BASE HEADER

Yes

ID sylw: 107286

Derbyniwyd: 07/03/2025

Ymatebydd: Cotswolds National Landscape Board

Summary of Ilmington sites
In the vicinity of Ilmington, there are a total of five sites that have been assessed in the HELAA process.
There is one site (RefID 541) that overlaps with the CNL that remains in consideration. In the table below, we have addressed this site in three components: (i) the CNL section (Ilmington West); (ii) the section in the setting of the CNL (Ilmington East); and (iii) the whole site.
In addition, there are four sites (RefID 7, 250, RefID 815 and RefID 854) that have been sifted out in Stage A of the HELAA process because they are each located entirely 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 the CNL. As such, we have included them in our assessment.
RefID 7: Land to the rear of Nellands Cottage (additional information)
The Landscape Sensitivity Assessment of Local Service Villages (Ilmington-Long Marston) indicates that the parcel of land on which this site is located has a High / Medium landscape sensitivity to housing development.139 However, the site would not be overlooked from more elevated viewpoints and there would only be limited visibility from the minor road to the east of the site.
Part of the site (approximately 0.08ha) overlaps with what is already an allocated site in the Ilmington Neighbourhood Plan (Site 2 - Land off Featherbed Lane for approximately 3 dwellings; 0.2ha).140
RefID 250: Mabel’s Farm, Land at Back Street (Additional Information)
RefID 250 covers the same area as RefID 854 and RefID 814 plus an additional area of land (approximately 0.6ha) to the west of RefID 814 and to the south of RefID 854.
The additional area of land extends further away from Back Street than most of the neighbouring existing development to the north and south and, if developed to its full extent, would protrude negatively into the landscape. A public right of way (PROW) footpath runs along the northern boundary of the additional area of land and another PROW footpaths crosses the additional area of land diagonally. Development on this part of the site could adversely affect views from these PROW.
RefID 541: Ilmington West & East (additional information)
This site consists of several parcels of land on both the west side of Ilmington (Ilmington West) and the east side (Ilmington East). Ilmington West and Ilmington West are separated by the existing settlement of Ilmington. Ilmington West is located within the CNL whereas Ilmington East is located in the setting of the CNL.
Ilmington West (in the CNL)
The scale of development at Ilmington West, both in terms of area (ha) and number of dwellings, would conflict with the requirement, in paragraph 189 of the NPPF, for the scale and extent of development within National Landscapes to be limited. It would also, in the Board’s opinion, definitely constitute major development, in the context of paragraph 190 of the NPPF.
Development on the more elevated part of Ilmington West (approximately 14.5ha of the site) would make the allocation visually prominent in views from Mickleton Road and from further afield, for example, from PROW to the north of Mickleton Road.
None of the Ilmington West section bears any relation to the existing settlement pattern. The Ilmington West section is aligned in a west-east direction whereas the existing settlement is primarily aligned in a south-north direction, focussed around Front Street and Back Street.
The Ilmington West section would also not be contiguous with the existing built development at Ilmington. This would be particularly noticeable in elevated, northward looking views from the Centenary Way. Development in the Ilmington West section would also adversely affect views from the PROW footpaths that run through - and along the boundary of - the site, including views looking south towards the escarpment outlier.
Even if just the 4.6ha of relatively low-lying land at Ilmington West (i.e. the field closest to the recreation ground) was developed, this would have an indicative capacity of 151 dwellings. This would represent a 45.8% increase on the 2021 census baseline figure of 330 dwellings in Ilmington. This would still far exceed the Board’s 5% ‘rule of thumb’ threshold for proportionality and would constitute major development in the context of paragraph 190 of the NPPF.
The Ilmington West section would be located within Landscape Character Type (LCT) 1 - Escarpment Outliers.141 One of the key features / characteristics of this LCT is the dramatic panoramic views from the upper slopes. The allocation would be likely to have a significant adverse effect on this key feature / characteristic. It would also conflict with the following guidelines:
•
Ensuring new development does not adversely affect settlement character and form.
•
Avoid development that will intrude negatively into the landscape and cannot be successfully mitigated, for example, extensions to settlements on visible hillsides. (N.B. Underlining added for emphasis).
Ilmington East (in setting of CNL)
Whilst the Ilmington East section is located outside of the CNL, National Landscape considerations are still relevant. This is because Ilmington is primarily a CNL settlement, with the vast majority of the conservation area and the vast majority of the settlement (as defined by the settlement boundary) being located within the CNL.
The eastern part of the site bears no relation to the existing settlement pattern, which is focussed around Front Street and Back Street. Development would extend along - and to the east of - the minor road to the east of Ilmington. This would be on the opposite side of a hill from the existing settlement.
The fields immediately to the east of Wilkins Way and Keyte Road are located within a Special Landscape Area, referred to as the Cotswold Fringe. This infers that it is an area of high landscape quality. Consideration would need to be given to the impact that any development in this location would have on this designation.
Development in the vicinity of Wharf Farm is likely to be highly visible for users of the Centenary Way, both in terms of where the Centenary Way passes through the site and where the it passes over the hill between Ilmington and Wharf Farm. Such development is likely to have a significant adverse effect on visual receptors using this PROW. Impacts on views from PROW within the CNL are likely to be more limited.
This part of the site would conflict with the following guideline in the CNL Landscape Strategy & Guidelines for LCT 1 (Escarpment Outliers):
•
Ensuring new development does not adversely affect settlement character and form.
Total site
This scale of development would be totally inappropriate for a settlement where the vast majority of the settlement, including the conservation area, lies within the CNL.
In addition to the impacts outlined above, this allocation (taken as a whole or taken as separate sections) is likely to result in a significant increase in the number of traffic movements generated in Ilmington. Given that Ilmington is located on minor roads that are not on a main route between larger settlements, it is also likely that there would be a significant increase in traffic movements on local roads within - and along the boundary of - the CNL.
As outlined in the Board’s Tranquillity Position Statement, an increase in traffic movements on these roads of 10% or more is likely to have a significant adverse effect on the tranquillity of the CNL in this locality.142 The traffic resulting from the allocation may well exceed this threshold.
Development of this scale could also have a significant adverse effect on the dark skies of the CNL, which are one of the CNL’s ‘special qualities’. The map below shows that Ilmington is only affected by light pollution to a very limited degree. Allowing up to a four-fold increase in the number of dwellings at Ilmington would make this light pollution much worse. Recommendations
We recommend that the site, as currently proposed, should not be taken forward for further consideration. The same applies to the western and eastern parts of the allocation if considered separately.
If consideration is going to be given to allocating any sites in Ilmington, this should be:
•
At a much smaller scale than currently proposed. Ideally, any allocations should, collectively, not result in an increase in settlement size (or increase in number of dwellings) of more than 5%.
•Confined to land that does not extend up the slopes of the escarpment outlier (LCT 1).
•Contiguous with the existing settlement and consistent with the (historic) settlement character and form. RefID 815: Mabel’s Farm (additional information)
This site is a strategic reserve site, for approximately 8 dwellings, in the Ilmington Neighbourhood Plan.143 With that in mind, it would probably make more sense to have development on this site than on other sites, or additional sites, in the vicinity of Ilmington. The fact that the site is allocated in the Neighbourhood Plan should be reflected in the Local Plan in some way.
The site is currently undeveloped and only has existing development to the north and east. One public right of way (PROW) footpath runs along the northern boundary of the site and another PROW footpath runs diagonally across the site. Consideration would need to be given to how adverse impacts on views from these PROW could be avoided and mitigated. Ideally, built development would not extend west of the point where two PROW meet on the southern boundary.
The site lies outside of, but adjacent to, the conservation area. Consideration will need to be given to how adverse effects on the conservation area can be avoiding and mitigated.
Given that development on this site could result in some adverse impacts on landscape character and adverse visual impacts, this site should remain as a reserve site rather than be upgraded to a main allocation.
RefID 854: Land at Mabel’s Farm (additional information)
Much of the site is already developed (i.e. the buildings associated with Mabel’s Farm). The northern half of the site, which is currently undeveloped, has Mabel’s Farm immediately to the south, housing immediately to the north and Back St (with housing on the opposite side of the road) immediately to the east. The western boundary appears to be well screened with vegetation. On this basis, the impacts on landscape character and visual impacts of infilling the undeveloped part of the site are likely to be limited.
A public right of way (PROW) footpath runs along the south-western boundary of the site. Consideration would need to be given to how the redevelopment of the site would affect views from this PROW. The trees and hedgerow along the southern boundary should be retained.
Conclusions
We recommend that:
•
RefID 854 should be retained as an allocated site in the Ilmington Neighbourhood Plan - this should be referred to in the Local Plan in some way;144 we recommend that the Neighbourhood Plan figure of 20 dwellings should be used (rather than the indicative capacity of 34 dwellings).
•
RefID 815 should be retained as a reserve site in the Ilmington Neighbourhood Plan - this should be referred to in the Local Plan in some way;145 we recommend that the Neighbourhood Plan figure of eight dwellings should be used (rather than the indicative capacity of 13 dwellings).
Based on the figures in the Neighbourhood Plan (i.e. 28 dwellings in total), these two sites would already increase the number of dwellings in Ilmington by 8.4%. In comparison, based on the Preferred Options indicative figure (i.e. 47 dwellings), this increase would be 14.2%. Both of these figures are well above the Board’s 5% ‘rule of thumb’ threshold for proportionality. As such, we recommend that no additional housing should be allocated.
However, we acknowledge that the Neighbourhood Plan only runs to 2031, whereas the Local Plan would run through to 2050. We also acknowledge that Ilmington is a Category 3 Service Village. Therefore, if there were exceptional circumstances that merited a higher level of housing provision in the longer term, RefID 7 would potentially merit further consideration, given its relatively limited landscape and visual impact.
We recommend that RefID 250 and, in particular, RefID 541 should remain sifted out and not given further consideration.
Ilmington is identified in the Preferred Options consultation as being a ‘Priority Area 3’ for spatial growth. We acknowledge the methodology that was used for this.146 However, we question the appropriateness of categorising any of the settlements within the CNL as being ‘Priority Area 3’ given that national planning policy requires the scale and extent of development in National Landscapes to be limited.