Cyngor Bro Morgannwg
Vale of Glamorgan Council

In summary the current settlement boundary of Fferm Goch is questioned under Policy SP2 Settlement Strategy. A revision to the minor rural settlement boundary of Fferm Goch is therefore proposed to allow the settlement boundary to follow criterion as set out in BP46; Settlement Boundary Review. The proposed change would allow the plan and meet the tests of soundness.
The test of soundness for a Local Development Plan (LDP) is a critical component of the
planning process to ensure that the plan is prepared in accordance with legal and procedural
requirements. It involves demonstrating that the plan is 'sound' based on three tests set out by the Welsh Government in the Development Plans Manual (Edition 3). These tests have therefore been considered in our responses and include:
•
Fit: Ensuring the plan is consistent with other plans, national policy, and relevant
objectives.
•
Appropriateness: Confirming that the plan is appropriate for the area based on
evidence.
•
Deliverability: Ensuring the plan is likely to be effective. The soundness of the LDP is assessed through a selfassessment by the Local Planning Authority (LPA) and then by an independent inspector.
SP2 Settlement Strategy and BP46 Settlement boundary Review Within BP 46 it is stated that the settlement boundaries separate the defined built up areas from the open countryside and are essential for managing development. The LDP aims to focus development within existing urban areas and restrict the scope of development in the countryside. The settlement boundaries are drawn to indicate where development is and is not considered acceptable albeit other material considerations will need to be considered. Planning Policy Wales (Edition 12 February 2024) (PPW) states: ‘Planning authorities must prioritise the use of suitable and sustainable underutilised land and/or underutilised sites for all types of development and that when identifying sites in development plans, planning authorities should consider previously developed land and/or underutilised sites located within existing settlements in the first instance with sites on the edge of settlements considered at the next stage (para 3.43). The document goes on to state: ‘Settlement boundaries play an important role in ensuring the delivery of sustainable development by encouraging development within the sustainable settlements. They also assist in protecting the surrounding undeveloped countryside from inappropriate development, in line with national planning policy by delineating the extent of built development. With regard to the settlement boundaries BP46 states : ‘The delineation of settlement boundaries therefore helps to support and reinforce the delivery of the Plan’s objectives and strategy and provides a key policy mechanism for managing growth within the Vale of Glamorgan’. The purpose of settlement boundaries is to protect the countryside beyond and to delineate the extent of built developments. It is understood land located to the outside of the settlement boundaries will then be considered as countryside for planning purposes and treated as such in decision making. PPW confirms the national position on development outside of settlements and states: ‘Development in the countryside should be located within and adjoining those settlements where it can best be accommodated in terms of infrastructure, access, habitat and landscape conservation. Infilling or minor extensions to existing settlements may be acceptable, in particular where they meet a local need for affordable housing or it can be demonstrated that the proposal will increase local economic activity. However, new building in the open countryside away from existing settlements or areas allocated for development in development plans must continue to be strictly controlled. All new development should be of a scale and design that respects the character of the surrounding area.’ ( Paragraph 3.60) BP46 Settlement Boundary Review, paragraph 3.5 and 3.6 sets out a methodology as follows: 3.6 Using these methods, the following methodology was followed:
• 1A Review the existing settlement boundaries for any anomalies.
• 1B Review the existing settlement boundaries to ensure that they logically follow building curtilages, where these have a functional relationship with existing dwellings.
• 1C Identify development completed since the 2016 Review adjacent to settlement boundaries.
• 1D Identify extant planning permission for housing or other appropriate built development adjacent to settlement boundaries.
• 1E Examine land uses immediately adjacent to the existing settlement boundaries and consider whether they lend themselves to being included within the settlement.
• 1F Ensure that the settlement boundary is drawn to logical defensible boundaries It is noted that the Fferm Goch settlement boundary has been amended from the position in the adopted LDP. The settlement boundary now includes:
• the parcel of land allocated for the affordable housing led site (HG4(4), Supported.
• the existing employment site of West Winds Business Park, Supported.
• the new housing to the south (Cwrt Canna), Supported.
• Llangan Primary school, Supported. Support is given to the changes to the settlement boundary to accommodate the RLDP allocation for rural led affordable housing (HG4(4), also for the inclusion of Westwinds business park and the immediate area to the south, some of which comprises brown field land. Support is also given to the inclusion of Cwrt Canna and Llangan Primary school all within the settlement boundary. Objection however is made, with particular reference to stated methodology 1 E and 1F of BP46 Settlement Boundary Review, in regard to the settlement boundary for the west of Fferm Goch where a parcel of circa 0.16 ha has been excluded from what would appear a logical inclusion in the settlement boundary. The reasons for the objection are stated below. The parcel of land that sits to the west of Cherry Acre should also brought in to the settlement boundary (Policy SP2 Settlement Strategy) for the following reasons: The inclusion is Logical in respect of the existing linear settlement pattern to both the north and south of the parcel in question. The exclusion of the parcel appears incongruous when viewed in the context of the rest of the Fferm Goch Settlement ( see Plan below of blue line of proposed settlement boundary), particularly in view of the north western edge of the proposed settlement limit.
VOG RLDP proposed settlement boundary at Fferm Goch The 1.6 ha plot is deemed suitable for inclusion as it lies immediately adjacent to developed areas including a domestic dwelling to the east, West Winds Business Park to the north and a stable development to the west. Furthermore an adopted highway sits immediately to the south of the site together with the recently developed Cwrt Canna housing development (this recent development overlooks the parcel of land see photos below) on the other side of the road and Llangan Primary school located immediately south of Cwrt Canna.

Six images.
Given the surrounding development, comprising residential, B1/B2 Employment, on 3 sides of the parcel, it clearly represents an infill site that lends itself to round off the Fferm Goch settlement in a logical manner. The inclusion of the parcel within the settlement boundary would follow the defensible boundaries of the historic field pattern and consistent hedgeline to the west, and the adopted highway to the south and therefore would not propose back land development. The inclusion of the parcel is considered in line with the RLDP strategy and the methodology of BP46 criterion 1F, ensuing that the settlement boundary is drawn to logical defensible boundaries.
As drawn the exclusion of the parcel in question appears arbitrary as it follows the wooden fence to the north, the domestic curtilage of Cherry Acre to the east (a residential house developed in the 1980s), rather than the historic field boundary to the west and adopted highway to the south. The photos attached show the parcel to display characteristics that are not necessarily associated with open countryside and are clearly longstanding in terms of regular maintenance of the improved grassland and semi mature non native tree planting that is regimented rather than sporadic or organic in nature.
It is acknowledged that the parcel sits within the SLA however it is not widely visible given the existing development on 3 sides of the parcel (plus that of the allocation HG4(4) to the north). Designation as SLA does not preclude its inclusion within the settlement boundary and should development be sought in the future then it would need to be clearly proven that any development permitted would have no unacceptable harm on the important landscape characteristics of the area (BP 28 Special Landscape Areas: Upper and Lower Thaw Valley).
It is therefore proposed that the Fferm Goch settlement boundary is revised to include the small parcel to the west ( located between the stable and Cherry Acre) that is currently shown outside of the settlement boundary. This proposal is a logical and consistent inclusion, especially when viewed in the context of the linear settlement of Fferm Goch and would allow for a small windfall opportunity in the future of a commensurate scale to the settlement. Small windfall sites are critical in sustaining the vitality of minor rural settlements and supporting community cohesion and infrastructure such as the Community hall, sport pitch, equipped play area and Llangan primary school.
The minor adjustment to the settlement boundary would allow all the methodology of BP46Settlement Boundary Review to be applied and Test 2 of the Test of Soundness to be met in terms of ‘appropriateness’ and confirmation that the plan is appropriate for the area based on evidence.