Delete the policy.

This policy in part duplicates the previous policy SP4 and a number of other policies in the plan; it is not considered necessary. This duplication causes confusion and extra work for those submitting planning applications.

HBF considers the vision is far too wordy to be clear or measurable.

The vision mentions a Marina; should this be removed following recent funding decisions?

The current plan was adopted before Future Wales identified the Vale of Glamorgan as a national growth area; therefore, planning to continue delivering at the same average rate as before this change in status clearly lacks ambition.

Para 5.8, there is no mention that the ten-year period used includes the pandemic and a significant increase in building costs, both of which slowed housebuilding rates and brought down the average annual delivery rate.

HBF suggests a higher rate of annual delivery could be achievable, as demonstrated by previous annual completions of 917 at its highest point and with six of the ten years higher than 526. This is supported by the Council's document BP7 Housing and Employment growth options, which identifies the 5yr build rate average (2016-2021) as 780 units, again well above that currently suggested by this plan.

In order to meet the high demand for affordable homes, a larger housing target would deliver more affordable homes, as each site would be subject to a percentage contribution of affordable homes.

Although it is right for the plan to be as sustainable as possible, a balance also has to be achieved, due to the position of the Vale of Glamorgan so close to Cardiff and Bridgend, there are always going to be job opportunities outside of the authority. Both Cardiff and Bridgend have very good linkages by rail, so such commuting can easily be achieved sustainably. In fact, the plan has said that its strategy is to place new development close to these public transport facilities. HBF consider that the level of employment planned within the Vale of Glamorgan should not be a limit on the level of housing proposed. This is an example of where cross-boundary issues need to be given more consideration, particularly due to the Vale's role as part of the wider national growth area.

The latest housing needs data released by the Welsh Government shows a significant increase in the need for affordable housing to meet unmet need and an increase in annual arising need. These figures both exceed those currently in Future Wales. This new data means the plan should increase its housing requirement to take account of this increased housing need. HBF suggests this adds to the previous reasons why the housing requirement figure should be increased.

In terms of detailed wording, HBF questions whether a plan can deliver. It can allocate land to allow for delivery, but the plan can't actually deliver.

In line with the comments already made on point 1 of the sustainable growth strategy, the HBF considers that the level of housing proposed lacks ambition and is not in line with the Vale of Glamorgan's position as a regional growth area in Future Wales.

The words 'including a minimum of 3,070 affordable homes' should be changed to ' a target of 3,070 affordable homes'. The reason for this is that a minimum suggests that it should be more; however, other relevant housing policies are worded to provide for a defined number or target. This change in wording does not stop more from being delivered.

The approach to limiting housing development, other than affordable-led schemes with a minimum of 50% affordable, in the identified towns and villages, restricts the ability of SME developers and, therefore, the range of homes that might be provided by the plan.

The HBF questions the wording under the heading 'Infrastructure', which is not appropriate wording, as it is part of the plan's role to identify the necessary infrastructure to deliver the level of growth proposed. The provision of infrastructure, which is necessary for development, is covered by other policies in the plan.

Why is the housing flexibility allowance figure not included in this policy?

Amend the wording of the supporting text and policy accordingly.

Remove the requirement for a placemaking statement.

The HBF objects to the phrase at para 6.33 'Development will be favoured'. Community engagement is already included in the planning process, and consultations take place during the LDP at various stages, so any development on an allocated site will have already been consulted on. There is also a requirement for a PAC to take place prior to an application being submitted and statutory consultation by the LPA once the application is submitted. If the place plans cover the application site, these have also undergone consultation. There is no justification for the LPA to suggest that one application will be favoured more, just based on the level of additional consultation which has taken place.

Para 6.34 The following wording should be added at an appropriate point: 'the Placemaking Statement should be proportionate to the scale of the development proposed.' The type of placemaking that can be achieved on each site varies considerably for several reasons, including the size/scale of the development.

The HBF objects to the requirement for a 'place-making statement' as it is unnecessary; all of the information required is already required to be included in a Design and Access statement, which is a mandatory requirement of a planning application. The requirement for unnecessary additional documentation solely adds delays to the planning process.

Point 6 should be reworded as follows:

'Contribute to new or enhanced transport services and facilities where appropriate.'

Clear criteria should be set for when the various highway reports are required to be submitted with an application.

Point 6 of the policy should be reworded, as it is not for a developer to provide transport services, at best and only where required as a direct result of the proposed development; they can contribute towards transport services provided by others.

The wording 'As appropriate, new development proposals will be required to provide Transport Statements, Transport Assessments and Travel Plans to ensure the delivery of travel choice and sustainable opportunities for travel.' is considered to be too vague. There is no clarification on when it would be 'appropriate' and in what scenario would one or all of the reports mentioned be required.

Further, the supporting text para. 6.187 does not really provide any specific guidance to support this policy requirement. At what stage in the planning process would it be decided that one or all of these documents are required, and based on what criteria? This lack of clarity could lead to delays in the delivery of new homes and uncertainty for developers.

The following wording: 'The delivery of new or improved infrastructure must be undertaken in a timely and coordinated manner to meet the needs of existing and planned communities prior to, or from the commencement of, the relevant phases of development.'
Should be reworded to say that the timing of delivery will be discussed and agreed with developers on a site-by-site basis, with a preference for its delivery as early as possible.

The HBF questions the following items in the list:
- Welsh language facilities
- Employment opportunities and complementary facilities, including training and working hubs.
- Mitigation of Severn Estuary Recreational Pressure.

The requirement to provide welsh language facilities is considered onerous. How would a developer provide Welsh language facilities as part of a development? What would this mean in practice, and for how long would they be required? The HBF suggests that a contribution towards Welsh Language improvements would be more appropriate, and would allow for an instance, a financial contribution to support existing facilities. Such an approach is common across other LDPs.

In terms of the Welsh Language, the Council's Background paper BP30 concludes:
'The evidence presented in this background paper demonstrates that the Welsh language, while an important part of Wales’s cultural heritage, does not hold a position of significant cultural prominence within the Vale of Glamorgan and that the RLDP is unlikely to materially influence the status, use or vitality of the Welsh language within the area.'

This would suggest that the requirements of the plan should not be overly onerous.

Concerning employment opportunities, the use of the phrase 'complementary facilities' is very vague. With regard to the example of the provision of training and working hubs, it is unlikely to be achievable on the scale of the developments proposed in the plan. A contribution towards such facilities in the wider area is likely to be more achievable, helping support existing facilities, rather than creating more that last only for the length of the development.

Mitigation of Severn Estuary Recreational Pressure: It would be helpful in the supporting text to reference Policy DNP8 – SEVERN ESTUARY RECREATIONAL PRESSURE. Is there any information available on how this will be calculated?

The following wording: 'The delivery of new or improved infrastructure must be undertaken in a timely and coordinated manner to meet the needs of existing and planned communities prior to, or from the commencement of, the relevant phases of development.'
Should be reworded to say that the timing of delivery will be discussed and agreed with developers on a site-by-site basis, with a preference for its delivery as early as possible.

Remove the requirement to carry out a screening assessment.

If the screening requirement is retained, the threshold should be set higher, as this would be an overly onerous requirement for smaller sites below 100 units.

The HBF objects to the requirement to carry out a screening assessment relating to health impacts, as the plan has already considered the impact of the proposed developments on the health and well-being of communities through the strategic HRA and HIA and set out policies to address any concerns. Consequently, where a development is in line with policies in the local plan, a HIA should not be necessary for individual sites. Only where there is a departure from the plan should the Council consider requiring an HIA.

Further, if the developer complies with the other wording of the policy, then the development will have taken into account its impact on health, so why then carry out a screening assessment? The policy tests can be achieved without carrying out a screening assessment.

In terms of the requirement to complete a Healthy Placemaking Checklist, the policy refers to guidance in an SPG, which currently does not exist; this could lead to delays in the delivery of housing schemes. It also leads to uncertainty for developers who do not currently know what will be required. Placemaking is also required by other policies in the plan, and the health impacts of the plan have also been considered through the HIA process, so what additional information could such a document provide?

Increase flexibility to 15%.

Increase the number of dwellings on allocated sites and increase the range of site sizes allocated.

The housing requirement and the number of homes delivered through new allocations should be increased to make the plan more ambitious and align with Future Wales and the Vales' identified role as a national growth area.

The flexibility allowance should be increased to 15%. The Development Plan Manual 3 suggests 10% should be the starting point. A higher figure is considered appropriate due to the low level of new allocations and the limited number of key sites allocated in the plan. This means the plan has a heavy reliance on a small number of sites, which would suggest the need for greater flexibility provided through a range of additional smaller sites.

The HBF suggests that the words 'functionally related' should be removed from the bold text at the end of the policy. Although the principle of this final paragraph is supported, the flexibility which it provides to developers is, in part, removed by the wording above. It is accepted planning practice that where something can not be provided on site, an off-site alternative can be acceptable, subject to the appropriate controls. However, limiting this to 'functionally relates' is onerous and unnecessary to achieve the aims of the policy.