Representation on the Vale of Glamorgan Deposit RLDP 2021–2036

Specific Policy/Site Objection:
• Policy SP4.4: Land at Church Farm, St Athan
• Policy SP4.5: Land to the West of St Athan
• Clive Road (Additional Allocation)
• Policy EMP2: MOD St Athan / Bro Tathan

Status: Unsound

1. Introduction

I wish to formally object to the allocation of the above sites and the broader designation of St Athan as a "Primary Settlement" for high-density growth within the Replacement Local Development Plan (RLDP). This allocation fails the Test of Soundness regarding Consistency (with national climate goals) and Effectiveness (deliverability of infrastructure).

2. Failure of Sustainable Transport (Policy SP7 & SP10)

The RLDP identifies St Athan as a "Strategic Hub," yet it remains the only primary settlement in the Vale of Glamorgan without a direct rail link. Relying on the "Active Travel" aspirations of Policy SP10 is unrealistic for a community where the majority of residents commute to Cardiff, Bridgend, or Barry.

The proposed density at the above sites will inevitably lead to an unsustainable increase in private car journeys on the B4265, specifically at the Gileston Road junction and Weycock Cross, which are already at or near capacity.

Concrete infrastructure is needed to be in place prior to any development of the land. Often intentions of infrastructure are not progressed. In addition where infrastructure is not in place prior to housing many commuters will become accustomed to travel by car and wont switch to public transport. It is difficult to see how developments work with Future Wales: The National Plan 2040

Active travel should look at linking key destinations and with the western vale being spread over longer distances more effort should be given to linking population centres with separated bicycle paths and wide accessible pavements. Shared bike / foot paths are inherently dangerous not allowing the safe use of wheelchairs and prams and sufficient use for children and dog walkers. Cycling should not have to stop at every intersection which creates visibility black spots by the way they turn away from traffic.

With current planned housing and that of additional housing in the LDP creating over 1,000 new homes and with each household having 1-2 cars per household this will add significant additional numbers of journeys on already poor road infrastructure. The vale lacks sufficient north / south routes pushing vehicles towards Weycock Cross in Barry which will have its own traffic issues or via Cowbridge with small country lanes. I personally worked in Cowbridge travelling from St Athan where buses would take over 1 hour 10 minutes and even then not arriving in time to start work. In contrast car travel would be 10 minutes or cycle would be 20 minutes but over dangerous roads.

Travel to Barry for meetings at peak times can take over 50 minutes from St Athan with significant delays leading to Weycock Cross and passed the secondary schools even before developments in the RLDP or existing planning. Public transport gets caught in the same traffic issues.

Access into St Athan is already dangerous from the war memorial with one near fatal accident already having taken place since the ‘improvements’ to the junction. Proposals for additional access from B4265 onto developed land would be on a hill with poor visibility and around a blind bend. Currently there is poor visibility leaving St Athan due to the side by side two car exit blocking views in both directions along with more visibility issues looking westward due to traffic furniture and signage.

While Bro Tathan (Policy EMP2) provides jobs, there is no guarantee that the people moving into local developments will work there. If they commute elsewhere, the RLDP fails its own climate goals (Policy SP1) by creating a "commuter colony" rather than a sustainable community.

Reference Policy CI3 (New Community Facilities). The proposed expansion of St Athan Primary School lacks a guaranteed timeline for when these facilities will be operational relative to house completions. New access to the school under existing planning is only ‘proposed’ and existing access to the school via Rock Road is a poorly surfaced and narrow one way road but is
often ignored with traffic coming via Rectory Drive which has a ‘No entry except for access’ restriction but is not enforced causing large numbers of vehicles into residential areas not built for this type of activity.

Speeding is already a great concern in the village with the current level of vehicle traffic with little compliance with the 20mph speed limit and no enforcement.

3. Coalescence and Loss of Settlement Identity (Policy SSC1)

The scale of development proposed for Church Farm, in conjunction with Policy SP4.5 (Land West of St Athan), threatens the distinct character of the village. The erosion of the "Strategic Gap" between St Athan and Eglwys Brewis violates the principles of Policy SSC1 (Settlement Boundaries). This "urban creep" creates a continuous sprawl that permanently destroys the rural setting of the historic Church Farm and the village’s unique sense of place.

St Athan should no longer be thought of as a village but as a small town with infrastructure to meet the growing demands of the population and lacks facilities that are given to surrounding towns such as fire / ambulance and police stations.

If the jobs at the Enterprise Zone (Aston Martin, Bro Tathan) do not match the demographic of the new residents, St Athan simply becomes a "dormitory" village, increasing the carbon footprint as people drive to Cardiff or Bridgend for work. In addition people will travel to St Athan from other areas should they be employed at the new commercial sites.

4. Infrastructure Lag and Healthcare Capacity (Policy CI3)

Under Policy CI3, development should only proceed where adequate community facilities exist or can be provided. Current primary healthcare services in St Athan and nearby Llantwit Major are already oversubscribed. The RLDP provides no "Triggers for Delivery" to ensure that new medical and educational facilities will be operational prior to the occupation of the hundreds of homes planned for the Church Farm site. This creates a significant risk to the wellbeing of both new and existing residents. Access to both village GP services are on a part time basis. With new dentist rules in Wales, this will increase the need for further travel around the area to meet simple check ups. With no A&E facilities in the county St Athan often falls between Cardiff and Bridgend hospitals and continued poor roads together with additional traffic gives greater
concern when emergencies happen.

5. Environmental and Biodiversity Impact (Policy SP5)

The Church Farm site consists of high-quality agricultural land and vital greenfield habitats. While Policy SP5 mandates a "Net Benefit for Biodiversity," the total loss of soil permeability and ancient hedgerow connectivity on a site of this scale cannot be mitigated by tokenistic landscaping. Once this valuable land is developed it is irretrievably lost for current and future generations. Currently there are red list species using the space like Yellowhammers and Skylarks. In addition there has been a collapse of invertebrate bio-mass over the last 40 years and personally seen since moving the area in 1980. Net Benefit for Biodiversity plans do not address any of these local and national concerns.

Land to the west of St Athan (SP4.5) This site consists of Grade 2 (Good) or 3a (Excellent) agricultural land. Under Planning Policy Wales (PPW) 12, such land should only be developed if there is an "overriding need" and no lower-grade land is available. The Vale of Glamorgan council has not sufficiently explored brownfield alternatives in the Barry Docks or the St Athan Enterprise Zone. The increased light pollution and "urban glow" will impact the rural character of the Western Vale.

The invertebrate charity Buglife shows that based on citizen science monitoring data, there has been a 75% to 79% decline in the abundance of flying insects in Wales between 2004 and 2023.

Natural Resources Wales also reported

• 79% Decrease in Flying Insects (2004–2023): Data from the "Bugs Matter" survey, which counts insect "splats" on vehicle number plates, recorded this 79% reduction in Wales, with 2023 showing further declines from previous years.
• Specific Invertebrate Declines: Moths, which are key pollinators, have seen an average decline of 43% in abundance since 1970.
• Widespread Biodiversity Loss: Welsh wildlife has decreased on average by 20% since 1994, and 18% of species in Wales are at risk of extinction.
• Habitats in Peril: Over the past 50 years, many insects have suffered declines of 65% to
70% in certain areas, particularly moths, butterflies, ladybirds, and ground beetles.
• Impact on Food Chain: Invertebrates that provide food for farmland birds have seen declines of 50-80%.

The cumulative impact of hard-standing surfaces also raises serious concerns regarding surface water runoff into the River Thaw catchment area. Significant surface flooding already takes place across the western Vale spilling onto roads causing travel disruption.

An increase in hard surfaces also increases ambient temperatures compared to grassland, woodland and other green spaces necessitating increased power use for cooling and comfortable living temperatures. Building practices can help mitigate this but only where this is incorporated into sustainable building rules.

Replacing green fields (which act as a natural sponge) with hundreds of roofs and driveways at Church Farm (SP4.4) and Land West of St Athan (SP4.5) will create a "funnel effect."

Dwr Cymru Welsh Water has previously noted concerns regarding the St Athan Wastewater Treatment Works. Proof is required that the current system can handle the RLDP's projected flow without increasing overflow events. Further development risks "Combined Sewer Overflows" (CSOs) into local watercourses, which contradicts the Council’s Nature Emergency declaration.

The Vale of Glamorgan Council requires a Sustainable Drainage Systems (SuDS) Approval Body (SAB) review. Attenuation ponds are often poorly maintained and can fail during the "1-in-100-year" storm events which are becoming more frequent.

6. Conclusion

The allocation of the above site policies are unsound. It promotes car-dependent growth in a rural location without the necessary infrastructure "trigger points" to protect the local environment or the B4265 road network.

Proposed Remedy: Reduce the housing density at the above sites and re-classify St Athan as a "Minor Rural Settlement" until such time as a dedicated rail link, suitable active travel infrastructure or high-frequency public transport other than rail is fully funded and scheduled for delivery.

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

Policy SP1 - Sustainable Growth Strategy
Policy SPl sets out that the plan will deliver 7,890 dwellings by 2036, including a minimum of 3,070 affordable homes. Policy SP1 also sets out that outside of the Strategic Growth Areas, the allocation of new sites will be limited to small-scale affordable housing led sites.
The number of households in VoG in mid-2021 (i.e. the start of the RLDP period) was 57,676. Based on Welsh Government's 2022-based household projections, the number of households is projected to increase to 67,299 in VoG in mid-2036 (i.e. the end of the RLDP period). This equates to a household increase of 9,623 which is 22.0% more than the 7,890 dwellings the RLDP targets in Policy SPl. In addition, the Development Plan Manual requires a conversion factor from households to dwellings with 4% being the baseline (it is acknowledged that this will vary depending on local circumstances). Taking a 4% uplift, the dwelling requirement figure would be 10,008 which is 26.8% more than the RLDP seeks to deliver in Policy SPl. The number of overall dwellings identified in Policy SPl will therefore not meet the identified household growth needs ofVoG for the RLDP period. The Council should review the position in terms of the updated household projections.
It is important to note that the above calculations are purely to meet newly arising need and do not make any allowance for existing unmet affordable housing needs or any policy aspirations. As stated in the supporting text of Sustainable Growth Strategy 4 of the RLDP (paragraph 5.23) "The Local Housing Market Assessment (LHMA) 2023 identifies a need for 1,075 affordable homes per annum over the next five years based on principal projections or 1,114 based on the RLDP projections. There is an identified backlog of need across all the sub-market areas in the Vale of Glamorgan, and the issue is acute in many communities." Policy SPl seeks to deliver only 3,070 affordable homes over the RLDP period, equating to 205 affordable dwellings per annum. This is only 18.4% of identified need per annum for the five-year period from 2023-2028 in the LHMA. The number of affordable homes identified in Policy SPl therefore falls drastically short of the identified need for affordable homes in VoG for the RLDP period.
In order for Policy SPl to achieve the third test of soundness (Will the plan deliver?), the policy must be updated to accommodate a greater level of housing delivery, that reflects the most up to date evidence. The Development Plans Manual states:
"In terms of considering the level of housing provision for a plan, the most up-to- date suite of Welsh Government Population and Household Projections are a fundamental part of the evidence base [paragraph 5.35]"
Policy SP1 as drafted sets out that the allocation of new [housing] sites will be primarily focused within the Strategic Growth Areas (SGA) identified on the Key Diagram and outside of the SGA, the allocation of sites will be limited to small-scale affordable housing led sites. The identification of St Athan as a settlement where development should be concentrated is supported.

Policy SP2 - Settlement Hierarchy
The identification of St Athan as a 'Primary Settlement' is supported. It is important that sufficient growth is directed to the Primary Settlements to reflect the opportunities presented for delivering new homes, both market and affordable.
As recognised at Paragraph 6.11 of the Deposit Plan, St Athan is a key location for employment growth and also benefits from a range of services and facilities. This is also reflected in the Integrated Sustainability Appraisal (Paragraph 9.2.10), which recognises that locating new development in proximity to the Cardiff Airport and Bro Tathan Enterprise Zone will help integrate housing and employment, supporting sustainable travel and local labour markets. Future growth at St Athan will therefore support its role within the wider regional growth area, as well as existing and future transport proposals.

Policy SP4 - Placemaking
We support the recognition in Policy SP4 that successful placemaking can add social, economic, environmental and culture value to new development. Placemaking is an important part of all developments brought forward by Barratt Redrow.
The identification of high level placemaking principles in the Deposit Plan is supported, but a degree of flexibility should be applied. This is important to ensure the appropriate placemaking approach can be applied for each site / development. For example, it will not necessarily be appropriate for all developments to incorporate a 'diverse mix of uses... ' or to be developed at 'high densities... and supporting mixed uses'. Where developments are delivered on a phased basis, any mix of uses, residential densities etc may vary between each phase.
Policy SP4 also requires all major development to provide a 'Placemaking Statement'. It should be made clear in the Policy, as per Paragraph 6.34 of the Deposit Plan, that this is not expected to be a standalone statement, but will form part of a Design and Access Statement. We recommend the policy is amended as follows:
"Placemaking Statements will be required as part of Design and Access Statements for all... " Paragraph 6.33, which supports Policy SP4 should also be amended. It is not appropriate to state that development will be 'favoured' where meaningful community involvement has been demonstrated. Taking allocated sites, significant consultation will have already taken place through the LDP process,
with further engagement required at the application stage through the PAC process. The RLDP should be amended to note that consultation will be 'encouraged' or similar.

Policy PGDl - Creating Well Designed and Inclusive Places
There is a degree of crossover and repetition between Policy PGDl and Policy SP4. For clarity and brevity of the Plan, a single policy could be taken forward.

Policy PGD2 - Residential Site Densities
It is noted that the minimum density sought for sites within the Key, Service Centre and Primary Settlements is higher than that currently required by the adopted LDP. It is important that flexibility is adopted where proposed allocations in the RLDP crossover with existing LDP allocations.

This is relevant to Church Farm, St Athan, which is allocated in the adopted LDP. The Deposit Plan retains this allocation, but also proposes a further phase of development to the east (through Policy HGl KS4). A planning application is currently being prepared for the first phase of development (relating to the existing allocation), which accords with the adopted LDP requirement of 30 dph. The RLDP should recognise that flexibility will be required where sites are delivered on a phased basis, with earlier phases also being identified in the adopted LDP.

The inclusion of caveats recognising that lower residential densities can, in some cases, be acceptable is welcomed. It is important that the characteristics of each site/ surrounding context can be taken into account, along with sites constraints and other technical requirements (such as SuDS).

Policy SP6 - Housing Requirement
Policy SP6 currently includes a flexibility allowance of 10%. The provision of a flexibility allowance is supported, but it should be increased to 15%. The Development Plan Manual 3 indicates that 10% should be the starting point. This would be consistent with a number of other adopted and emerging LDPs, which have been based on allowance above the standard 10% (e.g. adopted Bridgend LDP at 14% and emerging Monmouthshire LDP at 15%). A higher figure is considered appropriate due to the low level of new allocations, the limited number of key sites allocated in the plan and the need to increase the level of required growth (as referred to in our response to Policy SPl).

The number of homes delivered through new allocations should be increased to make the Plan more ambitious and align with Future Wales and the Vale's identified role as a National Growth Area.

Policy HSI - Housing Allocations
We support the identification of Church Farm, St Athan as a 'Key Site'.

The table within Policy HG1 should be amended to make it clear that the number of units listed for each site are approximate figures, allowing a degree of flexibility.

Policy HG1 KS4 - Land at Church Farm, St Athan
Paragraph 6.96 rightly acknowledges that the allocation will be delivered on a phased basis. With the first phase (the western parcel), representing land allocated through the adopted LDP. A hybrid planning application is due to be submitted in March 2026 for this phase of development. The application proposes 232 new homes and a new Class Al foodstore - as per Paragraph 6.99 of the Deposit Plan.
Paragraph 6.102 states that there is limited capacity in West Aberthaw Waste Water Treatment Works (WwTW). It continues by stating that if the development wishes to connect in advance of the planned AMP scheme, a Developer Impact Assessment to establish the reinforcement works needed at the WwTW will be required. It should be recognised in the Deposit Plan that this applies to the wider allocation, with sufficient capacity existing for the first phase of development.
Policy HG1 KS4 should be amended to read that the site will deliver "approximately 532 homes over the plan period... ".
The policy requires the development to comply with the Placemaking Principles set out in Policy SP4. This policy has been commented on separately, but as previously noted, it is important that the phased nature of the Church Farm development is recognised when applying the placemaking principles. As a result, there may be slight differences in what is appropriate across each phase.
The policy currently requires affordable dwellings to be dispersed across the site in clusters of not more than 10. This should be amended to clusters of no more than 15 units.
Policy HG1 KS4 also sets out a number of other requirements that the development "must" comply with. We do not support the current wording and use of "must comply with". Some of the requirements listed will require further consideration during the design development of the scheme. This will be supported by detailed technical work to be prepared in support of a future planning application. The wording should be amended to reflect that the list 'requirements' will be subject to further consideration, and should not be treated as definitive.
For example, the points listed under 'Sustainable Transport and Highways' should be informed by a Transport Assessment. This is reflected in Background Paper BP44 (Infrastructure Delivery Plan), which recognises that contributions towards off-site improvements to the capacity/ flow of junctions will be determined through a site-specific Transport Assessment.
The first bullet point under Policy HGl KS4 should be amended to read:
"A proportionate contribution towards off-site improvements to the capacity and flow of junctions on the strategic highway network, if identified as being necessary by a site-specific Transport Assessment". As per Policy HGl KS4, the first phase of development at Church Farm has been developed on the basis of an access point from Gileston Road. This is as per the request from the Highway Authority. The hybrid planning application will also deliver localised road widening on Gileston Road and provision of a new active travel route.

(continued) Policy HG1 KS4 - Land at Church Farm, St Athan
The third bullet point under the 'Sustainable Transport and Highways' heading should be amended. Transport work undertaken to date has demonstrated that there is no need for a new signalised junction at Gileston Road/ B4265. The need for and nature of any work required to this junction should be determined through the planning application process, informed by a Transport Assessment. It is therefore not appropriate for the Policy to state that an upgraded signalised junction 'must' be provided. The intention is for a second access point to be provided for the second phase of development from the B4265. This is in line with the access strategy requested by the Highway Authority. The form and nature of this access point will be agreed through the planning application process, informed by a Transport Assessment.
The hybrid planning application for the first phase makes provision for a new pedestrian and vehicular access to St Athan Primary School. Whilst the developer can make provision for such a link, it will be down to the Highway Authority and Education Department to determine whether it is provided. Policy HGl KS4 should be amended to reflect that it is not within the developers gift to guarantee the link is taken up, delivered or actually 'replace' the existing access on Rock Road. At the moment is unclear what type of access could be sought (e.g. pedestrian and / or vehicular) and whether this would solely be through Phase 1 (as indicated by Figure 16).
Upgrades to existing bus infrastructure is expected to be delivery through planning obligations. Again, the nature of any improvements will be determined through the planning application process.
The Policy sets out a number of requirements relating to 'Community Infrastructure'. This includes the transfer of land to the east of St Athan Primary School and an off-site contribution towards the delivery of additional school places. No detail is provided as to the quantum ofland expected to be transferred. It is also noted that Policy CI3 states that land 'may be' required.
Whilst the principle of transferring land for the redevelopment I expansion of St Athan Primary School would be considered in principle by BWD, further information will be required to consider this request in full. As it stands, no information has been provided as to the extent ofland required. It is also important that Policy HG1 KS4 recognises that the need to provide for/ contribute towards education facilities will need to be determined at the point of any future planning application.
If a land transfer is required and agreed as part of the second phase of development at Church Farm, this must be reflected in any request for off-site contributions. Background Paper 44 (Infrastructure Delivery Plan) states that the second phase of development will require the transfer ofland, or a Section 106 contribution of £5.8 million. The basis and justification for this sum of contribution is not detailed within the Plan or supporting documents. Full details will need to be provided and considered at the planning application stage.

(continued) Policy HG1 KS4 - Land at Church Farm, St Athan
Policy HG1 KS4 also identifies the need for a contribution towards the provision and enhancement of community facilities in the area, and a contribution towards training and development for the commercial element of Phase 1. Whilst the principle of providing a community facilities contribution is accepted, evidence of need for such a contribution will be required at the planning application stage. The Policy should also be amended to recognise that training and development could either be provided a contribution or as part of the development itself.
The need to respect the setting of the listed War Memorial is reflected in the hybrid planning application due to be submitted imminently for Phase 1. The scheme has been carefully designed, with the relocation of the proposed foodstore to the northwest corner of the site, setting housing back from the B4265 and realignment of the central green corridor.
The importance of green infrastructure, recreation spaces and biodiversity is recognised and supported. Land at Church Farm offers the opportunity to deliver high-quality landscape buffers, accessible green space, integrated SuDS features and pedestrian and cycle connectivity with the village of St Athan and the wider strategic active travel route.
It is important that the Policy is not overly prescriptive about the types of green infrastructure and open spaces to be provided, which could potentially constrain the ability to deliver a design and landscape led masterplan. Instead, the policy should focus on outcome-based placemaking principles and flexibility in how these outcomes are achieved through design. It is also important that the ability to provide GI and open space across the site reflects other policy requirements, such as the delivery of SuDS.
The Deposit Plan includes an indicative plan for Church Farm at Figure 16. Whilst referred to as 'indicative', the purpose and status of this plan should be made clear in the supporting text. It should only be treated as illustrative, with the final development for Phase 1 and 2 being subject to further detailed design and technical work. For example, it is noted that within the Phase 1 development, land identified as 'Significant POS' on the plan is actually intended to accommodate the main attenuation basin. Whilst it would serve a qualitative purpose, it would not act as POS per se.

Policy SP7 - Affordable Housing Provision

The provision of a range of tenures, types and sizes of affordable homes is supported in principle. This should be assessed on a site by site basis at the application stage, with the LHMA being a starting point for discussions with the Housing Strategy Service. This flexibility will ensure that the most appropriate mix of dwellings is brought forward based on factors such as site characteristics, local context, placemaking etc.

It is also important that Policy SP7 acknowledges that affordable housing provision should also consider the evidenced viability of a development. This would be consistent with Policy SPS.

Policy SP8 - Affordable Housing Requirements

Recognition that the provision of affordable housing should be negotiated on a site by basis, considering the evidenced viability of a development, is supported. Recognition that the exact mix of affordable housing will need to be considered on a case-by-case basis is also welcomed. This is important to ensure sufficient flexibility when discussing the most appropriate mix of affordable homes at the application stage.

Policy TRI - Transport Proposals
Policy TRI states that to mitigate the impact of development on the highway network, strategic highway improvements have been identified to the Gileston Road junction in St Athan. As per our comments under Policy HG I KS4, the need, and nature of any works to the Gileston Road / B4265 junction must be informed by detailed technical work.

We can confirm that the first phase of development, which will be subject to a hybrid planning application in March 2026, has been designed to not prejudice any future improvement works to the junction (should measures be demonstrated as necessary in the future).

Policy SP12 - Retail Floorspace Provision
The identification of new convenience floorspace at Church Farm, St Athan is supported. The provision of new retail floorspace in this location will support the existing and future population of St Athan, reducing the need to travel to other settlements to serve their needs.

Policy SP13 - Community Infrastructure and Planning Obligations.
We support the recognition in Policy SP13 that any requirement for planning obligations must be appropriate and have regard for development viability.
Policy SP13 also states that the delivery of new/ improved infrastructure should be timed to meet the needs of communities prior to, or from the commencement of, relevant phases of development. It must be recognised in the policy or supporting text that the delivery / timing of some infrastructure measures will be outside the control of developers I developments. This is particularly the case where financial contributions are made and measures will be delivered by others. Flexibility should therefore be allowed for through Policy SP13.

Policy Cll - Open Space Provision
The wording of Policy Cll, and/ or the supporting text, must allow greater flexibility to be applied to the open space standards. This is essential to ensure that the spaces provided are design, rather than standards led. It is also important that the type and range of provision is reflective oflocal context/ needs. This is reflected in Paragraph 6.233 of the Deposit Plan but Policy Cll should also be amended to reference this directly.

The proposed 62.2 sq m per dwelling requirement is overly prescriptive and not aligned with FiT's methodology, which is per person and intended to be applied strategically across different open space typologies, not as a uniform per dwelling metric. FiT's approach emphasises flexibility, multifunctionality and local context, meaning that applying a rigid per dwelling standard oversimplifies the guidance and risks generating disproportionate land take and unnecessary design constraints. When combined with the wider cumulative policy requirements of the RLDP, such an approach has the potential to impact development viability and reduce delivery.
The recognition that in some instances off-site contributions will be appropriate in lieu of on-site provision is welcomed.

Policy Cll requires an 'Open Space Strategy' to be submitted for all housing developments that meet the relevant thresholds. In many instances, the provision of open space within a scheme will be addressed through a Design and Access Statement and/ or Green Infrastructure. This ensures that open space provision is considered as part of the comprehensive approach to design, landscape and biodiversity. We would question the need for a standalone strategy or statement. The Policy should be amended to reflect this.

Policy CI3 - New Community Facilities
Policy CI3 identifies the 'allocation' ofland at St Athan Primary School for new community facilities. The supporting text (Paragraph 6.245) confirms that this land is allocated for the redevelopment and expansion of the existing school site. It continues by stating that a "small area of additional land may be required required ... to facilitate the delivery of the school" as part of the Key Site allocation at Church Farm. It states that improved access "may also be necessary".

As worded, the Policy is not clear what land is allocated - whether it is actually within the Primary School and/ or adjoining land. Ifland may be required within the Church Farm development (as implied by Policy HG1 KS4), it is currently unclear what quantum ofland would be sought. Whilst the principle of transferring land for expansion of the school (as part of Church Farm Phase 2) and facilitating improved access would be considered by BDW, it is important that what is being sought is clear.

It is important that there is coordination between policies in the Plan - for example, Policy CI3 and Policy HG1 KS4. This should include an amendment to Policy HG1 KS4 that the land 'may' be required, rather than must be provided. It is also important that ifland is provided for the school expansion, or improved access is facilitated, by the development at Church Farm, this is reflected in other requirements and expectations across the Plan (e.g. in terms of design, planning obligations etc).

Policy CCI - Residential Operational Net Zero Carbon Development
Current Building Regulations targets are sufficient to achieve Welsh Government's objectives for improving energy efficiency and delivering net zero carbon development. Additional local policy requirements risk creating inconsistency across Local Planning Authorities and may exceed what is necessary to align with national policy.

The policy should clarify that it applies only to regulated energy use. Developers have no control over how future homeowners use their homes, and therefore unregulated energy consumption such as appliance use, occupant behaviour, and plug loads, cannot form part of compliance requirements. This is consistent with Building Regulations methodology

Alternatively, if Policy CCI is kept in the RLDP, there must be some flexibility introduced for the requirements of Policy CCI to fall away should Building Regulations catch up or exceed or require different provisions than the requirements of Policy CCI during the lifetime of the RLDP. To not provide this flexibility would mean that the ability of the RLDP to deliver the new homes in VoG needs could be compromised. Clarification is also required on how the contribution to the Council's Project Zero fund is to be calculated and whether the timeframes in Policy CCI relate to the date of planning approval.
Furthermore, the demands of Policy CCI have to be considered in the context of all of the other requirements that impact on development viability (e.g. affordable housing). The Council must provide evidence that an assessment has been undertaken to demonstrate that development, specifically the housing allocations in Policy HGI, can bear the cumulative policy costs of the RLDP, including Policy CCL

The policy wording should be amended so that the performance requirements apply based on the date of planning permission rather than the RLDP adoption date. Changes in energy performance requirements can significantly affect site layout, building orientation, and design considerations. Without this amendment, approved schemes could unnecessarily require variations via Section 73 or Non Material Amendment applications.

Representation on the Vale of Glamorgan Deposit RLDP 2021–2036
Specific Policy/Site Objection:
• Policy SP4.4: Land at Church Farm, St Athan
• Policy SP4.5: Land to the West of St Athan
• Clive Road (Additional Allocation)
• Policy EMP2: MOD St Athan / Bro Tathan
Status: Unsound
1. Introduction
I wish to formally object to the allocation of the above sites and the broader designation of St
Athan as a "Primary Settlement" for high-density growth within the Replacement Local
Development Plan (RLDP). This allocation fails the Test of Soundness regarding Consistency
(with national climate goals) and Effectiveness (deliverability of infrastructure).
2. Failure of Sustainable Transport (Policy SP7 & SP10)
The RLDP identifies St Athan as a "Strategic Hub," yet it remains the only primary settlement in
the Vale of Glamorgan without a direct rail link. Relying on the "Active Travel" aspirations of
Policy SP10 is unrealistic for a community where the majority of residents commute to Cardiff,
Bridgend, or Barry.
The proposed density at the above sites will inevitably lead to an unsustainable increase in
private car journeys on the B4265, specifically at the Gileston Road junction and Weycock
Cross, which are already at or near capacity.
Concrete infrastructure is needed to be in place prior to any development of the land. Often
intentions of infrastructure are not progressed. In addition where infrastructure is not in place
prior to housing many commuters will become accustomed to travel by car and wont switch to
public transport. It is difficult to see how developments work with Future Wales: The National
Plan 2040
Active travel should look at linking key destinations and with the western vale being spread over
longer distances more effort should be given to linking population centres with separated
bicycle paths and wide accessible pavements. Shared bike / foot paths are inherently
dangerous not allowing the safe use of wheelchairs and prams and sufficient use for children
and dog walkers. Cycling should not have to stop at every intersection which creates visibility
black spots by the way they turn away from traffic.
With current planned housing and that of additional housing in the LDP creating over 1,000 new
homes and with each household having 1-2 cars per household this will add significant
additional numbers of journeys on already poor road infrastructure. The vale lacks sufficient
north / south routes pushing vehicles towards Weycock Cross in Barry which will have its own
traffic issues or via Cowbridge with small country lanes. I personally worked in Cowbridge
travelling from St Athan where buses would take over 1 hour 10 minutes and even then not
arriving in time to start work. In contrast car travel would be 10 minutes or cycle would be 20
minutes but over dangerous roads.
Travel to Barry for meetings at peak times can take over 50 minutes from St Athan with
significant delays leading to Weycock Cross and passed the secondary schools even before
developments in the RLDP or existing planning. Public transport gets caught in the same traffic
issues.
Access into St Athan is already dangerous from the war memorial with one near fatal accident
already having taken place since the ‘improvements’ to the junction. Proposals for additional
access from B4265 onto developed land would be on a hill with poor visibility and around a
blind bend. Currently there is poor visibility leaving St Athan due to the side by side two car exit
blocking views in both directions along with more visibility issues looking westward due to
traffic furniture and signage.
While Bro Tathan (Policy EMP2) provides jobs, there is no guarantee that the people moving
into local developments will work there. If they commute elsewhere, the RLDP fails its own
climate goals (Policy SP1) by creating a "commuter colony" rather than a sustainable
community.
Reference Policy CI3 (New Community Facilities). The proposed expansion of St Athan
Primary School lacks a guaranteed timeline for when these facilities will be operational relative
to house completions. New access to the school under existing planning is only ‘proposed’ and
existing access to the school via Rock Road is a poorly surfaced and narrow one way road but is
often ignored with traffic coming via Rectory Drive which has a ‘No entry except for access’
restriction but is not enforced causing large numbers of vehicles into residential areas not built
for this type of activity.
Speeding is already a great concern in the village with the current level of vehicle traffic with
little compliance with the 20mph speed limit and no enforcement.
3. Coalescence and Loss of Settlement Identity (Policy SSC1)
The scale of development proposed for Church Farm, in conjunction with Policy SP4.5 (Land
West of St Athan), threatens the distinct character of the village. The erosion of the "Strategic
Gap" between St Athan and Eglwys Brewis violates the principles of Policy SSC1 (Settlement
Boundaries). This "urban creep" creates a continuous sprawl that permanently destroys the
rural setting of the historic Church Farm and the village’s unique sense of place.
St Athan should no longer be thought of as a village but as a small town with infrastructure to
meet the growing demands of the population and lacks facilities that are given to surrounding
towns such as fire / ambulance and police stations.
If the jobs at the Enterprise Zone (Aston Martin, Bro Tathan) do not match the demographic of
the new residents, St Athan simply becomes a "dormitory" village, increasing the carbon
footprint as people drive to Cardiff or Bridgend for work. In addition people will travel to St Athan
from other areas should they be employed at the new commercial sites.
4. Infrastructure Lag and Healthcare Capacity (Policy CI3)
Under Policy CI3, development should only proceed where adequate community facilities exist
or can be provided. Current primary healthcare services in St Athan and nearby Llantwit Major
are already oversubscribed. The RLDP provides no "Triggers for Delivery" to ensure that new
medical and educational facilities will be operational prior to the occupation of the hundreds of
homes planned for the Church Farm site. This creates a significant risk to the wellbeing of both
new and existing residents. Access to both village GP services are on a part time basis. With
new dentist rules in Wales, this will increase the need for further travel around the area to meet
simple check ups. With no A&E facilities in the county St Athan often falls between Cardiff and
Bridgend hospitals and continued poor roads together with additional traffic gives greater
concern when emergencies happen.
5. Environmental and Biodiversity Impact (Policy SP5)
The Church Farm site consists of high-quality agricultural land and vital greenfield habitats.
While Policy SP5 mandates a "Net Benefit for Biodiversity," the total loss of soil permeability
and ancient hedgerow connectivity on a site of this scale cannot be mitigated by tokenistic
landscaping. Once this valuable land is developed it is irretrievably lost for current and future
generations. Currently there are red list species using the space like Yellowhammers and
Skylarks. In addition there has been a collapse of invertebrate bio-mass over the last 40 years
and personally seen since moving the area in 1980. Net Benefit for Biodiversity plans do not
address any of these local and national concerns.
Land to the west of St Athan (SP4.5) This site consists of Grade 2 (Good) or 3a (Excellent)
agricultural land. Under Planning Policy Wales (PPW) 12, such land should only be developed
if there is an "overriding need" and no lower-grade land is available. The Vale of Glamorgan
council has not sufficiently explored brownfield alternatives in the Barry Docks or the St Athan
Enterprise Zone. The increased light pollution and "urban glow" will impact the rural character of
the Western Vale.
The invertebrate charity Buglife shows that based on citizen science monitoring data, there has
been a 75% to 79% decline in the abundance of flying insects in Wales between 2004 and 2023.
Natural Resources Wales also reported
• 79% Decrease in Flying Insects (2004–2023): Data from the "Bugs Matter" survey,
which counts insect "splats" on vehicle number plates, recorded this 79% reduction in
Wales, with 2023 showing further declines from previous years.
• Specific Invertebrate Declines: Moths, which are key pollinators, have seen an average
decline of 43% in abundance since 1970.
• Widespread Biodiversity Loss: Welsh wildlife has decreased on average by 20% since
1994, and 18% of species in Wales are at risk of extinction.
• Habitats in Peril: Over the past 50 years, many insects have suffered declines of 65% to
70% in certain areas, particularly moths, butterflies, ladybirds, and ground beetles.
• Impact on Food Chain: Invertebrates that provide food for farmland birds have seen
declines of 50-80%.
The cumulative impact of hard-standing surfaces also raises serious concerns regarding
surface water runoff into the River Thaw catchment area. Significant surface flooding already
takes place across the western Vale spilling onto roads causing travel disruption.
An increase in hard surfaces also increases ambient temperatures compared to grassland,
woodland and other green spaces necessitating increased power use for cooling and
comfortable living temperatures. Building practices can help mitigate this but only where this is
incorporated into sustainable building rules.
Replacing green fields (which act as a natural sponge) with hundreds of roofs and driveways at
Church Farm (SP4.4) and Land West of St Athan (SP4.5) will create a "funnel effect."
Dwr Cymru Welsh Water has previously noted concerns regarding the St Athan Wastewater
Treatment Works. Proof is required that the current system can handle the RLDP's projected
f
low without increasing overflow events. Further development risks "Combined Sewer
Overflows" (CSOs) into local watercourses, which contradicts the Council’s Nature Emergency
declaration.
The Vale of Glamorgan Council requires a Sustainable Drainage Systems (SuDS) Approval
Body (SAB) review. Attenuation ponds are often poorly maintained and can fail during the "1-in
100-year" storm events which are becoming more frequent.
6. Conclusion
The allocation of the above site policies are unsound. It promotes car-dependent growth in a
rural location without the necessary infrastructure "trigger points" to protect the local
environment or the B4265 road network.
Proposed Remedy: Reduce the housing density at the above sites and re-classify St Athan as a
"Minor Rural Settlement" until such time as a dedicated rail link, suitable active travel
infrastructure or high-frequency public transport other than rail is fully funded and scheduled
for delivery.