1 Vale of Glamorgan Deposit Replacement Local Development Plan

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Object

1 Vale of Glamorgan Deposit Replacement Local Development Plan

PGD1 - CREATING WELL DESIGNED AND INCLUSIVE PLACES

Representation ID: 5881

Received: 11/03/2026

Respondent ID: 538

Respondent: HBF

Sound? Yes

Welsh language effects:

None

Representation Summary:

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.

Comment

1 Vale of Glamorgan Deposit Replacement Local Development Plan

VISION (2021 - 2036)

Representation ID: 5882

Received: 11/03/2026

Respondent ID: 538

Respondent: HBF

Welsh language effects:

None

Representation Summary:

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?

Comment

1 Vale of Glamorgan Deposit Replacement Local Development Plan

SP1 – SUSTAINABLE GROWTH STRATEGY

Representation ID: 5890

Received: 11/03/2026

Respondent ID: 538

Respondent: HBF

Welsh language effects:

None

Representation Summary:

The plan lacks aspiration and does not provide a level of growth in line with the Vale's role as part of the national growth area identified in Future Wales.

The plan's role is to balance the 'need' for housing in a sustainable way, rather than limit delivery.

The plan's housing requirement is being limited by a level of delivery lower than the plan has previously achieved.

Delivering more housing will support economic growth and deliver more affordable homes.

The latest Welsh Government housing needs data requires an increase in the level of housing proposed.

Comment

1 Vale of Glamorgan Deposit Replacement Local Development Plan

SP1 – SUSTAINABLE GROWTH STRATEGY

Representation ID: 5891

Received: 11/03/2026

Respondent ID: 538

Respondent: HBF

Welsh language effects:

None

Representation Summary:

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?

Object

1 Vale of Glamorgan Deposit Replacement Local Development Plan

SP4 - PLACEMAKING

Representation ID: 5906

Received: 11/03/2026

Respondent ID: 538

Respondent: HBF

Sound? Yes

Welsh language effects:

None

Representation Summary:

The HBF objects to the phrase at para 6.33 'Development will be favoured'.

The following wording should be added at an appropriate point: 'the Placemaking Statement should be proportionate to the scale of the development proposed.'

Remove the requirement for a placemaking statement.

Object

1 Vale of Glamorgan Deposit Replacement Local Development Plan

SP10 - SUSTAINABLE TRANSPORT

Representation ID: 5911

Received: 11/03/2026

Respondent ID: 538

Respondent: HBF

Sound? Yes

Welsh language effects:

None

Representation Summary:

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.

Comment

1 Vale of Glamorgan Deposit Replacement Local Development Plan

SP13 - COMMUNITY INFRASTRUCTURE AND PLANNING OBLIGATIONS

Representation ID: 5914

Received: 11/03/2026

Respondent ID: 538

Respondent: HBF

Welsh language effects:

None

Representation Summary:

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?

Object

1 Vale of Glamorgan Deposit Replacement Local Development Plan

SP5 - CREATING HEALTHY AND INCLUSIVE PLACES AND SPACES

Representation ID: 5925

Received: 11/03/2026

Respondent ID: 538

Respondent: HBF

Sound? Yes

Welsh language effects:

None

Representation Summary:

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?

Object

1 Vale of Glamorgan Deposit Replacement Local Development Plan

SP6 - HOUSING REQUIREMENT

Representation ID: 5940

Received: 11/03/2026

Respondent ID: 538

Respondent: HBF

Sound? Yes

Welsh language effects:

None

Representation Summary:

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.

Object

1 Vale of Glamorgan Deposit Replacement Local Development Plan

SP20 - BIODIVERSITY AND ECOSYSTEM RESILIENCE

Representation ID: 5941

Received: 11/03/2026

Respondent ID: 538

Respondent: HBF

Sound? Not specified

Welsh language effects:

None

Representation Summary:

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.

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