Flooding. The proposed site for development is in Flood Zone 3. The risk of flooding should not be ignored as was the case with the development of Court Close, Aberthin. We have lived here since 1976 and it is only in the last few years we have seen flooding in the grounds of the listed Great House, caused by houses being built on the field above the original part of Court Close.

Road safety. There will be a great increase in traffic within and through Aberthin and past the school. The development will probably see an additional 35 to 40 vehicles attached to those houses.

There is inadequate public transport, and few employment opportunities. Aberthin, though within about 1.5 miles from Cowbridge, is a minor rural settlement. And this proposed development is outside the present village boundary.

Can the local school cope with, possibly, an additional 20 children? Perhaps even more.

Dear Planning Department
I am writing to object to the planning proposal for new dwellings to be built in the large field behind Maes Lloi , Aberthin.
The volume of traffic is already high through the village, there is no designated crossing and more homes would inevitably add to this.
The field is not within village boundaries, and provides a valuable recreational space due to the public footpath access The 25 homes proposed is far too large an increase in proportion to the size of the village.
The field is in Flood Zone 3 as categorised by the council so should not be considered for development.
Aberthin has recently had additional housing in Court Close and so has met the criteria for expansion already.
The PLDP spatial strategy is meant to help to provide houses in sustainable locations with sufficient employment, infrastructure, public transport etc. Aberthin is a small rural village community which risks being adversely affected by this proposal due to its lack of these facilities Added pressure on Cowbridge Schools on Aberthin Road Please regard this as a strong objection to the proposal and listen to the concerns of the community and residents before allowing a development which is not required and will be detrimental to this very special village

I am writing to object to the planning proposal for the new dwellings to be built in the large field behind Maes Lloi , Aberthin.

The volume of traffic is already high through the village, there is no designated/safe crossing and more homes would inevitably add to this.

The field is not within village boundaries, and provides a valuable recreational space due to the public footpath access.

The 25 homes proposed is far too large an increase in proportion to the size of the village.

The field is in Flood Zone 3, as categorised by the council, so should not be considered for development.

Aberthin has recently had additional housing in Court Close and so has met the criteria for expansion already.

The PLDP spatial strategy is meant to help to provide houses in sustainable locations with sufficient employment, infrastructure, public transport etc. Aberthin is a small rural village community, which risks being adversely affected by this proposal due to its lack of these facilities.

Added pressure on Cowbridge Schools on Aberthin Road.

Please regard this as a strong OBJECTION to the proposal and listen to the concerns of the community and residents before allowing a development, which is not required and will be detrimental to this very special village.

I have lived in Aberthin for 20 years and use the field every day to either walk my Dog or walk into Cowbridge via the public footpath that links Aberthin to Cowbridge without having to go along the main Road, I see many people every day using this route. Its not clear from the plans that we will still have a safe access to this route into Cowbridge.

It should be noted that the field is not within existing village boundaries.

An extra 25 houses in Aberthin is a massive 14% increase and at least another 50 cars on an already very busy road.

The field is in flood zone 3.

The RLDP spatial strategy directs housing growth to sustainable locations, with employment, services. public transport, and infrastructure. Aberthin is very much a minor rural settlement offering no employment (maybe bar work), no services and an extremely limited bus route.

Cowbridge Comprehensive School is currently at full capacity putting extra pressure on the system,

Remove allocation.

I am writing to formally object to the proposed housing development under Application 2299 – Land to the West of Maendy Road, Aberthin.

Firstly, it should be noted that the site lies outside the established village boundary of Aberthin. Development in this location would therefore represent an extension into open countryside, which is contrary to the principles of sustainable and plan-led development.

The proposal for 25 additional dwellings would represent approximately a 14% increase in housing within Aberthin. For a village of this size, such an increase is significant and would materially alter the character and scale of the settlement.

In addition, the site is located within Flood Zone 3, which raises serious concerns regarding the appropriateness and safety of residential development in this location. Development in areas identified as having a high probability of flooding should be avoided wherever possible.

The Replacement Local Development Plan (RLDP) spatial strategy clearly directs housing growth towards sustainable settlements where there is appropriate access to employment opportunities, services, public transport, and supporting infrastructure. Aberthin does not meet these criteria and is classified as a minor rural settlement, with limited services and infrastructure to support additional development of this scale.

There are also concerns regarding local education capacity. Cowbridge Comprehensive School already faces capacity pressures and will not be able to accommodate the additional six pupils forecast under the RLDP as arising from this development.

For these reasons, the proposal is inconsistent with the principles of sustainable development, conflicts with the spatial strategy of the RLDP, and raises legitimate concerns regarding flooding risk, infrastructure provision, and the impact on the character of the village.

I respectfully request that the planning authority refuses this application.

I use the fields behind maes lloi in aberthin at least once a day every day to walk my dog. The proposed housing estate and the plan to create an access alleyway is something I object to. As a single woman I do not want to be walking alone down an alleyway as it is fundamentally unsafe to do so.
The destruction of highly valuable green space is another objection.

I am writing to object to the Housing Development - 2299- Land to West of Maendy Road, Aberthin.

It should be noted that the field is not within existing village boundaries.

An extra 25 houses in Aberthin is a 14% increase.

The field is in flood zone 3.

The RLDP spatial strategy directs housing growth to sustainable locations, with employment, services, public transport, and infrastructure. Abethin is not this. Aberthin is a minor rural settlement.

Insufficient capacity for Cowbridge Comprehensive School to accommodate RLDP forecasted additional 6 pupils from Aberthin development.

I write to object to Housing Development 2299 referred to above for the following reasons:

The field is not within existing Aberthin village boundaries;

The land identified for the development is in Flood Zone 3.

I note the RDLP spatial strategy directs growth to sustainable locations with appropriate levels of employment, services, public transport and infrastructure. Aberthin is a minor rural settlement and therefore does not meet this criteria.

An extra 25 houses in Aberthin represents a 14% increase.

Cowbridge Comprehensive school has insufficient capacity to accommodate additional pupils in line with the RLDP forecast should this development is approved.

I trust that my observations will be fully considered and look forward to hearing from you in due course.

1. Increase in traffic.
2. The field is not within the village boundary.
3. The 25 houses would be an increase of 14%.
4. This field is in a Flood Zone.
5. Aberthin is a rural settlement and has no infrastructure to cope with this ridiculous proposal which, includes insufficient capacity in Cowbridge Comprehensive School.

1. Primary request: delete Site 2299 from the RLDP and remove it from Policy HG4.
2. Settlement boundary: do not redraw the Aberthin settlement boundary to include this field parcel; if already redrawn, reinstate the defensible boundary aligned to existing built form unless a published boundary review justifies change.
Evidence disclosure requests (minimum):
a. Robust evidence qualifying necessity under HG4, aligned to national policies
b. Full Site 2299 proforma (BP18A indicates proformas exist and are available on request), including all scoring and override rationale.
c. Full FCA including modelling outputs, assumptions, and climate change allowances for both fluvial and pluvial events, surface runoff from surrounding slopes, high groundwater susceptibility, principal aquifer conditions, cumulative testing, implications on the nearby SSSI wetland habitat, ecology assessment and no worsening test.
d. Surface water modelling demonstrates intermediate risk treatment, exceedance routing and no worsening.
e. The advised 12-month Groundwater monitoring and data
f. SuDS feasibility and design, including implications on the nearby SSSI and ecology.
g. Drainage strategy demonstrating foul connection feasibility, capacity, and any required off-site reinforcement.
h. Dry access/egress assessment for residents and emergency vehicles during flood events.
i. Highways feasibility: access location, visibility, swept-path tracking and road safety audit.
j. Active travel and public transport assessment with deliverable mitigation package and funding mechanism.
k. Landscape/visual assessment for SLA impacts.
l. Ecology and heritage appraisals including SSSI proximity and Conservation Area setting.
m. Site-specific viability appraisal (including all abnormal costs) demonstrating affordable housing deliverability.
3. Confirmation regarding protection of hedgerow
4. Confirmation regarding PRoW

This representation objects to the allocation of Site HG4(2) – Land West of Maendy Road,
Aberthin (Site 2299) within the Vale of Glamorgan Replacement Local Development Plan (RLDP).
The allocation proposes approximately 25 dwellings as an affordable housing-led development
on greenfield agricultural land forming part of the countryside immediately west of Aberthin.
The allocation is unsound for several independent reasons.
First, the proposal conflicts with the Plan’s spatial strategy.
Aberthin is identified as a Minor Rural Settlement, where development is expected to be limited
in scale and primarily related to local needs. A development of approximately 25 dwellings
would represent around a 14% expansion of the settlement in a single phase, introducing
estate-scale growth into a small rural village with very limited services. This represents a
material step-change inconsistent with the role of such settlements within the hierarchy.
Second, the site is not necessary for delivery of the Plan’s housing strategy.
The RLDP identifies a housing requirement of 7,890 dwellings and housing provision of 8,660
dwellings, creating a surplus of 770 dwellings above the requirement. Removal of HG4(2)
Aberthin would still leave a surplus of 745 dwellings, and even removal of all HG4 rural
affordable-led sites would leave a surplus of 648 dwellings. The allocation is therefore not
required for the Plan to deliver its housing requirement.
Third, the RLDP evidence identifies affordable housing need at a ward level (Cowbridge) rather
than within Aberthin itself, and no evidence has been presented demonstrating a specific locally
arising need within the settlement.
Forth, the site makes only a negligible contribution to affordable housing delivery. The site is
expected to deliver approximately 13 affordable homes, representing only 0.42% of the Plan’s
projected affordable housing delivery of 3,070 homes. The Plan is therefore not materially
dependent on the site to deliver its affordable housing strategy.
Fifth, the site is heavily constrained by flood risk and drainage uncertainty.
Part of the site lies within Flood Zone 3, where highly vulnerable development on greenfield
land is not permitted under Technical Advice Note 15 (TAN15) unless the development is
essential to the Local Development Plan. Given the Plan’s housing surplus, and no identified
local need, the site cannot reasonably be considered essential. In addition:
• no detailed hydraulic model exists for the Nant Aberthin watercourse,
• no Flood Consequence Assessment has been undertaken at allocation stage,
• groundwater susceptibility is classified as “Red – high – groundwater likely to be at or
near the surface”, with a recommendation for 12 months monitoring which has not
been undertaken,
• surface water mapping indicates intermediate flood risk across part of the site, and
historical flood data indicates flooding
• the proposed SuDS detention basin location appears to fall within Flood Zone 3
according to Council constraint mapping, raising questions regarding compliance with
SuDS design guidance,
• the viability and performance of the proposed drainage strategy has not been
demonstrated, including potential effects on the hydrology of the nearby Cors Aberthin
SSSI wetland system, and
• no modelling has been provided to demonstrate that development would not worsen
flood risk to neighbouring properties, including those at Maes Lloi.
Taken together, these factors create substantial uncertainty regarding whether a compliant
drainage strategy could be delivered and whether flood risk could be safely managed.
Sixth, the site presents infrastructure and accessibility constraints.
Aberthin has very limited services and infrastructure. The settlement contains no shops and
limited community facilities, with most services located in nearby Cowbridge. Public transport
provision is limited to infrequent bus services which cease in the early evening and do not
operate on Sundays, and there are no designated active travel routes connecting the settlement
to surrounding towns. The road network through the village, particularly along the A4222
corridor, already experiences traffic pressures and safety concerns. The Council’s education
evidence also confirms that secondary school capacity serving the area is already under
pressure, with additional places required to accommodate projected growth.
Seventh, the allocation introduces development into a sensitive landscape and environmental
setting.
The site lies entirely within a Special Landscape Area, contributes to the countryside setting of
the Aberthin Conservation Area, lies close to Cors Aberthin SSSI, and contains established
hedgerow boundaries forming part of the historic field pattern of the Vale landscape.
Finally, the allocation represents a clear departure from the Council’s published site assessment
methodology.
Background Paper BP16 indicates that sites affected by flood risk should normally be discounted
from further consideration. Despite multiple constraints — including Flood Zone 3, groundwater
susceptibility and surface water risk — Site 2299 was not discounted. The site was previously
rejected during preparation of the adopted LDP on the basis that it was unrelated to the
settlement and constituted sporadic development in the countryside, and no material change in
circumstances has been demonstrated to justify a different conclusion. Additionally, audit trail
concerns are evident, e.g. N/A values in justification columns.
Taken together, the evidence demonstrates that the allocation:
• is not necessary to deliver the Plan’s housing requirement or affordable housing
outcomes, and no need has been established
• conflicts with national flood policy (TAN15),
• is inconsistent with Council’s own site assessment methodology, and
• introduces development into a sensitive rural landscape with infrastructure constraints
unnecessarily.
In conclusion, these matters demonstrate that the allocation fails the key tests of soundness: it
is not justified by the evidence, is not effective or deliverable due to unresolved environmental
and infrastructure constraints, and is not consistent with national policy, including Planning
Policy Wales (sustainable spatial strategy and protection of landscape) and Technical Advice
Note 15 (flood risk)
For these reasons, Site HG4(2) – Land West of Maendy Road, Aberthin should be removed from
the RLDP.

3.1 Settlement size and character
Aberthin is classified as a minor rural settlement. It is a historic agricultural village built around
the Nant Aberthin (Aberthin Brook), a tributary that flows into the River Thaw. The settlement is
surrounded by agricultural land parcels and a large common land called Stalling Down.
It is estimated to contain approximately 176 dwellings.
There is a close-knit community feel, with many residents taking parts in community events
organised by the village hall committee, such as a duck race (where plastic yellow ducks are
raced down the stream), a free bonfire and fireworks display held on the downs, quiz nights,
amateur dramatics and an annual Village Day, which has a barbeque, music and a dog show.
Aberthin has already been recently extended, under the last LDP. In around 2017, 20 properties
were built in Court close, 6 of those affordable. The settlement boundary was redrawn to
accommodate the site, as can be seen in the map below, marked in red. (REFER TO ATTACHED PDF FOR IMAGES)
3.1.1 Settlement boundary

3.2 Landscape and Environmental Context of Aberthin
The settlement is characterised by its historic village form, traditional buildings and strong
relationship with the surrounding countryside. Much of the landscape surrounding the village is
designated as a Special Landscape Area by Vale of Glamorgan Council, reflecting the recognised
scenic quality and rural character of the Nant Aberthin valley and the wider Vale landscape. The
historic character of the settlement is also recognised through the designation of the Aberthin
Conservation Area, which protects the architectural and historic character of the village and its
relationship with the surrounding rural landscape.
The surrounding countryside comprises a network of agricultural fields defined by historic
hedgerow boundaries, forming part of the traditional field pattern typical of the Vale of
Glamorgan. The area is also notable for its historic environment, with several Scheduled Ancient
Monuments and other archaeological features recorded in the surrounding landscape, reflecting
long-standing human activity in the Nant Aberthin valley. The landscape also supports important
ecological features associated with the Nant Aberthin watercourse and valley system, including
the nearby Cors Aberthin SSSI, a designated wetland site protected under the Wildlife and
Countryside Act 1981. Public rights of way cross the surrounding farmland, providing access to
the countryside and contributing to the rural character and recreational value of the area.
3.2.1 Landscape features
SSSI: shown in red, Conservation Area – maroon boundary, monuments in blue, ancient
woodland in green crosshatch, and SINC in green horizontal lines

3.3 Services and facilities
Aberthin has very limited services and infrastructure.
Known facilities include:
• a small community centre (a charity created to support itself, run by volunteers)
• two public houses, one of which has been operated and staffed primarily by the same
family for approximately 20 years.
The pubs are both well attended.
There are no shops.
The nearest Medical Centre is in central Cowbridge.
Cowbridge primary and secondary schools are within walking distance. The schools have had
significant oversubscription issues for at least a decade, despite recent expansion. There are no
other easily commutable secondary schools in the area.
3.4 Transport accessibility
Public transport provision is also extremely limited:
• The nearest train station is in Pontyclun, 4.7 miles way
• There is only one bus stop, located on one side of the road, for buses headed North.
Although buses do stop in the opposite direction, taking residents towards Cowbridge,
there is no designated bus stop, street furniture or pavements, for safety purposes. The
stop is also on a 90-degree bend with multiple side roads and opposite a pub car park
which all together pose a risk to personal safety.
• Buses operate approximately hourly
Services run only until around 7:30 pm
• No Sunday or bank holiday services exists.
• Buses are not busy
There are no designated cycle paths (Active Travel). A scheme went through consultation but
met with multiple objections. Some of these are relevant to LDP planning elements, such as:
o The high volume and speed of traffic on the existing highways, predominantly the A4222
that runs directly through Aberthin
o A lack of segregated infrastructure in the area, which would force cyclists to share space
with cars in narrow sections.
o The lack of street lighting in the area, which made the route unappealing for use at night
or during winter.
o Concerns regarding installing lighting due to wildlife disruption
The project has been on hold for 3 years.
The settlement is not (for many) realistically walkable to any nearby towns, including
Cowbridge, the nearest town, the centre of which is 2km away. There is a reliance on Cowbridge
for most needs. In some places pavements do not exist or are not continuous through either
side of the village. Most residents rely on car travel.
3.5 Flood risks and geology
Aberthin is in a flood risk area, with most of the heart of the village in flood zone 3 and further
parts in flood zone 2:
• Fluvial Risk (Rivers): The area immediately surrounding the Nant Aberthin is subject to
flood risk. Nant Aberthin joins the River Thaw,
• Surface Water: Due to its position at the base of the steep Pen y Lan Road and Stalling
Down, the village and the adjacent field of the proposed site 2299 are susceptible to
local flood risk caused by surface runoff during intense rainfall. Groundwater also
naturally flows downhill towards valley bottoms, where it can emerge as springs or
cause the water table to reach the surface.
• Groundwater: Much of the village and the surrounding valley floor is classified by the
British Geological Society as having a High Susceptibility to groundwater flooding. This
means geological conditions (specifically the permeable limestone bedrock and
overlying river gravels) could enable groundwater to emerge at the surface or remain
very shallow.
• Aquifer Designation: The underlying Carboniferous Limestone is classified as a Principal
Aquifer. These are layers of rock with high permeability that provide significant water storage. In Aberthin, this leads to a "flashy" groundwater table that rises rapidly in
response to rainfall.
• Alluvial Deposits: The valley floor contains permeable layers of alluvium and gravel.
When the nearby River Thaw or Nant Aberthin rises, it can "push" groundwater up
through these deposits into low-lying areas, a process known as groundwater-surface
water interaction.
• Under the Water Framework Directive (WFD), the groundwater body in this part of the
Vale of Glamorgan is generally monitored for "Good" or "Poor" quantitative status.
Additionally, much of the centre and the surrounding agricultural land to the immediate North
and West has experienced historical flooding and is in Development Advice Map Zone B

4 Site identification and baseline facts
4.1 Site 2299 or HG4(2)
Site 2299 is described as ‘Land West of Maendy Road, Aberthin’, promoted for 25 dwellings.
Its’ status is undeveloped greenfield land (agricultural field). Current lawful use and any
covenants/easements must be confirmed via Land Registry title and planning history searches.
The site is one of 4 proposed through policy HG4 – rural affordable housing-led site.

4.2 Scale and proportionality
Aberthin is understood to have 176 dwellings. 25 dwellings = 14.2% increase in a single phase.
This also follows a development in 2017 which already saw a 13% increase, so the new
development constitutes urban sprawl.

4.2.1 Site map for HG4 (2) in relationship to existing Aberthin settlement
4.3 Development proposal context diagram

4.4 Key mapped constraints/sensitivities
• Wholly within Special Landscape Area (SLA).
• Partial Flood Zone 3 (southern end) and broader fluvial sensitivity in the Nant Aberthin
corridor.
• Intermediate surface water risk across approximately half the site (per Vale planning
constraints mapping), with additional low surface water risk elsewhere.
• Groundwater susceptibility identified as ‘red – highest to ground’ and recommendations for 12
months groundwater monitoring and FCA
• History of flooding (DEVELOPMENT ADVICE MAP Zone B) across middle of the site
• Current (known) southern access wholly within Flood Zone 3; width constraints for emergency
vehicles.
• No existing sewerage or drainage infrastructure on site.
• Public right of way interacts with the southern access area and proposed drainage features
and run along western end from bottom to top of site
• Proximity to designated assets (SSSI nearby, SINC 165, Conservation Area setting) and mineral
safeguarding (limestone safeguarding area).
• Historic hedgerow running down western side of site

5 Principle, spatial strategy and previous rejection
5.1 Conflict with the Plan’s Spatial Strategy
The core objection is one of principle. The proposed allocation would release open countryside
for estate-scale residential development in a Minor Rural Settlement, contrary to the spatial
strategy of the RLDP.
The RLDP directs the majority of housing growth to sustainable locations — higher-order
settlements and service centres — where employment, services, public transport and
infrastructure are available. Minor Rural Settlements are not intended to accommodate estate
scale development; growth in such locations is expected to be very limited and typically
confined to local need or small-scale infill. Aberthin is not identified as a strategic growth
location and no specific local affordable housing need within the settlement has been
demonstrated.
This strategic approach is reflected in the housing distribution set out in BP9A. Figure 2 shows
that only 4.5% of total housing growth is directed to Minor Rural Settlements and Primary
Settlements outside the Strategic Growth Area. Applied to the Plan’s total housing provision of
8,660 dwellings, this equates to approximately 390 dwellings across all minor rural settlements
over the 15-year plan period. By contrast, the overwhelming majority of growth is directed to
larger settlements:
Settlement Category
Share of Housing
Primary settlements in Strategic Growth Area 40.5%
Service centres
26.4%
Key settlements
24.9%
This distribution demonstrates that minor rural settlements are not intended to play a
significant role in housing delivery, with growth instead concentrated in locations with stronger
services, infrastructure and sustainable transport connections.
Within this context, allocating HG4(2) Aberthin for approximately 25 dwellings would represent
a 14.2% expansion of the settlement in a single phase, introducing suburban-scale development
into a small rural village with very limited services and infrastructure. Although described as
“small-scale”, the assessment fails to consider proportionality: a 14% expansion of a minor rural
settlement cannot reasonably be regarded as small-scale development.
The allocation therefore represents a departure from the Plan’s spatial distribution strategy
rather than an implementation of it.

5.2 Consistency with Previous Plan Evidence
The site was previously assessed during preparation of the Vale of Glamorgan LDP 2011-2026
and rejected. The reason for rejection was clear: the site was considered unrelated to the
settlement and would represent unacceptable sporadic development in the countryside. This
reasoning remains valid.
The physical relationship between the site and the settlement has not changed. The field
remains a separate agricultural parcel outside the established built form of Aberthin. No new
infrastructure, services, or settlement expansion has occurred that would alter this relationship.
Allocating the same site in the absence of any material change in context raises serious
questions about the consistency and robustness of the site selection process.
5.3 Internal Inconsistency in the Council’s Own Assessment
The Council’s Candidate Site Assessment contains a clear internal inconsistency regarding the
status of Site 2299. At Stage 1 the site is described as “adjacent to a minor rural settlement”
(BP18A, p.14), which indicates that the land lies outside the settlement and forms part of the
open countryside. However, at Stage 2 the site is assessed on the basis that “a small-scale
affordable housing led development in a minor rural settlement would accord in principle with
the strategy” (BP18A, p.20).
These statements are incompatible. A site that is adjacent to a settlement is not within it. The
assessment therefore appears to assume that the settlement boundary will be extended to
incorporate the site, yet no explanation or evidence is provided to justify such a boundary
change. This raises serious concerns regarding the transparency and robustness of the site
selection process and suggests that the allocation may be site-led rather than plan-led.
5.4 Scale Does Not Resolve the Principal Conflict
The number of dwellings proposed does not resolve the fundamental policy conflict.
Even if the development were reduced in scale, the underlying issue would remain: the site
constitutes development in the countryside beyond a defensible settlement boundary and
represents estate-style expansion rather than small-scale infill.
5.5 Reliance Solely on Affordable Housing Justification
The Council’s own assessment makes clear that the only substantive justification for the site is
the potential delivery of affordable housing. No other strategic justification is provided.
Indeed, the assessment acknowledges that:
• Aberthin has limited services and facilities, and
• public transport provision is relatively infrequent.
The reliance solely on affordable housing as justification is problematic in principle. Affordable
housing provision cannot justify development in locations that conflict with the spatial strategy,
particularly where the overall housing requirement is already exceeded, the plan target for
affordable housing doubles the historic attainment and need for the LDP to contribute, and
alternative sustainable sites are available.
The detailed assessment of affordable housing need and delivery is addressed separately in
Section [6] of this representation.

6 Affordable Housing, Spatial Strategy, and Necessity: Why HG4(2) Is
Not Required
6.1 The RLDP Already Exceeds the Housing Requirement (and Explicitly Builds
in Flexibility)
A key test in allocating additional housing sites is whether they are necessary for the Plan to
deliver its housing requirement and strategy.
BP9A confirms a housing requirement of 7,890 dwellings and total housing provision of 8,660
dwellings, explicitly described as a 10% flexibility allowance:
• “The housing provision of 8,660 dwellings rounds to a 10% flexibility allowance…”
• “…it is considered that a 10% flexibility should be considered a maximum…”
This creates a surplus of 770 dwellings above the requirement (8,660 – 7,890), meaning the Plan
is not operating at the margin but already includes a substantial buffer.
Removal of HG4(2) Aberthin (25 dwellings) would leave provision at 8,635 dwellings, still
exceeding the requirement by 745 dwellings. Even removal of all HG4 rural affordable-led sites
(122 dwellings) would leave provision at 8,538 dwellings, still exceeding the requirement by 648
dwellings.
The Plan therefore retains a substantial flexibility margin without reliance on the HG4 rural sites.
These allocations are consequently discretionary additions rather than necessary components of
the housing strategy.
6.2 HG4 Rural Affordable-Led Sites Represent a Very Small Component of
Supply and are not Numerically Essential
BP9A identifies “Affordable housing led sites” (HG4) as a limited element of supply totalling 122
dwellings across four settlements (Colwinston 25, Aberthin 25, Wick 50, Fferm Goch 22).
This is 1.4% of total Plan provision.
HG4 rural affordable-led sites therefore represent a very small and numerically non-essential
component of supply. Numerically, the Plan is not dependent on these sites. As set out above,
even removing all HG4 sites, the Plan retains a surplus of 648 dwellings above the requirement.
This confirms that these allocations are not structurally required for housing delivery.
6.3 The 3,070 Affordable Homes Figure Represents Expected Delivery — Not
Demonstrated Need and HG4(2) is immaterial to delivery
A key point in interpreting the Plan’s affordable housing evidence is the meaning of the 3,070
figure referenced throughout the RLDP evidence base.
BP9A confirms that:
“the various sources of housing will contribute 3,070 affordable homes.”
This figure represents expected affordable housing delivery arising from the housing supply
identified in the Plan, including sites with planning permission, sites under construction, housing
allocations, windfalls and affordable-led sites. It is therefore derived from the overall housing
supply and assumed policy performance, rather than representing a quantified level of housing
need that must be met in full. In other words, 3,070 is a projection of delivery, not a measure of
need.
The actual level of demonstrated need is identified through the Local Housing Market
Assessment (LHMA). BP9A confirms that the LHMA identifies:
• 461 affordable homes per year, equating to
• 6,918 affordable homes over the 15-year plan period.
This distinction is critical.
Measure
Demonstrated affordable housing need (LHMA)
Number
6,918 homes
Affordable housing expected to be delivered by the RLDP 3,070 homes
The Plan therefore anticipates delivering less than half of the identified affordable housing need
through the planning system. This is not unusual, as delivery through planning mechanisms is
constrained by factors such as development viability, housing delivery rates, reliance on market
schemes to generate affordable units, and the availability of subsidy and Registered Social
Landlord funding.
However, this distinction is fundamental when considering the necessity of individual
allocations. Because the 3,070 figure represents expected delivery arising from the overall
housing supply, it is not a target that must be achieved through allocating specific individual
sites. The inclusion or exclusion of a small site therefore does not materially affect the Plan’s
affordable housing strategy.
This is particularly clear in the case of HG4(2) Aberthin. BP9A indicates that affordable housing
led sites are expected to deliver at least 50% affordable housing, meaning HG4(2) would provide
approximately:
• 13 affordable homes from 25 dwellings,
with 62 affordable homes across all HG4 rural affordable-led sites combined.
The numerical impact of removing the Aberthin site is therefore extremely small:
• Removing HG4(2) Aberthin reduces affordable delivery from 3,070 to approximately
3,057 homes (0.42% reduction).
• Removing all HG4 rural affordable-led sites reduces delivery from 3,070 to
approximately 3,008 homes (2.02% reduction).
BP18A states that “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.” However, a contribution of 0.42% from the Aberthin site cannot
reasonably be described as important and is numerically negligible.
Accordingly, the Plan is not materially dependent on HG4(2) Aberthin to meet its affordable
housing delivery expectations. The loss of the site would not undermine the Plan’s affordable
housing strategy or prevent the RLDP from delivering the level of affordable housing the Council
expects to arise from the housing supply.
The evidence therefore demonstrates that HG4(2) Aberthin is not necessary for the Plan to
achieve its projected affordable housing delivery.
6.4 Affordable Housing Delivery Framework
Affordable housing delivery in Wales is not solely dependent on allocations or planning
obligations secured through the Local Development Plan (LDP). Welsh Government statistics
show that affordable housing is delivered through a range of mechanisms, including Welsh
Government capital grant programmes, housing association development and direct local
authority provision.
In 2024–2025, 3,643 additional affordable homes were delivered across Wales. Of these, 882
homes (approximately 24%) were delivered through planning obligations linked to market
housing developments, while around 76% were delivered through other routes, primarily grant
funded programmes and delivery by Registered Social Landlords and local authorities. This
demonstrates that the planning system represents one component of the wider affordable
housing delivery framework, rather than the principal delivery mechanism.
Within the Vale of Glamorgan, monitoring reports indicate that 2,398 affordable homes were
delivered between 2011 and 2025 under the current LDP period. Recent statistics also show 147
local authority homes delivered in 2024–2025, demonstrating that council-led delivery
programmes continue to contribute alongside housing association development.
The RLDP evidence suggests that approximately half of identified affordable housing need may
be delivered through planning mechanisms associated with housing allocations. When
compared with national delivery patterns — where planning obligations account for around 24%
of affordable housing provision — this represents approximately double the typical contribution
delivered through planning mechanisms.
The available evidence therefore indicates that the RLDP is already expected to make an
unusually high contribution to affordable housing delivery through planning mechanisms alone.
Given national delivery patterns and the Vale’s historic delivery record, it is reasonable to expect
that a proportion of affordable housing supply during the plan period will continue to arise
through other established mechanisms operating alongside the LDP, including Welsh
Government grant programmes, housing association development and local authority housing
delivery.
The evidence therefore indicates that the Local Development Plan should be understood as one
delivery mechanism within a wider system, rather than the principal mechanism through which
affordable housing need is expected to be met.
6.4.1 Implications for Site Allocation
In this context, the justification for allocating additional sites primarily to support affordable
housing delivery becomes less clear. If the RLDP already assumes a level of provision through
planning mechanisms that doubles typical national delivery patterns, further allocations risk
over-provision relative to what is required to support the plan strategy, raising a potential
question of plan soundness.
This is particularly relevant where proposed sites are rural or environmentally sensitive
locations, or where development may introduce landscape, infrastructure or environmental
impacts affecting the rural character that defines much of the Vale of Glamorgan.
The evidence therefore suggests that the necessity for additional site allocations should be
clearly demonstrated, particularly where affordable housing delivery may reasonably be
expected to arise through the wider delivery framework operating alongside the planning
system.
6.5 The Evidence Base Identifies the Greatest Affordable Need in Larger
Settlements
The LHMA evidence summarised in the RLDP identifies that the greatest affordable housing
need is in:
• Barry
• Penarth / Llandough
• Llantwit Major
• Dinas Powys
• Rhoose
The Plan’s spatial strategy directs the overwhelming majority of growth to these areas and
settlement categories: Key Settlements, Service Centres and Primary Settlements in the
Strategic Growth area. This alignment between identified housing need and the spatial
distribution of growth is a central principle of the Plan’s strategy.
By contrast, Minor Rural Settlements such as Aberthin are not identified as primary locations for
addressing affordable housing need, and the evidence base does not demonstrate a specific
local need within the settlement itself. In this context, allocating a greenfield affordable housing
site in Aberthin appears inconsistent with the evidence base.
6.6 The Council’s “Local Need and Support for Services” Justification Requires
Evidence
The Plan suggests that rural affordable housing allocations are intended to:
• respond to local affordable housing needs, and
• support local services and facilities.
However, the evidence presented within BP9A does not demonstrate:
• there is any affordable housing need locally within Aberthin,
• What services exist that can be supported by extra residents
The justification for HG4 rural affordable housing sites relies on two related propositions: that
they respond to locally arising affordable housing need and that they support the sustainability
of rural communities by helping to maintain local services and facilities. However, the evidence
base does not demonstrate a specific affordable housing need within Aberthin itself (only the
ward of Cowbridge). Nor does the settlement contain a range of services that would realistically
be sustained by a development of this scale. In these circumstances, the policy rationale
underpinning the allocation appears weak. PPW and TAN 6 expects rural affordable housing to
be genuinely locally justified.
6.7 Development Within the Wider Corridor
Housing development has taken place across the Cowbridge–Aberthin–Ystradowen corridor in
recent years. Within Aberthin itself, approximately 20 dwellings were completed around 2017
2018, including affordable homes. The redevelopment of the former Cowbridge school site
between Aberthin and Cowbridge is currently under construction and will deliver approximately
34 affordable homes.
Further housing has been delivered in nearby settlements, including Maple Walk in Ystradowen
(46 homes), with expansion in the RLDP, the former police station site in Cowbridge (14), and
Clare Garden Village (475), with further expansion. Collectively, these developments
demonstrate that housing supply, including significant levels of affordable housing, is already
being delivered within the surrounding area and the corridor may already be at saturation point.
6.8 Overall Conclusion
The evidence demonstrates that the allocation of HG4(2) Aberthin is not necessary for the RLDP
to deliver either its housing requirement or its projected affordable housing outcomes.
Even if HG4(2) Aberthin were removed, the Plan would still exceed its housing requirement by
745 dwellings, and even if all HG4 rural affordable-led sites were removed the surplus would
remain 648 dwellings. These allocations are therefore not required to maintain an appropriate
housing supply or flexibility allowance.
HG4(2) Aberthin itself is expected to deliver approximately 13 affordable homes, reducing
projected affordable housing delivery by only 0.42% if removed. Even removing all HG4 rural
affordable-led sites would reduce projected delivery by only 2.02%. The Plan is therefore not
materially dependent on these sites to achieve its affordable housing outcomes.
National evidence also demonstrates that affordable housing delivery in Wales arises through
multiple mechanisms operating alongside the planning system. The RLDP assumption that
around 50% of affordable housing need will be delivered through planning mechanisms
represents a doubling of the typical contribution made through the planning system.
Extensive corridor development of housing supply and affordable is already taking place and
may have already saturated this corridor.
No clear evidence has been presented demonstrating a specific local affordable housing need
within the settlement.

7 Flood risk, surface water, ground water, drainage, and methodological
concerns
7.1 TAN 15 Section 10.22 – Highly Vulnerable Development on Greenfield
Land in Flood Zone 3
BP21A (p.15) states:
“For a proposed development site within Flood Zones 3 of the Flood Map for Planning for Rivers,
Section 10.22 of TAN-15 states that highly vulnerable development on greenfield land is not
permitted. Section 10.23 of TAN-15 states that other development proposals are acceptable if
they are essential to the LDP.”
This is the primary policy test.
• Residential development = highly vulnerable development.
• The site is greenfield land.
• The southern part of the site lies within Flood Zone 3.
• TAN 15 states highly vulnerable development on greenfield land in Flood Zone 3 is not
permitted.
The only potential exception pathway is if the development is “essential to the LDP.”
This site is not essential:
• The housing trajectory demonstrates over delivery.
• Strategic sites are already allocated and viability tested.
• Minor rural settlements are not required to meet housing numbers.
• Affordable housing delivery is already occurring in service centres along this corridor
and through other delivery vehicles
• No need established in Aberthin
Accordingly, the allocation conflicts directly with TAN 15 Section 10.22.
7.2 Welsh Government Notification Direction – Escalation to Ministers
BP21A (p.15) states:
“It is recognised that the Welsh Government notification direction requires applications for
Highly Vulnerable Development where the whole or part of the site is within Flood Zone 3 on a
Greenfield site to be referred to the Welsh Ministers. Any development proposals for this site
which include residential use are therefore likely to be required to be notified to the Welsh
Government.”
This confirms:
• The seriousness of the constraint.
• That residential development here triggers Ministerial scrutiny.
• That the proposal is not routine.
It is unclear whether this allocation has been formally notified to Welsh Government at plan
stage. Allocation without clarity on Ministerial position introduces further procedural and
soundness risk.
7.3 SuDS Basin – Location Discrepancy and Flood Zone 3 Conflict
BP21A (p.16) states:
“Residential units located entirely within Flood Zone 1. A proposed SuDS detention basin is
located to the south of the site and is within Flood Zone 2.
As per the advice of the CIRIA SuDS Manual, SuDS should not be located within an area at a
greater than 1% AEP chance of flooding, which aligns to Flood Zone 3.”
However:
• Vale of Glamorgan planning constraints mapping indicates the basin location falls wholly
within Flood Zone 3.
If the basin is within Flood Zone 3:
• This conflicts with CIRIA guidance.
• Basin storage may be compromised during fluvial events.
• Coincident pluvial + fluvial events reduce attenuation capacity.
• Exceedance flows could affect:
o Site access (within Flood Zone 3),
o The public right of way,
o Existing properties at Maes Lloi.
No combined-event modelling outputs have been published.
7.3.1 Mapping overlay showing SUDs basin entirely in Flood Zone 3
Flood Zone
3
Flood Zone
3
7.4 Drainage, SuDS Feasibility and Groundwater Constraints
The hydrogeological and flood characteristics of the area raise significant doubt as to whether
an effective Sustainable Drainage System (SuDS) could be implemented on the site without
creating additional flood or environmental risk.
Aberthin lies within a valley setting where several interacting flood mechanisms operate. Much
of the village lies within Flood Zone 3, with surrounding areas within Flood Zone 2, reflecting
fluvial flood risk associated with the Nant Aberthin, which ultimately joins the River Thaw. In
addition to fluvial flooding, the area is susceptible to surface water runoff due to the steep
topography of surrounding higher ground, including Pen-y-Lan Road and the Stalling Down
plateau, which generate rapid runoff during intense rainfall events that drain towards the valley
floor where the village and the proposed site are located.
Groundwater conditions present a further constraint. The valley floor surrounding Aberthin is
identified by the British Geological Survey as having high susceptibility to groundwater flooding.
The site lies above Carboniferous Limestone classified as a Principal Aquifer, overlain by
permeable gravels and alluvial deposits associated with the Nant Aberthin valley. These
geological conditions can produce a rapidly responding (“flashy”) groundwater table in which
groundwater levels rise quickly following rainfall and may emerge at the surface or remain very
shallow. Interaction between river levels and groundwater within the alluvial deposits can
further exacerbate this effect, with elevated river levels capable of forcing groundwater upward
into adjacent low-lying land.
These conditions create a challenging environment for SuDS design. Welsh SuDS standards
require infiltration to be demonstrated as suitable for local ground conditions and to assess its
effects on groundwater levels. Where groundwater is shallow or highly responsive to rainfall,
infiltration techniques such as soakaways or infiltration basins may become ineffective or may
worsen groundwater emergence and flooding. Introducing additional infiltration in a valley floor
already prone to groundwater rise could therefore increase the risk of groundwater flooding in
surrounding parts of the village.
Even if infiltration techniques were unsuitable and an attenuation-based system were proposed,
significant uncertainty would remain. Such systems require sufficient space for attenuation
features, exceedance routing and safe discharge to a receiving watercourse. In this case, the site
is constrained by landscape sensitivity, established hedgerows, a public right of way, and its
position at the base of surrounding slopes where runoff naturally accumulates, raising doubt as
to whether a compliant SuDS solution could be delivered without substantial engineering
intervention.
There are also potential implications for Cors Aberthin SSSI, which lies within the same
hydrological valley system. Wetland habitats are typically highly sensitive to changes in
hydrology, groundwater levels and water quality, and development that alters surface water
pathways, increases runoff or modifies groundwater recharge patterns could affect the
hydrological conditions supporting the wetland ecosystem.
Together this creates significant uncertainty regarding whether a SuDS solution could be both
effective and environmentally acceptable. In the absence of detailed hydrogeological
investigation, seasonal groundwater monitoring and robust drainage modelling demonstrating
no increase in flood risk or ecological harm, the assumption that drainage issues can be
satisfactorily resolved remains unproven. This uncertainty raises further concerns regarding the
deliverability and environmental suitability of the allocation.
7.5 Absence of a Detailed Hydraulic Model – Nant Aberthin
BP21A (p.12) states:
“The southern extent of the Site is partially located within Flood Zones 2 and 3… No detailed
model is available of the Nant Aberthin.”
This is critical.
• There is no detailed hydraulic model of the Nant Aberthin.
• Flood extents are therefore based on national-scale modelling.
• No localised calibration or site-specific modelling has been published.
• Flood depth, velocity and hazard classification are not robustly evidenced.
Allocation of highly vulnerable development without a detailed fluvial model is precautionary
risk deficient.
7.6 Absence of Allocation-Stage FCA
The assessment documented in BP21a for site 2299 was undertaken by JBA Consulting. They
note the assessment was purely desk-based, taking information provided by others with no
verification.
BP21A (p.17) states:
“Any planning application for the Site should be accompanied by an FCA which demonstrates
how the proposals meet the requirements of TAN-15.”
This confirms:
• An FCA is required.
• It has not yet been undertaken.
• It is deferred to application stage.
However, TAN 15 requires flood consequences to be demonstrated as acceptable.
Allocation of highly vulnerable development in Flood Zone 3 without an FCA at plan stage
means:
• Flood consequences have not been demonstrated.
• Mitigation feasibility has not been proven.
• Deliverability is uncertain.
7.7 TAN 15 Section 10.18 – Flood Zone 2 Justification Pathway Not Engaged
BP21A (p.15) states:
“Section 10.18 of TAN-15 states that it is possible to allocate sites within Flood Zone 2 where the
proposals assist the implementation of the strategy of the LDP to regenerate or revitalise
existing settlements or to achieve key economic or environmental objectives.”
However:
• The site is not within the established settlement form.
• It was previously rejected as unrelated countryside.
• It does not regenerate the settlement.
• It does not achieve a key economic objective.
• It does not achieve a key environmental objective.
The Section 10.18 justification pathway does not apply.
7.8 Surface Water Risk – “Minimal” Assertion vs Mapping Evidence
BP21A states:
“Surface water and small watercourse flood risk is minimal across the site…”
However:
• Vale planning constraints mapping identifies intermediate surface water risk across
approximately half of the site.
• The site slopes from north to south toward Maes Lloi.
• Proposed dwellings fall within areas of intermediate surface water flood risk.
• Proposed dwellings are in an area of historical flooding (DEVELOPMENT ADVICE MAP
Zone B)
• No surface water modelling outputs are published.
• No velocity modelling.
• No exceedance routing plan.
• No no-worsening assessment.
Surface water risk has not been robustly evidenced at allocation stage.
7.9 Mapping shows majority of proposed houses located in risk areas
The following mapping overlays show that 16 of the 25 houses are in areas of either surface
water risk or have experienced historical flooding
7.9.1 Map overlay showing houses in risk areas for surface water
Surface risk
intermediate
Surface risk
intermediate
Surface risk
less
Surface risk
less
7.9.2 Map overlay showing houses in historical flooding area (DEVELOPMENT ADVICE MAP
Zone B)
Historical
flooding
Historical
flooding
7.10 Groundwater – “Red – High” and 12-Month Monitoring Requirement
The site is classified “Red – Hhigh – groundwater likely to be at or near the surface” meaning:
Groundwater levels are either at or very near (within 0.025m of) the ground surface.
BP21A recommends groundwater monitoring over a 12-month period to capture seasonal
variation.
There is no evidence that:
• 12 months monitoring has been undertaken.
• Basin performance takes account of high groundwater.
• Infiltration feasibility has been proven.
• Climate change allowances have been applied to groundwater conditions.
Allocation prior to completion of recommended monitoring is evidentially premature.
7.11 Topography and Potential Runoff Toward Existing At-Risk Properties
The site slopes from north to south toward Maes Lloi.
• Existing properties at Maes Lloi are largely within Flood Zone 3.
• Residents have noted drainage overload during wet periods.
• There is no evidence published that assesses whether the proposed development would
not worsen existing flood risks to surrounding properties
• No quantified runoff comparison between greenfield and developed sites is provided.
• No exceedance flow mapping is published.
Downstream impact risk has not been robustly assessed.
7.12 Failure to Apply Council Methodology
BP21A (p.13) states:
“the approach adopted by the Council within its assessment methodology was for flood risk to
be given the strongest possible weighting… sites identified to fall within areas of flood risk were
discounted from further consideration.”
This is unequivocal.
However, this site:
• Lies partially within Flood Zone 3.
• Has mapped intermediate surface water risk.
• Has groundwater classified “Red – High.”
• Has access within Flood Zone 3.
• Has a history of flooding (DEVELOPMENT ADVICE MAP Zone B)
• Requires Ministerial notification.
• Requires FCA and groundwater monitoring.
• Requires SUDs viability assessment
• Requires SSSI/ecology assessment
This represents a clear departure from the Council’s own stated methodology.
BP16 (p.20) states:
“Sites located within Zone 2 will only be considered where: It will assist, or be part of, a strategy
supported by the Development Plan to regenerate an existing settlement or achieve key
economic or environmental objectives or address national security or energy needs; AND • Its
location meets the definition of a brownfield site, And • Is supported by a FCA that indicates
that the potential consequences of a flooding event for the development proposed is found to
be acceptable in accordance with the criteria contained in section 11 of TAN 15 (2021).
Sites located within Zone 3 will only be considered where: • The development is required under
exceptional circumstances, as defined in TAN e.g. addressing national security or energy security
needs, reasons of public health or to mitigate the impacts of climate change, AND • Its location
meets the definition of a brownfield site, And • Is supported by a FCA that indicates that the
potential consequences of a flooding event for the development proposed is found to be
acceptable in accordance with the criteria contained in section 11 of TAN 15 (2021).”
This site is within Flood zones 2 and 3, is not brownfield, has no FCA, meets none of the
conditions in section 11, TAN 15 and is not required for exceptional circumstances.
The council do not appear to have followed any of these elements of methodology with regard
to flood risk.
7.13 Soundness Consequences
The allocation:
• Conflicts with TAN 15 Section 10.22.
• Does not meet Section 10.18 justification.
• Requires Welsh Government notification.
• Proceeds without any hydraulic model.
• Proceeds without FCA.
• Proceeds without groundwater monitoring.
• No-worsening test absent
• No SUDs viability assessment
• Contains mapping discrepancies.
• Defers critical evidence to application stage.
Accordingly, the allocation fails the soundness tests because it is:
• Not Justified – not based on robust, proportionate evidence.
• Not Effective – deliverability dependent on unresolved flood constraints.
• Not Consistent with national policy – specifically TAN 15 restrictions.

8 Infrastructure Constraints
8.1 Access Considerations
Indicative plans suggest that access to the proposed development may be provided from the
A4222 on the northern side of Aberthin. This would introduce an additional junction onto a
section of road that already contains numerous access points and turning movements. Given the
existing road layout and traffic conditions, the introduction of a further access point warrants
careful consideration in relation to highway safety.
The existing southern access route also presents constraints. It lies within Flood Zone 3, is
restricted in width, and cannot accommodate emergency vehicles safely. Flood events could
potentially affect access and egress, which may have implications for both existing and future
residents.
8.2 Existing Road Environment
The A4222 Maendy Road, which connects Cowbridge and Ystradowen through Aberthin, already
carries significant traffic volumes, including heavy goods vehicles. The road environment
includes several features that influence traffic movement and safety, including:
• a 90-degree bend over a bridge
• multiple side road junctions
• pub car park exits and private driveways accessing the road
• limited footpath provision and crossing points
• areas of reduced street lighting
These characteristics mean that drivers already navigate a relatively complex road environment
through the village.
Historic planning decisions also indicate sensitivity around access to this road. In 1978, South
Glamorgan County Council required the closure of the access from Skaife House onto the A4222
(Directly opposite the proposed new entrance), as part of planning consent for development at
The Spinney, Downs View Close, reflecting previous concerns regarding additional junctions
along this section of road (at a time with far less traffic).
8.3 8.3 Strategic Transport Policy Context
The RLDP is supported by BP14 – Strategic Transport Assessment Stage 1, which emphasises the
importance of locating development where sustainable travel options are available and where
the need to travel can be reduced. The assessment highlights the role of planning policy in
encouraging modal shift toward walking, cycling and public transport.
The Strategic Transport Assessment Stage 2 (BP14a) identifies capacity pressures within parts of
the local network. In particular, the Aberthin Road / Cardiff Road / St Athan Road / Eastgate
junction is recorded as operating beyond theoretical capacity during the AM peak period. This
indicates that parts of the local highway network already experience congestion during peak
travel times.
8.4 Car Dependency and Sustainable Transport
The Strategic Transport Assessment highlights that the Vale of Glamorgan has relatively high
levels of car ownership, with 83.4% of households owning one or more vehicles. In smaller rural
settlements such as Aberthin, limited public transport and no active travel infrastructure mean
that residents are likely to rely heavily on private vehicles.
The Vale’s active travel network is described within the transport evidence as limited and
fragmented in certain areas. Aberthin currently has:
• no designated Active Travel routes
• no proposed routes within the Active Travel Network Maps
• limited safe walking or cycling connections to nearby settlements such as Cowbridge
and Ystradowen, with narrow or missing footpaths and poorly lit sections.
An Active Travel scheme went through consultation but met with multiple objections. Some of
these are relevant to LDP planning elements, such as:
o The high volume and speed of traffic on the existing highways, predominantly the A4222
that runs directly through Aberthin
o A lack of segregated infrastructure in the area, which would force cyclists to share space
with cars in narrow sections.
o The lack of street lighting in the area, which made the route unappealing for use at night
or during winter.
o Concerns regarding installing lighting due to wildlife disruption
The project has been on hold for 3 years.
Public transport provision is also limited, with bus services operating approximately hourly,
ending in the early evening at 7.30, with no Sunday services. These factors may influence travel
patterns and increase reliance on private vehicles.
8.5 Cumulative Transport Considerations
As discussed earlier, extensive development has occurred and is still ongoing in the Cowbridge
Aberthin–Ystradowen corridor. These settlements are largely connected by the A4222 corridor,
which functions as the principal route linking the surrounding communities. The route already
accommodates traffic associated with existing settlements and recent development.
In this context, the cumulative impact of additional development along the corridor raises
considerations regarding traffic growth, junction capacity, road safety and infrastructure
demand. These factors may warrant careful evaluation when assessing additional rural
allocations, particularly where the transport evidence indicates existing pressures within parts of
the network.
8.6 Policy Considerations
Based on the transport evidence and local context outlined above, several policy considerations
arise.
8.6.1 Conflict with sustainable transport objectives
The Strategic Transport Assessment supporting the RLDP (BP14 and BP14a) emphasises the
importance of locating development where sustainable transport options are available and
where reliance on private vehicles can be reduced.
8.6.2 Infrastructure capacity and network pressures
Transport evidence identifies existing pressures within parts of the local highway network,
including peak-period congestion at key junctions serving the area. When considered alongside
recent and ongoing development within the Cowbridge–Aberthin corridor, the potential
cumulative effect of additional traffic generation may require further assessment to ensure that
local infrastructure can accommodate additional demand.
8.6.3 Consistency with the RLDP spatial strategy
Planning Policy Wales and the RLDP strategy emphasises directing development toward
locations with stronger accessibility to services, facilities and sustainable transport networks. As
a small rural settlement with limited transport connectivity, the role of Aberthin within this
spatial strategy may require careful consideration when assessing the suitability of additional
housing allocations.
8.7 Education capacity
The Council’s education evidence (BP43 Education) confirms that secondary education provision
serving the Cowbridge area is already under pressure.
Appendix F of BP43 identifies that Cowbridge Comprehensive School will require an additional
177 places to accommodate projected demand generated by RLDP growth.
BP43 uses the following pupil yield formula:
• Primary: Dwellings × 0.278
• Secondary: Dwellings × 0.208
Applying this to a development of 20–30 dwellings at Aberthin would generate approximately:
• 6–8 primary pupils
• 5–6 secondary pupils
• approximately 1 Additional Learning Needs (ALN) pupil
BP43 also confirms that ALN provision across the authority is already under pressure.
The Aberthin allocation therefore adds additional pupil demand to an already constrained
education system.
Given that the RLDP already provides 8,660 dwellings against a requirement of 7,890 (a surplus
of 770 dwellings) and affordable housing delivery is already secured through larger strategic
allocations, the additional education demand created by HG4(2) Aberthin is unnecessary for the
delivery of the Plan’s housing strategy.
9 Landscape, Settlement Edge, Hedgerow Protection, Public Right of
Way, Conservation Area and Nearby SSSI
9.1 Landscape and heritage setting sensitivity
The proposed allocation HG4(2) – Land West of Maendy Road, Aberthin lies wholly within a
Special Landscape Area (SLA) designated by Vale of Glamorgan Council. Special Landscape Areas
identify landscapes of locally significant character and visual quality, and planning policy
requires development within such areas to conserve and enhance landscape character and
avoid unnecessary harm to valued landscapes.
The site comprises open agricultural land immediately west of Aberthin, forming part of the
rural valley landscape associated with the Nant Aberthin corridor and contributing to the wider
countryside setting of the village and surrounding landscape extending toward Cowbridge.
Key landscape characteristics include:
• open pastoral farmland typical of the Vale of Glamorgan landscape
• strong hedgerow field boundaries reflecting historic field patterns
• visual connection with the Nant Aberthin valley landscape
• a continuous mature hedgerow along the western boundary running north–south
This hedgerow forms a defining landscape feature, contributing both to the historic field
structure of the landscape and to ecological connectivity.
The existing development along Maendy Road forms a clear and well-defined rural settlement
edge to Aberthin. The proposed site lies beyond this edge and currently reads as open
countryside rather than part of the village. Development of approximately 25 dwellings would
extend the built form westwards into open farmland, resulting in:
• encroachment of residential development into countryside
• erosion of the clear distinction between settlement and rural landscape
• urbanisation of the existing rural settlement edge.
These changes would be particularly sensitive given the site’s location within a Special
Landscape Area.
The site also forms part of the wider setting of the Aberthin Conservation Area, which protects
the historic character and appearance of the village under the Planning (Listed Buildings and
Conservation Areas) Act 1990. Aberthin is characterised by traditional stone cottages, a compact
historic form and a strong relationship with the surrounding countryside. The open farmland
west of the village contributes to this rural setting and historic landscape context. Development
of the site would extend the built form into land that currently forms part of that setting,
potentially altering the way the historic settlement is experienced within the surrounding
landscape.
The site is also located close to Cors Aberthin SSSI, a designated Site of Special Scientific Interest
recognised for its wetland habitats and ecological importance within the Nant Aberthin valley
system. SSSIs are protected under the Wildlife and Countryside Act 1981, and planning policy
requires that development should avoid Development Advice Mapage to their special scientific
interest and associated ecological systems.
The proximity of the allocation to Cors Aberthin SSSI reinforces the environmental sensitivity of
the wider landscape, particularly in relation to:
• hydrology and water movement within the valley
• ecological connectivity through the Nant Aberthin corridor
• protection of surrounding habitats that contribute to the ecological functioning of the
SSSI.
9.2 Significance and protection of the boundary hedgerow
The continuous hedgerow running along the western boundary of the site is likely to be of
considerable ecological, historic and landscape value.
Hedgerows of this type in the Vale countryside commonly:
• form part of historic field boundaries
• provide habitat corridors for birds, bats and small mammals
• contribute significantly to the traditional landscape character of the Vale of Glamorgan
Such hedgerows may qualify as “Important Hedgerows” under the Hedgerows Regulations 1997.
Where a hedgerow meets the criteria set out in these Regulations:
• removal requires formal consent from the local authority, and
• if the hedgerow is classified as important, consent for removal must normally be
refused.
Removal of an important hedgerow without permission constitutes a criminal offence.
Given the continuous north–south structure of the boundary hedgerow and its role in the
historic field pattern, there is a realistic possibility that the hedgerow would meet the criteria for
protection.

9.3 Public Right of Way and proposed realignment
A Public Right of Way (PRoW) currently crosses the site through open agricultural land, forming
part of the rural footpath network around Aberthin. In its current form the route is experienced
as a traditional countryside path, crossing open farmland with clear visibility and an open rural
character.
However, the indicative layout associated with the allocation appears to show the path diverted
along the western boundary of the site, coinciding with the existing hedgerow. The proposed
layout indicates:
• rear residential gardens backing onto the path
• tree planting along the boundary
• the route positioned between housing plots and boundary vegetation.
9.3.1 Loss of rural character and safety concerns
This realignment would fundamentally alter the character of the route. Instead of crossing open
countryside, the diverted path would form a long, narrow corridor along the edge of the
development. The path would therefore be experienced as a confined passage rather than an
open countryside route, raising concerns regarding:
• loss of the rural character of the right of way
• reduced visibility and openness
• personal safety for walkers.
The arrangement would effectively create a long-enclosed route resembling an alleyway,
particularly where gardens back directly onto the path. These concerns are amplified by the
likelihood that the route would remain unlit, as public rights of way across rural land are rarely
provided with lighting, particularly within Special Landscape Areas where lighting may conflict
with policies protecting rural character and dark skies.
The resulting route would therefore be a long, narrow and potentially unlit corridor, raising
further safety and amenity concerns.
Length of enclosed
alleyway
9.3.2 Legal implications of diversion
Any diversion of a Public Right of Way requires a legal order under the Highways Act 1980.
To be confirmed, such an order must demonstrate that:
• the diversion is necessary to enable the development, and
• the alternative route is not substantially less convenient or less enjoyable for the public.
Replacing a path that currently crosses open countryside with a route running along the edge of
housing development may therefore attract objections from users, residents or rights-of-way
groups, potentially preventing confirmation of the diversion order.
9.4 Interaction between the path diversion and hedgerow removal
The proposed diversion appears to coincide directly with the existing boundary hedgerow,
suggesting that the development may require removal or substantial alteration of this hedgerow
in order to accommodate the path and housing layout.
If the hedgerow qualifies as an Important Hedgerow under the Hedgerows Regulations 1997, its
removal may be legally restricted or refused, creating uncertainty regarding whether the layout
assumed by the allocation could be implemented.
9.5 Implications for site deliverability
The allocation therefore appears to depend upon:
• diversion of an existing Public Right of Way,
• possible removal or alteration of a potentially protected hedgerow, and
• development within an SLA and sensitive landscape setting closely associated with the
Cors Aberthin SSSI and Nant Aberthin ecological corridor.
Each of these matters involves separate legal and environmental considerations, none of which
can be assumed to be achievable at the plan allocation stage.
If the diversion were refused, or if removal of the hedgerow were not permitted, the layout
assumed by the allocation may not be achievable in practice.
9.6 Conclusion
The allocation of HG4(2) would introduce residential development into open countryside within
a designated Special Landscape Area, extending the settlement edge of Aberthin into land that
currently contributes to the village’s rural setting and the wider setting of the Aberthin
Conservation Area.
The site contains a continuous boundary hedgerow likely to be of significant landscape and
ecological value, which may qualify for protection under the Hedgerows Regulations 1997.
The indicative layout also proposes diverting an existing Public Right of Way from its current
route across open farmland to a narrow boundary corridor running between residential gardens
and boundary planting, fundamentally altering the character of the route and raising safety and
amenity concerns, particularly as the path would likely remain unlit.
The site also lies close to Cors Aberthin SSSI, further highlighting the environmental sensitivity of
the surrounding landscape.
Taken together, these factors raise serious concerns regarding landscape impact, heritage
setting, environmental sensitivity, legal constraints and the practical deliverability of the
allocation, particularly given that the Plan already provides sufficient housing supply without
reliance on development of this sensitive site.

10 Plan Soundness and potential Misapplication of Policy HG4
10.1 Affordable Housing Exception Policy Must Operate Within National Policy
Policy HG4 allows for small-scale affordable housing-led development in Minor Rural
Settlements, reflecting the Welsh Government policy approach to rural exception sites.
However, such policies are intended to operate within the framework of the Plan’s spatial
strategy, not to override it.
Affordable housing exception mechanisms are designed to allow limited, carefully justified
departures from the normal settlement boundary approach where local need is demonstrated
and cannot otherwise be met. They are not intended to provide a general mechanism for
allocating greenfield housing sites in rural settlements.
The allocation of Site 2299 appears to rely on HG4 as the primary justification for development,
rather than demonstrating that the site aligns with the broader spatial strategy and site
selection methodology of the Plan.
PPW (12) allows rural affordable housing through exception mechanisms, but only where
certain conditions are met.
• small-scale
• genuinely local need (not demonstrated in Aberthin)
• proportionate to settlement size (2299 is disproportionate estate scale development)
• does not undermine settlement strategy (outside strategic growth and sustainable
areas)
Development Plans Manual (Edition 3) states that site allocations should:
• flow from the spatial strategy
• follow the site search sequence
• be supported by a transparent assessment process
In other words:
Strategy → site selection → allocation
In the case of site 2299 the order appears reversed:
Site promoted → affordable housing justification → boundary expanded → allocation.
That is the type of site-led planning the manual warns against.
10.2 HG4 Overrides the Plan-Led Site Selection Process
The evidence in the Candidate Site Assessment indicates that the site has been taken forward
solely on the basis that it could deliver affordable housing and there is no indication that the
assessment methodology has been carried out
This approach effectively allows HG4 to override the wider plan-making framework, including:
• the settlement hierarchy,
• the spatial distribution of housing growth,
• the requirement to prioritise sustainable locations, and
• the established methodology for identifying appropriate development sites.
This creates a policy loophole whereby any countryside site adjacent to a minor rural settlement
could potentially be justified simply by proposing affordable housing. This risk appears to have
been realised. HG1, 3 and 4 were all rejected according to the assessment methodology but
resubmitted as affordable led upon guidance: “but the site could be reconsidered as a small
scale affordable housing led development”.
HG4(2) Aberthin was previously rejected in the 2011-2026 LDP then crucially did not go through
the normal assessment process but went straight to allocation as affordable-led. This creates a
precedent for any candidate site, including those previously rejected to be submitted as
affordable-led and potentially be allocated without robust assessment.
Such an approach undermines the plan-led system and the spatial strategy on which the RLDP is
based.
10.3 Lack of Evidence That the Site Is Necessary to Deliver Affordable Housing
The justification for the site relies on reference to the Local Housing Market Assessment
(LHMA), which identifies a need for additional affordable housing within the relevant ward of
Cowbridge.
However, the existence of an identified need does not in itself justify the allocation of specific
countryside sites.
The RLDP must demonstrate that:
1. the affordable housing requirement cannot be met within the overall housing supply,
and
2. the proposed site represents the most appropriate and sustainable location to
contribute to meeting that need.
Neither has been demonstrated.
As previously discussed, the RLDP already provides a significant surplus of housing provision
over the housing requirement, including substantial capacity within more sustainable
settlements.
In these circumstances, the allocation of a countryside site solely on the basis of affordable
housing provision i.e. HG4 exception, is not justified.
10.4 Soundness Implications
For a Local Development Plan to be sound it must be:
• Justified – based on a robust and credible evidence base and the most appropriate
strategy.
• Consistent with national policy.
• Effective and deliverable.
The reliance on Policy HG4 as the primary justification for Site 2299 raises concerns in respect of
all three tests.
In particular:
• Justified: The evidence base does not demonstrate that the site is necessary to deliver
the Plan’s housing or affordable housing objectives, or that there is any evidenced need
in Aberthin
• Consistent with National policy: The allocation does not appear to arise from a
consistent application of the spatial strategy or site selection methodology and does not
take account of flood risks in accordance with policy. The approach risks undermining
the plan-led system by allowing countryside sites to be allocated solely on the basis of
affordable housing provision.
• Effective and Deliverable: The number of constraints lack mitigation evidence, e.g. no
FCA, SUDs assessment, overall site viability assessment and other missing assessments,
the limited infrastructure of the area is not mitigated, and only summary financial
viability is provided, and this has discrepancies
For these reasons, the allocation of Site 2299 using HG4 cannot be considered justified or sound.

11 Conflicts with methodology, shifts, audit trail concerns and gaps
11.1 Candidate Site Assessment Methodology (BP16)
11.1.1 Site Assessment Criteria Outcomes
Site 2299 has been assessed against 35 criteria within the candidate site assessment framework.
Of these, 12 criteria are recorded as green (no identified constraints to development). Four
criteria are marked as red, which represent the most significant level of concern, typically
indicating a major constraint to development, potential conflict with national policy, or
insufficient information to support the assessment.
A review of the scoring suggests that some classifications may warrant further consideration, as
below, and may increase red scores to 6. A site could be rejected on the basis of a single red
score (p10).
11.1.2 Potential Issues in the Scoring
11.1.2.1 Environment and Physical Constraints
The site is recorded as Amber under the category of Environmental and Physical Constraints.
However, part of the site lies within Flood Zone 3 and therefore appears to engage the
requirements of Technical Advice Note 15 (TAN15), specifically the Justification Test and
Acceptability of Consequences tests set out in Sections 10 and 11.
Guidance provided in Background Paper BP16 (page 20) states that sites located within Flood
Zone 3 will only be considered where specific criteria are met. These include:
• The development is required under exceptional circumstances, such as those relating to
national security, energy security, public health, or climate change mitigation.
• The site meets the definition of previously developed (brownfield) land.
• The proposal is supported by a Flood Consequences Assessment (FCA) demonstrating
that the potential consequences of flooding are acceptable in accordance with the
criteria contained within Section 11 of TAN15 (2021).
In the case of Site 2299:
• No exceptional circumstances have been identified.
• The site is greenfield rather than previously developed land.
• No evidence has been presented demonstrating compliance with the acceptability of
consequences test.
Further, on page 7 of the guidance:
“Flood risk – sites located within either a TAN 15 Defended Area, or Flood Zone 2 or 3 area which
do not meet the justification test and acceptability of consequences section 10 and11 out in TAN
15 will not pass the initial sifting.”
In light of these factors, the classification of Amber within this category is surprising, as it
appears the site should have not have even passed initial sifting.
11.1.2.2 Landscape Considerations
The site is also scored Amber under the Special Landscape Area criterion. However, the scoring
guidance indicates that a site should be classified as Red where it is predominantly greenfield
and wholly located within a Special Landscape Area or a Registered Landscape of Outstanding or
Special Historic Interest.
Site 2299 is identified as greenfield land and lies entirely within a designated Special Landscape
Area. Based on the stated scoring methodology, this suggests that a Red classification could be
more consistent with the guidance provided.
11.1.3 FCA requirement
On page 22 the FCA requirement and discounting rule is clear:
“Sites which are not accompanied by a FCA or do not meet the tests shall be automatically
discounted from further consideration.”
Site 2299 does not have an FCA, so should have been discounted.
11.2 Deposit assessment audit-trail concerns (BP18A) and unexplained shifts
Inconsistencies in the deposit candidate site assessment narrative are noted:
• BP18A p.14 describes the site 2299 as conforming with strategy/initial filter and uses
language indicating it is ‘adjacent’ to the settlement; later narrative suggests it is ‘in’ the
settlement without a published boundary justification.
• BP18A p.20 notes ‘suitable for further consideration’ while listing constraints without
explaining why those constraints did not prevent progression under BP16.
• BP18A p.34 significantly downplays flood risk (references only a part in Flood Zone 3) and
does not reflect mapped intermediate surface water risk covering around half the site,
historical flood data and ground water risk.
• BP18A p.77 contains a ‘Acceptable at PS stage’ recorded as “N/A” for site 2299 and a
‘Justification’ field recorded as “N/A” for site 2299, which undermines transparency.
• BP18A also indicates that detailed site proformas exist and are available on request. The
Council should disclose the full Site 2299 proforma used for decision-making, including RAG
scoring rationale and any override decisions.
• BP18A p.34 – indicates a viability assessment has been submitted for site 2299 which
demonstrates that the site is deliverable as an affordable housing led site. Only a summary
table has been published, which appears to under cost, and may need validating in light of
flood risks, SUDs viability, no sewerage on site, and contributions to education and
infrastructure costs cited elsewhere.
11.3 Independent viability evidence gap and deliverability risk (BP42A)
• BP42A (December 2025) provides Independent Financial Viability Assessments of five
strategic/key sites. Site 2299 is not included. Planning Policy Wales (PPW 12) directs
that: “as part of demonstrating the deliverability of housing sites, financial viability must
be assessed prior to their inclusion as allocations in a development plan. At the
‘Candidate Site’ stage of development plan preparation, land owners/developers must
carry out an initial site viability assessment and provide evidence to demonstrate the
financial deliverability of their sites.”
• BP42A states it is concerned with financial viability only and not broader constraints.
• Site 2299 is not a low-risk site; it is flood constrained, and requires a robust
management plan, SUDs viability needs testing (extending to SSSI implication), requires
full new sewage/drainage infrastructure, has access uncertainties and SLA landscape
constraints. These drive abnormal costs. Without site-specific viability testing,
deliverability and affordable housing delivery cannot be assumed.
• Site 2299 has viability tension: as abnormal costs rise (flood mitigation, SuDS,
groundwater management, highway works, sewage/drainage installation and potential
off-site reinforcement), affordable housing delivery is typically the first pressure point.
The RLDP must evidence deliverability for this site, not assume it.

12 Tests of soundness
For the RLDP to be sound it must be Justified, Effective and Consistent with National Policy.
12.1 Not Justified
The allocation is not supported by proportionate evidence:
• the RLDP already provides 770 dwellings above the housing requirement
• the site contributes only 0.42% of projected affordable housing delivery
• no specific local affordable housing need has been demonstrated within Aberthin
• the site conflicts with the spatial strategy which limits growth in Minor Rural
Settlements
• the allocation represents a departure from the Council’s own site assessment
methodology
• the allocation lacks a transparent audit trail
• does not demonstrate why this constrained countryside site is the most appropriate
option, particularly given delivery elsewhere in the corridor and strategic sites
12.2 Not Effective
The site cannot be shown to be deliverable because:
• significant flood risk constraints remain unresolved
• no Flood Consequence Assessment has been undertaken
• groundwater monitoring recommended in the evidence has not been completed
• the SuDS strategy has not been demonstrated to be viable
• potential impacts on Cors Aberthin SSSI hydrology have not been assessed
• no-worsening test absent
• access, drainage and infrastructure constraints remain uncertain
• viability is not independently tested or fully costed
12.3 Not Consistent with National Policy
The allocation conflicts with Technical Advice Note 15 (Flood Risk) because:
• the site partly lies within Flood Zone 3
• residential development is highly vulnerable development
• TAN15 states such development should not occur on greenfield land in Flood Zone 3
unless essential to the LDP
• the RLDP already contains a substantial housing surplus, meaning the site cannot be
considered essential
12.4 Conclusion
For these reasons the allocation of HG4(2) – Land West of Maendy Road, Aberthin cannot be
considered sound.
The site should therefore be removed from the RLDP.
10.3 Not consistent with national policy: the allocation conflicts with national objectives for
sustainable location and robust flood risk management (including safe access/egress and no
worsening).

13 Formal request and proposed modifications
1. Primary request: delete Site 2299 from the RLDP and remove it from Policy HG4.
2. Settlement boundary: do not redraw the Aberthin settlement boundary to include this
field parcel; if already redrawn, reinstate the defensible boundary aligned to existing
built form unless a published boundary review justifies change.
Evidence disclosure requests (minimum):
a. Robust evidence qualifying necessity under HG4, aligned to national policies
b. Full Site 2299 proforma (BP18A indicates proformas exist and are available on
request), including all scoring and override rationale.
c. Full FCA including modelling outputs, assumptions, and climate change
allowances for both fluvial and pluvial events, surface runoff from surrounding
slopes, high groundwater susceptibility, principal aquifer conditions, cumulative
testing, implications on the nearby SSSI wetland habitat, ecology assessment
and no worsening test.
d. Surface water modelling demonstrates intermediate risk treatment, exceedance
routing and no worsening.
e. The advised 12-month Groundwater monitoring and data
f.
SuDS feasibility and design, including implications on the nearby SSSI and
ecology.
g. Drainage strategy demonstrating foul connection feasibility, capacity, and any
required off-site reinforcement.
h. Dry access/egress assessment for residents and emergency vehicles during flood
events.
i.
j.
Highways feasibility: access location, visibility, swept-path tracking and road
safety audit.
Active travel and public transport assessment with deliverable mitigation
package and funding mechanism.
k. Landscape/visual assessment for SLA impacts.
l.
Ecology and heritage appraisals including SSSI proximity and Conservation Area
setting.
m. Site-specific viability appraisal (including all abnormal costs) demonstrating
affordable housing deliverability.
3. Confirmation regarding protection of hedgerow
4. Confirmation regarding PRoW

1. Primary request: delete Site 2299 from the RLDP and remove it from Policy HG4.
2. Settlement boundary: do not redraw the Aberthin settlement boundary to include this field parcel; if already redrawn, reinstate the defensible boundary aligned to existing built form unless a published boundary review justifies change.
Evidence disclosure requests (minimum):
a. Robust evidence qualifying necessity under HG4, aligned to national policies
b. Full Site 2299 proforma (BP18A indicates proformas exist and are available on request), including all scoring and override rationale.
c. Full FCA including modelling outputs, assumptions, and climate change allowances for both fluvial and pluvial events, surface runoff from surrounding slopes, high groundwater susceptibility, principal aquifer conditions, cumulative testing, implications on the nearby SSSI wetland habitat, ecology assessment and no worsening test.
d. Surface water modelling demonstrates intermediate risk treatment, exceedance routing and no worsening.
e. The advised 12-month Groundwater monitoring and data
f. SuDS feasibility and design, including implications on the nearby SSSI and ecology.
g. Drainage strategy demonstrating foul connection feasibility, capacity, and any required off-site reinforcement.
h. Dry access/egress assessment for residents and emergency vehicles during flood events.
i. Highways feasibility: access location, visibility, swept-path tracking and road safety audit.
j. Active travel and public transport assessment with deliverable mitigation package and funding mechanism.
k. Landscape/visual assessment for SLA impacts.
l. Ecology and heritage appraisals including SSSI proximity and Conservation Area setting.
m. Site-specific viability appraisal (including all abnormal costs) demonstrating affordable housing deliverability.
3. Confirmation regarding protection of hedgerow
4. Confirmation regarding PRoW

This representation objects to the allocation of Site HG4(2) – Land West of Maendy Road,
Aberthin (Site 2299) within the Vale of Glamorgan Replacement Local Development Plan (RLDP).
The allocation proposes approximately 25 dwellings as an affordable housing-led development
on greenfield agricultural land forming part of the countryside immediately west of Aberthin.
The allocation is unsound for several independent reasons.
First, the proposal conflicts with the Plan’s spatial strategy.
Aberthin is identified as a Minor Rural Settlement, where development is expected to be limited
in scale and primarily related to local needs. A development of approximately 25 dwellings
would represent around a 14% expansion of the settlement in a single phase, introducing
estate-scale growth into a small rural village with very limited services. This represents a
material step-change inconsistent with the role of such settlements within the hierarchy.
Second, the site is not necessary for delivery of the Plan’s housing strategy.
The RLDP identifies a housing requirement of 7,890 dwellings and housing provision of 8,660
dwellings, creating a surplus of 770 dwellings above the requirement. Removal of HG4(2)
Aberthin would still leave a surplus of 745 dwellings, and even removal of all HG4 rural
affordable-led sites would leave a surplus of 648 dwellings. The allocation is therefore not
required for the Plan to deliver its housing requirement.
Third, the RLDP evidence identifies affordable housing need at a ward level (Cowbridge) rather
than within Aberthin itself, and no evidence has been presented demonstrating a specific locally
arising need within the settlement.
Forth, the site makes only a negligible contribution to affordable housing delivery. The site is
expected to deliver approximately 13 affordable homes, representing only 0.42% of the Plan’s
projected affordable housing delivery of 3,070 homes. The Plan is therefore not materially
dependent on the site to deliver its affordable housing strategy.
Fifth, the site is heavily constrained by flood risk and drainage uncertainty.
Part of the site lies within Flood Zone 3, where highly vulnerable development on greenfield
land is not permitted under Technical Advice Note 15 (TAN15) unless the development is
essential to the Local Development Plan. Given the Plan’s housing surplus, and no identified
local need, the site cannot reasonably be considered essential. In addition:
• no detailed hydraulic model exists for the Nant Aberthin watercourse,
• no Flood Consequence Assessment has been undertaken at allocation stage,
• groundwater susceptibility is classified as “Red – high – groundwater likely to be at or
near the surface”, with a recommendation for 12 months monitoring which has not
been undertaken,
• surface water mapping indicates intermediate flood risk across part of the site, and
historical flood data indicates flooding
• the proposed SuDS detention basin location appears to fall within Flood Zone 3
according to Council constraint mapping, raising questions regarding compliance with
SuDS design guidance,
• the viability and performance of the proposed drainage strategy has not been
demonstrated, including potential effects on the hydrology of the nearby Cors Aberthin
SSSI wetland system, and
• no modelling has been provided to demonstrate that development would not worsen
flood risk to neighbouring properties, including those at Maes Lloi.
Taken together, these factors create substantial uncertainty regarding whether a compliant
drainage strategy could be delivered and whether flood risk could be safely managed.
Sixth, the site presents infrastructure and accessibility constraints.
Aberthin has very limited services and infrastructure. The settlement contains no shops and
limited community facilities, with most services located in nearby Cowbridge. Public transport
provision is limited to infrequent bus services which cease in the early evening and do not
operate on Sundays, and there are no designated active travel routes connecting the settlement
to surrounding towns. The road network through the village, particularly along the A4222
corridor, already experiences traffic pressures and safety concerns. The Council’s education
evidence also confirms that secondary school capacity serving the area is already under
pressure, with additional places required to accommodate projected growth.
Seventh, the allocation introduces development into a sensitive landscape and environmental
setting.
The site lies entirely within a Special Landscape Area, contributes to the countryside setting of
the Aberthin Conservation Area, lies close to Cors Aberthin SSSI, and contains established
hedgerow boundaries forming part of the historic field pattern of the Vale landscape.
Finally, the allocation represents a clear departure from the Council’s published site assessment
methodology.
Background Paper BP16 indicates that sites affected by flood risk should normally be discounted
from further consideration. Despite multiple constraints — including Flood Zone 3, groundwater
susceptibility and surface water risk — Site 2299 was not discounted. The site was previously
rejected during preparation of the adopted LDP on the basis that it was unrelated to the
settlement and constituted sporadic development in the countryside, and no material change in
circumstances has been demonstrated to justify a different conclusion. Additionally, audit trail
concerns are evident, e.g. N/A values in justification columns.
Taken together, the evidence demonstrates that the allocation:
• is not necessary to deliver the Plan’s housing requirement or affordable housing
outcomes, and no need has been established
• conflicts with national flood policy (TAN15),
• is inconsistent with Council’s own site assessment methodology, and
• introduces development into a sensitive rural landscape with infrastructure constraints
unnecessarily.
In conclusion, these matters demonstrate that the allocation fails the key tests of soundness: it
is not justified by the evidence, is not effective or deliverable due to unresolved environmental
and infrastructure constraints, and is not consistent with national policy, including Planning
Policy Wales (sustainable spatial strategy and protection of landscape) and Technical Advice
Note 15 (flood risk)
For these reasons, Site HG4(2) – Land West of Maendy Road, Aberthin should be removed from
the RLDP.

3.1 Settlement size and character
Aberthin is classified as a minor rural settlement. It is a historic agricultural village built around
the Nant Aberthin (Aberthin Brook), a tributary that flows into the River Thaw. The settlement is
surrounded by agricultural land parcels and a large common land called Stalling Down.
It is estimated to contain approximately 176 dwellings.
There is a close-knit community feel, with many residents taking parts in community events
organised by the village hall committee, such as a duck race (where plastic yellow ducks are
raced down the stream), a free bonfire and fireworks display held on the downs, quiz nights,
amateur dramatics and an annual Village Day, which has a barbeque, music and a dog show.
Aberthin has already been recently extended, under the last LDP. In around 2017, 20 properties
were built in Court close, 6 of those affordable. The settlement boundary was redrawn to
accommodate the site, as can be seen in the map below, marked in red. (REFER TO ATTACHED PDF FOR IMAGES)
3.1.1 Settlement boundary

3.2 Landscape and Environmental Context of Aberthin
The settlement is characterised by its historic village form, traditional buildings and strong
relationship with the surrounding countryside. Much of the landscape surrounding the village is
designated as a Special Landscape Area by Vale of Glamorgan Council, reflecting the recognised
scenic quality and rural character of the Nant Aberthin valley and the wider Vale landscape. The
historic character of the settlement is also recognised through the designation of the Aberthin
Conservation Area, which protects the architectural and historic character of the village and its
relationship with the surrounding rural landscape.
The surrounding countryside comprises a network of agricultural fields defined by historic
hedgerow boundaries, forming part of the traditional field pattern typical of the Vale of
Glamorgan. The area is also notable for its historic environment, with several Scheduled Ancient
Monuments and other archaeological features recorded in the surrounding landscape, reflecting
long-standing human activity in the Nant Aberthin valley. The landscape also supports important
ecological features associated with the Nant Aberthin watercourse and valley system, including
the nearby Cors Aberthin SSSI, a designated wetland site protected under the Wildlife and
Countryside Act 1981. Public rights of way cross the surrounding farmland, providing access to
the countryside and contributing to the rural character and recreational value of the area.
3.2.1 Landscape features
SSSI: shown in red, Conservation Area – maroon boundary, monuments in blue, ancient
woodland in green crosshatch, and SINC in green horizontal lines

3.3 Services and facilities
Aberthin has very limited services and infrastructure.
Known facilities include:
• a small community centre (a charity created to support itself, run by volunteers)
• two public houses, one of which has been operated and staffed primarily by the same
family for approximately 20 years.
The pubs are both well attended.
There are no shops.
The nearest Medical Centre is in central Cowbridge.
Cowbridge primary and secondary schools are within walking distance. The schools have had
significant oversubscription issues for at least a decade, despite recent expansion. There are no
other easily commutable secondary schools in the area.
3.4 Transport accessibility
Public transport provision is also extremely limited:
• The nearest train station is in Pontyclun, 4.7 miles way
• There is only one bus stop, located on one side of the road, for buses headed North.
Although buses do stop in the opposite direction, taking residents towards Cowbridge,
there is no designated bus stop, street furniture or pavements, for safety purposes. The
stop is also on a 90-degree bend with multiple side roads and opposite a pub car park
which all together pose a risk to personal safety.
• Buses operate approximately hourly
Services run only until around 7:30 pm
• No Sunday or bank holiday services exists.
• Buses are not busy
There are no designated cycle paths (Active Travel). A scheme went through consultation but
met with multiple objections. Some of these are relevant to LDP planning elements, such as:
o The high volume and speed of traffic on the existing highways, predominantly the A4222
that runs directly through Aberthin
o A lack of segregated infrastructure in the area, which would force cyclists to share space
with cars in narrow sections.
o The lack of street lighting in the area, which made the route unappealing for use at night
or during winter.
o Concerns regarding installing lighting due to wildlife disruption
The project has been on hold for 3 years.
The settlement is not (for many) realistically walkable to any nearby towns, including
Cowbridge, the nearest town, the centre of which is 2km away. There is a reliance on Cowbridge
for most needs. In some places pavements do not exist or are not continuous through either
side of the village. Most residents rely on car travel.
3.5 Flood risks and geology
Aberthin is in a flood risk area, with most of the heart of the village in flood zone 3 and further
parts in flood zone 2:
• Fluvial Risk (Rivers): The area immediately surrounding the Nant Aberthin is subject to
flood risk. Nant Aberthin joins the River Thaw,
• Surface Water: Due to its position at the base of the steep Pen y Lan Road and Stalling
Down, the village and the adjacent field of the proposed site 2299 are susceptible to
local flood risk caused by surface runoff during intense rainfall. Groundwater also
naturally flows downhill towards valley bottoms, where it can emerge as springs or
cause the water table to reach the surface.
• Groundwater: Much of the village and the surrounding valley floor is classified by the
British Geological Society as having a High Susceptibility to groundwater flooding. This
means geological conditions (specifically the permeable limestone bedrock and
overlying river gravels) could enable groundwater to emerge at the surface or remain
very shallow.
• Aquifer Designation: The underlying Carboniferous Limestone is classified as a Principal
Aquifer. These are layers of rock with high permeability that provide significant water storage. In Aberthin, this leads to a "flashy" groundwater table that rises rapidly in
response to rainfall.
• Alluvial Deposits: The valley floor contains permeable layers of alluvium and gravel.
When the nearby River Thaw or Nant Aberthin rises, it can "push" groundwater up
through these deposits into low-lying areas, a process known as groundwater-surface
water interaction.
• Under the Water Framework Directive (WFD), the groundwater body in this part of the
Vale of Glamorgan is generally monitored for "Good" or "Poor" quantitative status.
Additionally, much of the centre and the surrounding agricultural land to the immediate North
and West has experienced historical flooding and is in Development Advice Map Zone B

4 Site identification and baseline facts
4.1 Site 2299 or HG4(2)
Site 2299 is described as ‘Land West of Maendy Road, Aberthin’, promoted for 25 dwellings.
Its’ status is undeveloped greenfield land (agricultural field). Current lawful use and any
covenants/easements must be confirmed via Land Registry title and planning history searches.
The site is one of 4 proposed through policy HG4 – rural affordable housing-led site.

4.2 Scale and proportionality
Aberthin is understood to have 176 dwellings. 25 dwellings = 14.2% increase in a single phase.
This also follows a development in 2017 which already saw a 13% increase, so the new
development constitutes urban sprawl.

4.2.1 Site map for HG4 (2) in relationship to existing Aberthin settlement
4.3 Development proposal context diagram

4.4 Key mapped constraints/sensitivities
• Wholly within Special Landscape Area (SLA).
• Partial Flood Zone 3 (southern end) and broader fluvial sensitivity in the Nant Aberthin
corridor.
• Intermediate surface water risk across approximately half the site (per Vale planning
constraints mapping), with additional low surface water risk elsewhere.
• Groundwater susceptibility identified as ‘red – highest to ground’ and recommendations for 12
months groundwater monitoring and FCA
• History of flooding (DEVELOPMENT ADVICE MAP Zone B) across middle of the site
• Current (known) southern access wholly within Flood Zone 3; width constraints for emergency
vehicles.
• No existing sewerage or drainage infrastructure on site.
• Public right of way interacts with the southern access area and proposed drainage features
and run along western end from bottom to top of site
• Proximity to designated assets (SSSI nearby, SINC 165, Conservation Area setting) and mineral
safeguarding (limestone safeguarding area).
• Historic hedgerow running down western side of site

5 Principle, spatial strategy and previous rejection
5.1 Conflict with the Plan’s Spatial Strategy
The core objection is one of principle. The proposed allocation would release open countryside
for estate-scale residential development in a Minor Rural Settlement, contrary to the spatial
strategy of the RLDP.
The RLDP directs the majority of housing growth to sustainable locations — higher-order
settlements and service centres — where employment, services, public transport and
infrastructure are available. Minor Rural Settlements are not intended to accommodate estate
scale development; growth in such locations is expected to be very limited and typically
confined to local need or small-scale infill. Aberthin is not identified as a strategic growth
location and no specific local affordable housing need within the settlement has been
demonstrated.
This strategic approach is reflected in the housing distribution set out in BP9A. Figure 2 shows
that only 4.5% of total housing growth is directed to Minor Rural Settlements and Primary
Settlements outside the Strategic Growth Area. Applied to the Plan’s total housing provision of
8,660 dwellings, this equates to approximately 390 dwellings across all minor rural settlements
over the 15-year plan period. By contrast, the overwhelming majority of growth is directed to
larger settlements:
Settlement Category
Share of Housing
Primary settlements in Strategic Growth Area 40.5%
Service centres
26.4%
Key settlements
24.9%
This distribution demonstrates that minor rural settlements are not intended to play a
significant role in housing delivery, with growth instead concentrated in locations with stronger
services, infrastructure and sustainable transport connections.
Within this context, allocating HG4(2) Aberthin for approximately 25 dwellings would represent
a 14.2% expansion of the settlement in a single phase, introducing suburban-scale development
into a small rural village with very limited services and infrastructure. Although described as
“small-scale”, the assessment fails to consider proportionality: a 14% expansion of a minor rural
settlement cannot reasonably be regarded as small-scale development.
The allocation therefore represents a departure from the Plan’s spatial distribution strategy
rather than an implementation of it.

5.2 Consistency with Previous Plan Evidence
The site was previously assessed during preparation of the Vale of Glamorgan LDP 2011-2026
and rejected. The reason for rejection was clear: the site was considered unrelated to the
settlement and would represent unacceptable sporadic development in the countryside. This
reasoning remains valid.
The physical relationship between the site and the settlement has not changed. The field
remains a separate agricultural parcel outside the established built form of Aberthin. No new
infrastructure, services, or settlement expansion has occurred that would alter this relationship.
Allocating the same site in the absence of any material change in context raises serious
questions about the consistency and robustness of the site selection process.
5.3 Internal Inconsistency in the Council’s Own Assessment
The Council’s Candidate Site Assessment contains a clear internal inconsistency regarding the
status of Site 2299. At Stage 1 the site is described as “adjacent to a minor rural settlement”
(BP18A, p.14), which indicates that the land lies outside the settlement and forms part of the
open countryside. However, at Stage 2 the site is assessed on the basis that “a small-scale
affordable housing led development in a minor rural settlement would accord in principle with
the strategy” (BP18A, p.20).
These statements are incompatible. A site that is adjacent to a settlement is not within it. The
assessment therefore appears to assume that the settlement boundary will be extended to
incorporate the site, yet no explanation or evidence is provided to justify such a boundary
change. This raises serious concerns regarding the transparency and robustness of the site
selection process and suggests that the allocation may be site-led rather than plan-led.
5.4 Scale Does Not Resolve the Principal Conflict
The number of dwellings proposed does not resolve the fundamental policy conflict.
Even if the development were reduced in scale, the underlying issue would remain: the site
constitutes development in the countryside beyond a defensible settlement boundary and
represents estate-style expansion rather than small-scale infill.
5.5 Reliance Solely on Affordable Housing Justification
The Council’s own assessment makes clear that the only substantive justification for the site is
the potential delivery of affordable housing. No other strategic justification is provided.
Indeed, the assessment acknowledges that:
• Aberthin has limited services and facilities, and
• public transport provision is relatively infrequent.
The reliance solely on affordable housing as justification is problematic in principle. Affordable
housing provision cannot justify development in locations that conflict with the spatial strategy,
particularly where the overall housing requirement is already exceeded, the plan target for
affordable housing doubles the historic attainment and need for the LDP to contribute, and
alternative sustainable sites are available.
The detailed assessment of affordable housing need and delivery is addressed separately in
Section [6] of this representation.

6 Affordable Housing, Spatial Strategy, and Necessity: Why HG4(2) Is
Not Required
6.1 The RLDP Already Exceeds the Housing Requirement (and Explicitly Builds
in Flexibility)
A key test in allocating additional housing sites is whether they are necessary for the Plan to
deliver its housing requirement and strategy.
BP9A confirms a housing requirement of 7,890 dwellings and total housing provision of 8,660
dwellings, explicitly described as a 10% flexibility allowance:
• “The housing provision of 8,660 dwellings rounds to a 10% flexibility allowance…”
• “…it is considered that a 10% flexibility should be considered a maximum…”
This creates a surplus of 770 dwellings above the requirement (8,660 – 7,890), meaning the Plan
is not operating at the margin but already includes a substantial buffer.
Removal of HG4(2) Aberthin (25 dwellings) would leave provision at 8,635 dwellings, still
exceeding the requirement by 745 dwellings. Even removal of all HG4 rural affordable-led sites
(122 dwellings) would leave provision at 8,538 dwellings, still exceeding the requirement by 648
dwellings.
The Plan therefore retains a substantial flexibility margin without reliance on the HG4 rural sites.
These allocations are consequently discretionary additions rather than necessary components of
the housing strategy.
6.2 HG4 Rural Affordable-Led Sites Represent a Very Small Component of
Supply and are not Numerically Essential
BP9A identifies “Affordable housing led sites” (HG4) as a limited element of supply totalling 122
dwellings across four settlements (Colwinston 25, Aberthin 25, Wick 50, Fferm Goch 22).
This is 1.4% of total Plan provision.
HG4 rural affordable-led sites therefore represent a very small and numerically non-essential
component of supply. Numerically, the Plan is not dependent on these sites. As set out above,
even removing all HG4 sites, the Plan retains a surplus of 648 dwellings above the requirement.
This confirms that these allocations are not structurally required for housing delivery.
6.3 The 3,070 Affordable Homes Figure Represents Expected Delivery — Not
Demonstrated Need and HG4(2) is immaterial to delivery
A key point in interpreting the Plan’s affordable housing evidence is the meaning of the 3,070
figure referenced throughout the RLDP evidence base.
BP9A confirms that:
“the various sources of housing will contribute 3,070 affordable homes.”
This figure represents expected affordable housing delivery arising from the housing supply
identified in the Plan, including sites with planning permission, sites under construction, housing
allocations, windfalls and affordable-led sites. It is therefore derived from the overall housing
supply and assumed policy performance, rather than representing a quantified level of housing
need that must be met in full. In other words, 3,070 is a projection of delivery, not a measure of
need.
The actual level of demonstrated need is identified through the Local Housing Market
Assessment (LHMA). BP9A confirms that the LHMA identifies:
• 461 affordable homes per year, equating to
• 6,918 affordable homes over the 15-year plan period.
This distinction is critical.
Measure
Demonstrated affordable housing need (LHMA)
Number
6,918 homes
Affordable housing expected to be delivered by the RLDP 3,070 homes
The Plan therefore anticipates delivering less than half of the identified affordable housing need
through the planning system. This is not unusual, as delivery through planning mechanisms is
constrained by factors such as development viability, housing delivery rates, reliance on market
schemes to generate affordable units, and the availability of subsidy and Registered Social
Landlord funding.
However, this distinction is fundamental when considering the necessity of individual
allocations. Because the 3,070 figure represents expected delivery arising from the overall
housing supply, it is not a target that must be achieved through allocating specific individual
sites. The inclusion or exclusion of a small site therefore does not materially affect the Plan’s
affordable housing strategy.
This is particularly clear in the case of HG4(2) Aberthin. BP9A indicates that affordable housing
led sites are expected to deliver at least 50% affordable housing, meaning HG4(2) would provide
approximately:
• 13 affordable homes from 25 dwellings,
with 62 affordable homes across all HG4 rural affordable-led sites combined.
The numerical impact of removing the Aberthin site is therefore extremely small:
• Removing HG4(2) Aberthin reduces affordable delivery from 3,070 to approximately
3,057 homes (0.42% reduction).
• Removing all HG4 rural affordable-led sites reduces delivery from 3,070 to
approximately 3,008 homes (2.02% reduction).
BP18A states that “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.” However, a contribution of 0.42% from the Aberthin site cannot
reasonably be described as important and is numerically negligible.
Accordingly, the Plan is not materially dependent on HG4(2) Aberthin to meet its affordable
housing delivery expectations. The loss of the site would not undermine the Plan’s affordable
housing strategy or prevent the RLDP from delivering the level of affordable housing the Council
expects to arise from the housing supply.
The evidence therefore demonstrates that HG4(2) Aberthin is not necessary for the Plan to
achieve its projected affordable housing delivery.
6.4 Affordable Housing Delivery Framework
Affordable housing delivery in Wales is not solely dependent on allocations or planning
obligations secured through the Local Development Plan (LDP). Welsh Government statistics
show that affordable housing is delivered through a range of mechanisms, including Welsh
Government capital grant programmes, housing association development and direct local
authority provision.
In 2024–2025, 3,643 additional affordable homes were delivered across Wales. Of these, 882
homes (approximately 24%) were delivered through planning obligations linked to market
housing developments, while around 76% were delivered through other routes, primarily grant
funded programmes and delivery by Registered Social Landlords and local authorities. This
demonstrates that the planning system represents one component of the wider affordable
housing delivery framework, rather than the principal delivery mechanism.
Within the Vale of Glamorgan, monitoring reports indicate that 2,398 affordable homes were
delivered between 2011 and 2025 under the current LDP period. Recent statistics also show 147
local authority homes delivered in 2024–2025, demonstrating that council-led delivery
programmes continue to contribute alongside housing association development.
The RLDP evidence suggests that approximately half of identified affordable housing need may
be delivered through planning mechanisms associated with housing allocations. When
compared with national delivery patterns — where planning obligations account for around 24%
of affordable housing provision — this represents approximately double the typical contribution
delivered through planning mechanisms.
The available evidence therefore indicates that the RLDP is already expected to make an
unusually high contribution to affordable housing delivery through planning mechanisms alone.
Given national delivery patterns and the Vale’s historic delivery record, it is reasonable to expect
that a proportion of affordable housing supply during the plan period will continue to arise
through other established mechanisms operating alongside the LDP, including Welsh
Government grant programmes, housing association development and local authority housing
delivery.
The evidence therefore indicates that the Local Development Plan should be understood as one
delivery mechanism within a wider system, rather than the principal mechanism through which
affordable housing need is expected to be met.
6.4.1 Implications for Site Allocation
In this context, the justification for allocating additional sites primarily to support affordable
housing delivery becomes less clear. If the RLDP already assumes a level of provision through
planning mechanisms that doubles typical national delivery patterns, further allocations risk
over-provision relative to what is required to support the plan strategy, raising a potential
question of plan soundness.
This is particularly relevant where proposed sites are rural or environmentally sensitive
locations, or where development may introduce landscape, infrastructure or environmental
impacts affecting the rural character that defines much of the Vale of Glamorgan.
The evidence therefore suggests that the necessity for additional site allocations should be
clearly demonstrated, particularly where affordable housing delivery may reasonably be
expected to arise through the wider delivery framework operating alongside the planning
system.
6.5 The Evidence Base Identifies the Greatest Affordable Need in Larger
Settlements
The LHMA evidence summarised in the RLDP identifies that the greatest affordable housing
need is in:
• Barry
• Penarth / Llandough
• Llantwit Major
• Dinas Powys
• Rhoose
The Plan’s spatial strategy directs the overwhelming majority of growth to these areas and
settlement categories: Key Settlements, Service Centres and Primary Settlements in the
Strategic Growth area. This alignment between identified housing need and the spatial
distribution of growth is a central principle of the Plan’s strategy.
By contrast, Minor Rural Settlements such as Aberthin are not identified as primary locations for
addressing affordable housing need, and the evidence base does not demonstrate a specific
local need within the settlement itself. In this context, allocating a greenfield affordable housing
site in Aberthin appears inconsistent with the evidence base.
6.6 The Council’s “Local Need and Support for Services” Justification Requires
Evidence
The Plan suggests that rural affordable housing allocations are intended to:
• respond to local affordable housing needs, and
• support local services and facilities.
However, the evidence presented within BP9A does not demonstrate:
• there is any affordable housing need locally within Aberthin,
• What services exist that can be supported by extra residents
The justification for HG4 rural affordable housing sites relies on two related propositions: that
they respond to locally arising affordable housing need and that they support the sustainability
of rural communities by helping to maintain local services and facilities. However, the evidence
base does not demonstrate a specific affordable housing need within Aberthin itself (only the
ward of Cowbridge). Nor does the settlement contain a range of services that would realistically
be sustained by a development of this scale. In these circumstances, the policy rationale
underpinning the allocation appears weak. PPW and TAN 6 expects rural affordable housing to
be genuinely locally justified.
6.7 Development Within the Wider Corridor
Housing development has taken place across the Cowbridge–Aberthin–Ystradowen corridor in
recent years. Within Aberthin itself, approximately 20 dwellings were completed around 2017
2018, including affordable homes. The redevelopment of the former Cowbridge school site
between Aberthin and Cowbridge is currently under construction and will deliver approximately
34 affordable homes.
Further housing has been delivered in nearby settlements, including Maple Walk in Ystradowen
(46 homes), with expansion in the RLDP, the former police station site in Cowbridge (14), and
Clare Garden Village (475), with further expansion. Collectively, these developments
demonstrate that housing supply, including significant levels of affordable housing, is already
being delivered within the surrounding area and the corridor may already be at saturation point.
6.8 Overall Conclusion
The evidence demonstrates that the allocation of HG4(2) Aberthin is not necessary for the RLDP
to deliver either its housing requirement or its projected affordable housing outcomes.
Even if HG4(2) Aberthin were removed, the Plan would still exceed its housing requirement by
745 dwellings, and even if all HG4 rural affordable-led sites were removed the surplus would
remain 648 dwellings. These allocations are therefore not required to maintain an appropriate
housing supply or flexibility allowance.
HG4(2) Aberthin itself is expected to deliver approximately 13 affordable homes, reducing
projected affordable housing delivery by only 0.42% if removed. Even removing all HG4 rural
affordable-led sites would reduce projected delivery by only 2.02%. The Plan is therefore not
materially dependent on these sites to achieve its affordable housing outcomes.
National evidence also demonstrates that affordable housing delivery in Wales arises through
multiple mechanisms operating alongside the planning system. The RLDP assumption that
around 50% of affordable housing need will be delivered through planning mechanisms
represents a doubling of the typical contribution made through the planning system.
Extensive corridor development of housing supply and affordable is already taking place and
may have already saturated this corridor.
No clear evidence has been presented demonstrating a specific local affordable housing need
within the settlement.

7 Flood risk, surface water, ground water, drainage, and methodological
concerns
7.1 TAN 15 Section 10.22 – Highly Vulnerable Development on Greenfield
Land in Flood Zone 3
BP21A (p.15) states:
“For a proposed development site within Flood Zones 3 of the Flood Map for Planning for Rivers,
Section 10.22 of TAN-15 states that highly vulnerable development on greenfield land is not
permitted. Section 10.23 of TAN-15 states that other development proposals are acceptable if
they are essential to the LDP.”
This is the primary policy test.
• Residential development = highly vulnerable development.
• The site is greenfield land.
• The southern part of the site lies within Flood Zone 3.
• TAN 15 states highly vulnerable development on greenfield land in Flood Zone 3 is not
permitted.
The only potential exception pathway is if the development is “essential to the LDP.”
This site is not essential:
• The housing trajectory demonstrates over delivery.
• Strategic sites are already allocated and viability tested.
• Minor rural settlements are not required to meet housing numbers.
• Affordable housing delivery is already occurring in service centres along this corridor
and through other delivery vehicles
• No need established in Aberthin
Accordingly, the allocation conflicts directly with TAN 15 Section 10.22.
7.2 Welsh Government Notification Direction – Escalation to Ministers
BP21A (p.15) states:
“It is recognised that the Welsh Government notification direction requires applications for
Highly Vulnerable Development where the whole or part of the site is within Flood Zone 3 on a
Greenfield site to be referred to the Welsh Ministers. Any development proposals for this site
which include residential use are therefore likely to be required to be notified to the Welsh
Government.”
This confirms:
• The seriousness of the constraint.
• That residential development here triggers Ministerial scrutiny.
• That the proposal is not routine.
It is unclear whether this allocation has been formally notified to Welsh Government at plan
stage. Allocation without clarity on Ministerial position introduces further procedural and
soundness risk.
7.3 SuDS Basin – Location Discrepancy and Flood Zone 3 Conflict
BP21A (p.16) states:
“Residential units located entirely within Flood Zone 1. A proposed SuDS detention basin is
located to the south of the site and is within Flood Zone 2.
As per the advice of the CIRIA SuDS Manual, SuDS should not be located within an area at a
greater than 1% AEP chance of flooding, which aligns to Flood Zone 3.”
However:
• Vale of Glamorgan planning constraints mapping indicates the basin location falls wholly
within Flood Zone 3.
If the basin is within Flood Zone 3:
• This conflicts with CIRIA guidance.
• Basin storage may be compromised during fluvial events.
• Coincident pluvial + fluvial events reduce attenuation capacity.
• Exceedance flows could affect:
o Site access (within Flood Zone 3),
o The public right of way,
o Existing properties at Maes Lloi.
No combined-event modelling outputs have been published.
7.3.1 Mapping overlay showing SUDs basin entirely in Flood Zone 3
Flood Zone
3
Flood Zone
3
7.4 Drainage, SuDS Feasibility and Groundwater Constraints
The hydrogeological and flood characteristics of the area raise significant doubt as to whether
an effective Sustainable Drainage System (SuDS) could be implemented on the site without
creating additional flood or environmental risk.
Aberthin lies within a valley setting where several interacting flood mechanisms operate. Much
of the village lies within Flood Zone 3, with surrounding areas within Flood Zone 2, reflecting
fluvial flood risk associated with the Nant Aberthin, which ultimately joins the River Thaw. In
addition to fluvial flooding, the area is susceptible to surface water runoff due to the steep
topography of surrounding higher ground, including Pen-y-Lan Road and the Stalling Down
plateau, which generate rapid runoff during intense rainfall events that drain towards the valley
floor where the village and the proposed site are located.
Groundwater conditions present a further constraint. The valley floor surrounding Aberthin is
identified by the British Geological Survey as having high susceptibility to groundwater flooding.
The site lies above Carboniferous Limestone classified as a Principal Aquifer, overlain by
permeable gravels and alluvial deposits associated with the Nant Aberthin valley. These
geological conditions can produce a rapidly responding (“flashy”) groundwater table in which
groundwater levels rise quickly following rainfall and may emerge at the surface or remain very
shallow. Interaction between river levels and groundwater within the alluvial deposits can
further exacerbate this effect, with elevated river levels capable of forcing groundwater upward
into adjacent low-lying land.
These conditions create a challenging environment for SuDS design. Welsh SuDS standards
require infiltration to be demonstrated as suitable for local ground conditions and to assess its
effects on groundwater levels. Where groundwater is shallow or highly responsive to rainfall,
infiltration techniques such as soakaways or infiltration basins may become ineffective or may
worsen groundwater emergence and flooding. Introducing additional infiltration in a valley floor
already prone to groundwater rise could therefore increase the risk of groundwater flooding in
surrounding parts of the village.
Even if infiltration techniques were unsuitable and an attenuation-based system were proposed,
significant uncertainty would remain. Such systems require sufficient space for attenuation
features, exceedance routing and safe discharge to a receiving watercourse. In this case, the site
is constrained by landscape sensitivity, established hedgerows, a public right of way, and its
position at the base of surrounding slopes where runoff naturally accumulates, raising doubt as
to whether a compliant SuDS solution could be delivered without substantial engineering
intervention.
There are also potential implications for Cors Aberthin SSSI, which lies within the same
hydrological valley system. Wetland habitats are typically highly sensitive to changes in
hydrology, groundwater levels and water quality, and development that alters surface water
pathways, increases runoff or modifies groundwater recharge patterns could affect the
hydrological conditions supporting the wetland ecosystem.
Together this creates significant uncertainty regarding whether a SuDS solution could be both
effective and environmentally acceptable. In the absence of detailed hydrogeological
investigation, seasonal groundwater monitoring and robust drainage modelling demonstrating
no increase in flood risk or ecological harm, the assumption that drainage issues can be
satisfactorily resolved remains unproven. This uncertainty raises further concerns regarding the
deliverability and environmental suitability of the allocation.
7.5 Absence of a Detailed Hydraulic Model – Nant Aberthin
BP21A (p.12) states:
“The southern extent of the Site is partially located within Flood Zones 2 and 3… No detailed
model is available of the Nant Aberthin.”
This is critical.
• There is no detailed hydraulic model of the Nant Aberthin.
• Flood extents are therefore based on national-scale modelling.
• No localised calibration or site-specific modelling has been published.
• Flood depth, velocity and hazard classification are not robustly evidenced.
Allocation of highly vulnerable development without a detailed fluvial model is precautionary
risk deficient.
7.6 Absence of Allocation-Stage FCA
The assessment documented in BP21a for site 2299 was undertaken by JBA Consulting. They
note the assessment was purely desk-based, taking information provided by others with no
verification.
BP21A (p.17) states:
“Any planning application for the Site should be accompanied by an FCA which demonstrates
how the proposals meet the requirements of TAN-15.”
This confirms:
• An FCA is required.
• It has not yet been undertaken.
• It is deferred to application stage.
However, TAN 15 requires flood consequences to be demonstrated as acceptable.
Allocation of highly vulnerable development in Flood Zone 3 without an FCA at plan stage
means:
• Flood consequences have not been demonstrated.
• Mitigation feasibility has not been proven.
• Deliverability is uncertain.
7.7 TAN 15 Section 10.18 – Flood Zone 2 Justification Pathway Not Engaged
BP21A (p.15) states:
“Section 10.18 of TAN-15 states that it is possible to allocate sites within Flood Zone 2 where the
proposals assist the implementation of the strategy of the LDP to regenerate or revitalise
existing settlements or to achieve key economic or environmental objectives.”
However:
• The site is not within the established settlement form.
• It was previously rejected as unrelated countryside.
• It does not regenerate the settlement.
• It does not achieve a key economic objective.
• It does not achieve a key environmental objective.
The Section 10.18 justification pathway does not apply.
7.8 Surface Water Risk – “Minimal” Assertion vs Mapping Evidence
BP21A states:
“Surface water and small watercourse flood risk is minimal across the site…”
However:
• Vale planning constraints mapping identifies intermediate surface water risk across
approximately half of the site.
• The site slopes from north to south toward Maes Lloi.
• Proposed dwellings fall within areas of intermediate surface water flood risk.
• Proposed dwellings are in an area of historical flooding (DEVELOPMENT ADVICE MAP
Zone B)
• No surface water modelling outputs are published.
• No velocity modelling.
• No exceedance routing plan.
• No no-worsening assessment.
Surface water risk has not been robustly evidenced at allocation stage.
7.9 Mapping shows majority of proposed houses located in risk areas
The following mapping overlays show that 16 of the 25 houses are in areas of either surface
water risk or have experienced historical flooding
7.9.1 Map overlay showing houses in risk areas for surface water
Surface risk
intermediate
Surface risk
intermediate
Surface risk
less
Surface risk
less
7.9.2 Map overlay showing houses in historical flooding area (DEVELOPMENT ADVICE MAP
Zone B)
Historical
flooding
Historical
flooding
7.10 Groundwater – “Red – High” and 12-Month Monitoring Requirement
The site is classified “Red – Hhigh – groundwater likely to be at or near the surface” meaning:
Groundwater levels are either at or very near (within 0.025m of) the ground surface.
BP21A recommends groundwater monitoring over a 12-month period to capture seasonal
variation.
There is no evidence that:
• 12 months monitoring has been undertaken.
• Basin performance takes account of high groundwater.
• Infiltration feasibility has been proven.
• Climate change allowances have been applied to groundwater conditions.
Allocation prior to completion of recommended monitoring is evidentially premature.
7.11 Topography and Potential Runoff Toward Existing At-Risk Properties
The site slopes from north to south toward Maes Lloi.
• Existing properties at Maes Lloi are largely within Flood Zone 3.
• Residents have noted drainage overload during wet periods.
• There is no evidence published that assesses whether the proposed development would
not worsen existing flood risks to surrounding properties
• No quantified runoff comparison between greenfield and developed sites is provided.
• No exceedance flow mapping is published.
Downstream impact risk has not been robustly assessed.
7.12 Failure to Apply Council Methodology
BP21A (p.13) states:
“the approach adopted by the Council within its assessment methodology was for flood risk to
be given the strongest possible weighting… sites identified to fall within areas of flood risk were
discounted from further consideration.”
This is unequivocal.
However, this site:
• Lies partially within Flood Zone 3.
• Has mapped intermediate surface water risk.
• Has groundwater classified “Red – High.”
• Has access within Flood Zone 3.
• Has a history of flooding (DEVELOPMENT ADVICE MAP Zone B)
• Requires Ministerial notification.
• Requires FCA and groundwater monitoring.
• Requires SUDs viability assessment
• Requires SSSI/ecology assessment
This represents a clear departure from the Council’s own stated methodology.
BP16 (p.20) states:
“Sites located within Zone 2 will only be considered where: It will assist, or be part of, a strategy
supported by the Development Plan to regenerate an existing settlement or achieve key
economic or environmental objectives or address national security or energy needs; AND • Its
location meets the definition of a brownfield site, And • Is supported by a FCA that indicates
that the potential consequences of a flooding event for the development proposed is found to
be acceptable in accordance with the criteria contained in section 11 of TAN 15 (2021).
Sites located within Zone 3 will only be considered where: • The development is required under
exceptional circumstances, as defined in TAN e.g. addressing national security or energy security
needs, reasons of public health or to mitigate the impacts of climate change, AND • Its location
meets the definition of a brownfield site, And • Is supported by a FCA that indicates that the
potential consequences of a flooding event for the development proposed is found to be
acceptable in accordance with the criteria contained in section 11 of TAN 15 (2021).”
This site is within Flood zones 2 and 3, is not brownfield, has no FCA, meets none of the
conditions in section 11, TAN 15 and is not required for exceptional circumstances.
The council do not appear to have followed any of these elements of methodology with regard
to flood risk.
7.13 Soundness Consequences
The allocation:
• Conflicts with TAN 15 Section 10.22.
• Does not meet Section 10.18 justification.
• Requires Welsh Government notification.
• Proceeds without any hydraulic model.
• Proceeds without FCA.
• Proceeds without groundwater monitoring.
• No-worsening test absent
• No SUDs viability assessment
• Contains mapping discrepancies.
• Defers critical evidence to application stage.
Accordingly, the allocation fails the soundness tests because it is:
• Not Justified – not based on robust, proportionate evidence.
• Not Effective – deliverability dependent on unresolved flood constraints.
• Not Consistent with national policy – specifically TAN 15 restrictions.

8 Infrastructure Constraints
8.1 Access Considerations
Indicative plans suggest that access to the proposed development may be provided from the
A4222 on the northern side of Aberthin. This would introduce an additional junction onto a
section of road that already contains numerous access points and turning movements. Given the
existing road layout and traffic conditions, the introduction of a further access point warrants
careful consideration in relation to highway safety.
The existing southern access route also presents constraints. It lies within Flood Zone 3, is
restricted in width, and cannot accommodate emergency vehicles safely. Flood events could
potentially affect access and egress, which may have implications for both existing and future
residents.
8.2 Existing Road Environment
The A4222 Maendy Road, which connects Cowbridge and Ystradowen through Aberthin, already
carries significant traffic volumes, including heavy goods vehicles. The road environment
includes several features that influence traffic movement and safety, including:
• a 90-degree bend over a bridge
• multiple side road junctions
• pub car park exits and private driveways accessing the road
• limited footpath provision and crossing points
• areas of reduced street lighting
These characteristics mean that drivers already navigate a relatively complex road environment
through the village.
Historic planning decisions also indicate sensitivity around access to this road. In 1978, South
Glamorgan County Council required the closure of the access from Skaife House onto the A4222
(Directly opposite the proposed new entrance), as part of planning consent for development at
The Spinney, Downs View Close, reflecting previous concerns regarding additional junctions
along this section of road (at a time with far less traffic).
8.3 8.3 Strategic Transport Policy Context
The RLDP is supported by BP14 – Strategic Transport Assessment Stage 1, which emphasises the
importance of locating development where sustainable travel options are available and where
the need to travel can be reduced. The assessment highlights the role of planning policy in
encouraging modal shift toward walking, cycling and public transport.
The Strategic Transport Assessment Stage 2 (BP14a) identifies capacity pressures within parts of
the local network. In particular, the Aberthin Road / Cardiff Road / St Athan Road / Eastgate
junction is recorded as operating beyond theoretical capacity during the AM peak period. This
indicates that parts of the local highway network already experience congestion during peak
travel times.
8.4 Car Dependency and Sustainable Transport
The Strategic Transport Assessment highlights that the Vale of Glamorgan has relatively high
levels of car ownership, with 83.4% of households owning one or more vehicles. In smaller rural
settlements such as Aberthin, limited public transport and no active travel infrastructure mean
that residents are likely to rely heavily on private vehicles.
The Vale’s active travel network is described within the transport evidence as limited and
fragmented in certain areas. Aberthin currently has:
• no designated Active Travel routes
• no proposed routes within the Active Travel Network Maps
• limited safe walking or cycling connections to nearby settlements such as Cowbridge
and Ystradowen, with narrow or missing footpaths and poorly lit sections.
An Active Travel scheme went through consultation but met with multiple objections. Some of
these are relevant to LDP planning elements, such as:
o The high volume and speed of traffic on the existing highways, predominantly the A4222
that runs directly through Aberthin
o A lack of segregated infrastructure in the area, which would force cyclists to share space
with cars in narrow sections.
o The lack of street lighting in the area, which made the route unappealing for use at night
or during winter.
o Concerns regarding installing lighting due to wildlife disruption
The project has been on hold for 3 years.
Public transport provision is also limited, with bus services operating approximately hourly,
ending in the early evening at 7.30, with no Sunday services. These factors may influence travel
patterns and increase reliance on private vehicles.
8.5 Cumulative Transport Considerations
As discussed earlier, extensive development has occurred and is still ongoing in the Cowbridge
Aberthin–Ystradowen corridor. These settlements are largely connected by the A4222 corridor,
which functions as the principal route linking the surrounding communities. The route already
accommodates traffic associated with existing settlements and recent development.
In this context, the cumulative impact of additional development along the corridor raises
considerations regarding traffic growth, junction capacity, road safety and infrastructure
demand. These factors may warrant careful evaluation when assessing additional rural
allocations, particularly where the transport evidence indicates existing pressures within parts of
the network.
8.6 Policy Considerations
Based on the transport evidence and local context outlined above, several policy considerations
arise.
8.6.1 Conflict with sustainable transport objectives
The Strategic Transport Assessment supporting the RLDP (BP14 and BP14a) emphasises the
importance of locating development where sustainable transport options are available and
where reliance on private vehicles can be reduced.
8.6.2 Infrastructure capacity and network pressures
Transport evidence identifies existing pressures within parts of the local highway network,
including peak-period congestion at key junctions serving the area. When considered alongside
recent and ongoing development within the Cowbridge–Aberthin corridor, the potential
cumulative effect of additional traffic generation may require further assessment to ensure that
local infrastructure can accommodate additional demand.
8.6.3 Consistency with the RLDP spatial strategy
Planning Policy Wales and the RLDP strategy emphasises directing development toward
locations with stronger accessibility to services, facilities and sustainable transport networks. As
a small rural settlement with limited transport connectivity, the role of Aberthin within this
spatial strategy may require careful consideration when assessing the suitability of additional
housing allocations.
8.7 Education capacity
The Council’s education evidence (BP43 Education) confirms that secondary education provision
serving the Cowbridge area is already under pressure.
Appendix F of BP43 identifies that Cowbridge Comprehensive School will require an additional
177 places to accommodate projected demand generated by RLDP growth.
BP43 uses the following pupil yield formula:
• Primary: Dwellings × 0.278
• Secondary: Dwellings × 0.208
Applying this to a development of 20–30 dwellings at Aberthin would generate approximately:
• 6–8 primary pupils
• 5–6 secondary pupils
• approximately 1 Additional Learning Needs (ALN) pupil
BP43 also confirms that ALN provision across the authority is already under pressure.
The Aberthin allocation therefore adds additional pupil demand to an already constrained
education system.
Given that the RLDP already provides 8,660 dwellings against a requirement of 7,890 (a surplus
of 770 dwellings) and affordable housing delivery is already secured through larger strategic
allocations, the additional education demand created by HG4(2) Aberthin is unnecessary for the
delivery of the Plan’s housing strategy.
9 Landscape, Settlement Edge, Hedgerow Protection, Public Right of
Way, Conservation Area and Nearby SSSI
9.1 Landscape and heritage setting sensitivity
The proposed allocation HG4(2) – Land West of Maendy Road, Aberthin lies wholly within a
Special Landscape Area (SLA) designated by Vale of Glamorgan Council. Special Landscape Areas
identify landscapes of locally significant character and visual quality, and planning policy
requires development within such areas to conserve and enhance landscape character and
avoid unnecessary harm to valued landscapes.
The site comprises open agricultural land immediately west of Aberthin, forming part of the
rural valley landscape associated with the Nant Aberthin corridor and contributing to the wider
countryside setting of the village and surrounding landscape extending toward Cowbridge.
Key landscape characteristics include:
• open pastoral farmland typical of the Vale of Glamorgan landscape
• strong hedgerow field boundaries reflecting historic field patterns
• visual connection with the Nant Aberthin valley landscape
• a continuous mature hedgerow along the western boundary running north–south
This hedgerow forms a defining landscape feature, contributing both to the historic field
structure of the landscape and to ecological connectivity.
The existing development along Maendy Road forms a clear and well-defined rural settlement
edge to Aberthin. The proposed site lies beyond this edge and currently reads as open
countryside rather than part of the village. Development of approximately 25 dwellings would
extend the built form westwards into open farmland, resulting in:
• encroachment of residential development into countryside
• erosion of the clear distinction between settlement and rural landscape
• urbanisation of the existing rural settlement edge.
These changes would be particularly sensitive given the site’s location within a Special
Landscape Area.
The site also forms part of the wider setting of the Aberthin Conservation Area, which protects
the historic character and appearance of the village under the Planning (Listed Buildings and
Conservation Areas) Act 1990. Aberthin is characterised by traditional stone cottages, a compact
historic form and a strong relationship with the surrounding countryside. The open farmland
west of the village contributes to this rural setting and historic landscape context. Development
of the site would extend the built form into land that currently forms part of that setting,
potentially altering the way the historic settlement is experienced within the surrounding
landscape.
The site is also located close to Cors Aberthin SSSI, a designated Site of Special Scientific Interest
recognised for its wetland habitats and ecological importance within the Nant Aberthin valley
system. SSSIs are protected under the Wildlife and Countryside Act 1981, and planning policy
requires that development should avoid Development Advice Mapage to their special scientific
interest and associated ecological systems.
The proximity of the allocation to Cors Aberthin SSSI reinforces the environmental sensitivity of
the wider landscape, particularly in relation to:
• hydrology and water movement within the valley
• ecological connectivity through the Nant Aberthin corridor
• protection of surrounding habitats that contribute to the ecological functioning of the
SSSI.
9.2 Significance and protection of the boundary hedgerow
The continuous hedgerow running along the western boundary of the site is likely to be of
considerable ecological, historic and landscape value.
Hedgerows of this type in the Vale countryside commonly:
• form part of historic field boundaries
• provide habitat corridors for birds, bats and small mammals
• contribute significantly to the traditional landscape character of the Vale of Glamorgan
Such hedgerows may qualify as “Important Hedgerows” under the Hedgerows Regulations 1997.
Where a hedgerow meets the criteria set out in these Regulations:
• removal requires formal consent from the local authority, and
• if the hedgerow is classified as important, consent for removal must normally be
refused.
Removal of an important hedgerow without permission constitutes a criminal offence.
Given the continuous north–south structure of the boundary hedgerow and its role in the
historic field pattern, there is a realistic possibility that the hedgerow would meet the criteria for
protection.

9.3 Public Right of Way and proposed realignment
A Public Right of Way (PRoW) currently crosses the site through open agricultural land, forming
part of the rural footpath network around Aberthin. In its current form the route is experienced
as a traditional countryside path, crossing open farmland with clear visibility and an open rural
character.
However, the indicative layout associated with the allocation appears to show the path diverted
along the western boundary of the site, coinciding with the existing hedgerow. The proposed
layout indicates:
• rear residential gardens backing onto the path
• tree planting along the boundary
• the route positioned between housing plots and boundary vegetation.
9.3.1 Loss of rural character and safety concerns
This realignment would fundamentally alter the character of the route. Instead of crossing open
countryside, the diverted path would form a long, narrow corridor along the edge of the
development. The path would therefore be experienced as a confined passage rather than an
open countryside route, raising concerns regarding:
• loss of the rural character of the right of way
• reduced visibility and openness
• personal safety for walkers.
The arrangement would effectively create a long-enclosed route resembling an alleyway,
particularly where gardens back directly onto the path. These concerns are amplified by the
likelihood that the route would remain unlit, as public rights of way across rural land are rarely
provided with lighting, particularly within Special Landscape Areas where lighting may conflict
with policies protecting rural character and dark skies.
The resulting route would therefore be a long, narrow and potentially unlit corridor, raising
further safety and amenity concerns.
Length of enclosed
alleyway
9.3.2 Legal implications of diversion
Any diversion of a Public Right of Way requires a legal order under the Highways Act 1980.
To be confirmed, such an order must demonstrate that:
• the diversion is necessary to enable the development, and
• the alternative route is not substantially less convenient or less enjoyable for the public.
Replacing a path that currently crosses open countryside with a route running along the edge of
housing development may therefore attract objections from users, residents or rights-of-way
groups, potentially preventing confirmation of the diversion order.
9.4 Interaction between the path diversion and hedgerow removal
The proposed diversion appears to coincide directly with the existing boundary hedgerow,
suggesting that the development may require removal or substantial alteration of this hedgerow
in order to accommodate the path and housing layout.
If the hedgerow qualifies as an Important Hedgerow under the Hedgerows Regulations 1997, its
removal may be legally restricted or refused, creating uncertainty regarding whether the layout
assumed by the allocation could be implemented.
9.5 Implications for site deliverability
The allocation therefore appears to depend upon:
• diversion of an existing Public Right of Way,
• possible removal or alteration of a potentially protected hedgerow, and
• development within an SLA and sensitive landscape setting closely associated with the
Cors Aberthin SSSI and Nant Aberthin ecological corridor.
Each of these matters involves separate legal and environmental considerations, none of which
can be assumed to be achievable at the plan allocation stage.
If the diversion were refused, or if removal of the hedgerow were not permitted, the layout
assumed by the allocation may not be achievable in practice.
9.6 Conclusion
The allocation of HG4(2) would introduce residential development into open countryside within
a designated Special Landscape Area, extending the settlement edge of Aberthin into land that
currently contributes to the village’s rural setting and the wider setting of the Aberthin
Conservation Area.
The site contains a continuous boundary hedgerow likely to be of significant landscape and
ecological value, which may qualify for protection under the Hedgerows Regulations 1997.
The indicative layout also proposes diverting an existing Public Right of Way from its current
route across open farmland to a narrow boundary corridor running between residential gardens
and boundary planting, fundamentally altering the character of the route and raising safety and
amenity concerns, particularly as the path would likely remain unlit.
The site also lies close to Cors Aberthin SSSI, further highlighting the environmental sensitivity of
the surrounding landscape.
Taken together, these factors raise serious concerns regarding landscape impact, heritage
setting, environmental sensitivity, legal constraints and the practical deliverability of the
allocation, particularly given that the Plan already provides sufficient housing supply without
reliance on development of this sensitive site.

10 Plan Soundness and potential Misapplication of Policy HG4
10.1 Affordable Housing Exception Policy Must Operate Within National Policy
Policy HG4 allows for small-scale affordable housing-led development in Minor Rural
Settlements, reflecting the Welsh Government policy approach to rural exception sites.
However, such policies are intended to operate within the framework of the Plan’s spatial
strategy, not to override it.
Affordable housing exception mechanisms are designed to allow limited, carefully justified
departures from the normal settlement boundary approach where local need is demonstrated
and cannot otherwise be met. They are not intended to provide a general mechanism for
allocating greenfield housing sites in rural settlements.
The allocation of Site 2299 appears to rely on HG4 as the primary justification for development,
rather than demonstrating that the site aligns with the broader spatial strategy and site
selection methodology of the Plan.
PPW (12) allows rural affordable housing through exception mechanisms, but only where
certain conditions are met.
• small-scale
• genuinely local need (not demonstrated in Aberthin)
• proportionate to settlement size (2299 is disproportionate estate scale development)
• does not undermine settlement strategy (outside strategic growth and sustainable
areas)
Development Plans Manual (Edition 3) states that site allocations should:
• flow from the spatial strategy
• follow the site search sequence
• be supported by a transparent assessment process
In other words:
Strategy → site selection → allocation
In the case of site 2299 the order appears reversed:
Site promoted → affordable housing justification → boundary expanded → allocation.
That is the type of site-led planning the manual warns against.
10.2 HG4 Overrides the Plan-Led Site Selection Process
The evidence in the Candidate Site Assessment indicates that the site has been taken forward
solely on the basis that it could deliver affordable housing and there is no indication that the
assessment methodology has been carried out
This approach effectively allows HG4 to override the wider plan-making framework, including:
• the settlement hierarchy,
• the spatial distribution of housing growth,
• the requirement to prioritise sustainable locations, and
• the established methodology for identifying appropriate development sites.
This creates a policy loophole whereby any countryside site adjacent to a minor rural settlement
could potentially be justified simply by proposing affordable housing. This risk appears to have
been realised. HG1, 3 and 4 were all rejected according to the assessment methodology but
resubmitted as affordable led upon guidance: “but the site could be reconsidered as a small
scale affordable housing led development”.
HG4(2) Aberthin was previously rejected in the 2011-2026 LDP then crucially did not go through
the normal assessment process but went straight to allocation as affordable-led. This creates a
precedent for any candidate site, including those previously rejected to be submitted as
affordable-led and potentially be allocated without robust assessment.
Such an approach undermines the plan-led system and the spatial strategy on which the RLDP is
based.
10.3 Lack of Evidence That the Site Is Necessary to Deliver Affordable Housing
The justification for the site relies on reference to the Local Housing Market Assessment
(LHMA), which identifies a need for additional affordable housing within the relevant ward of
Cowbridge.
However, the existence of an identified need does not in itself justify the allocation of specific
countryside sites.
The RLDP must demonstrate that:
1. the affordable housing requirement cannot be met within the overall housing supply,
and
2. the proposed site represents the most appropriate and sustainable location to
contribute to meeting that need.
Neither has been demonstrated.
As previously discussed, the RLDP already provides a significant surplus of housing provision
over the housing requirement, including substantial capacity within more sustainable
settlements.
In these circumstances, the allocation of a countryside site solely on the basis of affordable
housing provision i.e. HG4 exception, is not justified.
10.4 Soundness Implications
For a Local Development Plan to be sound it must be:
• Justified – based on a robust and credible evidence base and the most appropriate
strategy.
• Consistent with national policy.
• Effective and deliverable.
The reliance on Policy HG4 as the primary justification for Site 2299 raises concerns in respect of
all three tests.
In particular:
• Justified: The evidence base does not demonstrate that the site is necessary to deliver
the Plan’s housing or affordable housing objectives, or that there is any evidenced need
in Aberthin
• Consistent with National policy: The allocation does not appear to arise from a
consistent application of the spatial strategy or site selection methodology and does not
take account of flood risks in accordance with policy. The approach risks undermining
the plan-led system by allowing countryside sites to be allocated solely on the basis of
affordable housing provision.
• Effective and Deliverable: The number of constraints lack mitigation evidence, e.g. no
FCA, SUDs assessment, overall site viability assessment and other missing assessments,
the limited infrastructure of the area is not mitigated, and only summary financial
viability is provided, and this has discrepancies
For these reasons, the allocation of Site 2299 using HG4 cannot be considered justified or sound.

11 Conflicts with methodology, shifts, audit trail concerns and gaps
11.1 Candidate Site Assessment Methodology (BP16)
11.1.1 Site Assessment Criteria Outcomes
Site 2299 has been assessed against 35 criteria within the candidate site assessment framework.
Of these, 12 criteria are recorded as green (no identified constraints to development). Four
criteria are marked as red, which represent the most significant level of concern, typically
indicating a major constraint to development, potential conflict with national policy, or
insufficient information to support the assessment.
A review of the scoring suggests that some classifications may warrant further consideration, as
below, and may increase red scores to 6. A site could be rejected on the basis of a single red
score (p10).
11.1.2 Potential Issues in the Scoring
11.1.2.1 Environment and Physical Constraints
The site is recorded as Amber under the category of Environmental and Physical Constraints.
However, part of the site lies within Flood Zone 3 and therefore appears to engage the
requirements of Technical Advice Note 15 (TAN15), specifically the Justification Test and
Acceptability of Consequences tests set out in Sections 10 and 11.
Guidance provided in Background Paper BP16 (page 20) states that sites located within Flood
Zone 3 will only be considered where specific criteria are met. These include:
• The development is required under exceptional circumstances, such as those relating to
national security, energy security, public health, or climate change mitigation.
• The site meets the definition of previously developed (brownfield) land.
• The proposal is supported by a Flood Consequences Assessment (FCA) demonstrating
that the potential consequences of flooding are acceptable in accordance with the
criteria contained within Section 11 of TAN15 (2021).
In the case of Site 2299:
• No exceptional circumstances have been identified.
• The site is greenfield rather than previously developed land.
• No evidence has been presented demonstrating compliance with the acceptability of
consequences test.
Further, on page 7 of the guidance:
“Flood risk – sites located within either a TAN 15 Defended Area, or Flood Zone 2 or 3 area which
do not meet the justification test and acceptability of consequences section 10 and11 out in TAN
15 will not pass the initial sifting.”
In light of these factors, the classification of Amber within this category is surprising, as it
appears the site should have not have even passed initial sifting.
11.1.2.2 Landscape Considerations
The site is also scored Amber under the Special Landscape Area criterion. However, the scoring
guidance indicates that a site should be classified as Red where it is predominantly greenfield
and wholly located within a Special Landscape Area or a Registered Landscape of Outstanding or
Special Historic Interest.
Site 2299 is identified as greenfield land and lies entirely within a designated Special Landscape
Area. Based on the stated scoring methodology, this suggests that a Red classification could be
more consistent with the guidance provided.
11.1.3 FCA requirement
On page 22 the FCA requirement and discounting rule is clear:
“Sites which are not accompanied by a FCA or do not meet the tests shall be automatically
discounted from further consideration.”
Site 2299 does not have an FCA, so should have been discounted.
11.2 Deposit assessment audit-trail concerns (BP18A) and unexplained shifts
Inconsistencies in the deposit candidate site assessment narrative are noted:
• BP18A p.14 describes the site 2299 as conforming with strategy/initial filter and uses
language indicating it is ‘adjacent’ to the settlement; later narrative suggests it is ‘in’ the
settlement without a published boundary justification.
• BP18A p.20 notes ‘suitable for further consideration’ while listing constraints without
explaining why those constraints did not prevent progression under BP16.
• BP18A p.34 significantly downplays flood risk (references only a part in Flood Zone 3) and
does not reflect mapped intermediate surface water risk covering around half the site,
historical flood data and ground water risk.
• BP18A p.77 contains a ‘Acceptable at PS stage’ recorded as “N/A” for site 2299 and a
‘Justification’ field recorded as “N/A” for site 2299, which undermines transparency.
• BP18A also indicates that detailed site proformas exist and are available on request. The
Council should disclose the full Site 2299 proforma used for decision-making, including RAG
scoring rationale and any override decisions.
• BP18A p.34 – indicates a viability assessment has been submitted for site 2299 which
demonstrates that the site is deliverable as an affordable housing led site. Only a summary
table has been published, which appears to under cost, and may need validating in light of
flood risks, SUDs viability, no sewerage on site, and contributions to education and
infrastructure costs cited elsewhere.
11.3 Independent viability evidence gap and deliverability risk (BP42A)
• BP42A (December 2025) provides Independent Financial Viability Assessments of five
strategic/key sites. Site 2299 is not included. Planning Policy Wales (PPW 12) directs
that: “as part of demonstrating the deliverability of housing sites, financial viability must
be assessed prior to their inclusion as allocations in a development plan. At the
‘Candidate Site’ stage of development plan preparation, land owners/developers must
carry out an initial site viability assessment and provide evidence to demonstrate the
financial deliverability of their sites.”
• BP42A states it is concerned with financial viability only and not broader constraints.
• Site 2299 is not a low-risk site; it is flood constrained, and requires a robust
management plan, SUDs viability needs testing (extending to SSSI implication), requires
full new sewage/drainage infrastructure, has access uncertainties and SLA landscape
constraints. These drive abnormal costs. Without site-specific viability testing,
deliverability and affordable housing delivery cannot be assumed.
• Site 2299 has viability tension: as abnormal costs rise (flood mitigation, SuDS,
groundwater management, highway works, sewage/drainage installation and potential
off-site reinforcement), affordable housing delivery is typically the first pressure point.
The RLDP must evidence deliverability for this site, not assume it.

12 Tests of soundness
For the RLDP to be sound it must be Justified, Effective and Consistent with National Policy.
12.1 Not Justified
The allocation is not supported by proportionate evidence:
• the RLDP already provides 770 dwellings above the housing requirement
• the site contributes only 0.42% of projected affordable housing delivery
• no specific local affordable housing need has been demonstrated within Aberthin
• the site conflicts with the spatial strategy which limits growth in Minor Rural
Settlements
• the allocation represents a departure from the Council’s own site assessment
methodology
• the allocation lacks a transparent audit trail
• does not demonstrate why this constrained countryside site is the most appropriate
option, particularly given delivery elsewhere in the corridor and strategic sites
12.2 Not Effective
The site cannot be shown to be deliverable because:
• significant flood risk constraints remain unresolved
• no Flood Consequence Assessment has been undertaken
• groundwater monitoring recommended in the evidence has not been completed
• the SuDS strategy has not been demonstrated to be viable
• potential impacts on Cors Aberthin SSSI hydrology have not been assessed
• no-worsening test absent
• access, drainage and infrastructure constraints remain uncertain
• viability is not independently tested or fully costed
12.3 Not Consistent with National Policy
The allocation conflicts with Technical Advice Note 15 (Flood Risk) because:
• the site partly lies within Flood Zone 3
• residential development is highly vulnerable development
• TAN15 states such development should not occur on greenfield land in Flood Zone 3
unless essential to the LDP
• the RLDP already contains a substantial housing surplus, meaning the site cannot be
considered essential
12.4 Conclusion
For these reasons the allocation of HG4(2) – Land West of Maendy Road, Aberthin cannot be
considered sound.
The site should therefore be removed from the RLDP.
10.3 Not consistent with national policy: the allocation conflicts with national objectives for
sustainable location and robust flood risk management (including safe access/egress and no
worsening).

13 Formal request and proposed modifications
1. Primary request: delete Site 2299 from the RLDP and remove it from Policy HG4.
2. Settlement boundary: do not redraw the Aberthin settlement boundary to include this
field parcel; if already redrawn, reinstate the defensible boundary aligned to existing
built form unless a published boundary review justifies change.
Evidence disclosure requests (minimum):
a. Robust evidence qualifying necessity under HG4, aligned to national policies
b. Full Site 2299 proforma (BP18A indicates proformas exist and are available on
request), including all scoring and override rationale.
c. Full FCA including modelling outputs, assumptions, and climate change
allowances for both fluvial and pluvial events, surface runoff from surrounding
slopes, high groundwater susceptibility, principal aquifer conditions, cumulative
testing, implications on the nearby SSSI wetland habitat, ecology assessment
and no worsening test.
d. Surface water modelling demonstrates intermediate risk treatment, exceedance
routing and no worsening.
e. The advised 12-month Groundwater monitoring and data
f.
SuDS feasibility and design, including implications on the nearby SSSI and
ecology.
g. Drainage strategy demonstrating foul connection feasibility, capacity, and any
required off-site reinforcement.
h. Dry access/egress assessment for residents and emergency vehicles during flood
events.
i.
j.
Highways feasibility: access location, visibility, swept-path tracking and road
safety audit.
Active travel and public transport assessment with deliverable mitigation
package and funding mechanism.
k. Landscape/visual assessment for SLA impacts.
l.
Ecology and heritage appraisals including SSSI proximity and Conservation Area
setting.
m. Site-specific viability appraisal (including all abnormal costs) demonstrating
affordable housing deliverability.
3. Confirmation regarding protection of hedgerow
4. Confirmation regarding PRoW

This development if it was to go ahead, would need an access road to the site, increasing traffic hazards within the village of Aberthin, already being subject to speeding motorists completely ignoring the speed limits of 30mph and 20 mph approaching the acute road bend at The Farmers Arms.
Despite its relatively small size ( 25 houses ) , this development would create sufficient hazards and difficulties in the Aberthin area , which is not suitable for the purpose proposed.

1. Primary request: delete Site 2299 from the RLDP and remove it from Policy HG4.
2. Settlement boundary: do not redraw the Aberthin settlement boundary to include this field parcel; if already redrawn, reinstate the defensible boundary aligned to existing built form unless a published boundary review justifies change.
Evidence disclosure requests (minimum):
a. Robust evidence qualifying necessity under HG4, aligned to national policies
b. Full Site 2299 proforma (BP18A indicates proformas exist and are available on request), including all scoring and override rationale.
c. Full FCA including modelling outputs, assumptions, and climate change allowances for both fluvial and pluvial events, surface runoff from surrounding slopes, high groundwater susceptibility, principal aquifer conditions, cumulative testing, implications on the nearby SSSI wetland habitat, ecology assessment and no worsening test.
d. Surface water modelling demonstrates intermediate risk treatment, exceedance routing and no worsening.
e. The advised 12-month Groundwater monitoring and data
f. SuDS feasibility and design, including implications on the nearby SSSI and ecology.
g. Drainage strategy demonstrating foul connection feasibility, capacity, and any required off-site reinforcement.
h. Dry access/egress assessment for residents and emergency vehicles during flood events.
i. Highways feasibility: access location, visibility, swept-path tracking and road safety audit.
j. Active travel and public transport assessment with deliverable mitigation package and funding mechanism.
k. Landscape/visual assessment for SLA impacts.
l. Ecology and heritage appraisals including SSSI proximity and Conservation Area setting.
m. Site-specific viability appraisal (including all abnormal costs) demonstrating affordable housing deliverability.
3. Confirmation regarding protection of hedgerow
4. Confirmation regarding PRoW

This representation objects to the allocation of Site HG4(2) – Land West of Maendy Road,
Aberthin (Site 2299) within the Vale of Glamorgan Replacement Local Development Plan (RLDP).
The allocation proposes approximately 25 dwellings as an affordable housing-led development
on greenfield agricultural land forming part of the countryside immediately west of Aberthin.
The allocation is unsound for several independent reasons.
First, the proposal conflicts with the Plan’s spatial strategy.
Aberthin is identified as a Minor Rural Settlement, where development is expected to be limited
in scale and primarily related to local needs. A development of approximately 25 dwellings
would represent around a 14% expansion of the settlement in a single phase, introducing
estate-scale growth into a small rural village with very limited services. This represents a
material step-change inconsistent with the role of such settlements within the hierarchy.
Second, the site is not necessary for delivery of the Plan’s housing strategy.
The RLDP identifies a housing requirement of 7,890 dwellings and housing provision of 8,660
dwellings, creating a surplus of 770 dwellings above the requirement. Removal of HG4(2)
Aberthin would still leave a surplus of 745 dwellings, and even removal of all HG4 rural
affordable-led sites would leave a surplus of 648 dwellings. The allocation is therefore not
required for the Plan to deliver its housing requirement.
Third, the RLDP evidence identifies affordable housing need at a ward level (Cowbridge) rather
than within Aberthin itself, and no evidence has been presented demonstrating a specific locally
arising need within the settlement.
Forth, the site makes only a negligible contribution to affordable housing delivery. The site is
expected to deliver approximately 13 affordable homes, representing only 0.42% of the Plan’s
projected affordable housing delivery of 3,070 homes. The Plan is therefore not materially
dependent on the site to deliver its affordable housing strategy.
Fifth, the site is heavily constrained by flood risk and drainage uncertainty.
Part of the site lies within Flood Zone 3, where highly vulnerable development on greenfield
land is not permitted under Technical Advice Note 15 (TAN15) unless the development is
essential to the Local Development Plan. Given the Plan’s housing surplus, and no identified
local need, the site cannot reasonably be considered essential. In addition:
• no detailed hydraulic model exists for the Nant Aberthin watercourse,
• no Flood Consequence Assessment has been undertaken at allocation stage,
• groundwater susceptibility is classified as “Red – high – groundwater likely to be at or
near the surface”, with a recommendation for 12 months monitoring which has not
been undertaken,
• surface water mapping indicates intermediate flood risk across part of the site, and
historical flood data indicates flooding
• the proposed SuDS detention basin location appears to fall within Flood Zone 3
according to Council constraint mapping, raising questions regarding compliance with
SuDS design guidance,
• the viability and performance of the proposed drainage strategy has not been
demonstrated, including potential effects on the hydrology of the nearby Cors Aberthin
SSSI wetland system, and
• no modelling has been provided to demonstrate that development would not worsen
flood risk to neighbouring properties, including those at Maes Lloi.
Taken together, these factors create substantial uncertainty regarding whether a compliant
drainage strategy could be delivered and whether flood risk could be safely managed.
Sixth, the site presents infrastructure and accessibility constraints.
Aberthin has very limited services and infrastructure. The settlement contains no shops and
limited community facilities, with most services located in nearby Cowbridge. Public transport
provision is limited to infrequent bus services which cease in the early evening and do not
operate on Sundays, and there are no designated active travel routes connecting the settlement
to surrounding towns. The road network through the village, particularly along the A4222
corridor, already experiences traffic pressures and safety concerns. The Council’s education
evidence also confirms that secondary school capacity serving the area is already under
pressure, with additional places required to accommodate projected growth.
Seventh, the allocation introduces development into a sensitive landscape and environmental
setting.
The site lies entirely within a Special Landscape Area, contributes to the countryside setting of
the Aberthin Conservation Area, lies close to Cors Aberthin SSSI, and contains established
hedgerow boundaries forming part of the historic field pattern of the Vale landscape.
Finally, the allocation represents a clear departure from the Council’s published site assessment
methodology.
Background Paper BP16 indicates that sites affected by flood risk should normally be discounted
from further consideration. Despite multiple constraints — including Flood Zone 3, groundwater
susceptibility and surface water risk — Site 2299 was not discounted. The site was previously
rejected during preparation of the adopted LDP on the basis that it was unrelated to the
settlement and constituted sporadic development in the countryside, and no material change in
circumstances has been demonstrated to justify a different conclusion. Additionally, audit trail
concerns are evident, e.g. N/A values in justification columns.
Taken together, the evidence demonstrates that the allocation:
• is not necessary to deliver the Plan’s housing requirement or affordable housing
outcomes, and no need has been established
• conflicts with national flood policy (TAN15),
• is inconsistent with Council’s own site assessment methodology, and
• introduces development into a sensitive rural landscape with infrastructure constraints
unnecessarily.
In conclusion, these matters demonstrate that the allocation fails the key tests of soundness: it
is not justified by the evidence, is not effective or deliverable due to unresolved environmental
and infrastructure constraints, and is not consistent with national policy, including Planning
Policy Wales (sustainable spatial strategy and protection of landscape) and Technical Advice
Note 15 (flood risk)
For these reasons, Site HG4(2) – Land West of Maendy Road, Aberthin should be removed from
the RLDP.

3.1 Settlement size and character
Aberthin is classified as a minor rural settlement. It is a historic agricultural village built around
the Nant Aberthin (Aberthin Brook), a tributary that flows into the River Thaw. The settlement is
surrounded by agricultural land parcels and a large common land called Stalling Down.
It is estimated to contain approximately 176 dwellings.
There is a close-knit community feel, with many residents taking parts in community events
organised by the village hall committee, such as a duck race (where plastic yellow ducks are
raced down the stream), a free bonfire and fireworks display held on the downs, quiz nights,
amateur dramatics and an annual Village Day, which has a barbeque, music and a dog show.
Aberthin has already been recently extended, under the last LDP. In around 2017, 20 properties
were built in Court close, 6 of those affordable. The settlement boundary was redrawn to
accommodate the site, as can be seen in the map below, marked in red. (REFER TO ATTACHED PDF FOR IMAGES)
3.1.1 Settlement boundary

3.2 Landscape and Environmental Context of Aberthin
The settlement is characterised by its historic village form, traditional buildings and strong
relationship with the surrounding countryside. Much of the landscape surrounding the village is
designated as a Special Landscape Area by Vale of Glamorgan Council, reflecting the recognised
scenic quality and rural character of the Nant Aberthin valley and the wider Vale landscape. The
historic character of the settlement is also recognised through the designation of the Aberthin
Conservation Area, which protects the architectural and historic character of the village and its
relationship with the surrounding rural landscape.
The surrounding countryside comprises a network of agricultural fields defined by historic
hedgerow boundaries, forming part of the traditional field pattern typical of the Vale of
Glamorgan. The area is also notable for its historic environment, with several Scheduled Ancient
Monuments and other archaeological features recorded in the surrounding landscape, reflecting
long-standing human activity in the Nant Aberthin valley. The landscape also supports important
ecological features associated with the Nant Aberthin watercourse and valley system, including
the nearby Cors Aberthin SSSI, a designated wetland site protected under the Wildlife and
Countryside Act 1981. Public rights of way cross the surrounding farmland, providing access to
the countryside and contributing to the rural character and recreational value of the area.
3.2.1 Landscape features
SSSI: shown in red, Conservation Area – maroon boundary, monuments in blue, ancient
woodland in green crosshatch, and SINC in green horizontal lines

3.3 Services and facilities
Aberthin has very limited services and infrastructure.
Known facilities include:
• a small community centre (a charity created to support itself, run by volunteers)
• two public houses, one of which has been operated and staffed primarily by the same
family for approximately 20 years.
The pubs are both well attended.
There are no shops.
The nearest Medical Centre is in central Cowbridge.
Cowbridge primary and secondary schools are within walking distance. The schools have had
significant oversubscription issues for at least a decade, despite recent expansion. There are no
other easily commutable secondary schools in the area.
3.4 Transport accessibility
Public transport provision is also extremely limited:
• The nearest train station is in Pontyclun, 4.7 miles way
• There is only one bus stop, located on one side of the road, for buses headed North.
Although buses do stop in the opposite direction, taking residents towards Cowbridge,
there is no designated bus stop, street furniture or pavements, for safety purposes. The
stop is also on a 90-degree bend with multiple side roads and opposite a pub car park
which all together pose a risk to personal safety.
• Buses operate approximately hourly
Services run only until around 7:30 pm
• No Sunday or bank holiday services exists.
• Buses are not busy
There are no designated cycle paths (Active Travel). A scheme went through consultation but
met with multiple objections. Some of these are relevant to LDP planning elements, such as:
o The high volume and speed of traffic on the existing highways, predominantly the A4222
that runs directly through Aberthin
o A lack of segregated infrastructure in the area, which would force cyclists to share space
with cars in narrow sections.
o The lack of street lighting in the area, which made the route unappealing for use at night
or during winter.
o Concerns regarding installing lighting due to wildlife disruption
The project has been on hold for 3 years.
The settlement is not (for many) realistically walkable to any nearby towns, including
Cowbridge, the nearest town, the centre of which is 2km away. There is a reliance on Cowbridge
for most needs. In some places pavements do not exist or are not continuous through either
side of the village. Most residents rely on car travel.
3.5 Flood risks and geology
Aberthin is in a flood risk area, with most of the heart of the village in flood zone 3 and further
parts in flood zone 2:
• Fluvial Risk (Rivers): The area immediately surrounding the Nant Aberthin is subject to
flood risk. Nant Aberthin joins the River Thaw,
• Surface Water: Due to its position at the base of the steep Pen y Lan Road and Stalling
Down, the village and the adjacent field of the proposed site 2299 are susceptible to
local flood risk caused by surface runoff during intense rainfall. Groundwater also
naturally flows downhill towards valley bottoms, where it can emerge as springs or
cause the water table to reach the surface.
• Groundwater: Much of the village and the surrounding valley floor is classified by the
British Geological Society as having a High Susceptibility to groundwater flooding. This
means geological conditions (specifically the permeable limestone bedrock and
overlying river gravels) could enable groundwater to emerge at the surface or remain
very shallow.
• Aquifer Designation: The underlying Carboniferous Limestone is classified as a Principal
Aquifer. These are layers of rock with high permeability that provide significant water storage. In Aberthin, this leads to a "flashy" groundwater table that rises rapidly in
response to rainfall.
• Alluvial Deposits: The valley floor contains permeable layers of alluvium and gravel.
When the nearby River Thaw or Nant Aberthin rises, it can "push" groundwater up
through these deposits into low-lying areas, a process known as groundwater-surface
water interaction.
• Under the Water Framework Directive (WFD), the groundwater body in this part of the
Vale of Glamorgan is generally monitored for "Good" or "Poor" quantitative status.
Additionally, much of the centre and the surrounding agricultural land to the immediate North
and West has experienced historical flooding and is in Development Advice Map Zone B

4 Site identification and baseline facts
4.1 Site 2299 or HG4(2)
Site 2299 is described as ‘Land West of Maendy Road, Aberthin’, promoted for 25 dwellings.
Its’ status is undeveloped greenfield land (agricultural field). Current lawful use and any
covenants/easements must be confirmed via Land Registry title and planning history searches.
The site is one of 4 proposed through policy HG4 – rural affordable housing-led site.

4.2 Scale and proportionality
Aberthin is understood to have 176 dwellings. 25 dwellings = 14.2% increase in a single phase.
This also follows a development in 2017 which already saw a 13% increase, so the new
development constitutes urban sprawl.

4.2.1 Site map for HG4 (2) in relationship to existing Aberthin settlement
4.3 Development proposal context diagram

4.4 Key mapped constraints/sensitivities
• Wholly within Special Landscape Area (SLA).
• Partial Flood Zone 3 (southern end) and broader fluvial sensitivity in the Nant Aberthin
corridor.
• Intermediate surface water risk across approximately half the site (per Vale planning
constraints mapping), with additional low surface water risk elsewhere.
• Groundwater susceptibility identified as ‘red – highest to ground’ and recommendations for 12
months groundwater monitoring and FCA
• History of flooding (DEVELOPMENT ADVICE MAP Zone B) across middle of the site
• Current (known) southern access wholly within Flood Zone 3; width constraints for emergency
vehicles.
• No existing sewerage or drainage infrastructure on site.
• Public right of way interacts with the southern access area and proposed drainage features
and run along western end from bottom to top of site
• Proximity to designated assets (SSSI nearby, SINC 165, Conservation Area setting) and mineral
safeguarding (limestone safeguarding area).
• Historic hedgerow running down western side of site

5 Principle, spatial strategy and previous rejection
5.1 Conflict with the Plan’s Spatial Strategy
The core objection is one of principle. The proposed allocation would release open countryside
for estate-scale residential development in a Minor Rural Settlement, contrary to the spatial
strategy of the RLDP.
The RLDP directs the majority of housing growth to sustainable locations — higher-order
settlements and service centres — where employment, services, public transport and
infrastructure are available. Minor Rural Settlements are not intended to accommodate estate
scale development; growth in such locations is expected to be very limited and typically
confined to local need or small-scale infill. Aberthin is not identified as a strategic growth
location and no specific local affordable housing need within the settlement has been
demonstrated.
This strategic approach is reflected in the housing distribution set out in BP9A. Figure 2 shows
that only 4.5% of total housing growth is directed to Minor Rural Settlements and Primary
Settlements outside the Strategic Growth Area. Applied to the Plan’s total housing provision of
8,660 dwellings, this equates to approximately 390 dwellings across all minor rural settlements
over the 15-year plan period. By contrast, the overwhelming majority of growth is directed to
larger settlements:
Settlement Category
Share of Housing
Primary settlements in Strategic Growth Area 40.5%
Service centres
26.4%
Key settlements
24.9%
This distribution demonstrates that minor rural settlements are not intended to play a
significant role in housing delivery, with growth instead concentrated in locations with stronger
services, infrastructure and sustainable transport connections.
Within this context, allocating HG4(2) Aberthin for approximately 25 dwellings would represent
a 14.2% expansion of the settlement in a single phase, introducing suburban-scale development
into a small rural village with very limited services and infrastructure. Although described as
“small-scale”, the assessment fails to consider proportionality: a 14% expansion of a minor rural
settlement cannot reasonably be regarded as small-scale development.
The allocation therefore represents a departure from the Plan’s spatial distribution strategy
rather than an implementation of it.

5.2 Consistency with Previous Plan Evidence
The site was previously assessed during preparation of the Vale of Glamorgan LDP 2011-2026
and rejected. The reason for rejection was clear: the site was considered unrelated to the
settlement and would represent unacceptable sporadic development in the countryside. This
reasoning remains valid.
The physical relationship between the site and the settlement has not changed. The field
remains a separate agricultural parcel outside the established built form of Aberthin. No new
infrastructure, services, or settlement expansion has occurred that would alter this relationship.
Allocating the same site in the absence of any material change in context raises serious
questions about the consistency and robustness of the site selection process.
5.3 Internal Inconsistency in the Council’s Own Assessment
The Council’s Candidate Site Assessment contains a clear internal inconsistency regarding the
status of Site 2299. At Stage 1 the site is described as “adjacent to a minor rural settlement”
(BP18A, p.14), which indicates that the land lies outside the settlement and forms part of the
open countryside. However, at Stage 2 the site is assessed on the basis that “a small-scale
affordable housing led development in a minor rural settlement would accord in principle with
the strategy” (BP18A, p.20).
These statements are incompatible. A site that is adjacent to a settlement is not within it. The
assessment therefore appears to assume that the settlement boundary will be extended to
incorporate the site, yet no explanation or evidence is provided to justify such a boundary
change. This raises serious concerns regarding the transparency and robustness of the site
selection process and suggests that the allocation may be site-led rather than plan-led.
5.4 Scale Does Not Resolve the Principal Conflict
The number of dwellings proposed does not resolve the fundamental policy conflict.
Even if the development were reduced in scale, the underlying issue would remain: the site
constitutes development in the countryside beyond a defensible settlement boundary and
represents estate-style expansion rather than small-scale infill.
5.5 Reliance Solely on Affordable Housing Justification
The Council’s own assessment makes clear that the only substantive justification for the site is
the potential delivery of affordable housing. No other strategic justification is provided.
Indeed, the assessment acknowledges that:
• Aberthin has limited services and facilities, and
• public transport provision is relatively infrequent.
The reliance solely on affordable housing as justification is problematic in principle. Affordable
housing provision cannot justify development in locations that conflict with the spatial strategy,
particularly where the overall housing requirement is already exceeded, the plan target for
affordable housing doubles the historic attainment and need for the LDP to contribute, and
alternative sustainable sites are available.
The detailed assessment of affordable housing need and delivery is addressed separately in
Section [6] of this representation.

6 Affordable Housing, Spatial Strategy, and Necessity: Why HG4(2) Is
Not Required
6.1 The RLDP Already Exceeds the Housing Requirement (and Explicitly Builds
in Flexibility)
A key test in allocating additional housing sites is whether they are necessary for the Plan to
deliver its housing requirement and strategy.
BP9A confirms a housing requirement of 7,890 dwellings and total housing provision of 8,660
dwellings, explicitly described as a 10% flexibility allowance:
• “The housing provision of 8,660 dwellings rounds to a 10% flexibility allowance…”
• “…it is considered that a 10% flexibility should be considered a maximum…”
This creates a surplus of 770 dwellings above the requirement (8,660 – 7,890), meaning the Plan
is not operating at the margin but already includes a substantial buffer.
Removal of HG4(2) Aberthin (25 dwellings) would leave provision at 8,635 dwellings, still
exceeding the requirement by 745 dwellings. Even removal of all HG4 rural affordable-led sites
(122 dwellings) would leave provision at 8,538 dwellings, still exceeding the requirement by 648
dwellings.
The Plan therefore retains a substantial flexibility margin without reliance on the HG4 rural sites.
These allocations are consequently discretionary additions rather than necessary components of
the housing strategy.
6.2 HG4 Rural Affordable-Led Sites Represent a Very Small Component of
Supply and are not Numerically Essential
BP9A identifies “Affordable housing led sites” (HG4) as a limited element of supply totalling 122
dwellings across four settlements (Colwinston 25, Aberthin 25, Wick 50, Fferm Goch 22).
This is 1.4% of total Plan provision.
HG4 rural affordable-led sites therefore represent a very small and numerically non-essential
component of supply. Numerically, the Plan is not dependent on these sites. As set out above,
even removing all HG4 sites, the Plan retains a surplus of 648 dwellings above the requirement.
This confirms that these allocations are not structurally required for housing delivery.
6.3 The 3,070 Affordable Homes Figure Represents Expected Delivery — Not
Demonstrated Need and HG4(2) is immaterial to delivery
A key point in interpreting the Plan’s affordable housing evidence is the meaning of the 3,070
figure referenced throughout the RLDP evidence base.
BP9A confirms that:
“the various sources of housing will contribute 3,070 affordable homes.”
This figure represents expected affordable housing delivery arising from the housing supply
identified in the Plan, including sites with planning permission, sites under construction, housing
allocations, windfalls and affordable-led sites. It is therefore derived from the overall housing
supply and assumed policy performance, rather than representing a quantified level of housing
need that must be met in full. In other words, 3,070 is a projection of delivery, not a measure of
need.
The actual level of demonstrated need is identified through the Local Housing Market
Assessment (LHMA). BP9A confirms that the LHMA identifies:
• 461 affordable homes per year, equating to
• 6,918 affordable homes over the 15-year plan period.
This distinction is critical.
Measure
Demonstrated affordable housing need (LHMA)
Number
6,918 homes
Affordable housing expected to be delivered by the RLDP 3,070 homes
The Plan therefore anticipates delivering less than half of the identified affordable housing need
through the planning system. This is not unusual, as delivery through planning mechanisms is
constrained by factors such as development viability, housing delivery rates, reliance on market
schemes to generate affordable units, and the availability of subsidy and Registered Social
Landlord funding.
However, this distinction is fundamental when considering the necessity of individual
allocations. Because the 3,070 figure represents expected delivery arising from the overall
housing supply, it is not a target that must be achieved through allocating specific individual
sites. The inclusion or exclusion of a small site therefore does not materially affect the Plan’s
affordable housing strategy.
This is particularly clear in the case of HG4(2) Aberthin. BP9A indicates that affordable housing
led sites are expected to deliver at least 50% affordable housing, meaning HG4(2) would provide
approximately:
• 13 affordable homes from 25 dwellings,
with 62 affordable homes across all HG4 rural affordable-led sites combined.
The numerical impact of removing the Aberthin site is therefore extremely small:
• Removing HG4(2) Aberthin reduces affordable delivery from 3,070 to approximately
3,057 homes (0.42% reduction).
• Removing all HG4 rural affordable-led sites reduces delivery from 3,070 to
approximately 3,008 homes (2.02% reduction).
BP18A states that “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.” However, a contribution of 0.42% from the Aberthin site cannot
reasonably be described as important and is numerically negligible.
Accordingly, the Plan is not materially dependent on HG4(2) Aberthin to meet its affordable
housing delivery expectations. The loss of the site would not undermine the Plan’s affordable
housing strategy or prevent the RLDP from delivering the level of affordable housing the Council
expects to arise from the housing supply.
The evidence therefore demonstrates that HG4(2) Aberthin is not necessary for the Plan to
achieve its projected affordable housing delivery.
6.4 Affordable Housing Delivery Framework
Affordable housing delivery in Wales is not solely dependent on allocations or planning
obligations secured through the Local Development Plan (LDP). Welsh Government statistics
show that affordable housing is delivered through a range of mechanisms, including Welsh
Government capital grant programmes, housing association development and direct local
authority provision.
In 2024–2025, 3,643 additional affordable homes were delivered across Wales. Of these, 882
homes (approximately 24%) were delivered through planning obligations linked to market
housing developments, while around 76% were delivered through other routes, primarily grant
funded programmes and delivery by Registered Social Landlords and local authorities. This
demonstrates that the planning system represents one component of the wider affordable
housing delivery framework, rather than the principal delivery mechanism.
Within the Vale of Glamorgan, monitoring reports indicate that 2,398 affordable homes were
delivered between 2011 and 2025 under the current LDP period. Recent statistics also show 147
local authority homes delivered in 2024–2025, demonstrating that council-led delivery
programmes continue to contribute alongside housing association development.
The RLDP evidence suggests that approximately half of identified affordable housing need may
be delivered through planning mechanisms associated with housing allocations. When
compared with national delivery patterns — where planning obligations account for around 24%
of affordable housing provision — this represents approximately double the typical contribution
delivered through planning mechanisms.
The available evidence therefore indicates that the RLDP is already expected to make an
unusually high contribution to affordable housing delivery through planning mechanisms alone.
Given national delivery patterns and the Vale’s historic delivery record, it is reasonable to expect
that a proportion of affordable housing supply during the plan period will continue to arise
through other established mechanisms operating alongside the LDP, including Welsh
Government grant programmes, housing association development and local authority housing
delivery.
The evidence therefore indicates that the Local Development Plan should be understood as one
delivery mechanism within a wider system, rather than the principal mechanism through which
affordable housing need is expected to be met.
6.4.1 Implications for Site Allocation
In this context, the justification for allocating additional sites primarily to support affordable
housing delivery becomes less clear. If the RLDP already assumes a level of provision through
planning mechanisms that doubles typical national delivery patterns, further allocations risk
over-provision relative to what is required to support the plan strategy, raising a potential
question of plan soundness.
This is particularly relevant where proposed sites are rural or environmentally sensitive
locations, or where development may introduce landscape, infrastructure or environmental
impacts affecting the rural character that defines much of the Vale of Glamorgan.
The evidence therefore suggests that the necessity for additional site allocations should be
clearly demonstrated, particularly where affordable housing delivery may reasonably be
expected to arise through the wider delivery framework operating alongside the planning
system.
6.5 The Evidence Base Identifies the Greatest Affordable Need in Larger
Settlements
The LHMA evidence summarised in the RLDP identifies that the greatest affordable housing
need is in:
• Barry
• Penarth / Llandough
• Llantwit Major
• Dinas Powys
• Rhoose
The Plan’s spatial strategy directs the overwhelming majority of growth to these areas and
settlement categories: Key Settlements, Service Centres and Primary Settlements in the
Strategic Growth area. This alignment between identified housing need and the spatial
distribution of growth is a central principle of the Plan’s strategy.
By contrast, Minor Rural Settlements such as Aberthin are not identified as primary locations for
addressing affordable housing need, and the evidence base does not demonstrate a specific
local need within the settlement itself. In this context, allocating a greenfield affordable housing
site in Aberthin appears inconsistent with the evidence base.
6.6 The Council’s “Local Need and Support for Services” Justification Requires
Evidence
The Plan suggests that rural affordable housing allocations are intended to:
• respond to local affordable housing needs, and
• support local services and facilities.
However, the evidence presented within BP9A does not demonstrate:
• there is any affordable housing need locally within Aberthin,
• What services exist that can be supported by extra residents
The justification for HG4 rural affordable housing sites relies on two related propositions: that
they respond to locally arising affordable housing need and that they support the sustainability
of rural communities by helping to maintain local services and facilities. However, the evidence
base does not demonstrate a specific affordable housing need within Aberthin itself (only the
ward of Cowbridge). Nor does the settlement contain a range of services that would realistically
be sustained by a development of this scale. In these circumstances, the policy rationale
underpinning the allocation appears weak. PPW and TAN 6 expects rural affordable housing to
be genuinely locally justified.
6.7 Development Within the Wider Corridor
Housing development has taken place across the Cowbridge–Aberthin–Ystradowen corridor in
recent years. Within Aberthin itself, approximately 20 dwellings were completed around 2017
2018, including affordable homes. The redevelopment of the former Cowbridge school site
between Aberthin and Cowbridge is currently under construction and will deliver approximately
34 affordable homes.
Further housing has been delivered in nearby settlements, including Maple Walk in Ystradowen
(46 homes), with expansion in the RLDP, the former police station site in Cowbridge (14), and
Clare Garden Village (475), with further expansion. Collectively, these developments
demonstrate that housing supply, including significant levels of affordable housing, is already
being delivered within the surrounding area and the corridor may already be at saturation point.
6.8 Overall Conclusion
The evidence demonstrates that the allocation of HG4(2) Aberthin is not necessary for the RLDP
to deliver either its housing requirement or its projected affordable housing outcomes.
Even if HG4(2) Aberthin were removed, the Plan would still exceed its housing requirement by
745 dwellings, and even if all HG4 rural affordable-led sites were removed the surplus would
remain 648 dwellings. These allocations are therefore not required to maintain an appropriate
housing supply or flexibility allowance.
HG4(2) Aberthin itself is expected to deliver approximately 13 affordable homes, reducing
projected affordable housing delivery by only 0.42% if removed. Even removing all HG4 rural
affordable-led sites would reduce projected delivery by only 2.02%. The Plan is therefore not
materially dependent on these sites to achieve its affordable housing outcomes.
National evidence also demonstrates that affordable housing delivery in Wales arises through
multiple mechanisms operating alongside the planning system. The RLDP assumption that
around 50% of affordable housing need will be delivered through planning mechanisms
represents a doubling of the typical contribution made through the planning system.
Extensive corridor development of housing supply and affordable is already taking place and
may have already saturated this corridor.
No clear evidence has been presented demonstrating a specific local affordable housing need
within the settlement.

7 Flood risk, surface water, ground water, drainage, and methodological
concerns
7.1 TAN 15 Section 10.22 – Highly Vulnerable Development on Greenfield
Land in Flood Zone 3
BP21A (p.15) states:
“For a proposed development site within Flood Zones 3 of the Flood Map for Planning for Rivers,
Section 10.22 of TAN-15 states that highly vulnerable development on greenfield land is not
permitted. Section 10.23 of TAN-15 states that other development proposals are acceptable if
they are essential to the LDP.”
This is the primary policy test.
• Residential development = highly vulnerable development.
• The site is greenfield land.
• The southern part of the site lies within Flood Zone 3.
• TAN 15 states highly vulnerable development on greenfield land in Flood Zone 3 is not
permitted.
The only potential exception pathway is if the development is “essential to the LDP.”
This site is not essential:
• The housing trajectory demonstrates over delivery.
• Strategic sites are already allocated and viability tested.
• Minor rural settlements are not required to meet housing numbers.
• Affordable housing delivery is already occurring in service centres along this corridor
and through other delivery vehicles
• No need established in Aberthin
Accordingly, the allocation conflicts directly with TAN 15 Section 10.22.
7.2 Welsh Government Notification Direction – Escalation to Ministers
BP21A (p.15) states:
“It is recognised that the Welsh Government notification direction requires applications for
Highly Vulnerable Development where the whole or part of the site is within Flood Zone 3 on a
Greenfield site to be referred to the Welsh Ministers. Any development proposals for this site
which include residential use are therefore likely to be required to be notified to the Welsh
Government.”
This confirms:
• The seriousness of the constraint.
• That residential development here triggers Ministerial scrutiny.
• That the proposal is not routine.
It is unclear whether this allocation has been formally notified to Welsh Government at plan
stage. Allocation without clarity on Ministerial position introduces further procedural and
soundness risk.
7.3 SuDS Basin – Location Discrepancy and Flood Zone 3 Conflict
BP21A (p.16) states:
“Residential units located entirely within Flood Zone 1. A proposed SuDS detention basin is
located to the south of the site and is within Flood Zone 2.
As per the advice of the CIRIA SuDS Manual, SuDS should not be located within an area at a
greater than 1% AEP chance of flooding, which aligns to Flood Zone 3.”
However:
• Vale of Glamorgan planning constraints mapping indicates the basin location falls wholly
within Flood Zone 3.
If the basin is within Flood Zone 3:
• This conflicts with CIRIA guidance.
• Basin storage may be compromised during fluvial events.
• Coincident pluvial + fluvial events reduce attenuation capacity.
• Exceedance flows could affect:
o Site access (within Flood Zone 3),
o The public right of way,
o Existing properties at Maes Lloi.
No combined-event modelling outputs have been published.
7.3.1 Mapping overlay showing SUDs basin entirely in Flood Zone 3
Flood Zone
3
Flood Zone
3
7.4 Drainage, SuDS Feasibility and Groundwater Constraints
The hydrogeological and flood characteristics of the area raise significant doubt as to whether
an effective Sustainable Drainage System (SuDS) could be implemented on the site without
creating additional flood or environmental risk.
Aberthin lies within a valley setting where several interacting flood mechanisms operate. Much
of the village lies within Flood Zone 3, with surrounding areas within Flood Zone 2, reflecting
fluvial flood risk associated with the Nant Aberthin, which ultimately joins the River Thaw. In
addition to fluvial flooding, the area is susceptible to surface water runoff due to the steep
topography of surrounding higher ground, including Pen-y-Lan Road and the Stalling Down
plateau, which generate rapid runoff during intense rainfall events that drain towards the valley
floor where the village and the proposed site are located.
Groundwater conditions present a further constraint. The valley floor surrounding Aberthin is
identified by the British Geological Survey as having high susceptibility to groundwater flooding.
The site lies above Carboniferous Limestone classified as a Principal Aquifer, overlain by
permeable gravels and alluvial deposits associated with the Nant Aberthin valley. These
geological conditions can produce a rapidly responding (“flashy”) groundwater table in which
groundwater levels rise quickly following rainfall and may emerge at the surface or remain very
shallow. Interaction between river levels and groundwater within the alluvial deposits can
further exacerbate this effect, with elevated river levels capable of forcing groundwater upward
into adjacent low-lying land.
These conditions create a challenging environment for SuDS design. Welsh SuDS standards
require infiltration to be demonstrated as suitable for local ground conditions and to assess its
effects on groundwater levels. Where groundwater is shallow or highly responsive to rainfall,
infiltration techniques such as soakaways or infiltration basins may become ineffective or may
worsen groundwater emergence and flooding. Introducing additional infiltration in a valley floor
already prone to groundwater rise could therefore increase the risk of groundwater flooding in
surrounding parts of the village.
Even if infiltration techniques were unsuitable and an attenuation-based system were proposed,
significant uncertainty would remain. Such systems require sufficient space for attenuation
features, exceedance routing and safe discharge to a receiving watercourse. In this case, the site
is constrained by landscape sensitivity, established hedgerows, a public right of way, and its
position at the base of surrounding slopes where runoff naturally accumulates, raising doubt as
to whether a compliant SuDS solution could be delivered without substantial engineering
intervention.
There are also potential implications for Cors Aberthin SSSI, which lies within the same
hydrological valley system. Wetland habitats are typically highly sensitive to changes in
hydrology, groundwater levels and water quality, and development that alters surface water
pathways, increases runoff or modifies groundwater recharge patterns could affect the
hydrological conditions supporting the wetland ecosystem.
Together this creates significant uncertainty regarding whether a SuDS solution could be both
effective and environmentally acceptable. In the absence of detailed hydrogeological
investigation, seasonal groundwater monitoring and robust drainage modelling demonstrating
no increase in flood risk or ecological harm, the assumption that drainage issues can be
satisfactorily resolved remains unproven. This uncertainty raises further concerns regarding the
deliverability and environmental suitability of the allocation.
7.5 Absence of a Detailed Hydraulic Model – Nant Aberthin
BP21A (p.12) states:
“The southern extent of the Site is partially located within Flood Zones 2 and 3… No detailed
model is available of the Nant Aberthin.”
This is critical.
• There is no detailed hydraulic model of the Nant Aberthin.
• Flood extents are therefore based on national-scale modelling.
• No localised calibration or site-specific modelling has been published.
• Flood depth, velocity and hazard classification are not robustly evidenced.
Allocation of highly vulnerable development without a detailed fluvial model is precautionary
risk deficient.
7.6 Absence of Allocation-Stage FCA
The assessment documented in BP21a for site 2299 was undertaken by JBA Consulting. They
note the assessment was purely desk-based, taking information provided by others with no
verification.
BP21A (p.17) states:
“Any planning application for the Site should be accompanied by an FCA which demonstrates
how the proposals meet the requirements of TAN-15.”
This confirms:
• An FCA is required.
• It has not yet been undertaken.
• It is deferred to application stage.
However, TAN 15 requires flood consequences to be demonstrated as acceptable.
Allocation of highly vulnerable development in Flood Zone 3 without an FCA at plan stage
means:
• Flood consequences have not been demonstrated.
• Mitigation feasibility has not been proven.
• Deliverability is uncertain.
7.7 TAN 15 Section 10.18 – Flood Zone 2 Justification Pathway Not Engaged
BP21A (p.15) states:
“Section 10.18 of TAN-15 states that it is possible to allocate sites within Flood Zone 2 where the
proposals assist the implementation of the strategy of the LDP to regenerate or revitalise
existing settlements or to achieve key economic or environmental objectives.”
However:
• The site is not within the established settlement form.
• It was previously rejected as unrelated countryside.
• It does not regenerate the settlement.
• It does not achieve a key economic objective.
• It does not achieve a key environmental objective.
The Section 10.18 justification pathway does not apply.
7.8 Surface Water Risk – “Minimal” Assertion vs Mapping Evidence
BP21A states:
“Surface water and small watercourse flood risk is minimal across the site…”
However:
• Vale planning constraints mapping identifies intermediate surface water risk across
approximately half of the site.
• The site slopes from north to south toward Maes Lloi.
• Proposed dwellings fall within areas of intermediate surface water flood risk.
• Proposed dwellings are in an area of historical flooding (DEVELOPMENT ADVICE MAP
Zone B)
• No surface water modelling outputs are published.
• No velocity modelling.
• No exceedance routing plan.
• No no-worsening assessment.
Surface water risk has not been robustly evidenced at allocation stage.
7.9 Mapping shows majority of proposed houses located in risk areas
The following mapping overlays show that 16 of the 25 houses are in areas of either surface
water risk or have experienced historical flooding
7.9.1 Map overlay showing houses in risk areas for surface water
Surface risk
intermediate
Surface risk
intermediate
Surface risk
less
Surface risk
less
7.9.2 Map overlay showing houses in historical flooding area (DEVELOPMENT ADVICE MAP
Zone B)
Historical
flooding
Historical
flooding
7.10 Groundwater – “Red – High” and 12-Month Monitoring Requirement
The site is classified “Red – Hhigh – groundwater likely to be at or near the surface” meaning:
Groundwater levels are either at or very near (within 0.025m of) the ground surface.
BP21A recommends groundwater monitoring over a 12-month period to capture seasonal
variation.
There is no evidence that:
• 12 months monitoring has been undertaken.
• Basin performance takes account of high groundwater.
• Infiltration feasibility has been proven.
• Climate change allowances have been applied to groundwater conditions.
Allocation prior to completion of recommended monitoring is evidentially premature.
7.11 Topography and Potential Runoff Toward Existing At-Risk Properties
The site slopes from north to south toward Maes Lloi.
• Existing properties at Maes Lloi are largely within Flood Zone 3.
• Residents have noted drainage overload during wet periods.
• There is no evidence published that assesses whether the proposed development would
not worsen existing flood risks to surrounding properties
• No quantified runoff comparison between greenfield and developed sites is provided.
• No exceedance flow mapping is published.
Downstream impact risk has not been robustly assessed.
7.12 Failure to Apply Council Methodology
BP21A (p.13) states:
“the approach adopted by the Council within its assessment methodology was for flood risk to
be given the strongest possible weighting… sites identified to fall within areas of flood risk were
discounted from further consideration.”
This is unequivocal.
However, this site:
• Lies partially within Flood Zone 3.
• Has mapped intermediate surface water risk.
• Has groundwater classified “Red – High.”
• Has access within Flood Zone 3.
• Has a history of flooding (DEVELOPMENT ADVICE MAP Zone B)
• Requires Ministerial notification.
• Requires FCA and groundwater monitoring.
• Requires SUDs viability assessment
• Requires SSSI/ecology assessment
This represents a clear departure from the Council’s own stated methodology.
BP16 (p.20) states:
“Sites located within Zone 2 will only be considered where: It will assist, or be part of, a strategy
supported by the Development Plan to regenerate an existing settlement or achieve key
economic or environmental objectives or address national security or energy needs; AND • Its
location meets the definition of a brownfield site, And • Is supported by a FCA that indicates
that the potential consequences of a flooding event for the development proposed is found to
be acceptable in accordance with the criteria contained in section 11 of TAN 15 (2021).
Sites located within Zone 3 will only be considered where: • The development is required under
exceptional circumstances, as defined in TAN e.g. addressing national security or energy security
needs, reasons of public health or to mitigate the impacts of climate change, AND • Its location
meets the definition of a brownfield site, And • Is supported by a FCA that indicates that the
potential consequences of a flooding event for the development proposed is found to be
acceptable in accordance with the criteria contained in section 11 of TAN 15 (2021).”
This site is within Flood zones 2 and 3, is not brownfield, has no FCA, meets none of the
conditions in section 11, TAN 15 and is not required for exceptional circumstances.
The council do not appear to have followed any of these elements of methodology with regard
to flood risk.
7.13 Soundness Consequences
The allocation:
• Conflicts with TAN 15 Section 10.22.
• Does not meet Section 10.18 justification.
• Requires Welsh Government notification.
• Proceeds without any hydraulic model.
• Proceeds without FCA.
• Proceeds without groundwater monitoring.
• No-worsening test absent
• No SUDs viability assessment
• Contains mapping discrepancies.
• Defers critical evidence to application stage.
Accordingly, the allocation fails the soundness tests because it is:
• Not Justified – not based on robust, proportionate evidence.
• Not Effective – deliverability dependent on unresolved flood constraints.
• Not Consistent with national policy – specifically TAN 15 restrictions.

8 Infrastructure Constraints
8.1 Access Considerations
Indicative plans suggest that access to the proposed development may be provided from the
A4222 on the northern side of Aberthin. This would introduce an additional junction onto a
section of road that already contains numerous access points and turning movements. Given the
existing road layout and traffic conditions, the introduction of a further access point warrants
careful consideration in relation to highway safety.
The existing southern access route also presents constraints. It lies within Flood Zone 3, is
restricted in width, and cannot accommodate emergency vehicles safely. Flood events could
potentially affect access and egress, which may have implications for both existing and future
residents.
8.2 Existing Road Environment
The A4222 Maendy Road, which connects Cowbridge and Ystradowen through Aberthin, already
carries significant traffic volumes, including heavy goods vehicles. The road environment
includes several features that influence traffic movement and safety, including:
• a 90-degree bend over a bridge
• multiple side road junctions
• pub car park exits and private driveways accessing the road
• limited footpath provision and crossing points
• areas of reduced street lighting
These characteristics mean that drivers already navigate a relatively complex road environment
through the village.
Historic planning decisions also indicate sensitivity around access to this road. In 1978, South
Glamorgan County Council required the closure of the access from Skaife House onto the A4222
(Directly opposite the proposed new entrance), as part of planning consent for development at
The Spinney, Downs View Close, reflecting previous concerns regarding additional junctions
along this section of road (at a time with far less traffic).
8.3 8.3 Strategic Transport Policy Context
The RLDP is supported by BP14 – Strategic Transport Assessment Stage 1, which emphasises the
importance of locating development where sustainable travel options are available and where
the need to travel can be reduced. The assessment highlights the role of planning policy in
encouraging modal shift toward walking, cycling and public transport.
The Strategic Transport Assessment Stage 2 (BP14a) identifies capacity pressures within parts of
the local network. In particular, the Aberthin Road / Cardiff Road / St Athan Road / Eastgate
junction is recorded as operating beyond theoretical capacity during the AM peak period. This
indicates that parts of the local highway network already experience congestion during peak
travel times.
8.4 Car Dependency and Sustainable Transport
The Strategic Transport Assessment highlights that the Vale of Glamorgan has relatively high
levels of car ownership, with 83.4% of households owning one or more vehicles. In smaller rural
settlements such as Aberthin, limited public transport and no active travel infrastructure mean
that residents are likely to rely heavily on private vehicles.
The Vale’s active travel network is described within the transport evidence as limited and
fragmented in certain areas. Aberthin currently has:
• no designated Active Travel routes
• no proposed routes within the Active Travel Network Maps
• limited safe walking or cycling connections to nearby settlements such as Cowbridge
and Ystradowen, with narrow or missing footpaths and poorly lit sections.
An Active Travel scheme went through consultation but met with multiple objections. Some of
these are relevant to LDP planning elements, such as:
o The high volume and speed of traffic on the existing highways, predominantly the A4222
that runs directly through Aberthin
o A lack of segregated infrastructure in the area, which would force cyclists to share space
with cars in narrow sections.
o The lack of street lighting in the area, which made the route unappealing for use at night
or during winter.
o Concerns regarding installing lighting due to wildlife disruption
The project has been on hold for 3 years.
Public transport provision is also limited, with bus services operating approximately hourly,
ending in the early evening at 7.30, with no Sunday services. These factors may influence travel
patterns and increase reliance on private vehicles.
8.5 Cumulative Transport Considerations
As discussed earlier, extensive development has occurred and is still ongoing in the Cowbridge
Aberthin–Ystradowen corridor. These settlements are largely connected by the A4222 corridor,
which functions as the principal route linking the surrounding communities. The route already
accommodates traffic associated with existing settlements and recent development.
In this context, the cumulative impact of additional development along the corridor raises
considerations regarding traffic growth, junction capacity, road safety and infrastructure
demand. These factors may warrant careful evaluation when assessing additional rural
allocations, particularly where the transport evidence indicates existing pressures within parts of
the network.
8.6 Policy Considerations
Based on the transport evidence and local context outlined above, several policy considerations
arise.
8.6.1 Conflict with sustainable transport objectives
The Strategic Transport Assessment supporting the RLDP (BP14 and BP14a) emphasises the
importance of locating development where sustainable transport options are available and
where reliance on private vehicles can be reduced.
8.6.2 Infrastructure capacity and network pressures
Transport evidence identifies existing pressures within parts of the local highway network,
including peak-period congestion at key junctions serving the area. When considered alongside
recent and ongoing development within the Cowbridge–Aberthin corridor, the potential
cumulative effect of additional traffic generation may require further assessment to ensure that
local infrastructure can accommodate additional demand.
8.6.3 Consistency with the RLDP spatial strategy
Planning Policy Wales and the RLDP strategy emphasises directing development toward
locations with stronger accessibility to services, facilities and sustainable transport networks. As
a small rural settlement with limited transport connectivity, the role of Aberthin within this
spatial strategy may require careful consideration when assessing the suitability of additional
housing allocations.
8.7 Education capacity
The Council’s education evidence (BP43 Education) confirms that secondary education provision
serving the Cowbridge area is already under pressure.
Appendix F of BP43 identifies that Cowbridge Comprehensive School will require an additional
177 places to accommodate projected demand generated by RLDP growth.
BP43 uses the following pupil yield formula:
• Primary: Dwellings × 0.278
• Secondary: Dwellings × 0.208
Applying this to a development of 20–30 dwellings at Aberthin would generate approximately:
• 6–8 primary pupils
• 5–6 secondary pupils
• approximately 1 Additional Learning Needs (ALN) pupil
BP43 also confirms that ALN provision across the authority is already under pressure.
The Aberthin allocation therefore adds additional pupil demand to an already constrained
education system.
Given that the RLDP already provides 8,660 dwellings against a requirement of 7,890 (a surplus
of 770 dwellings) and affordable housing delivery is already secured through larger strategic
allocations, the additional education demand created by HG4(2) Aberthin is unnecessary for the
delivery of the Plan’s housing strategy.
9 Landscape, Settlement Edge, Hedgerow Protection, Public Right of
Way, Conservation Area and Nearby SSSI
9.1 Landscape and heritage setting sensitivity
The proposed allocation HG4(2) – Land West of Maendy Road, Aberthin lies wholly within a
Special Landscape Area (SLA) designated by Vale of Glamorgan Council. Special Landscape Areas
identify landscapes of locally significant character and visual quality, and planning policy
requires development within such areas to conserve and enhance landscape character and
avoid unnecessary harm to valued landscapes.
The site comprises open agricultural land immediately west of Aberthin, forming part of the
rural valley landscape associated with the Nant Aberthin corridor and contributing to the wider
countryside setting of the village and surrounding landscape extending toward Cowbridge.
Key landscape characteristics include:
• open pastoral farmland typical of the Vale of Glamorgan landscape
• strong hedgerow field boundaries reflecting historic field patterns
• visual connection with the Nant Aberthin valley landscape
• a continuous mature hedgerow along the western boundary running north–south
This hedgerow forms a defining landscape feature, contributing both to the historic field
structure of the landscape and to ecological connectivity.
The existing development along Maendy Road forms a clear and well-defined rural settlement
edge to Aberthin. The proposed site lies beyond this edge and currently reads as open
countryside rather than part of the village. Development of approximately 25 dwellings would
extend the built form westwards into open farmland, resulting in:
• encroachment of residential development into countryside
• erosion of the clear distinction between settlement and rural landscape
• urbanisation of the existing rural settlement edge.
These changes would be particularly sensitive given the site’s location within a Special
Landscape Area.
The site also forms part of the wider setting of the Aberthin Conservation Area, which protects
the historic character and appearance of the village under the Planning (Listed Buildings and
Conservation Areas) Act 1990. Aberthin is characterised by traditional stone cottages, a compact
historic form and a strong relationship with the surrounding countryside. The open farmland
west of the village contributes to this rural setting and historic landscape context. Development
of the site would extend the built form into land that currently forms part of that setting,
potentially altering the way the historic settlement is experienced within the surrounding
landscape.
The site is also located close to Cors Aberthin SSSI, a designated Site of Special Scientific Interest
recognised for its wetland habitats and ecological importance within the Nant Aberthin valley
system. SSSIs are protected under the Wildlife and Countryside Act 1981, and planning policy
requires that development should avoid Development Advice Mapage to their special scientific
interest and associated ecological systems.
The proximity of the allocation to Cors Aberthin SSSI reinforces the environmental sensitivity of
the wider landscape, particularly in relation to:
• hydrology and water movement within the valley
• ecological connectivity through the Nant Aberthin corridor
• protection of surrounding habitats that contribute to the ecological functioning of the
SSSI.
9.2 Significance and protection of the boundary hedgerow
The continuous hedgerow running along the western boundary of the site is likely to be of
considerable ecological, historic and landscape value.
Hedgerows of this type in the Vale countryside commonly:
• form part of historic field boundaries
• provide habitat corridors for birds, bats and small mammals
• contribute significantly to the traditional landscape character of the Vale of Glamorgan
Such hedgerows may qualify as “Important Hedgerows” under the Hedgerows Regulations 1997.
Where a hedgerow meets the criteria set out in these Regulations:
• removal requires formal consent from the local authority, and
• if the hedgerow is classified as important, consent for removal must normally be
refused.
Removal of an important hedgerow without permission constitutes a criminal offence.
Given the continuous north–south structure of the boundary hedgerow and its role in the
historic field pattern, there is a realistic possibility that the hedgerow would meet the criteria for
protection.

9.3 Public Right of Way and proposed realignment
A Public Right of Way (PRoW) currently crosses the site through open agricultural land, forming
part of the rural footpath network around Aberthin. In its current form the route is experienced
as a traditional countryside path, crossing open farmland with clear visibility and an open rural
character.
However, the indicative layout associated with the allocation appears to show the path diverted
along the western boundary of the site, coinciding with the existing hedgerow. The proposed
layout indicates:
• rear residential gardens backing onto the path
• tree planting along the boundary
• the route positioned between housing plots and boundary vegetation.
9.3.1 Loss of rural character and safety concerns
This realignment would fundamentally alter the character of the route. Instead of crossing open
countryside, the diverted path would form a long, narrow corridor along the edge of the
development. The path would therefore be experienced as a confined passage rather than an
open countryside route, raising concerns regarding:
• loss of the rural character of the right of way
• reduced visibility and openness
• personal safety for walkers.
The arrangement would effectively create a long-enclosed route resembling an alleyway,
particularly where gardens back directly onto the path. These concerns are amplified by the
likelihood that the route would remain unlit, as public rights of way across rural land are rarely
provided with lighting, particularly within Special Landscape Areas where lighting may conflict
with policies protecting rural character and dark skies.
The resulting route would therefore be a long, narrow and potentially unlit corridor, raising
further safety and amenity concerns.
Length of enclosed
alleyway
9.3.2 Legal implications of diversion
Any diversion of a Public Right of Way requires a legal order under the Highways Act 1980.
To be confirmed, such an order must demonstrate that:
• the diversion is necessary to enable the development, and
• the alternative route is not substantially less convenient or less enjoyable for the public.
Replacing a path that currently crosses open countryside with a route running along the edge of
housing development may therefore attract objections from users, residents or rights-of-way
groups, potentially preventing confirmation of the diversion order.
9.4 Interaction between the path diversion and hedgerow removal
The proposed diversion appears to coincide directly with the existing boundary hedgerow,
suggesting that the development may require removal or substantial alteration of this hedgerow
in order to accommodate the path and housing layout.
If the hedgerow qualifies as an Important Hedgerow under the Hedgerows Regulations 1997, its
removal may be legally restricted or refused, creating uncertainty regarding whether the layout
assumed by the allocation could be implemented.
9.5 Implications for site deliverability
The allocation therefore appears to depend upon:
• diversion of an existing Public Right of Way,
• possible removal or alteration of a potentially protected hedgerow, and
• development within an SLA and sensitive landscape setting closely associated with the
Cors Aberthin SSSI and Nant Aberthin ecological corridor.
Each of these matters involves separate legal and environmental considerations, none of which
can be assumed to be achievable at the plan allocation stage.
If the diversion were refused, or if removal of the hedgerow were not permitted, the layout
assumed by the allocation may not be achievable in practice.
9.6 Conclusion
The allocation of HG4(2) would introduce residential development into open countryside within
a designated Special Landscape Area, extending the settlement edge of Aberthin into land that
currently contributes to the village’s rural setting and the wider setting of the Aberthin
Conservation Area.
The site contains a continuous boundary hedgerow likely to be of significant landscape and
ecological value, which may qualify for protection under the Hedgerows Regulations 1997.
The indicative layout also proposes diverting an existing Public Right of Way from its current
route across open farmland to a narrow boundary corridor running between residential gardens
and boundary planting, fundamentally altering the character of the route and raising safety and
amenity concerns, particularly as the path would likely remain unlit.
The site also lies close to Cors Aberthin SSSI, further highlighting the environmental sensitivity of
the surrounding landscape.
Taken together, these factors raise serious concerns regarding landscape impact, heritage
setting, environmental sensitivity, legal constraints and the practical deliverability of the
allocation, particularly given that the Plan already provides sufficient housing supply without
reliance on development of this sensitive site.

10 Plan Soundness and potential Misapplication of Policy HG4
10.1 Affordable Housing Exception Policy Must Operate Within National Policy
Policy HG4 allows for small-scale affordable housing-led development in Minor Rural
Settlements, reflecting the Welsh Government policy approach to rural exception sites.
However, such policies are intended to operate within the framework of the Plan’s spatial
strategy, not to override it.
Affordable housing exception mechanisms are designed to allow limited, carefully justified
departures from the normal settlement boundary approach where local need is demonstrated
and cannot otherwise be met. They are not intended to provide a general mechanism for
allocating greenfield housing sites in rural settlements.
The allocation of Site 2299 appears to rely on HG4 as the primary justification for development,
rather than demonstrating that the site aligns with the broader spatial strategy and site
selection methodology of the Plan.
PPW (12) allows rural affordable housing through exception mechanisms, but only where
certain conditions are met.
• small-scale
• genuinely local need (not demonstrated in Aberthin)
• proportionate to settlement size (2299 is disproportionate estate scale development)
• does not undermine settlement strategy (outside strategic growth and sustainable
areas)
Development Plans Manual (Edition 3) states that site allocations should:
• flow from the spatial strategy
• follow the site search sequence
• be supported by a transparent assessment process
In other words:
Strategy → site selection → allocation
In the case of site 2299 the order appears reversed:
Site promoted → affordable housing justification → boundary expanded → allocation.
That is the type of site-led planning the manual warns against.
10.2 HG4 Overrides the Plan-Led Site Selection Process
The evidence in the Candidate Site Assessment indicates that the site has been taken forward
solely on the basis that it could deliver affordable housing and there is no indication that the
assessment methodology has been carried out
This approach effectively allows HG4 to override the wider plan-making framework, including:
• the settlement hierarchy,
• the spatial distribution of housing growth,
• the requirement to prioritise sustainable locations, and
• the established methodology for identifying appropriate development sites.
This creates a policy loophole whereby any countryside site adjacent to a minor rural settlement
could potentially be justified simply by proposing affordable housing. This risk appears to have
been realised. HG1, 3 and 4 were all rejected according to the assessment methodology but
resubmitted as affordable led upon guidance: “but the site could be reconsidered as a small
scale affordable housing led development”.
HG4(2) Aberthin was previously rejected in the 2011-2026 LDP then crucially did not go through
the normal assessment process but went straight to allocation as affordable-led. This creates a
precedent for any candidate site, including those previously rejected to be submitted as
affordable-led and potentially be allocated without robust assessment.
Such an approach undermines the plan-led system and the spatial strategy on which the RLDP is
based.
10.3 Lack of Evidence That the Site Is Necessary to Deliver Affordable Housing
The justification for the site relies on reference to the Local Housing Market Assessment
(LHMA), which identifies a need for additional affordable housing within the relevant ward of
Cowbridge.
However, the existence of an identified need does not in itself justify the allocation of specific
countryside sites.
The RLDP must demonstrate that:
1. the affordable housing requirement cannot be met within the overall housing supply,
and
2. the proposed site represents the most appropriate and sustainable location to
contribute to meeting that need.
Neither has been demonstrated.
As previously discussed, the RLDP already provides a significant surplus of housing provision
over the housing requirement, including substantial capacity within more sustainable
settlements.
In these circumstances, the allocation of a countryside site solely on the basis of affordable
housing provision i.e. HG4 exception, is not justified.
10.4 Soundness Implications
For a Local Development Plan to be sound it must be:
• Justified – based on a robust and credible evidence base and the most appropriate
strategy.
• Consistent with national policy.
• Effective and deliverable.
The reliance on Policy HG4 as the primary justification for Site 2299 raises concerns in respect of
all three tests.
In particular:
• Justified: The evidence base does not demonstrate that the site is necessary to deliver
the Plan’s housing or affordable housing objectives, or that there is any evidenced need
in Aberthin
• Consistent with National policy: The allocation does not appear to arise from a
consistent application of the spatial strategy or site selection methodology and does not
take account of flood risks in accordance with policy. The approach risks undermining
the plan-led system by allowing countryside sites to be allocated solely on the basis of
affordable housing provision.
• Effective and Deliverable: The number of constraints lack mitigation evidence, e.g. no
FCA, SUDs assessment, overall site viability assessment and other missing assessments,
the limited infrastructure of the area is not mitigated, and only summary financial
viability is provided, and this has discrepancies
For these reasons, the allocation of Site 2299 using HG4 cannot be considered justified or sound.

11 Conflicts with methodology, shifts, audit trail concerns and gaps
11.1 Candidate Site Assessment Methodology (BP16)
11.1.1 Site Assessment Criteria Outcomes
Site 2299 has been assessed against 35 criteria within the candidate site assessment framework.
Of these, 12 criteria are recorded as green (no identified constraints to development). Four
criteria are marked as red, which represent the most significant level of concern, typically
indicating a major constraint to development, potential conflict with national policy, or
insufficient information to support the assessment.
A review of the scoring suggests that some classifications may warrant further consideration, as
below, and may increase red scores to 6. A site could be rejected on the basis of a single red
score (p10).
11.1.2 Potential Issues in the Scoring
11.1.2.1 Environment and Physical Constraints
The site is recorded as Amber under the category of Environmental and Physical Constraints.
However, part of the site lies within Flood Zone 3 and therefore appears to engage the
requirements of Technical Advice Note 15 (TAN15), specifically the Justification Test and
Acceptability of Consequences tests set out in Sections 10 and 11.
Guidance provided in Background Paper BP16 (page 20) states that sites located within Flood
Zone 3 will only be considered where specific criteria are met. These include:
• The development is required under exceptional circumstances, such as those relating to
national security, energy security, public health, or climate change mitigation.
• The site meets the definition of previously developed (brownfield) land.
• The proposal is supported by a Flood Consequences Assessment (FCA) demonstrating
that the potential consequences of flooding are acceptable in accordance with the
criteria contained within Section 11 of TAN15 (2021).
In the case of Site 2299:
• No exceptional circumstances have been identified.
• The site is greenfield rather than previously developed land.
• No evidence has been presented demonstrating compliance with the acceptability of
consequences test.
Further, on page 7 of the guidance:
“Flood risk – sites located within either a TAN 15 Defended Area, or Flood Zone 2 or 3 area which
do not meet the justification test and acceptability of consequences section 10 and11 out in TAN
15 will not pass the initial sifting.”
In light of these factors, the classification of Amber within this category is surprising, as it
appears the site should have not have even passed initial sifting.
11.1.2.2 Landscape Considerations
The site is also scored Amber under the Special Landscape Area criterion. However, the scoring
guidance indicates that a site should be classified as Red where it is predominantly greenfield
and wholly located within a Special Landscape Area or a Registered Landscape of Outstanding or
Special Historic Interest.
Site 2299 is identified as greenfield land and lies entirely within a designated Special Landscape
Area. Based on the stated scoring methodology, this suggests that a Red classification could be
more consistent with the guidance provided.
11.1.3 FCA requirement
On page 22 the FCA requirement and discounting rule is clear:
“Sites which are not accompanied by a FCA or do not meet the tests shall be automatically
discounted from further consideration.”
Site 2299 does not have an FCA, so should have been discounted.
11.2 Deposit assessment audit-trail concerns (BP18A) and unexplained shifts
Inconsistencies in the deposit candidate site assessment narrative are noted:
• BP18A p.14 describes the site 2299 as conforming with strategy/initial filter and uses
language indicating it is ‘adjacent’ to the settlement; later narrative suggests it is ‘in’ the
settlement without a published boundary justification.
• BP18A p.20 notes ‘suitable for further consideration’ while listing constraints without
explaining why those constraints did not prevent progression under BP16.
• BP18A p.34 significantly downplays flood risk (references only a part in Flood Zone 3) and
does not reflect mapped intermediate surface water risk covering around half the site,
historical flood data and ground water risk.
• BP18A p.77 contains a ‘Acceptable at PS stage’ recorded as “N/A” for site 2299 and a
‘Justification’ field recorded as “N/A” for site 2299, which undermines transparency.
• BP18A also indicates that detailed site proformas exist and are available on request. The
Council should disclose the full Site 2299 proforma used for decision-making, including RAG
scoring rationale and any override decisions.
• BP18A p.34 – indicates a viability assessment has been submitted for site 2299 which
demonstrates that the site is deliverable as an affordable housing led site. Only a summary
table has been published, which appears to under cost, and may need validating in light of
flood risks, SUDs viability, no sewerage on site, and contributions to education and
infrastructure costs cited elsewhere.
11.3 Independent viability evidence gap and deliverability risk (BP42A)
• BP42A (December 2025) provides Independent Financial Viability Assessments of five
strategic/key sites. Site 2299 is not included. Planning Policy Wales (PPW 12) directs
that: “as part of demonstrating the deliverability of housing sites, financial viability must
be assessed prior to their inclusion as allocations in a development plan. At the
‘Candidate Site’ stage of development plan preparation, land owners/developers must
carry out an initial site viability assessment and provide evidence to demonstrate the
financial deliverability of their sites.”
• BP42A states it is concerned with financial viability only and not broader constraints.
• Site 2299 is not a low-risk site; it is flood constrained, and requires a robust
management plan, SUDs viability needs testing (extending to SSSI implication), requires
full new sewage/drainage infrastructure, has access uncertainties and SLA landscape
constraints. These drive abnormal costs. Without site-specific viability testing,
deliverability and affordable housing delivery cannot be assumed.
• Site 2299 has viability tension: as abnormal costs rise (flood mitigation, SuDS,
groundwater management, highway works, sewage/drainage installation and potential
off-site reinforcement), affordable housing delivery is typically the first pressure point.
The RLDP must evidence deliverability for this site, not assume it.

12 Tests of soundness
For the RLDP to be sound it must be Justified, Effective and Consistent with National Policy.
12.1 Not Justified
The allocation is not supported by proportionate evidence:
• the RLDP already provides 770 dwellings above the housing requirement
• the site contributes only 0.42% of projected affordable housing delivery
• no specific local affordable housing need has been demonstrated within Aberthin
• the site conflicts with the spatial strategy which limits growth in Minor Rural
Settlements
• the allocation represents a departure from the Council’s own site assessment
methodology
• the allocation lacks a transparent audit trail
• does not demonstrate why this constrained countryside site is the most appropriate
option, particularly given delivery elsewhere in the corridor and strategic sites
12.2 Not Effective
The site cannot be shown to be deliverable because:
• significant flood risk constraints remain unresolved
• no Flood Consequence Assessment has been undertaken
• groundwater monitoring recommended in the evidence has not been completed
• the SuDS strategy has not been demonstrated to be viable
• potential impacts on Cors Aberthin SSSI hydrology have not been assessed
• no-worsening test absent
• access, drainage and infrastructure constraints remain uncertain
• viability is not independently tested or fully costed
12.3 Not Consistent with National Policy
The allocation conflicts with Technical Advice Note 15 (Flood Risk) because:
• the site partly lies within Flood Zone 3
• residential development is highly vulnerable development
• TAN15 states such development should not occur on greenfield land in Flood Zone 3
unless essential to the LDP
• the RLDP already contains a substantial housing surplus, meaning the site cannot be
considered essential
12.4 Conclusion
For these reasons the allocation of HG4(2) – Land West of Maendy Road, Aberthin cannot be
considered sound.
The site should therefore be removed from the RLDP.
10.3 Not consistent with national policy: the allocation conflicts with national objectives for
sustainable location and robust flood risk management (including safe access/egress and no
worsening).

13 Formal request and proposed modifications
1. Primary request: delete Site 2299 from the RLDP and remove it from Policy HG4.
2. Settlement boundary: do not redraw the Aberthin settlement boundary to include this
field parcel; if already redrawn, reinstate the defensible boundary aligned to existing
built form unless a published boundary review justifies change.
Evidence disclosure requests (minimum):
a. Robust evidence qualifying necessity under HG4, aligned to national policies
b. Full Site 2299 proforma (BP18A indicates proformas exist and are available on
request), including all scoring and override rationale.
c. Full FCA including modelling outputs, assumptions, and climate change
allowances for both fluvial and pluvial events, surface runoff from surrounding
slopes, high groundwater susceptibility, principal aquifer conditions, cumulative
testing, implications on the nearby SSSI wetland habitat, ecology assessment
and no worsening test.
d. Surface water modelling demonstrates intermediate risk treatment, exceedance
routing and no worsening.
e. The advised 12-month Groundwater monitoring and data
f.
SuDS feasibility and design, including implications on the nearby SSSI and
ecology.
g. Drainage strategy demonstrating foul connection feasibility, capacity, and any
required off-site reinforcement.
h. Dry access/egress assessment for residents and emergency vehicles during flood
events.
i.
j.
Highways feasibility: access location, visibility, swept-path tracking and road
safety audit.
Active travel and public transport assessment with deliverable mitigation
package and funding mechanism.
k. Landscape/visual assessment for SLA impacts.
l.
Ecology and heritage appraisals including SSSI proximity and Conservation Area
setting.
m. Site-specific viability appraisal (including all abnormal costs) demonstrating
affordable housing deliverability.
3. Confirmation regarding protection of hedgerow
4. Confirmation regarding PRoW

Changes to plan
1. Primary request: delete Site 2299 from the RLDP and remove it from Policy HG4.
2. Settlement boundary: do not redraw the Aberthin settlement boundary to include this
field parcel; if already redrawn, reinstate the defensible boundary aligned to existing
built form unless a published boundary review justifies change.
Evidence disclosure requests (minimum):
a. Robust evidence qualifying necessity under HG4, aligned to national policies
b. Full Site 2299 proforma (BP18A indicates proformas exist and are available on
request), including all scoring and override rationale.
c. Full FCA including modelling outputs, assumptions, and climate change
allowances for both fluvial and pluvial events, surface runoff from surrounding
slopes, high groundwater susceptibility, principal aquifer conditions, cumulative
testing, implications on the nearby SSSI wetland habitat, ecology assessment
and no worsening test.
d. Surface water modelling demonstrates intermediate risk treatment, exceedance
routing and no worsening.
e. The advised 12-month Groundwater monitoring and data
f.
SuDS feasibility and design, including implications on the nearby SSSI and
ecology.
g. Drainage strategy demonstrating foul connection feasibility, capacity, and any
required off-site reinforcement.
h. Dry access/egress assessment for residents and emergency vehicles during flood
events.
i.
j.
Highways feasibility: access location, visibility, swept-path tracking and road
safety audit.
Active travel and public transport assessment with deliverable mitigation
package and funding mechanism.
k. Landscape/visual assessment for SLA impacts.
l.
Ecology and heritage appraisals including SSSI proximity and Conservation Area
setting.
m. Site-specific viability appraisal (including all abnormal costs) demonstrating
affordable housing deliverability.
3. Confirmation regarding protection of hedgerow
4. Confirmation regarding PRoW

Remove allocation.

E-Petition submitted via Participate Vale -103 signatures
Petition Title - Oppose Unsustainable Greenfield Expansion Outside Aberthin’s Settlement Boundary
Petition Summary - A parcel of land in the village of Aberthin, located directly behind Maes Lloi, has been proposed for a housing development of 25 dwellings, with at least 50% designated as affordable housing. This site has been included in the Vale of Glamorgan Council’s Replacement Local Development Plan (RLDP). Residents have only recently become aware of this proposal, despite the plan being in preparation for over two years, and we now have until 11 March to submit objections. We are seeking the support of local residents and the many people from across the Vale who regularly use this valued green space. This petition is intentionally objective and non emotive, focusing on planning considerations and the wider impact on the community. The field is widely used by dog walkers, runners, and families, and forms part of the well used off road route linking Aberthin to Cowbridge. Key Planning Grounds for Objection 1. The site has previously been rejected for development • In the previous LDP, the land was dismissed because it was considered unrelated to the settlement of Aberthin and would constitute sporadic development in the countryside. • This was a clear spatial judgement based on location. • The site remains outside the established settlement boundary. • Nothing has changed in the physical relationship between the land and the village. • Allocation under Policy HG4 does not alter this fundamental reality. 2. The RLDP directs growth to strategic and sustainable locations • Aberthin is classified as a Minor Rural Settlement, not a sustainable growth location. • The RLDP states that development should be focused on the Strategic Growth Area and Service Centres. 3. Cowbridge is already delivering substantial planned growth • Cowbridge, a designated Service Centre, has hundreds of homes either under construction or allocated. • Infrastructure, services, and sustainable transport are concentrated there—not in Aberthin. • The Clare Gardens development alone will deliver 405 homes, including 133 affordable units and 57 first time buyer properties. • Given this scale of delivery, greenfield expansion outside Aberthin’s boundary is unnecessary. 4. The proposal represents disproportionate growth • Adding 25 dwellings would increase the size of Aberthin by approximately 15% in a single development. • This is not minor infill; it is a clear outward expansion. • Policy HG4 requires development in rural settlements to be small scale and proportionate. 5. Significant highway safety concerns The road through Aberthin (linking Cowbridge and Ystradowen) is already heavily trafficked, including a high volume of HGVs, with poor compliance to the 20mph limit. The proposed access point would sit less than 20 metres north of the last house in the village. This stretch of road has a history of incidents due to: • A sharp bend over a bridge • Two public house car parks • Three side road junctions • Multiple private driveways directly onto the main road Introducing another junction would exacerbate existing safety risks. 6. Flood risk and infrastructure concerns • Parts of the site fall within Flood Zones 2 and 3, requiring a full Flood Consequence Assessment. • Access is constrained and no specific sustainable transport measures have been identified. • There is no clear infrastructure strategy to support the development. Conclusion This petition seeks to ensure that development in the Vale of Glamorgan follows the principles of sustainability, proportionality, and sound planning judgement. The proposed allocation behind Maes Lloi does not meet these criteria. We therefore ask residents and users of this valued green space to support this petition and share it widely. Thank you for caring.

1. Primary request: delete Site 2299 from the RLDP and remove it from Policy HG4.
2. Settlement boundary: do not redraw the Aberthin settlement boundary to include this field parcel; if already redrawn, reinstate the defensible boundary aligned to existing built form unless a published boundary review justifies change.
Evidence disclosure requests (minimum):
a. Robust evidence qualifying necessity under HG4, aligned to national policies
b. Full Site 2299 proforma (BP18A indicates proformas exist and are available on request), including all scoring and override rationale.
c. Full FCA including modelling outputs, assumptions, and climate change allowances for both fluvial and pluvial events, surface runoff from surrounding slopes, high groundwater susceptibility, principal aquifer conditions, cumulative testing, implications on the nearby SSSI wetland habitat, ecology assessment and no worsening test.
d. Surface water modelling demonstrates intermediate risk treatment, exceedance routing and no worsening.
e. The advised 12-month Groundwater monitoring and data
f. SuDS feasibility and design, including implications on the nearby SSSI and ecology.
g. Drainage strategy demonstrating foul connection feasibility, capacity, and any required off-site reinforcement.
h. Dry access/egress assessment for residents and emergency vehicles during flood events.
i. Highways feasibility: access location, visibility, swept-path tracking and road safety audit.
j. Active travel and public transport assessment with deliverable mitigation package and funding mechanism.
k. Landscape/visual assessment for SLA impacts.
l. Ecology and heritage appraisals including SSSI proximity and Conservation Area setting.
m. Site-specific viability appraisal (including all abnormal costs) demonstrating affordable housing deliverability.
3. Confirmation regarding protection of hedgerow
4. Confirmation regarding PRoW

Land West of Maendy Road, Aberthin, site 2299 or HG4(2) – Vale of Glamorgan Replacement Local Development Plan (RLDP) Deposit Stage

Refer to attached document for images referred to

This representation objects to the allocation of Site HG4(2) – Land West of Maendy Road,
Aberthin (Site 2299) within the Vale of Glamorgan Replacement Local Development Plan (RLDP).
The allocation proposes approximately 25 dwellings as an affordable housing-led development
on greenfield agricultural land forming part of the countryside immediately west of Aberthin.
The allocation is unsound for several independent reasons.
First, the proposal conflicts with the Plan’s spatial strategy.
Aberthin is identified as a Minor Rural Settlement, where development is expected to be limited
in scale and primarily related to local needs. A development of approximately 25 dwellings
would represent around a 14% expansion of the settlement in a single phase, introducing
estate-scale growth into a small rural village with very limited services. This represents a
material step-change inconsistent with the role of such settlements within the hierarchy.
Second, the site is not necessary for delivery of the Plan’s housing strategy.
The RLDP identifies a housing requirement of 7,890 dwellings and housing provision of 8,660
dwellings, creating a surplus of 770 dwellings above the requirement. Removal of HG4(2)
Aberthin would still leave a surplus of 745 dwellings, and even removal of all HG4 rural
affordable-led sites would leave a surplus of 648 dwellings. The allocation is therefore not
required for the Plan to deliver its housing requirement.
Third, the RLDP evidence identifies affordable housing need at a ward level (Cowbridge) rather
than within Aberthin itself, and no evidence has been presented demonstrating a specific locally
arising need within the settlement.
Forth, the site makes only a negligible contribution to affordable housing delivery. The site is
expected to deliver approximately 13 affordable homes, representing only 0.42% of the Plan’s
projected affordable housing delivery of 3,070 homes. The Plan is therefore not materially
dependent on the site to deliver its affordable housing strategy.
Fifth, the site is heavily constrained by flood risk and drainage uncertainty.
Part of the site lies within Flood Zone 3, where highly vulnerable development on greenfield
land is not permitted under Technical Advice Note 15 (TAN15) unless the development is
essential to the Local Development Plan. Given the Plan’s housing surplus, and no identified
local need, the site cannot reasonably be considered essential. In addition:
• no detailed hydraulic model exists for the Nant Aberthin watercourse,
• no Flood Consequence Assessment has been undertaken at allocation stage,
• groundwater susceptibility is classified as “Red – high – groundwater likely to be at or
near the surface”, with a recommendation for 12 months monitoring which has not
been undertaken,
• surface water mapping indicates intermediate flood risk across part of the site, and
historical flood data indicates flooding
• the proposed SuDS detention basin location appears to fall within Flood Zone 3
according to Council constraint mapping, raising questions regarding compliance with
SuDS design guidance,
• the viability and performance of the proposed drainage strategy has not been
demonstrated, including potential effects on the hydrology of the nearby Cors Aberthin
SSSI wetland system, and
• no modelling has been provided to demonstrate that development would not worsen
flood risk to neighbouring properties, including those at Maes Lloi.
Taken together, these factors create substantial uncertainty regarding whether a compliant
drainage strategy could be delivered and whether flood risk could be safely managed.
Sixth, the site presents infrastructure and accessibility constraints.
Aberthin has very limited services and infrastructure. The settlement contains no shops and
limited community facilities, with most services located in nearby Cowbridge. Public transport
provision is limited to infrequent bus services which cease in the early evening and do not
operate on Sundays, and there are no designated active travel routes connecting the settlement
to surrounding towns. The road network through the village, particularly along the A4222
corridor, already experiences traffic pressures and safety concerns. The Council’s education
evidence also confirms that secondary school capacity serving the area is already under
pressure, with additional places required to accommodate projected growth.
Seventh, the allocation introduces development into a sensitive landscape and environmental
setting.
The site lies entirely within a Special Landscape Area, contributes to the countryside setting of
the Aberthin Conservation Area, lies close to Cors Aberthin SSSI, and contains established
hedgerow boundaries forming part of the historic field pattern of the Vale landscape.
Finally, the allocation represents a clear departure from the Council’s published site assessment
methodology.
Background Paper BP16 indicates that sites affected by flood risk should normally be discounted
from further consideration. Despite multiple constraints — including Flood Zone 3, groundwater
susceptibility and surface water risk — Site 2299 was not discounted. The site was previously
rejected during preparation of the adopted LDP on the basis that it was unrelated to the
settlement and constituted sporadic development in the countryside, and no material change in
circumstances has been demonstrated to justify a different conclusion. Additionally, audit trail
concerns are evident, e.g. N/A values in justification columns.
Taken together, the evidence demonstrates that the allocation:
• is not necessary to deliver the Plan’s housing requirement or affordable housing
outcomes, and no need has been established
• conflicts with national flood policy (TAN15),
• is inconsistent with Council’s own site assessment methodology, and
• introduces development into a sensitive rural landscape with infrastructure constraints
unnecessarily.
In conclusion, these matters demonstrate that the allocation fails the key tests of soundness: it
is not justified by the evidence, is not effective or deliverable due to unresolved environmental
and infrastructure constraints, and is not consistent with national policy, including Planning
Policy Wales (sustainable spatial strategy and protection of landscape) and Technical Advice
Note 15 (flood risk)
For these reasons, Site HG4(2) – Land West of Maendy Road, Aberthin should be removed from
the RLDP.

3.1 Settlement size and character
Aberthin is classified as a minor rural settlement. It is a historic agricultural village built around
the Nant Aberthin (Aberthin Brook), a tributary that flows into the River Thaw. The settlement is
surrounded by agricultural land parcels and a large common land called Stalling Down.
It is estimated to contain approximately 176 dwellings.
There is a close-knit community feel, with many residents taking parts in community events
organised by the village hall committee, such as a duck race (where plastic yellow ducks are
raced down the stream), a free bonfire and fireworks display held on the downs, quiz nights,
amateur dramatics and an annual Village Day, which has a barbeque, music and a dog show.
Aberthin has already been recently extended, under the last LDP. In around 2017, 20 properties
were built in Court close, 6 of those affordable. The settlement boundary was redrawn to
accommodate the site, as can be seen in the map below, marked in red. (REFER TO ATTACHED PDF FOR IMAGES)
3.1.1 Settlement boundary

3.2 Landscape and Environmental Context of Aberthin
The settlement is characterised by its historic village form, traditional buildings and strong
relationship with the surrounding countryside. Much of the landscape surrounding the village is
designated as a Special Landscape Area by Vale of Glamorgan Council, reflecting the recognised
scenic quality and rural character of the Nant Aberthin valley and the wider Vale landscape. The
historic character of the settlement is also recognised through the designation of the Aberthin
Conservation Area, which protects the architectural and historic character of the village and its
relationship with the surrounding rural landscape.
The surrounding countryside comprises a network of agricultural fields defined by historic
hedgerow boundaries, forming part of the traditional field pattern typical of the Vale of
Glamorgan. The area is also notable for its historic environment, with several Scheduled Ancient
Monuments and other archaeological features recorded in the surrounding landscape, reflecting
long-standing human activity in the Nant Aberthin valley. The landscape also supports important
ecological features associated with the Nant Aberthin watercourse and valley system, including
the nearby Cors Aberthin SSSI, a designated wetland site protected under the Wildlife and
Countryside Act 1981. Public rights of way cross the surrounding farmland, providing access to
the countryside and contributing to the rural character and recreational value of the area.
3.2.1 Landscape features
SSSI: shown in red, Conservation Area – maroon boundary, monuments in blue, ancient
woodland in green crosshatch, and SINC in green horizontal lines

3.3 Services and facilities
Aberthin has very limited services and infrastructure.
Known facilities include:
• a small community centre (a charity created to support itself, run by volunteers)
• two public houses, one of which has been operated and staffed primarily by the same
family for approximately 20 years.
The pubs are both well attended.
There are no shops.
The nearest Medical Centre is in central Cowbridge.
Cowbridge primary and secondary schools are within walking distance. The schools have had
significant oversubscription issues for at least a decade, despite recent expansion. There are no
other easily commutable secondary schools in the area.
3.4 Transport accessibility
Public transport provision is also extremely limited:
• The nearest train station is in Pontyclun, 4.7 miles way
• There is only one bus stop, located on one side of the road, for buses headed North.
Although buses do stop in the opposite direction, taking residents towards Cowbridge,
there is no designated bus stop, street furniture or pavements, for safety purposes. The
stop is also on a 90-degree bend with multiple side roads and opposite a pub car park
which all together pose a risk to personal safety.
• Buses operate approximately hourly
Services run only until around 7:30 pm
• No Sunday or bank holiday services exists.
• Buses are not busy
There are no designated cycle paths (Active Travel). A scheme went through consultation but
met with multiple objections. Some of these are relevant to LDP planning elements, such as:
o The high volume and speed of traffic on the existing highways, predominantly the A4222
that runs directly through Aberthin
o A lack of segregated infrastructure in the area, which would force cyclists to share space
with cars in narrow sections.
o The lack of street lighting in the area, which made the route unappealing for use at night
or during winter.
o Concerns regarding installing lighting due to wildlife disruption
The project has been on hold for 3 years.
The settlement is not (for many) realistically walkable to any nearby towns, including
Cowbridge, the nearest town, the centre of which is 2km away. There is a reliance on Cowbridge
for most needs. In some places pavements do not exist or are not continuous through either
side of the village. Most residents rely on car travel.
3.5 Flood risks and geology
Aberthin is in a flood risk area, with most of the heart of the village in flood zone 3 and further
parts in flood zone 2:
• Fluvial Risk (Rivers): The area immediately surrounding the Nant Aberthin is subject to
flood risk. Nant Aberthin joins the River Thaw,
• Surface Water: Due to its position at the base of the steep Pen y Lan Road and Stalling
Down, the village and the adjacent field of the proposed site 2299 are susceptible to
local flood risk caused by surface runoff during intense rainfall. Groundwater also
naturally flows downhill towards valley bottoms, where it can emerge as springs or
cause the water table to reach the surface.
• Groundwater: Much of the village and the surrounding valley floor is classified by the
British Geological Society as having a High Susceptibility to groundwater flooding. This
means geological conditions (specifically the permeable limestone bedrock and
overlying river gravels) could enable groundwater to emerge at the surface or remain
very shallow.
• Aquifer Designation: The underlying Carboniferous Limestone is classified as a Principal
Aquifer. These are layers of rock with high permeability that provide significant water storage. In Aberthin, this leads to a "flashy" groundwater table that rises rapidly in
response to rainfall.
• Alluvial Deposits: The valley floor contains permeable layers of alluvium and gravel.
When the nearby River Thaw or Nant Aberthin rises, it can "push" groundwater up
through these deposits into low-lying areas, a process known as groundwater-surface
water interaction.
• Under the Water Framework Directive (WFD), the groundwater body in this part of the
Vale of Glamorgan is generally monitored for "Good" or "Poor" quantitative status.
Additionally, much of the centre and the surrounding agricultural land to the immediate North
and West has experienced historical flooding and is in Development Advice Map Zone B

4 Site identification and baseline facts
4.1 Site 2299 or HG4(2)
Site 2299 is described as ‘Land West of Maendy Road, Aberthin’, promoted for 25 dwellings.
Its’ status is undeveloped greenfield land (agricultural field). Current lawful use and any
covenants/easements must be confirmed via Land Registry title and planning history searches.
The site is one of 4 proposed through policy HG4 – rural affordable housing-led site.

4.2 Scale and proportionality
Aberthin is understood to have 176 dwellings. 25 dwellings = 14.2% increase in a single phase.
This also follows a development in 2017 which already saw a 13% increase, so the new
development constitutes urban sprawl.

4.2.1 Site map for HG4 (2) in relationship to existing Aberthin settlement
4.3 Development proposal context diagram

4.4 Key mapped constraints/sensitivities
• Wholly within Special Landscape Area (SLA).
• Partial Flood Zone 3 (southern end) and broader fluvial sensitivity in the Nant Aberthin
corridor.
• Intermediate surface water risk across approximately half the site (per Vale planning
constraints mapping), with additional low surface water risk elsewhere.
• Groundwater susceptibility identified as ‘red – highest to ground’ and recommendations for 12
months groundwater monitoring and FCA
• History of flooding (DEVELOPMENT ADVICE MAP Zone B) across middle of the site
• Current (known) southern access wholly within Flood Zone 3; width constraints for emergency
vehicles.
• No existing sewerage or drainage infrastructure on site.
• Public right of way interacts with the southern access area and proposed drainage features
and run along western end from bottom to top of site
• Proximity to designated assets (SSSI nearby, SINC 165, Conservation Area setting) and mineral
safeguarding (limestone safeguarding area).
• Historic hedgerow running down western side of site

5 Principle, spatial strategy and previous rejection
5.1 Conflict with the Plan’s Spatial Strategy
The core objection is one of principle. The proposed allocation would release open countryside
for estate-scale residential development in a Minor Rural Settlement, contrary to the spatial
strategy of the RLDP.
The RLDP directs the majority of housing growth to sustainable locations — higher-order
settlements and service centres — where employment, services, public transport and
infrastructure are available. Minor Rural Settlements are not intended to accommodate estate
scale development; growth in such locations is expected to be very limited and typically
confined to local need or small-scale infill. Aberthin is not identified as a strategic growth
location and no specific local affordable housing need within the settlement has been
demonstrated.
This strategic approach is reflected in the housing distribution set out in BP9A. Figure 2 shows
that only 4.5% of total housing growth is directed to Minor Rural Settlements and Primary
Settlements outside the Strategic Growth Area. Applied to the Plan’s total housing provision of
8,660 dwellings, this equates to approximately 390 dwellings across all minor rural settlements
over the 15-year plan period. By contrast, the overwhelming majority of growth is directed to
larger settlements:
Settlement Category
Share of Housing
Primary settlements in Strategic Growth Area 40.5%
Service centres
26.4%
Key settlements
24.9%
This distribution demonstrates that minor rural settlements are not intended to play a
significant role in housing delivery, with growth instead concentrated in locations with stronger
services, infrastructure and sustainable transport connections.
Within this context, allocating HG4(2) Aberthin for approximately 25 dwellings would represent
a 14.2% expansion of the settlement in a single phase, introducing suburban-scale development
into a small rural village with very limited services and infrastructure. Although described as
“small-scale”, the assessment fails to consider proportionality: a 14% expansion of a minor rural
settlement cannot reasonably be regarded as small-scale development.
The allocation therefore represents a departure from the Plan’s spatial distribution strategy
rather than an implementation of it.

5.2 Consistency with Previous Plan Evidence
The site was previously assessed during preparation of the Vale of Glamorgan LDP 2011-2026
and rejected. The reason for rejection was clear: the site was considered unrelated to the
settlement and would represent unacceptable sporadic development in the countryside. This
reasoning remains valid.
The physical relationship between the site and the settlement has not changed. The field
remains a separate agricultural parcel outside the established built form of Aberthin. No new
infrastructure, services, or settlement expansion has occurred that would alter this relationship.
Allocating the same site in the absence of any material change in context raises serious
questions about the consistency and robustness of the site selection process.
5.3 Internal Inconsistency in the Council’s Own Assessment
The Council’s Candidate Site Assessment contains a clear internal inconsistency regarding the
status of Site 2299. At Stage 1 the site is described as “adjacent to a minor rural settlement”
(BP18A, p.14), which indicates that the land lies outside the settlement and forms part of the
open countryside. However, at Stage 2 the site is assessed on the basis that “a small-scale
affordable housing led development in a minor rural settlement would accord in principle with
the strategy” (BP18A, p.20).
These statements are incompatible. A site that is adjacent to a settlement is not within it. The
assessment therefore appears to assume that the settlement boundary will be extended to
incorporate the site, yet no explanation or evidence is provided to justify such a boundary
change. This raises serious concerns regarding the transparency and robustness of the site
selection process and suggests that the allocation may be site-led rather than plan-led.
5.4 Scale Does Not Resolve the Principal Conflict
The number of dwellings proposed does not resolve the fundamental policy conflict.
Even if the development were reduced in scale, the underlying issue would remain: the site
constitutes development in the countryside beyond a defensible settlement boundary and
represents estate-style expansion rather than small-scale infill.
5.5 Reliance Solely on Affordable Housing Justification
The Council’s own assessment makes clear that the only substantive justification for the site is
the potential delivery of affordable housing. No other strategic justification is provided.
Indeed, the assessment acknowledges that:
• Aberthin has limited services and facilities, and
• public transport provision is relatively infrequent.
The reliance solely on affordable housing as justification is problematic in principle. Affordable
housing provision cannot justify development in locations that conflict with the spatial strategy,
particularly where the overall housing requirement is already exceeded, the plan target for
affordable housing doubles the historic attainment and need for the LDP to contribute, and
alternative sustainable sites are available.
The detailed assessment of affordable housing need and delivery is addressed separately in
Section [6] of this representation.

6 Affordable Housing, Spatial Strategy, and Necessity: Why HG4(2) Is
Not Required
6.1 The RLDP Already Exceeds the Housing Requirement (and Explicitly Builds
in Flexibility)
A key test in allocating additional housing sites is whether they are necessary for the Plan to
deliver its housing requirement and strategy.
BP9A confirms a housing requirement of 7,890 dwellings and total housing provision of 8,660
dwellings, explicitly described as a 10% flexibility allowance:
• “The housing provision of 8,660 dwellings rounds to a 10% flexibility allowance…”
• “…it is considered that a 10% flexibility should be considered a maximum…”
This creates a surplus of 770 dwellings above the requirement (8,660 – 7,890), meaning the Plan
is not operating at the margin but already includes a substantial buffer.
Removal of HG4(2) Aberthin (25 dwellings) would leave provision at 8,635 dwellings, still
exceeding the requirement by 745 dwellings. Even removal of all HG4 rural affordable-led sites
(122 dwellings) would leave provision at 8,538 dwellings, still exceeding the requirement by 648
dwellings.
The Plan therefore retains a substantial flexibility margin without reliance on the HG4 rural sites.
These allocations are consequently discretionary additions rather than necessary components of
the housing strategy.
6.2 HG4 Rural Affordable-Led Sites Represent a Very Small Component of
Supply and are not Numerically Essential
BP9A identifies “Affordable housing led sites” (HG4) as a limited element of supply totalling 122
dwellings across four settlements (Colwinston 25, Aberthin 25, Wick 50, Fferm Goch 22).
This is 1.4% of total Plan provision.
HG4 rural affordable-led sites therefore represent a very small and numerically non-essential
component of supply. Numerically, the Plan is not dependent on these sites. As set out above,
even removing all HG4 sites, the Plan retains a surplus of 648 dwellings above the requirement.
This confirms that these allocations are not structurally required for housing delivery.
6.3 The 3,070 Affordable Homes Figure Represents Expected Delivery — Not
Demonstrated Need and HG4(2) is immaterial to delivery
A key point in interpreting the Plan’s affordable housing evidence is the meaning of the 3,070
figure referenced throughout the RLDP evidence base.
BP9A confirms that:
“the various sources of housing will contribute 3,070 affordable homes.”
This figure represents expected affordable housing delivery arising from the housing supply
identified in the Plan, including sites with planning permission, sites under construction, housing
allocations, windfalls and affordable-led sites. It is therefore derived from the overall housing
supply and assumed policy performance, rather than representing a quantified level of housing
need that must be met in full. In other words, 3,070 is a projection of delivery, not a measure of
need.
The actual level of demonstrated need is identified through the Local Housing Market
Assessment (LHMA). BP9A confirms that the LHMA identifies:
• 461 affordable homes per year, equating to
• 6,918 affordable homes over the 15-year plan period.
This distinction is critical.
Measure
Demonstrated affordable housing need (LHMA)
Number
6,918 homes
Affordable housing expected to be delivered by the RLDP 3,070 homes
The Plan therefore anticipates delivering less than half of the identified affordable housing need
through the planning system. This is not unusual, as delivery through planning mechanisms is
constrained by factors such as development viability, housing delivery rates, reliance on market
schemes to generate affordable units, and the availability of subsidy and Registered Social
Landlord funding.
However, this distinction is fundamental when considering the necessity of individual
allocations. Because the 3,070 figure represents expected delivery arising from the overall
housing supply, it is not a target that must be achieved through allocating specific individual
sites. The inclusion or exclusion of a small site therefore does not materially affect the Plan’s
affordable housing strategy.
This is particularly clear in the case of HG4(2) Aberthin. BP9A indicates that affordable housing
led sites are expected to deliver at least 50% affordable housing, meaning HG4(2) would provide
approximately:
• 13 affordable homes from 25 dwellings,
with 62 affordable homes across all HG4 rural affordable-led sites combined.
The numerical impact of removing the Aberthin site is therefore extremely small:
• Removing HG4(2) Aberthin reduces affordable delivery from 3,070 to approximately
3,057 homes (0.42% reduction).
• Removing all HG4 rural affordable-led sites reduces delivery from 3,070 to
approximately 3,008 homes (2.02% reduction).
BP18A states that “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.” However, a contribution of 0.42% from the Aberthin site cannot
reasonably be described as important and is numerically negligible.
Accordingly, the Plan is not materially dependent on HG4(2) Aberthin to meet its affordable
housing delivery expectations. The loss of the site would not undermine the Plan’s affordable
housing strategy or prevent the RLDP from delivering the level of affordable housing the Council
expects to arise from the housing supply.
The evidence therefore demonstrates that HG4(2) Aberthin is not necessary for the Plan to
achieve its projected affordable housing delivery.
6.4 Affordable Housing Delivery Framework
Affordable housing delivery in Wales is not solely dependent on allocations or planning
obligations secured through the Local Development Plan (LDP). Welsh Government statistics
show that affordable housing is delivered through a range of mechanisms, including Welsh
Government capital grant programmes, housing association development and direct local
authority provision.
In 2024–2025, 3,643 additional affordable homes were delivered across Wales. Of these, 882
homes (approximately 24%) were delivered through planning obligations linked to market
housing developments, while around 76% were delivered through other routes, primarily grant
funded programmes and delivery by Registered Social Landlords and local authorities. This
demonstrates that the planning system represents one component of the wider affordable
housing delivery framework, rather than the principal delivery mechanism.
Within the Vale of Glamorgan, monitoring reports indicate that 2,398 affordable homes were
delivered between 2011 and 2025 under the current LDP period. Recent statistics also show 147
local authority homes delivered in 2024–2025, demonstrating that council-led delivery
programmes continue to contribute alongside housing association development.
The RLDP evidence suggests that approximately half of identified affordable housing need may
be delivered through planning mechanisms associated with housing allocations. When
compared with national delivery patterns — where planning obligations account for around 24%
of affordable housing provision — this represents approximately double the typical contribution
delivered through planning mechanisms.
The available evidence therefore indicates that the RLDP is already expected to make an
unusually high contribution to affordable housing delivery through planning mechanisms alone.
Given national delivery patterns and the Vale’s historic delivery record, it is reasonable to expect
that a proportion of affordable housing supply during the plan period will continue to arise
through other established mechanisms operating alongside the LDP, including Welsh
Government grant programmes, housing association development and local authority housing
delivery.
The evidence therefore indicates that the Local Development Plan should be understood as one
delivery mechanism within a wider system, rather than the principal mechanism through which
affordable housing need is expected to be met.
6.4.1 Implications for Site Allocation
In this context, the justification for allocating additional sites primarily to support affordable
housing delivery becomes less clear. If the RLDP already assumes a level of provision through
planning mechanisms that doubles typical national delivery patterns, further allocations risk
over-provision relative to what is required to support the plan strategy, raising a potential
question of plan soundness.
This is particularly relevant where proposed sites are rural or environmentally sensitive
locations, or where development may introduce landscape, infrastructure or environmental
impacts affecting the rural character that defines much of the Vale of Glamorgan.
The evidence therefore suggests that the necessity for additional site allocations should be
clearly demonstrated, particularly where affordable housing delivery may reasonably be
expected to arise through the wider delivery framework operating alongside the planning
system.
6.5 The Evidence Base Identifies the Greatest Affordable Need in Larger
Settlements
The LHMA evidence summarised in the RLDP identifies that the greatest affordable housing
need is in:
• Barry
• Penarth / Llandough
• Llantwit Major
• Dinas Powys
• Rhoose
The Plan’s spatial strategy directs the overwhelming majority of growth to these areas and
settlement categories: Key Settlements, Service Centres and Primary Settlements in the
Strategic Growth area. This alignment between identified housing need and the spatial
distribution of growth is a central principle of the Plan’s strategy.
By contrast, Minor Rural Settlements such as Aberthin are not identified as primary locations for
addressing affordable housing need, and the evidence base does not demonstrate a specific
local need within the settlement itself. In this context, allocating a greenfield affordable housing
site in Aberthin appears inconsistent with the evidence base.
6.6 The Council’s “Local Need and Support for Services” Justification Requires
Evidence
The Plan suggests that rural affordable housing allocations are intended to:
• respond to local affordable housing needs, and
• support local services and facilities.
However, the evidence presented within BP9A does not demonstrate:
• there is any affordable housing need locally within Aberthin,
• What services exist that can be supported by extra residents
The justification for HG4 rural affordable housing sites relies on two related propositions: that
they respond to locally arising affordable housing need and that they support the sustainability
of rural communities by helping to maintain local services and facilities. However, the evidence
base does not demonstrate a specific affordable housing need within Aberthin itself (only the
ward of Cowbridge). Nor does the settlement contain a range of services that would realistically
be sustained by a development of this scale. In these circumstances, the policy rationale
underpinning the allocation appears weak. PPW and TAN 6 expects rural affordable housing to
be genuinely locally justified.
6.7 Development Within the Wider Corridor
Housing development has taken place across the Cowbridge–Aberthin–Ystradowen corridor in
recent years. Within Aberthin itself, approximately 20 dwellings were completed around 2017
2018, including affordable homes. The redevelopment of the former Cowbridge school site
between Aberthin and Cowbridge is currently under construction and will deliver approximately
34 affordable homes.
Further housing has been delivered in nearby settlements, including Maple Walk in Ystradowen
(46 homes), with expansion in the RLDP, the former police station site in Cowbridge (14), and
Clare Garden Village (475), with further expansion. Collectively, these developments
demonstrate that housing supply, including significant levels of affordable housing, is already
being delivered within the surrounding area and the corridor may already be at saturation point.
6.8 Overall Conclusion
The evidence demonstrates that the allocation of HG4(2) Aberthin is not necessary for the RLDP
to deliver either its housing requirement or its projected affordable housing outcomes.
Even if HG4(2) Aberthin were removed, the Plan would still exceed its housing requirement by
745 dwellings, and even if all HG4 rural affordable-led sites were removed the surplus would
remain 648 dwellings. These allocations are therefore not required to maintain an appropriate
housing supply or flexibility allowance.
HG4(2) Aberthin itself is expected to deliver approximately 13 affordable homes, reducing
projected affordable housing delivery by only 0.42% if removed. Even removing all HG4 rural
affordable-led sites would reduce projected delivery by only 2.02%. The Plan is therefore not
materially dependent on these sites to achieve its affordable housing outcomes.
National evidence also demonstrates that affordable housing delivery in Wales arises through
multiple mechanisms operating alongside the planning system. The RLDP assumption that
around 50% of affordable housing need will be delivered through planning mechanisms
represents a doubling of the typical contribution made through the planning system.
Extensive corridor development of housing supply and affordable is already taking place and
may have already saturated this corridor.
No clear evidence has been presented demonstrating a specific local affordable housing need
within the settlement.

7 Flood risk, surface water, ground water, drainage, and methodological
concerns
7.1 TAN 15 Section 10.22 – Highly Vulnerable Development on Greenfield
Land in Flood Zone 3
BP21A (p.15) states:
“For a proposed development site within Flood Zones 3 of the Flood Map for Planning for Rivers,
Section 10.22 of TAN-15 states that highly vulnerable development on greenfield land is not
permitted. Section 10.23 of TAN-15 states that other development proposals are acceptable if
they are essential to the LDP.”
This is the primary policy test.
• Residential development = highly vulnerable development.
• The site is greenfield land.
• The southern part of the site lies within Flood Zone 3.
• TAN 15 states highly vulnerable development on greenfield land in Flood Zone 3 is not
permitted.
The only potential exception pathway is if the development is “essential to the LDP.”
This site is not essential:
• The housing trajectory demonstrates over delivery.
• Strategic sites are already allocated and viability tested.
• Minor rural settlements are not required to meet housing numbers.
• Affordable housing delivery is already occurring in service centres along this corridor
and through other delivery vehicles
• No need established in Aberthin
Accordingly, the allocation conflicts directly with TAN 15 Section 10.22.
7.2 Welsh Government Notification Direction – Escalation to Ministers
BP21A (p.15) states:
“It is recognised that the Welsh Government notification direction requires applications for
Highly Vulnerable Development where the whole or part of the site is within Flood Zone 3 on a
Greenfield site to be referred to the Welsh Ministers. Any development proposals for this site
which include residential use are therefore likely to be required to be notified to the Welsh
Government.”
This confirms:
• The seriousness of the constraint.
• That residential development here triggers Ministerial scrutiny.
• That the proposal is not routine.
It is unclear whether this allocation has been formally notified to Welsh Government at plan
stage. Allocation without clarity on Ministerial position introduces further procedural and
soundness risk.
7.3 SuDS Basin – Location Discrepancy and Flood Zone 3 Conflict
BP21A (p.16) states:
“Residential units located entirely within Flood Zone 1. A proposed SuDS detention basin is
located to the south of the site and is within Flood Zone 2.
As per the advice of the CIRIA SuDS Manual, SuDS should not be located within an area at a
greater than 1% AEP chance of flooding, which aligns to Flood Zone 3.”
However:
• Vale of Glamorgan planning constraints mapping indicates the basin location falls wholly
within Flood Zone 3.
If the basin is within Flood Zone 3:
• This conflicts with CIRIA guidance.
• Basin storage may be compromised during fluvial events.
• Coincident pluvial + fluvial events reduce attenuation capacity.
• Exceedance flows could affect:
o Site access (within Flood Zone 3),
o The public right of way,
o Existing properties at Maes Lloi.
No combined-event modelling outputs have been published.
7.3.1 Mapping overlay showing SUDs basin entirely in Flood Zone 3
Flood Zone
3
Flood Zone
3
7.4 Drainage, SuDS Feasibility and Groundwater Constraints
The hydrogeological and flood characteristics of the area raise significant doubt as to whether
an effective Sustainable Drainage System (SuDS) could be implemented on the site without
creating additional flood or environmental risk.
Aberthin lies within a valley setting where several interacting flood mechanisms operate. Much
of the village lies within Flood Zone 3, with surrounding areas within Flood Zone 2, reflecting
fluvial flood risk associated with the Nant Aberthin, which ultimately joins the River Thaw. In
addition to fluvial flooding, the area is susceptible to surface water runoff due to the steep
topography of surrounding higher ground, including Pen-y-Lan Road and the Stalling Down
plateau, which generate rapid runoff during intense rainfall events that drain towards the valley
floor where the village and the proposed site are located.
Groundwater conditions present a further constraint. The valley floor surrounding Aberthin is
identified by the British Geological Survey as having high susceptibility to groundwater flooding.
The site lies above Carboniferous Limestone classified as a Principal Aquifer, overlain by
permeable gravels and alluvial deposits associated with the Nant Aberthin valley. These
geological conditions can produce a rapidly responding (“flashy”) groundwater table in which
groundwater levels rise quickly following rainfall and may emerge at the surface or remain very
shallow. Interaction between river levels and groundwater within the alluvial deposits can
further exacerbate this effect, with elevated river levels capable of forcing groundwater upward
into adjacent low-lying land.
These conditions create a challenging environment for SuDS design. Welsh SuDS standards
require infiltration to be demonstrated as suitable for local ground conditions and to assess its
effects on groundwater levels. Where groundwater is shallow or highly responsive to rainfall,
infiltration techniques such as soakaways or infiltration basins may become ineffective or may
worsen groundwater emergence and flooding. Introducing additional infiltration in a valley floor
already prone to groundwater rise could therefore increase the risk of groundwater flooding in
surrounding parts of the village.
Even if infiltration techniques were unsuitable and an attenuation-based system were proposed,
significant uncertainty would remain. Such systems require sufficient space for attenuation
features, exceedance routing and safe discharge to a receiving watercourse. In this case, the site
is constrained by landscape sensitivity, established hedgerows, a public right of way, and its
position at the base of surrounding slopes where runoff naturally accumulates, raising doubt as
to whether a compliant SuDS solution could be delivered without substantial engineering
intervention.
There are also potential implications for Cors Aberthin SSSI, which lies within the same
hydrological valley system. Wetland habitats are typically highly sensitive to changes in
hydrology, groundwater levels and water quality, and development that alters surface water
pathways, increases runoff or modifies groundwater recharge patterns could affect the
hydrological conditions supporting the wetland ecosystem.
Together this creates significant uncertainty regarding whether a SuDS solution could be both
effective and environmentally acceptable. In the absence of detailed hydrogeological
investigation, seasonal groundwater monitoring and robust drainage modelling demonstrating
no increase in flood risk or ecological harm, the assumption that drainage issues can be
satisfactorily resolved remains unproven. This uncertainty raises further concerns regarding the
deliverability and environmental suitability of the allocation.
7.5 Absence of a Detailed Hydraulic Model – Nant Aberthin
BP21A (p.12) states:
“The southern extent of the Site is partially located within Flood Zones 2 and 3… No detailed
model is available of the Nant Aberthin.”
This is critical.
• There is no detailed hydraulic model of the Nant Aberthin.
• Flood extents are therefore based on national-scale modelling.
• No localised calibration or site-specific modelling has been published.
• Flood depth, velocity and hazard classification are not robustly evidenced.
Allocation of highly vulnerable development without a detailed fluvial model is precautionary
risk deficient.
7.6 Absence of Allocation-Stage FCA
The assessment documented in BP21a for site 2299 was undertaken by JBA Consulting. They
note the assessment was purely desk-based, taking information provided by others with no
verification.
BP21A (p.17) states:
“Any planning application for the Site should be accompanied by an FCA which demonstrates
how the proposals meet the requirements of TAN-15.”
This confirms:
• An FCA is required.
• It has not yet been undertaken.
• It is deferred to application stage.
However, TAN 15 requires flood consequences to be demonstrated as acceptable.
Allocation of highly vulnerable development in Flood Zone 3 without an FCA at plan stage
means:
• Flood consequences have not been demonstrated.
• Mitigation feasibility has not been proven.
• Deliverability is uncertain.
7.7 TAN 15 Section 10.18 – Flood Zone 2 Justification Pathway Not Engaged
BP21A (p.15) states:
“Section 10.18 of TAN-15 states that it is possible to allocate sites within Flood Zone 2 where the
proposals assist the implementation of the strategy of the LDP to regenerate or revitalise
existing settlements or to achieve key economic or environmental objectives.”
However:
• The site is not within the established settlement form.
• It was previously rejected as unrelated countryside.
• It does not regenerate the settlement.
• It does not achieve a key economic objective.
• It does not achieve a key environmental objective.
The Section 10.18 justification pathway does not apply.
7.8 Surface Water Risk – “Minimal” Assertion vs Mapping Evidence
BP21A states:
“Surface water and small watercourse flood risk is minimal across the site…”
However:
• Vale planning constraints mapping identifies intermediate surface water risk across
approximately half of the site.
• The site slopes from north to south toward Maes Lloi.
• Proposed dwellings fall within areas of intermediate surface water flood risk.
• Proposed dwellings are in an area of historical flooding (DEVELOPMENT ADVICE MAP
Zone B)
• No surface water modelling outputs are published.
• No velocity modelling.
• No exceedance routing plan.
• No no-worsening assessment.
Surface water risk has not been robustly evidenced at allocation stage.
7.9 Mapping shows majority of proposed houses located in risk areas
The following mapping overlays show that 16 of the 25 houses are in areas of either surface
water risk or have experienced historical flooding
7.9.1 Map overlay showing houses in risk areas for surface water
Surface risk
intermediate
Surface risk
intermediate
Surface risk
less
Surface risk
less
7.9.2 Map overlay showing houses in historical flooding area (DEVELOPMENT ADVICE MAP
Zone B)
Historical
flooding
Historical
flooding
7.10 Groundwater – “Red – High” and 12-Month Monitoring Requirement
The site is classified “Red – Hhigh – groundwater likely to be at or near the surface” meaning:
Groundwater levels are either at or very near (within 0.025m of) the ground surface.
BP21A recommends groundwater monitoring over a 12-month period to capture seasonal
variation.
There is no evidence that:
• 12 months monitoring has been undertaken.
• Basin performance takes account of high groundwater.
• Infiltration feasibility has been proven.
• Climate change allowances have been applied to groundwater conditions.
Allocation prior to completion of recommended monitoring is evidentially premature.
7.11 Topography and Potential Runoff Toward Existing At-Risk Properties
The site slopes from north to south toward Maes Lloi.
• Existing properties at Maes Lloi are largely within Flood Zone 3.
• Residents have noted drainage overload during wet periods.
• There is no evidence published that assesses whether the proposed development would
not worsen existing flood risks to surrounding properties
• No quantified runoff comparison between greenfield and developed sites is provided.
• No exceedance flow mapping is published.
Downstream impact risk has not been robustly assessed.
7.12 Failure to Apply Council Methodology
BP21A (p.13) states:
“the approach adopted by the Council within its assessment methodology was for flood risk to
be given the strongest possible weighting… sites identified to fall within areas of flood risk were
discounted from further consideration.”
This is unequivocal.
However, this site:
• Lies partially within Flood Zone 3.
• Has mapped intermediate surface water risk.
• Has groundwater classified “Red – High.”
• Has access within Flood Zone 3.
• Has a history of flooding (DEVELOPMENT ADVICE MAP Zone B)
• Requires Ministerial notification.
• Requires FCA and groundwater monitoring.
• Requires SUDs viability assessment
• Requires SSSI/ecology assessment
This represents a clear departure from the Council’s own stated methodology.
BP16 (p.20) states:
“Sites located within Zone 2 will only be considered where: It will assist, or be part of, a strategy
supported by the Development Plan to regenerate an existing settlement or achieve key
economic or environmental objectives or address national security or energy needs; AND • Its
location meets the definition of a brownfield site, And • Is supported by a FCA that indicates
that the potential consequences of a flooding event for the development proposed is found to
be acceptable in accordance with the criteria contained in section 11 of TAN 15 (2021).
Sites located within Zone 3 will only be considered where: • The development is required under
exceptional circumstances, as defined in TAN e.g. addressing national security or energy security
needs, reasons of public health or to mitigate the impacts of climate change, AND • Its location
meets the definition of a brownfield site, And • Is supported by a FCA that indicates that the
potential consequences of a flooding event for the development proposed is found to be
acceptable in accordance with the criteria contained in section 11 of TAN 15 (2021).”
This site is within Flood zones 2 and 3, is not brownfield, has no FCA, meets none of the
conditions in section 11, TAN 15 and is not required for exceptional circumstances.
The council do not appear to have followed any of these elements of methodology with regard
to flood risk.
7.13 Soundness Consequences
The allocation:
• Conflicts with TAN 15 Section 10.22.
• Does not meet Section 10.18 justification.
• Requires Welsh Government notification.
• Proceeds without any hydraulic model.
• Proceeds without FCA.
• Proceeds without groundwater monitoring.
• No-worsening test absent
• No SUDs viability assessment
• Contains mapping discrepancies.
• Defers critical evidence to application stage.
Accordingly, the allocation fails the soundness tests because it is:
• Not Justified – not based on robust, proportionate evidence.
• Not Effective – deliverability dependent on unresolved flood constraints.
• Not Consistent with national policy – specifically TAN 15 restrictions.

8 Infrastructure Constraints
8.1 Access Considerations
Indicative plans suggest that access to the proposed development may be provided from the
A4222 on the northern side of Aberthin. This would introduce an additional junction onto a
section of road that already contains numerous access points and turning movements. Given the
existing road layout and traffic conditions, the introduction of a further access point warrants
careful consideration in relation to highway safety.
The existing southern access route also presents constraints. It lies within Flood Zone 3, is
restricted in width, and cannot accommodate emergency vehicles safely. Flood events could
potentially affect access and egress, which may have implications for both existing and future
residents.
8.2 Existing Road Environment
The A4222 Maendy Road, which connects Cowbridge and Ystradowen through Aberthin, already
carries significant traffic volumes, including heavy goods vehicles. The road environment
includes several features that influence traffic movement and safety, including:
• a 90-degree bend over a bridge
• multiple side road junctions
• pub car park exits and private driveways accessing the road
• limited footpath provision and crossing points
• areas of reduced street lighting
These characteristics mean that drivers already navigate a relatively complex road environment
through the village.
Historic planning decisions also indicate sensitivity around access to this road. In 1978, South
Glamorgan County Council required the closure of the access from Skaife House onto the A4222
(Directly opposite the proposed new entrance), as part of planning consent for development at
The Spinney, Downs View Close, reflecting previous concerns regarding additional junctions
along this section of road (at a time with far less traffic).
8.3 8.3 Strategic Transport Policy Context
The RLDP is supported by BP14 – Strategic Transport Assessment Stage 1, which emphasises the
importance of locating development where sustainable travel options are available and where
the need to travel can be reduced. The assessment highlights the role of planning policy in
encouraging modal shift toward walking, cycling and public transport.
The Strategic Transport Assessment Stage 2 (BP14a) identifies capacity pressures within parts of
the local network. In particular, the Aberthin Road / Cardiff Road / St Athan Road / Eastgate
junction is recorded as operating beyond theoretical capacity during the AM peak period. This
indicates that parts of the local highway network already experience congestion during peak
travel times.
8.4 Car Dependency and Sustainable Transport
The Strategic Transport Assessment highlights that the Vale of Glamorgan has relatively high
levels of car ownership, with 83.4% of households owning one or more vehicles. In smaller rural
settlements such as Aberthin, limited public transport and no active travel infrastructure mean
that residents are likely to rely heavily on private vehicles.
The Vale’s active travel network is described within the transport evidence as limited and
fragmented in certain areas. Aberthin currently has:
• no designated Active Travel routes
• no proposed routes within the Active Travel Network Maps
• limited safe walking or cycling connections to nearby settlements such as Cowbridge
and Ystradowen, with narrow or missing footpaths and poorly lit sections.
An Active Travel scheme went through consultation but met with multiple objections. Some of
these are relevant to LDP planning elements, such as:
o The high volume and speed of traffic on the existing highways, predominantly the A4222
that runs directly through Aberthin
o A lack of segregated infrastructure in the area, which would force cyclists to share space
with cars in narrow sections.
o The lack of street lighting in the area, which made the route unappealing for use at night
or during winter.
o Concerns regarding installing lighting due to wildlife disruption
The project has been on hold for 3 years.
Public transport provision is also limited, with bus services operating approximately hourly,
ending in the early evening at 7.30, with no Sunday services. These factors may influence travel
patterns and increase reliance on private vehicles.
8.5 Cumulative Transport Considerations
As discussed earlier, extensive development has occurred and is still ongoing in the Cowbridge
Aberthin–Ystradowen corridor. These settlements are largely connected by the A4222 corridor,
which functions as the principal route linking the surrounding communities. The route already
accommodates traffic associated with existing settlements and recent development.
In this context, the cumulative impact of additional development along the corridor raises
considerations regarding traffic growth, junction capacity, road safety and infrastructure
demand. These factors may warrant careful evaluation when assessing additional rural
allocations, particularly where the transport evidence indicates existing pressures within parts of
the network.
8.6 Policy Considerations
Based on the transport evidence and local context outlined above, several policy considerations
arise.
8.6.1 Conflict with sustainable transport objectives
The Strategic Transport Assessment supporting the RLDP (BP14 and BP14a) emphasises the
importance of locating development where sustainable transport options are available and
where reliance on private vehicles can be reduced.
8.6.2 Infrastructure capacity and network pressures
Transport evidence identifies existing pressures within parts of the local highway network,
including peak-period congestion at key junctions serving the area. When considered alongside
recent and ongoing development within the Cowbridge–Aberthin corridor, the potential
cumulative effect of additional traffic generation may require further assessment to ensure that
local infrastructure can accommodate additional demand.
8.6.3 Consistency with the RLDP spatial strategy
Planning Policy Wales and the RLDP strategy emphasises directing development toward
locations with stronger accessibility to services, facilities and sustainable transport networks. As
a small rural settlement with limited transport connectivity, the role of Aberthin within this
spatial strategy may require careful consideration when assessing the suitability of additional
housing allocations.
8.7 Education capacity
The Council’s education evidence (BP43 Education) confirms that secondary education provision
serving the Cowbridge area is already under pressure.
Appendix F of BP43 identifies that Cowbridge Comprehensive School will require an additional
177 places to accommodate projected demand generated by RLDP growth.
BP43 uses the following pupil yield formula:
• Primary: Dwellings × 0.278
• Secondary: Dwellings × 0.208
Applying this to a development of 20–30 dwellings at Aberthin would generate approximately:
• 6–8 primary pupils
• 5–6 secondary pupils
• approximately 1 Additional Learning Needs (ALN) pupil
BP43 also confirms that ALN provision across the authority is already under pressure.
The Aberthin allocation therefore adds additional pupil demand to an already constrained
education system.
Given that the RLDP already provides 8,660 dwellings against a requirement of 7,890 (a surplus
of 770 dwellings) and affordable housing delivery is already secured through larger strategic
allocations, the additional education demand created by HG4(2) Aberthin is unnecessary for the
delivery of the Plan’s housing strategy.
9 Landscape, Settlement Edge, Hedgerow Protection, Public Right of
Way, Conservation Area and Nearby SSSI
9.1 Landscape and heritage setting sensitivity
The proposed allocation HG4(2) – Land West of Maendy Road, Aberthin lies wholly within a
Special Landscape Area (SLA) designated by Vale of Glamorgan Council. Special Landscape Areas
identify landscapes of locally significant character and visual quality, and planning policy
requires development within such areas to conserve and enhance landscape character and
avoid unnecessary harm to valued landscapes.
The site comprises open agricultural land immediately west of Aberthin, forming part of the
rural valley landscape associated with the Nant Aberthin corridor and contributing to the wider
countryside setting of the village and surrounding landscape extending toward Cowbridge.
Key landscape characteristics include:
• open pastoral farmland typical of the Vale of Glamorgan landscape
• strong hedgerow field boundaries reflecting historic field patterns
• visual connection with the Nant Aberthin valley landscape
• a continuous mature hedgerow along the western boundary running north–south
This hedgerow forms a defining landscape feature, contributing both to the historic field
structure of the landscape and to ecological connectivity.
The existing development along Maendy Road forms a clear and well-defined rural settlement
edge to Aberthin. The proposed site lies beyond this edge and currently reads as open
countryside rather than part of the village. Development of approximately 25 dwellings would
extend the built form westwards into open farmland, resulting in:
• encroachment of residential development into countryside
• erosion of the clear distinction between settlement and rural landscape
• urbanisation of the existing rural settlement edge.
These changes would be particularly sensitive given the site’s location within a Special
Landscape Area.
The site also forms part of the wider setting of the Aberthin Conservation Area, which protects
the historic character and appearance of the village under the Planning (Listed Buildings and
Conservation Areas) Act 1990. Aberthin is characterised by traditional stone cottages, a compact
historic form and a strong relationship with the surrounding countryside. The open farmland
west of the village contributes to this rural setting and historic landscape context. Development
of the site would extend the built form into land that currently forms part of that setting,
potentially altering the way the historic settlement is experienced within the surrounding
landscape.
The site is also located close to Cors Aberthin SSSI, a designated Site of Special Scientific Interest
recognised for its wetland habitats and ecological importance within the Nant Aberthin valley
system. SSSIs are protected under the Wildlife and Countryside Act 1981, and planning policy
requires that development should avoid Development Advice Mapage to their special scientific
interest and associated ecological systems.
The proximity of the allocation to Cors Aberthin SSSI reinforces the environmental sensitivity of
the wider landscape, particularly in relation to:
• hydrology and water movement within the valley
• ecological connectivity through the Nant Aberthin corridor
• protection of surrounding habitats that contribute to the ecological functioning of the
SSSI.
9.2 Significance and protection of the boundary hedgerow
The continuous hedgerow running along the western boundary of the site is likely to be of
considerable ecological, historic and landscape value.
Hedgerows of this type in the Vale countryside commonly:
• form part of historic field boundaries
• provide habitat corridors for birds, bats and small mammals
• contribute significantly to the traditional landscape character of the Vale of Glamorgan
Such hedgerows may qualify as “Important Hedgerows” under the Hedgerows Regulations 1997.
Where a hedgerow meets the criteria set out in these Regulations:
• removal requires formal consent from the local authority, and
• if the hedgerow is classified as important, consent for removal must normally be
refused.
Removal of an important hedgerow without permission constitutes a criminal offence.
Given the continuous north–south structure of the boundary hedgerow and its role in the
historic field pattern, there is a realistic possibility that the hedgerow would meet the criteria for
protection.

9.3 Public Right of Way and proposed realignment
A Public Right of Way (PRoW) currently crosses the site through open agricultural land, forming
part of the rural footpath network around Aberthin. In its current form the route is experienced
as a traditional countryside path, crossing open farmland with clear visibility and an open rural
character.
However, the indicative layout associated with the allocation appears to show the path diverted
along the western boundary of the site, coinciding with the existing hedgerow. The proposed
layout indicates:
• rear residential gardens backing onto the path
• tree planting along the boundary
• the route positioned between housing plots and boundary vegetation.
9.3.1 Loss of rural character and safety concerns
This realignment would fundamentally alter the character of the route. Instead of crossing open
countryside, the diverted path would form a long, narrow corridor along the edge of the
development. The path would therefore be experienced as a confined passage rather than an
open countryside route, raising concerns regarding:
• loss of the rural character of the right of way
• reduced visibility and openness
• personal safety for walkers.
The arrangement would effectively create a long-enclosed route resembling an alleyway,
particularly where gardens back directly onto the path. These concerns are amplified by the
likelihood that the route would remain unlit, as public rights of way across rural land are rarely
provided with lighting, particularly within Special Landscape Areas where lighting may conflict
with policies protecting rural character and dark skies.
The resulting route would therefore be a long, narrow and potentially unlit corridor, raising
further safety and amenity concerns.
Length of enclosed
alleyway
9.3.2 Legal implications of diversion
Any diversion of a Public Right of Way requires a legal order under the Highways Act 1980.
To be confirmed, such an order must demonstrate that:
• the diversion is necessary to enable the development, and
• the alternative route is not substantially less convenient or less enjoyable for the public.
Replacing a path that currently crosses open countryside with a route running along the edge of
housing development may therefore attract objections from users, residents or rights-of-way
groups, potentially preventing confirmation of the diversion order.
9.4 Interaction between the path diversion and hedgerow removal
The proposed diversion appears to coincide directly with the existing boundary hedgerow,
suggesting that the development may require removal or substantial alteration of this hedgerow
in order to accommodate the path and housing layout.
If the hedgerow qualifies as an Important Hedgerow under the Hedgerows Regulations 1997, its
removal may be legally restricted or refused, creating uncertainty regarding whether the layout
assumed by the allocation could be implemented.
9.5 Implications for site deliverability
The allocation therefore appears to depend upon:
• diversion of an existing Public Right of Way,
• possible removal or alteration of a potentially protected hedgerow, and
• development within an SLA and sensitive landscape setting closely associated with the
Cors Aberthin SSSI and Nant Aberthin ecological corridor.
Each of these matters involves separate legal and environmental considerations, none of which
can be assumed to be achievable at the plan allocation stage.
If the diversion were refused, or if removal of the hedgerow were not permitted, the layout
assumed by the allocation may not be achievable in practice.
9.6 Conclusion
The allocation of HG4(2) would introduce residential development into open countryside within
a designated Special Landscape Area, extending the settlement edge of Aberthin into land that
currently contributes to the village’s rural setting and the wider setting of the Aberthin
Conservation Area.
The site contains a continuous boundary hedgerow likely to be of significant landscape and
ecological value, which may qualify for protection under the Hedgerows Regulations 1997.
The indicative layout also proposes diverting an existing Public Right of Way from its current
route across open farmland to a narrow boundary corridor running between residential gardens
and boundary planting, fundamentally altering the character of the route and raising safety and
amenity concerns, particularly as the path would likely remain unlit.
The site also lies close to Cors Aberthin SSSI, further highlighting the environmental sensitivity of
the surrounding landscape.
Taken together, these factors raise serious concerns regarding landscape impact, heritage
setting, environmental sensitivity, legal constraints and the practical deliverability of the
allocation, particularly given that the Plan already provides sufficient housing supply without
reliance on development of this sensitive site.

10 Plan Soundness and potential Misapplication of Policy HG4
10.1 Affordable Housing Exception Policy Must Operate Within National Policy
Policy HG4 allows for small-scale affordable housing-led development in Minor Rural
Settlements, reflecting the Welsh Government policy approach to rural exception sites.
However, such policies are intended to operate within the framework of the Plan’s spatial
strategy, not to override it.
Affordable housing exception mechanisms are designed to allow limited, carefully justified
departures from the normal settlement boundary approach where local need is demonstrated
and cannot otherwise be met. They are not intended to provide a general mechanism for
allocating greenfield housing sites in rural settlements.
The allocation of Site 2299 appears to rely on HG4 as the primary justification for development,
rather than demonstrating that the site aligns with the broader spatial strategy and site
selection methodology of the Plan.
PPW (12) allows rural affordable housing through exception mechanisms, but only where
certain conditions are met.
• small-scale
• genuinely local need (not demonstrated in Aberthin)
• proportionate to settlement size (2299 is disproportionate estate scale development)
• does not undermine settlement strategy (outside strategic growth and sustainable
areas)
Development Plans Manual (Edition 3) states that site allocations should:
• flow from the spatial strategy
• follow the site search sequence
• be supported by a transparent assessment process
In other words:
Strategy → site selection → allocation
In the case of site 2299 the order appears reversed:
Site promoted → affordable housing justification → boundary expanded → allocation.
That is the type of site-led planning the manual warns against.
10.2 HG4 Overrides the Plan-Led Site Selection Process
The evidence in the Candidate Site Assessment indicates that the site has been taken forward
solely on the basis that it could deliver affordable housing and there is no indication that the
assessment methodology has been carried out
This approach effectively allows HG4 to override the wider plan-making framework, including:
• the settlement hierarchy,
• the spatial distribution of housing growth,
• the requirement to prioritise sustainable locations, and
• the established methodology for identifying appropriate development sites.
This creates a policy loophole whereby any countryside site adjacent to a minor rural settlement
could potentially be justified simply by proposing affordable housing. This risk appears to have
been realised. HG1, 3 and 4 were all rejected according to the assessment methodology but
resubmitted as affordable led upon guidance: “but the site could be reconsidered as a small
scale affordable housing led development”.
HG4(2) Aberthin was previously rejected in the 2011-2026 LDP then crucially did not go through
the normal assessment process but went straight to allocation as affordable-led. This creates a
precedent for any candidate site, including those previously rejected to be submitted as
affordable-led and potentially be allocated without robust assessment.
Such an approach undermines the plan-led system and the spatial strategy on which the RLDP is
based.
10.3 Lack of Evidence That the Site Is Necessary to Deliver Affordable Housing
The justification for the site relies on reference to the Local Housing Market Assessment
(LHMA), which identifies a need for additional affordable housing within the relevant ward of
Cowbridge.
However, the existence of an identified need does not in itself justify the allocation of specific
countryside sites.
The RLDP must demonstrate that:
1. the affordable housing requirement cannot be met within the overall housing supply,
and
2. the proposed site represents the most appropriate and sustainable location to
contribute to meeting that need.
Neither has been demonstrated.
As previously discussed, the RLDP already provides a significant surplus of housing provision
over the housing requirement, including substantial capacity within more sustainable
settlements.
In these circumstances, the allocation of a countryside site solely on the basis of affordable
housing provision i.e. HG4 exception, is not justified.
10.4 Soundness Implications
For a Local Development Plan to be sound it must be:
• Justified – based on a robust and credible evidence base and the most appropriate
strategy.
• Consistent with national policy.
• Effective and deliverable.
The reliance on Policy HG4 as the primary justification for Site 2299 raises concerns in respect of
all three tests.
In particular:
• Justified: The evidence base does not demonstrate that the site is necessary to deliver
the Plan’s housing or affordable housing objectives, or that there is any evidenced need
in Aberthin
• Consistent with National policy: The allocation does not appear to arise from a
consistent application of the spatial strategy or site selection methodology and does not
take account of flood risks in accordance with policy. The approach risks undermining
the plan-led system by allowing countryside sites to be allocated solely on the basis of
affordable housing provision.
• Effective and Deliverable: The number of constraints lack mitigation evidence, e.g. no
FCA, SUDs assessment, overall site viability assessment and other missing assessments,
the limited infrastructure of the area is not mitigated, and only summary financial
viability is provided, and this has discrepancies
For these reasons, the allocation of Site 2299 using HG4 cannot be considered justified or sound.

11 Conflicts with methodology, shifts, audit trail concerns and gaps
11.1 Candidate Site Assessment Methodology (BP16)
11.1.1 Site Assessment Criteria Outcomes
Site 2299 has been assessed against 35 criteria within the candidate site assessment framework.
Of these, 12 criteria are recorded as green (no identified constraints to development). Four
criteria are marked as red, which represent the most significant level of concern, typically
indicating a major constraint to development, potential conflict with national policy, or
insufficient information to support the assessment.
A review of the scoring suggests that some classifications may warrant further consideration, as
below, and may increase red scores to 6. A site could be rejected on the basis of a single red
score (p10).
11.1.2 Potential Issues in the Scoring
11.1.2.1 Environment and Physical Constraints
The site is recorded as Amber under the category of Environmental and Physical Constraints.
However, part of the site lies within Flood Zone 3 and therefore appears to engage the
requirements of Technical Advice Note 15 (TAN15), specifically the Justification Test and
Acceptability of Consequences tests set out in Sections 10 and 11.
Guidance provided in Background Paper BP16 (page 20) states that sites located within Flood
Zone 3 will only be considered where specific criteria are met. These include:
• The development is required under exceptional circumstances, such as those relating to
national security, energy security, public health, or climate change mitigation.
• The site meets the definition of previously developed (brownfield) land.
• The proposal is supported by a Flood Consequences Assessment (FCA) demonstrating
that the potential consequences of flooding are acceptable in accordance with the
criteria contained within Section 11 of TAN15 (2021).
In the case of Site 2299:
• No exceptional circumstances have been identified.
• The site is greenfield rather than previously developed land.
• No evidence has been presented demonstrating compliance with the acceptability of
consequences test.
Further, on page 7 of the guidance:
“Flood risk – sites located within either a TAN 15 Defended Area, or Flood Zone 2 or 3 area which
do not meet the justification test and acceptability of consequences section 10 and11 out in TAN
15 will not pass the initial sifting.”
In light of these factors, the classification of Amber within this category is surprising, as it
appears the site should have not have even passed initial sifting.
11.1.2.2 Landscape Considerations
The site is also scored Amber under the Special Landscape Area criterion. However, the scoring
guidance indicates that a site should be classified as Red where it is predominantly greenfield
and wholly located within a Special Landscape Area or a Registered Landscape of Outstanding or
Special Historic Interest.
Site 2299 is identified as greenfield land and lies entirely within a designated Special Landscape
Area. Based on the stated scoring methodology, this suggests that a Red classification could be
more consistent with the guidance provided.
11.1.3 FCA requirement
On page 22 the FCA requirement and discounting rule is clear:
“Sites which are not accompanied by a FCA or do not meet the tests shall be automatically
discounted from further consideration.”
Site 2299 does not have an FCA, so should have been discounted.
11.2 Deposit assessment audit-trail concerns (BP18A) and unexplained shifts
Inconsistencies in the deposit candidate site assessment narrative are noted:
• BP18A p.14 describes the site 2299 as conforming with strategy/initial filter and uses
language indicating it is ‘adjacent’ to the settlement; later narrative suggests it is ‘in’ the
settlement without a published boundary justification.
• BP18A p.20 notes ‘suitable for further consideration’ while listing constraints without
explaining why those constraints did not prevent progression under BP16.
• BP18A p.34 significantly downplays flood risk (references only a part in Flood Zone 3) and
does not reflect mapped intermediate surface water risk covering around half the site,
historical flood data and ground water risk.
• BP18A p.77 contains a ‘Acceptable at PS stage’ recorded as “N/A” for site 2299 and a
‘Justification’ field recorded as “N/A” for site 2299, which undermines transparency.
• BP18A also indicates that detailed site proformas exist and are available on request. The
Council should disclose the full Site 2299 proforma used for decision-making, including RAG
scoring rationale and any override decisions.
• BP18A p.34 – indicates a viability assessment has been submitted for site 2299 which
demonstrates that the site is deliverable as an affordable housing led site. Only a summary
table has been published, which appears to under cost, and may need validating in light of
flood risks, SUDs viability, no sewerage on site, and contributions to education and
infrastructure costs cited elsewhere.
11.3 Independent viability evidence gap and deliverability risk (BP42A)
• BP42A (December 2025) provides Independent Financial Viability Assessments of five
strategic/key sites. Site 2299 is not included. Planning Policy Wales (PPW 12) directs
that: “as part of demonstrating the deliverability of housing sites, financial viability must
be assessed prior to their inclusion as allocations in a development plan. At the
‘Candidate Site’ stage of development plan preparation, land owners/developers must
carry out an initial site viability assessment and provide evidence to demonstrate the
financial deliverability of their sites.”
• BP42A states it is concerned with financial viability only and not broader constraints.
• Site 2299 is not a low-risk site; it is flood constrained, and requires a robust
management plan, SUDs viability needs testing (extending to SSSI implication), requires
full new sewage/drainage infrastructure, has access uncertainties and SLA landscape
constraints. These drive abnormal costs. Without site-specific viability testing,
deliverability and affordable housing delivery cannot be assumed.
• Site 2299 has viability tension: as abnormal costs rise (flood mitigation, SuDS,
groundwater management, highway works, sewage/drainage installation and potential
off-site reinforcement), affordable housing delivery is typically the first pressure point.
The RLDP must evidence deliverability for this site, not assume it.

12 Tests of soundness
For the RLDP to be sound it must be Justified, Effective and Consistent with National Policy.
12.1 Not Justified
The allocation is not supported by proportionate evidence:
• the RLDP already provides 770 dwellings above the housing requirement
• the site contributes only 0.42% of projected affordable housing delivery
• no specific local affordable housing need has been demonstrated within Aberthin
• the site conflicts with the spatial strategy which limits growth in Minor Rural
Settlements
• the allocation represents a departure from the Council’s own site assessment
methodology
• the allocation lacks a transparent audit trail
• does not demonstrate why this constrained countryside site is the most appropriate
option, particularly given delivery elsewhere in the corridor and strategic sites
12.2 Not Effective
The site cannot be shown to be deliverable because:
• significant flood risk constraints remain unresolved
• no Flood Consequence Assessment has been undertaken
• groundwater monitoring recommended in the evidence has not been completed
• the SuDS strategy has not been demonstrated to be viable
• potential impacts on Cors Aberthin SSSI hydrology have not been assessed
• no-worsening test absent
• access, drainage and infrastructure constraints remain uncertain
• viability is not independently tested or fully costed
12.3 Not Consistent with National Policy
The allocation conflicts with Technical Advice Note 15 (Flood Risk) because:
• the site partly lies within Flood Zone 3
• residential development is highly vulnerable development
• TAN15 states such development should not occur on greenfield land in Flood Zone 3
unless essential to the LDP
• the RLDP already contains a substantial housing surplus, meaning the site cannot be
considered essential
12.4 Conclusion
For these reasons the allocation of HG4(2) – Land West of Maendy Road, Aberthin cannot be
considered sound.
The site should therefore be removed from the RLDP.
10.3 Not consistent with national policy: the allocation conflicts with national objectives for
sustainable location and robust flood risk management (including safe access/egress and no
worsening).

13 Formal request and proposed modifications
1. Primary request: delete Site 2299 from the RLDP and remove it from Policy HG4.
2. Settlement boundary: do not redraw the Aberthin settlement boundary to include this
field parcel; if already redrawn, reinstate the defensible boundary aligned to existing
built form unless a published boundary review justifies change.
Evidence disclosure requests (minimum):
a. Robust evidence qualifying necessity under HG4, aligned to national policies
b. Full Site 2299 proforma (BP18A indicates proformas exist and are available on
request), including all scoring and override rationale.
c. Full FCA including modelling outputs, assumptions, and climate change
allowances for both fluvial and pluvial events, surface runoff from surrounding
slopes, high groundwater susceptibility, principal aquifer conditions, cumulative
testing, implications on the nearby SSSI wetland habitat, ecology assessment
and no worsening test.
d. Surface water modelling demonstrates intermediate risk treatment, exceedance
routing and no worsening.
e. The advised 12-month Groundwater monitoring and data
f.
SuDS feasibility and design, including implications on the nearby SSSI and
ecology.
g. Drainage strategy demonstrating foul connection feasibility, capacity, and any
required off-site reinforcement.
h. Dry access/egress assessment for residents and emergency vehicles during flood
events.
i.
j.
Highways feasibility: access location, visibility, swept-path tracking and road
safety audit.
Active travel and public transport assessment with deliverable mitigation
package and funding mechanism.
k. Landscape/visual assessment for SLA impacts.
l.
Ecology and heritage appraisals including SSSI proximity and Conservation Area
setting.
m. Site-specific viability appraisal (including all abnormal costs) demonstrating
affordable housing deliverability.
3. Confirmation regarding protection of hedgerow
4. Confirmation regarding PRoW

Personally I wish to raise my objection due to the density and the substantial increase in dwellings in Aberthin it would cause.

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.