Gwrthwynebu

1 Ymgynghoriad ar Cynllun Datblygu Lleol Newydd

ID sylw: 5084

Derbyniwyd: 01/03/2026

Respondent ID: 3068

Ymatebydd: Mr Dewi Gaylard

Cadarn? Heb nodi

Effeithiau ar y Gymraeg:

The Welsh language is a material planning consideration under section 31 of the Planning (Wales) Act 2015 and must be given appropriate weight in both plan making and decision taking. Planning Policy Wales (PPW) requires development to contribute to placemaking outcomes that support cultural identity and community wellbeing, including the Welsh language. In addition, the Welsh Language (Wales) Measure 2011 establishes the legal principle that Welsh must be treated no less favourably than English, and places duties on public bodies to promote and facilitate opportunities to use Welsh.

The allocation and proposed development of HG1 KS2 fail to demonstrate compliance with these requirements.

A development plan allocation of this scale constitutes a policy decision for the purposes of the Welsh Language Standards (Policy Making Standards). Those standards require the Council to give conscientious consideration to whether the decision would:
• affect opportunities for people to use Welsh; and
• have the effect of treating the Welsh language less favourably than English.

In the case of HG1 KS2, no robust Welsh language impact assessment has been provided to demonstrate that these duties have been met.

The proposed development of 250 dwellings represents a scale of growth that would materially alter the demographic balance of Dinas Powys. Large greenfield housing developments typically introduce significant in migration from outside the local area. Without specific mitigation, this risks diluting the everyday use of Welsh in the community and reducing informal opportunities to use the language in social, educational, and community settings. Such effects are indirect but well recognised in Welsh planning policy and guidance and must be assessed, not assumed to be neutral.

Opportunities to use Welsh are closely linked to the availability and capacity of Welsh medium education and early years provision. The application and supporting evidence do not demonstrate that Welsh medium provision can realistically expand to accommodate the population growth arising from HG1 KS2. Where population growth is accommodated by default within English medium provision, the practical effect is to treat Welsh less favourably than English, contrary to the 2011 Measure and Welsh Language Standards.

The Vale of Glamorgan Council is also subject to its own Welsh Language Promotion Strategy, which commits the authority to increasing opportunities to use Welsh and embedding language considerations into policy decisions. The allocation of HG1 KS2, without clear assessment or mitigation of Welsh language impacts, conflicts with those commitments and reveals a disconnect between the Council’s language duties and the spatial outcomes of the Deposit RLDP.

Taken together, the absence of a meaningful Welsh language impact assessment, the scale and location of the proposed development, and the lack of credible mitigation measures demonstrate that the HG1 KS2 allocation:
• fails to protect or enhance opportunities to use Welsh;
• risks treating Welsh less favourably than English in effect; and
• is inconsistent with national planning policy, statutory language duties, and the Council’s own adopted language strategies.

Accordingly, reduced weight should be given to the HG1 KS2 allocation, and planning permission should be refused on Welsh language grounds as well as on the other policy conflicts identified.

Crynodeb o'r Gynrychiolaeth:

I oppose planning application HG1 KS2 for 250 homes on greenfield land near Dinas Powys due to concerns over traffic, flood risk, strained local services, biodiversity loss, green space reduction, limited public transport, community impact, and policy non-compliance. The site’s environmental and landscape value, existing congestion, floodplain vulnerability, and infrastructure capacity issues are not adequately addressed by the developer’s mitigation claims. The development conflicts with national and local policies, threatens community identity, and causes irreversible harm. I believe it should be refused based on these grounds.

Testun llawn:

Formal Objection to Planning Ref: HG1 KS2 – Proposed Development of 250 Dwellings off Cardiff Road, Dinas Powys

I am writing to submit a formal objection to planning application HG1 KS2, concerning the proposed construction of 250 dwellings on greenfield land between Eastbrook and Llandough, on the fringes of Dinas Powys. This site encompasses the river corridor and agricultural fields of Eastbrook, an area of significant environmental, landscape, and community value.

While the site is allocated within the Local Development Plan (LDP), allocation does not guarantee approval. Planning Policy Wales (PPW) makes clear that each application must still demonstrate compliance with national policy, local policy, and the Well being of Future Generations Act, and must not cause unacceptable harm. This proposal fails those tests. Furthermore, several of the assumptions made during the LDP allocation process are now outdated, and new evidence demonstrates that the development would have severe and irreversible impacts.

A summary of my objectionas are as follows:
1. Traffic and Congestion – Mitigation Claims Are Not Credible
2. Flood Risk – SuDS Cannot Replace Natural Floodplains
3. Schools, GP Surgeries, and NHS Services – Section 106 Cannot Fix Structural Capacity Issues
4. Biodiversity and Wildlife – “Net Gain” Claims Are Misleading
5. Loss of Greenfield Land and Landscape Character – Allocation Does Not Override Harm
6. Public Transport – Proximity Does Not Equal Capacity
7. Village Identity and Community Cohesion – Design Codes Cannot Prevent Overdevelopment
8. Policy Compliance – The Proposal Fails Multiple National and Local Tests

My objections, including rebuttals to anticipated counter arguments, are set out below.

1. Traffic and Congestion – Mitigation Claims Are Not Credible

Cardiff Road, Dinas Powys Hill, and the approaches to Llandough are already heavily congested at peak times. The Dinas Powys Transport Network has long been recognised as operating beyond capacity, with no major upgrades delivered.

The developer may argue that a Transport Assessment (TA) and minor junction improvements will mitigate impacts. However:
• TAs routinely underestimate trip generation, relying on outdated modelling and optimistic modal shift assumptions.
• Eastbrook Station is already at peak time capacity, and rail services cannot absorb hundreds of additional commuters.
• Bus services are infrequent and unreliable, and no enforceable commitment exists to improve them.
• The road network is physically constrained by existing development, meaning no meaningful widening or reconfiguration is possible.

PPW requires development to avoid “unacceptable harm” to highway capacity. This proposal would significantly worsen congestion, air quality, and journey times, with no realistic mitigation available.

2. Flood Risk – SuDS Cannot Replace Natural Floodplains

The proposed site includes low lying fields adjacent to the Eastbrook river, which already experience surface water accumulation. Under TAN 15, highly vulnerable development such as housing should not be located in areas at risk of flooding unless stringent tests are met.

The developer may claim that Sustainable Drainage Systems (SuDS) will control runoff. However:
• SuDS cannot replicate the absorption capacity of natural floodplains.
• The site’s topography funnels water toward existing homes in Eastbrook, meaning any increase in runoff, even if “controlled,” raises downstream risk. In recent years Dinas Powys has seen increased Flooding Incidents.
• Climate change projections used during the LDP process are now outdated; rainfall intensity has increased significantly.

PPW and TAN 15 emphasise a precautionary approach. Building on a functional floodplain contradicts both the letter and spirit of national policy.

3. Schools, GP Surgeries, and NHS Services – Section 106 Cannot Fix Structural Capacity Issues

Local schools, GP practices, and Llandough Hospital are already operating at or near capacity. The developer may argue that Section 106 contributions can fund expansions. However:
• There is no physical space to expand several existing local schools, and staffing shortages cannot be solved with financial contributions.
• GP practices in Dinas Powys, Penarth and Llandough already have long waiting times; the Cardiff & Vale Health Board has repeatedly acknowledged workforce pressures.
• Llandough Hospital is a regional facility already under strain; additional population growth will worsen waiting times.

PPW requires developments to demonstrate that essential services can accommodate growth. This proposal fails that test.

4. Biodiversity and Wildlife – “Net Gain” Claims Are Misleading

The Eastbrook fields and river corridor form an important wildlife habitat supporting birds, bats, amphibians, and small mammals. The developer may claim that ecological mitigation, such as bat boxes or landscaping, will deliver biodiversity net gain.

However:
• Net gain cannot replace the loss of mature, interconnected habitats.
• Artificial features do not replicate the ecological function of natural riverbanks and fields.
• The site forms part of a wider ecological network linking Cosmeston, Cogan Wood, and the Dinas Powys countryside; fragmentation would be permanent.

The Environment (Wales) Act 2016 requires public bodies to maintain and enhance biodiversity. This development would do the opposite.

5. Loss of Greenfield Land and Landscape Character – Allocation Does Not Override Harm

The Council may argue that the principle of development was established through the LDP. However:
• PPW states that allocated sites must still be assessed against current evidence and policy at application stage.
• The LDP was adopted in 2017; since then, climate, transport, and infrastructure pressures have intensified, making previous assumptions outdated.
• The site forms one of the last remaining green buffers between Dinas Powys and Llandough; its loss would fundamentally alter the settlement pattern.

The proposal conflicts with LDP Policy MG17 (Special Landscape Areas) and PPW’s placemaking principles.

6. Public Transport – Proximity Does Not Equal Capacity

The developer may argue that the site is “sustainably located” due to Eastbrook Station. However:
• Peak time trains are already full.
• The station has limited parking and no capacity for expansion.
• Bus services are infrequent, with no guaranteed improvements.

PPW requires realistic, not theoretical, sustainable transport options. This development would remain car dependent.

7. Village Identity and Community Cohesion – Design Codes Cannot Prevent Overdevelopment

Dinas Powys and Llandough are distinct village communities. A development of 250 homes—effectively a new estate larger than many existing neighbourhoods, would overwhelm the existing settlement pattern.

The developer may argue that design codes will ensure integration. However:
• Scale, not design, is the primary issue.
• The development would merge communities, erode village identity, and contribute to suburban sprawl.
• PPW requires developments to respect local character and sense of place; this proposal does neither.

8. Policy Compliance – The Proposal Fails Multiple National and Local Tests

The developer may claim alignment with PPW, the Well being of Future Generations Act, and the LDP. However, the proposal conflicts with:
• PPW (Edition 11) – placemaking, climate resilience, sustainable transport
• TAN 15 – flood risk
• Environment (Wales) Act 2016 – biodiversity duty
• LDP Policy MD2 – infrastructure capacity
• LDP Policy MG17 – landscape protection
• Well being of Future Generations Act – long term environmental and community wellbeing

Allocation alone does not override these conflicts.

Conclusion

For the reasons outlined above, I strongly object to planning application HG1 KS2. The proposal would cause significant and irreversible harm to the environment, local infrastructure, community identity, and the wellbeing of current and future residents. The mitigation measures proposed are insufficient, unrealistic, or based on outdated assumptions. The development fails to meet the requirements of national and local planning policy and should therefore be refused.

Atodiadau: