BASE HEADER

Yes

ID sylw: 107284

Derbyniwyd: 07/03/2025

Ymatebydd: Cotswolds National Landscape Board

Summary of Brailes sites
There are nine sites at Lower Brailes, all of which have been sifted out in Stage A of the HELAA process.
For seven of these nine sites, the only reason for being sifted out in the HELAA A assessment is because they are 100% within the CNL. One of the other sites, RefID 706 should have been sifted out because it is 100% within the CNL, rather than because of being in flood zones 2 or 3 (which it is not). The only site that had a valid additional reason for being sifted out is RefID 413 which was sifted out both because it is 100% within the CNL and because of the site location.
So, overall, there are, in effect, eight sites where the only valid reason for them being sifted out in Stage A of the HELAA A process is because they are 100% located within the CNL. As outlined above, the Board does not agree with the principle of sites being sifted out because they are located entirely within in the CNL. As such, we have included them in our assessment.

[table provided in rep]

Additional considerations
Lower Brailes is primarily located within Landscape Character Type (LCT) 19 (Unwooded Vale).114 The CNL Landscape Strategy & Guidelines for LCT 19 states that the sparsely settled and deeply rural Unwooded Vale landscape type is highly sensitivity to change. Despite this, even in rural areas, the screening effects of landform, farm woodlands, hedgerows and shelterbelts provide a framework in which some opportunities for small-scale development exist.
The eastern end of Lower Brailes extends into LCT 6 (Ironstone Hills and Valleys)115 and Upper Brailes is mainly located in LCT 1 (Escarpment Outliers)116. There are multiple Public Rights of Way (PROW) in these LCTs, particularly to the south of Lower Brailes, which overlook the settlement. The views that are experienced from these LCTs are one of their key features / characteristics. The CNL Landscape Strategy & Guidelines for LCT 19 states that vale landscapes bordering upland areas with wide vantage points, such as the Escarpment Outliers, are particularly sensitive to the effects of large-scale built development.
Any further assessments should have regard to the key features / characteristics of LCTs 1,6 and 19 and should factor in the landscape sensitivity considerations outlined above.
Conclusions
Sites 849, 850 and 851 are already allocated housing sites (and are the only allocated sites) in the Brailes Neighbourhood Plan. Presumably this will be reflected in the Local Plan in some way.117 The allocated sites would already increase the number of dwellings in Brailes parish by 7.5%, which is above the Board’s 5% ‘rule of thumb’ threshold for proportionality. We recommend that, ideally, no additional sites should be allocated.
We acknowledge that the Neighbourhood Plan runs to 2031, whereas the Local Plan would run to 2050. We also acknowledge that Brailes is a Category 2 Local Service Village, Therefore, if there were exceptional circumstances that merited a higher level of housing provision in the longer term, RefID 11 would potentially merit further consideration given that there is already some degree of development on three sides.
We recommend that the following sites should remain sifted out:
•RefID 717 - we consider that it definitely constitutes major development, in the context of paragraph 190 of the NPPF.
•RefID 312 - the % increase in number of dwellings is quite large so it would potentially constitute major development.
•RefID 706 - mainly because of it being a potential Local Wildlife Site.
•RefID 709 - mainly because it is not contiguous with the settlement boundary (although consideration could be given to this site if it would otherwise become derelict).