Testun llawn:
Formal Representation: Site SP4 KS3 (Readers Way, Rhoose)
To: The Planning Policy Department, Vale of Glamorgan Council
Subject: Objection to Allocation of Site SP4 KS3 – Lack of Technical Soundness and Deliverability
I am writing to formally object to the inclusion of Site SP4 KS3 (Land at Readers Way) in the Deposit RLDP. The proposal for 520 homes at this location is technically "Unsound" under the Welsh Government Development Plans Manual and fails to meet the requirements of TAN 15 and Planning Policy Wales (PPW) for the following reasons:
1. Lack of Validated Drainage Evidence (Test of Soundness 2 & 3)
The proposed drainage strategy relies on deep borehole infiltration. However, the evidence base (ESP Report 7618e) appears to lack a full, consecutive winter groundwater monitoring program (Oct–Mar). Without winter data, the Council cannot confirm that the "1m unsaturated zone" required by SuDS Standard S6 is maintained. This is a critical failure, given the known variability of the limestone.Also it is proposed to increase the site from 450 to 520 houses. It is not evident that the site been accurately monitored for this increase. Without the full winter monitoring and revision of the calculations for the additional housing this fundamentally fails.
will this extra housing also adversely affect the possibility of ground water contamination into the Reader Way biodiversity pond in that area.
2. Failure to Apply Mandatory Factor of Safety (FoS)
The developer has failed to demonstrate the application of a Factor of Safety (FoS) of 10.0 to borehole infiltration rates, as mandated by the SAB for high-risk sites near existing residential assets. A 10.0 FoS should be applied.No mention of who takes responsibility for the upkeep of the drainage and attenuation ponds infrastructure when the development is completed ie the associated problems that occurred at Rhoose Point development where nobody would take overall responsibility.
3. Cumulative Impact and Infrastructure Failure
The site’s drainage impact on the existing flood drainage issues at Celtic Way and the railway underpass has not been addressed through enforceable mechanisms. I contend that the Council must mandate Grampian Conditions or Section 106/104 agreements to ensure:
No development commences until off-site flood mitigation for the underpass bottleneck is completed compliant with SuDS sustainable drainage requirements
"Bunding" requirements for attenuation ponds are legally secured to prevent overtopping during 1-in-100-year storm events (+40% climate change).
4. Historic Precedent (Rhoose Point)
The Council is repeating the systemic drainage failings seen at Rhoose Point, where inadequate technical oversight has led to long-term adoption and maintenance issues this should not happen again. The current "Amber" assessment of SP4 KS3 must be elevated to "Red" until such time as the winter monitoring and mounding analysis definitively prove the site's safety .