I write regarding the ongoing consultation relating to the Deposit Plan. I make these representations in my capacity as Leader of the Council's Conservative Group. Please take this correspondence as our Group's response to the consultation.

Our Group does not consider any of the key sites designated within the Plan to be suitable. The respective ward members for St Athan, Rhoose, Illtyd and Dinas Powys have articulated detailed reasons for this previously. I too, as ward member for Llandough, have raised concerns regarding the impacts developing the Cardiff Road site would have on road safety issues at the Merrie Harrier junction.

Our Group has been approached by residents from across the Vale of Glamorgan expressing deep concerns regarding the consultation process. Many have found the consultation portal difficult to navigate, and relevant information hard to locate. Given the time required to read all the relevant documents prior to crafting a response, residents do not feel the six-week consultation process is sufficient. As a Group, we agree. For this reason, at Full Council on Monday, I requested extension to the consultation period. It is regrettable this was not granted.

As such, it is the view of our Group that the consultation is flawed. We therefore believe that it must be carried out again.

Thank you for taking the time to consider our representations.

Q1: Dinas Powys is already totally congested with traffic queuing at all times of day.
There has already been extensive flooding. More concrete instead of fields will make it worse.
Eastbrook station is not suitable for people with disabilities.

Q2: This is not relevant.

Q1: SITE REFERENCE/POLICY/PARAGRAPH NUMBER: HG1 KS2
Whilst the reference is specific to the Eastbrook development the majority of these comments could be applied to the entire RDLP and the original LDP. The desire to build new homes on green spaces, destroying farm and woodland and wildlife without consideration to infrastructure is destroying all the great things about the Vale of Glamorgan; whilst affecting the communities in the Vale. With all the the new housing the population of Dinas Powys is increasing to the point that it is losing its identity as a village. In addition to the above the loss of the green belt boundary between Dinas Powys, Llandough and Penarth further affects the village identity, we are nearing some pseudo super town that will have no heart or community. With our local schools already full and over-subscribed how are they going to handle the additional families and with our education authority in disarray how will they manage to deal with the over capacity from a budget perspective. All GP surgeries are at capacity and there is no ongoing consultation with this service to rectify the current situation let alone the future issues. The new site at Eastbrook will have a water run off into the Cadoxton River which has burst and flooded homes in Dinas Powys many times. The increase in homes will lead to more discharge of raw sewage into the sea. This development will have an impact on many wildlife habitats, destroy wildlife homes to build our own does not seem morally or ethically right! The mantra that has been used to justify all these new homes and continues is people will use public transport, cycle and walk as opposed to using cars, Active Travel as you call it, has already been proven not to work. As far as the Eastbrook site is concerned there is limited access to Eastbrook train station, with no viable pedestrian access, limited and inadequate parking and no disabled access to or from one side. With Cardiff Road already at capacity bus travel does not offer any advantage over car travel and if the development were to go ahead then the additional traffic lights in the bus lane between Eastbrook and the Merrie Harrier will only add more misery. Another 250 homes could add as many as 500 additional cars entering Cardiff Road which has been over capacity for 5 years, with no upgrades in that time or planned. There is an infants school on the main Murch crossroads in Dinas Powys and the pollution today is unacceptable for many hours a day without this introduction of additional cars.
This additional traffic and the 250 homes will affect emergency services, first responders, maternity and A&E facilities through increased demand and congestion.
In addition to the above comments I want to raise the following specific issues regarding the Eastbrook development.
Highways objected to both the original Eastbrook proposal for 800 homes the current one for 250 homes, so why are the they pursuing this proposal when it is clearly not deliverable in transport and other terms.
The consultants have not provided a Transport Assessment, surely there should be a full assessment carried out before this is passed and Transport Assessment be placed in the public domain for consultation.
The site is not a viable Active Travel site due to the restraints of Cardiff Road and the southern end of the of the site, so does not follow guidelines.
The consultants Strategic Flooding Assessment is meant to record details of recent flood events but did not specifically detail the flooding of 100 homes in Dinas Powys in December 2020. An omission which at best a terrible oversight and worst misleading.
Has a catchment wide hydraulic model been commissioned, completed and agreed with NRW and does it show no increase in flood risk to existing properties?
The use of SuDS on the site can only add more water into the flood plain eventually are they viable given soil and ground water constraints and who is gong to be responsible for maintaining them as there have been issues with planning a maintenance programme at the Woodlands site in Dinas Powys, which is the responsibility of the council!
It would also be good to know the number of raw sewage discharges since all these new housing developments were finished namely Woodlands, Scholars Park and Caerwent Close as from that data we should be able to predict the affect these 250 houses will have. Sewage pollution that is unacceptable in the 21st century.
What evidence is there and where is it that 250 houses are needed in Eastbrook?
Having been turned down before, what were the reasons to do so and what has changed to make it viable now?
Have the Vale council exhausted all the key sites outlined in the previous LDP and if not why not?
Have the Vale council used all their rolled forward housing sites?
Have the Vale council carried out a Sequential Test, thereby proving there are no lower risk sites available?
Has an Exception Test been carried out to ensure the development will be made safe throughout its lifetime without increasing risks of flooding elsewhere?
Were these carried out in the case of Woodlands, Scholars Park and Caerwent Close?
From Persimmons marketing brief 50 homes will be affordable housing to be managed by a housing association, what is classed as affordable housing?
With the elderly population increasing and the birth rate falling how do you justify this need and what proportion will be age friendly?
250 houses are not what the elderly need they want to be able to downsize to age friendly housing i.e. bungalows, what are the Vale council doing about this?
I understand that both the UK and Welsh Governments are 'ordering' house building but that is mainly to boost the economy by getting Britain building but repurposing existing empty buildings does that too. Cardiff have just done that with an office block in Cardiff Bay, so instead of making the east side of the Vale part of Cardiff why not do that?

Q2: I fail to see the relevance.

Planning reference HG1 KS2 North of Dinas Powys, off Cardiff Road 250 dwellings proposed.
1. Wildlife: These areas have a large variety of flora and provides habitat for a large variety of wildlife. This loss is totally unnecessary and will have a detrimental effect on Dinas Powys.
2. Doctors: It is presently very difficult to get an appointment to see my local doctor with a long wait for non-urgent consultation. The nurses at the practice also have a heavy workload dressing wounds etc., something I experienced recently with wound dressing over a 4 month period. An additional 1150 dwellings with average 2+ residents is going to make the problem much worse and is liable to result in failure with catastrophic results.
3. Flooding: Dinas Powys has suffered major flooding and the danger of flooding in recent years. While developers can provide attenuation to allow controlled flows into the local streams, they only work with a functioning control system. Even when working correctly they still release water into the system. Cardiff Road is regularly flooded with cars only able to pass with caution but making it impossible for pedestrians which affects access to our house. Should there be failure of the attenuation control or under capacity this could have catastrophic consequences with major flooding to Dinas Powys.
4. Sewerage: How will the local foul sewerage system be able to cope with the increased flow from the new developments, will the developers be installing new pipes to the sewerage works digging up the main roads in Dinas Powys with months of chaos?
5. Traffic: The roads in Dinas Powys are heavily congested especially during rush hours which nowadays extends to most of the day. Queues of stationary traffic emitting exhaust fumes, this will be made significantly worse if these developments occur. This is also liable to become another excuse to build a bypass which definitely has to be avoided.
6. Parking: The Eastbrook station car park is presently totally inadequate. This results in additional car journeys which would be avoided if parking was available, the new developments can only make this matter worse.
7. Schools The local primary school was built over 100 years ago for a small village, while it has expanded and there are additional schools, I understand that the present schools are over capacity which can only be made worse with these developments.
8. Village: Dinas Powys is a unique village to the residents, these developments will enlarge it and eventually joining it to Barry, Penarth and Llandough resulting in loss of identity and individuality which is important to a society.
9. Construction: While restrictions will be imposed on the contractors, these are not always adhered to and difficult to monitor resulting in more disruption to the residents of Dinas Powys.

Q2: This all depends on who comes to live there which is an unknown factor.

Remove allocation.

I wish to comment on the proposals for Eastbrook.
It is clear that there is substantial opposition to the proposals for 250 properties in Eastbrook.
I have attended a number of public meetings in Dinas Powys and I have heard no evidence that there is any declared support for these plans.
Residents are worried about the impact on the community in respect of an increased risk of flooding, addition traffic and extra substantial demand on health services.
Both primary and secondary schools are at capacity. The road network is over capacity. Pavements along Cardiff Road are narrow and not properly maintained. The nearest railway station car park is generally full. There are no community facilities in the immediate vicinity apart from Seel Park.
If this consultation is meaningful the authority must respond to public opinion and reject this proposal.

Dear Sir/Madam I initially submitted a response to the plans for the land north of Eastbrook on January 31st 2026. In it, I made it plain that I disagreed with the proposed location of 250 houses at the location designated as HG1 KS2- LAND TO THE NORTH OF DINAS POWYS
In the intervening weeks, a number of issues involving Vale Council policy have been brought to my and other people's attention.
1) The obvious issue is potholes, making driving through Dinas Powys (and not just the main road) both uncomfortable and dangerous. With the already excessive traffic travelling through the village the Council's first responsibility is to provide safe and usable roads for the existing population. Your second responsibility is to ensure that, in the case of damage to cars as a result of poor road surfaces, you pay compensation to the drivers inconvenienced by such incidents as well as ensuring that road surfaces are in good condition at the start of the autumn/winter. I realise that repairing holes during the winter can be very complicated but this is one of the many issues that you, as councillors elected by the people of the Vale, the responsibility of good quality management.
2) A second is the information that Persimmon - who already have a vested interest in the issue of flooding both on the land proposed for the 250+ houses north of Eastbrook and in the wider issue of flooding in Dinas Powys - was asked to carry out an assessment to see that the project would be 'waterproof' and 'floodproof'. This review ought to have been passed to a totally independent body, rather than by a body who already has a major interest in the project. When will the Vale be arranging such an independent assessor.
I could happily carry on with other issues that concern many people in Dinas Powys, from the serious lack of basic social infrastructure such as schools and medical facilities (I don't regard privately owned surgeries and dentists as part of such infrastructure). However, I won't but will give you a scenario to consider - - which is apt in more than one sense.
If you were planning to create a new road somewhere on the outskirts of a village such as Dinas Powys, would your first action be to lay asphalt? Of course you wouldn't. Assuming that you had already decided on the route for the road, you would need to clear the route of vegetation, topsoil, debris and any obstacles. Only then could you start digging the area to reach a suitable foundation level before the ground is levelled and slopes are created to assist proper drainage.
Only once that stage has been completed can the preparation of the subgrade layer get underway. This stage is crucial as a strong subgrade is vital to the finished road being strong enough to withstand heavy traffic loads and environmental conditions.This is followed by the installation of the base layer to ensure equal distribution of the load of traffic across the road structure. Only then can initial paving (asphalt or concrete) be started. Halfway through this, drains and gutters need to be constructed before the final layer(s) of paving is finally laid.
Applied to the situation here in Dinas Powys, you are trying to lay 'asphalt' before ensuring the various variables and stages listed above have been given the go-ahead.
In my view, the Eastbrook development (HG1 KS2) is the asphalt on the top of the project. There are plenty of planning and review processes (the clearance of debris topsoil and vegetation) to be properly satisfied before ant progress is made. For instance, new schools and medical facilities need to be planned and created; the A4055 needs to be reviewed to ensure that there are no unduly long backlogs traveling through the village (currently, these start around 7am and often carry on till mid- morning before a second 'rush hour' lasts from midday till about 2pm before a third rush hour starts at 3pm, going on till 7/7:30pm), and that the road can cope with the added weight of traffic (let alone the added weight of heavier electric cars). Add to that, the huge amount of work that needs to be done on ensuring that water flowing into the Eastbrook from the north and the west does not overload that water course or get displaced further downstream thus putting additional pressure on the River Cadoxton south of the Infant School.
Rather than repeating my comments submitted on January 31ˢᵗ, I will leave the committee to imagine quite how many issues need to be resolved before the first sod of earth to be cut on the site north of Eastbrook is even considered to be possible.

I genuinely hope that all formal objections will be considered carefully, and that the Local Planning Authority approach them with a preparedness to exclude HG1 KS2 from the Replacement Local Development Plan.

I'm writing with regards to the Deposit Replacement Local Development Plan so to formally object to the inclusion of HG1 KS2 - Land to the North of Dinas Powys.

The 13.3 Ha site, as shown on the Proposals Map, is allocated as a location for 250 homes.

As you are aware the site would have to adhere to the Placemaking Principles in Policy SP4 Placemaking. Having considered these, I think it reasonable to suggest that the Principles are not being adhered to for several reasons, namely:

- Despite SP4(2) requiring the prioritising of health and well-being during the design process, there is no specific requirement that ensures cooperation with and a contribution to local GPs and the Cardiff and Vale University Health Board;

- Despite SP4(7) requiring that developments be located appropriately where homes, local services, and facilities are accessible and well connected, the fields are situated in an area where the highways are already congested and public services overstretched;

- Despite SP4(5) expecting the delivery of environmental and ecological benefits, the fields in question are currently part of the Cwrt-yr-Ala Basin Special Landscape Area (SLA). As MG17(6) of the current Local Development Plan advises, the detail of SLAs are in the Designation of Special Landscape Areas (Background Paper), September 2013. That notes that Cwrt-yr-Ala Basin includes land of high habitat value, and: "The SLA boundary has been extended to include the open space buffer between Penarth and Dinas Powys, which should be maintained for Dinas Powys' character as one of few such large villages in SE Wales." So important is that buffer that the fields are also part of the current green wedge between Dinas Powys, Penarth, and Llandough. As such, there is no doubt that the scheme would have a detrimental impact not just on the environment, but an SLA.

The site also has to be in line with the criteria in Policy PGD1 Creating Well Designed Places. Having considered this, again I think it reasonable to suggest that the site does not adhere to the principles outlined:

- Despite PGD1(1) requiring the promotion of sustainable transport choices, as I have already explained, it is foreseeable that residents would have private vehicles, and as such compound the already difficult traffic situation. This is also contrary to PGD1(6);

- Despite PGD1(2) requiring improvements to health and reducing health inequalities, as highlighted above, there is no direct commitment to supporting local health services;

- Despite PGD1(3) requiring a positive contribution towards climate change resilience, in addition to the development being on an SLA, it raises serious questions about the impact on flooding, not only to the proposed estate, but the surrounding area. This is also contrary to PGD1(5);
- Despite PGD1(4) requiring a positive contribution to the character of the area, the scheme would be pushing in to the much needed green wedge.
It was with interest that I read the comments by your Local Planning Authority in the Penarth Times. Indeed, the spokesperson is quoted as stating, in relation to the site under consideration, that "the proposed development is in a sustainable location". The petition by local residents, and the points outlined by me above, seriously bring into question the reliability of the Council's public position.
I genuinely hope that all formal objections will be considered carefully, and that the Local Planning Authority approach them with a preparedness to exclude HG1 KS2 from the Replacement Local Development Plan

SECTION 9 — MANDATORY POLICY WORDING REQUIRED TO MAKE THE RLDP SOUND
To ensure that the Eastbrook allocation is sound, the RLDP must include explicit, enforceable, and unambiguous policy wording that secures the necessary hydrological, environmental, and infrastructure safeguards. Without this wording, the allocation fails the tests of soundness — particularly CE2 (coherence and effectiveness), CE3 (environmental protection), and CE4 (deliverability).
The following policy wording is mandatory to ensure that development does not increase flood risk elsewhere and that mitigation is viable, deliverable, and enforceable.
9.1 Mandatory Flood-Risk Policy Wording
The RLDP must include the following:
Policy FR-X: Catchment-Wide Flood-Risk Assessment (Mandatory Requirement)
Development at Eastbrook (HG1 - KS2) will not be permitted unless:
1. A full catchment-wide hydraulic model has been prepared, agreed with Natural Resources Wales (NRW), and approved by the Local Planning Authority (LPA).
2. The model demonstrates no increase in flood risk to any existing property within the catchment for all relevant storm events, including climate-change allowances.
3. All required mitigation measures are:
o Technically feasible
o Financially viable
o Deliverable within the plan period
o Secured through planning conditions or legal agreement
4. All mitigation measures are delivered prior to the commencement of development.
5. Overland flow routes, groundwater pathways, and natural drainage functions are preserved, enhanced, or appropriately managed.
6. A long-term management and maintenance plan for all SuDS and flood-risk infrastructure is secured.
9.2 Mandatory Groundwater and Overland Flow Policy Wording
Policy FR-Y: Groundwater and Overland Flow Protection
Development proposals must:
• Demonstrate that groundwater emergence will not be exacerbated
• Preserve all existing overland flow routes
• Provide exceedance routing that avoids existing residential areas
• Incorporate groundwater-resilient design measures
• Avoid any obstruction of natural drainage pathways
No development will be permitted unless these requirements are met in full.
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9.3 Mandatory SuDS Policy Wording
Policy SuDS-X: Sustainable Drainage Requirements
All development must:
• Provide SuDS designed in accordance with national standards
• Demonstrate that infiltration-based SuDS are viable, or provide alternatives where infiltration is not feasible
• Include attenuation sized using catchment-wide modelling outputs
• Provide exceedance routing that avoids downstream receptors
• Secure long-term maintenance arrangements
SuDS must be operational before any dwelling is occupied.
9.4 Mandatory Infrastructure Delivery Policy Wording
Policy INF-X: Infrastructure Delivery and Phasing
Development at Eastbrook (HG1 - KS2) will not be permitted unless:
• All required infrastructure upgrades (education, healthcare, utilities, drainage, highways) are identified
• Funding is secured
• Delivery is guaranteed within the plan period
• Infrastructure is delivered in advance of occupation
The RLDP must demonstrate that infrastructure delivery is viable and enforceable.
9.5 Summary
Without the mandatory policy wording set out above, the RLDP:
• Does not secure the evidence required to assess flood risk
• Does not guarantee that mitigation will be delivered
• Does not ensure that development will not increase flood risk elsewhere
• Does not demonstrate deliverability
• Fails multiple tests of soundness
The inclusion of this wording is essential to ensure that the Eastbrook allocation is sound, effective, and compliant with national policy.

Dinas Powys Community Council submits this technical objection to the proposed allocation of the Eastbrook site within the Vale of Glamorgan Replacement Local Development Plan (RLDP). While the Council recognises and welcomes several positive changes in the revised RLDP, the Eastbrook allocation remains fundamentally unsound due to unresolved constraints relating to:
• Flood risk and hydrology
• Highways and transport capacity
• Environmental and landscape impact
• Infrastructure limitations
• Deliverability and viability

The Eastbrook site lies within a complex hydrological catchment characterised by:
• Groundwater emergence
• Overland flow routes
• Low-permeability soils
• A history of significant flood events, including the 2020 incident
• Interactions between surface water, groundwater, and existing drainage systems
Natural Resources Wales (NRW) has repeatedly identified flood-risk concerns at this location, and the Council’s own evidence base acknowledges the need for detailed catchment-wide modelling before any development can be considered.

The RLDP currently lacks:
• Mandatory policy wording to secure pre-delivery of mitigation
• Requirements for catchment-wide modelling
• Guarantees that development will not increase flood risk elsewhere
• Mechanisms to ensure that mitigation is viable, deliverable, and enforceable

Without these safeguards, the allocation is unsound under the tests of:
• Soundness Test CE2 (coherence and effectiveness)
• Soundness Test CE4 (deliverability)
• Soundness Test CE3 (environmental protection)
This objection sets out:
1. The positive changes recognised in the revised RLDP
2. The continued reasons why the Eastbrook allocation remains unsound
3. A full technical hydrology and flood-risk chapter
4. Mandatory policy wording required to make the allocation sound
5. A formal request for written confirmation from the Vale of Glamorgan Council
6. Supporting diagrams (ASCII + placeholders)


SECTION 1. EXECUTIVE SUMMARY
Dinas Powys Community Council submits this technical objection to the proposed allocation of the Eastbrook site within the Vale of Glamorgan Replacement Local Development Plan (RLDP). While the Council recognises and welcomes several positive changes in the revised RLDP, the Eastbrook allocation remains fundamentally unsound due to unresolved constraints relating to:
• Flood risk and hydrology
• Highways and transport capacity
• Environmental and landscape impact
• Infrastructure limitations
• Deliverability and viability
The Eastbrook site lies within a complex hydrological catchment characterised by:
• Groundwater emergence
• Overland flow routes
• Low-permeability soils
• A history of significant flood events, including the 2020 incident
• Interactions between surface water, groundwater, and existing drainage systems
Natural Resources Wales (NRW) has repeatedly identified flood-risk concerns at this location, and the Council’s own evidence base acknowledges the need for detailed catchment-wide modelling before any development can be considered.
The RLDP currently lacks:
• Mandatory policy wording to secure pre-delivery of mitigation
• Requirements for catchment-wide modelling
• Guarantees that development will not increase flood risk elsewhere
• Mechanisms to ensure that mitigation is viable, deliverable, and enforceable
Without these safeguards, the allocation is unsound under the tests of:
• Soundness Test CE2 (coherence and effectiveness)
• Soundness Test CE4 (deliverability)
• Soundness Test CE3 (environmental protection)
This objection sets out:
1. The positive changes recognised in the revised RLDP
2. The continued reasons why the Eastbrook allocation remains unsound
3. A full technical hydrology and flood-risk chapter
4. Mandatory policy wording required to make the allocation sound
5. A formal request for written confirmation from the Vale of Glamorgan Council
6. Supporting diagrams (ASCII + placeholders)

The Community Council urges the Vale of Glamorgan Council to either:
• Remove the Eastbrook allocation from the RLDP, or
• Incorporate the mandatory policy wording and evidence requirements set out in this document.
Failure to do so will leave the RLDP vulnerable to challenge at Examination.

Examination.

SECTION 2 - INTRODUCTION
Dinas Powys Community Council (DPCC) submits this formal objection to the proposed allocation of the Eastbrook site (HG1 - KS2) within the Vale of Glamorgan Replacement Local Development Plan (RLDP). The Council recognises the importance of delivering sustainable housing across the Vale, and it acknowledges some of the positive changes made in the revised RLDP. However, the Eastbrook allocation remains fundamentally unsound due to unresolved and significant constraints relating to:
• Flood risk and hydrology
• Highways and transport capacity
• Environmental and landscape impact
• Infrastructure limitations
• Deliverability and viability
The Eastbrook site occupies a sensitive position within a complex hydrological catchment. The area is characterised by groundwater emergence, overland flow routes, low-permeability soils, and a history of significant flood events — most notably the 2020 incident, which affected properties downstream. Natural Resources Wales (NRW) has repeatedly highlighted concerns regarding flood risk at this location, and the Council’s own evidence base acknowledges the need for detailed catchment-wide modelling before any development can be considered.
Despite these known constraints, the RLDP does not currently include:
• Mandatory policy wording to secure pre-delivery of mitigation
• Requirements for catchment-wide modelling
• Guarantees that development will not increase flood risk elsewhere
• Mechanisms to ensure that mitigation is viable, deliverable, and enforceable
This objection sets out the failure to follow legal Consultation Procedural Soundness, the technical evidence, policy requirements, and mandatory safeguards necessary to make the RLDP sound. Without these safeguards, the allocation fails the tests of soundness, particularly:
• CE2 — Coherence and effectiveness
• CE3 — Environmental protection
• CE4 — Deliverability
This Council therefore requests either:
1. Removal of the Eastbrook allocation from the RLDP, or
2. Inclusion of the mandatory policy wording and evidence requirements set out in this document
Failure to address these issues will leave the RLDP vulnerable to challenge at Examination.

CHANGES IN THE REVISED RLDP
Dinas Powys Community Council (DPCC) recognises and welcomes some improvements made in the revised Replacement Local Development Plan (RLDP). These changes demonstrate a more balanced approach to growth and a clearer acknowledgement of environmental and infrastructure constraints across the Vale. DPCC considers the following amendments to be positive and constructive:
3.1 Reduction in Overall Housing Numbers
The reduction in the total housing requirement reflects a more realistic assessment of demographic trends, household formation rates, and deliverability across the plan period. This reduces pressure on constrained settlements such as Dinas Powys.
3.2 Greater Emphasis on Sustainable Locations
The revised RLDP places stronger emphasis on locating development where sustainable transport options exist. This aligns with national policy and reduces reliance on private car travel.
3.3 Strengthened Climate-Change and Flood-Risk Policies
The Council welcomes the enhanced policy framework relating to:
• Climate-change adaptation
• Flood-risk management
• Sustainable drainage (SuDS)
• Nature-based solutions
These changes reflect national guidance and NRW expectations.
3.4 Recognition of Infrastructure Constraints
The revised evidence base acknowledges that certain settlements – including Dinas Powys -face:
• Highway capacity limitations
• Public transport constraints
• Limited school and healthcare capacity
This recognition is essential for sound plan-making.

3.5 Improved Evidence Base
The updated background papers, including the Settlement Sustainability Assessment and the Infrastructure Assessment, provide a clearer picture of constraints and opportunities across the Vale.

SECTION 4 — CONTINUED OBJECTION TO THE EASTBROOK ALLOCATION
Despite recognising positive changes in the revised RLDP, Dinas Powys Community Council (DPCC) maintains a clear and evidence-based objection to the proposed allocation of the Eastbrook site (HG1 – KS2). DPCC email asked for clarification from the Vale planning office on the fact that the planning policy (dated 17 December 2025) stated ‘feedback received has helped to refine proposals for the sites in the deposit plan’. When asked at the consultation at Murchfield what the refinements were, the response was ‘there has not been any’.
The allocation remains unsound because the fundamental constraints affecting the site have not been resolved, mitigated, or fully understood.
DPCC’s objection is based on the following core issues:
4.1 Flood Risk and Hydrology
The Eastbrook site sits within a complex and sensitive hydrological catchment. Key concerns include:
• Groundwater emergence during prolonged wet periods
• Overland flow routes that cross the site and discharge toward existing residential areas
• Low-permeability soils that limit infiltration
• A history of significant flood events, including the 2020 incident
• Interactions between surface water, groundwater, and existing drainage systems
NRW has repeatedly raised concerns about flood risk at this location. The Council’s own evidence base acknowledges that catchment-wide modelling is required before any development can be considered. This modelling has not been undertaken.
4.2 Highways and Transport Capacity
Dinas Powys already experiences:
• Congestion on Cardiff Road
• Limited capacity at key junctions
• Insufficient public transport frequency
• High dependency on private car travel
The Eastbrook allocation would exacerbate these issues. No deliverable or funded mitigation has been identified.
4.3 Environmental and Landscape Impact
The site contributes to:
• Local landscape character
• Biodiversity connectivity
• Air quality
• Green infrastructure
• Natural drainage functions
Development would result in the loss of greenfield land that currently performs essential hydrological and ecological roles.
4.4 Infrastructure Limitations
Local infrastructure is already under pressure, including:
• Schools
• Healthcare provision
• Utilities
• Surface-water drainage systems
No evidence has been provided to demonstrate that these constraints can be resolved within the plan period.
4.5 Deliverability and Viability
The RLDP does not demonstrate that:
• Required flood-risk mitigation is technically feasible
• Mitigation is financially viable
• Mitigation can be delivered before development
• Mitigation will not increase flood risk elsewhere
Without this evidence, the allocation fails Soundness Test CE4 (deliverability).
Finally, there are questionable processes in the Consultation procedure that DPCC would like to question. These include:
Lack of Formalised Documentation and Transparent Feedback Loops: The consultation process currently lacks procedural transparency, specifically regarding the recording of public participation and the subsequent analysis of feedback. There is no evidence of formalised record-keeping for public attendance at engagement events, nor a transparent ledger of how individual resident comments were synthesised into the current Plan. Without clear feedback loops, it remains entirely unclear to stakeholders how local consultation responses have influenced site allocation decisions, compromising the Plan's legitimacy and accountability.
Significant Digital Barriers and Technical Complexity: The Council’s primary reliance on an "online-first" engagement strategy, through its consultation portal, has created substantial barriers to participation. The technical reports and modelling assumptions provided are often not easily interpretable by laypersons, limiting the ability of the community to effectively scrutinise the evidence base. The complexity of the account-creation process and the technical nature of the guidance notes have resulted in a disproportionate administrative burden that discourages meaningful public response.
Digital Exclusion and Demographic Disparity: The current consultation framework fails to adhere to the requirement that engagement must be "inclusive and accessible to all local groups", particularly those less likely to participate. Residents in Dinas Powys, specifically non-digitally native demographics and the elderly, face significant digital exclusion due to the lack of accessible summaries and the high level of technical literacy required to complete online forms. This lack of equitable access undermines the Council's duty to ensure a robust and representative evidence base.
Inflexible Scheduling and Inequitable Engagement Windows: The timing of the consultation periods has been identified as a factor that alienated or excluded significant portions of the local community. Despite formal requests from the DPCC for more accessible scheduling to facilitate wider public attendance, these requests were refused. Furthermore, there is a perceived pre-determination in the process, where preferred strategies and site directions appear to be announced prior to effectively engaging public opinion, rendering the subsequent consultation window a mere formality rather than a meaningful opportunity for influence.
Conclusion on Soundness: Due to these systemic failures in the Plan-making process, the RLDP fails the test of Effectiveness (CE2). Until the Council can demonstrate a fully transparent, accessible, and documented consultation process that genuinely reflects the lived experience of the community, the Plan cannot be considered fully justified or consistent with national policy regarding community involvement.
SECTION 5 — TRANSPORT AND HIGHWAYS

CONSTRAINTS

Transport and highways capacity remain a critical constraint for Dinas Powys and a central reason why the Eastbrook allocation is unsound. The settlement already experiences significant congestion with increasing air pollution (around critical areas such as schools), limited public transport provision, and constrained junction capacity. The RLDP does not demonstrate that these issues can be resolved within the plan period, nor does it provide evidence that the Eastbrook allocation can be delivered without exacerbating existing problems.

5.1 Existing Congestion and Network Stress

Dinas Powys suffers from chronic congestion, particularly along:

Cardiff Road The approach to the Merrie Harrier junction The route toward Penarth The route toward Barry

Peak-time delays are well-documented, and queueing frequently extends through residential areas. The network operates close to or at capacity during peak hours, leaving little room for additional traffic generated by new development.

5.2 Limited Public Transport Provision

Public transport options are constrained by:

Infrequent bus services Limited rail capacity at Eastbrook Station Poor integration between modes Lack of reliable alternatives to private car travel

The RLDP does not identify any committed or funded improvements that would materially increase public transport capacity.

5.3 Junction Capacity Constraints

Key junctions in and around Dinas Powys are already operating at or near capacity. These include:

Merrie Harrier junction Cardiff Road / Penlan Road Cardiff Road / Millbrook Road

No evidence has been provided to demonstrate that these junctions can accommodate additional traffic from the Eastbrook allocation.

5.4 Lack of Deliverable Mitigation

The RLDP does not include:

Funded highway improvements Committed public transport enhancements A deliverable transport strategy for Dinas Powys Evidence that mitigation is viable or achievable within the plan period

Without deliverable mitigation, the allocation fails Soundness Test CE4 (deliverability).

5.5 Cumulative Impact

The cumulative impact of, existing congestion, committed developments, background traffic growth and the Eastbrook allocation has not been assessed in a robust or comprehensive manner.

a. Unresolved Chronic Congestion on the A4055 Corridor:

The RLDP fails to demonstrate that the primary highway network serving Dinas Powys can accommodate the proposed level of growth without resulting in unacceptable congestion.

Existing Network Stress: The A4055 (Cardiff Road) and the approach to the Merrie Harrier junction are already characterized by "chronic congestion". Peak-time delays are well-documented, with queuing frequently extending through residential areas as the network operates at or near capacity.

Absence of Modelling: The Plan lacks transparent, settlement-specific junction capacity assessments or peak-hour traffic modelling for these key constraints. Without this evidence, the Council's assumption that an additional 250 units can be absorbed is technically unjustified.

The RLDP Preferred strategy requires the developer to provide "improvements to infrastructure, including the upgrading of highways. and utility networks" and provide "on and off-site measures" to provide safe linkages to Eastbrook Station and "upgrading of highways". It is unclear what if any specific and definitive instruction will be given to the developer and how the Council will monitor and ensure that appropriate objectives are achieved.

VOG Highways say that Persimmon cannot pencil in the 'secondary' or emergency access. Persimmon failed to do a traffic study to contest Highways' view. Another is no proposal to bring pedestrian/cycle access up to the Welsh Government standard. The suggested George's Row and Seel Park routes to Eastbrook Station and Camms Corner shopping area do not work. Highways point out this is a Welsh Government requirement for new developments.

In reference to Welsh Government's policies;

Policy conflict Fails PPW11 TAN 18, and the Fire and Rescue Services Act duty to maintain effective response capability. The proposal's reliance on a single access for a development of 250 dwellings is;

Contrary to PPW11 (safe, resilient access) Contrary to Tan 18 (avoid single points of failure) Contrary to Fire and Rescue operational requirements in Wales Contrary to Manual for Streets principles Contrary to established Welsh LHA practice Unsupported by appeal precedent.

The development therefore presents an unacceptable and avoidable risk to residents and emergency responders. A second access, or at minimum a fully engineered emergency only route, is essential to make the scheme safe and policy compliant.

b. Cumulative Traffic Flows from Regional RLDP Growth:

The RLDP directs a significant portion of the 7,890 required dwellings to settlements east of Dinas Powys, including major allocations in Barry and Penarth.

Impact of Neighbouring Allocations: Developments such as Upper Cosmeston Farm in Penarth (576 units) and the proposed growth in Barry (686 units) will significantly increase commuter volumes along the A4055, which serves as the primary arterial route to Cardiff.

Commuter Dependency: Data identifies Cardiff as the destination for 63.6% of all commuters from the Vale traveling by car. The RLDP fails to robustly assess the cumulative impact of background traffic growth, committed developments, and the Eastbrook allocation on the Dinas Powys road network. The Eastbrook allocation is fundamentally car-dependent due to infrequent bus services and limited modal integration. Furthermore, the RLDP does not identify any funded or committed highway improvements for the A4055 (Cardiff Road) or the Merrie Harrier junction, both of which are already operating at or near capacity. This lack of deliverable mitigation contradicts the transport objectives.

c. Failure of Active Travel and Pedestrian Infrastructure: The Plan relies on "sustainable transport options" to justify the Eastbrook site, yet the physical infrastructure is fundamentally non-compliant with inclusive design standards: Pavement Capacity and Safety: Existing pedestrian routes connecting the site to the village centre, are insufficient in width to accommodate double buggies or wheelchairs. These routes are further obstructed weekly by refuse collection and recycling bags, forcing vulnerable pedestrians - including those with single buggies or small children - to navigate restricted and unsafe spaces.

During the consultation (6th February 2026) Vale officers were asked if they had walked the proposed active travel route along Cardiff Road. We were told they had not. Photos below show how narrow the pavement is and this does not meet with the Active Travel Guidelines. There is no capacity to widen this route. In addition, the other proposed route via Powys Gardens involves a very steep hill. Would this be accessible for people with mobility scooters or mobility issues. It would also be a hazard in icy weather. This route also incorporates an alleyway which is not visible from start to finish with a 90 degree angle and no lighting. This is a safety concern. Another route is via some garages which are off George's Row. This is not and adopted road by the Vale and therefore not within their remit to propose it as an active travel route.

Eastbrook Railway Station Accessibility: While the station is within a 10-minute walk, it suffers from a critical "accessibility gap." Only one platform is accessible to residents with limited mobility, prams, or cycles. Due to the absence of a lift to the opposite platform, these residents must undertake a one-mile detour via local roads to access rail services, rendering the "sustainable" rail link effectively inaccessible to a significant portion of the demographic. Feedback from the Vale drop in session (6th February 2026), revealed that when residents mentioned that mothers with prams and people with mobility issues can't use the Eastbrook station, The response was 'it's fine for the majority'. When asked about the minority and about them being discriminated against there was no response. When looking at Active Travel Guidelines it references the Equality Act 2010. What dialogue has the Vale had with organisations representing people with protected characteristics.
d. Deficiencies in Public Transport Provision: The reliance on "good bus links" is not supported by current service levels:

Infrequent Bus Services: Dinas Powys is characterized by infrequent bus services that do not provide a reliable alternative to private car travel.

Lack of Mitigation: The RLDP does not identify any committed or funded improvements to bus frequency or capacity, ensuring that the Eastbrook development will remain car- dependent and exacerbate existing A4055 corridor failures. Without a committed and funded scheme to address the documented "chronic congestion" at the Merrie Harrier junction and A4055, the allocation fails the deliverability standards outlined in the RLDP Section 7.8.

Mandatory Policy Wording Required for Soundness: to address these obstacles and ensure they are not sidelined during the development process, the RLDP must include the following:

Enforceable policy wording to meet Soundness Tests CE2 (Effectiveness) and CE4 (Deliverability): Policy TR-DNP: Enforceable Transport and Accessibility Mitigation

Development at Eastbrook (HG1 - KS2), in the opinion of DPCC, should not be permitted unless the following criteria are met and delivered in advance of occupation:

1. Corridor Capacity and Cumulative Modelling: A comprehensive Cumulative Transport Assessment is completed and approved, demonstrating that the A4055 and Merrie Harrier junction can accommodate traffic from Eastbrook in combination with committed growth in Barry and Penarth without exceeding statutory capacity or safety limits. During the consultation Vale officers admitted that the road is already over capacity.

2. Eastbrook Station Bilateral Access: Legally binding funding and a delivery program are secured for the installation of a lift or accessible bridge at Eastbrook Railway Station to ensure bilateral platform access for all users, removing the current one-mile detour requirement.

However, having been in discussion with the Department of Transport, they have no plans to make any improvements to the station with regard to access.

3. Statutory Inclusive Pedestrian Widths: All off-site pedestrian linkages to the village centre and station are widened to meet statutory inclusive design standards, ensuring a minimum effective width for simultaneous passage of double buggies and wheelchairs. In line with the Active Travel Act has the Vale carried out an Equality impact assessment (EQIAs). Proposed active travel routes do not meet the criteria.

4. Operational Access Management: A Pedestrian Management Plan is approved, demonstrating how safe passage for prams and wheelchairs will be maintained during weekly refuse and recycling collections.

5. Secured Bus Enhancements: Written confirmation and funding are secured to increase bus service frequency to provide a genuine, high-frequency alternative to private car travel for Cardiff-bound commuters. Has a WelTAG survey has been carried out? Due to the volume of traffic through Dinas Powys a bus service is thinking of reducing the service as so much time is spent in static traffic. Evidence that these routes can be preserved or managed safely including evidence of Equality Impact Assessment (EQIAs). Evidence of the Active Travel Wales Act 2013. What reasonable measures have you taken to include children and young people in the planning and implementation and review of the decision-making process? Conclusion: In the absence of this 'mandatory wording' and the required 'technical modelling', the Eastbrook allocation is unsound. It ignores the physical reality of the infrastructure, the lived experience of residents on the A4055, and the cumulative traffic pressures generated by the RLDP's own regional growth strategy. Based on a review of the Vale of Glamorgan RLDP Preferred Strategy and the Final Review Report, the following technical objection focuses on the proposed delivery of 250 houses at the Eastbrook site. This objection highlights the failure to align the housing mix with local demographic needs, the lack of transparency regarding infrastructure funding, and the questionable justification for further large-scale growth in Dinas Powys. 5.6 Summary

The transport and highways evidence base does not demonstrate that the Eastbrook allocation can be delivered without causing severe impacts on the local network. The RLDP therefore fails to meet the requirements of national planning policy, which requires development to be located where sustainable transport options exist and where the impact on the transport network can be effectively mitigated.

SECTION 6 — ENVIRONMENTAL AND LANDSCAPE IMPACT

The Eastbrook allocation sits within a sensitive landscape setting that performs important ecological, visual, and hydrological functions. Development of this site would result in the permanent loss of greenfield land that currently contributes to the environmental quality and character of Dinas Powys. The RLDP does not demonstrate that these impacts can be acceptably mitigated.

6.1 Landscape Character and Visual Impact

The site forms part of the green corridor that separates Eastbrook from adjoining areas. It contributes to:

The semi-rural character of the settlement edge Views from public rights of way The visual transition between built form and open countryside The sense of openness and separation between neighbourhoods

Development would introduce built form into an area that currently provides visual relief and contributes to local identity.

6.2 Biodiversity and Habitat Connectivity

The site supports:

Hedgerows Grassland habitats Mature trees Wildlife corridors connecting to wider green infrastructure

These features provide habitat for a range of species and contribute to ecological connectivity across the settlement. Development would fragment these habitats and reduce biodiversity value.

6.3 Green Infrastructure Functions

The land performs several important green-infrastructure functions, including:

Natural drainage and infiltration Groundwater recharge Overland flow conveyance Urban cooling Carbon sequestration

These functions are particularly important given the site's hydrological sensitivity.

6.4 Impact on Local Amenity

The site provides informal amenity value for local residents, including:

Views Open space character A sense of separation between built areas

Development would reduce these qualities and alter the character of the local environment.

6.5 Lack of Robust Mitigation Evidence

The RLDP does not provide:

A landscape and visual impact assessment A biodiversity net-gain strategy A green-infrastructure plan Evidence that ecological impacts can be mitigated or compensated A clear demonstration that the site can deliver net environmental benefits

Without this evidence, the allocation fails Soundness Test CE3 (environmental protection).

Statutory Ecological and Environmental Impacts: The development will cause detrimental impacts on protected European sites and irreplaceable local habitats like Ancient Woodland.

Independent Source Verification:

The HRA of the Preferred Strategy (2023) explicitly flags Site 440 (HG1 - KS2 Land North of Dinas Powys) as being only 2.6km from the Severn Estuary SAC/SPA/Ramsar.

The HRA concludes that "Mitigation is Required" for this site because it falls within the core recreational catchment of the Estuary. It recommends that the RLDP must contribute to Strategic Access Management and Monitoring (SAMM) and the provision of alternative green spaces (SANG) to protect the integrity of the Estuary.

NRW's ECOR documents that previous attempts to build flood storage in the area were opposed by the Woodland Trust because they would threaten Ancient Woodland, which is described as an "irreplaceable natural resource".

Prematurity regarding Green Infrastructure (Policy SP10 / MG18): Section 7.10 of the Review Report mandates a new Green Infrastructure Assessment (GIA) to comply with updated national policy (PPW) and the Section 6 duty to enhance biodiversity.

Grounds for Objection: The Review Report highlights that this GIA is intended to "inform plan policies and policy wording". Furthermore, independent evidence confirms the Eastbrook area is subject to Policy MG18 (Green Wedge), where development that prejudices the "open nature of the land" is prohibited. Allocating Eastbrook before the completion of the settlement-specific GIA and a formal review of the Green Wedge's integrity contradicts the sequential approach described in Section 7.

To prevent irreversible damage to the environment and ensure the ecological integrity of Dinas Powys, the RLDP must move beyond high-level assumptions. Based on the evidence in the sources, the following measures are strictly necessary to protect the local and regional environment from the impacts of the proposed Eastbrook development:

1. Mandatory Hydrological Safeguards: The Eastbrook site sits within a complex catchment characterized by groundwater emergence and low-permeability soils. To prevent increased flood risk to the environment and existing properties, the following must be delivered:

Catchment-Wide Hydraulic Modelling: A full model, agreed with Natural Resources Wales (NRW), must be completed to assess surface water, groundwater, and overland flow. This model must specifically incorporate data from the 2020 flood event to demonstrate "no increase in flood risk" to any property within the catchment.

Preservation of Natural Drainage: Existing overland flow routes and groundwater pathways must be preserved, enhanced, or appropriately managed to prevent the displacement of water into sensitive habitats or residential areas.

Proven SuDS Feasibility: A detailed study is required to prove that Sustainable Drainage Systems (SuDS) can operate effectively given the site's documented high groundwater levels and limited infiltration capacity.

2. Protection of Irreplaceable Habitats: The development area includes and is adjacent to Ancient Woodland and Sites of Importance for Nature Conservation (SINC), such as Coed Clwyd-Gwyn and Case Hill Wood.

Avoidance of Loss: Ancient woodland is an "irreplaceable natural resource". To prevent environmental damage, the Council must demonstrate that development will not result in its loss or deterioration, as "no amount of tree planting" can replace the unique biodiversity and interactions developed over centuries in these woods.

Connectivity and Resilience: The Plan must secure a Green Infrastructure Plan that maintains wildlife corridors and prevents the fragmentation of habitats for protected species, including bats, otters, and dormice.

Hydrological Stability: Measures must ensure that the development does not cause nutrient enrichment or pollution of woodland soils via sediment-heavy floodwaters, which can destabilize trees and kill overwintering species.

3. Mitigation for European Protected Sites: The Habitats Regulations Assessment (HRA) confirms that the Eastbrook site (Site 440 - HG1 - KS2) has "medium-high suitability" as off-site supporting habitat for the Severn Estuary SPA/Ramsar. To prevent an adverse effect on the integrity of this site, the following is necessary:

Bird Surveys and Evidence: The applicant must provide non-breeding bird surveys covering autumn, winter, and spring to determine if the site constitutes "functionally linked habitat" (supporting >1% of a qualifying population). Enforceable Mitigation: If significant populations are identified, the development must include avoidance measures and be assessed through a project-specific HRA.
4. Air Quality and Carbon Mitigation: Dinas Powys suffers from chronic congestion on the A4055, yet location-specific air quality modelling is absent from the evidence base. Cumulative Impact Modelling: To prevent harm to human health and the environment, the Council must conduct detailed air quality modelling that tests the cumulative effect of growth in Eastbrook alongside regional growth in Barry and Penarth. Decarbonisation Standards: New development must contribute to the Council's Net Zero 2030 ambition through siting and design that prioritizes active travel over car dependency, thereby reducing vehicle emissions.
5. Infrastructure Pre-Delivery: To prevent environmental harm from overloaded systems, essential infrastructure must be phased correctly: Wastewater Capacity: A settlement-specific assessment must prove the consented capacity of local wastewater treatment works is sufficient to prevent sewer surcharging and the discharge of untreated water into local watercourses. Phasing Requirements: All required infrastructure upgrades-including drainage, utilities, and highways mitigation-must be delivered and operational in advance of occupation. Conclusion: Without these mandatory policy safeguards and the completion of the required technical evidence base, the Eastbrook allocation remains unsound and poses a significant risk of irreparable damage to the environment of Dinas Powys.

SECTION 7 — INFRASTRUCTURE CAPACITY AND SERVICE LIMITATIONS

Infrastructure capacity is a critical determinant of whether a site is suitable and deliverable within the RLDP period. In the case of Eastbrook, the evidence demonstrates that essential infrastructure in Dinas Powys is already under significant pressure. The RLDP does not provide clear, funded, or deliverable solutions to these constraints, nor does it demonstrate that the Eastbrook allocation can be supported without unacceptable impacts on existing residents.

7.1 Education Capacity

Local schools are operating at or near capacity. Key issues include:

Limited availability of primary school places Pressure on secondary school capacity within the wider catchment. No identified funding or land for expansion No evidence that developer contributions would be sufficient or timely

The RLDP does not demonstrate that additional demand generated by the Eastbrook allocation can be accommodated.

Education Provision and School Oversubscription: The RLDP identifies Dinas Powys as a sustainable location for growth, yet it fails to provide settlement-specific evidence that local schools can absorb the additional demand from 250 new homes.

Capacity Deficit: Local primary and secondary schools are already operating at or near peak capacity. Existing data indicates limited availability of primary school places and significant pressure on secondary school capacity within the wider catchment area.

Lack of Expansion Capability: There is no identified land or secured funding for the physical expansion of these schools. The Plan provides no evidence that developer contributions (Section 106) would be sufficient or timely enough to resolve these standard-of-service deficits prior to the occupation of new homes.

Policy Inconsistency: Proceeding with the allocation without a confirmed delivery plan for school places is contrary to Planning Policy Wales, which requires growth to be directed only where essential infrastructure is available or can be secured.

To ensure that education capacity is not "overridden" by strategic regional data, the following enforceable requirement should be incorporated into Policy SP4 KS2: Policy ED-DNP: Mandatory Local Education Capacity Confirmation "Development at Eastbrook will not be permitted unless:

1. Direct Local School Consultation: A formal School Capacity Impact Report is submitted, based on direct consultation with the Headteachers and Governing Bodies of the specific schools within the Dinas Powys catchment area.

2. Verified Local Headroom: The report must provide written confirmation from these local institutions that they have the physical classroom space and staff capacity to accommodate the projected pupil yield from the development without increasing class sizes beyond statutory limits or compromising educational standards.

3. Local vs. Authority Primacy: High-level strategic projections from the Education Authority shall be deemed insufficient evidence of deliverability if they are contradicted by the operational data and physical constraints identified by the local schools themselves.

4. Pre-commencement Delivery: Any required physical expansions or new school infrastructure must be fully funded, completed, and operational prior to the occupation of the first dwelling to ensure places are available when needed

7.2 Healthcare Provision

Healthcare services in Dinas Powys and the surrounding area face:

Limited GP medical centre capacity Long waiting times Pressure on community health services No committed investment to expand provision

The medical services serving Dinas Powys are currently at capacity, and the RLDP fails to identify a mechanism to expand provision in line with population growth. Whilst it's understood that the Vale Council have spoken with the local health board. Unfortunately, there has been no consultation with single medical centre in Dinas Powys. They would be best placed to comment on the significant impact of additional housing on their provision of healthcare which is already stretched well beyond its limits.

GP and Dental Strain: Local residents already experience limited medical GP capacity and long waiting times. Existing community health services are under "significant pressure," and there is no committed investment to expand these facilities across Dinas Powys.

Lack of Local Consultation: While the Council claims to work at a high level with the Cardiff and Vale University Health Board, there has been no direct consultation with the local Health Centre serving Dinas Powys. Consequently, the Plan does not account for the technical and operational realities of a surgery that is already at capacity and cannot absorb the projected increase in patient numbers. A direct operational capacity verification from the Dinas Powys Medical Centre - current patient list size is around 11k which has increased significantly due to the closure of a nearby practice and therefore the practice is experiencing a reduced operational capacity. Any additional housing would put further strain on the practice demands and waiting times for local residents and would mean the practice moves further outside the idealised UK average (1 GP per 1,400-1,600 patients).

Health Inequality Risk: Without settlement-specific planning and confirmed provision, the proposed growth risks reducing access to healthcare for both existing and new residents, directly undermining the health and well-being objectives set out in Policy SP6.

7.3 Utilities and Drainage

Utility networks in the area face known constraints:

Surface-water drainage systems are already under pressure Foul drainage capacity is limited Welsh Water has previously raised concerns about network capacity in the settlement No evidence has been provided to demonstrate that upgrades are deliverable within the plan period

Given the site's hydrological sensitivity, drainage capacity is a critical issue.

7.4 Emergency Services and Community Infrastructure

The Eastbrook allocation would place additional pressure on:

Emergency services Community facilities Local open space Recreational infrastructure

No evidence has been provided to demonstrate that these services can absorb additional demand.

7.5 Funding and Deliverability

The RLDP does not identify:

Committed funding a delivery programme a mechanism to secure timely infrastructure upgrades Evidence that developer contributions would be viable or sufficient

Without this, the allocation fails Soundness Test CE4 (deliverability).

7.6 Summary

Reference Environment and Regeneration Scrutiny Committee 14 January 2025 it states. 'Produce sustainable Urban Drainage Solutions'. No progress due to funding and competing priorities. Infrastructure in Dinas Powys is already excessively stretched. The RLDP does not demonstrate that the Eastbrook allocation can be supported without a significant adverse impact on existing residents. Nor does it provide evidence that required upgrades are viable, deliverable, or fundable within the plan period.

SECTION 8 — HYDROLOGY AND FLOOD-RISK ANALYSIS (FULL TECHNICAL CHAPTER)

The Eastbrook site lies within a hydrologically sensitive catchment characterised by complex interactions between surface water, groundwater, overland flow, and existing drainage infrastructure. The site has a documented history of flooding, including the significant 2020 event, and Natural Resources Wales (NRW) has repeatedly raised concerns about the potential for development to increase flood risk elsewhere. At the Vale Council's drop-in session (6th Feb), there was a lack of knowledge that there is a Holy Well on the Eastbrook site, referenced in the NRW report on flooding (NRW Dinas Powys Flood Risk Management Scheme OBC page 10).

This section provides a technical assessment of the hydrological constraints affecting the site and sets out the evidence required to ensure that any development does not exacerbate flood risk to existing properties.
8.1 Catchment Overview
The Eastbrook site forms part of a small but highly responsive catchment. Key characteristics include: Low-permeability soils, resulting in rapid surface-water runoff Groundwater emergence during prolonged wet periods Overland flow routes crossing the site and discharging toward existing residential areas Limited infiltration capacity, reducing the effectiveness of SuDS Downstream constraints within the existing drainage network The catchment responds quickly to rainfall, with limited storage capacity and a high risk of exceedance during intense or prolonged events.

8.2 Hydrological Function of the Site

The site currently performs several important hydrological functions:

Attenuation of surface water during storm events Conveyance of overland flow along natural depressions Groundwater emergence and dissipation Reduction of peak flows entering downstream drainage systems Natural infiltration, albeit limited by soil type

Development would significantly alter these functions, increasing runoff rates and volumes unless substantial mitigation is provided.

8.3 Overland Flow Routes

Multiple overland flow routes cross the site. These routes convey water:

From higher ground to the north and east Across the site during heavy rainfall Toward existing residential areas downstream

Below is an ASCII-style conceptual diagram illustrating the simplified flow pattern:

Code [Higher Ground]

V

Overland Flow Across Site

V [Existing Residential Area] (Downstream Flood Receptors)

Diagrammatic representation for illustrative purposes only - not to scale.

These routes are active during moderate and heavy rainfall events and were observed during the 2020 flood incident.

8.4 Groundwater Emergence

Groundwater emergence has been recorded on and around the site during:

Prolonged wet periods High antecedent moisture conditions Winter months

This groundwater emergence contributes to:

Saturated ground conditions Reduced infiltration capacity Increased surface-water runoff Localised flooding

Any development must demonstrate that it will not alter groundwater pathways or increase groundwater-related flood risk.

8.5 The 2020 Flood Event

The 2020 flood event provides clear evidence of the site's hydrological sensitivity. During this event:

Overland flow crossed the site Groundwater emergence contributed to saturated conditions Downstream properties experienced flooding Existing drainage systems were overwhelmed

The event demonstrated that:

The catchment is highly responsive The site plays a critical role in attenuating and conveying water Development could increase flood risk unless carefully managed

The RLDP does not include any analysis of the 2020 event, nor does it require developers to assess its implications.

8.6 NRW Position and Evidence Requirements

NRW has consistently raised concerns about:

Surface-water flood risk Groundwater interactions Overland flow routes Downstream flood receptors Lack of catchment-wide modelling

NRW has advised that catchment-wide hydraulic modelling is required to:

Understand baseline conditions Assess the impact of development Identify necessary mitigation Ensure no increase in flood risk elsewhere

This modelling has NOT been undertaken.

The RLDP flood risk evidence base is functionally obsolete. It relies on the 2013 Local Flood Risk Management Strategy and a September 2020 NRW decision to abandon capital mitigation. Both of these were rendered technically invalid by the scale of the December 2020 flood event. NRW has not formally reviewed or updated a mitigation strategy for this catchment in the 11 years since the original LFRMS was published. NRW's last formal review of flood mitigation for this area was the September 2020 ECOR, which predates the 2020 flood. No post-flood mitigation review or catchment modelling incorporating the 2020 data has been undertaken.

8.7 Limitations of SuDS on This Site

While SuDS are a national requirement, their effectiveness on this site is constrained by:

Low-permeability soils High groundwater levels Limited infiltration potential Steep localised gradients Overland flow pathways that cannot be obstructed

SuDS alone cannot mitigate the hydrological impacts of development without:

Catchment-wide modelling Detailed design Pre-delivery of mitigation Long-term maintenance arrangements

8.8 Required Mitigation Measures

To ensure no increase in flood risk, the following mitigation measures would be required:

Catchment-wide hydraulic modelling Preservation of overland flow routes On-site attenuation with exceedance routing Groundwater management measures Upgrades to downstream drainage systems Pre-delivery of mitigation before development commences

The RLDP does not secure any of these measures.

8.9 Summary

The Eastbrook site is hydrologically complex and highly sensitive. Without detailed catchment-wide modelling and enforceable mitigation, development would increase flood risk to existing properties. The RLDP does not provide the evidence or policy framework required to ensure that the allocation is sound.

Natural Resources Wales (NRW) has not formally reviewed or updated its flood mitigation plans for Dinas Powys since the major flood event on December 23, 2020. The evidence base reveals a critical gap between the last strategic planning and the reality of the 2020 disaster:

1. The "2013 Strategy" Precedent: The Local Flood Risk Management Strategy (LFRMS) for the Vale of Glamorgan is dated December 2013. While this document identified Dinas Powys as being at "significant future risk," it is now over a decade old and predates both the 2020 flood and updated climate change projections. Reference Environment and Regeneration Scrutiny Committee 14 January 2025 it states. 'Implement a flood risk management plan and shoreline management plan'. No progress due to funding and competing priorities.

The above shows that the concerns of residents and flood issues in Dinas Powys are not being taken seriously.

2. Pre-Flood Rejection of Mitigation (September 2020): The most recent formal NRW assessment regarding a strategic flood scheme for Dinas Powys - the Environmental Constraints and Opportunities Record (ECOR) - was completed in September 2020, just three months before the major flood event.

A "Walkaway" Conclusion: In that pre-flood report, NRW concluded it was "unable to justify a capital flood scheme" for Dinas Powys because it was deemed only "marginally cost-beneficial".

Status Quo: NRW stated they would continue only with "business as usual" (manual channel clearing) rather than any new structural mitigation.

3. No Post-Flood Review of Mitigation: While NRW conducted "flood reconnaissance" in January 2021 and contributed to the Section 19 Flood Investigation Report (published in November 2021), these were investigative documents rather than updated mitigation plans. Missing Evidence Base: The sources explicitly state that "no catchment-wide hydraulic modelling has been undertaken" that incorporates the actual data and observations from the December 2020 event.

Outstanding Recommendations: The Section 19 report concluded by recommending that NRW "consider the viability of options to reduce flood risk," which confirms that such a review had not yet taken place as of late 2021.

4. RLDP Soundness Failure: The current RLDP is being challenged because it relies on high- level strategic data that ignores the 2020 flood event entirely.

The objection drafts note that the RLDP "does not include any analysis of the 2020 event" nor does it require developers to assess its implications.

Without an NRW-approved model that accounts for the 98 internal property floodings observed in 2020, the Council cannot technically prove that 250 additional houses will not increase flood risk elsewhere.

In conclusion, in this respect, the RLDP is unsound because its flood evidence base is functionally obsolete. It relies on a 2013 Strategy and a September 2020 NRW decision to abandon mitigation-both of which were rendered invalid by the scale of the December 2020 flood. NRW has not reviewed or modelled a new mitigation strategy for the catchment since that event occurred, leaving the settlement and the proposed site without any verified protection.

SECTION 9 — MANDATORY POLICY WORDING REQUIRED TO MAKE THE RLDP SOUND

To ensure that the Eastbrook allocation is sound, the RLDP must include explicit, enforceable, and unambiguous policy wording that secures the necessary hydrological, environmental, and infrastructure safeguards. Without this wording, the allocation fails the tests of soundness - particularly CE2 (coherence and effectiveness), CE3 (environmental protection), and CE4 (deliverability).

The following policy wording is mandatory to ensure that development does not increase flood risk elsewhere and that mitigation is viable, deliverable, and enforceable.

9.1 Mandatory Flood-Risk Policy Wording

The RLDP must include the following:

Policy FR-X: Catchment-Wide Flood-Risk Assessment (Mandatory Requirement) Development at Eastbrook (HG1 - KS2) will not be permitted unless:

1. A full catchment-wide hydraulic model has been prepared, agreed with Natural Resources Wales (NRW), and approved by the Local Planning Authority (LPA). 2. The model demonstrates no increase in flood risk to any existing property within the catchment for all relevant storm events, including climate-change allowances. 3. All required mitigation measures are: Technically feasible Financially viable Deliverable within the plan period Secured through planning conditions or legal agreement 4. All mitigation measures are delivered prior to the commencement of development. 5. Overland flow routes, groundwater pathways, and natural drainage functions are preserved, enhanced, or appropriately managed. 6. A long-term management and maintenance plan for all SuDS and flood-risk infrastructure is secured.

9.2 Mandatory Groundwater and Overland Flow Policy Wording Policy FR-Y: Groundwater and Overland Flow Protection Development proposals must:

Demonstrate that groundwater emergence will not be exacerbated Preserve all existing overland flow routes Provide exceedance routing that avoids existing residential areas Incorporate groundwater-resilient design measures Avoid any obstruction of natural drainage pathways

No development will be permitted unless these requirements are met in full.

9.3 Mandatory SuDS Policy Wording

Policy SuDS-X: Sustainable Drainage Requirements

All development must:

Provide SuDS designed in accordance with national standards Demonstrate that infiltration-based SuDS are viable, or provide alternatives where infiltration is not feasible Include attenuation sized using catchment-wide modelling outputs Provide exceedance routing that avoids downstream receptors Secure long-term maintenance arrangements

SuDS must be operational before any dwelling is occupied.

9.4 Mandatory Infrastructure Delivery Policy Wording

Policy INF-X: Infrastructure Delivery and Phasing

Development at Eastbrook (HG1 - KS2) will not be permitted unless:

All required infrastructure upgrades (education, healthcare, utilities, drainage, highways) are identified Funding is secured Delivery is guaranteed within the plan period Infrastructure is delivered in advance of occupation

The RLDP must demonstrate that infrastructure delivery is viable and enforceable.

9.5 Summary

Without the mandatory policy wording set out above, the RLDP:

Does not secure the evidence required to assess flood risk Does not guarantee that mitigation will be delivered Does not ensure that development will not increase flood risk elsewhere Does not demonstrate deliverability Fails multiple tests of soundness

The inclusion of this wording is essential to ensure that the Eastbrook allocation is sound, effective, and compliant with national policy.

SECTION 10 - HOUSING DELIVERY AND

DEMOGRAPHIC MISALIGNMENT

While Section 4 of the review of the RLDP focuses on high-level data across the Vale, DPCC utilises these specific evidence base shifts to argue that the Eastbrook allocation is no longer justified under the new planning context. The Vale Council have removed S106 affordable housing money (£1m) from Dinas Powys, as we were told there are no housing developments planned and the funds were reallocated to Myrtle Close which negates the suggestion in the RLDP that there is a need for affordable housing in Dinas Powys. Therefore the development should be removed from the RLDP or the S106 moved back to Dinas Powys.

Mapping Section 4 Evidence to Dinas Powys Objections:

1. Review Report Ref: 4.1.1 4.1.11 (Population and Household Projections): Review Report Context: This section details the transition from 2011-based projections to the more recent 2018-based Welsh Government projections, noting a "significant departure" from the evidence that underpinned the original LDP.

Relationship to Dinas Powys: DPCC explicitly links this update to their objection in Ref: this response section 3.1 (Reduction in Overall Housing Numbers). We argue that the more realistic assessment of demographic trends and the subsequent reduction in the total housing requirement for the Vale should "reduce pressure on constrained settlements such as Dinas Powys". We maintain that with lower overall demand, the "unnecessary" and high-risk allocation at Eastbrook should be the first to be removed.

2. Review Report Ref: 4.2.1 - 4.2.15 (Economic Considerations and Employment): Review Report Context: This section reviews the employment land supply and economic growth scenarios for the 2021-2036 period. It lists major strategic employment sites, none of which are located within Dinas Powys.

Relationship to Dinas Powys: In the Preferred Strategy and subsequent objections, Dinas Powys is categorised as a Primary Settlement. DPCC points out that since the Review Report identifies economic and employment growth as being concentrated in the "Strategic Growth Area" (Barry, Rhoose, St Athan), allocating 250 houses in Dinas Powys creates a car-dependent commuter settlement. This contradicts the Review Report's emphasis on aligning housing with major employment hubs to reduce private car travel.

3. Review Report Ref: 4.3.1 (Conclusion on Evidence Base Changes): Review Report Context: The report concludes that the updated population, economic, and legislative evidence represents a "significant departure from that which informed the existing LDP" and supports the need for a full replacement plan.

Relationship to Dinas Powys: DPCC uses this conclusion to support their Ref: this response section 3.5 (Improved Evidence Base) objection. We argue that because the Vale Council's own Review Report acknowledges a "significant departure" in the evidence base, the Council must also acknowledge that the previous assumptions
regarding the deliverability of Eastbrook are now invalid. Specifically, they point to the "improved picture of constraints" (such as the 2020 flood event) that must be re- evaluated under the "robust and transparent" evidence standards called for in Section 4 of this response. Summary of Evidence Linkage: Section 4 of the Review Report provides the technical justification for a "Realistic assessment" of growth. DPCC's position is that if the Vale Council follows its own evidence in Section 4 - which shows lower housing need and a concentration of employment elsewhere - it cannot logically justify a large-scale housing development on a high-flood-risk greenfield site in a "constrained settlement" like Dinas Powys.

SECTION 11 - REQUIRED EVIDENCE FROM THE VALE OF GLAMORGAN COUNCIL

For the Eastbrook allocation to be considered sound, DPCC request that the Vale of Glamorgan Council must provide clear, transparent, and technically robust evidence demonstrating that the site is:

Deliverable Developable Environmentally acceptable Hydrologically safe Supported by adequate infrastructure

At present, this evidence is absent from the RLDP. The following items are required before the allocation can be considered sound.

11.1 Catchment-Wide Hydraulic Modelling

The Council must provide:

A full catchment-wide hydraulic model Prepared in consultation with NRW Covering surface water, groundwater, and overland flow Including climate-change allowances Assessing the 2020 flood event Demonstrating no increase in flood risk to existing properties

This modelling is essential to understand baseline conditions and the impact of development.

11.2 Groundwater Assessment

A detailed groundwater assessment is required to:

Map groundwater emergence zones Assess seasonal variations Identify groundwater pathways Determine the impact of development on groundwater levels Demonstrate that development will not exacerbate groundwater flooding

No such assessment has been provided.

11.3 Overland Flow Route Mapping

The Council must provide:

High-resolution mapping of overland flow routes Assessment of exceedance pathways Identification of downstream receptors

This is particularly important given the 2020 flood event.

11.4 SuDS Feasibility Study

A SuDS feasibility study must be provided to:

Assess infiltration potential Identify viable SuDS options Determine attenuation requirements Demonstrate that SuDS can operate effectively given soil and groundwater constraints

Without this, SuDS cannot be assumed to mitigate flood risk.

11.5 Downstream Drainage Capacity Assessment

The Council must provide:

A full assessment of downstream drainage capacity Identification of constraints Required upgrades Funding mechanisms Delivery timescales

This is essential to ensure that development does not overload existing systems.

11.6 Infrastructure Delivery Plan (IDP) Evidence

The IDP must demonstrate:

Education capacity solutions Healthcare capacity solutions Utilities upgrades Drainage improvements Highways mitigation Funding sources Delivery timescales Viability

At present, the IDP does not provide this level of detail.

11.7 Transport Assessment

A comprehensive transport assessment is required to: Assess cumulative impacts Model peak-time flows Identify junction constraints Provide deliverable mitigation Demonstrate that sustainable transport options exist No such assessment has been provided. 11.8 Landscape and Ecology Evidence

The Council must provide: A landscape and visual impact assessment A biodiversity net-gain strategy A green-infrastructure plan Evidence that ecological impacts can be mitigated These are essential to comply with national policy.
11.9 Summary

The RLDP currently lacks the evidence required to demonstrate that the Eastbrook allocation is: Safe Deliverable Environmentally acceptable Supported by adequate infrastructure Until this evidence is provided, the allocation remains unsound.

SECTION 12 — SCHEMATIC DIAGRAMS (ASCII + PLACEHOLDERS)

This section provides conceptual diagrams to support the hydrological and technical evidence presented earlier. These are illustrative only, not to scale, and intended to help the Inspector and Vale of Glamorgan officers visualise the key issues. Each diagram includes:

An ASCII sketch for immediate clarity A placeholder label for later replacement with a formal graphic in the final PDF

12.1 Diagram 1 — Catchment Overview (Placeholder: FIG-01)

Code [Higher Ground] /\ / \ / V V

Eastbrook Site (Low permeability I soils)

V [Downstream Residential Area]

Placeholder: FIG-01 - Catchment Overview Diagram

12.2 Diagram 2 - Overland Flow Routes (Placeholder: FIG-02)

Code Rainfall I V

Field <-- Overland flow entering site

V

Eastbrook Site Natural flow path I

V [Existing Properties]

Placeholder: FIG-02 - Overland Flow Route Mapping

3712.3 Diagram 3 — Groundwater Emergence Zones (Placeholder: FIG-03)

Code Subsurface Water Table

^ ^ ^ I (Groundwater emergence)

| Eastbrook Site I Saturated ground I

Placeholder: FIG-03 - Groundwater Emergence Conceptual Diagram

12.4 Diagram 4 - SuDS Limitations (Placeholder: FIG-04)

Code [Rainfall]

V [SuDS Basin]

I (Low infiltration) V [Standing Water] I V Risk of exceedance flow I V [Downstream Properties]

Placeholder: FIG-04 - SuDS Feasibility Constraints Diagram

12.5 Diagram 5 - Required Mitigation Sequence (Placeholder: FIG-05)

Code Step 1: Catchment-wide model I V Step 2: Identify mitigation I V Step 3: Secure funding & delivery

V Step 4: Construct mitigation | V Step 5: Only then permit development

Placeholder: FIG-05 - Mitigation Delivery Sequence Diagram

SECTION 13 — FORMAL REQUEST FOR WRITTEN CONFIRMATION FROM THE VALE OF GLAMORGAN COUNCIL

Given the significant unresolved constraints associated with the Eastbrook allocation, Dinas Powys Community Council formally requests written confirmation from the Vale of Glamorgan Council addressing the following matters. These confirmations are essential to demonstrate that the allocation is sound, deliverable, and compliant with national policy.

The Council requests that the Vale of Glamorgan provides a written response to each point below.

13.1 Confirmation of Catchment-Wide Modelling

Please confirm:

Whether a catchment-wide hydraulic model has been commissioned Whether NRW has been consulted on the scope Whether the model includes surface water, groundwater, and overland flow Whether the model assesses the 2020 flood event Whether the model demonstrates no increase in flood risk to existing properties

If no such model exists, please confirm:

When it will be commissioned When it will be completed Whether the RLDP will be updated to include its findings

13.2 Confirmation of Groundwater Assessment

Please confirm:

Whether a detailed groundwater assessment has been undertaken Whether groundwater emergence zones have been mapped Whether development will alter groundwater pathways Whether mitigation is technically feasible

If no assessment exists, please confirm when it will be prepared.

13.3 Confirmation of Overland Flow Route Mapping

Please confirm:

Whether high-resolution overland flow mapping has been completed Whether exceedance routes have been identified Whether these routes can be preserved within the development layout

If not, please confirm when this work will be undertaken.

13.4 Confirmation of SuDS Feasibility

Please confirm:

Whether infiltration testing has been undertaken Whether infiltration-based SuDS are viable Whether attenuation volumes have been calculated Whether SuDS can operate effectively given soil and groundwater constraints

If not, please confirm when a SuDS feasibility study will be completed.

13.5 Confirmation of Downstream Drainage Capacity

Please confirm:

Whether downstream drainage capacity has been assessed Whether upgrades are required How upgrades will be funded When upgrades will be delivered Whether upgrades will be delivered before development begins

If no assessment exists, please confirm when it will be undertaken.

13.6 Confirmation of Infrastructure Delivery

Please confirm:

How education capacity will be increased How healthcare capacity will be expanded How utilities and drainage upgrades will be funded How highways mitigation will be delivered Whether all required infrastructure is viable and deliverable within the plan period

If not, please confirm when the Infrastructure Delivery Plan will be updated.

13.7 Confirmation of Transport Assessment

Please confirm:

Whether a cumulative transport assessment has been undertaken Whether junction capacity constraints have been modelled Whether deliverable mitigation has been identified Whether sustainable transport improvements are committed and funded

If not, please confirm when this work will be completed.

13.8 Confirmation of Environmental and Landscape Evidence

Please confirm:

Whether a landscape and visual impact assessment has been prepared Whether a biodiversity net-gain strategy exists Whether a green-infrastructure plan has been completed Whether location-specific modelling to assess air quality, specifically, near schools at peak times has been undertaken.

If not, please confirm when these assessments will be undertaken.

13.9 Summary

The Vale of Glamorgan Council must provide written confirmation addressing each of the above points. Without this information, the Eastbrook allocation remains unsupported by evidence and therefore fails multiple tests of soundness.

13.10 Key objections

1. Procedural and Consultation Failures

Lack of Transparency: There is no evidence of formal record-keeping for public attendance at events or a transparent ledger showing how resident feedback was synthesized into the Plan.

Digital Barriers and Exclusion: The "online-first" strategy and complex account- creation process created a disproportionate burden for residents, particularly non-digitally native and elderly demographics who lacked accessible summaries.

Pre-determination: The requests, by DPCC, for more accessible scheduling were refused, leading to a perception that strategies were fixed prior to engaging public opinion.

When asked about the revised plans as stated in an email to DPCC we were told there were none. 2. Hydrology and Unresolved Flood Risk

The 2020 Flood Precedent: On December 23, 2020, a storm caused internal flooding to 98 properties in Dinas Powys. The Section 19 Flood Investigation Report confirmed "hydraulic locking" occurred, where elevated river levels prevented surface water systems from discharging, causing sewer surcharging.

Obsolete Evidence Base: The RLDP relies on a 2013 Strategy and a September 2020 NRW decision that predates the major 2020 flood. No catchment-wide modelling incorporating 2020 data has been undertaken.

SuDS Infeasibility: High groundwater (as shallow as 1.83m) and shallow bedrock render standard infiltration-based Sustainable Drainage Systems (SuDS) unproven and high-risk for this site.

3. Transport and Highways Constraints

Chronic Congestion: The A4055 (Cardiff Road) and Merrie Harrier junction are already at capacity. The Plan fails to assess the cumulative impact of major regional growth in Barry (376 units) and Penarth (576 units) on these local corridors.

Active Travel and Accessibility Failures: Eastbrook Station lacks bilateral access; residents with limited mobility or prams must undertake a one-mile detour to reach the Cardiff-bound platform because there is no lift.

Safety Issues: Existing pedestrian routes are too narrow for double buggies and are frequently obstructed by weekly refuse collections, forcing vulnerable pedestrians into the carriageway.

4. Exhausted Social and Utility Infrastructure

Healthcare Strain: The Dinas Powys Medical Centre is at full capacity with a list size of approximately 11,000 patients, far exceeding idealized UK GP-to- patient ratios.

Education Capacity: Local schools are operating at or near peak capacity with no identified land or funding for expansion.

Wastewater Capacity: There is no settlement-specific evidence that the consented capacity of local treatment works can accommodate 250 additional dwellings without risk of sewer surcharging.

5. Environmental and Ecological Impact

Irreplaceable Habitats: The site is adjacent to Ancient Woodland (Coed Clwyd-Gwyn and Case Hill Wood), which cannot be mitigated by new planting.

European Protected Sites: The HRA confirms the site is within 2.6km of the Severn Estuary SAC/SPA/Ramsar and explicitly concludes that "Mitigation is Required".

Air Quality: The Dinas Powys Roadside monitoring station was closed in 2016, and the Plan lacks location-specific modelling to assess the impact of increased peak-time idling near schools.

6. Housing Delivery and Demographic Misalignment Lack of Downsizing Options: Despite an aging population, the Plan contains no mandatory requirement for single-story bungalows, which are needed to free up family-sized housing stock. Affordable Housing Viability: The Community Council argues that high un- costed infrastructure burdens (flood and highway mitigation) make the 40% affordable housing target financially unviable.

S106 Transparency: £1M in S106 affordable housing funds from previous developments was diverted away from Dinas Powys because we were told there were no housing developments in Dinas Powys. Therefore the money has to be refunded or the 250 houses removed from the RLDP.

SECTION 14 — INITIAL E-MAIL FROM DPCC TO VALE OF GLAMORGAN COUNCIL (dated 29/01/2026)

The Local Development Team confirmed receipt of a formal email from Dinas Powys Community Council on 3 February 2026. This email was also sent to Senior Planning Officer, lan Robinson and CEO, Rob Thomas. It is appended below:

'Dear Sir / Madam,

Re: Formal Objection to the Proposed Allocation of Eastbrook (DNP-H1) in the Replacement Local Development Plan (RLDP)

Dinas Powys Community Council submits this formal objection to the proposed allocation of the Eastbrook site (SP4 KS2) within the Vale of Glamorgan Replacement Local Development Plan (RLDP). The Eastbrook allocation remains fundamentally flawed due to unresolved constraints relating to:

Flood risk and hydrology Highways and transport capacity Environmental and landscape impact Infrastructure limitations Deliverability and viability

The site lies within a hydrologically sensitive catchment characterised by groundwater emergence, overland flow routes, low-permeability soils, and a history of significant flood events, including the 2020 incident. Natural Resources Wales (NRW) has repeatedly raised concerns about flood risk at this location, and the Council's own evidence base acknowledges the need for catchment-wide modelling before any development can be considered.

The RLDP does not currently include:

Mandatory policy wording to secure pre-delivery of mitigation Requirements for catchment-wide modelling Guarantees that development will not increase flood risk elsewhere Evidence that mitigation is viable, deliverable, and enforceable

Without these safeguards, the allocation fails several tests of soundness, including CE2, CE3, and CE4.

Eastbrook in Dinas Powys is considered to be in a high-risk flood area. It is located within the catchment of the Cadoxton River and its tributary, the East Brook, which have a history of overflowing, causing significant, frequent flooding to homes and roads.

River and Surface Water Flooding: The area experiences flooding from the East Brook and the River Cadoxton. Intense rainfall can also overwhelm the surface water and sewerage systems, causing additional property flooding.

High Water Levels: The ground in the area, particularly in fields adjacent to existing properties, is often described as "totally waterlogged" for significant portions of the year, indicating a high- water table.

Key details regarding flood risk in this area include: High Risk Area: Natural Resources Wales (NRW) has identified a significant risk of flooding from the Cadoxton River and East Brook, affecting areas like St Cadocs Avenue, Greenfield Avenue, Elm Grove Place, and Cardiff Road.

Significant History: The area has experienced multiple flooding events, including major incidents in 1948, 1986, 1998, 1999, 2008, 2012, 2013, and a severe event in December 2020 where approximately 40-100+ properties were affected.

Future Risk: Due to climate change, the number of properties at risk of flooding in the area is expected to increase from nearly 200 to over 350 by 2117.

Causes: The area suffers from rapid runoff from the surrounding hillsides, which overwhelms the capacity of the river channels and drains. NRW has been exploring options for a flood management scheme, including natural flood management and potential engineering solutions, to reduce the risk to the community. It is recommended to check the specific, up-to-date flood map for any particular property on the NRW website.

The Dinas Powys Community Council formally requests written confirmation from the Vale of Glamorgan Council addressing the following matters:

1. Has a catchment-wide hydraulic model has been commissioned, completed, and agreed with NRW? If so, does the model demonstrate no increase in flood risk to existing properties? 2. Have groundwater emergence, overland flow routes, and the 2020 flood event have been assessed? 3. Are SuDS viable given soil and groundwater constraints? 4. Has downstream drainage capacity been assessed and, if necessary, upgraded? 5. Will education, healthcare, utilities, and highways infrastructure be expanded to support the allocation? a) Has consultation taken place with the GP surgery/Local schools? b) What additional services will be provided? 6. Have deliverable and funded mitigation for transport and highways impacts been identified? a) Please provide figures of air pollution and traffic flow surveys along Cardiff Road. What is the capacity along Cardiff Road? b) Department of transport will not be investing in Eastbrook station. Therefore, no lift/ramp to address the needs of the community. Yet it is being used to form a decision about the housing. Please explain the reason behind this?

7. Have landscape, biodiversity, and green-infrastructure assessments been completed? a) Apparently the placemaking workshop has helped refine proposals. What are the refinements and when can we see the results from the surveys people completed at the Murchfield consultation?

In the opinion of Dinas Powys Community Council these confirmations are essential to demonstrate that the allocation is sound and that development will not increase flood risk or place unacceptable pressure on local infrastructure.

The Vale Council state that millions of pounds of Dinas Powys S106 funding could be moved to Myrtle Close in Penarth as 'there are no developments' in Dinas Powys. If this is the case Eastbrook needs to be removed from the RLDP or the money should stay allocated to Dinas Powys.

The Vale Council allocated 900-1500 houses for Argae lane. But once the site was considered not viable the figures were reviewed and they were reduced in number and moved to another site.

Where is the evidence that 250 houses are needed in Eastbrook? The Eastbrook site was turned down before. Why? What has changed to make it viable now? Have the Vale Council exhausted all the key sites outlined in the previous LDP and if not why? Have the Vale Council used all of their rolled forward housing sites? Have the Vale Council carried out a Sequential Test? Proving there are no lower risk sites available? Has the Exception test been carried out? Ensuring the development will be made safe throughout its lifetime without increasing floor risks elsewhere? Out of the 250 houses 40% will be affordable housing. Managed by housing associations according to Persimmon glossy proposal. What is classed as affordable housing? Birth rate has fallen for a number of years, and the elderly population is increasing. How do you justify these figures? What proportion of the proposed 250 houses will be age friendly?

In the appendix to the Homes and Safe Communities Scrutiny Committee report (6th January 2024), there is a comment regarding the need for bungalows. Residents and councillors enquired about bungalows enabling people to downsize and free up family homes. We were told they are providing what the Vale has requested. We met with housing and they said, 'it won't happen'. So knowing there is a need for elderly accommodation what is the plan to address this need?

By 2034, 1 in 4 will be over the age of 65. This is an increase of 75% from 9.3% in 2018 to 13.7% in 2038.

The Vale indicates 70% of the housing need is in Barry/Penarth and Llandough. Of the remaining 30% what percentage is allocated to Dinas Powys? You state greatest areas of demand are Penarth/Barry and Llandough but there is no mention of Dinas Powys.

In conclusion, in the absence of the required evidence and mandatory policy safeguards, the Eastbrook allocation remains unsound. The Dinas Powys Community Council therefore requests that the Vale of Glamorgan Council: Removes the Eastbrook allocation from the RLDP, or Incorporates the mandatory policy wording and evidence requirements set out above. We look forward to receiving your written response. Yours faithfully, Clerk on behalf of Dinas Powys Community Council'

SECTION 15 — CONCLUSION OF THE

TECHNICAL OBJECTION

Dinas Powys Community Council recognises the importance of delivering sustainable, well-planned growth across the Vale of Glamorgan. The revised RLDP contains some positive and constructive changes, and the Council welcomes the improved emphasis on sustainability, climate resilience, and infrastructure capacity. However, despite these improvements, the proposed allocation of the Eastbrook site (HG1 - KS2) remains fundamentally unsound.

The evidence presented in this objection demonstrates that:

The site lies within a highly sensitive hydrological catchment Flood risk is influenced by surface water, groundwater, and overland flow The 2020 flood event provides clear evidence of the site's vulnerability NRW has repeatedly raised concerns that have not been resolved No catchment-wide hydraulic modelling has been undertaken SuDS feasibility is unproven due to soil and groundwater constraints Downstream drainage capacity has not been assessed Transport and highways impacts remain unmitigated Education, healthcare, and utilities infrastructure are already under pressure No evidence demonstrates that required mitigation is viable, fundable, or deliverable The RLDP lacks mandatory policy wording needed to secure mitigation and ensure no increase in flood risk elsewhere

As a result, the allocation fails multiple tests of soundness, including:

CE2 - Coherence and effectiveness CE3 - Environmental protection CE4 - Deliverability

Until the Vale of Glamorgan Council provides the required evidence and incorporates the mandatory policy wording set out in this document, the Eastbrook allocation cannot be considered sound. The Dinas Powys Community Council therefore respectfully requests that the Vale of Glamorgan Council:

1. Removes the Eastbrook allocation from the RLDP, or 2. Incorporates the mandatory policy wording, evidence requirements, and safeguards detailed in this objection

Failure to address these issues will leave the RLDP vulnerable to challenge at Examination and may result in development that increases flood risk to existing residents, places unacceptable pressure on local infrastructure, and undermines the environmental quality of Dinas Powys.

Dinas Powys Community Council remains committed to constructive engagement and looks forward to receiving the Vale of Glamorgan Council's written response to the matters raised.

I believe that this development – HG1 – KS2 – Land to the North of Dinas Powys will have a negative impact on the residents and surrounding areas.
Flooding has been a problem in the past and it is still of great concern – with run off increasing into the Eastbrook, which floods often.
The transport infrastructure cannot cope with the current situation. Most home owners now have more than one car.
The traffic, especially on Cardiff Road becomes severely congested at peak times. Additional vehicles will exacerbate the problem. The emission fumes from extra vehicles will increase also – it will affect nearby homes and people who do walk or cycle the road, not forgetting the pupils and teachers at Dinas Powys Infant School.
I also have concerns over the development at the bottom of Leckwith Hill as this will also have impact on traffic coming down (and up) Leckwith Hill; the problem will undoubtedly back up towards Llandough and the Merrie Harrier junction.
Pen-y-Turnpike is already affected by the traffic as it used as a ‘rat run’ to reach Leckwith Hill. This has an impact on traffic moving through the village centre of Dinas Powys, where there are already several pinch points.
Active Travel – Cycling along Cardiff Road through Dinas Powys can be treacherous at times, especially through Eastbrook as the road is incredibly narrow. There appears to be no scope for widening this road.
A bus lane of 400 metres does not make that much difference to the traffic issues.
All of these concerns I believe will have an adverse impact on the local economy to function efficiently. Dinas Powys as a Community will lose its identity and become part of an urban sprawl.
Green Infrastructure Strategy – I cannot see how a development will enhance the green infrastructure strategy. The proposed development will take away a part of the valued green belt in the Eastbrook locality.

I believe that this development – HG1 – KS2 – Land to the North of Dinas Powys will have a negative impact on the residents and surrounding areas.
Flooding has been a problem in the past and it is still of great concern – with run off increasing into the Eastbrook, which floods often.
The transport infrastructure cannot cope with the current situation. Most home owners now have more than one car.
The traffic, especially on Cardiff Road becomes severely congested at peak times. Additional vehicles will exacerbate the problem. The fumes from vehicles will increase also – it will affect nearby homes and people who do walk or cycle the road, not forgetting the pupils and teachers at Dinas Powys Infant School.
I also have concerns over the development at the bottom of Leckwith Hill as this will also have impact on traffic coming down (and up) Leckwith Hill; the problem will undoubtedly back up towards Llandough and the Merrie Harrier junction.
Pen-y-Turnpike is already affected by the traffic as it used as a ‘rat run’ to reach Leckwith Hill. This has an impact on traffic moving through the village centre of Dinas Powys, where there are already several pinch points.
Active Travel – Cycling along Cardiff Road through Dinas Powys can be treacherous at times, especially through Eastbrook as the road is incredibly narrow. There appears to be no scope for widening this road.
A bus lane of 400 metres does not make that much difference to the traffic issues.
All of these concerns I believe will have an adverse impact on the local economy to function efficiently. Dinas Powys as a Community will lose its identity and become part of an urban sprawl.
Green Infrastructure Strategy – I cannot see how a development will enhance the green infrastructure strategy. The proposed development will take away a part of the valued green belt in the Eastbrook locality.

I would like to Object to the inclusion of the candidate site Ref 353 Land on the West Side of Cardiff Road, Dinas Powis as a housing site within the VoG LDP review on the basis of the following material issues.

Traffic and Highway Safety:
This is a site abutting an already severely congested A road (A4055). This is a single carriageway principle road travelling from Barry to South Cardiff which would be significantly compromised by
A) the increased traffic as a result of addition of 250 new homes. Equating to circa 500+ vehicles using the road plus accessing a new junction
B) the additional of a signalised junction 300m from an established junction and the additional tailbacks this would create.
I do not believe that Persimmon Homes have provided sufficient analysis of the additional transport and traffic requirements of this site and access. Both options 1 and 2 of the site access arrangements are whole insufficient and have not accurately accounted for the current volume of traffic already travelling along Cardiff Road. This access arrangement also compromises work already completed on active travel and the bus lane. A mitigation to this has not been demonstrated in their assessment or initial design. One of the options proposed the use of the but lane to support the turning/joining arrangement to/from this site which will compromise the rational for the creation of the bus lane in the first instance.
The integrity of the A4055 and surrounding infrastructure would not support the suggested signalised junctions, which would create significant build up of traffic both within Dinas Powys but also and more significantly towards and crossing the already congested junction at the Merry Harrier and beyond.
Importantly from the Authority's perspective this is a site which for many years the authority has considered the potential need for a by-pass, and therefore this site would be a significant departure from many years of concern, This would signify a poor evaluation of the impact of this candidate site by the authority based on previous concerns and work by the authority themselves.
I would also like to object on the ground of significant loss of green space and ecology which I do not believe has been fully assessed or addressed via the Green Infrastructure statement or Preliminary Economy Appraisal which is wholly insufficient to provide certainly of mitigation for the scale of this greenfield site.
The clear loss of greenbelt at this location would result in the merging of two communities of Dinas Powys and Llandough. In this location this development would constitute the loss of green space in its entirety not merely reduce it.
Also do not believe the engagement of 52 individuals as set out in the community engagement constitutes a full and accurate reflection of the views of local residents accounting for less than 0.4% of the population.
On balance when considering all candidate sites across the authority, and given the housing numbers the authority needs to achieve, this site would represent a poor choice, creating a significant numbers of new and additional challenges for the authority.

The proposal is not thought out.
Infrastructure- The doctors surgery is incapable of dealing with current demand and has not been consulted. The roads are gridlocked. Anyone trying to get to work has to wait a long time. Any more traffic.
Trains- Although the trains have now caught up will current demand it is no use. Parking at Dinas is now excellent. The parking at Eastbrook is overfull.
Exhaust fumes- This is a serious concern. Traffic concerns Cardiff Road so in excessive periods of time (see above) and exhaust fumes poisonous to all and specifically for people will chest infections.
The Village- This is a village and does not have the shops and support 250 houses. This is a planning Jolly. Think through it again and expand elsewhere.

Objections to HG1 KS2
1. The increase in traffic along the roads of Dinas Powys they are already congested.
2. Public transport will be further strained.
3. Increased strain on public services namely medical centre.
4. Further housing encroaching on green belt between Dinas Powys and Llandoch.
5. Lack of supporting infrastructure/access
6. Already saturated school places.

1. Increased congestion - another 300 + vehicles on cardiff road which is already at a standstill during peak times
2. Flooding - the proposed location is on a site that already floods and this proposed development will only make this risk greater
3. Public services - the doctor’s surgery & schools are already over subscribed
4. Environmental - loss of wildlife from this greenbelt area
5. Reduced greenbelt - Dinas Powys is gradually losing it's village identify & this development will see the village edging ever closer to Llandoogh
6- Public transport - limited access to Eastbrook station. Especially for disabled persons. Limited bus services on already congested rds, which will only get worse

Objections
1) Increased congested on an already extremely busy and gridlocked road.
2) Increased flooding risk. The proposed location floods numerous times in the year, this will lead to further instances of the Cadoxton river bursting its banks and flooding homes, as has happened many times before in Dinas Powys.
3) An unacceptable increased pressure on services such as Doctors that are already at capacity.
4) Environmental factors. This development will swallow yet more green space and destroy habitats and wildlife. This will also merge Dinas Powys into Llandough. Dinas Powys will lose it's village identity.
5) NHS services-emergency services, first responders, maternity services will all be directly affected by increased traffic load and congestion.

Development will increase traffic and flood risk. Permanently change the character of where I live. Eastbrook is a green space and an irreplaceable ecosystem for local wildlife including bats and newts.

1. The site is unsuitable.
i) stop using green field-think green spaces, health of well-being, biodiversity.
ii) use brownfield sites.
iii) find and use empty houses - lots of them.
2. Drs surgery is full-cannot get an appointment.
i) No maternity services.
ii) No injury services.
iii) Parking almost impossible.
iv) Up a very steep hill and impossible to walk if elderly, pregnant or disabled.
3. DP is full of exhaust fumes on Cardiff Road-500/1000 more cars is not a good idea to add to this problem.
3. Flooding issues on Cardiff Rd despite what the VoG planning dep have denied - I was caught up in it!!!!!
4. Development would be in the wrong place - too far away from village to benefits from village life.

1. Cardiff Rd is chocoblock full of exhaust fumes=very bad for children.
2. The walk up Ash Path (unlit!!) feels unsafe and is a very very long walk from most places in Dinas Powys
A different point - village is already overdeveloped and any more estates will make DP unmanageable for the Dinas Powys Community Council. That is besides-flooding problems, traffic, DRS cannot cope, cars parked on pavement-Cardiff Rd
All unsurmountable problems.

I request this Development is removed from the RLDP with immediate effect.

I wish to register my strongest objection to the proposed housing development HG1 KS2 Eastbrook in the RDLP.
Firstly I request this development is removed from the RDLP with immediate effect, as outlined below, Dinas Powys has less infrastructure and utilities than the other included sites. The need for further housing around the Vale is not in dispute but siting it in an area of green wedge space between Dinas + Llandough, on a road already severely congested and in a village that has schools and other services, including the GP surgery already beyond capacity is dangerous, damaging and would lead to permanent, further degradation of our village.
This clearly does not meet the requirements of so called Active Travel (Wales) Act 2013. As a keen cyclist I simply do not travel beyond Dinas on my bike as it is too dangerous, particularly towards Barry and the Vale. The traffic on Cardiff Road is beyond ridiculous already, how can an extra Set of lights assist this? How can you widen the roads and inaccessible paving? How can people with limited or no mobility use such an impractical train station?
Flooding is another major concern. The fields are often waterlogged and the RLDP has not shown that this site can be made flood safe. There is no modelling of downstream impacts no cumulative assessment and no evidence of drainage network capacity. Allocating land without proving it can be safely developed is irresponsible and contrary to TAN15 and PPW11. Planning Policy Wales, Technical Advice Note. The Environment (Wales) Act 2016, the Active Travel (Wales) Act 2013, the Equality Act 2010, Future Wates: The National Plan + the new Environment (Principles, Governance and Biodiversity Targets) (Wales) Bill, passed on 24 February 2026. This site is neither safe nor deliverable and I Implore you to do what is right for our precious community.

Object to building on green spaces when brown/grey sites are available. congestion also significant already. Local facilities - schools and doctors are already stretched.

The development is totally unnecessary. There is constant congestion on the road adjacent to the proposed site. Local services are at full capacity already at this moment in time e.g. doctor surgery and schools.
There is added noise and air pollution and disturbance of natural habitats.

Taking away live ecosystems that may or may not be there is wrong and harmful - its common sense if you payed attention in school. Flooding has already happened and will continue to happen and become worse if there are more houses built in Eastbrook. More houses equals more people. More people equals more cars. More cars equals more traffic on main roads. Locals can't get to work. Students can't get to school. Roads will become dangerous, and even if they already are, it'll be worse. Schools are full, and healthcare would be trickier to get due too overpopulation in Dinas. Since there'd be more people it'll connect us to Llandough and we'd no longer be a village. We're not a big city like Cardiff with all its shops. There isn't enough facilities for everyone.

The site will impact the bus route that I use to get to work. At Llandough hospital it will increase congestion, increase flooding and reduce the green belt.

I object to the proposed HG1 KS2 Eastrbook development for the following reasons:-
1) Potential flooding-there is no evidence that this has been considered.
2) Access to the devlopment will cause more traffic congestion.
3) Schools in the village are over subscribed
4) The medical centre will be impacted.
5) Access from the development on foot/pushchair/wheelchair is not safe.
6) Access to the nearest railway station is not suitable for prams/wheelchairs

1. Increased congestion of traffic. More homes means more cars. Cardiff road already has congestion problems.
2. Increased air pollution.
3. Doctors and schools at full capacity.
4. Increased congestion will cause answer problems for increased ambulances and police to emergency calls.
5. Loss of green belt area causing loss of protected wild life.
6. More traffic more road deterioration "potholes".
7. Public safety at risk with more traffic.
8. Increased drainage, risk of increased flooding.
9. Dinas Powis is losing it's village identity.
10. If the by - pass was agreed 20+ yrs ago the congestion of traffic would have been solved.

Lack of infrastructure to support development. Road congestion, lack of school/GP/hospital services. Flooding risk. Loss of greenbelt/nature/wildlife habitats.

Please See attached letter as well as comments below: In light of the Environmental (Principles, Governance and Biodiversity) Wales Bill, passed by the Senedd on 24 Feb 2026, it is now even more clearly unacceptable that this plan does not establish legally binding biodiversity targets. The new office of Environmental Governance is established to hold public bodies to account. The land mark legislation is explicitly framed as a response to the nature and climate emergencies and is intended to halt and reverse biodiversity decline in Wales. Proceeding with the allocation of HGI KS2 Eastbrook-destroying a functioning green wedge and wildlife habitat without clear evidence of biodiversity enhancement directly contradicts the spirit and intent of this new law and the wider duties under the Environment (Wales) Act 2016.
Our schools, GP surgeries and emergency services are already overstretched. Adding hundreds of new residents with committed, funded infrastructure, will make life harder for everyone who already lives here. This undermines the 'A More Equal Wales' and 'A Healthier Wales' goals of the Well-Being of Future Generations Act, and fails the RLDP tests of soundness on effectiveness and deliverability.
For all these Reasons, the permanent loss of green wedge space, the unresolved safety issues, the flood risk, the failure to protect and enhance biodiversity, the fact of supporting infrastructure, the catastrophic increase un traffic and pollution and the general harm to our communities well-being I strongly object to the allocation of HG1 KS2 Eastbrook.
Whilst the need for further housing is not in dispute, this is the wrong site as clearly outlined above and in my attached letter. The consequences would be irreversible and affect our community and future generations. Please remove HGI KS2 from the RLDP with immediate effect.
Letter attached as past of my objection:
Additional Objections of; Hard Constraints not being adhered to, the suppression of Reporting on Dinas Powys Flooding in the RLDP, Policy Conflicts and Contradictions, Increased levels of traffic and pollution, Failure to identify the protected and endangered wildlife species evident within the proposed development area, and the increase of additional Patients to adversely affect and impact the quality of NHS services within our community.
1. Objection: Requirement for Two Accesses for
Developments Over 100 Dwellings (Wales)
1.1 Summary Position
The proposed development exceeds 100 dwellings yet relies on a single point of access to the public highway. In the Welsh context, this is not acceptable.
While no single statute sets a numeric threshold, the combined weight of: Planning Policy Wales (PPW11) TAN 18: Transport Welsh Fire & Rescue Service operational requirements, Manual for Streets (as adopted in Wales), Local Highway Authority practice across Welsh authorities. Appeal precedent in Wales and England
creates a clear and compelling expectation that large residential schemes must provide two independent access points, or at minimum a fully engineered emergency-only secondary route.
The proposal fails to meet that expectation and therefore presents an unacceptable risk to life, property, and network resilience, contrary to national policy and good practice.

1.2 Planning Policy Wales (PPW11): Network Resilience and Safety
PPW11 places network safety and resilience at the heart of transport planning.
Key principles include: PPW11 4.1.9 - development must ensure "safe, efficient and reliable" access. PPW11 4.1.31 - transport infrastructure must be "resilient to disruption". PPW11 4.1.52 - planning must support emergency access and avoid creating unsafe environments.
A single access serving over 100 dwellings is inherently non-resilient. If blocked by: a collision, a fallen tree, flooding, a utilities failure, or even routine roadworks, the entire estate becomes inaccessible to emergency services, directly undermining PPW's requirement for resilient, safe access.
1.3 TAN 18: Transport - Safe Access and Emergency Provision.
TAN 18 does not set a numeric threshold, but it is explicit that: Access must be safe for all users at all times. Emergency access must be maintained under all foreseeable conditions. Layouts must avoid single points of failure.
TAN 18 repeatedly emphasizes the need for robust access arrangements and the avoidance of designs that compromise emergency response. A single access serving a large population is the textbook example of a single point of failure.
1.4 Welsh Fire & Rescue Service Requirements
Fire & Rescue Services in Wales (South Wales, Mid & West Wales, and North Wales) consistently advise that: Large residential developments should not rely on a single access. A secondary access or emergency-only route is required where more than ~100 dwellings are served. Blocked access routes are a critical risk factor in fire fatalities and delayed response times.
This is grounded in: The Fire and Rescue Services Act 2004 (duty to respond effectively). Approved Document B (access for fire appliances). BS 9991 (resilient access for residential developments).
In practice, Welsh fire authorities routinely object to single-access schemes above 100 dwellings unless a fully engineered, unobstructed emergency route is provided.
1.5 Manual for Streets (MfS) - adopted in Wales stresses
Network permeability Avoiding cul-de-sacs serving large populations Ensuring emergency access under all conditions
MfS does not set a numeric threshold, but its design philosophy is clear: Large developments must not depend on a single access point.
1.6 Local Highway Authority Practice Across Wales
Across Welsh LPAs, the working norm is: Up to ~100 dwellings - - single access may be acceptable if geometry is excellent. 100-150 dwellings - strong justification required; emergency access normally mandated. 150+ dwellings - two accesses are expected as standard.
Authorities including: Vale of Glamorgan Cardiff Rhondda Cynon Taf Carmarthenshire Flintshire all routinely require two accesses or a dedicated emergency route for schemes of this scale.
This reflects risk-based practice and lessons learned from blocked-access incidents.
1.7 Appeal Decisions: Consistent Support for Two Accesses
Inspectors have repeatedly upheld refusals where: A single access serves >100-150 dwellings, and No secondary emergency route is provided.
Key themes in appeal reasoning include: Unacceptable risk to life and property Failure to ensure resilient access Conflict with national policy on safe and reliable transport networks Over-reliance on a single vulnerable point of access
Conversely, appeals succeed only where: A fully engineered emergency-only link is provided, or The dwelling count is significantly lower.
The proposed development falls squarely into the high-risk category.
1.8 Risk Assessment: Why a Single Access is Unacceptable
A single access serving over 100 homes creates: 1. Life-safety risk Emergency services may be unable to reach residents during: fires, medical emergencies, flooding, or road obstructions.
2. Evacuation risk Residents may be unable to leave during: fire events, gas leaks, or environmental hazards.
3. Infrastructure vulnerability - One incident can isolate the entire estate.
4. Policy conflict Fails PPW11, TAN 18, and the Fire & Rescue Services Act duty to maintain effective response capability.
1.9 Conclusion
The proposal's reliance on a single access for a development of 250 dwellings is:
Contrary to PPW11 (safe, resilient access) Contrary to TAN 18 (avoid single points of failure) Contrary to Fire & Rescue operational requirements in Wales Contrary to Manual for Streets principles Contrary to established Welsh LHA practice Unsupported by appeal precedent
The development therefore presents an unacceptable and avoidable risk to residents and emergency responders. A second access, or at minimum a fully engineered emergency-only route, is essential to make the scheme safe and policy-compliant.
2. Objection: Hard Constraints have not been Adhered To
2.1 Highways says that Persimmon cannot pencil in the 'secondary' or 'emergency' access. Persimmon Failed to Do a Traffic Study to Contest Highways View.
2.2 There is no Proposal to bring pedestrian or cycle access up to Welsh Government Standards.
2.3 The Proposed George's Row and Seel Park routes to Eastbrook Station and Camms Corner shops do not work.
2.4 The highway adjacent to the site and providing ingress and egress to any homes built there is on the most congested road within the Vale of Glamorgan. As such it is deemed as traffic sensitive under the terms of the New Roads and Street Works Act 1991. Any planned development is clearly contradictory to both the spirit and the intention of the legislation.
2.5 Risk Assessment: Why Failure to Provide this Information is Unacceptable
The highway proposal for this scheme is deemed as traffic sensitive under the terms of the New Roads and Street Works Act 1991. Any planned development is clearly contradictory to both the spirit and the intention of the legislation.
Highways advise that the above points are a Welsh Government Requirement for all new developments. This information has not been provided. The RLDP Team need to answer these hard constraints as well as report on amending the draft, prior to any approval.
3. Objection: JBA Consulting Suppressed Dinas Powys Flooding in the RLDP Documents (Wales)
3.1 Risk Assessment: Why Failure to Report this Information is Unacceptable
Their Strategic Flooding Assessment (SFCA) had to record details of historical flood events, yet omitted the Dec. 2020 flooding of 100 homes in Dinas Powys. This same company (JBA Consulting), wrote its Section 19 legal report in 2021. Their SFCA just mentions that the flooding measures dealt with the problem - yet their 2021 report: Recommends that NRW assess viability of options to manage the flood risk across Dinas Powys; for DCWW to assess the viability of offline storage for the Cae'r Odyn surface water system. There appears to be a cover up of these measures that have been clearly ignored. On their map, located on the last page of the SFCA, that proposes woodland planting to hold-back rainstorm run-off, on part of the proposed Persimmon's Eastbrook site. The map is only indicative giving no source for the data. A full survey is still required.
The reports that are provided, need to be accurate, honest, transparent and compliant with legislation and policy. This is not. A full survey needs to take place to establish the full potential for flooding measures within Dinas Powys and the proposed Eastbrook Development Site.
4. Objection: Policy Conflicts and Contradictions
4.1 Policy Conflict: Fails PPW11, TAN 18, and the Fire and Rescue Services Act - A duty to maintain effective response capability.
4.2 The proposal's reliance on a single access for a development of 250 dwellings is Contradictory:
Contrary to PPW11 (safe, resilient access), Contrary to TAN 18 (avoid single points of failure), Contrary to Fire and Rescue Operational Requirements in Wales, Contrary to Manual for Streets principles, Contrary to established Welsh LHA practice, Unsupported by appeal precedent 6.
The development therefore presents an unacceptable and avoidable risk to residents and emergency responders. A second access, or at minimum, a fully engineered emergency only route, is essential to make the scheme safe and policy compliant.
4.3 The Welsh Government has placed a physical and ideological moratorium on the building of new roads, an example of this is the blocking of a by-pass around Dinas Powys:
The proposed plans show the building of roads on the proposed development to serve the new residents. This is clearly contradictory to the stated aims and rules imposed by the Welsh Government
5. Objection: Additional
5.1 Unacceptable Increased Levels of Traffic on Cardiff Road Resulting in Increased Air Pollution:
With the proposal of 250 plus, additional dwellings, assuming a minimum of two car each house hold, that is an increase of a minimum of 500 cars (although many households have 3 cars, 1 each plus a works vehicle), that will require access onto Cardiff Road and produce increased air pollution. This is unacceptable. For the Local Authority appointed consultant to advise that there is an unlikely increase in pollution levels is both implausible and raises issues of competence, and integrity and should be questioned further.
5.2 Failure to Undertake the Appropriate Environmental Studies, at the Relevant Times of the Year to Assist in Identifying the Protected and Endangered Species Evident within the Proposed Development Area:
These protected and endangered species present include:
Hazel Dormice: These are found in the woodlands and hedgerows adjacent to the Eastbrook fields.
Otters: Evidence of otters, which are protected, have been recorded in the vicinity of the Eastbrook.
Bats: Various species of bats, which are protected, use the area for foraging and commuting. Badgers: These are present and are protected, given the suitable habitat.
Kingfishers: These protected bird species are noted in the area.
The High Brown Fritillary Butterfly: one of the UK's most threatened species, is found in the fields of Eastbrook, as well as throughout the Vale of Glamorgan Gold Crested
Newts: endangered and protected, have been identified in the fields.
5.2.1 Summary:
This proposed development area, known as greenfield sites in Eastbrook, Dinas Powys, serve as a vital habitat and corridor for this wildlife.
Appropriate environmental and ecological studies and reports need to be carried out, at the relevant times of the year, specifically focusing on the above noted and sited endangered species, in and around this proposed development area.
5.3 Additional Patients to Adversely Impact Current and Existing Quality of Services and Resources.
The likelihood of an excess of 500 new patients being registered at the Dinas Powys Medical Centre will further impact and degrade the quality of services afforded to local residents, which are already far below standards prescribed by the Welsh Government.
6. Conclusion:
This development would clearly have a substantial negative and adverse impact on the residents and wildlife of our local community, and is completely contradictory to any Local Authority or Welsh Government stated aim to protect or even improve the community in which we live.
It is also contradictory the stated commitment to nature, climate, land and biodiversity. The LA and Welsh Government declared a nature emergency in 2019 and then again in 2021, and this proposed development, as well as the lack of genuine and actual reporting regarding the endangered and protected species of wildlife, is in complete contradiction to this. (7 Key Site Supporting Information >KS2 Land North of Dinas Powys>Green Infrastructure Statements)
I would urge the Councillor's within the Vale of Glamorgan Local Authority to abandon this proposed development plan while they are still in a position of authority to do so. I would further urge the elected Councillors to be mindful of the fact that myself and my fellow residents will judge their actions on this, and other, matters, when next having the opportunity to vote on local elections. Honesty, openness, transparency, as well as perceived competence, adhering to (and not ignoring or contradicting) policy and legislation, as well as listening to the voice of the people (that the Vale of Glamorgan Council serve), and protecting and preserving environment as well as the health and well-being of the people, animals and wildlife that all reside within the Vale of Glamorgan, will all be assessed and measured.

Flooding at Cardiff Road (previously flooded railway terrace DP. 2020)
There is only one access point to the estate (2 is a necessity) for emergency access.
A green wedge (green belt) is being built on between Dinas Powys and Llandough.

Over 250 houses. too much strain on infrastructure, drainage, sewage, cars, roads, schooling, doctors surgeries etc. Building all over green belt and greenfields and our precious biodiversity. As we are in a climate emergency of decreasing biodiversity of flora and fauna that the Vale of Glamorgan and Government has announced! So uphold it.

Roadworks traffic queues.
Dinas Powys a small village.
Schools over subscribed.
No Welsh education in Dinas leaving one Welsh school for the children to attend.
Only one doctors that take Dinas residents and Penarth residents.
Increased flooding due to building on green spaces. No appropriate walk ways to Pen Y Garth-school bus far too expensive.
Cardiff road full of exhaust fumes and traffic very busy as people passing through to Penarth, Barry and Cardiff. Trains unreliable and poor access to Barry.
Brookside crossing not safe-not able to cross safely with a pushchair.
No disabled access at the train station.
No maternity service at doctors, Doctors close for 1 hour at lunch, means children are not seen if they fall ill.
No paediatrics at Llandough (all increasing traffic)

I Object to HGI KS2 Eastbrook because our roads and Eastbrook Railway Station are already clearly overstretched to full capacity Adding more cars/passenger to an already overstretched capacity is unsafe and unsustainable.
In addition, there is a very real risk of increased flooding, more homes means more discharge of raw sewage. Has an recent flood risk assessment for the Dinas Powys area be made with respect to additional homes being proposed? With the out-dated drainage system in Dinas Powys, how will the proposed additional 250 homes affect this current situation?
From my own experience in Iestyn Close and in many other areas in Dinas Powys, the out-dated drainage system caused a major flood last year in October. How will this be addressed? The current infrastructure cannot cope!!

1) Increased congestion
2) Losing village identity
3) Doctors and schools already at full capacity
4) Active travel- train station- Car Parking, no disabled facilities
5) Flooding to increase
6) Extra Traffic increase what about ambulances-urgently needed
7) Extra parking problems
8) Air pollution
9) Public safety- fires and police if required urgently
10) Losing our walking with wildfires in greenfield areas 11) To stop massive lorries travelling through pot holes if more traffic!