Road Works. Flooding. Drains are always blocked along Cardiff road. If they build more houses traffic will be at a standstill.

Traffic is bad enough along Cardiff Road. Flooding, pollution, traffic congestion, and more road works.

As a resident of Dinas Powys, I have objections to the proposed housing development at Eastbrook, which I believe is contrary to Welsh Government policy and would cause irreversible harm to our community, environment and infrastructure.
The site would access Cardiff Road which is already at capacity. 250 new homes could bring 300+ additional vehicles making daily travel unsafe, stressful and unsustainable. The traffic is frequently at a standstill on both sides of Dinas during peak times, in particular by the Merrie Harrier. Additional traffic from the new development would exacerbate the problem. This in turn would have a negative impact on air quality.
The air pollution survey seems to have been accepted at face value. The survey demonstrates pollution levels met because of the open green fields and space to disperse pollutants. 250 homes built on greenfields would completely change dissipation effect.
The proposal's reliance on a single access point for a development of 250 homes dwellings is contrary to established Welsh government policies.
PPW11 (safe resilient access), Tan 18 (Avoid single points of failure) ; and the fire and rescue operational requirements in Wales ; manual for street principles.
The development therefore presents an unacceptable and avoidable risk to residents and emergency responders.
The medical centre is working to capacity. The likelihood of 500 new patients registered would clearly impact on health services.
The development would seriously redact the green belt boundary merging Dinas Powys and Llandough. These boundaries are meant to be protected not just to fit an agenda. How can the council allocate the site for development when evidence suggests a shortage of open space?
The development would destroy vast valuable areas of habitat of wildlife. The Senedd has approved new environmental legislation aimed at helping Wales significantly progress in addressing nature and climate crisis. The development at Eastbrook would go against this legislation as there must be legally binding targets to restore wildlife and improve the health of our environment.
Worryingly, JBA consulting in their strategic flooding assessment (SFCA) failed to record the December 2020 in Dinas Powys. The same company wrote in section 19 legal report 2021 "JBA.... recommends that NWR amend the viability of options to manage flood risk across Dinas Powys ; for DCWW to amend the viability of offunt storage for the Cae'r Odin surface water safety system" these measures seem to have be ignored.
The map on the last page of the SFCA proposed woodland planting to hold back rainstorm run-off a part of proposed development site. Clearly, building houses on this land is a flood risk for the wider Dinas Powys area.
Given the issues outlined, serious consideration should be given to stop this development.

NO!NO!NO! Flooding, Congestion, Loss of wildlife.

I can't believe how this could be considered. The traffic is nose to tail most of the day (don't even mention the pot holes, some huge lorries use the road). Doctor's surgery you are more likely to die before getting an appointment. Chemist has now got a 7 day turnaround for repeat prescriptions. All schools have full capacity. How many years has a bypass been talked about. Dinas Powys in a fabulous place to live a "village" but being totally ruined. No, No, No I prey this housing does not go ahead. But they do say money talks.

Increased congestion, massive problems with emergency vehicles trying to access roads. Increased flooding, don't want a concrete jungle, water flowing in highways. Doctors, schools already overcrowded. Loss of wildlife - there are bats livings in house lofts in Jestyn Close distributed by this development (Owls, foxes, worms, squirrels, tit family, black bird and other varieties affected). Overcrowded train services. Britain is already facing greenbelt shortage - lots of animal species being potentially made extinct if this continues. Dinas Powys will no longer be a village just a name.

Increased congestion means it's extremely difficult to get out of our drive. Increased strain on local NHS service. Very difficult to get a doctors appointment even now without numbers. Local GPs surgeries already over subscribed beyond capacity. Schools already at capacity. Increased risk of flooding. Water run off rather than absorption means increase a overwhelming of existing surface water drainage system. Loss of local wildlife a habitats due to even more urban developments. Dinas Powys did have a real village, community feel. This has been eroded over time and local infrastructure has been already overwhelmed.

1. Increased Congestion
Due to the lack of bypass in Dinas Powys, there is only one main road that runs from Barry to Cardiff. With the increased houses built over the Murch within the last 10 years, the traffic has increased drastically, which resulted in further congestion, so is already proving difficult to join this road from our house. The addition of 250 houses with 300-500 additional houses onto an already overburdened road, would cause significant congestion + bottle neck. The infrastructure has never expanded or improved as Dinas Powys has grown to leaves the current residents at considerable disadvantage.
2. Doctors and Schools at capacity
As Dinas Powys had grown, the infrastructure has failed to keep up. No investment has been made up to accommodate the additional families/people who now reside in. Dinas Powys and the GP/surgeries are struggling to keep up. Residents already face a delay in appointment, with 10 day for blood tests which is detrimental to their physical and mental health. With the threat of 300-500 new homes being built, the burden this will add to a struggling health service would cause further disruption and delays, which will affect peoples health.
3. Increased Flooding
Water run off from Eastbrook site will enter the Cadoxton river which has burst+flooded homes in Dinas Powys, which will only get worse.
4. Losing identity
GP has grown and continues to grow, I feel it's not in keeping it's lovely rural feel of a village.
5. School
Over subscribed currently. No improvements have been made into the existing infrastructure to accommodate more families moving to the area. With the additional homes being built, this further threatens the education system which is already struggling.

I strongly object to the above development for the following reasons. Increased congestion. Increased flooding-the high chance on this is very worrying! Doctors and schools which are already at capacity and oversubscribed. Loss of wildlife. Active travel. Difficulty for emergency services due to congestion. Reduced greenbelt. Dinas Powys will lose it's identity as a village.

These homes will: increase flooding, doctors and schools can't cope already, loss of wildlife, one road in and out of Dinas we need a bypass, greater delays on road for emergency services, loss of green belt.

I strongly object to the development. My full reasons are set out on the attached document, 3 pages long. This is the wrong area for development. I am willing to speak at a Committee.
I am writing as a long-standing resident of Dinas Powys to register my strongest objection to the proposed allocation HG1 KS2 Eastbrook in the Replacement Local Development Plan (RLDP).

This is not simply a planning matter to me; it is about the long-term well-being of my family, my community, and the future character of the place we call home. The allocation is unsafe, unjustified, environmentally damaging, and would permanently destroy a green space that is central to our physical and mental well-being. It is also inconsistent with key Welsh and UK legislation, including Planning Policy Wales (PPW11), Technical Advice Note 15 (TAN 15), the Well-being of Future Generations (Wales) Act 2015, the Environment (Wales) Act 2016, the Active Travel (Wales) Act 2013, the Equality Act 2010, Future Wales: The National Plan 2040, and the new Environment (Principles, Governance and Biodiversity Targets) (Wales) Bill passed on 24 February 2026.

The Eastbrook fields are not just land on a map. They are where many of us walk to clear our heads, where children play, where wildlife still thrives, and where the landscape opens enough to breathe. Once this green wedge is built on, it is lost forever. No amount of landscaping or token open space can replace the sense of calm, identity, and connection to nature that these fields provide. Removing this strategic green wedge undermines PPW11 and Future Wales policies on settlement identity, green infrastructure and the protection of open space, and conflicts with the Well-being of Future Generations Act duty to improve the social, environmental and cultural well-being of Wales over the long term.

The roads around Eastbrook are already congested and fragile. The Council has not provided the required traffic modelling, junction capacity testing, or a deliverable second/emergency access. Without this, the site is not safe or deliverable. This approach conflicts with PPW11 and Future Wales, which require transport impacts and resilience to be properly assessed at plan-making stage, and with the Active Travel (Wales) Act 2013, which prioritises walking and cycling over car-dependent development. The lack of step-free access at Eastbrook Station also raises concerns under the Equality Act 2010, as increased reliance on an inaccessible station disadvantages disabled people and those with mobility impairments - this is discrimination. Active travel should be safe for all pedestrians, however the proposed accesses would pose serious risk to women & girls if you expect them to be walked through at night especially. The paths are through existing parkland, with no lights and no clear visibility around sharp corners, no surveillance. I would not walk them & I certainly would not expect my daughter to. Again, discrimination. These areas, including Seel Park, will become 'no-go' areas. I would be devastated to see the parkland, woodland and adjoining fields destroyed.

Flooding is another major concern. The fields are often waterlogged, and the RLDP has not shown that the site can be made flood-safe. There is no modelling of downstream impacts, no cumulative assessment, no demonstration that SuDS can be accommodated, and no evidence of drainage network capacity. Allocating land without proving it can be safely developed is irresponsible and contrary to TAN 15 and PPW11, which require flood risk to be addressed at the plan stage and not deferred to later applications.

The Eastbrook fields also have clear biodiversity value as semi-natural green space and wildlife habitat, including owls and bats. The RLDP provides no robust ecological evidence and no credible path to biodiversity net benefit. This conflicts with the Environment (Wales) Act 2016, which places a duty on public authorities to seek to maintain and enhance biodiversity and promote the resilience of ecosystems. It is now even more clearly unacceptable in light of the Environment (Principles, Governance and Biodiversity Targets) (Wales) Bill, passed by the Senedd on 24 February 2026, which establishes legally binding biodiversity targets and a new Office of Environmental Governance Wales to hold public bodies to account. That landmark 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 HG1 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 without 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 space, the harm to community well-being, the unresolved safety issues, the flood risk, the failure to protect and enhance biodiversity in the context of the new Environment (Principles, Governance and Biodiversity Targets) (Wales) Bill, and the lack of supporting infrastructure - I strongly object to the allocation of HG1 KS2 Eastbrook. This is the wrong site, it conflicts with Welsh and national legislation and policy, and the consequences would be irreversible. There are no advantages for the people of Dinas Powys if this development goes ahead - - not one. Please remove HG1 KS2 Eastbrook from the RLDP.

I wish to register my opposition to the proposed development of 250 houses In Dinas Powys.
1. It will increase the amount of traffic along Cardiff Road which is already heavily congested. It will also increase pollution levels.
2. The schools and doctors facilities are at capacity and it is already difficult to arrange appointments.
3. The risk of flooding will increase due to water run off from the site entering the river Cadoxton. Over 100 homes were flooded in December 2020.
4. The green belt boundary will be reduced together with a loss of wildlife.
5. Pedestrian access at Eastbrook station is already inadequate and also the lack of extra parking facilities.

I wish to register my opposition to the proposed development of 250 houses in Dinas Powys.
1) Increased amount of traffic in and out of Dinas Powys, adding further congestion on Cardiff Road. This will also increase pollution levels.
2) The schools and doctors facilities are at capacity and is already difficult to get a medical appointment.
3) The risk to flooding will increase and further homes will be prone to flooding as in 2020 when over 100 homes were affected.
4) Wildlife will be affected, along with the greenbelt boundary
5) Pedestrian access at Eastbrook station is already inadequate with a lack of extra parking an issue

Vale of Glamorgan Replacement Local Development Plan (RLDP) 2022-2037
Thank you for consulting Welsh Water on the Vale of Glamorgan Deposit LDP, we appreciate and welcome the opportunity to engage in the Local Development Plan process.
Settlement boundaries
SSC1 – development within settlement boundaries
We welcome the requirement for new development to make efficient use of land and benefit from existing infrastructure provision or, where necessary, make provision for new infrastructure without any unacceptable effect on the natural environment (10).
Housing delivery
HG1 - housing allocations
A. Key sites (Policy HG1 KS1-5)
Our representation on the above sites are included in appendix 1.
B. Housing allocations (HG1 (1) to HG1 (9))
Our representation on the above sites are included in appendix 1.
C. Major landbank sites (HG2 (1) to HG2 (5))
These sites are existing commitments and Dwr Cymru Welsh Water has made representations on the planning applications submitted for these sites.
D. Housing led redevelopment opportunity (HG3 (1))
Our representation on the above site is included in appendix 1.
E. Rural affordable housing led sites (HG4 (1) to HG4(4))
Our representations on the above sites are included in appendix 1.
Our representations on the proposed allocated sites are included in appendix 1. Where planning applications have already been submitted and are pending a decision, we have made representations during the planning application consultation process regarding the capability of our infrastructure to accommodate the proposed development. If capacity does not exist within our infrastructure to accommodate the demands arising from a development site, the planning authority can make planning permission conditional upon there being adequate infrastructure available to cater for the development. A developer has a right to connect to our sewerage networks provided that a development site benefits from planning permission and there are no overriding planning conditions attached to the permission that controls the location or timing of that physical connection.
Gypsy and traveller accommodation (GT)
SP9 - gypsy and traveller site provision
Our representation on the site allocation is included in appendix 1.
Retail, commercial and service centres (RCS)
SP12 - retail floorspace provision
Our representations on the site allocations are included in appendix 2.
Community infrastructure (CI)
SP13 - community infrastructure and planning obligations
We support the provisions within the policy that the Council will secure new and improved community infrastructure where appropriate and within a timely manner, and the specific reference to utilities infrastructure. Where existing water and sewerage infrastructure requires reinforcement to serve a development it must be provided as part of the development to mitigate any adverse impacts. In circumstances where the development generates the need for infrastructure improvements that are not programmed for delivery by infrastructure providers then it must be funded by the development. Therefore, it is important for developers to engage early with relevant infrastructure providers, including the statutory sewerage and water undertaker. We welcome that the policy states that improved infrastructure must be undertaken in a timely manner. The delivery of reinforcements to the sewerage and water networks can controlled either through planning condition or a commercial agreement between the developer and Welsh Water.
Adequate potable water supply and drainage infrastructure is key to ensuring new development sites are sustainable, viable and deliverable. Hydraulic modelling assessments (HMA) may be required to determine an adequate point of connection to the water network and/or public sewers, and developers would be strongly recommended to fund investigations at pre-planning stage. Once commissioned and completed the HMA would identify suitable connection points and/or the necessary reinforcement works required to accommodate the development (for example upsizing sewers/water mains, additional storage tanks etc). In certain circumstances surface water removal could be an alternative option for allocations where foul sewer HMAs are being requested, and we would welcome early engagement with the site developer.
The reinforcements required to the network would be established by the HMA and costings would be provided at detailed design stage. The developer would need to fund a scheme by way of the requisition provisions of the Water Industry Act or via a legal/commercial agreement with Welsh Water.
Community facilities
CI3 – new community facilities
Our representations on the site allocations are included in appendix 2.
CI5 - cemetery and crematorium provision
Our representation on the site allocation is included in appendix 2.
Productive and enterprising places
SP14 - employment growth
Our representations on the site allocations are included in appendix 2.
We support sustainable economic development, however the LPA and potential developers should be aware that the obligations of a water and sewerage undertaker only extend to the ‘domestic’ supply part of an employment development (sinks, toilets, kitchen facilities etc). We are not obliged to provide potable water for use in any industrial process. Where an employment development results in higher demands of water supply and/or trade effluent discharge consent, under Section 118 of the Water Industry Act 1991, we recommend and welcome early consultation with developers. The capability of our infrastructure to service future employment allocations will be assessed when the potential demands arising from the developments are known.
EMP1 - employment regeneration opportunity areas
Our representations on the site allocations are included in appendix 2.
Climate change and transition towards net zero (CC)
SP16 - climate change mitigation and adaptation
We are supportive of this policy as the protection of water resources are key in ensuring we maintain a safe, healthy and reliable water supply. Incorporating water efficiency measures into developments will help minimise adverse impacts on localised and wider water supply networks including the quality of water resources.
We are also pleased that the policy includes particular emphasis on the importance of sustainable urban drainage systems (SuDS), in conjunction with Schedule 3 of the Flood and Water Management Act 2010. The tackling of surface water at source is a vital component of sustainable development and will mitigate against overloaded sewers which can ultimately lead to flooding. Disposing of surface water in a sustainable manner by ensuring that it does not communicate with the public sewerage network, including rainwater harvesting systems, protects the environment and assists in ensuring that there is sufficient capacity in the public sewerage network for foul-only flows from development sites.
SP19 – Green Infrastructure
In conjunction with SAB applications, under Schedule 3 of the Flood and Water Management Act 2010, we welcome provision within this policy to integrate green infrastructure with sustainable drainage systems.
Environmental protection
DNP5 – environmental protection
We welcome provisions within the policy to protect the natural environment from unacceptable impact from pollution of land, surface water, ground water and the air as well as flooding risks.
We hope that the above will assist you as you continue to progress the LDP. If you require any further information, then please do not hesitate to contact us on 0800 917 2652 or forward.plans@dwrcymru.com.

Appendix 1 – HG1 Housing Allocations, SP9 Gypsy & Traveller Site
Our representations on site allocations are provided in the table below. The following caveats are applicable to all sites:
• In accordance with the Water Industry Act 1991, Welsh Water retains rights of access to its assets at all times. Where there are sewers and/or water mains crossing sites then protection measures in respect of these assets will be required, usually in the form of an easement width or in some instances a diversion.
• Where insufficient hydraulic capacity exists within the public sewerage network or water supply network to accommodate/serve a development site, hydraulic modelling assessments (HMA) may be required, and developers would be strongly recommended to fund investigations during pre-planning stages. The findings of the HMA will identify the extent of any reinforcement required to accommodate the development, which can be procured via the requisition provisions of the Water Industry Act 1991 (as amended). If the sewerage network system in the locality is currently at capacity, there may be an opportunity to overcome our concerns by delivering a surface water removal scheme. This approach would ensure that there is no net increase in volume of flows communicating with the public sewer network, and therefore no further detriment to the public sewer network downstream of the development.
• In some instances, off-site water mains or public sewers may be required to connect to a suitable point on the existing networks at the developers’ cost. We may seek to control points of connection to the public sewerage network via appropriate planning conditions. Where assets need to be laid over private land, developers will need to comply with the requisition provisions of the Water Industry Act 1991.
• If there is limited or no capacity available at a Wastewater Treatment Works (WwTW), developers may need to fund a Developer Impact Assessment (DIA) to identify required reinforcement works. In these instances, a commercial agreement would be required between the developer and Welsh Water to deliver the necessary reinforcement works.
• Where capacity is currently available in the water supply network to accommodate development, we reserve the right to reassess our position at the time of the formal application for the provision of new water mains under Section 41 and Section 51 of the Water Industry Act (1991) to ensure there is sufficient capacity available to serve the development without causing detriment to existing customers’ supply as demands upon our water systems change continually.
• Please note the below comments are subject to change as the LDP progresses and/or as planning applications are submitted.

See tables in attachment for site specific comments.

Appendix 2 - Employment sites & other uses
Capacity comments for employment allocations can only be provided once the type of development and occupier/end-user of a site is known. Once requirements are confirmed, usually through the planning application process, further assessments will be undertaken. High-level comments are provided in the table below regarding any watermains/sewers crossing the proposed allocations, and the WwTW catchment that the sites are located within.
The following provisions are applicable to all allocated employment sites:
• the obligations of a water and sewerage undertaker extend to ‘domestic’ supplies only. We are not obliged to provide potable water for use in any industrial process. Where an employment allocation results in higher demands of water supply and/or trade effluent discharges we recommend and welcome early consultation with Welsh Water.
• The individual plots available for development can represent a substantial area of land for which the potential demands upon our assets are unknown at present. It is essential that we understand these demands to allow us to assess the impact on our assets. It may be necessary for water and/or sewerage hydraulic modelling assessments (HMAs) to be undertaken at the developer’s expense to establish where the proposed development could connect to the existing networks, and to identify any required infrastructure reinforcement works. Water mains and/or sewerage infrastructure required for any potential development site can be acquired through the requisition provisions of the Water Industry Act 1991 (as amended).
• In accordance with the Water Industry Act 1991, Welsh Water retains rights of access to its assets at all times. Where there are water mains and/or sewers crossing sites then protection measures in respect of these assets will be required, usually in the form of an easement width or in some instances a diversion of the asset.
• Where there is limited or no capacity at a WwTW, dependant on the scale and pace of development, developers may need to fund a Developer Impact Assessment (DIA) to identify required reinforcement works. In these instances, a commercial agreement would be required between the developer and Welsh Water to deliver the necessary reinforcements.
• If any development site gives rise to a new discharge (or alters an existing discharge) of trade effluent, directly or indirectly to the public sewerage system, then a Discharge Consent under Section 118 of the Water Industry Act 1991 is required from Welsh Water. Please note that the issuing of a discharge consent is independent of the planning process and a consent may be refused despite planning permission being granted.

See tables in attachments for site specific comments

My disagreement/objections to HG1 KS2 are as follows:-
a.) Invasion into the green belt which could eventually result in the merger of Dinas Powys/Eastbrook and Llandough, i.e. loss of the village identity;
b.) Additional use of the pedestrian traffic lights for Eastbrook Railway Station would result in increased traffic delays and pollution;
c.) 250 new homes will mean a substantial increase of traffic movements from and to the site with access controlled by traffic lights. Many occupiers are likely to own a second car. In addition, proposed sites at KS1, KS3, KS4 and KS5 provide for 2028 new homes and it is reasonable to assume a proportion of cars leaving those sites will use Cardiff Road to travel to work or for recreational purposes - creating further grid locking and pollution. There is effectively no provision to improve traffic flow through Dinas Powys which has increasingly become congested. Dinas Powys By-Pass should be provided prior to consideration of more housing in the area;
d.) Flood risk from Cadoxton River and East Brook has not been adequately addressed. Natural Resources Wales have in the recent past undertaken a review of the flood risk; however, they have not put forward comprehensive proposals to solve the problem, but devised plans to "manage" incidents as and when they arise. Surface water running off a developed site would end up in East Brook and therefrom into Cadoxton River increasing the flood risk. Appropriate action would be essential to address this matter. Consideration of foul waste arrangements is also essential - Does the existing system have capacity for the proposed additional housing?; and
e.) Doctors and dentists services are already stretched. What about availability of places in the schools?

Ref: Objection to RLDP and Site Ref: HG1 KS2
Please find below my objections to the RLDP and Site Ref: HG1 KS2 - the proposed development of 250 homes in Eastbrook, Dinas Powys Vale of Glamorgan (Ref:444).
It is framed specifically for Welsh Planning Practice, TAN guidance, Welsh Government Policy and Fire and Rescue Expectations in Wales.

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.

My objections are as follows:

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 secondary two independent access points, or at minimum a fully engineered emergency-only 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.
2.4 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

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 Councilors 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 be grateful for confirmation that my objections have been formally received and noted.

I trust that the Vale of Glamorgan Council will now withdraw the RLDP and abandon this proposed development plan for Eastbrook, Dinas Powys.

Kind Regards

We formally request the immediate removal of Site SP4.2 from the RLDP. This land must remain a protected Green Wedge. The developer's "Vision" represents a profound logical and ecological contradiction; it claims to "enhance" a sensitive habitat only after its wholesale destruction, while proposing 'integration' through a car-centric model that ignores the physical reality of the site.

Introduction: A Heritage Under Threat

My name is Matthew Jackson-Hookins. I live on Powys Drive with my partner, our three-year-old daughter, and our dog. Having lived in Dinas Powys since I was a child, I write this with a profound sense of responsibility for the future of the village where my daughter is now growing up. We chose to raise our family here because of the surrounding countryside, the quiet village feeling, and the local community vibe that makes this place special.

To a developer, Site SP4.2 is a "blank canvas" on a map, to those of us who have lived alongside and observed this land through every season, it is a complex and temperamental environment that cannot be built upon without severe, irreversible consequences. No one who truly understands the physical reality and unique topography of this site could conclude that this is a sustainable or safe proposal. This development represents a breaking point—one that threatens to destroy the delicate balance that makes Dinas Powys a home rather than just another urban extension.

Because this plan is fundamentally flawed, I have compiled a comprehensive technical refutation. The following points outline the specific technical failures of the proposal for Site SP4.2 why it must be removed from the RLDP.
1. Highways & Public Health: A Documented Failure of Air Quality Outline of Issues Dinas Powys is uniquely vulnerable to atmospheric pollution due to its status as a "topographical trap." Situated on a valley floor, the village is enclosed by surrounding ridges that prevent the effective dispersal of vehicle emissions—a phenomenon exacerbated by the frequent temperature inversions common to the area. Empirical data for Cardiff Road confirms a current state of crisis: this corridor already experiences "Significant Air Pollution" that exceeds three separate World Health Organization (WHO) safety limits. Consequently, this location is currently ranked in the 44th national percentile for poor air quality.
Introducing a high-volume junction and an estimated 500+ daily vehicle movements to this specific, already-saturated bottleneck is more than a planning oversight; it represents a direct and documented threat to the respiratory health of residents and children commuting to school.
The Policy Contradiction The current proposal stands in direct opposition to several statutory frameworks:
• Environment (Air Quality and Soundscapes) (Wales) Act 2024: This Act mandates a "preventative approach" to emissions and requires public bodies to proactively reduce exposure to harmful pollutants.
• Planning Policy Wales (PPW) 12, Section 3.8: This section explicitly requires the planning system to maximize its contribution to health and well-being while minimizing environmental risks.
• Future Wales 2040 (Policy 1): This policy mandates that all strategic growth must support "Health and Wellbeing"; however, this specific allocation actively degrades both.
The Failure of Assessment The Council has fundamentally failed to account for the "topographical trap" effect of the valley. By proposing 250 households on a corridor that already exceeds WHO safety limits, the Council is in direct violation of the "Healthier Wales" goal established by the Well-being of Future Generations (Wales) Act 2015. While the Council's own Local Air Quality Management (LAQM) reports acknowledge the sensitivity of the A4055, this allocation ignores that data.
Furthermore, the Council's traffic models rely on broad averages that overlook the reality of localized, stationary idling at the proposed new junction. This idling will concentrate $NO_2$ and particulate matter in a zone already identified as high-pollution. To ignore site-specific pollution data in favor of generalized models constitutes a significant procedural error.
Note on Topography: The provided topographical map above offers empirical proof of the site's physical unsuitability. By illustrating the dramatic elevation drop from the 100m+ surrounding ridges to the 12m valley floor, the data confirms that Dinas Powys is a natural "topographical trap." Although the proposed housing sits on higher ground, the environmental impact is displaced: every vehicle generated by this development must descend into the basin, leading to concentrated idling at a new junction. These additional pollutants will not disperse; instead, they will "pool" at the lowest point where children walk to school, exacerbating a crisis in a zone that already fails three WHO safety limits.
Furthermore, this development will inevitably introduce a significant volume of new vehicles into an already saturated network. This influx will directly worsen existing congestion and pollution, pushing the village's fragile infrastructure beyond its documented breaking point.
Emergency Service Access & Public Safety Risk: Internal Highways assessments and national emergency response benchmarks indicate that when a network reaches the "saturation point" cited in the WelTAG study, "Blue Light" vehicles (Police, Fire, and Ambulance) lose the physical "filter space" required to bypass traffic. This directly endangers Dinas Powys residents by increasing response times beyond safe statutory limits. The Council has been warned that a saturated road network is a "severely compromised" environment for emergency responders.
To propose further development in the face of such overwhelming evidence is to ignore over ten years of expert warnings and official government data. The Council cannot simultaneously admit the network is at a "saturation point" and argue that it has the capacity for significant residential growth.
A Demand for Transparency In light of the data utilized from the official gov.uk Road Traffic portal and the Council's own conflicting reports, we demand full transparency regarding the following:
1. Publication of Raw Traffic Data: The Council must release the full, unedited Highways monitoring datasets used to justify the "capacity" for new developments.
2. Emergency Impact Assessment: Immediate release of any correspondence regarding the projected impact of "Saturation Point" congestion on life-saving response times.
3. Conflict Resolution: An explanation of the logical contradiction between the Arcadis "Doomsday" warning and the current push for residential growth.
3. Child and Elderly Safety: The Vulnerable at Greatest Risk Outline of Issues Scientific research and public health data consistently confirm that children and the elderly are the most susceptible to the adverse effects of poor air quality and traffic-related pollutants. Children possess higher respiratory rates and developing lungs, meaning they inhale more pollutants per pound of body weight than adults. Similarly, the elderly often suffer from underlying cardiovascular or respiratory conditions that are acutely exacerbated by the levels of Nitrogen Dioxide ($NO_2$) and Particulate Matter ($PM_{2.5}$) already documented on Cardiff Road.
HEALTH EFFECTS OF AIR POLLUTION
• Headache and anxiety
• Irritation of eyes, nose and throat
• Breathing problems
• Impacts on the respiratory system: Irritation, inflammation and infections, Asthma and reduced lung function, Lung Cancer
• Impacts on the reproductive system
By placing 250 additional homes and a major new junction within a "topographical trap" that already exceeds WHO safety limits, the Council is knowingly increasing the health risks for its most vulnerable residents. Furthermore, the sheer increase in traffic volume poses a physical safety risk to children commuting to local schools. The Council has failed to provide a viable "Safe Route to School" plan that does not force children to walk alongside a congested, high-pollution arterial road.
The Policy Contradiction The current proposal fails to align with key protective frameworks:
• "A Healthier Wales" (Well-being of Future Generations Act): This legally obligates the Council to act in a way that protects the long-term physical and mental health of children.
• United Nations Convention on the Rights of the Child (UNCRC): These rights are incorporated into the Welsh policy framework, requiring a "best interests" assessment for any development that impacts children's health and safety.
The Failure of Due Diligence The Council has disregarded the specific vulnerabilities of the pediatric and geriatric populations in Dinas Powys. There is no evidence within the LDP Integrated Sustainability Appraisal (ISA) that the Council has conducted a specific Pedestrian Safety and Respiratory Risk Audit for children who will be forced to navigate this high-pollution junction daily. This omission renders the site allocation unsound.
Demand for Transparency We demand the immediate initiation and public disclosure of the following:
• A Child Health Impact Assessment (CHIA): To specifically quantify the long-term respiratory impact on children living near and commuting past the affected corridor.
• A Stage 1 Road Safety Audit: Focused specifically on pedestrian crossing safety and "Safe Routes to School" for children and the elderly at the proposed new junction.
• Vulnerability Mapping: Data showing how the concentration of pollutants in this "topographical trap" correlates with the locations of local schools, nurseries, and elderly care facilities.
4. Hydro-Geological Reality: The "Basin" and 2025 Infrastructure Evidence Outline of Issues Dinas Powys is situated within a natural geological "basin," where surrounding limestone ridges shed surface water directly toward the Eastbrook and Cadoxton Brook systems. The land to the north acts as a critical "soakaway" sponge; its high water table is documented in historical drainage records and is well-known to multi-generational residents. The village's specific topography dictates that every square meter of greenfield land developed uphill results in the immediate displacement of water into the foundations of the lower village.
The Topographical Contradiction Proposed site SP4.2 sits on a critical uphill slope. Replacing this natural soakaway with impermeable concrete surfaces will inevitably displace floodwater into the vulnerable Eastbrook basin below. Furthermore, the steep terrain across proposed access points creates a physical barrier for the elderly and disabled. This gradient renders the site non-compliant with the Equality Act 2010 and Active Travel guidance.
The St Davids Avenue Incident (October 12, 2025) The St Davids Avenue incident on October 12, 2025, serves as more than just a localized repair issue; it is a damning contradiction of the Council's claim that the land is suitable for high-density development. While the Council's planning assessments suggest the ground conditions can support the weight and drainage requirements of 250 homes, Welsh Water's official attribution of the burst to "ground movements and changing soil conditions" provides immediate, real-world evidence to the contrary.
The Contradiction: The Council cannot logically argue that the land is stable enough for a major housing allocation while their primary utility provider is simultaneously blaming the "extreme sensitivity" of that same soil for catastrophic infrastructure failure.
The Impact of Development: By replacing a natural, absorbent greenfield slope with thousands of tonnes of concrete and brick, the Council will inevitably accelerate these "ground movements." The additional weight and the alteration of natural water pathways will further destabilize the fragile Dinas Powys basin.
The "Waterfall" Precedent: If a single pipe failure can create a "torrent of water" lasting 10 hours and damaging multiple properties, the introduction of a new, high-pressure junction and a 250-home sewage/water load into this "saturated" network is an act of extreme negligence. This incident has inadvertently provided the very evidence needed to prove that further development in this specific location will lead to systemic infrastructure collapse and irreversible damage to existing homes. It serves as a stress-test that proved the existing network has zero residual capacity for further connection.
The Policy Contradiction The Council's proposal stands in violation of several critical mandates:
• "A Resilient Wales" (Well-being of Future Generations Act): Legally requires public bodies to maintain and enhance infrastructure stability.
• Planning Policy Wales (PPW) Section 6.6 and TAN 15: These enforce a preventative approach to flood risk, requiring developers to provide evidence that new builds will not increase risk elsewhere.

The Failure of Infrastructure Assessment The Council's assessment of infrastructure capacity is demonstrably flawed. Local representatives, including Cllr Malcolm Phillips, have officially recorded concerns regarding the "failing infrastructure" of the village. To construct 250 homes on the village's primary natural soakaway, while connecting them to a proven-failing pipe network, constitutes planning negligence. This contradicts the Vale of Glamorgan Shoreline Management Plan and the Local Flood Risk Management Strategy. Such development will inevitably displace groundwater into existing foundations, leading to subsidence and structural damage.

Demand for Transparency Following the 2025 infrastructure failure, we demand the immediate production and public release of:
• A Cumulative Hydro-Geological Impact Assessment: This must detail how the loss of the uphill soakaway will impact the water table of the Eastbrook basin.
• A Water Network Stress Test Report: Professional verification that the existing Victorian-era pipe network can handle additional load without risking further catastrophic bursts.
• A Subsidence Risk Plan: Projecting the impact of groundwater displacement on the structural integrity of existing lower-village homes.

5. The "Brownfield First" Failure: Neglecting Viable Alternatives
Outline of Issues: Dinas Powys is being targeted for aggressive greenfield expansion despite the Council's failure to demonstrate a rigorous, legally required "sequential approach" to land allocation. The Land North of Dinas Powys is a high-value greenfield site providing essential ecosystem services and carbon sequestration. However, the Council has bypassed significant, underutilized brownfield opportunities within the Barry area that are demonstrably more suitable for high-density housing. Crucially, the Council has also ignored the strategic necessity of the Dinas Powys Bypass, which should have been a non-negotiable prerequisite for any further regional growth.
The Policy Contradiction:
• Planning Policy Wales (PPW) 12 (Section 3.51): Explicitly states: "Previously developed (brownfield) land should, wherever possible, be used in preference to greenfield sites".
• Future Wales 2040: Prioritizes "Urban Growth Zones" specifically to prevent the loss of productive agricultural and ecological land.
The Failure: The Council has systematically ignored more sustainable brownfield sites—such as redundant industrial land in Barry Docks—which are situated closer to existing employment hubs. By allocating Site SP4.2, the Council has effectively neutralized the "cost-benefit" argument that usually favors greenfield development. Furthermore, the exclusion of the bypass from the infrastructure plan, while continuing to funnel housing traffic onto the A4055, constitutes a violation of the National Development Framework's strategy for regional transport and regeneration.
Demand for Transparency: We demand a formal Brownfield Sequential Test Audit and an updated Dinas Powys Bypass Feasibility Study.
The "Mole" Density Vacuum and Sequential Failure The most egregious example of the Council's failure to apply a "Brownfield First" strategy is the allocation of "The Mole" (Barry Waterfront). This 10-acre, Tier 1 brownfield peninsula has been earmarked for a mere 65 units—a startlingly low density for a prime urban hub. Under Future Wales 2040 and PPW 12, such sites are mandated for high-density development to maximize land use and protect the environment. Standard urban planning for a waterfront hub should target densities of 50-80 dwellings per hectare (dph).
If the Council optimized The Mole to match these modern urban standards, the resulting yield would accommodate the 250 units currently proposed for Site SP4.2. Such a strategic shift would render the destruction of the Dinas Powys Green Wedge entirely unnecessary. Furthermore, the recent acceptance of the Marina development at The Mole confirms the site's commercial and technical viability. By choosing to sacrifice 25 acres of high-value green space at SP4.2 instead of optimizing a viable 10-acre brownfield site, the Council has fundamentally failed the "Sequential Approach" required by national policy. This is a clear case of developer convenience—the "tail wagging the dog"—prioritizing easy greenfield "plug-and-play" sites over the responsible remediation and densification of urban land.
The Barry Docks & Argae Lane Precedent: A Strategy of Inconsistency The Council's decision in May 2025 to withdraw the Argae Lane/Barry Docks Link Road site—citing "deliverability and infrastructure concerns"—sets a legal precedent that must be applied to Site SP4.2. Critically, the constraints in Dinas Powys are significantly worse than those that led to the Barry withdrawal:
• Infrastructure Sensitivity: Unlike the Barry Link Road, which was designed for high-volume bypass traffic, Dinas Powys relies on a single arterial corridor (A4055) and a network of narrow residential lanes.
• Geographical Constraints: While Barry residents have multiple arterial routes to "bypass" congestion, Dinas Powys residents are geographically landlocked. Adding 250 homes here ensures that existing residents become trapped under a permanent blanket of traffic with no alternative escape routes.
• The "Sustainable" Fallacy: The Council justified the Argae Lane withdrawal because pedestrian and cycle links required excessive upgrading. In Dinas Powys, these links are even more deficient; the "sustainable" travel route to Eastbrook Station is physically impassable for the disabled and elderly. If Barry's links were deemed "undeliverable," then the Dinas Powys links—which face greater topographical and legal barriers—are effectively non-existent.
• Discriminatory Planning Standards: It is procedurally unsound to scrap a site in Barry due to highway constraints while forcing an allocation in Dinas Powys that suffers from the same issues on a more severe scale. Barry's infrastructure was built for town-scale growth; Dinas Powys is a village being asked to perform as an urban extension without the requisite physical capacity. By proceeding with SP4.2 while withdrawing the Barry site for identical reasons, the Council is failing its duty of consistency. They are prioritizing developer convenience over the documented reality that Dinas Powys has reached its absolute physical limit.
The "Ghost" Industrial Land (Wimbourne Road) As evidenced by the June 2024 Site Condition Report, sites like Wimboune Road remain underutilized, serving only as low-value industrial storage. By refusing to proactively re-designate this land for Residential Use (Class C3), the Council is manufacturing an artificial 'need' to destroy the Dinas Powys Green Wedge. This represents a failure of the "Sequential Approach" mandated by PPW 12. Instead, the Council has opted for the "path of least resistance," sacrificing high-value greenfield land simply because it is cheaper and easier for developers. The "need" for greenfield expansion only exists because they have failed to unlock the residential potential of the brownfield land already at their disposal.
Methodological Error: The Urban Capacity Study The Council's 2025 Urban Capacity Study is fundamentally flawed because it is entirely passive. It relies almost exclusively on sites handed to them by landowners during the "Call for Sites" process. By failing to use Compulsory Purchase Order (CPO) powers or proactive land assembly to unlock "stalled" brownfield sites in Barry, the Council is acting as a passive observer rather than a "Master Developer". They are allowing landowners to dictate the geography of housing growth instead of protecting our village as the law intended.
Demand for Transparency: We formally demand a Sequential Test Verification Report that justifies prioritizing greenfield development at Site SP4.2 over high-density opportunities at The Mole and Wimbourne Road. This must include:
• A Transparent Density Comparison: A side-by-side analysis of "Dwellings Per Hectare" (dph) across all sites.
• Justification for Under-utilization: An explanation as to why low-density housing is being permitted in prime urban transport hubs while a "housing crisis" is simultaneously cited to justify destroying the Green Wedge.
• Evidence of Policy Compliance: Proof that the "Sequential Approach" mandated by PPW 12 has been exhausted.
• Accountability for "Stalled" Sites: A report on why proactive land assembly or CPO powers have not been utilized to unlock Tier 1 brownfield land in Barry.

6. Technical Deliverability: The "Active Travel" Fallacy
Outline of Issues: The Council's justification for Site SP4.2's sustainability is predicated upon an aspirational "modal shift" toward walking and cycling. However, the proposed infrastructure is physically unworkable and strategically flawed. The site is effectively landlocked by third-party private property and substandard access points. The proposed links through George's Row, Powys Close, and the associated "gullies" are fundamentally unfit for purpose.
Council Admission of Failure (June 2024 Report): In the Council's own June 2024 Barry to Dinas Powys Active Travel Consultation Report (Officer Response 16), they stated regarding this corridor: "This option was considered during the development of this scheme but was discounted due to the loss of vegetation, impact on flooding and gradient issues". This admission creates an irreconcilable conflict. If the terrain cannot sustain a 3-meter-wide cycle path, it is a technical impossibility to suggest the same land can sustain the far more invasive footprint of a 250-home housing estate. A housing development requires massive soil displacement, heavy-duty roads, and expansive impermeable surfaces. If the environmental "carrying capacity" cannot support a single travel link, it cannot support a major urban extension without causing the very flooding and ecological destruction the Council's own report warned against.
Expert Rejection of "Sustainable" Links: This is further supported by Vale Veloways, who branded the proposed routes as "not suitable for commuting" and "hostile" to users. The Council cannot claim compliance with the National Sustainable Transport Hierarchy (PPW 12) when its own expert stakeholders have rejected these links. Their sustainability claims are undermined by their own previous evidence.
Infrastructure Deficit: George's Row & Powys Close:
• The Width Deficit: Under the Active Travel (Wales) Design Guidance, a shared-use path requires a minimum width of 3 meters. There is no physical ability to achieve this without removing boundary walls or encroaching on private land.
• Dangerous User Conflicts: Because these conduits cannot be widened, cyclists and pedestrians will be forced into a cramped space. On this steep site, downhill cyclists create a significant collision risk to vulnerable walkers.
• Safety and "Blind Corridors": These routes fail the "Safe and Accessible" mandate of PPW 12. Flanked by high boundaries with zero "overlooking" (passive surveillance), they create "dead zones" that act as focal points for Anti-Social Behavior (ASB). Resident feedback confirms these paths are already avoided after dark.
• Topographical Contradiction (Equality Act 2010): National Design Guidance states routes should ideally be no steeper than 5%. The steepness of Powys Drive, George's Row, and Powys Close significantly exceeds this. To ignore these gradient issues effectively "designs out" the elderly and disabled, violating the Public Sector Equality Duty.
The "Active Travel" Fallacy (Greenwashing): The claim to prioritize pedestrians is a form of "Greenwashing". While the developer proposes an engineered road link for vehicles, they expect pedestrians to navigate narrow, intimidating, and steep conduits. This "Quality Gap" will inevitably force residents into their cars. One does not build a major arterial road link for a community that is supposedly "walking to the train station".

7. Active Travel Continued: Infrastructure Incompatibility
Outline of Issues: Proximity to Eastbrook Station is used as a strategic justification. However, the station currently lacks step-free access to the Cardiff-bound platform. By framing the site as "sustainable" when a parent with a pram or a person in a wheelchair cannot board a train, the Council is engaging in a "False Sustainability" narrative.

A Precedent of Infrastructure Failure: The Rejected Lift:
• The 2021 Refurbishment Failure: During a 2021 footbridge refurbishment, community requests for a lift were rejected by Network Rail and the Council, who opted for a "like-for-like" repair of the steep, stepped bridge.
• Funding Bypassing: Eastbrook has been repeatedly excluded from the Department for Transport's 'Access for All' funding rounds. The Council has historically deferred responsibility for the lift, citing a lack of local budget.
• The "Secondary Status" Myth: Authorities justify the lack of investment by labeling Eastbrook a "low-scale priority," yet promote the station as a "primary" strategic asset to justify 250+ new homes. This is an impossible paradox.
• Logistical Constraints: Network Rail previously maintained that the existing 19th-century bridge made a lift installation too costly and opted for a budget-driven repair, sabotaging "Active Travel" goals.

It is intellectually dishonest to call a location "low priority" for safety and accessibility, but "high priority" for developer profit. To approve this development without a guaranteed, funded, and legally binding commitment to build the Eastbrook lift is to ignore a decade of infrastructure failure.
A Breach of the Equality Act 2010: Providing a primary travel link that lacks step-free access physically bars the disabled and elderly from the designated route to the village. This is not "community integration"; it is physical segregation based on mobility.
The Overburdened Crossing Barrier:
• The Single Pressure Point: Adding 250 households will force the existing pedestrian crossing at Eastbrook to become dangerously overburdened.
• Documented Danger: Current crossing conditions have been described as "lethal" due to traffic volume. Funneling hundreds of additional movements into this point constitutes planning negligence.
The At-Grade Track Crossing: To avoid the A4055, the Council proposes an at-grade track crossing. This is a reckless solution. It lacks essential safety features like handrails and non-slip footing. Under the South Wales Metro upgrades, rail frequencies are set to increase, making this an unacceptable safety risk. A single slip by a child or parent at this unrailed crossing could lead to a catastrophic incident.
Conclusion: The "Commuter Island" Reality When "sustainable" links are physically inaccessible, topographically impossible, or legally non-compliant, they cease to be links at all. Site SP4.2 is a "Commuter Island" that will be 100% car-dependent. This will pour additional volume onto a saturated and dangerous road network, in direct opposition to the core principles of PPW 12.
Demand for Transparency: We formally demand an Independent Topographical Accessibility Audit to verify if proposed routes meet the required ratios for wheelchair users and the elderly. If they do not, the Council must admit the site is entirely car-dependent.

8. Regional Cumulative Impact: The Barry-Cardiff "Statistical Blindness"
The "Geographical Funnel" Effect: Dinas Powys serves as the critical geographical "pinch-point" for the entire south-eastern Vale of Glamorgan. The Council's assessment of Site SP4.2 is fundamentally flawed because it operates within a geographic vacuum, ignoring the village's role as the primary "pressure valve" for two major urban centers.
• The Barry Pressure: As of 2024/2025, the population of Barry is estimated at over 58,000 residents. Official ONS and Welsh Government commuter flow data confirms that Barry functions as a primary "dormitory" town, with approximately 43% to 45% of its working population commuting into Cardiff daily.
• The Route of Least Resistance: While the A4050 (Port Road) serves western Barry, the A4055 through Dinas Powys is the only direct arterial route for thousands of residents within the Barry Waterfront, Bendricks, and East Barry developments.
• The "Country Lane" Trap: To bypass the chronic congestion at the Merrie Harrier junction, commuters increasingly saturate surrounding rural routes, including Twyn-y-Rodyn, Argae Lane, and St Andrews Road. These routes are narrow, unlit, and lack the physical width to safely accommodate two-way heavy traffic. By allocating 250 homes at Site SP4.2, the Council is effectively sealing this "trap" for both residents and commuters.
Methodological Failure: Data Inconsistency Unlike Barry, which benefits from multiple bypass options and arterial alternatives, Dinas Powys is physically landlocked by its railway infrastructure and the topography of the valley. Residents cannot "bypass" their own village.
The traffic data utilized for the Revised Local Development Plan (RLDP) is statistically incomplete; it relies on localized, "snapshot" counts that fail to account for the massive surge in vehicle movements generated by the recent 2,000-home expansion at Barry Waterfront. Adding an estimated 500+ daily vehicle movements from Site SP4.2 into the Eastbrook catchment without a documented plan to increase rail carriage frequency or deliver a bypass is a recipe for systemic infrastructure failure. The Council is exhibiting "statistical blindness" by treating Dinas Powys as an isolated settlement rather than the primary transit corridor for a town of 58,000 people.
Forecasted Gridlock Existing residents face the prospect of living under a permanent blanket of traffic, unable to safely exit their own driveways during peak hours while Barry's commuter volume continues to swell. The Council's own WelTAG study admitted that background traffic growth is expected to increase by 35% by 2026. Introducing 250+ homes at Site SP4.2, alongside the thousands of units already nearing completion at the Barry Waterfront, will lead to total regional gridlock.
Demand for Transparency We formally contest the validity of the current Transport Assessment on the grounds that it fails to provide a Cumulative Regional Transport Impact Assessment (CRTIA). Under PPW 12 Paragraph 4.1.2, the Council has a statutory duty to ensure the LDP evidence base is "robust and comprehensive". By relying on isolated "snapshot" data, the current assessment ignores the synergistic congestion at the Merrie Harrier junction and the A4055 corridor.
We demand that the Council demonstrates, via microsimulation modeling (VISSIM or equivalent), a 10-year projection of traffic volumes that accounts for the concurrent impact of:
1. Committed Development: The completed build-out and associated trip generation from the 215 units at Cosmeston and the expansion of the Barry Waterfront.
2. Strategic Growth: The projected 35% background growth identified in the Council's own WelTAG studies.
3. Site Specifics: The additional peak-hour trip generation specifically originating from Site SP4.2.
Until this cumulative data is modeled and subjected to public scrutiny, the allocation of Site SP4.2 remains technically unsound, irresponsible, and a direct violation of the Sustainable Transport Hierarchy. We formally state that any approval granted without this granular, multi-site modeling constitutes a failure of the "Test of Soundness" and leaves the RLDP vulnerable to procedural challenge.

9. Ecology & Biodiversity: The "Dormouse Precedent" The Breach of Statutory Duty: The Council's proposal for Site SP4.2 is fundamentally inconsistent with its own recent ecological findings and fails to satisfy the "Section 6 Duty" of the Environment (Wales) Act 2016, which requires public authorities to seek to maintain and enhance biodiversity.
• The Dormouse Precedent: Recent surveys commissioned by the Vale of Glamorgan Council for the Biglis-to-Dinas Powys Active Travel Route (ATR) (2023/2024 reports) confirmed the presence of Hazel Dormice within the hedgerow network directly contiguous with Site SP4.2. Proposing the removal or fragmentation of these same hedgerows without a comprehensive Phase 2 Species-Specific Survey is a direct breach of the Conservation of Habitats and Species Regulations 2017.
• Dark Corridors & SSSI Proximity: Local records and the site's proximity to the Dinas Powys Woods SSSI confirm that this land serves as a vital "dark corridor" for Greater and Lesser Horseshoe Bats. The introduction of high-density street lighting and the removal of mature treelines will cause permanent habitat fragmentation, disrupting essential foraging and commuting routes for these protected species.
Evidence of Decline: The "Data Vacuum" The Council has failed to provide a Seasonal Pond Audit or a Great Crested Newt (GCN) Mitigation Strategy, despite the high water table and drainage ditches providing optimal terrestrial and aquatic habitat. Nationally, these species remain in an "unfavourable" conservation status, yet the Council is proceeding with a "data vacuum" regarding local populations.
Species: Hazel Dormouse
National Population Trend (Last 20 years): -75% (State of Nature Report)
Principal Cause of Local Extinction: Loss of hedgerow connectivity & urban light pollution
Species: Horseshoe Bats
National Population Trend (Last 20 years): Significant decline in range
Principal Cause of Local Extinction: Loss of “dark corridors” and foraging grounds
Species: Great Crested News
National Population Trend (Last 20 years): ~50% (Estimated)
Principal Cause of Local Extinction: Destruction of terrestrial habitat & drainage shifts
The State of Nature 2023 report confirms that 1 in 6 species in Wales are at risk of extinction. By developing the Green Wedge at Site SP4.2, the Council is actively contributing to this local decline. Furthermore, it should be noted that the Council's own Ecology Officer (as of July 2024) raised significant objections to the early proposals for this site, citing the irreversible impact on the local ecosystem.
Demand for Transparency: We demand Phase 2 Species-Specific Ecological Surveys conducted over a full active season (April-October). This must include a Lighting Impact Assessment to prove how the "Dark Corridor" for Horseshoe Bats will be maintained in perpetuity.
Summary of Ecological Risk The Council cannot claim "Biodiversity Net Gain" while simultaneously destroying the core habitat of European Protected Species. A "desktop study" or generic Phase 1 habitat survey is legally insufficient for a site of this ecological sensitivity.
Demand for Transparency: We formally demand the immediate release of a Phase 2 Species-Specific Survey for the Hazel Dormouse, conducted over a full active season (April-October). The Council must transparently demonstrate how the proposed "sustainable transport links"—which necessitate significant hedgerow removal—can be achieved without creating a fragmented "Dead Zone" in breach of the Conservation of Habitats and Species Regulations 2017.
This section effectively shifts the argument from environmental concerns to the daily lived reality of the village, highlighting a "systemic collapse" of services. I have refined the language to be more assertive, ensuring the data is presented clearly and the legal arguments regarding "Consumptive Capacity" and "Section 106" are reinforced.

10. Infrastructure Deficit: The "Tipping Point" of Local Services Failure of Consumptive Capacity: The fundamental flaw of Site SP4.2 is the assumption that Dinas Powys can "consume" an additional 250+ households without a corresponding investment in primary infrastructure. The village is currently operating at an infrastructure deficit; adding further residents is not "growth," it is a recipe for the systemic collapse of local services.
Healthcare and Dentistry The village's medical and dental provisions are already overstretched to a degree that is dangerous for current residents.
• GP Wait Times: Residents already report multi-week wait times for non-emergency appointments. Data indicates that GP patient lists in the Vale are at record highs.
• Demographics: Dinas Powys has the second-highest percentage of elderly patients in the Eastern Vale Cluster; this demographic requires more frequent, complex, and "at-home" medical care.
• Capacity Myth: The Dinas Powys Medical Centre was built to replace an outdated 1971 facility to meet existing needs, not to facilitate a massive population explosion.
• Zero Dental Capacity: There is effectively zero capacity for new NHS dental patients in the Dinas Powys area.
• The Infrastructure Gap: The SP4.2 proposal includes no provision for new medical or dental facilities, relying entirely on a network that is already failing to meet demand.

Education: Schools at Breaking Point Dinas Powys Primary and nearby secondary schools (St Cyres/Stanwell) are currently at or exceeding functional capacity.
• The Planning Trap: Site SP4.2 falls into a precarious "middle ground." It is too small to trigger the mandatory requirement for a developer to build a new school, yet large enough to add hundreds of children to the local catchment.
• Operational Integrity: The Council's internal "500-unit threshold" for new school provision is a local guideline that cannot supersede the national requirement to ensure that class sizes do not prejudice the quality of education. When a system reaches 100% capacity, adding any further load is a breach of operational integrity.

Primary School Capacity (2025/26 Data)
Dinas Powys Primary - At capacity 'in year' transfers have eliminated the previous 1.6% surplus.
St Andrews Major C/W - Oversubscribed. As a voluntary aided school, its 2026 waiting list is already active.

Secondary School Capacity (2025/26 Data)
Stanwell School - Overcapacity (surplus: -8).
St Cyres - Near capacity. Surplus concentrated in Year 11, not Year 7 entry.

see attachment for table/data.

Note: This development will effectively displace local children from their own village schools, forcing them to be "bussed" to other areas of the Vale—increasing traffic and destroying the community cohesion that village schools provide.
Demand for Transparency: We formally demand that the Council provides:
1. A Cumulative Education Impact Assessment: This must account for the combined pressure of Site SP4.2 alongside the 2,000+ homes at Barry Waterfront, which share the same secondary catchments.
2. Verification of Physical Capacity: The Council must identify the specific, physical location of the new desks required for these children.

The Myth of the "Walkable" Development Dinas Powys is a village by design and scale, not a town in waiting. Its retail "center" consists of a modest cluster of independent businesses and convenience stores that have already hit their absolute limit for logistical and parking capacity. While developers label the SP4.2 site as sustainable, the reality is a forced reliance on the car. Because the village has been stripped of its essential anchors in recent years—including the Post Office and NatWest bank—new residents cannot fulfill their daily needs within the village core.
• Mandatory Out-of-Village Trips: Every new household will be forced onto the road for banking, postal, and major retail/supermarket visitation.
• The A4055 Bottleneck: This creates a direct injection of traffic onto Cardiff Road, a corridor already documented as a high-congestion failure point.
Village Scale vs. Urban Expectation The loss of the bank and post office is the clearest indicator that Dinas Powys is contracting, not expanding into a functional urban hub.
• Logistical Deadlock: The tiny footprint of existing stores means they cannot accommodate the delivery or foot-traffic requirements of a 250+ household surge.
• Zero Parking Elasticity: There is no "spillover" parking. Every new car competing for a space at The Twyn is a deterrent to existing shoppers, leading to the economic strangulation of our last independent retailers.

By adding high-density housing without the civic infrastructure to support it, the development doesn't "grow" the village—it hollows it out. Dinas Powys is being transformed into a car-dependent dormitory, where residents sleep in the village but are forced to drive elsewhere to live, work, and shop.

The Section 106 Myth: A Legacy of "Phantom Mitigation" The Council often points to S106 developer contributions as a "cure-all". We reject this narrative as "Phantom Mitigation" because the village has already reached a physical "ceiling" that money cannot fix.
• Physical Impossibility: Even if the Council receives millions in S106 funds, you cannot buy your way out of a landlocked site. As documented, the Eastbrook Station Lift remains undeliverable due to topography, and previous Active Travel Schemes were rejected by the Council itself due to gradient constraints.
• The "Overbooking" Fallacy: Accepting money for a school or medical center that is already landlocked and at capacity is the planning equivalent of "overbooking" a flight with no seats available. It is a paper exercise that fails to provide a single extra desk or doctor's appointment in reality.
• Failure of Accountability (The Barry Waterfront Precedent): Our distrust is rooted in empirical local evidence. The Barry Waterfront development stands as a grim monument to broken promises.
o The Promise: A vibrant "District Centre," a community hub, and lush green public parks.
o The Bleak Reality (Status: 2026): Years after the developers extracted their profits, the "District Centre" remains a desolate, fenced-off gravel pit. The promised public spaces have been left abandoned and derelict.
o Structural Decay: The failure is so profound that as of today, major structural remediation is being performed on recently completed homes to fix fundamental build errors.

High-density housing delivered at speed, followed by a decade of stagnation, "unadopted" crumbling roads, and legal limbo.
• The Lesson: If the Council cannot hold developers to account on a flagship town-center site, it is a certainty they will fail to enforce complex requirements on the marginal and difficult land of SP4.2.

The Council Tax Trap: Revenue vs. Reality The claim that more houses equal "Better Services" is a fiscal fallacy. In Dinas Powys, more houses equal Infrastructure Liability.
• The "Service Dilution" Effect: New Council Tax revenue does not create "better" services; it dilutes existing ones. Every current resident will see a measurable decline in GP access and school choice as the "service-per-head" ratio drops.
• The Maintenance Sinking Fund: As evidenced by the October 2025 St Davids Avenue pipe failure, our Victorian infrastructure is at a breaking point.
• Subsidizing Failure: Additional Council Tax will not be used for "village enhancements". Instead, it will be swallowed by the massive costs of reactive, emergency repairs to a network pushed beyond its structural limits. The existing taxpayer is effectively being asked to subsidize the inevitable systemic collapse caused by this development.

We present these facts now so the Council understands that we see past the "fiscal illusions" of S106 and Council Tax. The village has reached its physical and fiscal limit. To push ahead in the face of this objective evidence is a deliberate choice to ignore the reality that "more money cannot fix 'no space'".

11. Procedural Error: The Internal Contradictions of the Developer "Vision" Neutrality of Evidence: The Council's heavy reliance on the Tir Collective "Vision" represents a significant procedural flaw. These documents are developer-funded pieces of advocacy designed to manufacture a veneer of "deliverability". By adopting a marketing document commissioned by parties with a vested financial interest as primary evidence, the Council has allowed Optimism Bias to undermine the neutrality of the Revised Local Development Plan (RLDP) process.

Evidence of Misleading Engagement (The Data Vacuum): The Council utilized this "Vision" to prematurely validate Site SP4.2 before independent, statutory assessments were complete:
• The October 2024 Murchfield Event: This "informal engagement" was conducted in a technical data vacuum. While the Council presented "vibrant" illustrations, it withheld its own March 2021 Arcadis technical data and the July 2024 statutory objection from the Council's Ecology Officer. This constitutes Information Asymmetry.
• Front-Loading the Preferred Strategy: By endorsing the "Preferred Strategy" in September 2024 based on promoter evidence, the Council effectively "pre-determined" the site's suitability, ignoring the 1:12+ gradients and flooding risks admitted in its own background WelTAG reports.

Refutation of Tir Collective Claims:
• The Roundabout Paradox: While the Vision claims a "modal shift" toward Active Travel, the Council's primary engineering evidence—the March 2021 Arcadis WelTAG Stage Two Plus Report—explicitly modeled the site access via a large-scale 4-arm arterial roundabout on the A4055. A 4-arm roundabout is a "capacity-driven" engineering solution for high-volume vehicular flow; its technical necessity is a de facto admission that Site SP4.2 is fundamentally car-dependent.
• The "15-Minute Neighbourhood" Fallacy: The report asserts the site follows 15-minute principles. This is a topographical impossibility. The Dinas Powys GI Statement and Arcadis surveys confirm steep 1:12+ gradients. For the elderly or those with limited mobility, the radius shrinks to zero, forcing car use and creating a fundamental breach of the Equality Act 2010.
• The "Green Infrastructure" (GI) Myth: The developer uses "Biodiversity Net Gain" as a buzzword. However, the land is a high-functioning "Green Wedge" carbon sink. Replacing this complex ecosystem with manicured suburban greenery and high-density street lighting creates an ecological "Dead Zone". It is a scientific impossibility to "enhance" a habitat by first destroying the ancient, protected hedgerow networks identified as significant baseline assets.
• The Hydro-Dynamic Reality: The GI Statement fails to account for the site's role as an "uphill soakaway". As proven by the October 2025 St Davids Avenue infrastructure failure, the ground is at a breaking point.
• The Rail Access Fallacy: Highlighting proximity to Eastbrook Station ignores that the station lacks step-free access to the Cardiff-bound platform. To present a site as "rail-led" when a significant segment of the population is physically and legally barred from using that connection is a material misrepresentation.

Conclusion: Procedural Impropriety It is procedurally unsound to utilize a developer's "marketing vision" to counter the Council's own admissions—specifically the Arcadis WelTAG and the Ecology Officer's 2024 objection.

We contend that the Tir Collective document should be stripped of its weight as evidence. It lacks technical rigor and serves only to obscure the documented breaking point of the Dinas Powys infrastructure.

12. The Developer's Strategy: Persimmon Homes and the "Standard Product" The primary driver of this proposal is Persimmon Homes' intent to deploy a "Standard Housing Product" on a site that is topographically hostile.
• The Topographical Mismatch: Persimmon's standard designs are engineered for flat or low-gradient sites. However, the Arcadis reports confirm gradients of 1:12+.
• Engineering vs. Environment: To force these standard units onto this terrain requires massive "cut and fill" engineering. By omitting detailed topographical cross-sections, the developer has presented a "flat-earth" model. This is physically impossible to construct without destroying the very "Green Infrastructure" they claim to protect, constituting a direct breach of LDP Policy SP1 (Sustainability).

The "Consultant Shield": Tir Consulting's Evidential Vacuum The developer has engaged Tir Consulting to provide a veneer of technical legitimacy. However, the Tir "Vision" document is a professional anomaly; it reaches absolute conclusions while relying on almost zero site-specific baseline data. Tir is acting less as an independent expert and more as a promotional arm, shielding Persimmon from the technical evidence provided by the Council's own specialists.

Systemic Failure to Address Material Constraints Tir Consulting has omitted critical data points required for a sound planning decision:
• Geotechnical Negligence: While claiming the site is "deliverable" for drainage, there is zero evidence of on-site borehole testing. Proposing high-density development on clay-heavy slopes, especially following the October 2025 St Davids Avenue infrastructure failure, ignores the Precautionary Principle.
• Infrastructure Capacity Deficit: Tir identifies Dinas Powys Primary School as a "viability asset" based solely on proximity. This ignores functional reality—the school is at capacity. This violates LDP Policy MD4, which requires infrastructure to be "adequate," not just "nearby".
• Direct Contradiction of Statutory Advice: It is a material failure for Tir to promote "Biodiversity Net Gain" while entirely ignoring the Chief Ecology Officer's formal objections.

Direct Quotes from the Chief Ecology Officer (July & November 2024):
• "An Ecological consultant has not been engaged and a Preliminary Ecological Assessment (PEA) not prepared as recommended by CIEEM and PPW12."
• "Damage to Ancient Semi-Natural Woodland and SINC [Site of Importance for Nature Conservation] has been undertaken in advance of the application."
• "Baseline of site has not been established... [the proposal results in] a disparate parcel of woodland that will not fit the wider woodland."
• The Verdict: "Recommendation for refusal [of the site] still stands."

Public Consultation: Manufactured Consent and Procedural Defect The Murchfield Community Centre Misrepresentations (18th Oct 2024) The public consultation process reached its lowest point of professional integrity during the meeting on Friday, 18th October 2024. For a consultation to be legally valid in the UK, it must satisfy the Gunning Principles. This meeting failed on every count:
1. Formative Stage: Proposals were already fixed to a rigid, unsuitable product.
2. Intelligent Consideration: Suppressing Arcadis data prevented an informed response.
3. Adequate Time: One evening is insufficient to debunk a complex narrative.
4. Conscientious Account: The Council cannot conscientiously rely on data that its own experts (Arcadis/Ecology) have already refuted.

The table below links the developer's promotional claims directly to the technical evidence that proves their delivery is physically or legally impossible.

1. Linear Green Park Spine
Key Design Principle (Presented at Murchfield): A green park acting as the central "spine" of the scheme.
The Evidence-Based Refutation (The Arcadis/Technical Reality): The Topographical Barrier: Arcadis data documents 1:12 gradients. A "linear park" cannot function as a usable spine without massive, ecologically destructive terracing and retaining walls.
Policy & Legal: PPW 12, Sec 3.3 (Good Design must be integrated with landscape).

2. Sustainable Transport Links
Key Design Principle (Presented at Murchfield): 10-minute walk to Eastbrook station via retained PRoW.
The Evidence-Based Refutation (The Arcadis/Technical Reality): The Accessibility Barrier: This 10-minute claim is a "flat-map" fallacy. For the elderly or mobility-impaired, a 1:12 gradient is a physical wall mandating car use and violating the sustainable travel hierarchy.
Policy & Legal: Equality Act 2010 & PPW Para 4.1.25 (Accessibility for all).

3. ‘Streets’ not ‘Roads’
Key Design Principle (Presented at Murchfield): Dedicated junction at Cardiff Road promoting walking and cycling.
The Evidence-Based Refutation (The Arcadis/Technical Reality): The Engineering Barrier: Arcadis WelTAG (2021) confirms this site requires a high-volume 4-arm arterial roundabout. Branding this as "streets" is a semantic attempt to mask heavy, car-centric highway engineering.
Policy & Legal: PPW 12 (Sustainable Transport Hierarchy).

4. Sustainable Urban Drainage (SuDS)
Key Design Principle (Presented at Murchfield): Rain gardens and swales to "green up" the streets.
The Evidence-Based Refutation (The Arcadis/Technical Reality): The Hydro-Dynamic Fallacy: SuDS on clay-heavy, saturated slopes is ineffective. Following the Oct 2025 infrastructure failure, the ground is proven to be at a tipping point; this approach will merely displace floodwater to existing homes.
Policy & Legal: Statutory SuDS Standards 2019 (Standard S1 - Runoff Destination).

5. Topographical Response
Key Design Principle (Presented at Murchfield): Development parcels will respond to the topography of the land.
The Evidence-Based Refutation (The Arcadis/Technical Reality): The Construction Reality: Persimmon's "Standard House Types" are flat-site products. To force them onto these slopes requires massive "cut and fill" engineering, which is the literal opposite of "responding to topography."
Policy & Legal: LDP Policy SP1 (Sustainability & Environmental Protection).

6. Robust Buffers
Key Design Principle (Presented at Murchfield): Parcels set back from historic tree belts and hedgerows.
The Evidence-Based Refutation (The Arcadis/Technical Reality): The Ecological Reality: Refuted by the July 2024 Ecology Officer Objection. These "buffers" are paper constructs that ignore the documented destruction of ancient hedgerow networks already undertaken on-site.
Policy & Legal: Environment (Wales) Act S.6 (Duty to enhance biodiversity).

A consultation based on technically inaccurate claims, such as those presented at the Murchfield Community Centre, is not a valid exercise in public engagement; it is manufactured consent. The Council is now on notice: to grant permission based on this "Vision" is to ignore the Environment (Wales) Act, the Gunning Principles, and the Council's own technical experts.

13. Irreparable Harm to the Green Wedge: Preventing Coalescence

Restorative vs. Destructive Development:
A fundamental planning distinction must be drawn between the "restorative" nature of brownfield development and the "destructive" impact of building on virgin Green Wedge land.
• Restorative (Barry Docks/Waterfront): Developing previously used land is a restorative act. It remediates industrial scars, revitalizes urban centers, and utilizes existing infrastructure.
• Destructive (Site SP4.2): Developing this "virgin" land—which has never been allocated for human habitation—is inherently destructive. Once this "Green Lung" is built upon, the biological and environmental loss is permanent and irreversible.

Violation of Policy MG18 and Cultural Identity
The narrow strip of land between Dinas Powys and Llandough is the primary factor maintaining the village's distinct identity. This Green Wedge was designated specifically because the risk of Dinas Powys being absorbed as a mere suburb of Cardiff is acute.
• Substantial Harm: Developing Site SP4.2 causes "substantial harm" to the openness of the landscape, violating the very purpose of the Green Wedge designation.
• Administrative Erasure: This proposal represents the administrative erasure of the village boundary, signaling the beginning of the end for Dinas Powys as a standalone settlement.
• Policy Breach: The resulting coalescence with Llandough and the wider Cardiff urban area is irretrievable. This constitutes a direct breach of Policy MG18 of the Council's existing Local Development Plan (LDP).

Data-Driven Evidence: Public Support for Restorative Growth
Public opinion across the Vale confirms that residents support growth when it is restorative rather than destructive. The Council is currently overlooking high-potential Barry sites despite clear community backing for urban regeneration:

Site / Project | Nature of Development | Community Support (RLDP 2025 Data) |

Neptune Road (Barry) | Restorative (Brownfield) | Supported. 14 in favor / 11 against. |
• Failure of the Sequential Test: The Council has bypassed high-potential, restorative brownfield sites—such as The Mole and Barry Docks—in favor of "plug-and-play" virgin greenfield land. This is a rejection of the "Brownfield First" principle central to sustainable planning logic.
• Equality Act and "Active Travel" Dishonesty: Proposing "sustainable" links that are topographically impassable for the disabled and the elderly is a breach of the Equality Act 2010. The Council's simultaneous modeling of a high-capacity 4-arm roundabout on the A4055 is a de facto admission that the developers' "Active Travel Vision" is a marketing facade for a 100% car-dependent enclave.

Statutory Legal Vulnerability: Beyond local planning policy, this allocation creates an unacceptable legal risk for the Council. Given the documented evidence of air quality breaches and ecological sensitivity, a decision to proceed would fail the Precautionary Principle under Welsh Environmental Law. Furthermore, the reliance on topographically impossible "Active Travel" routes constitutes a breach of the Section 149 Public Sector Equality Duty (Equality Act 2010). Any approval based on the current flawed evidence base would be Wednesbury unreasonable and susceptible to formal legal challenge via Judicial Review.

The "Overbooking" of Infrastructure: The Council's own WelTAG Stage Two Plus reports admit that traffic growth is already outstripping available investment. To ignore this data is a failure of leadership. Relying on Section 106 "Phantom Mitigation" for landlocked, over-capacity schools is a logistical impossibility. You cannot "buy" your way out of a lack of physical space.

A Final Plea: Planning for People, Not Prototypes: We are under no illusions; we know that some of these claims carry more weight than others. We know that the Council may attempt to "bureaucratically sprawl" all over this objection, burying our technical concerns under layers of administrative justification. But we ask you to see the finer point: the opposition to this is rife because people are rightly concerned. This is not a community that reflexively says "no" to growth. Our history proves it. We fully supported the development of Scholar Park—the former St Cyres School site. That project is the perfect example of the "restorative" planning we advocate for; it took a previously developed site and reinvigorated it so that the community could actually benefit.

People understand the need for housing, but Site SP4.2 is simply not right. It is "one step too far." There is a restorative logic to building on the footprints of the past, as seen at Scholar Park, but there is only permanent destruction in building upon the "Green Lung" of our future.

Formal Request for Removal: We formally request the immediate removal of Site SP4.2 from the RLDP. This land must remain a protected Green Wedge. The developer's "Vision" represents a profound logical and ecological contradiction; it claims to "enhance" a sensitive habitat only after its wholesale destruction, while proposing 'integration' through a car-centric model that ignores the physical reality of the site.

Dinas Powys will not stand by while it is transformed into a congested, underserviced, and polluted dormitory. The Council must fulfill its democratic and statutory duty by prioritizing the restoration of our towns over the permanent destruction of our Green Wedge.

The development proposed on a "green corridor" site that is known to regularly flood, is highly inappropriate. The impact on nature, wildlife and local residents makes it obvious this is a poor choice. Furthermore, the already choked up Cardiff Road is not fit for nor designed for all extra traffic that comes with such developments. More tailbacks, more pollution, longer journey times. If this development goes ahead, sets a precedent that remaining surrounding green areas be developed which will have a huge impact on the quality and enjoyments for all Dinas Powys residents-an impact that will change this community forever. Please don't do it.