Cyngor Bro Morgannwg
Vale of Glamorgan Council

Requested Action It is respectfully requested that: The allocation of Site SP4 KS2 be removed.

Objection to Allocation HG1 KS2 - Land North of Dinas Powys (SP4 KS2) This submission sets out an objection to the allocation of Site SP4 KS2 (Land North of Dinas Powys) within the Vale of Glamorgan Replacement Local Development Plan (RLDP). The allocation is considered unsound, inconsistent, and contrary to national planning policy, and is not supported by sufficient settlement-specific evidence.

1. Previously Rejected for the Same Constraints The site was previously assessed during the 2011-2026 LDP process (Site 1098/CS.1) and rejected at Stage 2 due to "insurmountable constraints." Similarly, candidate site 2036/CS.2 (Land at Eastbrook) was rejected on the grounds that development would: Represent unacceptable intrusion into the countryside Promote coalescence between Dinas Powys and Llandough Be subject to significant highway constraints No clear evidence has been provided to demonstrate that these constraints have been resolved.

2. Green Wedge Conflict & Risk of Coalescence The site lies wholly within the designated Green Wedge between Dinas Powys, Penarth and Llandough. The 2011 Green Wedge Background Paper identifies its purposes as: Preventing settlement coalescence Protecting open countryside Maintaining settlement identity Preserving the setting of built-up areas The RLDP's Integrated Sustainability Appraisal (2023) confirms Green Wedges continue to protect settlement integrity. Allocating ~250 homes on this land would materially reduce separation between Dinas Powys and Llandough, directly conflicting with paragraph 3.78 of Planning Policy Wales. Paragraph 3.64 of Planning Policy Wales requires Green Wedges to be "soundly based." No robust evidence has been presented to justify altering this designation. Once Green Wedge land is released, it cannot realistically be restored. Approval would create pressure for further incremental loss.

3. Inconsistent Candidate Site Assessment (BP18A) Background Paper BP18A shows clear inconsistencies. Site SP4 KS2 (Site 444) was progressed, while overlapping or adjacent smaller sites were rejected: Site 356 - Land east of Pen-Y-Turnpike Road (rejected due to Green Wedge harm) Site 419 - Land at The Grange (rejected due to Green Wedge harm) Site 423 - Land North Dinas Powys (rejected due to sporadic countryside intrusion) These sites are smaller and would pose less risk of coalescence than SP4 KS2. The differential treatment lacks explanation and undermines transparency and credibility of the assessment process.

4. Highways, Traffic & Sustainable Transport Previous Council findings confirmed the Station Road/Cardiff Road junction was operating at capacity. The main road through Dinas Powys is at a standstill in both directions for much of the day. The traffic coming from Penarth will back up due to the increased traffic (approx 500 extra vehicles on the road) resulting from 250 additional houses. The RLDP does not provide: Detailed updated junction modelling Cumulative traffic impact assessment Funded and deliverable mitigation measures Planning Policy Wales requires development to avoid severe residual impacts on the road network and promote sustainable transport. The Plan relies on aspirational measures without demonstrating modal shift sufficient to offset ~250 additional dwellings.

5. Air Quality Concerns Air quality monitoring was undertaken adjacent to open fields, where pollutant dispersion is naturally favourable. The survey effectively demonstrated acceptable limits because open land allows dissipation. Introducing 250 homes would: Alter dispersion dynamics Increase vehicle movements Create potential pollutant accumulation No post-development dispersion modelling or cumulative emissions modelling has been presented. There has been no focused monitoring at sensitive receptors such as local primary schools during peak term-time traffic.

6. Flood Risk & Drainage (TAN 15) Parts of the Eastbrook area have known drainage and flood constraints. The RLDP: Defers mitigation to application stage Does not provide robust cumulative runoff modelling Does not clearly demonstrate compliance with current TAN 15 requirements including climate change allowances The site proposed for development floods after the slightest rainfall. If this development did go ahead the water would be diverted toward the rest of the village who already experience severe flooding and the loss and distress that comes with that.

7. Wastewater & Sewerage Infrastructure There is no published confirmation from Dwr Cymru Welsh Water confirming network and treatment capacity. The Plan does not identify: Required upgrades Funding mechanisms Delivery timescales Infrastructure sequencing Reliance on future upgrades without secured delivery undermines effectiveness.

8. Schools & Community Infrastructure Previous assessments noted limited school and medical capacity. Section 106 education contributions from earlier developments (including Taylor Wimpey funding originally linked to nursery and primary provision) have not resulted in clear, transparent delivery of additional school capacity. Subsequent housing approvals (e.g. Bendricks / Hayes Road) have added pressure without clear education funding alignment. The RLDP provides no: Settlement-specific capacity study Confirmed expansion programme Delivery timetable aligned with housing growth

9. Best and Most Versatile Agricultural Land The site comprises Grade 2/3a agricultural land (Best and Most Versatile). Planning Policy Wales requires protection of such land unless overriding need is demonstrated. No published BMV assessment or alternatives analysis has been provided.

10. Placemaking & Settlement Character The proposal represents a disproportionate extension relative to the scale and pattern of Dinas Powys. The allocation appears driven by housing numbers rather than: Local character Infrastructure capacity Community wellbeing Sensitive placemaking principles

11. Loss of natural habitat for local wildlife The land proposed for development is a natural habitat for many species including: Bats Foxes Tawny Owls Dragon flies Woodpeckers Sparrowhawks Greater Spotted Woodpeckers

12. Active Travel and public transport The Council offers a narrative of active travel being a reasonable alternative to using vehicles. This has not been thought through properly. Many people have to take children to school, which they could not do by foot on on a bicycle. The same argument goes for people working in areas not accessible by public transport. The bus and train service running through Dinas Powys is insufficient for the residents currently living here so would not cope with the increased demand. The train station at Eastbrook does not have a lift or a crossing for people with a physical disability or parents with a pushchair. The route to walk around to the other side of the train station would add an additional 20/30 minutes to the journey on foot. Overall Conclusion The allocation of HG1 KS2 / SP4 KS2 is unsound because it is: Not Justified Contradicts established Green Wedge purpose Inconsistent site assessment Previously rejected for unresolved constraints Not Effective Infrastructure capacity (highways, schools, sewerage, drainage) not demonstrated Over-reliance on future mitigation Not Consistent with National Policy Conflicts with Planning Policy Wales Green Wedge policy Fails to demonstrate sustainable transport compliance Risks loss of Best and Most Versatile agricultural land

Requested Action It is respectfully requested that: The allocation of Site SP4 KS2 be removed.