Cyngor Bro Morgannwg
Vale of Glamorgan Council

I write to formally object to the allocation of Site HG1 KS2 – Land North of Dinas Powys within the Replacement Local Development Plan. I believe the site is unsuitable for the proposed development, based on inaccurate assumptions within the access and transport statement, insufficient consideration for the potential flooding risk for both the development and the fluvial network, and the impact on the village of Dinas Powys.

Transport
* the modelling associated with the access and transport statement considers a five-day average to determine peak traffic flows. This is incorrect given there is clear increases in commuting traffic on Tuesday-Thursday, with typically people working from home on Monday and Friday. As such the traffic modelling that the whole statement is based on fails to identify the true 'peak' of traffic. Furthermore, peak traffic flows in the area are from 7.00 - 10.00 and so this window of survey fails to capture the full picture.
* the access and transport statement itself acknowledges "the Cardiff Road corridor currently operates effectively as one long dynamic queue during peak periods" but then states that the level of traffic growth will unlikely materialise. This is in spite of their own (flawed, see above) modelling indicating a 5% impact with the development in place for am transport.
* the viability of the settlement relies on the use of public transport and walking to reduce car journeys. This fails to acknowledge the 2023 National Travel Survey which states that 67% of journeys to work are by private car, and given the nature of the development working-age people would be the primary market
* further to this, the access and transport statement highlights the proximity to Eastbrook station. This station is DDA compliant as there is no ramp/lift to allow for access to both platforms, and as such the use of the train is excluded to those who could live in the proposed development. It should also be noted that the train network in the morning is particularly oversubscribed and no modelling has been provided that demonstrates additional train passenger capacity to be accommodated.
* related to the points above, residents in the proposed development would need to use their vehicles to be able to access retail, as there is none within easy commuting distance. The assessment of less than 2km of walking being a suitable threshold for considering facilities in the locale fails to account for those carrying purchases. Note the appendix to the access and transport statement states that a mobility access hub should be built into the development, but this is not shown on the plans provided.
* the access and travel statement summarises with the statement that "It is therefore concluded that the site is suitably located for a residential development which could be delivered without detriment to highway safety and would additionally be able to take advantage of existing and proposed active travel connections to key locations such that future residents would not be required to rely on the private car." This takes no account for where people work, who would be moving into the development, personal preference of travel - and is not justified within the work shown.
* all traffic modelling fails to acknowledge the impact of construction traffic on the transport network, which would have a much more significant effect that the modelled private vehicles.
Flooding
* Flooding of East Brook and the River Cadaxton in Dinas Powys is known. Schemes proposed by NRW to address the flooding have not been brought forward
* The site currently has multiple water courses classified as "surface water and small watercourses", in both Flood Zone 2 and 3. As part of any Flood Consequence Assessment (FCA), the development would need ensure, accounting for climate change, that the properties were not at risk of flooding. This may result in significant import of material to raise levels
* The site is clearly slow draining, as evidenced during rainfall events by the extent of standing water/saturated ground. The drainage proposal provided by JBA is based on soakways/SUDS - these are unlikely to be viable if the ground is this impermeable - likely resulting in mass earthworks to create swales/attenuation cells etc
* Welsh Government TAN 15 states that the development needs to demonstrate that it will not cause or exacerbate the nature of frequency of flooding. No confidence is provided from the supporting documents, other than "SUDS" - see point above
Village Impact
* PPW 12 states that "places grow and develop in a way that uses land efficient... the location of housing,employment and leisure and other facilities are planned to help reduce the need to travel". This is not being appropriately considered in the location of this development, given that it is on the edge of an already stretched village whereby a significant part of the community around Eastbrook station already do not have easy access to leisure or retail facilities.
* PPW12 also states that a 'green wedge' is required to separate communities and prevent con-urbanisation. This land was previously designated as part of the green wedge, but this has been pushed aside given the interest in bringing forward this development. Any future phases of the development would further eat into the already identified green wedge.
* Dinas Powys is already oversubscribed for school places, and the medical facility is stretched, given it serves such a large area. The response provided in the Stakeholder Engagement report was that “A full assessment of local infrastructure, including schools and healthcare facilities, will be conducted to ensure the proposed scheme does not have any significant adverse impact on the overall function of key local services.” But this has not been provided in the supporting documentation"
* furthermore, the stakeholder engagement report summarises that the development has "general support"; these are based on biased questions i.e 'how important do you feel these aspects are', rather than an outright question of whether the development is supported.
* Note also that the feedback states that 75% of responders are neutral/negative when asked whether the scheme will meet local housing needs, and the feedback shows strongly that responders are not at all confident that the proposed development will mitigate the impacts on local traffic, in spite of the traffic assessment being one of the documents available in the consultation.

In addition to these three main areas of my objection, I would also like to raise the following

* the inclusion of this site, over and above other areas within the Vale of Glamorgan, shows a lack of support for levelling up growth. There is sufficient development in Cardiff and the surrounding areas, and spreading economic prosperity throughout the Vale, particularly in light of Welsh Government/Cardiff Capital Region support of developments such as Aberthaw, appears short-sighted
* there are numerous properties for sale within Dinas Powys, which have been on the market for months (years in some cases). This indicates that there is not the demand for housing in the area
* I am aware that this development has been previously promoted in the LDP and was not included, based on the traffic modelling undertaken. In my opinion, adequate justification has not been provided to overrule that decision.
* Persimmon clearly intend to develop the whole extent, and not just this first phase of development. The full development would completely change the character of the area through merging of Penarth, Llandough and Dinas Powys, and should not be allowed to proceed.

In summary, I believe that the porpoised development of Site HG1 KS2 – Land North of Dinas Powys is disproportionate to the capacity of the village, is not adequately considered through traffic modelling and does not follow best practice as set out in PPW12. As such, I respectfully request that Vale of Glamorgan Council reconsider the allocation of this site within the Replacement Local Development Plan.