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ID sylw: 107067

Derbyniwyd: 07/03/2025

Ymatebydd: Cotswolds National Landscape Board

Over-riding concerns
The Board’s primary concern relates to Draft Policy Direction 1 (Meeting South Warwickshire’s Sustainable Development Needs).
Our concern is that there is not sufficient evidence or clarity to be able to identify whether the aspiration to meet the South Warwickshire’s objectively assessed needs (OAN) can be achieved without harming assets of particular importance, including the CNL. If meeting the area’s OAN cannot be achieved without causing harm to the natural beauty of the CNL, consideration should be given to setting a housing requirement figure that is lower than the housing need figure identified in the Government’s ‘standard method’.
This issue is complicated by three main factors, as outlined below.
Firstly, there is some ambiguity regarding exactly what OAN the SWLP is seeking to accommodate. For example, the SWLP states that provision will be made for at least the quantum of development identified in the Councils’ Housing and Economic Development Needs Assessment (HEDNA). However, it then goes on to say that that there will be ‘sufficient flexibility’ to accommodate the ‘standard method’ figure (which is significantly larger). As such, it sets two differing targets. If the intention is to accommodate the ‘standard method’ figure then this should be stated in a way that is unambiguously explicit and direct.
Secondly, there is considerable ambiguity regarding exactly which sites the South Warwickshire Councils intend to allocate for housing and other development. Some sites have been sifted out through the Housing and Economic Land Availability Assessment (HELAA) process. However, as we understand it, there are still far more sites currently in consideration than the Councils anticipate actually allocating.
Thirdly, through the HELAA process, the Councils have sifted out all sites that are located entirely within the CNL. This includes some sites that are allocated (or identified as reserve sites) in the relevant Neighbourhood Plan but have not yet been developed. We do not agree with the principle of sifting out potential allocations on the basis of being located 100% within the CNL. This is because, as outlined above, we recognise that a limited degree of development within the CNL may be appropriate in order to retain thriving and vibrant local communities. Therefore, we have reviewed and assessed nearly all of the sites within the CNL that have been sifted out through the HELAA process.
For some of these sites, we have recommended that they should remain in consideration, rather than being sifted out. As such, we are taking the unusual step of advocating a less restrictive approach to development in the CNL than the local authorities have proposed.
Conversely, there are a number of very large sites that overlap with the CNL boundary that have not been sifted out in the HELAA process. The Councils have indicated that such sites are unlikely to be allocated. However, given that they are still in consideration at this stage, it has still been necessary for the Board to review and assess them. We have recommended that all of these larger sites that overlap with the CNL boundary should not be taken forward (at least with regards to the CNL sections).