BASE HEADER

No

ID sylw: 107261

Derbyniwyd: 07/03/2025

Ymatebydd: Cotswolds National Landscape Board

The CNL should not be expected to accommodate these growth needs.

The Board acknowledges that it is appropriate for the South Warwickshire Councils to give consideration to accommodating unmet needs arising from outside South Warwickshire. However, the approach taken by Draft Policy Direction 4 is, in the Board’s opinion, too permissive.
Paragraph 36 of the National Planning Policy Framework (NPPF) states, inter alia, that:
•
Plans are ‘sound’ if they are:
a)
Positively prepared … informed by agreements with other authorities, so that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development.10 (N.B. Added for emphasis).
We recommend that the underlined text should be reflected in Draft Policy Direction 4. In other words, the South Warwickshire Councils should only give consideration to accommodating unmet needs arising from outside South Warwickshire if it is practical to do so and if it is consistent with achieving sustainable development. This should include consideration of paragraphs 11b and 11d of the NPPF, which set out the circumstances in which objectively assessed needs (OAN) do not have to be met in full.
The Government’s Planning Practice Guidance on the Natural Environment states that National Landscapes ‘are unlikely to be suitable areas for accommodating unmet needs from neighbouring (non-designated) areas’.11 Policy CE15 of the CNL Management Plan expands on this by stating that ‘in the context of the CNL, this includes unmet needs relating to adjacent urban areas and unmet needs arising in local authority areas that do not overlap with the CNL’.12 In this context, it would not be appropriate to release reserve sites in the CNL on the basis of accommodating unmet needs from neighbouring local authority areas. This should be made explicit in Draft Policy Direction 4.