore, a key part of the strategy is to allow for affordable housing led developments within sustainable primary and minor rural settlements outside of the Strategic Growth Area, at a scale that is appropriate to the size of the community it is serving. An ‘affordable housing led’ scheme is one where a minimum of 50% of the dwellings would need to be affordable, although this could increase to a maximum of 100% if the site is brought forward by a social landlord”.

In terms of the definition / explanation of what the affordable housing-led development sites are seeking to achieve, paragraph 6.132 of the Deposit Plan outlines the following:

“Accordingly, to ensure that new developments respond to the high demand for smaller properties, as identified in the LHMA, priority will be given to affordable homes that are small to medium-sized, typically comprising one to three bedrooms. Representations received from the local community through the RLDP process also highlighted a desire for new housing developments to offer opportunities for accessing smaller market homes. This is particularly relevant in the rural Vale, where housing choices are more limited. Providing smaller, more affordable market homes may assist first-time buyers and enable older residents to downsize to more manageable properties within their local area. Affordable housing-led sites will therefore need to demonstrate that an appropriate range of both affordable and market dwellings has been provided.”

Despite the acknowledgement within this strategic objective, we do not consider that the RLDP goes far enough to meet this objective, nor are its provisions and allocations adequate.

It is considered that this objective is undermined by the allocations set out by the RLDP (not least the absence of allocations in the rural Vale). Notwithstanding the Vision’s clear acknowledgement of the benefit of the growth of the rural Vale, these areas have not been supported through the plan due to the lack of growth which has been attributed to these areas in terms of further housing, employment and sustainable transport. All growth options have been selected on the basis of being in either Key Settlement, Service Centre settlement or Primary Settlements, all of which are already sustainable areas served by rail. As a result, it is not clear how this objective can be achieved, without the allocation of further sites within the Minor Rural Settlements, such as Ogmore By Sea. The Vale is characteristically ‘rural’, and as such, there needs to be a stronger emphasis on supporting and delivering new development in order to bolster the rural economy. This includes enabling opportunities to provide employment and business premises within
/ near to rural settlements, as well as focusing housing growth in these areas to reduce travel time, and use of sustainable transport.

It is considered that the current Strategy does not provide adequately for all residents across the Vale, only those within the Strategic Growth Area. The underlying Vision and Objectives set out in the emerging Plan are accordingly wholly un-provided for by the detail of the Plan. This brings into question the “soundness” of the Plan.

The Strategic Growth Area does not take into account the important role and proximity of Bridgend to the West and/or the Principal Settlement and Strategic Growth Area of Talbot Green / Pontyclun / Llantrisant to the north (as defined in the RCTCBC LDP). The Minor Rural Settlements to the west are more likely to be supported by job opportunities and employment in Bridgend than further east in Barry or Cardiff. Similarly, those in the north align with, and function in association with, the Principal Settlement and Strategic Growth Area of Talbot Green / Pontyclun / Llantrisant to the north. These settlements are served by existing bus services that provide sustainable modes of travel to key employment locations in and around Bridgend. This is acknowledged in Paragraph 3.3 of the Strategy which states “The greatest number of residents who travel outside of the Vale for work purposes travel to Cardiff followed by Bridgend and Rhondda Cynon Taf, whilst a smaller proportion commute into the Vale from these neighbouring authorities”. The Demographic Evidence (Feb 2023) estimates the Vale as being a net importer of workers from RCT and Caerphilly (Para 3.6) - as shown in Figure 10 in the Preferred Strategy.

The current Strategy does not support any improvement of sustainable travel or further investment in settlements linked more closely to these areas - given that Growth has been apportioned in only the Key Service Centre and Primary Settlements. It is considered that this will fail to support and facilitate the current (and any future) employment coming into the Vale, nor will it support any employment which is located outside of the Vale to the West and North. The Growth Option is too heavily reliant on access to railway stations as the key and sole sustainable transport method, whereas access to bus services should also be appropriately assessed and focused on in terms of promoting sustainable development. It is unreasonable to devise a strategy that hinges on directing growth to areas that are accessible to railway facilities, where it is recognised in the Plan that the Vale is inherently rural. The delivery and soundness of the Plan is therefore questioned and we continue to object to the spatial growth strategy as set out in the Deposit Plan.

Housing Supply

RLDP Allocations - Key Sites

As set out in representations made throughout the Plan preparation process, we consider that the Plan is too reliant on the delivery of ‘key sites’ to meet the housing need over the Plan period. Specifically, the Plan makes provision for 2,278 units in these Key Sites, which equates to circa 65% of RLDP allocations in the housing supply. The 5 key sites that are allocated in the Deposit Plan are as follows:

• Land at North West Barry – 376no. units;
• North of Dinas Powys – 250no. units;
• Land at Readers Way, Rhoose – 520no. units;
• Land at Church Farm, St Athan – 532no. units; and
• Land to the West of St Athan – 600no. units.

We object to the current housing supply to allocate 2,278no. (65%) of units across strategic sites, as this makes for a risky and unrobust strategy for delivering housing, and in turn, meeting the identified housing need over the Plan period.

As stated in previous representations, there is concern that the proposed timing and phasing of the proposed Key Sites is unrealistic and unrobust, and in turn, undermines the soundness of the Plan, given the heavy reliance on Key Sites delivering new homes across the Plan period. Whilst it is not disputed that the sites would have gone through rigorous assessment to inform their proposed allocation, the timescales for securing planning permission (with all associated conditions discharged) is considered to be unachievable. This is particularly the case for the following timescales that are set out in the Housing Trajectory that underpin the Plan:

• “Time period of pre-application discussions/PAC consultation” – 4 months

• “Time between submission of planning application and determination” – 6 months
• “Time taken from planning consent to the discharge of relevant conditions to enable site construction” – 4 months

It is considered that the above timescales are fundamentally unrobust, and result in a distorted position of housing sites over the RLDP Plan period. It is not considered that these reflect or are informed by the timescales that are currently being incurred for planning applications submitted for major housing sites across Wales. It is rather the case that such applications would typically be determined 1-2 years following submission, given that there are a wide range of stakeholders involved in the determination of major planning applications – which often adds to the delays associated with the determination of such applications.

It is equally the case that the assumptions in the trajectory are solely based on expected timescales for processing formal submissions made to the Council, and do not factor in the timescales associated with, and needed for, the preparation of the material for submission.

It is assumed that these timescales have not considered that such major developments can be subject to the need to undertaking and submitting an Environmental Impact Assessment (EIA), which adds another layer to the determination of any planning application – given the additional considerations that form part of this process. As such, any site subject to EIA would very likely result in further delays extending beyond the timescales set out in the trajectory. Equally, as set out above, the preparation of an application subject to an EIA requires even more detail and assessment, which only further adds to the preparation stage (which has not been factored into as part of the trajectory). Accordingly, it is not considered that the trajectory contains any contingency if any site is required to undertake EIA as part of their application.

For the reasons stated above, it is unlikely that the sites will yield in full, particularly those sites which are expected to deliver housing right up to the final year of the Plan period (‘Land at Readers Way’ and ‘Land to the West of St Athan’). These sites do not allow for any ‘slippage’ should any delays arise through the development management process (which for the reasons set out above, will very likely be the case), and as such, a gap in housing delivery will be brought about as a result of these sites not yielding in full.

Given the proposed ambitious timescales set out for the delivery of the Key Sites, it is considered the housing trajectory is unrobust, and in turn, undermines the soundness of the Plan as a result. A change in strategy should be pursued whereby a greater proportion of small to medium sites are allocated for housing in the Plan period, which are more likely to fully yield given that such sites are subject to less assessment and consideration compared to strategic sites. This would make for a more robust strategy, where a greater number of small to medium sites can deliver housing in the short and medium term of the Plan period, whereas the strategic sites represent a more longer-term strategy to deliver housing – which would then spill into the next Plan period.

Accordingly, we object to the Deposit Plan in its current form, where there is an overreliance on housing need to be met through the delivery of the Key Sites, which we consider to be unrobust, and undermine the integrity and soundness of the Plan. The current strategy of the Plan is at significant risk of not delivering the level of housing expected based on the sites allocated, as least as swifty as identified in the housing trajectory. Should no change be made to the Plan to address the above issues, then it is extremely likely that the Plan would ‘fail’ in meeting the identified housing need.

Windfall Sites

It is noted that the RLDP is made up of the following:

• Existing land supply (3,838 units)
• Windfall sites (1,303 units)
• Allocated sites (3,521 units)

Para 6.69 states that “Analysis of historical delivery of housing indicates that on average small windfall sites (sites of less than 10 dwellings) have provided some 53 dwelling completions per year, and large windfall sites (10 dwellings or greater) contributed on average 80 dwellings per year. Overall, it is projected that windfall sites could contribute a further 1,303 dwellings over the remainder of the plan”.

As set out in our previous representations to the Housing Trajectory, we would object to the expected numbers of completions expected during the Plan period, given that there are a number of issues with delivering housing in Wales and given past completions rates for The Vale of Glamorgan – which is discussed in greater detail later in this submission. Again, this results in the Plan being at risk of not delivering the level of housing expected based on the sites allocated – including any windfall sites.

St Athan Train Station

The RLDP Sustainable Growth Strategy comprises six key elements, of which the following is set out in respect to the allocation of new housing growth in the Authority:

“3. Focusing development at locations that are well served by existing and proposed rail stations as part of the South Wales Metro and in areas with good bus links.”

The strategy outlines that a feasibility study for a station in St Athan had been undertaken in 2022, which identifies that a new station could be located in St Athan, subject to further investigation work. Accordingly, in line with the spatial strategy adopted for the RLDP (i.e. focus development around sustainable transport nodes), St Athan was identified as a ‘Strategic Opportunity Area’ to accommodate strategic growth – through the proposed allocation of two key sites : ‘Land at Church Farm’ and ‘Land West of St Athan’. These sites have been identified to deliver 532no. and 600no. units respectively in the Plan period. These are separate to, and are in addition to, the 51no. units that have now been attributed to the site ‘Land South of Clive Road’ and 80no. units attributed to ‘Former Stadium Site, adjacent to Burley Place’ in St Athan. Accordingly, in total, the Housing Trajectory makes a provision for a total of 1,263no. homes to be delivered in St Athan over the Plan period.

It is now the case, however, that the proposed railway station at St Athan is not in the first phase of delivery for new stations in South Wales – as confirmed in the ‘Today, Tomorrow, Together: A vision for rail across Wales and Borders’ (February 2026) recently published by Transport For Wales. This paper acknowledges that a new railway station at St Athan would represent a longer term opportunity, and therefore, will not be delivered in the short term / within the Plan period of the emerging Plan. Equally the Council have not provided any evidence to contradict this, and therefore, it is very unlikely that any new train station will be delivered in St Athan over the Plan period. This brings about significant questions regarding the suitability and acceptability of the proposed allocations set out above.

The strategy to allocate new housing growth is predicated on focusing residential development around sustainable transport nodes, and given that St Athan will be without any railway station in the Plan period, it is not considered that the sites align with the strategy of the RLDP. Accordingly, the wider Housing Trajectory is considered to be unsound, given that a total of 1,263no. homes (36% of the Plan’s new housing allocations) are expected to be delivered in St Athan within the Plan period.

It is considered that there has been an overprovision for housing growth in St Athan generally, and this issue is now further exacerbated by the lack of any forthcoming rail provision. Given this, to add further sites for housing in this location over and above the original provision is considered to be unsound. As set out above, the justification to allocate sites at St Athan has relied heavily on the railway station being delivered in the Plan period, and as such, there are serious questions marks associated with the acceptability of the proposed allocated sites - given their incompatibility with the core strategy of the RLDP.

In terms of the expected delivery of the Key Sites in St Athan, it is noted that the trajectory identifies that for the majority of the Plan period, both sites will be delivering 80no. dwellings per annum on each site (equating to 160no units in total). Whilst these are two separate sites, we seriously question the realistic prospects of the significant number of

homes being built simultaneously on two sites in proximity to one another – given the considerable logistical issues that would be brought about.

Accordingly, it remains that there are serious questions regarding the suitability and acceptability of the proposed allocations at St Athan, which do not accord with the strategy adopted for the RLDP – to focus housing growth on settlements that are supported by railway stations. Moreover, the scale of development proposed at St Athan is also not considered to be proportionate, with a significant number of homes delivered in a location not served by a railway station.

Rolled forward LDP Sites

The proposed land supply within the housing trajectory includes provision for ‘rolled forward’ LDP sites, which contribute to the total of ‘Proposed Additional Housing Allocations’ forming part of the housing supply. Specifically, a total of 1,242no. units have been identified as additional housing allocations, of which 959no. are expected to be delivered on the rolled forward LDP sites. As such, these sites are to provide for a significant proportion of additional housing in the Plan period (specifically circa 77%).

The Development Plans Manual (DPM) sets out that allocations rolled forward from a previous plan will require careful justification for inclusion in a revised plan. The DPM outlines that “there will need to be a substantial change in circumstances to demonstrate sites can be delivered and justify being included again. Clear evidence will be required that such sites can be delivered.” The below table included in the consultation document provides a breakdown of the rolled forward LDP sites, and in particular, sets out the status of each site:


The above table evidences that the current LDP has under delivered in regard to its targeted unit number of the Plan period, given that these sites did not yield any housing over the current Plan period. This is further exacerbated by the Land Bank sites that have also not delivered any housing across the existing LDP period, amounting to 1,860no units. Accordingly, when considering the non-delivery of both rolled forward LDP sites and Land Bank sites, this amounts to an approximate shortfall of 2,189 homes being delivered, or 33% of the total housing supply identified for the current LDP (8,525no. dwellings).

It is therefore considered that, as a minimum, the units carried over from the LDP (without planning permission) should be a surplus to the housing supply proposed for the RLDP, as opposed to being relied on to deliver the housing need over the Plan period. This is particularly the case for the two sites (Land to the west of Pencoedtre Lane, and Land between Northern Access Road and Eglwys Brewis Road) which do not currently have any active planning application

submitted for their development. These sites total an amount of 370no. units to be delivered in the Plan period, which represents more than a third of the additional housing allocations to make up the housing supply.

As such, it is considered that the unmet need deriving from the existing LDP is still present – indeed it has grown, and will continue to do so, not least when considered in conjunction with the projected population growth over the coming years to 2036, and the aspirations for growth in the Plan’s strategy.

Accordingly, in order to secure the targeted level of housing, a greater level of provision for new allocations should be applied in order to meet the housing requirement. This would bring about better certainty that the housing requirement is met by the housing supply over the Plan period, not least given that the current Plan failed in this respect. Without a re-apportioning of the housing supply, it is considered that the Plan would heavily rely on the contingency (i.e. rolled forward LDP sites) coming forward in the Plan period, yet there is uncertainty that these will yield in full over the new Plan period. This raises issues of ’soundness’, and risks rendering the Plan unrobust.

Housing Delivery Rate Assumptions

As set out in our previous representations to the Housing Trajectory consultation, we have considerable concerns in relation to the proposed delivery of the sites identified in the trajectory – which we do not consider are robust or reasonable.

Appendix 1 of the Deposit Plan sets out the development trajectory bar chart – which illustrates the proposed delivery of housing, on a per annum basis, over the Plan period.

Extract of Housing Trajectory Graph (annotated by GJP – red dotted line)
It is our view that the trajectory makes for an unrealistic and unrobust delivery rate of housing, which does not reflect the pattern of housing completions in the Vale of Glamorgan. We therefore have concerns regarding the soundness of the trajectory, not least that there remain significant uncertainties as to the delivery of the Key Sites (as discussed earlier in these representations).

Firstly, the graph / trajectory illustrates a large ‘spike’ in terms of housing delivery in the year 2027-28, which is considered to be a marked and pronounced step change in the rate of delivery. This envisages / relies on a significantly higher rate of delivery than previous years in the Vale of Glamorgan (2021 through 2021 – as depicted by the green columns). It is considered that this level of delivery is unlikely to materialise, not least given prevailing market

circumstances, past rates of delivery on the ground, and also in light of levels achieved across Wales and the UK in general.

The published trajectory shows that the average level of completions from 2021 - 2025 has been approx. 400 - 500 units, however, the chart shows that from 2027 – 2028, completions are expected to rise to approx. 1,000 units per year. The expected delivery levels in the trajectory therefore show and assume a doubling in delivery rates and unit numbers (an increase of approx. 100% relative to past rates). There is no clear evidence as to how this level of completions can be achieved let alone guaranteed. This is the case in particular given that the forthcoming years (2025-2027) are expected to see performance (yield) drop significantly (delivery rates in 2025 – 2026 and 2026 – 2027). The chart shows only approx. 200 units being delivered over these years. It is therefore unclear how completion rates are expected to rise so quickly (from 200 in 2025-26 to 1000 in 2027-28), and by such a significant amount. The assumptions in the trajectory are wholly unrobust in our view.

It is also the case that the anticipated delivery of housing fails to be consistent within and across the Plan period. It is unclear as to why completions rates aren’t spread out more evenly throughout the Plan period - to ensure a robust and most realistic housing trajectory until 2036. By comparison to the marked increase in the rate of delivery between and over the period 2027 to 2031, there is then a marked fall-off or drop in delivery towards and by the end of the Plan period. Indeed, in the final year, the level of completions are expected to be lower than the period 2021-2025.

Accordingly, we consider that the housing trajectory, as proposed, is entirely manufactured and unreflective of the past completion rates, as well as the recent published completion rates provided by Welsh Government recently in August 2025. As set out in our previous representations, it has been evidenced that there has been a general decline in the number of new dwellings started and completed.

Description of Figure 1: ‘New House Building: April 2024 to March 2025’
As identified in the graph above, in 2024-25, 4,631 new dwellings were completed, which represents 3% fewer than the previous year. This figure represented the second lowest number on record, with the lowest number recorded in 2021-22, a year heavily affected by the coronavirus (COVID-19) pandemic (in 2021-22, 4,616 new dwellings were completed) The New Housing Pipeline Report Quarter 3, 2025 Report (December 2025) published by the HBF evidenced that the number of residential units approved in the UK fell by 7% during the third quarter of 2025, extending the decline seen during the first half of the year. At 45,075, the number of units approved was 34% down on the third quarter of 2024 and the lowest quarterly total since 2012 Q2. At 146,798, the overall number of units approved during the first nine months of 2025 was 25% lower than a year ago.



HBF Graph Illustrating Residential Approvals (2006-2025)

The above graph clearly shows a pronounced downward trend in the number of residential planning approvals over the period, particuarly with a sharp decrease seen since 2020. Further, the HBF document ‘Increasing Housing Supply in Wales’ (4th September 2025) clearly shows that The Vale of Glamorgan has not met the housing delivery requirements in recent years in 2023 – 2024 – along with every other authority in Wales (except Newport). Accordingly, this further adds to the argument that historically The Vale (and most other authorities) have underprovided. This adds considerable uncertainty on the assumed transformation in yield and delivery as built into the trajectory.

Graph: Housing Delivery as a proportion of annual housing requirement in Wales per Authority

More recently, the Welsh Government has released its new estimates of housing need (Estimates of Additional Hosing Need: 2025-based – February 2026). The estimates show how many new homes need to be built over the next twenty years to address existing unmet need as well as newly arising need. The figures set out that around 8,700no. new homes a year are needed over the next Senedd term up to 2030 to meet new housing need. Additionally, there is an unmet need for 9,400 affordable homes.

Overall, this represents more than double 2024/25 levels of supply, where just 4,638 new homes were built.

HBF: Estimates of Housing Need

HBF: Actual Delivery vs Estimates of Need

The above graphs unequivocally evidence that historical rates of delivery of housing in Wales has remained low, and moreover, significant numbers of housing need to be allocated in order to meet the estimate of need. It is not

considered that the housing trajectory, in its current form, is robust to meet the housing need over the Plan period, given the uncertainties of the Key Sites, and the level of housing delivery that has been identified for the Plan.

Affordable Housing-Led Sites

HG4 - Rural Affordable Housing Led Sites

Policy HG4 of the Deposit Plan identifies four sites to be allocated as affordable housing-led sites, totalling approximately 122 dwellings within the plan period. Given the target levels of achieving 3,070 affordable dwellings over the course of the Plan period (up to 2036), it is not considered that this policy goes far enough to address the target and level of affordable housing need.


It is noted that the number of units identified for each site relate to the ‘total’ number of units delivered, as opposed to the affordable housing provision. Accordingly, it can be assumed that circa 50% of each allocation will comprise affordable units (given each site is affordable-led), which would equate to a total provision of circa 61no. units. The contribution from the affordable housing-led sites would only equate to 2% of the total need (3,070no. units). Even when coupled with the affordable housing provision from open market sites and 100% exception sites, the total delivery of affordable housing will still be nowhere near enough to meet the overall affordable housing need over the Plan period. Accordingly, it is considered that inadequate provision has been made for such sites.

Insofar as to the sites chosen and allocated are concerned, it is clear from reviewing the Stage 1 and Stage 2 Candidate Site Assessment that the allocated sites HG4(1) – (4) were not considered acceptable due to being outside the strategic growth areas, and were considered to be unacceptable intrusions into the open countryside. After being resubmitted as affordable housing-led sites, the sites were allocated, some with a smaller area in order to accommodate less dwellings in total.

The sustainable credentials of the sites allocated is not disputed, and it is acknowledged that these minor rural settlements have the ability to accommodate further growth, in the form of affordable-led housing allocations. However, it is considered that the should also form an allocation as part of this policy, given its high sustainability credentials and its appropriate location to accommodate a suitable level of development. Please refer to the previous representations made to the Housing Trajectory Consultation (dated 17th October) for further, more detailed comments regarding the above sites.

The LHMA 2023 shows that there is a need for 124 affordable homes in the St Brides Major local housing market area (which Ogmore is located within). As such, there is an identified need for affordable housing in this area, something which the site could address through an allocation.

It is questionable whether Wick has the capacity to accommodate 50 new dwellings, given the sustainability and rural nature of the area. As a result, it is suggested that the number of homes allocated in Wick is reduced and that a further allocation in St Brides Major is secured, in order to facilitate supporting the delivery of affordable housing through the housing market area, rather than in one minor rural settlement. The sustainability of Ogmore has been assessed, both by the Council through the Sustainability Appraisal and again, through our assessment of the site.

Securing further delivery of Affordable Units

As set out above, the affordable housing-led allocated sites only provide 122no. affordable dwellings, which comprise 4no. allocated sites that are expected to deliver approximately between 20 – 50 dwellings. However, the RLDP sets a

target of 3,070 affordable homes to be delivered in the Plan period. This means that affordable housing-led allocations make up less than 4 % of the target provision and will only make provision for 2% of the targeted number. We would therefore object to the sites included within Policy HG4 and would suggest that more sites should be allocated as part of the policy in order to secure delivery of a higher number of affordable housing units to mere the target.

Whilst it is acknowledged that the Key Sites will provide for a significant proportion of affordable housing, as set out above in these representations, there is serious concern regarding the deliverability of these sites, which would result in a significant gap of affordable housing delivered.

A greater number of affordable housing-led sites allocated would ensure there is sufficient contingency built into the Plan, to ensure that the overall affordable housing need is met over the Plan period. Failure to do so would result in affordable housing need being unmet, with demand continuing to outstrip supply.

Previous representations to the Preferred Strategy (dated 14th February 2024) provided comment on the sustainability scoring of Ogmore and the proposed site. As outlined within these representations, it is considered that the site (ID xxx) represents a sustainable, deliverable and acceptable site. The site is within a maximum of a 22- minute bus journey to a every key service listed, due to the proximity of the site to settlements such as Bridgend. Due to the availability of frequent bus services, and active travel links, these key services are readily available to access for any residents within Ogmore By Sea without the need to travel by car. The site is located within 5 miles of Bridgend, and within a maximum 22-minute bus journey of the following services:

• St Brides Primary School;
• Brynteg Comprehensive School;
• Bridgend College;
• Riversdale Surgery; and
• Bridgend town centre for various Retail Services

Moreover, Ogmore has benefitted from the recent development of the Ogmore By Sea Village Hall, which provides space for community activities and events to take place. The hall also includes a coffee shop (Welsh Coffee Company), which only adds further to the daily services provision available within the settlement. Access to the hall and coffee shop is directly provided for pedestrians from the Main Road, which allows for direct access from the site.

Accordingly, the settlement of Ogmore represents an acceptable location to allocate an affordable housing-led site, given the access to existing services and facilities that would serve future residents of the site.

It is acknowledged that the site also lies within the Glamorgan Heritage Coast and this point is addressed further below.

To conclude, the settlement, location and site are inherently suitable and deliverable, and will make a significant contribution to achieving and realising the housing and economic development needs of Ogmore By Sea, support the surrounding settlements, and the Plan area as a whole. As such, the site should be considered further.

Comments on Specific Policies

HG5 - Affordable Housing Exception Sites

Given the unmet need and extant backlog of affordable housing, as identified within the LHMA (2023), it is noted that an Affordable Housing Exception Sites policy has been adopted in order to assist in the delivery of affordable housing. Policy HG5 sets out the specific criteria where proposals for 100% small scale affordable housing developments will be permitted outside settlement boundaries. The current policy wording for the Affordable Housing Site Exception Policy and the criteria listed out in the policy is generally supported.

That said, it is noted that a ‘cap’ of 10 dwellings (as referenced within supporting text Para 6.140) is set. This should be amended due to such a ‘cap’ limiting the flexibility of the policy, in particularly for sites coming forward as part of this policy in Minor Rural Settlements.

As such, we would suggest that supporting Para 6.140 should be amended in order to allow for further flexibility for sites in Minor Rural Settlements to come forward and to deliver affordable housing, given that the criteria set out in the policy would already protect and restrict the extent of any development as it stands. Therefore, the proposed amendments to Para 6.140 are outlined below in red:

6.140 “For the purposes of this policy, ‘small-scale’ will generally mean no more than around 10 dwellings on sites adjoining Minor Rural Settlements. In Primary Settlements outside the Strategic Growth Area, proposals for more than 10 dwellings may be acceptable where required to meet a specific need and where the number of dwellings is proportionate to the size of the settlement. In assessing the scale and extent of any proposed local needs housing, consideration should also be given to affordable housing already planned in the ward or nearby area, including sites with existing planning permissions and those allocated in the RLDP. The size and type of affordable housing proposed should reflect the identified local need in the area.”

The above suggested wording would achieve a more flexible policy, which would allow for a variety of scaled applications to secure planning permission for solely 100% affordable housing across the Authority area. This greater flexibility would enable the policy to make a significant contribution towards meeting the affordable housing need – which, as set out earlier is in considerable need.

Policy DNP3 – Glamorgan Heritage Coast

Given that the site is located in the Glamorgan Heritage Coast, it is noted that the following policy is of relevance to any future development on the site. Criteria 4 of Policy DNP3 states:

“The special environmental qualities of the Glamorgan Heritage Coast will be conserved and enhanced. New development will be restricted to:
4. Other appropriate and sustainable development that accords with National Policy.”
It is also noted that supporting Para 6.422 “In seeking to protect the Glamorgan Heritage Coast, the Council acknowledges that there are some built up areas within the boundary, including the Minor Rural Settlement of Ogmore. In addition, the Vale of Glamorgan rail line crosses part of the Heritage Coast designation in the location where a new station at St Athan is proposed. Whilst being mindful of the need to protect the special qualities of the Glamorgan Heritage Coast, the Council accepts that development within these areas is appropriate, subject to relevant policies of the Plan”(GJP emphasis).

We would offer general support for this policy, and consider this to provide flexibility which allows for certain forms of development. However, we would suggest that the policy wording should be amended to reflect that ‘housing’ should be supported in the Glamorgan Heritage Coast, providing that the policy exceptions are met. Therefore, the following amendment is proposed as part of the policy should be changed to include “small scale housing” or something similar. The proposed amendments to Policy DNP3 are outlined below in red:

“The special environmental qualities of the Glamorgan Heritage Coast will be conserved and enhanced. New development will be restricted to:
4. Other appropriate and sustainable development, including small-scale housing proposals that accords with National Policy.”

Again, this would ensure that suitable housing developments can be delivered in the Plan period, to meet the housing needs of the Vale of Glamorgan – particularly in respect of affordable housing.

SECTION 3. Suitability of the site for development

The site promoter objects to the overall assessment of the site, in that it is not considered suitable for further development in the Plan. The promoted site has undergone extensive scrutiny and appraisal at a high level to ascertain the qualities of the site, in light of all identified material considerations which relate to the proposals.

The delivery of the site will yield much needed housing (including Affordable housing) and contribute to the overall supply in the new Plan period, whilst making effective use of a suitably located site for residential development.

Moreover, as set out in ‘Annex 2’ of our representations, the site has overcome the ‘constraints’ set out in the Candidate Site Assessment undertaken for the site, which demonstrates that the proposal is both acceptable and deliverable.

SUMMARY AND CONCLUSIONS

In summary, the site promoters:

• Object to the distribution of growth proposed for the Plan area, with a more balanced and equitable distribution of housing sites required in order to meet the identified housing need;
• Object to the level of growth identified for the Plan period;
• Object to the housing trajectory that underpins the delivery of housing within the Plan period – which is considered to be unrealistic and unrobust, leading to serious uncertainty regarding the “soundness” of the Plan;
• Object to the over-reliance on Key Sites and Rolled Forward Sites in making up the Plan’s housing land supply;
• Object to the scale and timing of delivery of sites in / around St Athan – all of which are predicated on railway station provision which will not be realised in the Plan period;
• Object to the under-provision of sites under Policy HG4 – Rural Affordable Housing-Led sites, not least given their extremely limited contribution to the targeted need for affordable housing;
• Object to Policy DNP3 – Glamorgan Heritage Coast, given the lack of recognition for the potential for small-scale housing proposals;
• Object to the current wording of the HG5 Policy ‘Affordable Housing Exception Sites’ which requires greater flexibility to play an important role in delivery much-needed affordable homes across the Authority; and
• Object the Council’s assessment that the site is not considered suitable for development.

The site and proposals are consistent with the RLDP strategy, other Vale of Glamorgan strategies, and the requirements of Planning Policy Wales and Future Wales. It will make a significant contribution to the Vale’s identified housing requirement in the RLDP period and will provide for a wide range of uses that will support the wider community whilst embodying principles relating to placemaking and the well-being of future generations.

The site has no fundamental constraints and has the ability to deliver significant economic, social and environmental benefits for the benefit of future residents and the existing local community. The site is demonstrated to be viable, being able to deliver policy-compliant levels of affordable housing and given its location within a strong market area, will benefit from high delivery rates.

ANNEX 2
SECTION 4. A summary of the suitability of the site for development including a Response to the Candidate Site Assessment

This section of the overall representations to the Deposit Plan is to respond to, and address, the Council’s assessment of the site.

While the issues the Council have raised in their assessment of the site have been addressed and discussed within the representations made at the Preferred Strategy stage of the Plan, a similar ‘scoring’ exercise has been undertaken as part of the evidence base for the Deposit Plan. As such, it is still pertinent to consider and respond to the Council’s assessment of the site as part of these representations

The Detailed Site Assessment for Land at Hazelwood, Ogmore By Sea (Site ID: 3855) sets out that the position of the site at the Deposit Stage is as follows:

“The original site as ruled out as the development would represent unacceptable intrusion in to the open countryside. Whilst the site has now been identified for an affordable housing led development, the original reason for ruling it out still remains.”
In terms of the assertion that “the development would represent an unacceptable intrusion into to the open countryside”, this is strongly disputed, in that the development of the site would represent a natural rounding off of the existing settlement boundary. An extract of the site relative to the settlement boundary is provided below, which clearly shows that the development of the site would not extend beyond the existing settlement pattern that exists in Ogmore.

Site Outlined in Red and Settlement Shaded in Blue
As clearly demonstrated in the above mapping, the site would extend no further eastwards than the existing housing area to the south of the site. Equally, the site would not be extending any further north than the existing settlement pattern in Ogmore. This position is further supported by the wider aerial view of the site provided overleaf:



Wider Aerial View of Site Outlined in Red and Settlement Shaded in Blue

In summary, it is considered that the proposed allocation of the site represents a logical rounding off of the existing settlement, as depicted in the mapping provided above – where the site follows the existing envelope of the settlement. The site does not extend any further eastwards than the established built form located immediately to the south; indeed, it sits comfortably within the same development line.

As such, it cannot be considered that the site represents an ‘intrusion’ into the countryside, as the site would be visually and functionally related to the settlement. It therefore follows that the site would be read as part of the settlement, and not the wider rural landscape.

Candidate Site Assessment

The Detailed Site Assessment undertaken by the LPA includes a summary and assessment of the ‘scoring’ system used at the Preferred Strategy stage. A comparison between the site assessments undertaken at both the Preferred Strategy stage and Deposit Plan stage is provided overleaf for reference.



Site Assessment at Preferred Strategy Stage Site Assessment at Deposit Plan Stage
As demonstrated above, there are no changes to the scoring attributed to the site. Detailed submissions were made on the previous assessment undertaken by the Council at Preferred Strategy stage, and as such, should be read in conjunction with this submission (see Appendix A).

Sustainability

Notwithstanding the above, it is considered that the site represents a more sustainable location than what was previously assessed at Preferred Strategy stage, in light of the Ogmore by Sea Hall development. The Hall acts as a community facility, whereby the space is available for hire by local community groups such as birthday parties, weddings, group meetings, and other such similar uses. Moreover, a café (Welsh Coffee Co) is located within the premises which sells both food and drink.

The hall and café are within walking distance to and from the site, where new access facilities have been implemented from Main Road directly to the building, to allow access for pedestrians and cyclists. This is illustrated in the image below:

Walking and Cycling Facilities

The Tusker Rock pub and post office are also located along Main Road, all of which are within walking distance to the site.

Accordingly, the site is well served by new amenities (i.e. community hall) that comprehensively improves the sustainability of the site / settlement, and in turn, improves the sustainability credentials of the site promotion. It therefore follows that the site represents an acceptable location for residential development, and the site should be looked upon favourably accordingly.

It is also the case, as set out in previous representations, that the site is within a maximum 22-minuted bus journey of the following services and facilities:

• St Brides Primary School;
• Brynteg Comprehensive School;
• Bridgend College;
• Riversdale Surgery; and
• Bridgend town centre.

As such, key services and facilities can be access by sustainable travel over and above the existing level of provision available in Ogmore By Sea (as discussed above).

Accordingly, the relevant ‘red’ scorings in the Council’s assessment should be updated to reflect the site’s suitability and sustainability to accommodate the proposed residential development of the site.

Glamorgan Heritage Coast

Insofar as to the position regarding the site’s location within the Glamorgan Heritage Coast, detailed submissions are made not only in the Preferred Strategy representations, but also in Annex 1 of this submission. In short, given the pressing need for such development (particuarly affordable housing) to come forward in the Plan period to meet ever-increasing needs, development of this nature should be considered more favourably – not least that, as outlined in this Annex, the site would not extend any further that the existing settlement boundary.

Accordingly, the site would be perceived to form part of the settlement of Ogmore By Sea, and not the wider landscape, and therefore, would not have any detrimental impact on the Heritage Coast in any respect. The scoring should be amended accordingly to reflect this position.

Climate Change

As outlined in previous representations, the development will incorporate climate change measures, such as EV charging points, PV panels, as well as adopting sustainable materials for construction whilst maximising the potential for the dwellings to be energy efficient. Accordingly, the development will be built to high sustainable standards, and therefore, the scoring of the site should be amended as a result.

Summary and Conclusion

It has been evidenced above that there are no fundamental constraints at, or associated with the site, that would preclude the site coming forward for development in the RLDP period.

To conclude, the settlement, location and site are inherently suitable and deliverable, and will make a significant contribution to achieving and realising the housing and economic development needs of the Vale of Glamorgan.

Summary of These Representations

In short, and to summarise the case made and set out, these representations seek to object to the Housing Trajectory published as part of the consultation on the Draft Housing Trajectory For Housing Stakeholder Group (October 2025) which underpins the Plan and the delivery / realisation of its underlying strategy.

Detailed submissions and objections are raised below in respect to the trajectory information published regarding the soundness and robustness of this information (and it’s consultation), which we do not consider are adequate, robust, or sound to deliver the Plans aims and objectives.

Preface

This Submission sets out the detailed case in support of these representations. The representations are structured as follows:

1. Procedural Consultation Matters;
2. Timing Assumptions underpinning the Trajectory;
3. Housing Delivery Rate Assumptions;;
4. Status & Standing of Sites included in the Trajectory;
5. Key Sites;
6. St Athan Train Station;
7. Geographic distribution of the ‘new’ sites / provision;
8. Detailed comments in respect to ‘new’ sites;
9. Conclusions Procedural Consultation Matters
Firstly, we do not consider that the consultation on the Housing Trajectory information has been procedurally undertaken appropriately or suitably.

Only 14 days have been afforded to parties to make representations on the information provided. This is despite new sites being introduced (at this late stage) i.e. Land South of Clive Road (identified in Table 4), as well as a number of affordable housing led housing sites being introduced (i.e. those outlined in Table 5). This does not provide an adequate process or timescale for objectors to scrutinise the published content, and to make comments on sites which have been presented for the first time at a late stage in the process.

As part of these representations, we will be making brief comment on the sites which have not been previously consulted upon, namely:
Other Housing Allocations
• Land south of Clive Road, St Athan;

Affordable Housing Led Sites
• Land at Heol Fain, Wick;
• Land west of Maendy Road, Aberthin;
• Land Noth of West Winds Business Park, Fferm Goch; and
• Land to the East of Colwinston;

It is considered necessary to comment on these sites, given that they form an important and critical part of the housing trajectory, and by association in the Council and Plan reaching their targets. Moreover, these sites have not been consulted on previously. Accordingly we consider it necessary to pass comment on these in order to ensure that the consultation is fair and robust.

As well as limited time given to comment on the information contained within the Housing Trajectory, the LPA have failed to set up a Housing Stakeholder group to agree and discuss the trajectory information and data – with the cover email to the consultation (dated 3rd October 2025) stating “it is considered that it would be the best use of stakeholder time to conduct this engagement via email, particularly as many of the forecasts have been developed in consultation with site promoters including developers and their agents”.

We submit that the stakeholder consultation has not been a transparent nor robust consultation process, given that the Development Plans Manual states at Para 5.66 “A housing trajectory must be prepared to support the Deposit Plan. In order to generate a housing trajectory and associated phasing tables it will be necessary for LPAs to engage with stakeholders through a Housing Stakeholder Group. This will ensure that the timing and phasing of sites is robust and based on up to date information”. Given that this has not taken place, we would raise fundamental concerns that the consultation of the trajectory has not adequately taken place as per the relevant guidance. Afterall, the guidance stresses that a Group should be formed as a necessity. Accordingly, there has not been an adequate process and opportunity to review and comment on the information published, including in respect to the other sites have been introduced at this late stage.

Timing Assumptions underpinning the Trajectory

The assumed and factored in timescales of the various stages of bringing forward sites i.e. the pre-application stage, the planning application process, and the discharge of condition process outlined in the trajectory are considered to be fundamentally inaccurate, and result in a distorted position of the delivery of housing sites over the RLDP Plan period. The assumptions are far too ambitious, and without evidence / are not comparable with the timescales being incurred in processing such stages at the Development Management stage(s).

Specifically, we raise objection to the following timescales which are considered to be extremely ambitious and unrealistic:

• “Time period of pre-application discussions/PAC consultation” = 4 months
• “Time between submission of planning application and determination” = 6 months
• “Time taken from planning consent to the discharge of relevant conditions to enable site construction” = 4 months

In our experience, having submitted a significant number of major and other applications for housing and other forms of development in the last 1-2 years to the Council (and elsewhere in Wales and England), it is extremely unlikely that major applications can be submitted, and planning permissions granted, within the timeframes assumed by the trajectory. A wide range of stakeholders are also involved in the determination of major planning applications, which often adds to the delays associated with the determination of such applications. We would therefore consider that a time period of “6 months” given to all major applications in the housing trajectory is not feasible, and distorts the trajectory timescales for the remaining Plan period.

The assumptions in the trajectory are also solely based on expected timescales for the processing of formal submissions made to the Council, and do not factor in the timescales associated with, and needed for, the preparation of the material for submission (i.e. pre-application enquiry submissions / planning application / discharge of condition details etc). When factored in these will elongate the timescales for bringing forward schemes considerably.

Moreover, it is common practice for larger housing sites and major applications to have a range of pre-commencement conditions attached to a permission once granted. Again, we would raise concerns with the timescales indicated in the trajectory related to this part of the planning process. It is highly unusual and questionable that any technical work required by these conditions (usually relating to drainage and highways matters) would be instructed, completed and submitted within 2 months, and for these to then be signed off / approved in a further 2 months. There are also other technical matters and necessary approvals falling outside of, and over and above, the planning system, such as SAB, s.106, s.38 and s.278 agreements, timescales for which have not been accounted for – and all of which are rarely completed within “4 months” as indicated.

It is therefore highly doubtful that the timescales legislated for in the trajectory for the various stages pre-construction are achievable – with no information about these proposed timescales outlined within the supporting text of the Housing Trajectory. We would therefore raise considerable concerns and objections to these as they stand without full evidence to fully show how these have been calculated, and without there being considerable (and necessary) adjustment to the timescales indicated and factored in.

We would therefore object to the timescales indicated in the ‘Timing and Phasing of Sites’ table, given that the delivery start dates will be pushed back further into the Plan period. Accordingly, and as a result, the Plan is at risk of not delivering the level of housing expected based on the sites allocated, at least as swiftly as is set out in the trajectory.

Housing Delivery Rate Assumptions

We would also raise considerable doubt over the proposed delivery of the sites identified in the Housing Trajectory - which we do not consider are robust or reasonable.

The development trajectory bar chart set out in the consultation material (extracted below) anticipates and legislates for a number of critical events and circumstances – all of which are considered to be unrobust and unsound.

Extract of Housing Trajectory Graph (annotated by GJP – red dotted line)

Firstly, a large ‘spike’ (material increase) in housing delivery is factored in to take place in 2027 – 2028. This is a marked and pronounced step change in the rate of delivery, and envisages / relies on a significantly higher rate of delivery than previous years in The Vale of Glamorgan (2021 through 2025 - as depicted by the green columns). This is considered extremely unlikely to materialise, not least given prevailing market circumstances, past rates of delivery on the ground, and also in light of levels achieved across Wales and the UK in general.

The published trajectory shows that the average level of completions in The Vale of Glamorgan from 2021 - 2025 has been approx. 400 - 500 units. However, the chart shows that from 2027 – 2028, completions are expected to rise to approx. 1,000 units per year. The expected delivery levels in the trajectory therefore show and assume a doubling in delivery rates and unit numbers (an increase of approx. 100%relative to past rates). There is no clear evidence as to how this level of completions can be achieved let alone guaranteed. This is the case in particular given that the forthcoming years (2025-2027) are expected to see performance (yield) drop significantly (delivery rates in 2025 – 2026 and 2026 – 2027). The chart shows only approx. 200 units being delivered over these years. It is therefore unclear how completion rates are expected to rise so quickly (from 200 in 2025-26 to 1000 in 2027-28), and by such a significant amount. The assumptions in the trajectory are wholly unrobust in our view.

The anticipated delivery of housing also fails to be consistent within and across the Plan period. It is unclear as to why completions rates aren’t spread out more evenly throughout the Plan period - to ensure a robust and most realistic housing trajectory until 2036. By comparison to the marked increase in the rate of delivery between and over the

period 2027 to 2031, there is then a marked fall-off or drop in delivery towards and by the end of the Plan period. Indeed, in the final year, the level of completions are expected to be lower than the period 2021-2015.

To summarise, we consider the defined position to be wholly manufactured and unreflective of the past completion rates, as well as the recently published completion rates provided by Welsh Government recently in August 2025. In the Welsh Government Statistics Document ‘’New House Building: April 2024 to March 2025’, information on the number of new dwellings started is provided, where building has commenced and those completed for April 2024 to March 2025. Figure 1 provides a graph showing starts in the last 10 years, and it is clear that there has been a general decline in the number of new dwellings started and completed.

Description of Figure 1:.‘New House Building: April 2024 to March 2025’
In 2024-25, 4,631 new dwellings were completed, 3% fewer than in the previous year. This was the second lowest number on record, with the lowest number recorded in 2021-22, a year heavily affected by the coronavirus (COVID-19) pandemic (in 2021-22, 4,616 new dwellings were completed). The New Housing Pipeline Report Quarter 2, 2025 Report (September, 2025) published by the HBF evidenced that the number of residential units approved in the UK fell by 6% during the second quarter of 2025, continuing the decline of approval during the first three months of the year. Wales saw one of the largest declines in the UK in approvals with a decline of 29%.

Further, the HBF document ‘Increasing Housing Supply in Wales’ (4th September 2025) clearly shows that The Vale of Glamorgan has not met the housing delivery requirements in recent years in 2023 – 2024 – along with every other authority in Wales (except Newport). Accordingly, this further adds to the argument that historically The Vale (and most other authorities) have underprovided. This adds considerable uncertainty on the assumed transformation in yield and delivery as built into the trajectory.


Graph: Housing Delivery as a proportion of annual housing requirement in Wales per Authority

The Home Building Sector Skills Plan (Aug 2025) published by the HBF also identified the following issues with the workforce to bring forward built development in Wales:

• “A shortfall in numbers entering roles from the education system;
• An ageing workforce: 25% of the home building workforce is aged over 50, meaning the sector is facing an impending retirement cliff edge;
• Challenges attracting a wider talent pipeline into the sector;
• A lack of understanding of critical future skills needed, and direction from the Future Homes Standard; and
• Output within the sector fluctuating with demand and economic pressures, leading to additional pressures in recruitment and training”.

It is not considered that in the next 1-2 years that any of these issues can or will be substantially corrected – at least sufficiently so to allow for, and enable, the planned delivery rates of new housing completions to be as high as < > 1,000 homes in one year (and for four consecutive years at that).

We would therefore object to the proposed numbers of completion expected during the Plan period, given that there are a number of issues with delivering housing in Wales and given past completions rates for The Vale of Glamorgan. Again, this results in the Plan being at risk of not delivering the level of housing expected based on the sites allocated.

Status & Standing of Sites included in the Trajectory

The proposed land supply within the housing trajectory includes provision for ‘rolled forward’ LDP sites, which contribute to the total of ‘Proposed Additional Housing Allocations’ forming part of the housing supply. Specifically, a total of 1,242no. units have been identified as additional housing allocations, of which 959no. are expected to be delivered on the rolled forward LDP sites. As such, these sites are to provide for a significant proportion of additional housing in the Plan period (specifically circa 77%).

The Development Plans Manual (DPM) sets out that allocations rolled forward from a previous plan will require careful justification for inclusion in a revised plan. The DPM outlines that “there will need to be a substantial change in circumstances to demonstrate sites can be delivered and justify being included again. Clear evidence will be required that such sites can be delivered.” The below table included in the consultation document provides a breakdown of the rolled forward LDP sites, and in particular, sets out the status of each site:




The above table evidences that the current LDP has under delivered in regard to its targeted unit number of the Plan period, given that these sites did not yield any housing over the current plan period. This is further exacerbated by the Land Bank sites that have also not delivered any housing across the existing LDP period, amounting to 1,860no units. Accordingly, when considering the non-delivery of both rolled forward LDP sites and Land Bank sites, this amounts to an approximate shortfall of 2,189 homes being delivered, or 33% of the total housing supply identified for the current LDP (8,525no. dwellings).

It is therefore considered that, as a minimum, the units carried over from the LDP (without planning permission) should be a surplus to the housing supply proposed for the RLDP, as opposed to being relied on to deliver the housing need over the Plan period. This is particularly the case for the two sites (Land to the west of Pencoedtre Lane, and Land between Northern Access Road and Eglwys Brewis Road) which do not currently have any active planning application submitted for their development. These sites total an amount of 370no. units to be delivered in the Plan period, which represents more than a third of the additional housing allocations to make up the housing supply.

As such, it is considered that the unmet need deriving from the existing LDP is still present – indeed it has grown, and will continue to do so, not least when considered in conjunction with the projected population growth over the coming years to 2036, and the aspirations for growth in the Plan’s strategy.

Accordingly, in order to secure the targeted level of housing, a greater level of provision for new allocations should be applied in order to meet the housing requirement. This would bring about better certainty that the housing requirement is met by the housing supply over the Plan period, not least given that the current Plan failed in this respect. Without a re-apportioning of the housing supply, it is considered that the Plan would heavily rely on the contingency (i.e. rolled forward LDP sites) coming forward in the Plan period, yet there is uncertainty that these will yield in full over the new Plan period. This raises issues of ‘’soundness’’, and risks rendering the Plan unrobust.

On this basis, we would object to the Plan if the provision of housing is not adjusted to rebalance the provision to include new allocations in lieu of rolled forward LDP sites in the housing supply.

Key Sites

As set out in previous representations at Preferred Strategy stage, it is considered that the housing supply relies heavily on the delivery of the ‘key sites’ to deliver housing (and meet need) over the Plan period. The total number of housing units attributed to key sites amounts to 2,278, which equates to over 25% of the total provision in the Plan period.

As detailed above, we consider there to be concerns regarding the proposed ‘Timing and Phasing of Sites’ table included in the Housing Trajectory which we consider are not reflective or accurate and will therefore have the effect of delivery start dates being much later into the Plan period than anticipated. The result of this will be that the Plan will be at risk of not delivery the level of housing expected and needed. Moreover, the Housing Trajectory Graph presents an overly ambitious level of housing completions over the Plan period - which the Council consider will be markedly higher than the average levels experienced in the last five years. Again, for the reasons set out above, we consider that these rates of expected completions to have no evidence supporting them, and to be unachievable and unsound.

Insofar as to the removal of the previously proposed site ‘Land at North East Barry’, this site was expected to deliver 900no. units in the Plan period. Following its omission from the housing supply, other sites have been identified, which comprises the inclusion of a new key site (Land at North West Barry), 3no. non-strategic sites, and also affordable housing-led allocations. In terms of the quantum of development attributed to these new sites, this amounts to 659no. dwellings. This is some 250 units less than the 900no. homes that was previously attributed to ‘Land at North East Barry’. Whilst it is appreciated that the number of homes forming part of the existing supply (completions, units with planning permission etc.) have increased since Preferred Strategy stage, there will be a net loss in market housing provision and delivery.

This position is made worse and compounded as a result of accounting for the affordable-led sites in making up the housing supply.

As set out within the Preferred Strategy, these sites are expected to deliver at least 51% affordable housing. These units are not open market units, and will not / cannot contribute to the supply of such housing. These units will contribute to the provision of affordable housing, and will go some way to meeting the acute need for such housing (albeit will not eradicate / address in full the well known and accepted considerable requirement). Accordingly it is considered that these sites should be in addition to the housing supply, as opposed to forming part of the provision. In turn, there would need to be an increase in allocations for non-strategic sites, to ensure that there is sufficient market housing delivery over the Plan period.

Were such changes to be made and introduced, this would achieve and assist realise a more robust and sound housing supply, which will ensure that the identified housing need is met / addressed over the Plan period. Without these changes it is considered that the housing supply is not sufficient, and inevitably, housing need will not be met within the Plan.

St Athan Train Station

As set out in the Preferred Strategy (para A3.29), the strategy seeks to focus development around key sustainable transport nodes. The strategy outlined that a feasibility study for a station in St Athan had been undertaken, which identifies that a new station could be located in St Athan, subject to further investigation work. Accordingly, in line with the spatial strategy adopted for the RLDP (i.e. focus development around sustainable transport nodes), St Athan was identified as a ‘Strategic Opportunity Area’ to accommodate strategic growth – through the proposed allocation of two key sites : ‘Land at Church Farm’ and ‘Land West of St Athan’. These sites have been identified to deliver 532no. and 600no. units respectively in the Plan period. These are separate to, and are in addition to, the 51no. units that have now been attributed to the site ‘Land South of Clive Road’ in St Athan. Accordingly, in total, the Housing Trajectory makes a provision for a total of 1,183no. homes to be delivered in St Athan over the Plan period.

It is now the case that, subsequent to the publication of the Preferred Strategy, the proposed railway station at St Athan is not in the first phase of delivery for new stations in South Wales. The focus in the first phase of such improvements across the region is towards improving connectivity in east Cardiff, Newport, and Magor. Accordingly,

it is very unlikely that any new train station will be delivered in St Athan over the Plan period, which significantly questions the suitability and acceptability of the proposed allocations set out above.

The strategy to allocate new housing growth is predicated on focusing residential development around sustainable transport nodes, and given that St Athan will be without any railway station in the Plan period, it is not considered that these sites align with the strategy of the RLDP. Accordingly, the wider Housing Trajectory is considered to be unsound, given that a total of 1,183no. homes are expected to be delivered in St Athan within the Plan period.

It is considered that there has been an overprovision for housing growth in St Athan generally, and this issue is now further exacerbated by the lack of any forthcoming rail provision. Given this, to add a further site for housing in this location over and above the original provision is considered to be unsound. As set out above, the justification to allocate sites at St Athan has relied heavily on the railway station being delivered in the Plan period, and as such, there are serious questions marks associated with the acceptability of the proposed allocated sites - given their incompatibility with the core strategy of the RLDP.

We therefore consider the Trajectory to be both unrobust and unsound, and therefore, we object to the Trajectory in its current form accordingly.

Geographic distribution of the ‘new’ sites / provision

As a general and overarching comment in respect to the additional sites now included within the Plan, and forming part of the trajectory, (and a matter expanded upon when critiquing each of these sites in the next section to this submission), it is clear and evident that these additional sites have been positioned to settlements that have already, and recently, been attributed significant growth in the preceding Plan and plan period.

Significant allocations (which have also contributed to significant levels of affordable housing) have been realised and built out in locations (such as Wick and Colwinston). Notwithstanding this, two of the additional sites are now proposed for these recently expanded settlements. Given that the purpose of the affordable housing led allocations is to meet unmet affordable housing need, it is questioned why such new allocations are attributed to settlements that have already seen open market and affordable housing provision, as compared to other comparable settlements that have not received any growth whatsoever over a considerable period of time.

It is considered accordingly that the geographic positioning of these allocations is at odds with their underlying purpose - to meet unmet affordable housing need in communities that have seen no provision

Detailed Comments in respect to ‘new’ sites

Other Housing Allocations

Land south of Clive Road, St Athan

A summary of the Candidate Sites Assessment at Preferred Strategy Stage has been extracted below for ease:


As set out at the outset of these representations, and whilst we note the findings of the Candidate Sites Assessment at Preferred Strategy Stage (i.e. Suitable for further consideration), we do not consider that the consultation on this site has been undertaken procedurally appropriately or suitably. We therefore consider the consultation on this site is “unrobust” and “unsound”.

As set out previously, the strategy seeks to focus development around key sustainable transport nodes. The strategy outlined that a feasibility study for a station in St Athan had been undertaken, which identifies that a new station could be located in St Athan, subject to further investigation work. It is now the case that, subsequent to the publication of the Preferred Strategy, the proposed railway station at St Athan is not in the first phase of delivery for new stations in South Wales, where the focus is towards improving connectivity in east Cardiff, Newport, and Magor. Accordingly, it is very unlikely that any new train station will be delivered in St Athan over the Plan period, which significantly questions the suitability and acceptability of the proposed allocations set out above.

It is considered that there has been an overprovision for housing growth in St Athan generally, and this issue is now further exacerbated by the lack of any forthcoming rail provision. Given this, to add a further site for housing over and above the original provision is considered to be unsound. As set out above, the justification to allocate sites at St Athan has relied heavily on the railway station being delivered in the Plan period, and as such, there are serious questions marks associated with the acceptability of the proposed allocated sites – given their incompatibility with the core strategy of the RLDP.

Affordable Housing Led Allocations Land at Heol Fain, Wick
A summary of the Candidate Sites Assessment at Preferred Strategy Stage has been extracted below for ease:

Candidate Site Stage 2 Assessment (Site Ref. 404)

The findings of the Candidate Site Assessment for this site are noted. We are assuming the reason this site is proposed to be allocated is a product of the site promoters/developers heading the findings stated below, and changing the form of development to be in accord with this:

“A market housing led scheme would not be acceptable, but the site could be reconsidered as a small scale affordable housing led development subject to need and viability at a maximum of 50 dwellings. In accordance with the Settlement Appraisal Review, it is considered that Wick could potentially accommodate limited affordable housing led growth.”

Whilst no clear deficiency exists in respect to the site, it is known that Wick has been subject to significant growth and expansion in recent years – not least by virtue of significant housing allocations in the settlement as part of previous plans.

To evidence this, 35% of the 124 units approved on the ‘Rectory Field, St Brides Road’ site (i.e. circa 43 units as per site allocation ref. MG(47) and PP ref. 2014/01424/FUL) were approved as Affordable Housing units. This makes a substantial provision of such Affordable Housing units (and housing generally) in the settlement in recent years.

Other similarly sized and comparable settlements and locations have not by contrast been subject to any growth for some considerable time, and accordingly would warrant and benefit from provision as part of this new replacement plan.

Notwithstanding the location of such provision, and as set out in detail at the outset of these representations, National Planning Policy advocates the high and acute need for affordable housing, whilst recent analysis evidences that there is a housing emergency. These circumstances - coupled with the shortcomings identified and set out earlier in these submissions in respect to the adequacy of provision within the plan (rolled forward sites / inadequate provision etc) – means that notwithstanding any potential allocation at Wick, further provision ought to be made in comparable (previously unprovided for) locations, such as Ogmore By Sea.

Land West of Maendy Road, Aberthin

‘Land West of Maendy Road’ has been registered as an Affordable Housing Led Allocation candidate site for the RLDP, however as far as we know from our review, there is no assessment and critique of this site. This site has not been included in the ‘Candidate Assessment at Preferred Strategy Stage’ (October 2023). As such, with an absence of publicly available information, it is not clear how the Council has judged this site against the criteria. This raises questions accordingly in respect to the “soundness” of a site which forms part of the intended housing land supply, and by association the trajectory. Without this, and without being consulted on (as others have been prior to this) we question whether this allocation is “sound” (i.e. its allocation is considered to be “unsound”).

Land North of West Winds Business Park, Fferm Goch

The below sets out the candidate site stage two assessment of ‘Land to north and west of Westwinds Business Park’:

Candidate Site Stage 2 Assessment (Site Ref. 398)

As can be seen above, the site was not considered suitable for further consideration, with the site scoring negatively (red) in respect to a number of key factors. These include the following:

• Access to Retail;
• Access to Health Services;
• Sustainable Transport- Public Transport;
• Access/ Proximity to services and facilities conclusion;
• Climate Change; and

• Health and Wellbeing.

Given the fact the site scores red in ‘Sustainable Transport – Public Transport’, this shows the site is not served by public transport connections within 800m, as outlined in the key below:


Additionally, Policy SP7 (Sustainable Transport) of the Vale of Glamorgan Preferred Strategy states “New development must support an enhanced transport network that increases the proportion of journeys being undertaken by sustainable travel modes”. Additionally Objective 8 (Promoting Active and Sustainable Travel Choices) states “new development is directed to locations that are or can be accessible by a choice of modes of transport, including walking, cycling, and public transport.”

It is well known that residents of affordable housing are statistically less likely to own private vehicles, making access to reliable and frequent public transport essential for ensuring equitable mobility. The provision of public transport infrastructure in close proximity to such developments is therefore a critical component in supporting access to employment, education, healthcare, and other key services, while also promoting sustainable travel patterns and social inclusion.

The site also scores red in respect to Access/Proximity to services, showing the site is greater than 1200m away from key services, as seen in the key below:


In respect of the above, Preferred Strategy 6.40 states the need “To ensure that new development takes place in locations that have the best access to a wide range of services, facilities, and employment opportunities, whilst minimising the need to travel, the distribution of growth is guided by the following settlement hierarchy”. To further highlight the importance of both sustainable transport and proximity to services, the preferred strategy also states the need to “Facilitate the development of adaptable, accessible, well-connected communities that have a strong sense of identity, offer a sustainable range of services and facilities and are equipped with adequate infrastructure”. In addition, Promoting Active and Sustainable Travel Choices outlines to “Promote and encourage the use of sustainable methods of travel, particularly active modes of transport, whilst simultaneously reducing the need to travel”.

In light of the above, this site does not align with the aims and targets set out in the Preferred Strategy, as it fails to meet several key development goals set out. It should therefore not be considered suitable to be allocated for future developments. Its inclusion is therefore unsound.

Should this view be concurred with, 22 affordable units will be lost from the proposed affordable 122 units, and ultimately will be lost from the overall housing land supply. As stated in the draft housing trajectory “there is a need for small scale affordable housing led development (minimum 50% affordable) to respond to local affordable needs and help sustain services and facilities within these rural communities”. There is a clear possibility therefore that this proposed allocation is removed and/or not delivered as its inclusion is unsound as it does not align with the aims and targets set out in the Preferred Strategy - as it fails to meet several key development goals set out. A “small scale

affordable housing led development” which is needed to “respond to local affordable needs and help sustain services and facilities within these rural communities” will therefore not be provided for. This is clearly an issue.

When comparing this with ‘Land at Hazelwood, Ogmore By Sea, the following is set out:

Access to Services and Facilities

This criterion has been assessed firstly on the location of the site proposal in terms of whether it is located within, adjacent to, or outside a settlement, and secondly the ease of pedestrian and cycle access to key services listed below.



With reference to the above:

• In terms of public transport, there are two bus stops located approximately 200m (3-minute walk) from the site (‘Ogmore By Sea Post Office’), with the ‘303’ providing services between Llantwit Major and Bridgend.

• The site is located 200m (3-minute walk) from the ‘Ogmore By Sea Post Office’ which can provide basic goods to meet day-today needs such as bread, butter, milk etc.

• The site is also located 50m (1-minute walk) from a children’s park.

These services and facilities are therefore well within the best category (i.e. categorised/scored as ‘green’) - within 800m of site (10-minute walk). Accordingly, the site therefore has good access to services and facilities. This

Furthermore, the settlement of Ogmore By Sea has been ranked higher than Llangan (which the site ‘Land to north and west of Westwinds Business Park’ is located within) in the VoG Sustainable Settlements Appraisal, and therefore, is considered to constitute a more sustainable location to accommodate residential growth. Most notably, Ogmore By Sea scores ‘13’ in respect to ‘Daily Facilities’ whereas Llangan only scores ‘3’, evidencing that residents in Ogmore have much better access to services within the locality as compared to Llangan.

Given the above, ‘Land at Hazelwood, Ogmore’ does/should align with the aims and targets set out in the Preferred Strategy as it meets several of the key development goals set out. Its inclusion should therefore, in our view, be considered “sound” and therefore suitable to be allocated for future developments. The site should properly and appropriately be allocated in lieu of ‘Land to north and west of Westwinds Business Park’ – the inclusion of which is “unsound”. ‘Land at Hazelwood, Ogmore’ would therefore ensure that affordable units, where “there is a need for small scale affordable housing led development (minimum 50% affordable) to respond to local affordable needs and help

sustain services and facilities within these rural communities”, are provided for. As such the proposed housing trajectory would be maintained.

Land to the East of Colwinston, Colwinston

A summary of the Candidate Sites Assessment at Preferred Strategy Stage has been extracted below:


As outlined above, the site was rejected and considered not suitable for further consideration. In fact, and unlike ‘Land at Heol Fain, Wick’ and ‘Land to north and west of Westwinds Business Park’ it was stated that this site “could not be considered as a suitable affordable housing led development site”. Despite this, this site is identified to be allocated as an Affordable Housing Led Allocation. As such, the inclusion of this site is “unsound”.

It is known that Colwinston has been subject to significant housing allocations in the settlement as part of previous plans. To evidence this, 25% of the 64 units (i.e. 16 units) were approved on the site allocation ref. MG2(41) and PP ref.

2014/00242/FUL. This makes a substantial provision of such Affordable Housing units (and housing generally) in the settlement in recent years.

Other similarly sized and comparable settlements and locations have not by contrast been subject to any growth for some considerable time, and accordingly would warrant and benefit from provision as part of this new replacement plan.

Notwithstanding the location of such provision, and as set out in detail at the outset of these representations, National Planning Policy advocates the high and acute need for affordable housing, whilst recent analysis evidences that there is a housing emergency. These circumstances - coupled with the shortcomings identified and set out earlier in these submissions in respect to the adequacy of provision within the plan (rolled forward sites / inadequate provision etc) – means that notwithstanding any potential allocation at Colwinston, further provision ought to be made in comparable (previously unprovided for) locations, such as Ogmore By Sea.

Summary of These Representations

To re-iterate, and to summarise the case made and set out, these representations seek to object to the Housing Trajectory published as part of the consultation on the Draft Housing Trajectory For Housing Stakeholder Group (October 2025) which underpins the Plan and the delivery / realisation of its underlying strategy.

Detailed submissions and objections are raised above in respect to the trajectory information published regarding the soundness and robustness of this information (and it’s consultation), which we do not consider are adequate, robust, or sound to deliver the Plans aims and objectives.

My objections refer to the village of St Athan and its proposed overdevelopment - The vilage has limited infrastructure two doctors surgeries which are full to capacity with existing patients, a school which apparently is full and struggles to take on any additional children three shops but it is proposed to add 1100 houses over possibly 7 building sites. This means an additional 1500 -2000 vehicles on the already narrow and congested roads some of which were built for horse and carts not large motorcars.
We do not have a railway station or a regular half hourly bus service