Cyngor Bro Morgannwg
Vale of Glamorgan Council

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 Furthermore, several of the assumptions made during the LDP allocation process are now outdated, and new evidence demonstrates that the development would have severe and irreversible impacts.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• TAs routinely underestimate trip generation, relying on outdated modelling and optimistic modal shift assumptions.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.