Testun llawn:
Objection to the Allocation of 250 Dwellings at Cardiff Road, Dinas Powys.
This submission objects to the proposed allocation on the grounds that the evidence relating to transport, air quality, sustainable travel, flood risk and primary healthcare capacity is incomplete, outdated and insufficient to satisfy the statutory tests of soundness, as laid out in the Four Statutory Tests of Soundness (Wales). These are widely referred to as C1-C4. Particular attention should be devoted to tests C2 and C3, when gathering presentable evidence in mitigation. The current Plan does not demonstrate that the development on this scale can be accommodated sustainably and not just meet the C1-C4 tests but should exceed as a matter of fact and good governance.
Transport Capacity and Cumulative Impact
The existing highway network traversing through Dinas Powys, in particular Cardiff Road (which is the main vehicular route through the village for all traffic from Barry and other outlying areas travelling to Cardiff itself), St Andrews Road, the A4055 and associated junctions and interactions, already experience severe peak-time congestion. No settlement specific junction modelling has been provided, peak hour assessments or baseline traffic data confirming that the existing network retains sufficient capacity or that cumulative predictive impacts have been assessed in accordance with the national policy.
Lack of Deliverables and Enforceable Mitigation
The plan fails to clearly identify any costed or enforceable mitigation measures for Dinas Powys. There is no certainty regarding the interventions required, their phasing-in, funding or which delivery mechanisms will be utilised. In the absence of secured and timely mitigation, the Plan fails to adequately address the four statutory tests C1-C4 (Wales).
Air quality and Public Health
No location-specific or cumulative air quality modelling has been undertaken for Dinas Powys. The plan does not assess worst-case parameters (which is a given for any large development), conditions or sensitive receptors, nor does it try to demonstrate continued compliance with the existing statutory thresholds. Surely, the additional traffic generated from this large development will have a detrimental and additive impact. This clearly represents a significant evidence gap with direct implications for public health and compliance.
Sustainable Transport Assumptions
The RLDP contains no committed or funded sustainable transport improvements for Dinas Powys. Without identified schemes, delivery timescales or secured investment, the assumed model shift is unsubstantiated and as such does not pass the completeness check. Car dependency will not only remain high but will be added to with this large scale development, leading to increased congestion, extended travel times, delays and worsening air quality.
Primary Healthcare Capacity
Dinas Powys Health Centre is already operating beyond its intended and practical capacity for provision of GP services to the Dinas Powys residents, leading to poor primary care and further extending access to timely appointments and care. The RLDP provide no assessment of the additional demand that will be generated by the occupants of the 250 new dwellings, no evidence of engagement with the Heath Board, and no strategy for adequately expanding local primary care provisions. Without a clearly costed and deliverable plan for primary healthcare capacity enlargement it is difficult to understand how essential healthcare services will manage the increased population needs. The allocation simply ignores this statutory requirement and doesn't even try to demonstrate that necessary infrastructure can be delivered alongside the growth, contrary to national requirements.
Flood Risk Evidence Not Fit for Purpose
The flood risk evidence underpinning the Plan is obsolete. Since, it doesn't incorporate the major flood event of 23rd December 2020, which resulted in internal flooding to 98 properties.
- the Local Flood Risk Management Strategy (2013) predates the 2020 event and updated climate projections.
- NRWs September 2020 ECOR rejected a strategic scheme based on assumptions disproven by the 2020 flood.
- no post-flood catchment-wide hydraulic modelling has been undertaken.
- NRW has not produced any updated mitigation strategy incorporating 2020 data set.
Without an updated, actual event based and informed model, the Council has failed to demonstrate that additional development will NOT increase flood risk within the catchment or elsewhere.
Failure to Meet Soundness Tests
The RLDP fails to meet national policy requirements for a robust, proportionate and use of up-to-date evidence base. Key omissions include (but not limited to):
- no junction capacity modelling.
- no cumulative air quality modelling.
- no define or enforceable mitigation strategy.
- no committed sustainable transport plan.
- no assessment of primary healthcare capacity and flooded evidence invalidated by the December 2020 event.
The plan is therefore not justified, it fails to meet key legal requirements, its not effective and not sufficient credible evidence is made available.
Conclusion
The proposed development at Cardiff Road cannot be considered safe, sustainable or supported by adequate evidence. Until the Council produces updated transport modelling, enforceable mitigation, robust air quality assessments, a primary healthcare capacity plan and NRW approved post 2020 flood modelling, the allocation should not proceed and the RLDP should not be classified as "found sound" as it applies to Dinas Powys.
