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ID sylw: 107267

Derbyniwyd: 07/03/2025

Ymatebydd: Cotswolds National Landscape Board

As outlined above, the Cotswolds National Landscape (CNL) Board:
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does not broadly support the proposals relating to Draft Policy Directions 1,2 or 4 or the proposals relating to Strategic Growth Location 17.
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does broadly support the proposals relating to Draft Policy Directions 3, 5 and 6.
There are some additional proposals in Chapter 4 that we do not broadly support, as outlined below.
Windfall allowance
Firstly, we are concerned about the proportion of the overall housing need that the Councils anticipate being met by a ‘windfall allowance’ (i.e. sites that are not allocated in the Local Plan). Table 3 indicates that 9,375 dwellings out of the 54,700 that are needed over the plan period will be provided via a windfall allowance (i.e. 17%). When existing commitments (17,068 dwellings) are taken out of the equation, the windfall allowance makes up 25% of the remaining housing need. This seems like a high percentage, particularly given that there are supposedly more sites currently in consideration than the Councils will actually need to meet the identified housing need.
Paragraph 75 of the NPPF states that:
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Where an allowance is to be made for windfall sites as part of anticipated supply, there should be compelling evidence that they will provide a reliable source of supply. Any allowance should be realistic having regard to the strategic housing land availability assessment, historic windfall delivery rates and expected future trends.13
If there are more sites in consideration than the Council will actually need then, presumably, the Councils could set a lower windfall allowance percentage.
Priority Area buffer zones
Secondly, we are concerned about the way that Priority Area ‘buffer zones’ are shown in Figure 5 (Spatial Growth Strategy Priority Areas). For example, the Meon Vale area is identified as being a Priority Area 1 zone. This Priority Area 1 zone is surrounded by a Priority Area 2 buffer zone, which extends into the CNL and includes the CNL settlement of Upper Quinton. In the Board’s opinion, the CNL should not be included within this buffer zone, not least because National Landscapes ‘are unlikely to be suitable areas for accommodating unmet needs from adjoining (non-designated) areas’. The same principle applies to the Priority Area 3 buffer zone around Moreton-in-Marsh, which extends into the CNL, including the CNL settlement of Barton-on-the-Heath. We consider that the mapping of the Priority Area buffer zones should be more nuanced to take account of this by not extending these buffer zones into the CNL.