Leave the Model Farm alone

This is not needed.

Drop it from the plan

yet again building an industrial park on farmland taking away produce producing land and adding to more traffic to an already congested A4226

This is an objection to further development in Rhoose on the following grounds:
● over development without improvement to infrastructure
● current roads unable to support additional traffic as a result of further development, roads in/out of Rhoose are already choked
● loss of green fields/arable land to building, solar panels, battery storage units
● Model Farm proposed development will change the landscape, destroy habitats, reduce biodiversity, add pressure to roads, cause flooding in Porthkrry Park
● additional pressure on already overloaded pumping stations/sewerage infrastructure
● adverse effect on current residents mental health due to over population of the village and loss of green areas
● increase in youth annoyance/antisocial behaviour

All RDLP allocations and commitments for development must form part of any transport infrastructure statement to ensure the transport infrastructure plan is sound.

AS this is am allocation the likely traffic generated by it must be included within the calculations for additional housing at Weycock Cross and all sites in Rhoose. The responses to the earlier consultation suggest this is not being done.

A transport impact assessment / model is needed for the whole plan and not on a piecemeal basis

Object to the Model farm development. Some 6000 traffic movements a day! combined with weycock cross readers way other employment land at airport plus a 2000 pupil college. A comprehensive up to date transport assessment is needed to ensure the plan is sound.

Removal of this proposal.

This would take farm land that is currently actively farmed. This should not be permitted.
This would also add to the already overburdened traffic on Port Road towards and at Weycock cross.

Remove Model Farm from the RLDP.

Cardiff Airport Enterprise Zone, primarily the development at Model Farm, is an unsustainable development and does not work in conjunction with the Wellbeing of Future Generations Act. We must preserving green spaces, especially those in which product crops for food or resale, in order to sustain our local circular economy not create a white elephant industry development.

I support these business developments in principle but fear that they will come before existing road and transport infrastructure is upgraded to cope. There needs to be substantial improvements to transport infrastructure before these sorts of developments are considered. By developing the business zones first the council also risks only attracting low quality businesses to the area as the higher quality businesses will be put off by poor infrastructure and transport links.

Object to the rolling forward of Model Farm development with no viability assessment as you requires in order that "the RLDP can satisfy new policy requirements and remain viable and deliverable" (refs. DMM+PPW)
The High Court blocked the first officer-recommended approval, because the non-viability had been concealed; this was one reason for Committee rejection in March’23. To now exempt it from viability assessment deviously ignores the your prescription for rolling forward, which the RLDP team has been unable to justify.
The site had no sustainability/viability assessment for the 2015 LDP, pretending siting in the Enterprise Zone covered it.

We submitted a "comment" but need to ensure it's taken as an objection to rolling forward this development into the RLDP. Exempting it from Site Specific Viability Assessment shows unacceptable bias - evidence shows it's unviable.
Its siting in CA&StAthan EnterpriseZone does not exempt it from sustainable development and viability requirements. 'FutureWales' recognised the EZ as a strategic economic location that complements (but does not replace) the National Growth Area structure. The EZ is not a Growth Area itself, but it supports the NGA’s economic role.
The attached document ModelFarm-failsDMMcriteria FoE09Mar'26 gives supporting evidence from DMM and FutureWales.

Modal farm is prime active farmland this should be maintained to ensure local food production

Modal farm is prime active farmland this should be maintained to ensure local food production

Removal from the plans.

Model Farm should not be on this plan. It's an area of significant importance for the local community, wildlife, and the economy as it currently stands. Taking that away for a white elephant of an industrial part would be seriously detrimental to the Vale as a whole, now and for future generations. It would be bring no growth to the area, only extra traffic, pollution, and disruption.

Improved road links and a greater incorporation of the airport rail link running into the various areas of the village will give people the option to make increased use of public transport and thus help with the traffic volume and flow.
The 'green wedge' must be preserved.

The potential development at Model Farm will remove a significant amount of green space and bring much additional traffic flow and delays on an already busy route that experiences significant delays at numerous times during the day. The situation will be exacerbated with the current construction of the Vale College Campus, with industrial units on the site, and proposed housing developments in Rhoose.
Noting that Cardiff Airport is considered important as an international gateway and essential to Wales’ economy, the access route (already not ideal) will be severely compromised and could further jeopardise the airport’s future.

Thank you for consulting Natural Resources Wales (NRW) on the Vale of Glamorgan Replacement Local Development Plan (RLDP) Deposit Plan, which we received on 28 January 2026.
We have reviewed the deposit plan and published documents and have recommendations on matters relating to coherence and consistency. We advise these are addressed prior to submission of the RLDP.
1. Summary
We welcome that the Vale of Glamorgan Council has declared a ‘nature emergency’ and in 2021 committed to a target of no net loss of biodiversity in the Vale of Glamorgan. The deposit plan takes this a step further through its vision, objectives and policies in seeking
the achievement of net biodiversity benefit. We also welcome the recognition within the deposit plan and supporting documents that additional growth within the Vale has the potential to lead to negative effects on nationally and locally designated biodiversity. We
appreciate that the deposit plan’s policies seek to mitigate against these potential adverse effects with detailed wording and requirements.
However, we consider that the deposit plan would benefit from more specific mention of designated conservation sites especially where these are related to specific allocations and their associated policies. We note this issue was raised within the Integrated Sustainability Assessment (ISA) (see Section 2 below) however we do not see this recommendation properly reflected within the deposit plan itself. We consider this is a gap that should be addressed to ensure clarity within the policy requirements for any future planning applications.
General Approach to Designated Sites
In line with our role in development planning and our consultation remit, we advise that where new development may occur within or be likely to affect statutory designated sites including Special Areas of Conservation (SAC), Special Protection Areas (SPA), Sites of Special Scientific Interest (SSSI), National Nature Reserves (NNR) and Marine Conservation Zones (MCZ) this could be more clearly identified as a key consideration especially with respect to site allocations (housing and employment). We consider that the issue of avoiding or mitigating potential impacts and utilising opportunities for supporting and enhancing these sites (as noted by para 6.401 of the deposit plan) could have more substantial recognition across the deposit plan and its supporting documents. This would improve the clarity of approach.
We have furthermore noted that Policy SP20 (Biodiversity and Ecosystem Resilience) currently excludes specific mention of designated sites (although it does refer to protected species and habitats) and we suggest that this is addressed – our comments on SP20 are set out in Section 3 of this letter.
By across the plan, we mean there is scope to include mention of relevant statutorily designated sites within the constraints text for the sites listed in Appendix B of document BP44 Infrastructure Delivery Plan (perhaps summarising in line with the approach taken to the Historic Environment Record) and within document BP32A Green Infrastructure Assessment of Key Sites, evidence which can then be reflected as appropriate in Key Sites Policies (HG1 KS1 to KS5) to inform their master planning. The Preliminary Ecological Appraisals already undertaken for Key Sites (Key Site Supporting Information) would appear to hold relevant information in this respect.
We note that document BP32A has a useful general paragraph on biodiversity assets at paras 3.7-3.8 linked to the evidence collated in the Green Infrastructure Assessment (GIA). In short, where designated sites are identified in proximity to allocated sites it would be
helpful to make clear reference to them in a consistent manner. This would bring the deposit plan more fully into alignment with the ISA findings. For any employment sites
within proximity of designated sites, we consider that the employment background paper BP12A could potentially be updated to similar effect.
With reference to omissions on this matter, we refer you to our comments on sites set out in Section 4 of this letter, including sites KS1, HG1 (1), SP14 1. and SP14 4.
Overall, we consider that the recognition of designated sites appears somewhat inconsistent in the deposit plan, although we recognise that much of this is done by the
Green Infrastructure Strategy (GIS) which incorporates the GIA.
It may be that Policy SP20 (please see our suggested amendments in Section 3 of this letter) together with addressing the meaning of “areas of high ecological value” will also go some way towards resolving the points we raise.
Master Planning
We welcome the illustrative master plans included in the deposit plan but would caveat that at the detailed stages schemes must be able to adapt, where necessary, to site
specific environmental constraints (including protected sites, species and habitats), for example in response to updated ecological appraisals or detailed species surveys.
Designs need to be flexible enough to ensure compliance with the stepwise approach (avoid, minimise, mitigate) in achieving Net Biodiversity Benefit (NBB) and improving the resilience of ecosystems as required by Planning Policy Wales, edition 12 (PPW12) and Policy 9 of Future Wales, the National Plan. We note the plan has good reference to this within Policy SP20 and supporting paragraph 6.405, thus enabling thorough consideration
at the project/planning application level and in master planning.
Please see our detailed site-specific comments in Section 4 in order to consider where our comments may lead to adjustments in master plans. For example, the species protection issues we highlight with regard to KS3 at Readers Way, Rhoose.
Strategic Opportunity at Bro Tathan
In addition to the above points, we advise that the Bro Tathan area of the Vale includes a number of different allocations and is already known as an important ecological area for great crested newts (GCN) and dormice, in particular. Given the commitments already
made under previous planning applications at the site and the necessary requirement for future biodiversity provisions, we advise a more strategic overview of the area should be considered and either set out within the deposit plan or secured within an updated GIS.
This will ensure that development in the area:
• does not cause detriment to the maintenance of the favourable conservation status of protected species;
• results in green spaces and infrastructure that is meaningfully spatially connected and sufficient in size.
Overall, we consider piecemeal development of the St Athan area will not lead to effective conservation delivery and will make the planning process less efficient at project level.
Areas of High Ecological Value
As previously noted within our preferred strategy response (Ref: CAS-244275-Q4F4, dated: 14th February 2024), the deposit plan continues to make reference to avoiding
areas of ‘High Ecological Value’ (criterion 1 of SP20). We have not been able to establish where these areas are or how their ecological value is being determined. We consider this issue needs to be clarified and ideally a definition provided.
2. Integrated Sustainability Assessment (ISA)
With regards to Section 9.9 of the ISA, we agree that additional growth in the Vale has the potential to lead to negative effects on nationally and locally designated biodiversity. The ISA concludes that the housing-specific policies set out within the deposit plan work well to
mitigate the potential adverse effects, through design stipulations and policy inclusions.
The ISA then goes on to recommend that Key Site policies are updated, where appropriate, to reference specific designated sites which they are in proximity to, in
order to help establish appropriate protection and/or enhancement measures.
We agree with these recommendations and would go further in advising that all allocations and their associated policies should reference specific designated sites relevant to that site. For instance, we would advise Barry Woodlands SSSI and Walters Farm SSSI is identified in relation to Key Site 1 – Land at North West of Barry, and Barry Woodlands SSSI should also be identified for Housing Allocation HG1 (1) Land to the West of
Pencoedtre Lane. Please refer to our site-specific comments in Section 4 below.

3. Plan and Policy Wording
Strategic Policies
Strategic Policy SP19 – Green Infrastructure
We welcome that the GIS and GIA has informed the master planning of the Key Site allocations (6.395). To ensure this approach is carried forward for other development proposals, we consider there should be a stronger “policy hook” within Policy SP19 to link the content and evidence of the GI work to the policy and its influence on decision-making. Without this we consider there may be a risk of a policy gap/mismatch when determining planning applications.
This could be resolved by a new criterion such as:
“the provision of green infrastructure must have regard to any adopted or emerging guidance including the Green Infrastructure Strategy/Green Infrastructure Assessment
(and the Assets listed therein), and Green Infrastructure (Action) Plan for the Vale.”
To strengthen Policy SP19 we also recommend an addition to the wording of criterion 2 to read:
“Protect and enhance connectivity between existing green infrastructure assets and be planned wherever possible to positively support areas of high ecological value”.
We furthermore note that criterion 3 of SP19 refers to achieving net benefit for biodiversity whilst the policy overall seeks to provide, protect and enhance high quality multi-functional green infrastructure. We have previously commented that multi-functional green spaces may not always be compatible with biodiversity. It should be recognised that multifunctional uses of space can be to the detriment of the natural environment and so must be carefully considered. We recommend that paragraph 6.397 wording is updated to reflect this potential conflict so that NBB required by PPW (and as promoted by para 6.396 together with Policy SP20) is able to be prioritised and not compromised.
This point could also be raised under Policy SP4 Placemaking – at para 6.32. It should not be assumed that multifunctional spaces will also be delivering for nature in every situation and in some cases separate provision of spaces to meet biodiversity goals will be essential.
Paragraph 6.401 is welcomed regarding the opportunities that exist for the protection, maintenance and further enhancement of green infrastructure assets.
Strategic Policy 20 (SP20) – Biodiversity and Ecosystem Resilience
We welcome the inclusion of SP20 which recognises the importance of natural assets and aims to protect these. We have made comments regarding the term “high ecological value” in our Summary section at the start of this letter.
We also note that whilst reference is made to sites and areas of European, national and local importance (para. 6.402), this is not distinctly carried through within SP20 or within a specific detailed policy in the deposit plan. We advise that a more detailed policy for the Natural Environment (similar to DNP4 for the Historic Environment) could be included within the deposit plan and this should include reference to the protection of statutorily designated sites. Alternatively, SP20 itself could be updated to include reference to these in a similar manner to the approach taken to non-statutory designated sites provided by criterion 5 of SP20. We consider this would strengthen the deposit plan’s alignment to
section 6.4.3 of PPW12. This issue is also reflected in our feedback to the ISA as set out in Section 2.
By adding a detailed policy for the wider protection of the natural environment, there is scope to ensure a clearer message within the deposit plan regarding the need for natural resources (including land, air, water and soils) in the Vale to be protected for themselves and the essential ecosystem services they deliver. This is opposed to merely preventing pollution (deposit plan Policy DNP5). Taking such an approach would enable an
opportunity to add the consideration of Sustainable Management of Natural Resources (SMNR) into the plan policy framework rather than confining this to the deposit plan context (para 2.11) and the policy context of the GIS (page 53).
We note that Policy CC4: Renewable, Low and Zero Carbon Energy Generation is more distinct in seeking to safeguard a range of assets (including nature conservation interests and soil conservation interests) and we consider a similar policy approach may be useful
for all development proposals. We also suggest that the placemaking strategic policy (Policy SP4) could be altered in order to highlight the Natural Environment alongside its
current reference to the Historic Environment. We note that placemaking principles (Figure 11 - Identity) includes the need for development to respond to natural physical attributes of the site. This is an issue is linked to our site-specific comments (Section 4 below) where we cite, for example, the need to buffer woodlands, hedgerows and watercourses and preserve linear corridors.
Ensuring an SMNR approach will impact positively on the ground to safeguard and improve ecological networks and protect and enhance ecosystems, essential to meeting
the nature emergency. Topics we draw your attention to include river restoration where, in particular, the removal/remediation of physical modifications can make a significant impact upon water quality. The GIS provides scope to capture various projects and wider initiatives, including those based on catchment scale improvements and we welcome the opportunity to be continually involved in this work. We note and welcome the recognition of
nature-based solutions within Policies SP16, SP19 and SP20 and in detailed Policy CC6.
With regards to natural assets and water resources, we consider that specific reference to water quality is lacking within the strategic and/or detailed policies. Whilst we note that water quality is mentioned within criterion 9 of Policy SP16, we consider the deposit plan should include more direct reference to the Water Framework Directive. We consider there is an opportunity for SP20 to be updated to ensure developments protect water quality and quantity. Alternatively, as mentioned above, this could fit within a detailed policy for the protection of the natural environment.
As a minor point, please note that the South Central Area Statement is not hyphenated (para 2.10 and 2.11). Please note also that, referring to paragraph 6.404 and 6.405, the
requirements for developments to demonstrate NBB is based on PPW12, rather than The Environment (Wales) Act 2016.

Detailed Policies

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

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

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

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

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

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

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

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

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

Spatial Planning of Biodiversity
A masterplan or spatial biodiversity or GI plan should demonstrate the retention, provision and enhancement of essential areas for protected species. It should ensure that individual site-based habitat provisions are not designed in isolation but considered in association with nearby sites to demonstrate how habitat connectivity and resilience will be provided both across the site and to the wider landscape. Note that functional separation of public
open space and areas for biodiversity compensation may be required. Suitable buffers will need to be applied to any woodland and retained or created habitats on site. A sensitive lighting strategy will also likely be required for these sites. This point was raised previously during our review of the strategic candidate sites (ref: CAS-234819-C1V3, dated 4th October 2023).

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

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

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

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

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

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

5. Housing And Employment Allocations
Housing Allocations

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Introduction
The following representation is made in support of the employment allocation of Land south of Port Road (Model Farm), Rhoose (44.75 ha net) within the Vale of Glamorgan Replacement Local Development Plan (RLDP) Deposit Plan.
Policy SP14: Employment Growth of the Deposit Plan identifies the site as a strategic employment allocation to support job growth and economic prosperity across the Vale of Glamorgan over the plan period and to meet the projected employment land needs of 67.8 hectares of employment land, as well as the delivery of up to 5,338 jobs and provision of 182 net hectares of employment land for B1 (Office and Light Industry), B2 (General Industries) and B8 (Distribution and Storage).
Our client, Legal and General, fully support the proposed allocation within the Deposit Plan which is to contribute 25% of the RLDP allocated employment land provision.

Site Context
The site proposes a 44.75 ha business park on land at Port Road, Rhoose, adjacent to Cardiff Airport. The site will provide approximately 1.7 million sq. ft Class B1, B2 and B8 floorspace, car parking, landscaping, drainage infrastructure and biodiversity enhancement. It will provide high quality offices, light industrial and warehousing and distribution units in a unique setting. It will also deliver an extension to the existing Porthkerry Country Park.
The site is allocated in the adopted Local Development Plan (LDP) 2011 – 2026 under Policy SP2: Strategic Sites for employment uses at land adjacent to the airport and Port Road, Rhoose, as part of the St. Athan – Cardiff Airport Enterprise Zone. Additionally, the site is one of the 11 sites allocated for future employment development under Policy MG9.
The Cardiff Airport and Gateway Development Zone 2011-2026 Supplementary Planning Guidance (SPG) emphasises the strategic significance of the site, highlighting its potential to deliver regionally important economic growth across a range of employment sectors.
An outline planning application was submitted on the allocated site in 2019 for demolition of existing buildings and erection of 44.79ha Class B1/B2/B8 Business Park, car parking, landscaping, drainage infrastructure, biodiversity provision and ancillary works. The application was amended in 2021 to a hybrid planning application ref: 2019/00871/OUT comprising an outline application for the demolition of existing buildings and erection of 44.75ha Class B1/B2/B8 Business Park, car parking, landscaping, drainage infrastructure, ecological mitigation and ancillary works (all matters reserved aside from access) within Area A and a full application for change of use from agricultural land to country park (Use Class D2) within Area B. The application was recommended for approval at Committee.
Notwithstanding the positive recommendation, the site is currently subject to an appeal for non-determination of 2019/00871/OUT. The inquiry was adjourned in March 2025 due to procedural matters and is scheduled to recommence in March 2026. Legal and General remains committed to the delivery of the site through its participation in the appeal process.

Cardiff Airport and St Athan Enterprise Zone
Planning Policy Wales
Planning Policy Wales (PPW) forms the national policy for Wales, outlining guidance for making planning decisions. PPW advises that the planning system plays a central role in supporting economic growth by ensuring that a sufficient supply of appropriately located employment land is identified and protected through development plans.
Employment land should be aligned with the principles of sustainable development, the well-being goals, and national decarbonisation objectives. Planning authorities are required to:
• Plan proactively for a mix of employment opportunities;
• Allocate and protect land that meets the current and future needs of business and industry;
• Ensure that employment land is well-connected, particularly via public transport, road, and digital infrastructure.
Paragraph 5.4.17 recognises Enterprise Zones as an example of where co-ordinated action can take place to encourage investment in a particular sector in a particular place. It refers that planning authorities should seek to support the development of business networks and clusters particularly in relation to innovative and technology-based enterprise.

Future Wales: The National Plan 2040
Future Wales: The National Plan 2040 (Future Wales) forms the development plan for Wales. It influences all levels of the planning system in Wales and helps to shape Strategic and Local Development Plans prepared by councils.
Model Farm falls within the Gateway Development Zone of the St Athan – Cardiff Airport Enterprise Zone which has been designated by Welsh Government for aerospace and defence related investment. It is supported by Policy 10 of Future Wales which recognises:
‘The Enterprise Zone offers a wide range of development sites and business accommodation, providing opportunities for the development of bespoke facilities or investment in existing accommodation’.
The strategic role of the Enterprise Zone is reinforced by several policies in Future Wales:
• Policy 1 (Where Wales Will Grow) – supports concentration of economic growth in the South East region, including Enterprise Zones.
• Policy 2 (Shaping Urban Growth and Regeneration) – requires that development at strategic gateways such as Cardiff Airport be maximised to support economic resilience.
• Policy 33 (National Growth Area – Cardiff, Newport and the Valleys) – identifies the Cardiff Airport & Bro Tathan Enterprise Zone as a nationally significant economic cluster.

Replacement Local Development Plan
The Deposit Plan sets out an overall strategy, allocating land for a range of and uses and setting out policies aimed at guiding development and framing development management decision making. The Deposit Plan Vision looks forward 15 years to 2036, where:
The Vale has a thriving local economy with a balanced, diversified business base. New employment growth at Bro Tathan and Cardiff Airport Enterprise Zones has attracted inward investment from knowledge-based and high-tech businesses, creating high quality employment and training.
Key strategic Objectives 9 Building a Prosperous and Green Economy – promotes the Cardiff Airport and St Athan Enterprise Zone as an important employment area, enabling delivery of high-quality and skilled jobs, training, and education opportunities. It promotes a range and choice of good quality employment land and supports infrastructure to enable local businesses to expand. The objective is to create opportunities for inward investment and enable the Vale of Glamorgan’s economy to respond to future changes in work and employment patterns. Legal and General fully support the objective which aligns with Welsh Government aspirations for the Cardiff Airport and St Athan Enterprise Zone.

Employment Land Provision
The Council’s adopted Economic Development, Employment Land and Premises SPG provides detailed guidance on how planning applications relating to employment land will be considered in support of the LDP strategy. The SPG reinforces the strong policy presumption in favour of retaining and delivering employment uses on allocated and existing employment sites, particularly those of regional economic importance such as land near Cardiff Airport and the Bro Tathan Enterprise Zone (i.e. Model Farm).
Model Farm’s position within the Enterprise Zone, in proximity to Cardiff Airport, Bro Tathan Enterprise Zone and the Cardiff and Vale College development presents the opportunity to develop the area into a high-quality business cluster. These strategically located flagship sites are intended to stimulate inward investment and consolidate the role of the Vale of Glamorgan within the Cardiff Capital Region.
The Employment Land Study (March 2023) recognises the value of Model Farm in recommending its allocation in the RLDP. Accordingly, Policy SP14 – Employment Growth of the Deposit Plan consolidates this opportunity through allocating the Model Farm site as a major employment allocation. Legal and General agrees that the position of Model Farm as a major employment site within the employment hierarchy reflects its importance as a key area of investment and employment opportunity within the Vale of Glamorgan.

Delivery
The value that the Deposit Plan places on the development of Model Farm is wholly appropriate given its alignment with PPW, Future Wales and Welsh Government’s reaffirmed commitment to delivering Enterprise Zones in Wales.
Legal and General remain committed to delivering the proposal at Model Farm. In doing so, Legal and General intend to collaborate with other users in the Enterprise Zone to realise its full potential in driving economic development of the wider Cardiff Capital Region.

We'd ask that you consider the above omissions, deem that a firm Statement of Common Ground with DCWW similar to that of 2015 is required at this stage, and issue amendments to this draft RLDP to cover them.

Thank you for signposting me to the Infrastructure Delivery document. I see this falls short of detailing the new sewerage infrastructure central to unlocking the development of allocated sites stated in para.i
Para. 3.104 mentions SuDS to prevent surface water entering the sewer system, but nothing on WW's strategic plan for local authority schemes to divert existing highway drainage into surface water out of their sewers.
Para.3.105 says the obvious that capacity may not exist within the existing sewerage network, but does not include sewage treatment capacity and does not specify where it's lacking. There's a comment for NW Barry that pumping capacity "may"not exist.
Para.3.108 says capacity constraints at treatment works and improvements as being in the current AMP or not, so why not be specific on the programme to 2030 ?
We see no mention of the Vale's Bathing beaches (several new ones) and policy to ensure sewage discharges do not undermine attaining Bathing Water standards; does this issue not belong in the RLDP, setting out divided responsibilities of VoG, NRW and DCWW (cf. Watchtower and Ogmore-by-Sea beaches closed 2024,5)?

On specifics, KS4 and KS5 say of capacity limits at West Aberthaw works that "DCWW has confirmed that upgrades are planned as part of the AMP8 programme 2025 and 2030". Can you provide documents on this?
WW said in 2015 they "planned" upgrades so questions are obvious - is the W.Aberthaw upgrade still not programmed and committed? Are the plans sufficient to take the much bigger numbers of homes now planned. Will land purchase and planning consent be needed? Will the developers proposing local sites have to pay via S.106?
On Model Farm, WW said the developer would have to undertake a sewerage HMA which L&G have been unwilling to progress, doubtless because their Viability Assessment showed the development was uneconomic. Such an HMA may show the need for sewer links across unexplored land, possibly uncovering archaeological constraints, causing delays of several years.
It seems you have not followed Council's Methodology based on the Development Plans Manual
to require this developer to reappraise existing LDP site allocations without extant planning permission through the candidate site assessment process.
I don't see that the Employment Land Study indicating (3.1) Model Farm to be a "realistic development proposal" over-rides the DPM guidance on examining viability constraints, so is this decision documented, please ?
In view of the response deadline, we look forward to a timely response. We'd ask that you consider the above omissions, deem that a firm Statement of Common Ground with DCWW similar to that of 2015 is required at this stage, and issue amendments to this draft RLDP to cover them.

It is considered that the Model Farm (Policy SP14(2)) Employment allocation should not be rolled forward into the Replacement LDP, and rather it would be more appropriate to de-allocate for sites with much more certainty.

Boyer have prepared and submitted the following representation on behalf of The Stevens Family in response to the current Vale of Glamorgan Replacement Local Development Plan (RLDP) 2021- 2036 Deposit Plan Consultation.

As you will be aware previous representations were submitted on behalf of The Stevens Family between 2019 and 2024 in response to the Quashed outline application submitted on behalf of Legal & General, and subsequent Appeal, in relation to the proposed Parc Busness Porth Cymru (PBPC) Business Park on land at Model Farm, Port Road, Rhoose (Ref: 2019/00871/OUT).

It is in this context upon which these representations, outlined below, are specifically made in relation to the Deposit Plan, and should also be read in conjunction with the previous 2024 Preferred Strategy representations relating to the proposed identification of the 44.75ha (net) Land South of Port Road, Rhoose (Model Farm) as a rollover Major Employment Allocation within Employment Growth Policy SP14(2).

As identified in previous correspondence, The Stevens Family does not object in principle to the provision of employment land within the Vale of Glamorgan, nor to the overarching objective of supporting economic growth and job creation. However, serious concerns remain as to whether the Model Farm site (SP14(2)) can realistically and credibly be relied upon as a deliverable employment allocation within the emerging RLDP period. These concerns relate to matters of soundness, deliverability, viability, market demand and unresolved technical constraints, as required to be assessed under national policy and guidance.

A summary of our main representations are as follows:
- The Stevens Family question the need for Model Farm to be included in the provision for 182 net ha of employment land for the requirement of 67.8 ha under Policy SP14. If the rollover allocation at Model Farm (Policy SP14(2)) was removed, then the provision would still allow for nearly doubling the projected employment land needs.
- Significant concern is raised regarding the ‘rollover’ Land South of Port Road, Rhoose (Model Farm) Employment Allocation (as part of SP14: Employment Growth) as deliverability is not sufficiently demonstrated by the Council and Representors. Currently there is significant ambiguity regarding the actual delivery, contrary to the Welsh Government’s Development Plans Manual (DPM) Edition 3 requirements.
- The proposed Model Farm allocation is currently subject to an Appeal, having had the previous planning applications quashed by the High Court.
- It is inappropriate to allocate an employment site which has been proven to be unviable through detailed independent assessment which predicted a loss of £10,405,000 before interest, or £34,508,455M if interest costs were payable at 5%.
- Supporting evidence confirms that whilst the Representors suggest they remain committed, there is a huge contradiction as they also suggest that they are taking a “long-term view” about when the scheme might come forward.
- Serious questions are raised in terms of the employment demand and delivery for a 161,834 sqm floorspace development considering the current available space, low uptake over the last decade and availability of more attractive and better connected alternatives.
- When assessed against the Tests of Soundness CE2 & CE3, Policy SP14(2) fails to adequately justify Model Farm’s continued inclusion in the Deposit Plan.
- There are a number of technical constraints which have not been addressed sufficiently via the planning application process, and these simply cannot be left to roll forward to the Local Development Plan.

Policy SP14 – Economic Growth
It is acknowledged that the RLDP must make adequate provision for employment land to meet forecast economic needs over the plan period and that a range of sites of differing scales and uses will be required.

Within the Preferred Strategy, Policy SP13 – Economic Growth outlined that the RLDP makes provision for 168 net ha to meet the projected employment land needs of 67.8 ha of employment land, including for B1 (Office and Light Industry), B2 (General Industries) and B8 (Distribution and Storage) employment uses which has the potential to support an additional 5,338 jobs over the plan period.

From a review of the current Deposit Plan, it is noted that employment growth is now assessed under Policy SP14 and that whilst the provision of jobs has not increased, The Stevens Family wish to highlight that the provision of proposed employment land has in fact increased to 182 ha. This is a result of an increase at both the major employment allocations at Bro Tathan Aerospace and Business Park (from 48.5 to 66.7 ha net) and Land to the South of Junction 34 of the M4, Hensol (29.59 to 36.23ha net).

Furthermore, the local employment allocations have also altered from the Preferred Strategy with, Atlantic Trading Estate, Barry (reduced from 6.21ha to 1.59 ha net); Vale Business Park, Llandow (reducing from 12.4 to 10.9 ha net); and Land at Llandow Trading Estate (1.85 ha net) replacing Land to the South of Junction 34 M4 Hensol (Area D 6.64 ha net).

Given this change, The Stevens Family question the actual need for SP14(2) Land south of Port Road (Model Farm), Rhoose. The total amount of employment space within the Vale has increased by 14 net ha by virtue of the amendments to Policy SP14, and in fact without the allocation of Model Farm would still provide 137.25 net ha which would still allow for nearly doubling the projected employment land needs of 67.8 ha of employment land.
Continued RLDP ‘Rollover’ Allocations

It is acknowledged that the RLDP must make adequate provision for employment land to meet forecast economic needs over the plan period and that a range of sites of differing scales and uses will be required. However, as noted above The Stevens Family consider that this can adequately be met without Model Farm. They reiterate some serious concerns over the deliverability of the rollover allocation, for reasons discussed below.
Welsh Government’s Development Plans Manual (DPM) Edition 3 specifies that “Allocations rolled forward from a previous plan will require careful justification for inclusion in a revised plan, aligning with PPW. 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 (Boyer emphasis). The sites should be subject to the same candidate site process requirements as new sites i.e. they must be demonstrated to be sustainable and deliverable”. Given that these factors are clearly set out within the latest version of the DPM reinforces their importance for the Welsh Government and the on-going need for Local Planning Authority’s to demonstrate deliverability.

Having reviewed both the Preferred Strategy and the current Deposit Plan background technical evidence base there is nothing to indicate that the circumstances surrounding the Model Farm (Policy SP14(2)) have materially improved since the site was previously allocated. The site remains undelivered, subject to planning uncertainty following the quashing of the previous permission and current Appeal process, as well as being constrained by unresolved technical and infrastructure issues. The continued allocation therefore represents a rollover in the strictest sense, without the justification required by national policy.

Furthermore, Paragraph 6.270 of the Deposit Plan outlines that ‘Land south of Port Road (Model Farm) Rhoose is currently subject to an appeal for non-determination of an outline planning application for a B1, B2, B8 Business. If the appeal is allowed (Boyer emphasis), the site is anticipated to deliver 1.7 million sq. ft of Class B1, B2 and B8 offices, light industrial and warehousing and distribution units, alongside car parking, landscaping, drainage infrastructure and biodiversity enhancement works which include land for expansion of Porthkerry Country Park to the south.

Clearly, the Quashed decision notice and the subsequent Appeal (which has been significantly delayed and only now looking to reopen in late March 2026) are important factors in the delivery of the employment allocation.
The Council, in their own words, note that the outcome of the Appeal impacts the anticipated delivery and therefore no decisions on the site’s acceptability nor allocation should be taken forward until the Appeal is determined. This may not fit with the Council’s timeframe for the RLDP, however the level of ambiguity on the actual delivery is so significant as to impact on the Council’s ability to deliver their employment land and jobs over the plan period.
The distinct lack of actual timeframes and delivery is further outlined in the supporting Employment Land Study (March 2023 BP12) document. Paragraph 5.40 outlines that ‘Model Farm is an employment proposal for Legal and General owned land in the east of the Land adjacent to Cardiff Airport and south of Port Road, Rhoose… Agents for Legal and General have confirmed that the investor remains committed to a development here but is taking a long term view about when the scheme might come forward (Boyer emphasis). It still sees strong potential here for a high-quality business cluster reinforced by Cardiff and Vale College’s investment nearby. It has stated that there is a development partner for the project.
Paragraph 3.9 of the Employment Supplementary Paper (November 2025 BP12A) further outlines that ‘Consideration will be given to the outcome of the Appeal decision and any implications this may have’.

The lack of evidence for the delivery is further illustrated in the Candidate Site Assessment at Preferred Strategy Stage (October 2023 BP 18) background paper in regard to Candidate Site 551 – Model Farm. The RAG Analysis system to assess sites against the Preferred Strategy (Appendix 2 of BP18) highlights that developer interest is coloured Amber which means that the Council themselves consider that the site accords with the strategy but there are some concerns around deliverability that would need to be addressed.

Evidently, there is a distinct lack of surety on the deliverability of the site, both from the current Appeal and the promoters in terms of timeframe. Moreover, what is conveniently ignored in all of the RLDP assessment is the unviable nature of the proposed allocation.

Viability/Deliverability
The Stevens Family have previously provided detailed comments on this issue in relation to the planning application (Ref: 2019/00871/OUT), however they continue to consider that the matter is of significant relevance to the proposed rollover allocation at Model Farm through the RLDP.
Given there has been no further information provided between the previous Preferred Strategy consultation and the current Deposit Plan, The Stevens Family reiterate that viability is a core determinant of deliverability and must be addressed at plan-making stage. The previously published RPS & Sutton Viability Assessment as well as the Avison Young independent review provided independent viability assessments relating to the quashed planning application and remain highly material. Those assessments demonstrated a substantial and structural viability deficit, even before accounting for interest costs. When realistic assumptions were applied, the deficit increased significantly, confirming that the scheme is not commercially viable.

Crucially, the evidence also illustrated that the development could not support policy-compliant infrastructure and mitigation requirements. Significant reductions in sustainable transport contributions and other obligations were required even to marginally improve viability. This is not a minor viability issue but a fundamental failure to support policy-compliant development.

In summary, the independent viability assessments prepared in relation to the site demonstrate that:
• The scheme generates a significant financial deficit (c. £10.4m without interest and c. £34.5m with interest);
• The development cannot viably support policy-compliant infrastructure or mitigation contributions; and
• Delivery would be dependent on substantial public sector intervention or gap funding, for which no commitment exists.

No updated viability evidence accompanies the Deposit RLDP to demonstrate that circumstances have materially changed. As viability is a core component of deliverability under the Development Plans Manual (Edition 3), the allocation cannot be considered effective or considered justified or deliverable.

Consequently, the demand, and indeed the appetite to construct such a development is highly questionable. Serious concern is raised as to why this information is not taken into consideration in Employment Land Study (March 2023 BP12) document and the update (November 2025 BP12A) as there is clear evidence of the unviable nature of the allocation.
The Stevens Family have considerable business/ commercial experience and seriously question why such an unviable and undeliverable allocation would be maintained, unless it was for a future alternative use.

Employment Need
The Stevens Family maintain that the scale of employment development proposed at Model Farm is not supported by historic or current market evidence.

The Employment Land Study (March 2023 BP12) demonstrates very modest employment floorspace take-up within the Vale of Glamorgan over the past decade. When compared to the quantum proposed at Model Farm alone, it is clear that the allocation assumes an absorption rate significantly exceeding historic trends. The Employment Land Study records that over the past decade approximately 83,950 sqm of industrial floorspace has been transacted across the Vale of Glamorgan. This is only around half of the floorspace proposed at Model Farm alone. Even under optimistic assumptions, the proposed floorspace would take well beyond the plan period to be absorbed. This introduces a high risk that the site would remain undeveloped or only partially developed by 2036, undermining the effectiveness of the RLDP. This is further Page evidenced by the Agents for Legal and General confirming that the investor is taking a long-term view about when the scheme might come forward. Demand for large-format B2 and B8 units has been particularly limited. Transactions for units exceeding 5,000 square metres are rare within the Vale of Glamorgan. The allocation therefore relies heavily on speculative demand that has not historically materialised. When assessed against average annual take-up rates:
• The proposed floorspace would take in excess of 20 years to be absorbed by the market, even if Model Farm were the only site available.
• This timeframe extends well beyond the plan period, directly conflicting with the requirement for effective delivery.

The evidence further shows that:
• There has been very limited demand for large-scale units exceeding 5,000 sqm within the Vale of Glamorgan;
• Only a single transaction of this scale occurred over a ten-year period; and
• Several of the unit sizes envisaged at Model Farm significantly exceed historic demand patterns.
In the surrounding context, the Cardiff Capital Region (CCR) £36 million investment at Aberthaw Power Station, brings into doubt the desirability of the Model Farm. The Study states that CCR have received a range of suggestions from business for uses on the site and is ultimately a more attractive opportunity for businesses and operations that Model Farm. Whilst it is acknowledged that there are on-going works required, the clear investment is evident at Aberthaw, which is in stark contrast to Model Farm and L&G’s stance of a very long term view about when the scheme might come forward.

Test of Soundness
When assessed against the Tests of Soundness, Policy SP14(2) fails in several key respects.
• The allocation is not justified (CE2) because it is not supported by robust or proportionate evidence on viability or market demand and fails to demonstrate a substantial change in circumstances required for a rollover allocation.
The continued allocation of Model Farm is not justified by proportionate or robust evidence and the Development Plans Manual (Edition 3) is explicit that rollover allocations must demonstrate a substantial change in circumstances and be subject to the same scrutiny as new sites. No such change has been evidenced. Instead:
• The site remains undelivered;
• Viability evidence demonstrates a substantial financial deficit;
• Market demand assumptions appear optimistic when assessed against historic take-up data; and
• Multiple technical and environmental constraints remain unresolved.
In this context, the allocation of the site under Policy SP14(2) cannot be considered justified.
• The allocation is not effective (CE3) because there is no reasonable prospect of delivery within the plan period, and the site remains constrained by viability deficits, weak demand and unresolved delivery uncertainty.
For a plan to be sound it must be effective and capable of being delivered. The evidence demonstrates that this test is not met in respect of Model Farm (Policy SP14(2)).
The Employment Land Study (March 2023 BP12) and the Employment Supplementary Paper (November 2025 BP12A) confirm that the site promoter is taking a long-term view regarding delivery. This position is fundamentally incompatible with plan-making requirements, which demand a reasonable prospect that allocated sites will come forward within the plan period. There is no delivery programme, no agreed phasing strategy and no evidence of imminent implementation.
The Council’s own Candidate Site Assessment (October 2023 BP 18) assigns the site an “Amber” rating for deliverability, acknowledging unresolved concerns. This confirms that uncertainty persists and that the site cannot be relied upon to deliver employment land between 2021 and 2036.

Taken together, these factors demonstrate that there is no reasonable prospect that the Model Farm site will deliver employment development between 2021 and 2036. As such, the allocation cannot be considered effective.

Technical Constraints
In addition to viability and market demand, The Stevens Family have continually reiterated that there are a number of technical constraints which have been highlighted in relation to the planning application, and which materially affect deliverability and reinforce concerns regarding soundness.

Drainage
Drainage remains a fundamental constraint. Concerns have previously been raised by statutory consultees (Dwr Cymru Welsh Water - DCWW) regarding insufficient capacity within existing foul sewerage infrastructure to accommodate development of this scale. A suitable point of connection has not been clearly identified, and there is no confirmed strategy demonstrating how capacity issues will be resolved.

The absence of a comprehensive Hydraulic Modelling Assessment is a significant evidential gap. For a site of this scale, drainage capacity is a prerequisite for delivery. Without certainty on foul and surface water solutions, the site cannot be considered deliverable.

Furthermore, proposed foul drainage routes continue to cross third-party land, including private residential land in the ownership of The Stevens Family. There is a significant conflict in the proposed route as it passes directly through an area of The Stevens Family land which has an extant consent for the reinstatement of a range of domestic garden buildings; the reinstatement and extension of adjoining south facing greenhouse; and the reconstruction of the terraced cold frames (application ref: 2020/01007/FUL – Granted November 2020). Following the discharge of relevant conditions the works on the reinstatement has commencement and is nearing completion. Clearly there is a significant conflict and it would be wholly unreasonable for The Stevens Family to undo any consented works for the sake of any future proposed drainage.

Furthermore, the route impacts sensitive ecological areas (including a SINC and Ancient Woodland), introducing legal, environmental and deliverability risks that have not been resolved at plan-making stage.
Transport

The site is acknowledged to be heavily reliant on off-site transport infrastructure improvements to mitigate its impact and promote sustainable travel. However, the viability evidence demonstrates that the development cannot support policy-compliant transport contributions.
The reliance on land transfer in lieu of financial contributions does not provide certainty that necessary infrastructure will be delivered, nor does it demonstrate compliance with national sustainable transport policy. This creates a clear disconnect between policy aspirations and realistic delivery.

A strategic employment allocation that cannot viably deliver sustainable transport mitigation is inherently unsound.

Ecology
The site is subject to significant ecological constraints, including impacts on SINCs, Ancient Woodland and habitats supporting protected species. Previous ecological assessments provided by The Stevens Family have identified the potential presence of species such as Great Crested Newts and Dormice, and concerns remain regarding habitat loss and fragmentation.

These constraints were reflected in the Candidate Site Assessment, where the site scored “Red” in relation to impacts on SINCs and Local Nature Reserves and “Amber” across a wide range of environmental criteria. The scale of mitigation required has direct implications for both viability and deliverability and has not been adequately addressed in the evidence base.

Given the significance of the ecological constraints then it is considered that there are still further works required to evidence the allocation of the site. In particular this relates to the concerns around the Habitat Suitability Index (HSI), assessment of the on-site pond for its suitability for Great Crested Newts (GCN) as well as Dormice.

It is considered that this information should be provided now as part of the allocation process as it has significant implications.

Furthermore, The Stevens Family also note that the recently passed Environment (Principles, Governance and Biodiversity Targets) (Wales) Bill establishes a strengthened framework for environmental protection in Wales by embedding key environmental principles such as the precautionary principle, prevention of environmental harm, rectification at source and the polluter pays principle into Welsh law and requiring public authorities to apply them in policy and decision-making. It also introduces a new environmental governance system, including the Office of Environmental Governance Wales, and enables Welsh Ministers to set legally binding biodiversity targets aimed at halting and reversing the decline of nature, increasing native species and improving ecosystem resilience.

In this context, the proposed employment allocation of Model Farm, under Policy SP14(2), should be carefully reconsidered where there is no clear demonstrable need for the allocation. The principles embedded in the Bill emphasise preventative action and the integration of environmental protection into policy decisions, meaning that avoidable harm to biodiversity should be prevented wherever possible. Where development would result in the loss or degradation of habitats and ecological networks, and the allocation is not required to meet identified employment needs, protecting the site from development would better align with the Bill’s objectives to safeguard ecosystems and contribute to reversing biodiversity decline in Wales.

Cumulative Impact of Constraints
Individually, each of the above constraints presents a challenge. Collectively, they demonstrate that Model Farm is a highly constrained site with no clear pathway to resolution. The cumulative impact of drainage, transport, ecological and environmental constraints further undermines the assumption that the site can be viably and effectively delivered within the plan period.
Candidate Site Assessment at Preferred Strategy Stage (October 2023 BP 18)

As highlighted, the proposed Candidate Site 551 (Model Farm) has undertaken a RAG Analysis system to assess sites against the Preferred Strategy (Appendix 2 of BP18). Whilst it has already been noted that the site scored Amber in terms of deliverability (meaning that the Council themselves consider that the site raises concerns around deliverability that would need to be addressed), there are a number of other concerns raised where there is a distinct lack of evidence for the delivery of the site.

In particular, it is illustrated that the site scored Red (does not accord with the strategy) in regard to the direct impact on surrounding SINCs and Local Nature Reserves and is a significant factor that needs addressing to allow any rollover allocation.

Furthermore, in terms of the Amber scores, the following are highlighted as raising concern for the Authority and which need to be addressed:
- Agricultural Land
- Mineral Resource
- Green Wedge Designation
- Special Landscape Areas
- Contaminated Land
- Existing Physical Site Constraints
- Historic Environment

Given the significant amount of Amber scores, it is clearly demonstrated that the Model Farm site has a number of issues which need to be fully assessed and with no apparent solutions or updates, then The Stevens Family seriously question the validity of the proposed rollover allocation at Model Farm.

Summary
In summary, The Stevens Family have strong reservations regarding the proposed rollover allocation at Model Farm under Policy SP14(2), many of which have been previously raised and continue to be unaddressed by the evidence base underpinning the Deposit Plan.
It has been demonstrated that even without the allocation of Model Farm the Deposit Plan would still provide 137.25 net ha which would be nearly double the projected Vale employment land needs of 67.8 ha.
There are significant deliverability concerns, not only with the evidenced lack of viability (as independently assessed), but also demand. It is considered that when assessed against the Tests of Soundness, Policy SP14(2) – Model Farm, fails in several key respects.
In particular, the proposed rollover allocation is not justified under Test of Soundness CE2 because it is not clearly supported by robust or proportionate evidence on viability or market demand and fails to demonstrate a substantial change in circumstances required for a rollover allocation.
Furthermore, the allocation is not effective under Test of Soundness CE3 because there is no reasonable prospect of delivery within the plan period (as suggested by the promoters that they are taking a long-term view), and the site remains constrained by viability deficits, weak demand and unresolved delivery uncertainty.

The Stevens Family consider that the rollover allocation of the site is contrary to the Welsh Government’s Development Plans Manual (DPM) Edition 3 and does not substantially evidence any deliverability.

It is considered that the Model Farm (Policy SP14(2)) Employment allocation should not be rolled forward into the Replacement LDP, and rather it would be more appropriate to de-allocate for sites with much more certainty.

Moreover, there still remains concerns regarding drainage, transport, and ecology and the distinct lack of any evidence base update to prove otherwise. This is supported by the Councils own assessment as part of the Candidate Site Assessment at Preferred Strategy Stage (October 2023 BP 18) background paper which maintained an Amber score for a number of issues which, by the Councils own admission, identifies concerns around deliverability that would need to be addressed.

Overall, there remains serious questions as to how such an unviable scheme can even be considered for a rollover allocation.

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