2 Dogfennau Ategol
Chwilio sylwadau
Canlyniadau chwilio Barry & Vale Friends of the Earth
Chwilio o’r newyddGwrthwynebu
2 Dogfennau Ategol
BP21 De-ddwyrain Cymru – Asesiad Strategol o Ganlyniadau Llifogydd (Cam 1)
ID sylw: 6240
Derbyniwyd: 11/03/2026
Respondent ID: 708
Ymatebydd: Barry & Vale Friends of the Earth
Asiant : Barry & Vale Friends of the Earth
The statutory Section 19 report on the 23 Dec2020 flooding of about 100 properties included recommendations that have been ignored, relating to blockage during high river levels of highway drains from central streets and of the Cae'r Odyn's newer street drains.
The Strategic Flood Consequences Assessment omits mention of that flood episode (1:20yr rainstorm) and omits mention of the need for measures to cope with stronger rainstorms(1:100). We guess that omission was not due to the consultant JPA who has professional standards to maintain, but to the LPA or RLDP team. Whichever, it fails to comply with
3.4 The SFCA is a desk-based study which collates existing information to undertake a broad assessment of potential flood risks across the study area, including the Vale of Glamorgan, from all sources of flooding. The study identifies areas at potential high risk from flooding, provides details of historical flood events, and detail of any flood risk management structures or procedures present.
The SFCA fails to mention the Dec.2020 flooding, the 2021 Section 19 report on it with unfulfilled recommendations and NRW’s conclusion from ~2018 to not proceed with dam/holding reservoir upstream but “working with nature” with catchment measures. JPA Consulting wrote both the Section 19 report and this SFCA. It’s likely not JPA but the RLDP team omitted this important information, because of their interest in promoting the site for housing. Whichever, the SFCA is a statutory document that requires completing to professional standard.
The SFCA does identify priority areas for natural flood management. In this regard, the SFCA (9.3.6.10) identifies small areas across the Vale that are suitable for runoff attenuation and large portions of the Vale that are suitable for wider catchment woodland planting… (Appendix J1 of the SFCA). We find a map on p.153 Working with Natural Processes - Potential Mapping (JPA + VoG Dec.2021) show Woodland Planting on this hillside, including part of the Persimmon site.
The fields below Llandough Hospital are an important part of the East Brook catchment. Drainage from the Hospital discharging into the East Brook (via settlement tanks) increased over the last decade by large area carparking and building developments.
The development site and adjacent hillside fields are a significant holding area for rainstorms, soakaway being slow. Housing development with normal SuDS measures with “attenuation ponds” will speed up storm-discharges. The issue is not as the KS2 spec says Small area <5% affected by river flooding, but the the downstream consequencies of the development in flooding at the Murch cross-road and adding to the river Cadoxton just downstream.
The applicant has no given any study to include measures to trap the stormwater in holding ponds, or otherwise to increase delays to it reaching the East Brook. He has concealed the proposal for woodland planting on part of the site as the SFCA map indicates.
The strong flooding constraint is also being hidden by the RLDP people, if it’s they who have censored important material from the JPA report.
We require a revised statutory SFCA is issued to professional standard which properly includes both the 2021 Section 19 report and proposals for forward policy towards flooding measures for Dinas Powys itself. These would be oriented to “working with nature” as agreed, and recognize that the Eastbrook housing development goes in the wrong direction. They would also record the need to divert highway drainage from discharges into the Cadoxton as per the Section 19 recommendations.
Safeguarding against flooding has to be the priority for any development in Dinas Powys. The strategic Flood Assessment report's omission of setting such a requirement is unacceptable. The Section 19 report on the 23 Dec2020 flooding of about 100 properties produced recommendations that have been ignored, relating to blockage during high river levels of highway drains from central streets and of the Cae'r Odyn's newer street drains. The omission of that flood episode (1:20yr rainstorm) and reporting need for measures to cope with stronger rainstorms(1:100) seems not due to the consultant JPA but to the LPA or RLDP team.
Gwrthwynebu
2 Dogfennau Ategol
BP44 Cynllun Seilwaith
ID sylw: 6799
Derbyniwyd: 06/03/2026
Respondent ID: 708
Ymatebydd: Barry & Vale Friends of the Earth
Asiant : Barry & Vale Friends of the Earth
The Infrastructure Plan falls short of detailing the new sewerage infrastructure central to unlocking the development of allocated sites stated in para.i Para. 3.104 mentions SuDS to prevent surface water entering the sewer system, but nothing on WW's strategic plan for local authority schemes to divert existing highway drainage into surface water out of their sewers.
Para.3.105 says the obvious that capacity may not exist within the existing sewerage network, but does not include sewage treatment capacity and does not specify where it's lacking. There's a comment for NW Barry that pumping capacity "may"not exist.
Para.3.108 says capacity constraints at treatment works and improvements as being in the current AMP or not, so why not be specific on the programme to 2030 ?
We see no mention of the Vale's Bathing beaches (several new ones) and policy to ensure sewage discharges do not undermine attaining Bathing Water standards; does this issue not belong in the RLDP, setting out divided responsibilities of VoG, NRW and DCWW (cf. Watchtower and Ogmore-by-Sea beaches closed 2024,5)?
Thank you for signposting me to the Infrastructure Delivery document. I see this falls short of detailing the new sewerage infrastructure central to unlocking the development of allocated sites stated in para.i
Para. 3.104 mentions SuDS to prevent surface water entering the sewer system, but nothing on WW's strategic plan for local authority schemes to divert existing highway drainage into surface water out of their sewers.
Para.3.105 says the obvious that capacity may not exist within the existing sewerage network, but does not include sewage treatment capacity and does not specify where it's lacking. There's a comment for NW Barry that pumping capacity "may"not exist.
Para.3.108 says capacity constraints at treatment works and improvements as being in the current AMP or not, so why not be specific on the programme to 2030 ?
We see no mention of the Vale's Bathing beaches (several new ones) and policy to ensure sewage discharges do not undermine attaining Bathing Water standards; does this issue not belong in the RLDP, setting out divided responsibilities of VoG, NRW and DCWW (cf. Watchtower and Ogmore-by-Sea beaches closed 2024,5)?
On specifics, KS4 and KS5 say of capacity limits at West Aberthaw works that "DCWW has confirmed that upgrades are planned as part of the AMP8 programme 2025 and 2030". Can you provide documents on this?
WW said in 2015 they "planned" upgrades so questions are obvious - is the W.Aberthaw upgrade still not programmed and committed? Are the plans sufficient to take the much bigger numbers of homes now planned. Will land purchase and planning consent be needed? Will the developers proposing local sites have to pay via S.106?
On Model Farm, WW said the developer would have to undertake a sewerage HMA which L&G have been unwilling to progress, doubtless because their Viability Assessment showed the development was uneconomic. Such an HMA may show the need for sewer links across unexplored land, possibly uncovering archaeological constraints, causing delays of several years.
It seems you have not followed Council's Methodology based on the Development Plans Manual
to require this developer to reappraise existing LDP site allocations without extant planning permission through the candidate site assessment process.
I don't see that the Employment Land Study indicating (3.1) Model Farm to be a "realistic development proposal" over-rides the DPM guidance on examining viability constraints, so is this decision documented, please ?
In view of the response deadline, we look forward to a timely response. We'd ask that you consider the above omissions, deem that a firm Statement of Common Ground with DCWW similar to that of 2015 is required at this stage, and issue amendments to this draft RLDP to cover them.
