This is the maximum housing Rhoose should take over the next 10 years. There should not be additional allocation even considered until this is built.

More flood prevention from existing properties. Communication/community buy in for the multi use space. Traffic management for entrance.

The plan doesn't show the already increased effects of flooding over the railway line onto properties below. This needs to be addressed. Also, the community green spaces/multi use space is not sustainable without communication with local community groups about usage, and sufficient parking/changing availabilty. Entrance on Pentir Y De needs addressing as it is a blind turning on the road from the estate and access cannot be from the South Point school side as this would create a 'rat run' down a straight road without traffic management in place.

Q1. First of all, I would like to comment on the consultation process established. I have found it very complex and very difficult to access. It would appear that you have a consultation system which actively discourages people from communicating with you in order to reduce the number of residents who give you feedback.

My main concerns are regarding the proposed development of housing to the north of Fontygary Road in Rhoose I would like to convey that I believe any such development would not just be extremely undesirable at the present time but would come at the cost of not just increasing travel delays but also an increased risk of road accidents including increased fatality risk.

The proposals show that Fonmon Road and Celtic Way will have both increased footfall and an increase in vehicle traffic as a result of this plan. I can only assume that whoever has come up with this plan does not live in the area and has no real experience of the actual situation on the ground. At present, pedestrians, both adult and schoolchildren, cyclists and vehicles of all kinds, not just cars, but bin lorries, buses and delivery vehicles attempt to go to and from Fontygary Road into Fonmon Road in order to access Fonmon Park Estate, Adenfield Way and its tributaries, and Court Farm Estate. The southern end of Fonmon Road where it joins Fontygary Road is often the scene of much congestion as it is not wide enough for two vehicles to pass one another. Pedestrians, including children on their way to and from School often have to manoeuvre around vehicles as there is no pavement, cyclists, often have to dismount to manoeuvre around vehicles. Increasing both pedestrian and vehicle traffic at this bottleneck is an accident waiting to happen. I assume that whoever has come up with this plan is prioritising what they believe to be housing needs before safety. In the summer months the many people out of the area who choose to visit Fontygary Bay and are unfamiliar with the area, increase the hazards of traffic at this location. The imposition of a 20 mile speed limit in the area has not improved the situation as there are often long delays at the traffic lights and drivers getting very frustrated

My second concern is the travel access to and from Rhoose. In the past residents have been told repeatedly that many forms of travel infrastructure will be improved. This has not occurred. There should be a complete halt on any further building work in Rhoose until improved travel infrastructure is actually completed. Too often we have been told that it is a part of the plan, but that part is then modified. Given the plan for increased airline traffic at Rhoose Airport, the new college which is being built alongside the airport, the plan for a development site at Model Farm, and the plans for development at the old Aberthaw Power station, and that the present transport infrastructure does not meet current needs let alone all these additional plans, to create even more residential development in Rhoose. It is simply to put the profit of building and selling houses ahead of the safety of the residents of the area.

Q2. There is a negative impact. This development will have a significant impact on the Welsh language. As there is not a shortage of housing in the area many of these homes are likely to be purchased by immigrants who have arrived in Wales and outnumber those struggling to maintain the language. Furthermore, there will be a significant increase in education costs in the area to provide multi-lingual support for those coming from other countries.

Recently, a significant quantity of raw sewage was surfacing and pooling under the railway bridge at Fontygary. This is not the first time this has occurred. It is also becoming a more frequent occurrence. We believe it was then overflowing in front of the chip shop and onto the grass towards Fontygary Park.
Welsh Water’s response to this was to blame the Vale of Glamorgan Council. They stated that the Vale Council were aware that the present sewage system is beyond capacity and that at times of high tide and heavy rain the system cannot handle the quantities of sewage entering the system. They stated that they are authorised to release raw sewage into the sea at Fontygary Bay at these times. They stated that while the Council continues to approve further building works with subsequent sewage entering the present system the situation will only further deteriorate.
Knowing this I believe that councillors have been irresponsible to allow any development (such as the new college at Rhoose Airport) before a new sewage system is put in place.
Given the public health risks of allowing sewage to overflow in this way, by making recommendations or decisions which will considerably worsen the situation, surely councillors and planning officers are deliberately exposing themselves to legal action. My main concern here is however the health risks needlessly increasing to the public.
I therefore object to any future developments in Rhoose until such time as a new sewage system is in place and has been given time to prove to work effectively.

We would also request that a member of the planning department reply to us by email and answer two questions:
1. Are they ignorant of the sewage backup/ capacity problems in Rhoose?
2. If they are aware of the current sewage problem how can they recommend any further building development in the Rhoose area?

Recently, a significant quantity of raw sewage was surfacing and pooling under the railway bridge at Fontygary. This is not the first time this has occurred. It is also becoming a more frequent occurrence. We believe it was then overflowing in front of the chip shop and onto the grass towards Fontygary Park.
Welsh Water’s response to this was to blame the Vale of Glamorgan Council. They stated that the Vale Council were aware that the present sewage system is beyond capacity and that at times of high tide and heavy rain the system cannot handle the quantities of sewage entering the system. They stated that they are authorised to release raw sewage into the sea at Fontygary Bay at these times. They stated that while the Council continues to approve further building works with subsequent sewage entering the present system the situation will only further deteriorate.
Knowing this I believe that councillors have been irresponsible to allow any development (such as the new college at Rhoose Airport) before a new sewage system is put in place.
Given the public health risks of allowing sewage to overflow in this way, by making recommendations or decisions which will considerably worsen the situation, surely councillors and planning officers are deliberately exposing themselves to legal action. My main concern here is however the health risks needlessly increasing to the public.
I therefore object to any future developments in Rhoose until such time as a new sewage system is in place and has been given time to prove to work effectively.

We would also request that a member of the planning department reply to us by email and answer two questions:
1. Are they ignorant of the sewage backup/ capacity problems in Rhoose?
2. If they are aware of the current sewage problem how can they recommend any further building development in the Rhoose area?

Thank you for consulting us on the Vale of Glamorgan Replacement Local Development Plan. This email forms for the basis of our response.

Network Rail is a statutory undertaker responsible for maintaining and operating the country’s railway infrastructure and associated estate. Network Rail owns, operates, maintains and develops the main rail network. This includes the railway tracks, stations, signalling systems, bridges, tunnels, level crossings and viaducts. The preparation of development plan policy is important in relation to the protection and enhancement of Network Rail’s infrastructure.

This representation focuses specifically on housing allocation HG1(9) – Land north of the railway line, Rhoose, and in particular on matters relating to movement, connectivity, and the treatment of the existing Public Right of Way (PRoW) within and adjoining the allocation.

HG1 (9)- Land Noth of the railway line Rhoose

Under this reference 339 houses are allocated on land north of the railway line, Rhoose. A planning application (2022/00733/FUL) is currently in progress on this site and Network Rail have been engaging with both the Local Planning Authority and the developer on the proposed development and the impact the houses with have on level crossing risk.

Network Rail acknowledges the strategic role of Policy SP6 – Housing Requirement in meeting identified housing needs across the Vale of Glamorgan and recognises the importance of allocating sufficient land to deliver new homes over the plan period.

However, the delivery of housing under Policy SP6 must be achieved in a manner that is safe, sustainable, and supported by appropriate infrastructure and mitigation. In this regard, Network Rail’s position in relation to HG1(9) is not one of objection to housing delivery, but rather a concern that development must not proceed in the absence of measures necessary to mitigate the demonstrable safety impacts arising from increased use of the Happy Valley Public Right of Way level crossing.

Network Rail has consistently objected to residential development on land north of the railway line at Rhoose where proposals have come forward in the absence of appropriate mitigation to address increased risk at the Happy Valley PRoW level crossing. Through detailed risk assessments and sustained engagement with the Local Planning Authority, Network Rail has set out clear evidence that development of this site would result in a material increase in the number of users traversing the level crossing, which is currently used as a local community and recreational route and provides a direct pedestrian link across the Vale of Glamorgan line. It has been communicated directly to the Local Planning Authority and discussed with the developer, that a Grampian-style condition that would allow development to commence while ensuring that no occupation occurs until a diversion order submitted and decided under Section 257 of the Town and Country Planning Act 1990.

The allocation for HG1 (9) should therefore acknowledge that appropriate mitigation for the level crossing is required, in this case the stopping up and diversion of the public right of way over Happy Valley Level Crossing.

Any development of land which would result in a material increase or significant change in the character of traffic using rail crossings should be refused unless, in consultation with Network Rail, it can either be demonstrated that the safety will not be compromised, or where safety is compromised serious mitigation measures would be incorporated to prevent any increased safety risk as a requirement of any permission.

In this context, the RLDP should ensure that housing delivery under Policy SP6 is explicitly contingent upon the resolution of known mitigation requirements, including those relating to the Public Right of Way and associated level crossing at Rhoose.

Candidate Sites – Porthkerry Road, Rhoose (2)

It is noted a number of candidate sites are proposed as part of the replacement local development plan. This potential site is proposed for housing and sits just north of the allocated HG1 (9) site. It should be noted that should the diversion not happen under application 2022/00733/FUL, we would have concerns about this potential allocation north of the site and so, we would look for a built intervention to provide mitigation at the crossing as a pre requisite to ensure level crossing risk is appropriately mitigated.

We trust these comments will be useful in the preparation of the forthcoming plan documents.

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