We appreciate the necessity to generating a Settlement Hierarchy and the need to ensure development is controlled in a manner suitable for each level within that. However, we would suggest the conflicts this generates with the overarching Objectives in respect of Sustainable Communities, the Wellbeing of the older and young persons and the wishes of the local communities, can be relatively simply addressed by either:
1. Providing a defined settlement boundary for ALL settlements including ‘Hamlets and Smaller Rural Settlements’
The proposed planning polices and constraints notably those in SSC1 and HG5 could then be applied across all existing settlements and communities to allow for appropriate development of affordable homes to meet the aspirations of Para 5.24 and the local Community.

OBSERVATIONS
a. The Council notes that there are now NO New Housing Developments Sites shown in
the Deposit RLDP for the Penllyn Community Council area, although Ystradowen, Penllyn
and Craig Penllyn are defined as ‘Minor Rural Settlement Areas’ and would therefore
appear to come within the scope of the of SSC1 and HG5 for infill and affordable housing.
b. However, the remainder of our rural communities are classed as ‘Hamlets and Smaller
Rural Settlements’, have no defined settlement boundaries and for the purposes of
Planning Policies are therefore regarded as ‘Countryside’.
c. The Deposit RLDP includes over 40 references [see Appendix 1] which include within
the stated Strategic Objectives and other statements, recognition of the housing needs of
All rural Communities including Hamlets and Smaller Rural Communities and reflects:
i) The need to support to maintain such Communities and to promote the appropriately
scaled, affordable development required by such communities to maintain a
sustainable demographic balance.
ii) The need to provide appropriate housing within all such rural communities to meet the
material needs and wellbeing of both young families and elderly residents.
d. Despite these stated Objectives and supporting comments noted at e above, the
proposed Planning Policies set out in the RLDP, particularly those in relation to
Development in the Countryside, not only fail to address the requirement/provision of
community supported, single unit/ micro developments of appropriate affordable
housing, necessary to meet the acknowledged rural need, but in fact actively
discriminate against such development outside settlement boundaries.
e. The RLDP thereby excluding some 54 of the 75 Rural Communities within the defined
area from effectively address this critical socio-economic issue in a manner which has
been historically shown to be not only acceptable but actively welcomed by the vast
majority of residents of these hamlets and smaller rural communities.
f. The existing LDP Rural Exception Site Policy and Policy MD10 Affordable Housing
Developments Outside Settlement Boundaries provide that:
Small scale affordable housing developments will be permitted outside settlement
boundaries where they have a distinct physical or visual relationship with an existing
settlement and where it is demonstrated that:
1. The proposal meets an identified local need which cannot be satisfied within identified
settlement boundaries.
2. The number of dwellings is in proportion to the size of the settlement.
3. The proposed dwelling(s) will be of a size, tenure and design which is
commensurate with the affordable housing need.
4. In cases where the dwelling is to be provided by either a private landlord
or the intended occupier, secure mechanisms are in place to ensure the
property shall remain affordable in perpetuity; and
5. The development has reasonable access to the availability and proximity
of local community services and facilities.
However, the Policies within this RLDP particularly SSC1 and HG5 appear to effectively
remove this exception from Hamlets and Smaller rural Settlements without settlement
boundaries thereby preventing essential socially necessary development within some 54
of the Vales rural communities.
g. It is noted that much of this conflict between ‘Objective and Result’, stems from the
focus given to Settlement Boundaries within the RLDP. In the document these are only
defined for ‘Minor Rural Settlements Areas’ and not for settlements classed as ‘Hamlets
and Smaller Rural Settlements’.
h. These classifications arise out of the SETTLEMENT APPRAISAL REVIEW [BP5] which
provides an effective rational methodology for a hierarchy of settlement. However, such
an appraisal is defined by the many subjective factors, not least the way in which it
divides settlements eg City and Llansnnor.
The Appraisal Report itself recognises the limitations of this approach in for example
paras: 12.8.5 and particularly 12.8.6 below:
12.8.5 In this respect it is important to note that the use of scoring and ranking
methods means that certain socio-economic and environmental factors, which are
important in understanding the overall role, function and sustainability of a settlement,
are not fully considered by this study. These are generally factors where it is difficult to
attribute a numerical value. Furthermore, it is important to recognise that one of the
limitations of using scoring and ranking methods is that certain assumptions and
generalisations are invariably used, for example, regarding residents travel to work
patterns and the actual use of sustainable transport modes.
12.8.6 Therefore, a strategic assessment such as this one is not intended to be a
comprehensive planning assessment of individual settlements or potential
development sites within them. Such detailed planning assessments would need to
consider the environmental, social and economic issues affecting specific
settlements. Decisions on levels of growth and individual proposals will be made as
informed planning judgements having considered all other relevant factors.

i. Consequently The Deposited RLDP as it stands neither: designates Settlement
Boundaries to allow the relevant proposed Planning Policies to be implemented within
these smaller rural Settlements/ Communities; nor does it provide specific Planning
Policy/ mechanisms for the provision of managed, Community supported, appropriately
scaled, single unit /micro (1-3 units) developments of the affordable housing, suitable for
younger families and older residents, necessary to maintain balanced and sustainable
Communities in such rural settlements.
By failing to include either or both of the above, the Plan fails to meet its own specific
Strategic Objectives set out in the document and therefore also fails to properly address
the requirements of the Well-being of Future Generations Act (Wales) 2015 (Well-Being
Act)

Provide additional or amended Planning policies [either free standing or within SP3 or HG5] to allow for single unit/micro development, by companies or individuals, of
appropriate, affordable housing units within all communities including ‘Hamlets and Smaller Rural Settlements’ [in the Countryside] where this is supported by the local community and meets the requirements of SSC1.

These new/amended policy statements [alongside the existing requirements of SSC1 and HG5] could then be applied across all existing settlements and communities
currently classified as undefined ‘Hamlets and Smaller Rural Settlements’ and hence ‘Countryside’ to allow for controlled appropriate development of affordable homes to
meet the aspirations of Para 5.24. and the local Community.

Provide additional or amended Planning policies [either free standing or within SP3 or HG5] to allow for single unit/micro development, by companies or individuals, of
appropriate, affordable housing units within all communities including ‘Hamlets and Smaller Rural Settlements’ [in the Countryside] where this is supported by the local community and meets the requirements of SSC1.

These new/amended policy statements [alongside the existing requirements of SSC1 and HG5] could then be applied across all existing settlements and communities
currently classified as undefined ‘Hamlets and Smaller Rural Settlements’ and hence ‘Countryside’ to allow for controlled appropriate development of affordable homes to
meet the aspirations of Para 5.24. and the local Community.

Provide additional or amended Planning policies [either free standing or within SP3 or HG5] to allow for single unit/micro development, by companies or individuals, of
appropriate, affordable housing units within all communities including ‘Hamlets and Smaller Rural Settlements’ [in the Countryside] where this is supported by the local community and meets the requirements of SSC1. These new/amended policy statements [alongside the existing requirements of SSC1 and HG5] could then be applied across all existing settlements and communities currently classified as undefined ‘Hamlets and Smaller Rural Settlements’ and hence ‘Countryside’ to allow for controlled appropriate development of affordable homes to meet the aspirations of Para 5.24. and the local Community.

Amend paragraph 3.11

Summary: 3.11 The lowest tier consists of 54 hamlets and smaller rural settlements of the Vale. These are largely comprised of either a small group of dwellings or more sporadic/ dispersed and loose knit groups of residential properties…

THE DESCRIPTION IN THIS PARAGRAPH IS INCOMPLETE/ INACCURATE IN THAT IT FAILS TO ACKNOWLEDGE THAT MANY OF THESE SETTLEMENTS, ALTHOUGH SMALLER, ARE DISTINCT COMMUNITIES WITH FACILITIES SUCH AS CHURCHES, COMMUNITY HALLS., PUBS AND SCHOOLS EQUIVALENT TO THOSE IN THE MINOR RURAL SETTLEMENTS CATEGORY.
THE POPULATION/SIZE IS OFTEN ARTIFICIALLY REDUCED IN THE REVIEW BY DELIBERATELY DIVIDING ADJACENT SETTLEMENTS WHICH EFFECTIVELY WORK AS ONE COMMUNITY EG CITY AND LLANSANNOR.