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

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

The site does not appear viable. The flooding problems from the land above are difficult and costly to resolve. They relate to the unresolved flooding on Llandough Hill spilling over the Penarth Road. No drainage solution has been reached so the development is on-hold. The developer already demanded reduced S.106 with small fraction of affordable homes. For "deliverability" (WGovt manual DMM), it needs to be subject to a Stage 3: Site Specific Viability Assessment, in order to ensure that sites which progress to allocation within the RLDP can satisfy new policy requirements and remain viable and deliverable.

Cosmestutline application as approved in March 2024 is still not final. on housing development has not been finalisd. The oEven if that outline was signed, the details are not. It’s included in the RLDP as a landbank site to be rolled forward.
The RLDP inclusion for rolling forward is contrary to the DMM requirement that site-specific allocations have delivery/viability evidence. A Stage 3: Site Specific Viability Assessment is needed, in order to ensure that sites which progress to allocation within the RLDP can satisfy new policy requirements and remain viable and deliverable.
We attach fuller argument.

An alternative site is needed for the re-build of Richard Gwyn school. Flooding is a strong constraint on the idea of rebuilding on the same site. No assessment re predicted higher flood levels; no solution for walking access via the tunnel during flooding; no assessment of completing the active travel access from Coldbrook with a tunnel to meet WGovt standards.
We anticipate the WGovt rejects the rebuild on the present site on grounds of flooding. This site at Pencoedtre is one of the few alternatives. It was school land so the education departement should reclaim it for new RichardGwyn.

The KS2 requirements say: a secondary access closer for emergencies as well as pedestrians and cycling. Highways asked the applicant to respond but they were unsuccessful
# no drawings of the sole suggested access onto Cardiff Rd using the farm gateway by Wayside cottages
# blockage of access to carparking at one side, removal of parking space at the other
# limited visibility with roadside cottages and narrow pavement, roadway too narrow for a turning lane
# reported impossible to insert cycling and pedestrian lanes on CardiffRd to meet Active travel minimum standards so gave up.
The development is unviable.

- Essential that viability information is provided for all Candidate Sites
- We do not find this reuirement has been met for All sites
- 3.44 PPW sets out the policy …housing delivery in the development plan process. A key element of this is ensuring financial viability is assessed at the candidate site stage. The site promoter (LPA, land owner and/or developer) must carry out an initial site viability assessment and provide evidence that sites can be delivered. As required by national policy, all candidate sites are subject to a viability assessment.

- Strategic Growth Area: Focuses on settlements with good transport links to reduce car dependency.

You say this but Rhoose to St Athan fail it
- Rhoose: Key site for 339 homes north of the railway and employment development, including land east of Cardiff Airport (16.3 ha) and south of Port Road (44.75 ha).
- St Athan & Llantwit Major: Targeted for residential development, including 235 units near Eglwys Brewis Road and 105 units at St Athan Road., Clive Rd 51, Church Farm 500, west of St Athan 600
-
- Can’t be called “good transport” without the railway – more frequent than hourly and with stations at Eglwys Brewis and St Athan. The 304 bus taking over an hour to Cardiff isn’t “good”. road transport is caught in snarl-ups at Weycock Cross and Culverhouse Cross.
- Single access key sites and others over 100 homes are not deliverable

- Essential that viability information is provided for all Candidate Sites
- We do not find this reuirement has been met for All sites
- 3.44 PPW sets out the policy …housing delivery in the development plan process. A key element of this is ensuring financial viability is assessed at the candidate site stage. The site promoter (LPA, land owner and/or developer) must carry out an initial site viability assessment and provide evidence that sites can be delivered. As required by national policy, all candidate sites are subject to a viability assessment.

- Strategic Growth Area: Focuses on settlements with good transport links to reduce car dependency.

You say this but Rhoose to St Athan fail it
- Rhoose: Key site for 339 homes north of the railway and employment development, including land east of Cardiff Airport (16.3 ha) and south of Port Road (44.75 ha).
- St Athan & Llantwit Major: Targeted for residential development, including 235 units near Eglwys Brewis Road and 105 units at St Athan Road., Clive Rd 51, Church Farm 500, west of St Athan 600
-
- Can’t be called “good transport” without the railway – more frequent than hourly and with stations at Eglwys Brewis and St Athan. The 304 bus taking over an hour to Cardiff isn’t “good”. road transport is caught in snarl-ups at Weycock Cross and Culverhouse Cross.
- Single access key sites and others over 100 homes are not deliverable

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

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

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

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

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

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