ANNEX 1
Preface

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

The representations are structured into the following sections:

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

SECTION 1. Response to the Deposit Plan

Distribution of Growth

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

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

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

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

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

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

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

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

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

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

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

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

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

Housing Supply

RLDP Allocations - Key Sites

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

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

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

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

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

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

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

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

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

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

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

Windfall Sites

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

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

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

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

St Athan Train Station

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

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

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

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

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

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

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

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

Rolled forward LDP Sites

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

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

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

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

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

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

Housing Delivery Rate Assumptions

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

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

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

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

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

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

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

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

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

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

HBF: Estimates of Housing Need

HBF: Actual Delivery vs Estimates of Need

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

Affordable Housing-Led Sites

HG4 - Rural Affordable Housing Led Sites

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

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

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

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

Securing further delivery of Affordable Units

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

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

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

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

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

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

Comments on Specific Policies

HG5 - Affordable Housing Exception Sites

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

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

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

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

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

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

Deliverability of the Site

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

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

In summary, the site promoters:

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

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

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

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

Land at Ystradowen (Site ID: 4060)

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

The second section/paragraph of the assessment states:

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Summary and Conclusion

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

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

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

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

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

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

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

Summary of These Representations

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

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

Preface

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

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

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

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

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

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

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

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

Timing Assumptions underpinning the Trajectory

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

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

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

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

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

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

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

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

Housing Delivery Rate Assumptions

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

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

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

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

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

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

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

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

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

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

Status & Standing of Sites included in the Trajectory

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

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

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

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

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

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

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

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

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

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

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

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

St Athan Train Station

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

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

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

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

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

Geographic distribution of the ‘new’ sites / provision

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

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

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

Other Housing Allocations

Land south of Clive Road, St Athan

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

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

Affordable Housing Led Allocations

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Access to Services and Facilities

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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