Yes

ID sylw: 107253

Derbyniwyd: 06/03/2025

Ymatebydd: CEMEX UK Operations Ltd

Asiant : Victoria Bullock

Site 391-
The CEMEX Long Ichington site is suitable, available and achievable and would contribute to a mix of sites that would be needed to supply variety to the market and maintain housing land supply. Consistent with the NPPF 2024, it would provide the opportunity for housing development to meet the increased Standard Method housing requirement and as yet undefined unmet housing need of the surrounding authorities.
5 We support the identification the CEMEX Long Itchington Site as a Part B site for further consideration. There is however merit in a move beyond the HELAA methodology and weighting to understand the settlement hierarchy and sustainability of settlements and sites beyond the strategic growth Priority Areas. This is needed if the housing requirement is to be met and indeed exceeded.

Other

ID sylw: 107254

Derbyniwyd: 07/03/2025

Ymatebydd: R. Adams & Sons R. Adams & Sons

Asiant : Iceni Projects

Land at the Adams Property, North of Henley-in-Arden, B95 9QA (‘the Site’).
RA&S are looking to optimise the current operation of its Site through the development of the existing bulk haulage provider business. Their aim is to support and grow the existing supply and distribution chain to meet a demonstrable need, whilst also protecting and optimising the historic and well established business. This will in-turn create new and local employment opportunities to support and grow Henley-in-Arden’s local and rural economy.
The Site is in an excellent strategic location and future development can utilise the existing infrastructure, to provide greater employment opportunities and continued support for local and rural businesses. Allocating the Site will secure its continued growth with the potential to deliver the following:
1. Establish a reliable and farmer-centric grain store in the South Birmingham agricultural catchments;
2. Achieve an annual throughput target of 20,000 tonnes of storage and 5,000 tonnes of additional conditioning throughout within the first years of operations;
3. Create new employment opportunities for the local community; and
4. Promote sustainable agricultural practices through collaboration with local farms and utilising green energy storage and transport solutions where possible.

Yes

ID sylw: 107283

Derbyniwyd: 07/03/2025

Ymatebydd: Cotswolds National Landscape Board

The Preferred Options consultation has taken an unusual approach by including more sites than are actually needed to accommodate South Warwickshire’s identified housing need. This means that there are many more sites for the Board to comment on than would normally be the case.
The Preferred Options consultation includes many sites that are either within the Cotswolds National Landscape (CNL), that overlap with the CNL boundary or that are in the setting of the CNL. We provide an analysis of these sites below.
Key considerations include whether:
• the potential allocations would:
o conserve and enhance the natural beauty of the CNL;
o further the purpose of conserving and enhancing the natural beauty of the CNL (i.e. leave the natural beauty of the CNL in a better state).
• allocations within the CNL would:
o be small in scale and extent;
o constitute major development in the context of paragraph 190 of the National Planning Policy Framework (NPPF);
In this context, it is important to address natural beauty in its holistic sense. This includes not only the area’s landscape and scenic beauty, but also its cultural heritage (including historic environment), natural heritage (including biodiversity) and relative tranquillity. The ‘special qualities’ of the CNL are a key consideration as are the key features / characteristics of the relevant landscape character types.
In principle, site allocations that would harm the natural beauty of the CNL should not be taken forward. If any sites are taken forward that would harm the natural beauty of the CNL, consideration should be given to providing some form of compensation for the harm that would be caused.
Paragraph 189 of the NPPF requires great weight to be given to conserving and enhancing landscape and scenic beauty in National Landscapes. This great weight applies not only to development within the CNL but also to development within its setting. For example, great weight should be given to the impact of development outside the CNL on views from the CNL.
As stated in footnote 68 of the NPPF, whether a proposal is ‘major development’ (in the context of paragraph 190 of the NPPF) is a matter for the decision maker, taking into account its nature, scale and setting, and whether it could have a significant adverse impact on the purpose for which the area has been designated’. With regards to ‘scale’, a key consideration is whether a development / allocation would be proportionate to the existing settlement.
The Board’s Landscape-led Development Position Statement (Appendix 5)102 provides a checklist of factors to consider when assessing whether a proposal constitutes major development. One of the questions in the checklist, relating to scale and proportionality, is:
• Would it exceed 5% of the size of - and / or the number of dwellings in - the existing settlement?
If the answer is ‘yes’ then it is more likely to constitute major development.
The 5% ‘rule of thumb’ threshold relating to size is based on what is now paragraph 76 and footnote 36 of the NPPF, which relate to community-led development and which provide the NPPF’s only definition of what constitute ‘proportionate’. Paragraph 76 states that community-led development adjacent to existing settlements and proportionate in size to them. Footnote 36 defines ‘proportionate’, in this context, stating that ‘community-led development exception sites should not … exceed 5% of the size of the existing settlement’.
The 5% ‘rule of thumb’ threshold relating to number of dwellings is partly based on the same definition of what is proportionate. It is also based on the assessment that was undertaken by South Downs National Park Authority to identify whether their potential Local Plan allocations would be major development in the context of what is now paragraph 190 of the NPPF.103 In that assessment:
• a potential allocation of 20 dwellings in the village of Coldwaltham (population of 850) was considered to be major development in relation to scale - at the 2011 census there were 421 dwellings in Coldwaltham, so 20 dwellings would be a 4.8% increase (i.e. a 4.8% increase was considered to be major development);
• a potential allocation of 30 dwellings in the village of Greatham, which had 400 dwellings, was considered to be major development in relation to scale (i.e. a 7.5% increase was considered to be major development).
Given that paragraph 189 of the NPPF requires the scale and extent of development in National Landscapes to be limited, we consider this to be an appropriate threshold to use in the context of housing development:
in settlements within the CNL (where an increase larger than 5% would indicate that it is likely to be major development);
• outside the CNL where the centre of the settlement and / or most of the existing built development is within the CNL (i.e. a CNL settlement);
• outside the CNL in settlements that are directly adjacent to the CNL boundary and which would be seen from higher elevation views within the CNL.
As stated in national planning practice guidance on the natural environment, national landscapes ‘are unlikely to be suitable areas for accommodating unmet needs from adjoining (non-designated) areas’ (Paragraph 041).104 This includes unmet needs relating to settlements that are adjacent to the CNL boundary. In other words, in principle, sites should not be allocated that would expand an adjacent settlement into the CNL (such as the potential allocation, within the CNL, at Tysoe).
Given that the CNL only occupies 5% of the South Warwickshire area (including 10.6% of the area of Stratford on Avon District), we consider that it is highly unlikely that exceptional circumstances could be demonstrated to justify allocations within the CNL that exceed the 5% proportionality threshold (i.e. major development). Therefore, in most cases, we recommend that sites within the CNL that exceed this threshold should be sifted out and not given further consideration. The main exception to this is where there is robust evidence of local need specific to the settlement / parish, such as:
• sites having already been allocated, or identified as reserve sites, in Neighbourhood Plans;
• data in a Rural Housing Needs Survey.
Slightly higher levels of housing provision might be appropriate in Category 2 and Category 3 Local Service Villages. This is because it is appropriate to focus housing provision in settlements that have a wider range of facilities and services. However, exceptional circumstances would still need to be demonstrated and the level of housing provision should not significantly exceed the 5% threshold.
If the standard method housing need figure could only be met by including allocations that would be harmful 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. This approach would be consistent with paragraph 11b of the NPPF, which outlines the circumstances in which objectively needs don’t have to be met in full. This includes where the application of NPPF policies that relate to National Landscapes provides a strong reason for restricting the overall scale, type or distribution of development in the plan area. It is also consistent with the Government’s planning practice guidance on the natural environment, which states that the NPPF’s policies for protecting National Landscapes ‘may mean that it is not possible to meet objectively assessed needs for development in full through the plan-making process’.105
In the Preferred Options consultation, sites that would be located entirely within the CNL have been sifted out in Stage A of the Housing and Economic Land Availability Assessment (HELAA). However, the Board does not agree with the principle of sifting out potential allocation sites on the basis of being located within the CNL. This is because we recognise that a small quantum of development may be appropriate in CNL settlements to ensure that they remain thriving and vibrant communities. Therefore, our analysis includes those sites that have been sifted out on this basis. In some instances, we recommend that these sites should be given further consideration.
Sites that overlap with the CNL boundary (i.e. sites that are partly within and partly outside the CNL) have not been sifted out in the HELAA process, even if the CNL component is not contiguous with the rest of the site. As a result, there are some sites that cover a large area of land within the CNL that are still being given further consideration. In the Board’s opinion, the CNL component of these larger sites would constitute major development and should not be taken forward.
Relevant settlements
There are several settlements that include potential allocations (including sites that have been sifted out) that are located within the CNL. These are:
• Brailes - nine sites (all of which have been sifted out).
• Cherington - two sites (including one that has been sifted out).
• Ilmington - five sites (including four that have been sifted out).
• Long Compton - seven sites (all of which have been sifted out).
• Tysoe - nine sites (including one that has been sifted out).
• Warmington - one site.
So, in total, we have given consideration to 33 sites at these settlements, including 21 sites that have been sifted out Stage A of the HELAA process.
There are also several additional settlements within the setting of the CNL that have potential allocations. These settlements are:
• Meon Vale / Long Marston / Long Marston Airfield
• Oxhill
• Quinton
• Shipston-on-Stour
• Quinton
Assessment
For the settlements that include potential allocations that are located within the CNL, the Board has compiled tables that provide the following information:
• RefID.
• Site name.
• Site area.
• % increase in area of settlement (based on settlement boundary area, calculated manually using the Preferred Options consultation interactive map) - an increase of up to 5% is shaded green, an increase of 5-10% is shaded amber and an increase of more than 10% is shaded red.
• Number of existing dwellings (based on 2021 census data106).
% increase in number of dwellings in the settlement - an increase of up to 5% is shaded green, an increase of 5-10% is shaded orange and an increase of more than 10% is shaded red.
• Landscape sensitivity (based Stratford on Avon District Council’s Landscape Sensitivity Assessment (LSA) of Local Service Villages) - a ‘high’ or ‘high-medium’ landscape sensitivity is shaded red and ‘medium’ landscape sensitivity is shaded orange.107
• Comments, including relevant information from the Preferred Options consultation interactive map and from the relevant Neighbourhood Plan.
With regards to landscape sensitivity, it is worth noting that the Board’s Landscape-led Development Position Statement states that locations that have high or medium-high landscape sensitivity to housing development would probably constitute major development (in the context of paragraph 190 of the NPPF) and should not be allocated.108 The exception to this would be for areas of medium-high landscape sensitivity where it is demonstrated that development impacts could be fully mitigated.
The lands parcels that were assessed in the LSA were very large. There could potentially be smaller areas of land, within these larger parcels that have a lower landscape sensitivity. To address this issue, we recommend that a further LSA should be undertaken specifically for those sites that might be given further consideration. Development in areas of ‘high / medium’ sensitivity would merit more consideration for development than areas of ‘high’ sensitivity.
Following on from these summary tables, our assessment then addresses key considerations such as the CNL’s ‘special qualities’, the CNL Landscape Character Assessment and the CNL Landscape Strategy & Guidelines (including key features / characteristics of the relevant landscape character types), and potential impacts on tranquillity (particularly in relation to traffic movements) and dark skies.
With regards to the CNL Landscape Strategy & Guidelines, strategies / guidelines that are common to all landscape character types include:
• Maintain the open, sparsely settled character by limiting new development to existing settlements and avoiding development between existing villages.
• Avoid development that will intrude negatively into the landscape and cannot be successfully mitigated, for example, extensions to settlements in areas of open landscape and / or onto the escarpment.
• Ensure that new development does not adversely affect the wider rural landscape and views.
• Ensure new development is proportionate and does not overwhelm the existing development.
• Conserve pattern of settlements fringing the lower slopes and their existing relationship to landform.
• Ensure that new development does not adversely affect settlement character and form.
These strategies / guidelines should be taken into account when assessing the suitability of the potential allocations. For the additional settlements that include potential allocations within the setting of the CNL, we primarily focus on potential impacts on views from the CNL and, for larger allocations, potential impacts on the tranquillity of the CNL (resulting from increases in traffic movements) and on the dark skies of the CNL.
For all sites, we conclude by stating whether we think that the site should sifted out or remain in consideration.
Recommendations
For sites within the CNL and sites within the CNL’s 3km buffer zone that the Council is considering taking forward to the Regulation 19 (pre-submission) consultation stage, we recommend that the following assessments should be undertaken:
• An updated landscape sensitivity assessment (LSA) specifically for the sites that are being proposed, including consideration of landscape and visual effects in relation to the CNL.
• For sites that would increase the number of dwellings in the settlement by 10% or more, an assessment of the potential increase in traffic movements on roads within - and along the boundary of the CNL that would result from the proposed allocation.
• An assessment of whether the allocation is likely to further the purpose of conserving the natural beauty of the CNL (including: (i) whether the allocation would have a (net) beneficial, harmful, neutral or negligible effect or no effect;109 and (ii) what reasonable and proportionate action could be taken to further this purpose, over and above avoidance and mitigation of harm).
For sites within the CNL, specifically, that remain in consideration, we recommend that an assessment should be undertaken to identify whether the site constitutes major development, in the context of paragraph 190 of the NPPF. If it is deemed to constitute major development, a further assessment should be undertaken to identify whether exceptional circumstances apply to justify the proposal.

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).

Yes

ID sylw: 107285

Derbyniwyd: 07/03/2025

Ymatebydd: Cotswolds National Landscape Board

Summary of Cherington sites
At Cherington there is one site (RefID 539) that overlaps with the CNL boundary that is still in consideration. In the table below, we have addressed this site in three parts: (i) the northern section (N), in the setting of the CNL; (ii) the southern section (S), within the CNL; and (iii) the whole site.
Another site (RefID 522) was assessed in the HELAA Stage A process but was sifted out for two reasons. Firstly, it scored a ‘red’ in relation to ‘site purpose’, which means that it was put forward for protection (i.e. no change from its existing state) rather than for consideration as an allocation. Secondly, it scored a ‘red’ in relation to ‘AONB’ because it is located 100% within the CNL.
As outlined above, the Board doesn’t agree with the principle of ruling out potential sites just because they are located entirely within the CNL. However, given that RefID522 was sifted out in relation to ‘site purpose’ as well, we do not think it is necessary to comment on this site.
Ref ID 539: Cherington West (West), Camperdown Farm, Little Wolford Road, Cherington CV36 5HS
This site consists of two parcels of land, one on the south side of the minor road to the west of Cherington, within the CNL, and an adjacent parcel of land, on the north side of this road, outside the CNL. The southern part of the site, within the CNL, would be subject to additional policy considerations, such as whether development there would constitute major development, in the context of paragraph 190 of the NPPF. As such, it is not clear why this site has been assessed, in the HELAA, as one unit. It would have made more sense to assess the southern and northern parts as two difference sites.
In that scenario, based on the HELAA methodology122, all of the southern part of the site would have been sifted out, with only the northern part of the site remaining for further consideration. However, we do not agree with the principle of automatically ruling out sites on the basis that they would be located entirely within the CNL. As such, we have included the southern part of the site in our assessment.
It is important to note that the vast majority of Cherington, including all of its conservation area, is located within the CNL. As such, we consider Cherington to be a CNL settlement.
Southern section (within the CNL)
The proposed scale of development in this section of the site, both in terms of area (ha) and indicative 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.
Most of the southern, CNL section would be located in Landscape Character Type (LCT) 19 (Unwooded Vale), specifically Landscape Character Area 19E (Unwooded Vale - Vale of Feldon Fringe).123 The south western corner of the site is located in LCT 6 (Ironstone Hills and Valleys), specifically Landscape Character Area 6A (Ironstone Hills and Valleys - Whichford Hills and Valleys).124
The CNL Landscape Character Assessment for LCT 19 states that ‘the Vale of Feldon Fringe is deeply rural’.125 This is reflected in the key features / characteristics for LCT 19, which includes ‘quiet winding lanes link numerous isolated farms and hamlets and emphasise the rural character of the landscape’. The CNL Landscape Strategy & Guidelines for LCT 19 states that ‘the sparsely settled and deeply rural Unwooded Vale landscape is highly sensitivity to change’.126 Developing the site would conflict with the sparsely settled and deeply rural character of the area.
One of the key features / characteristics of LCT 6 is the ‘rolling rounded ridgelines and hills providing dramatic sweeping views over wide areas of the landscape’. Such views would be experienced from PROW footpaths, such as the Shakespeare Way, to the south of the site. Development on the site would have a significant adverse effect on this key feature / characteristic, with regards to northward looking views from these footpaths. The CNL Landscape Strategy & Guidelines for LCT 19 states that ‘Vale landscapes bordering upland areas with wide vantage points … are particularly sensitive to the effects of large-scale built development … as these are difficult to screen from elevated vantage points’.127 Similarly, the CNL Landscape Strategy and Guidelines for LCT 6 states that ‘the landscape [of the Ironstone Hills and Valleys] is made more sensitive by the wide panoramic views across the landscape from high elevations’.128 In other words, the LCT 19 landscape would be particularly sensitive to the scale of development proposed.
Northern section (in the setting of the CNL)
Although this section is located outside the CNL, the landscape and visual impact considerations outlined above (for the section within the CNL) would still apply.
Whole site
The site, both in its totally and with regards to its northern and southern sections does not reflect the (historic) settlement pattern and form. Existing development in Cherington, particularly the conservation area, is primarily orientated in a west-east direction along the through road, whereas the site is orientated in a south-north direction (i.e. perpendicular to the existing settlement pattern).
In addition to the impacts outlined above, allocating this site, both in its entirety and in its separate sections, would significantly increase the number of traffic movements generated in Cherington parish and / or within the settlement boundary of Cherington and Stourton. Given that Cherington is located on a minor road, which is unlikely to experience a significant amount of through traffic, it is highly likely that the allocation would significantly increase traffic movements on local roads within - and along the boundary of - the CNL. As outlined in the Board’s Tranquillity Position Statement (paragraph 4.5), an increase of 10% or more should be considered significant and is likely have a significant adverse effect on the tranquillity of the CNL in this locality.129
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 Cherington is only affected by light pollution a very limited degree. Allowing up to an eight-fold increase in the number of dwellings at Cherington would make this light pollution much worse. It is worth noting that Cherington was not included in the Landscape Sensitivity Assessment of Local Service Villages.130 This is presumably because Cherington did not merit ‘local service village’ size because of its limited size and services. By extension, it was presumably not anticipated that Cherington would be a likely location for future allocations.
Conclusions
The Board recommends that site RefID 539 should be sifted out and not given further consideration.

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.

Yes

ID sylw: 107287

Derbyniwyd: 07/03/2025

Ymatebydd: Cotswolds National Landscape Board

Summary of Long Compton sites
There are seven sites at Long Compton, all of which have been sifted out in Stage A of the HELAA process on the basis of being located 100% in the CNL. As outlined above, the Board does not agree with the principle of ruling out sites on the basis of being located in the CNL. As such, we have reviewed these sites to see if they still merit further consideration, as outlined below. Additional considerations
Long Compton is primarily located within Landscape Character Type (LCT) 17 (Pastoral Lowland Vale).153 Any further assessments should have regard to the key features / characteristics of LCT 17. The CNL Landscape Strategy & Guidelines for LCT 17 states that existing vale settlements may have the capacity to accommodate some development where this does not interfere with, or detract from, their landscape setting.
Immediately to the north of Long Compton is LCT 6 (Ironstone Hills and Valleys)154 and immediately to the south is LCT 15 (Farmed Slopes)155. A key feature / characteristic of both these LCTs is the views that are experienced over wide areas of landscape, including across the Pastoral Lowland Vale (LCT 17). The CNL Landscape Strategy & Guidelines for LCT 17 states that the proximity to elevated viewing opportunities on the neighbouring Farmed Slopes increases the sensitivity of the Pastoral Lowland Vale to large scale development. The views that can be experienced from the Macmillan Way and Shakespeare’s Way, looking towards Long Compton from both the north and the south, are particularly important considerations in this regard.
Additional housing already allocated in Neighbourhood Plan
The Long Compton Neighbourhood Plan identifies three potential housing sites as shown in the map below •
Site 1 - The Old Piggeries, Old Hill, Long Compton: 0.4ha; 4/5 homes.
•
Site 2 - Land at Ashby Farmyard, Old Hill, Long Compton: 0.3ha; 5/7 homes.
•
Site 3 - Land for Affordable Housing, Off Weston Court, Long Compton: 0.9ha; nine homes in first phase (northern half of site), with possible future development, during the Plan period (i.e. 2011-2031), subject to identification of local need.
From Google maps, it appears that all of these sites have now been developed, apart from the southern half of Site 3. As such, with the exception of the southern half of Site 3, they pre-date the timescales of the SWLP, which will cover the period 2025-2030.
The southern half of Site 3 is approximately the same size as the northern half (i.e. approximately 4.5ha). So, if the southern half of Site 3 is developed at the same density as the northern half, there could be approximately 9-10 new dwellings. However, if it was developed at the indicative capacity used in the HELAA process (i.e. 33 dwellings per hectare), there could be approximately 13 dwellings.
13 dwellings would increase the number of dwellings in Long Compton parish by approximately 3.5%, compared to the 2021 census baseline of 370 dwellings. This is below the Board’s 5% ‘rule of thumb’ threshold for proportionality.
Sites 1 and 2 are within the settlement boundary but Site 3 is not. Presumably the settlement boundary will be expanded to include Site 3 give that development has already taken place there.
Conclusions
We consider that the primary location for further housing development in Long Compton should be the southern half of Site 3 in the Ilmington Neighbourhood Plan, directly north of and adjacent to RefID 666.157 As indicated above, this could potentially accommodate 13 dwellings, which would increase the number of dwellings in Long Compton parish by approximately 3.5%.
On this basis, with regards to proportionality, there is potentially scope for some additional housing development during the SWLP plan period of 2025-2050.
We consider that the following sites potentially merit further consideration:
•Ref ID 354 / Ref ID 425; and / or
•Ref ID 666.
For Ref ID 354 / Ref ID 425, consideration will need to be given to the potential impacts of any lighting on the adjacent Dark Skies Discovery Site (Aunt Phoebe’s Recreation Ground). Provided that lighting issues could be adequately addressed, this site is potentially a better option than RefID 166 as it is on previously developed land within the settlement boundary.
We recommend that the following sites should remain sifted out:
•RefID 309 - mainly because it is a potential Local Wildlife Site.
•RefID 353 - mainly because it would probably constitute major development in the context of paragraph190 of the NPPF.
•RefID 719 - we consider that this would definitely constitute major development in the context of paragraph 190 of the NPPF.

Yes

ID sylw: 107288

Derbyniwyd: 07/03/2025

Ymatebydd: Cotswolds National Landscape Board

Summary of Tysoe sites
At Tysoe, there are eight sites that remain in consideration. Of these (Ref ID 544), one overlaps with the CNL boundary and seven are located in the setting of the CNL.
In addition, one site (RefID 323) was sifted out because it was located entirely within the CNL. As outlined above, the Board does not agree with the principle of ruling out sites on the basis of being located in the CNL. As such, we have reviewed this site to see if it still merits further consideration, as outlined below.
RefID24: Land off Meadow Lane (additional information)
The Ref ID24 site covers part of the larger RefID 35 site.
This site is located approximately 100m from the boundary of the CNL but is separated from the CNL by the existing built development of Middle Tysoe.
The site extends northwards beyond the existing built development (and settlement boundary) of Middle Tysoe by approximately 75m. This wouldn’t be a significant addition to the total length of built development in Middle / Upper Tysoe, which currently extends approximately 1,300m from south to north. However, it would reduce the gap between built development in Middle Tysoe and Lower Tysoe by approximately 25% (the current gap being approximately 300m). This could potentially contribute to a sense of coalescence between the two.
Development in the western end of the site would also extend built development further west than on neighbouring land to the south, which could potentially create a perception of intruding into the open landscape to the west.
Overall, allocating this site could potentially result in some minor adverse effects for visual receptors in the CNL. However, these effects could be reduced by ensuring that development does not extend:
• further north than the current settlement boundary (unless the adjacent site, RefID 296, is allocated / developed first);
• further west than the western boundary of the school playing field to the south.
REfID35: Land to the rear of Meadow Lane, Tysoe (additional information)
The RefID 35 site includes the land that is in the RefID 24 site and some additional land.
This site is a larger version of site RefID 24. Similar considerations apply for both sites. However, this site is considerably larger than RefID 24, resulting in a larger quantum of housing, and extends further west, resulting in a more significant intrusion into the open countryside. Developing up to the north-western corner would bring the built development of Middle Tysoe within approximately 220m of built development at Lower Tysoe.
Development on this site could potentially impinge on two of the ‘valued views’ identified in the Tysoe Neighbourhood Plan, specifically View 4 (From Lower Tysoe towards Middle Tysoe) and View 5 (From the footpath south of Lower Tysoe towards Middle Tysoe). This would be to a greater degree than for RefID 24.
RefID 296: Land to the North of Lower Grounds, Middle Tysoe (additional information)
This site is located adjacent to the CNL boundary, on the opposite side of Tysoe Road.
The site extends northwards beyond the existing built development (and settlement boundary) of Middle Tysoe by approximately 75m. This wouldn’t be a significant addition to the total length of built development in Middle / Upper Tysoe, which currently extends approximately 1,300m from south to north. However, it would reduce the gap between built development in Middle Tysoe and Lower Tysoe by approximately 25% (the current gap being approximately 300m). This could potentially contribute to a sense of coalescence between the two, for example when viewed from the Centenary Way, within the CNL.
Having said that, the hedge along the northern boundary of the site (which also extends further westwards) could provide a robust and definitive limit of development for Middle / Upper Tysoe, with a clear gap still being maintained between the village and the hamlet.
RefID 397: South of Oxhill Road, Tysoe (additional information)
This site is located approximately 300m of the CNL boundary to the south and approximately 380m to the south.
71
Development on this site is likely to have an adverse impact on views from the Public Right of Way (PROW) footpaths in the vicinity of Windmill Hill. From these viewpoints, the development on the site would be seen to protrude to the side of the existing development at Middle / Upper Tysoe rather than being seen in the foreground or background of this existing development. As such, it would be relatively prominent.
Development on the site would adversely affect the setting of Windmill Hill Windmill, which is a Grade II listed building. In views from Windmill Hill, the development would be seen behind Tysoe Manor (Grade II* listed building), replacing the currently undeveloped backdrop. As such it would also adversely affect the setting of Tysoe Manor, both in terms of its proximity and in terms of the views of Tysoe Manor from Windmill Hill.
The higher elevations of Windmill Hill lie within Landscape Character Type (LCT) 6 - Ironstone Hills and Valleys. One of the key features / characteristics of LCT 6 is the dramatic sweeping views over wide areas of the landscape. Development on this site would adversely affect this key feature / characteristic.
Development on the site would also be visible from the PROW footpath, to the south east of Upper Tysoe, on the Cotswold escarpment and from the road up the escarpment to Tysoe Hill. Views from the escarpment are one of the ‘special qualities’ of the CNL and one of the key features / characteristics of LCT 2 (Escarpment).
RefID 544: Lower Tysoe - West, East & North (additional information)
RefID 544 appears to be the same as RefID 571, except that RefID 571 doesn’t include the section of RefID 544 that is located within the CNL.
This site consists of several parcels of land, both within the CNL and within its setting, that are not physically connected. The part of the site that is located within the CNL would be subject to additional policy considerations, such as whether development there would constitute major development, in the context of paragraph 190 of the NPPF.
Based on these points, it is not clear why this site has been assessed, in the HELAA, as one unit. It would have made more sense to assess the section within the CNL as a separate site. In that scenario, based on the HELAA methodology, all of the western part of the site would have been sifted out, with only the eastern part of the site remaining for further consideration.
Lower Tysoe East (section within CNL)
Lower Tysoe East is located to the east of the hamlet of Lower Tysoe. Lower Tysoe doesn’t have a defined settlement boundary, presumably because it is too small, whereas Middle / Upper Tysoe does. The only built development within Lower Tysoe East is Hopkins Farm, which is on the eastern edge of the hamlet of Lower Tysoe.
The proposed scale of development, both in terms of area (ha) and potential number of dwellings and would be completely inappropriate in the CNL. The scale of the Lower Tysoe East section would also be completely disproportionate in relation to the adjacent hamlet of Lower Tysoe, which lies outside the CNL, and to the amount of housing in Tysoe Parish as a whole.
Nearly all of the existing built development at Tysoe is located outside the CNL and only a tiny section of the settlement boundary extends into the CNL. As such, housing needs associated with Tysoe arise outside the CNL boundary. Government guidance makes it clear that National Landscapes ‘are unlikely to be suitable areas for accommodating unmet needs from adjoining (non-designated) areas’.162 In other words, the CNL should not be expected to accommodate housing needs relating to Tysoe given that these needs arise outside of the CNL.
Development in the CNL section would have a significant adverse effect on:
• views from the public rights of way (PROW) that cross the CNL section of the site, including the Centenary Way;
• westward looking views from the more elevated PROW on the escarpment, to the east of the site, including the Centenary Way;
• eastward looking views, towards the escarpment from Tysoe Road and from the PROW in the vicinity of Lower Tysoe.
The CNL section would mainly overlap with Landscape Character Type (LCT) 19 (Unwooded Vale), specifically Landscape Character Area 19E (Unwooded Vale - Vale of Feldon Fringe).163 The eastern fringe of the site, approximately above the 140m contour line, would overlap with LCT 2 (Escarpment), specifically Landscape Character Area 2G (Escarpment - Edge Hill).164 The allocation would also come within approximately 200m of LCT 7 (High Wold).165
The CNL Landscape Strategy & Guidelines for LCT 19 states that the Unwooded Vale is a sparsely settled and deeply rural landscape type, is highly sensitive to change and is not currently associated with development. It adds that Vale landscapes bordering upland areas with wide vantage points, such as the escarpment, are particularly sensitive to the effects of large scale, built development.166 Allocating the CNL section of this site would conflict with this landscape character and this landscape sensitivity.
The Cotswold escarpment, including views from and to it, is one of the ‘special qualities’ of the CNL. The dramatic panoramic views that are experienced from the escarpment are also one of the key features / characteristics of LCT 2 (Escarpment). Allocating CNL section of the site would affect these views. It would also directly affect the escarpment if development extended into LCT 2.
LCT 7 (High Wold) lies approximately 200m east of the eastern boundary of the CNL section. The open, panoramic views that are experienced on the High Wold are one of the ‘special qualities’ of the CNL. However, views from the High Wold, towards the site, are likely to be restricted by the area of woodland that runs along the upper slopes of the escarpment.
Lower Tysoe West & North (in setting of CNL)
As indicated above, the section of RefID 544 that lies outside of the CNL (i.e. Lower Tysoe West & North) is the same as the whole of RefID 571. This section includes three contiguous parcels of land to the north of the hamlet of Lower Tysoe (Lower Tysoe North) and a separate parcel of land to the west of Middle Tysoe (Lower Tysoe West), both of which come within approximately 280m of the CNL boundary.
Allocating the parcels of land north of Lower Tysoe would extend built development up to 2km northwards from the edge of existing built development at Lower Tysoe, whereas built development at Lower Tysoe currently only extends approximately 500m south to north and approximately 800m west to east. Lower Tysoe is mainly orientated in a west-east direction, whereas development on these parcels of land would be orientated in a south-north direction (i.e. perpendicular to the existing settlement pattern).
The large parcel of land to the west of Middle Tysoe would extend built development up to 1.5km north-west of the edge of built development at Middle Tysoe, whereas built development at Middle Tysoe currently only extends approximately 300m in a south-east to north-west direction. Middle Tysoe is mainly orientated in a south-west to north-east direction whereas development on this parcel of land would be orientated in a south-east to north-west direction (i.e. perpendicular to the existing settlement pattern).
The extent to which this section of the site would be completely disproportionate to the existing settlements of Middle / Upper Tysoe and Lower Tysoe and the extent to which it would deviate from the existing settlement pattern would be clearly visible from the CNL. This would include views from PROW on the Cotswold escarpment, including the Centenary Way. Views from the escarpment are one of the ‘special qualities’ of the CNL. Allocating this site would have a significant adverse effect on these views and on this special quality.
Total site
In addition to the impacts outlined above, allocating this site, both in its entirety and in its separate sections, would significantly increase the number of traffic movements generated in Tysoe parish. Given that Lower, Middle and Upper Tysoe are located on a minor road, which is unlikely to experience a significant amount of through traffic, it is highly likely that the allocation would significantly increase traffic movements on local roads within - and along the boundary of - the CNL. As outlined in the Board’s Tranquillity Position Statement, an increase of 10% or more should be considered significant and is likely have a significant adverse effect on the tranquillity of the CNL in this locality. This tranquillity is one of the ‘special qualities’ of the CNL.167
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 Tysoe is already affected by light pollution to some degree, with the effects of this light pollution extending into the CNL. Allowing up to a seven-fold increase in the number of dwellings at Tysoe would make this light pollution much worse. Recommendations
We recommend that the allocation, as currently proposed, should not be taken forward for further consideration. This applies to the site both in its entirety and in the context of the separate sections within it.
RefID 571: Tysoe North - Herberts Farm - Land to the north of Middle Tysoe (additional information)
This appears to be the same as RefID 544, except that RefID 571 doesn’t include the section of RefID 544 that is located within the CNL.
Please refer to our comments on site RefID 544, above.
RefID 830: Herbert’s Farm, Saddledon Street, Tysoe (additional information)
This site is located within the settlement boundary of Upper / Middle Tysoe. Most of the site is already identified as a strategic reserve site in the Tysoe Neighbourhood Plan, with potential for future residential development of up to 16 houses.168 Presumably, this fact will be referenced, in some way, in the Local Plan.
RefID 865: Land to the West of Sandpits Road (additional information)
This site is located within the settlement boundary of Upper / Middle Tysoe. The site is already allocated in the Tysoe Neighbourhood Plan, with potential for future residential development of up to 16 houses.169 Presumably, this fact will be referenced, in some way, in the Local Plan.
168 Tysoe
RefID 323: Land to South of Middleton Close, Upper Tysoe (additional information)
This site is located entirely within the CNL. All of the existing built development at Middle / Upper Tysoe is located outside the CNL and only a tiny section of the settlement boundary extends into the CNL. As such, housing needs associated with Tysoe arise outside the settlement boundary. Government guidance makes it clear that National Landscapes ‘are unlikely to be suitable areas for accommodating unmet needs from adjoining (non-designated) areas’.170 In other words, the CNL should not be expected to accommodate housing needs relating to Middle / Upper Tysoe given that these needs arise outside of the CNL.
Extending development, eastwards, into the CNL would not reflect the (historic) settlement character and form.
Conclusions
We recommend that:
• RefID 865 should be retained as an allocated site in the Tysoe Neighbourhood Plan - this should be referred to in the Local Plan in some way;171 we recommend that the Neighbourhood Plan figure of 13 dwellings should be used (rather than the indicative capacity of 19 dwellings).
• Ref ID 830 should be retained as a strategic reserve site in the Tysoe Neighbourhood Plan - this should be referred to in the Local Plan in some way; we recommend that the Neighbourhood Plan figure of 16 dwellings should be used (rather than the indicative capacity of 32 dwellings).
In addition to these two sites, the Neighbourhood Plan allocates an additional site for two dwellings. So, in total, the Neighbourhood Plan already makes provision for 31 dwellings. This represents a 6% increase in the number of dwellings in Tysoe parish, compared to the 2021 census baseline. This already slightly exceeds the Board’s 5% ‘rule of thumb’ threshold for proportionality. As such, we recommend that now additional housing should be allocated. However, we acknowledge that the Neighbourhood Plan only runs to 2031, whereas the Local Plan runs to 2050. We also acknowledge that Tysoe is a Category 2 Local Service Village. Therefore, if there were circumstances that merited a higher level of housing provision, the following sites potentially merit further consideration:
• RefID 296.
• RefID 24 (subject to the mitigation measures that we have recommended).
All of the other Tysoe sites should be sifted out and not given further consideration.

Yes

ID sylw: 107289

Derbyniwyd: 07/03/2025

Ymatebydd: Cotswolds National Landscape Board

RefID 688: Land north of Mollington Lane, Warmington, Banbury, OX17 1BS (additional information)
The vast majority of built development at Warmington (and most of the settlement boundary and conservation area) is located within the CNL. As such, we consider Warmington to be a CNL settlement. However, site RefID 688, itself, is located outside of - but adjacent to - the CNL boundary.
The site is located on relatively flat land on the northern edge of Warmington, which, in effect, is an extension of Landscape Character Type (LCT) 19 (Unwooded Vale),176 whereas most of the village of Warmington slopes down the Cotswold escarpment (LCT 2)177. This site itself is undeveloped but there is existing development on its west, south and east side. The northern boundary of the site appears to be well vegetated, although the vegetation is quite gappy (being primarily trees rather than hedgerow).
The site does not appear to be overlooked from public rights of way (PROW) on the escarpment. However, a PROW footpath crosses the site itself. This PROW carries both the Macmillan Way and the Battlefields Trail. Development on the site is likely to adversely affect views from this section of footpath, including views looking southwards towards the escarpment. To help reduce potential impacts on the views towards the escarpment we recommend that built development should not extend south of the PROW.
Conclusions
The indicative capacity of RefID 688 far exceeds the Board’s 5% ‘rule of thumb’ threshold for proportionality. However: •
the site would not be overlooked from PROW on the escarpment;
• it is not within the CNL (so this increase would not constitute major development in the context of paragraph 190 of the NPPF);
• the area is only slightly above the 5% threshold;
• as outlined above, the site would potentially be suitable in other regards.
If housing was provided at a lower density than the Local Plan indicative capacity, this site would potentially merit further consideration subject to the following mitigation measures:
• development should not extend south of the PROW that crosses the site;
• planting of a hedgerow on the northern boundary.

Yes

ID sylw: 107292

Derbyniwyd: 07/03/2025

Ymatebydd: Cotswolds National Landscape Board

Land at Long Marston (inc. Long Marston Airfield)
Context
The largest site in the Long Marston area is the potential new settlement, E1, which is referred to in the Preferred Options document as ‘Long Marston Airfield’ and in the interactive map as ‘Land at Long Marston’. In this assessment we will use the name ‘Long Marston Airfield’. This site would cover approximately 771ha and would extend up to approximately 5km from south to north and approximately 2.5km from west to east. The south east corner of the site is adjacent to the CNL. The new settlement has an indicative capacity of nearly 10,000 dwellings.
The new settlement overlaps with multiple sites including, from south to north:
•
RefID 141: Land at Meon Vale / Land to South of Station Road; 190ha (including the existing settlement at Meon Vale and the Rail Innovation Centre, the latter of which is identified as a ‘Major Investment Centre’); identified as a ‘Priority Area 1’.
•
RefID 146: Land to North of Station Road; 128ha (mostly undeveloped at present).
•
Ref ID 310: Long Marston Airfield; 169ha (which doesn’t include the south east corner of the airfield which has already been developed for housing); identified as a ‘Major Investment Site’.
•
RefID 333: North of Long Marston Airfield; 137ha (mostly undeveloped at present);
•
multiple sites to the east of the B4632, east and north-east of Long Marston Airfield (mostly undeveloped at present).
The only part of the proposed new settlement area that currently has a significant amount of built development is the Meon Vale part of the site (approximately 190ha). A new settlement of 771ha would be a 306% increase compared to this baseline, or a four-fold increase.
In addition to the area covered by the proposed new settlement, there are also sites proposed at Long Marston and at Quinton, which, if all were allocated, would significantly increase the size of these settlements in their own right and would add to the overall scale of development as seen from the CNL.
Assessment
The south east corner of the proposed new settlement is adjacent to the CNL boundary and most of it, upper to the north end of Long Marston airfield lies within the CNL 3km buffer zone. When issues such as potential increases in traffic movements are factored in, it could be argued that the whole of the settlement would be within the setting of the CNL.
With this in mind, it is essential to consider the potential impact of the new settlement (and / or its component sites) on the natural beauty of the CNL.
In this regard, it is worth noting that the Sustainability Appraisal states that:
•
New Settlement E1 is identified as the worst performing new settlement against landscape. New Settlement E1 is likely to result in adverse impacts on the local landscape character, views from the PRoW network and coalescence. Additionally, New Settlement E1 is likely to result in significant adverse impacts on the Cotswold National Landscape and its setting, which is located 45m from the new settlement.180 (N.B. Underlining added for emphasis).
The potential impacts on the CNL are discussed in more detail below.
Impacts on the scenic beauty of the CNL (including views from Meon Hill)
Meon Hill is located within Landscape Character Type (LCT) 1 (Escarpment Outliers), specifically Landscape Character Area LCT 1F (Escarpment Outliers - Meon and Ebrington Hills).181 One of the key features / characteristics of LCT 1 is the ‘dramatic panoramic views’ from the escarpment outliers, including Meon Hill. A Public Right of Way (PROW) footpath runs around the northern and western sides of Meon Hill, with the Heart of England Way, Monarch’s Way and Centenary Way using this PROW. Therefore, a key consideration should be the impact of the new settlement (and / or its component sites) on views from this PROW.
The New Settlement Methodology includes consideration of landscape sensitivity.182 If a proposed new settlement includes ‘landscape descriptor units’ (LDUs) with ‘very high’ or ‘high’ visual sensitivity, it is classed as ‘red’ if it includes LDUs with ‘moderate’ visual sensitivity it is classed as ‘amber’. The proposed new settlement E1 is classed as being ‘amber’, in this regard. Given that the settlement would be overlooked from PROW on Meon Hill and that the panoramic views that would be experienced from these PROW are one of the key features / characteristics of LCT1, we do not consider that the ‘amber’ rating for landscape sensitivity is appropriate. We consider that a ‘red’ rating would be more appropriate.
We acknowledge that the part of the proposed new settlement that is closest to the CNL, Meon Vale, is already developed. This existing development would be the most dominant aspect of the new settlement in views from PROW on the north-west side of Meon Hill (i.e. from the Heart of England Way). The magnitude of change in these views, resulting from the additional development in the new settlement, would be relatively limited (but not necessarily negligible).
New development in the new settlement would be further away from the CNL (approximately 1.3km, or more, from the PROW on Meon Hill). However, the existing development at Long Marston Airfield, for example, is clearly visible from PROW on the north-east side of Meon Hill (i.e. from the Monarch’s Way / Centenary Way), albeit beyond the existing built development at Quinton. Additional development at Long Marston Arfield would be clearly discernible in these views.
The sheer scale of what is being proposed means that the new settlement is likely to be more visually prominent, in views from the CNL, than the current baseline. As such, the magnitude of change in these views is likely to be at least ‘small adverse’ and not negligible. When combined with the ‘high’ value of the visual receptors on these PROW, this would result in at least a ‘moderate adverse’ visual effect.
Impacts on views from the CNL could potentially be moderated, to some degree, by requiring appropriate landscape mitigation measures, including hedgerow planting and tree planting, at the southern and eastern boundaries of the settlement. Landscape mitigation measures should also be undertaken within each site and between each site. For example, it may be appropriate to have tree belts between: RefID 141 and RefID 146; Ref ID 146 and RefID 310; and RefID 310 and RefID 333. This would help to ‘break up’ the mass of development that would be perceived in views from the PROW on Meon Hill.
Impact on cultural heritage of CNL
Another consideration relevant to Meon Hill is the potential impact of the proposed new settlement (and / or its component sites) on the setting of hillfort on top of Meon Hill, which is a scheduled monument. This impact will need to be assessed.
Impacts on the relative tranquillity of the CNL
The scale of the proposed new settlement (and / or its component sites) is likely to result in a significant increase in the number of traffic movements generated in this locality, even factoring in the potential provision of a new train station at Long Marston and the reopening of the Stratford-Honeybourne train line. This could significantly increase the number of traffic movements on roads within the CNL and along its boundary.
The Board’s Tranquillity Position Statement states that an increase in traffic movements of 10% or more is likely to have a significant adverse impact on the relative tranquillity of the CNL, which is one of the CNL’s ‘special qualities’.183 Given the scale of the proposed development is it quite likely that this threshold would be exceeded.
This is potentially the most significant issue with regards to potential impacts on the natural beauty of the CNL. The dark skies of the CNL are one of the area’s ‘special qualities’. The existing development at Meon Vale already impacts on the dark skies of the CNL to some degree, as shown in the map below. The scale of the proposed new settlement (and / or its component sites, including the Rail Innovation Centre) could significantly exacerbate this issue.
To help address this issue, lighting should be avoided where possible and, where lighting is installed, this should comply with best practice standards. Consideration should also be given to reducing, or removing, existing sources of lighting, such as at the roundabout on the south-east corner of the Meon Vale development.
Conclusions
Overall, we consider that New Settlement E1, when considered in its entirety, is likely to have a significant adverse effect on the natural beauty of the CNL, compared to the current baseline, particularly with regards to the impact of increased traffic movements on roads through - and along the boundary of - the CNL. We also consider that there would be adverse effects in relation to:
•
the scenic beauty of the CNL, particularly with regards to impacts on views from the public rights of way on Meon Hill;
•
the setting of the scheduled monument on Meon Hill (a multivallate hillfort);
•
the dark skies of the CNL.
On this basis, we recommend that New Settlement E1 should not be allocated, at least not in its entirety.
We acknowledge that there is likely to be further development at Meon Vale, including at the Rail Innovation Centre. We also acknowledge that Long Marston Airfield (as defined by the existing settlement boundary) is already allocated as a new settlement in Stratford-on-Avon District’s adopted Core Strategy.184 As such, our main recommendation for these two sites is to provide appropriate / additional landscape mitigation along the southern and eastern boundaries of each site and including trees and hedgerows. If necessary, this should include a tree belt, rather than a small number of individual trees. Consideration should also be given to appropriate landscape mitigation within the sites, to reduce the mass of development that would be perceived in views from the CNL.
Elsewhere within the boundary of the proposed New Settlement E1, we recommend that there should be no built development and no coalescence between Meon Vale and Long Marston Airfield. Development should also be avoided that would create a sense of coalescence with Lower Quinton and / or Upper Quinton. Ideally, development should not extend eastwards of the B4632 (Campden Road) or northwards of Long Marston Airfield. The total quantum of development within the boundary of proposed New Settlement E1 should be at a level where the resulting increase in traffic movements on roads through - and along the boundary of - the CNL would not exceed 10%.
Measures should also be taken to reduce existing sources of lighting, including at the roundabout on the south-east corner of the Meon Vale site.

Yes

ID sylw: 107293

Derbyniwyd: 07/03/2025

Ymatebydd: Cotswolds National Landscape Board

Lower Quinton
For context, it is worth noting that the Quinton Neighbourhood Plan includes a map of land parcels / sites adjacent to Quinton that are considered to be potentially deliverable (with potentially deliverable sites shaded amber and cross hatched).186
Approximately 75% of the hamlet of Upper Quinton, including the heart of the hamlet, at The Green, is located within the CNL. As such, we consider Upper Quinton to be a CNL settlement. The whole of the village of Lower Quinton is located outside of the CNL but is still within the setting of the CNL. At present, the minimum gap between the settlement boundaries of Upper and Lower Quinton is approximately 130m, on the west side of Goose Lane.
Summary of Quinton sites
There are six sites in consideration in the vicinity of Upper and Lower Quinton:
•
RefID 151: Land to the North of Tailor’s Lane; 4.21ha (indicative capacity = 138 dwellings).
•
RefID 410: Land East of Goose Lane; 1.17ha (indicative capacity = 38 dwellings).
•
RefID 414: Lower Quinton Garage; 2.05ha (indicative capacity = 67 dwellings).
•
RefID 431: Land at Goose Lane; 9.05ha (indicative capacity = 298 dwellings).
•
RefID508: Land North of Main Road; 11.77ha (indicative capacity = 235 dwellings).
• RefID 822: East of Goose Lane; 1.72ha (indicative capacity = 56 dwellings).
None of the sites are located within the CNL but two (RefID 151 and RefID 414) are adjacent to the CNL boundary and all the sites are within the setting of the CNL.
A key consideration for these sites is the extent to which they would impact on views from public rights of way (PROW) within the CNL, particularly the Heart of England Way, Monarch’s Way and Centenary Way on the norther slopes of Meon Hill.
RefID 151: Land to the North of Tailor’s Lane
RefID 151 is adjacent to the CNL. It would form an extension to Upper Quinton and, at 4.21ha in size, would increase the size of the settlement by approximately 50%, compared to the baseline area of approximately 8.52ha. Given that Upper Quinton is a CNL settlement, we consider that it would be appropriate to apply the 5% ‘rule of thumb’ threshold for proportionality. The site would be 10 times larger than this threshold.
In conjunction with RefID 414, it would increase the size of the settlement of Upper Quinton by approximately 75%. This would be 15 times larger than the 5% ‘rule of thumb’ threshold for proportionality.
The settlement boundary of Upper Quinton currently extends approximately 150m north of Tailor’s Lane. RefID 151 would extend the settlement boundary a further 180m northwards. It would bring the northern limit of the settlement boundary of Upper Quinton as far north as the southern limit of the settlement boundary of Lower Quinton.
Even if the site didn’t extend beyond the current northern limit of built development for Upper Quinton, it would still cover 2ha, which would be a 23% increase compared to the current settlement area baseline of 8.5ha. This is five times larger than the 5% ‘rule of thumb’ threshold for proportionality.
In conjunction with RefID 431 it would result in the coalescence of Upper and Lower Quinton.
In the Quinton Neighbourhood Plan the southern half of the site is shown as not being potentially deliverable and the northern half of the site is not considered in this regard.187
The Neighbourhood Plan also shows that the entire site is ‘ridge and furrow’.188 This ridge and furrow land is contiguous with - and is a continuation of - the ridge and furrow land in the CNL. This provided a continuity in landscape character between the CNL and the adjacent land.
In north-facing views from the Heart of England Way, west of Upper Quinton, there is currently an undeveloped gap of approximately 815m between the Heart of England Way and built development at Lower Quinton. However, RefID 151 would reduce this undeveloped gap to just 330m. Allocating the site would, therefore, have a significant adverse impact on these views.
RefID 410: Land East of Goose Lane
Ref ID 410 is on the south-east side of Lower Quinton, south of - and adjacent to - RefID 822. It would bring the built development of Lower Quinton a further 60m south than RefID 822, although it would not extend the southern limit of built development on the opposite side of Goose Lane.
In the Quinton Neighbourhood Plan, the site was identified as not being potentially deliverable.
The site is clearly visible in views from the Monarch’s Way / Centenary Way on Meon Hill, to the east of Upper Quinton. However, in these views, the site is in front of existing, recently built development. It would be more prominent in these views than RefID 822. As such, it would be more appropriate to develop RefID 822, which is already a reserve site in the Quinton Neighbourhood Plan.
The southern edge of the site does not follow an existing field boundary. As such, it is very exposed in views from the CNL. If the site was to be allocated or development was to be permitted, a new hedgerow should be planted along the southern boundary together with some additional tree planting along this boundary.
Overall, compared to the current baseline, we consider that allocating the site would harm the natural beauty of the CNL, particularly with regards to impacts on views from the CNL. However, if Ref ID 822 was to be allocated / developed first, the impact on views from the CNL would be more limited.
RefID 414: Lower Quinton Garage
RefID 414 is on the boundary of the CNL. It would be an extension to Upper Quinton. At 2.05ha in size, it would increase the size of the settlement by approximately 24%, compared to the current baseline of 8.5ha. Given that Upper Quinton is a CNL settlement, we consider that it would be appropriate to apply the 5% ‘rule of thumb’ threshold for proportionality. An increase of 8.5ha would be five times larger than the 5% ‘rule of thumb’ threshold for proportionality.
There is already some built development on site for an agricultural services company. This includes a large barn-type structure. In addition, there is currently a lot of machinery and vehicles on site, which creates a sense of visual clutter, for example, when viewed from the Monarch’s Way / Centenary Way, within the CNL on Meon Hill.
Well-designed housing could potentially be less intrusive, in these views, than the existing use of the site. However, the main part of the site is not contiguous with the existing settlement of Upper Quinton, being approximately 30m from the current settlement boundary. This gap is clearly visible in views from the Monarch’s Way / Centenary Way. Developing the site for housing would also be at odds with the existing (and historic) settlement pattern at Upper Quinton, which is focussed around Hill Lane and Tailor’s Lane.
On balance, we consider that allocating the site would harm the natural beauty of the CNL, particularly in relation to impacts on views from the CNL.
RefID 431: Land at Goose Lane
Allocating the whole of RefID 431 would result in the coalescence of Upper and Lower Quinton. This would result in Upper Quinton losing its character as a hamlet within the CNL and would, instead, create a perception of urban sprawl spreading up to and into the CNL.
When viewed from PROW within the CNL, particularly the Monarch’s Way, on Meon Hill, to the west of Upper Quinton, the southern half of the site can be seen quite clearly whereas the western part of the northern half is well screened by an existing hedgerow. Development on the northern half of the site would be viewed in the context of the existing built development immediately to the north, and could potentially be accommodated without harming the natural beauty of the CNL. In contrast, development on the southern half would be more prominent in these views and is likely to harm the natural beauty of the CNL.
The Quinton Neighbourhood Plan (Figure 11) identifies that the northern half of the site would be potentially deliverable. We would agree with this conclusion, providing that a robust hedgerow, with an additional tree planting, was planted along the full length of the southern edge of northern half of the site. Ideally, development should not extend further south than the adjacent built development. It should certainly not extend further south than the current southern limit of built development in Upper Quinton (i.e. Meon Medical Centre).
RefID508: Land North of Main Road
RefID 508 is on the north side of Lower Quinton (i.e. on the opposite side of Lower Quinton from the CNL). It is approximately 680m from the CNL boundary and approximately 1.3km from elevated views on PROW within the CNL.
The site would be partially visible in views from the PROW to the south east of Upper Quinton (i.e. Monarch’s Way / Centenary) but the magnitude of change in these views is likely to be limited because of the intervening, built development. The site would be less discernible in views from the PROW to the south west of Upper Quinton (i.e. the Heart of England Way). Any potential impacts could be minimised by ensuring that the southern boundary of the site is well vegetated (i.e. hedgerow and trees).
Overall, we consider that allocating this site would not adversely affect the natural beauty of the CNL, including views from the CNL.
RefID 822: East of Goose Lane
RefID is located on the south-east side of Lower Quinton, immediately to the south of some relatively recent built development. In the Quinton Neighbourhood Plan, the site is identified as being potentially deliverable and is allocated as a Reserve Housing Site, with the potential for future residential development of up to 30 dwellings (Policy HO.2).189 Policy HO.2 specifies that the site will only be released during the plan period (i.e. before 2031) if it can be demonstrated, through the submission of evidence, that there is an identified need for its early release. Policy HO.2 also specifies that an updated landscape sensitivity assessment should be provided as part of any future planning application for the reserve site, paying specific attention to the proximity of the CNL.
The existing built development, north of RefID 822, comes within approximately 1km of elevated views on PROW in the CNL (specifically the Monarch’s Way / Centenary Way) south east of Upper Quinton). Allocating RefID 822 would bring built development within approximately 900m of these views. However, in these views, development on the site would be seen in the context of the adjacent built development to the north. The field is also partly screened by an existing hedgerow on its southern boundary. As such, the magnitude of change in these views would be limited, possibly negligible. Potential impacts could be further mitigated by planting trees along the hedgerow on the southern boundary.
Conclusions
A clear gap should be retained between Upper and Lower Quinton to avoid coalescence between the two settlements. Ideally, development at Lower Quinton should not extend further south than the current southern limit of built development and development at Upper Quinton should not extend further north than the current northern limit of built development.
It is important that Upper Quinton should retain its character as a hamlet and not expand to the extent that it would be considered a settlement. Further consideration should be given to RefID 822 as it is already identified as a Reserve Housing Site (and as being potentially deliverable) in the Quinton Neighbourhood Plan.190 At the very least, reference should be made to this fact in the Local Plan. Adverse impacts on views from the CNL are likely to be minimal.
The Neighbourhood Plan covers the period 2011-2031, whereas the Local Plan would cover the period up to 2050. As such, we acknowledge that additional housing may be required in Lower Quinton during the Plan period.
If further housing is required, we consider that the following sites should potentially be given further consideration:
•
RefID 431 (northern half)
•
RefID 508
We recommend that the following sites should be sifted out and not given further consideration:
•
RefID 151.
•
RefID 410 (at least until RefID 822 has been developed).
•
RefID 414.
•
RefID 431 (southern half)
When allocating sites at Lower Quinton, consideration should still be given to whether the allocations, both individually and collectively, would be proportionate to the existing settlement. As outlined above, the Board applies a 5% rule of thumb threshold for proportionality for settlements within and directly adjacent to the CNL. However, given that Lower Quinton is not directly adjacent to the CNL boundary and given that it is a Category 1 Local Service Village, a higher threshold may be appropriate (e.g. 10%). Not exceeding this threshold would help to ensure that, in views from the CNL, there does not appear to be a significant increase in the scale and extent of built development at Lower Quinton.
Finally, we have some concerns regarding the Priority Area zoning that overlaps with this part of the CNL, including Upper Quinton. Upper Quinton lies within:
•
the Priority Area 2 ‘buffer’ zone relating to Meon Vale;
•
the Priority Area 3 zone relating to Lower Quinton.
We acknowledge that the zoning is just based on set distances from particular locations. However, in the context of the CNL, it should be more nuanced than this. Ideally, the CNL, including Upper Quinton, should be excluded from these Priority Area zones. There are two main reasons for this, as outlined below.
Firstly, national planning policy requires the scale and extent of development in National Landscapes to be limited. Inclusion within the Priority Area zones risks proposals being put forward, within and / or directly adjacent to, the CNL that would conflict with this policy requirement.
Secondly, national Planning Practice Guidance states that National Landscapes ‘are unlikely to be suitable areas for accommodating unmet needs from adjoining (non-designated) areas’.191 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’.192 As such, the CNL, including Upper Quinton, should not be expected to accommodate growth relating primarily to Meon Vale / Long Marston and Lower Quinton. Growth at Lower Quinton should also take into account potential impacts on views from the CNL and potential increases in traffic movements on roads through - and along the boundary of - the CNL.

Yes

ID sylw: 107294

Derbyniwyd: 07/03/2025

Ymatebydd: Cotswolds National Landscape Board

Shipston on Stour
Summary of Shipston on Stour sites
In the draft Local Plan, Shipston on Stour is identified as:
•
a small town;
•
a ‘Priority Area 1’ location, with a ‘Priority Area 2’ buffer;
•
a Strategic Growth Location (with all of the potential allocations being collectively classed as Strategic Growth Location SG17 (Shipston on Stour Group)).
There are approximately 14 sites in consideration at Shipston on Stour. From a CNL perspective, the largest and most significant sites are Ref ID 148 and Ref ID 747, on the east side of Shipston on Stour and within the CNL 3km buffer.
•
Ref ID 148: Land at Fell Mill Farm, Shipston; 33.91ha (indicative capacity = 678 dwellings).
•
Ref ID 747: Land at Leasow Farm; 47.45ha (indicative capacity = 909).
The other sites are smaller in scale and are mostly located on the west side of CNL, outside the CNL 3km buffer (and on the opposite side of the town from the closest part of the CNL), although RefID 689 protrudes incongruously into the open countryside.
Potential impacts on the natural beauty of the CNL
Sustainability appraisal
The Sustainability Appraisal states:
•
The Shipston-on-Stour SGL is likely to impact long-reaching views from the Cotswolds National Landscape. The closest point to of the SGL in the east lies 1.6km from the National Landscape, whilst the southernmost point of the SGL is located approximately 3.2km from the designation. Ebrington Hill is the tallest hill in the Plan area which lies in the south west of the Stratford-on-Avon District with an elevation of 261m. The SGLs in proximity to Ebrington Hill, most namely Shipston-on-Stour, have the potential to impact views from the peak. However, it is worth noting that Shipston-on-Stour is surrounded by built form. Overall, a minor negative impact is expected for Shipston-on-Stour on landscape.194
RefID 148 and RefID747
The largest sites within SGL 17 and, therefore, the sites that are likely to be the most visually intrusive, with regards to views from the CNL, are sites RefID 148 and RefID 747, on the eastern side of Shipston-on-Stour, which, together, cover 81ha.
RefID 747comes within approximately 1.7km of the CNL boundary and within approximately 2km of elevated views from public rights of way (PROW) on the western slopes of Brailes Hill, within the CNL. The existing settlement boundary on the west side of Ref ID 747 is approximately 2.7km from the CNL boundary so RefID 747 would bring built development 1km closer to the CNL (or 37% closer).
RefID 148 comes within approximately 2.2km of the CNL boundary and within approximately 2.5km of elevated views from PROW on the western slopes of Brailes Hill, within the CNL. The existing settlement boundary on the west side of RefID148 is approximately 2.8km from the CNL boundary so RefID 148 would bring built development approximately 600m closer to the CNL (or 21% closer).
Brailes Hill is located within Landscape Character Type (LCT) 1 - Escarpment Outliers.195 More specifically, it is located within Landscape Character Area 1G (Escarpment Outliers - Brailes Hill and Castle Hill). One of the key features of LCT 1 is the ‘dramatic panoramic views from upper slopes’. Therefore, an important consideration, with regards to the Shipston on Stour sites (particularly RefID 148 and RefID 747) is the potential impact on these panoramic views from Brailes Hill.
The scale and extent of RefID 148 and RefID 747, including the extent to which they extend built development towards the CNL, means that development on these sites is likely to be a prominent feature in views from PROW on Brailes Hill. This development would significantly increase the prominence of Shipston on Stour in these views. However, there are a couple of small hills to the east of the site, including Borough Hill, which might help to reduce the visual impact of these sites.
RefID 747 could potentially also have an adverse impact on views looking towards the CNL, for example with regards to views from Fell Mill Lane, which passes through the site and which forms part of National Cycle Route 48.
It is worth noting that the western section of these two sites is identified as an ‘area of restraint’ in the adopted Core Strategy on the basis that makes an important contribution to the character of the settlement.196 Parts of the two sites are also within the floodplain, which the Core Strategy identifies as being ‘an overriding constraint to development’.197 These constraints further restrict the scope for development on these two sites.
RefID 689
RefID 689, which protrudes incongruously into the open countryside on the north side of Shipston-on-Stour, could also have an adverse impact on views from the CNL.
Traffic movements / tranquillity
Given the scale of development that is being considered at Shipston on Stour, there is likely to be a significant increase in the number of traffic movements generated in Shipston. This, in turn, could potentially increase the number of traffic movements on roads within - and along the boundary of the CNL (to the east, west and south of Shipston on Stour). As outlined in the Board’s Tranquillity Position Statement (Section 4.5), we consider that an increase in traffic movements of more than 10% would be significant and would adversely affect the relative tranquillity of the CNL.
Conclusions
We recommend that RefID 148 and RefID 747 should not be taken forward, at least not to their full extent.
If any development is allocated on RefID 747, we recommend that the site boundary should not extend further east / south-east than Fell Mill Lane, where it passes through the site. This would help to prevent development extending over the brow / ridge of Borough Hill and becoming more visible in views from the CNL. It would also help to avoid adverse impacts on views from Fell Mill Lane towards the CNL.
For both sites, development should also not extend into the ‘area of restraint’ or into the floodplain.
Ideally, RefID 689 should also not be taken forward.
The other sites within SGL 17 would potentially be acceptable, from a CNL perspective, as they are smaller in scale and more in keeping with the existing settlement pattern
We recommend that further assessments should be undertaken to assess the visual impacts of RefID 148, Ref ID 689 RefID 747 on views from the CNL. We also recommend that an assessment should be undertaken of the likely increase in traffic movements that would result from the allocations at Shipston, including on roads within - and along the boundary of - the CNL.

Yes

ID sylw: 107295

Derbyniwyd: 07/03/2025

Ymatebydd: Cotswolds National Landscape Board

Oxhill
Summary of Oxhill sites
Oxhill is located approximately 2km from the boundary of the CNL. As such, it lies within the CNL 3km buffer zone, within which consideration should be given to potential impacts on the natural beauty of the CNL (for example, potential impacts on views from the CNL).
The Preferred Options document identifies three sites for further consideration:
•
RefID 29: Land adjacent to Hares Breath, Whatcote Road, Oxhill (2.11ha).
•
RefID 663: Land off Green Lane, Oxhill (23.05ha), which includes the area covered by:
o
RefID 754: Green Lane, Oxhill (3.18ha)
RefID 663 is, therefore, by far the largest site and is the site that is most likely to impact on views from the CNL.
Assessment
RefID 663 comes within approximately 2.1km of the CNL boundary and within approximately 3km of elevated views from public rights of way (PROW), within the CNL, on the slopes of Windmill Hill. Windmill Hill is located within Landscape Character Type (LCT) 6 - Ironstone Hills and Valleys.198 More specifically, it is located within Landscape Character Area 6A - Ironstone Hills and Valleys (Whichford Hills and Valleys). One of the key features / characteristics of LCT 6 is the ‘dramatic sweeping views over wide areas of the landscape’. Therefore, a key consideration will be the extent to which the sites at Oxhill, particularly RefID 663.
The settlement boundary of Oxhill covers approximately 20ha. Ref ID 663 and RefID 29 would increase this area by 24.16ha. In other words, the area of built development would be more than doubled. As such, development on these sites could result in Oxhill becoming more prominent in views from the CNL.
However, the PROW on Windmill Hill are orientated in a south-west to north-east direction, whereas Oxhill is to the north-west of Windmill Hill. As such, the Oxhill area is not likely to be a primary focal point for users of these PROW. Also, the top of Windmill Hill is encircled by trees, limiting the views that can be experienced across the wider landscape.
Conclusions
We recommend that further assessments should be undertaken to assess the potential visual impact of RefID 663 on views from the CNL.

No

ID sylw: 107305

Derbyniwyd: 26/02/2025

Ymatebydd: Mr Mark Gleaves

The area bounded by REFID 400 is also included in the area bounded by REFID 123. This double-counts capacity.

The sites <10 ha are proposed to be denser than even 2 existing Bearley estates and the forthcoming site with outline permission. This is contrary to the village's character.

Sites 123 and 590 will exacerbate surface water flooding on the Grange Road estate. Runoff from these sites already contributes to flooding on Site 400. 60% of that site is expected to be prone to surface water flooding by 2040-60 (see government long-term flood risk maps). These sites contribute to flooding on the sports field, sports club, the A3400 and beneath Bearley railway bridge.

Site 123 would intensify use of two narrow and poorly aligned highways. These junctions present risks for traffic and pedestrians. Use-intensification of the Grange Road/Oaktree Close or School Lane/Old Snitterfield Road routes would exacerbate risk, particularly during rush-hour.

There is only a dirt track access to Site 400 from Snitterfield Road. A through-road to access the adjacent 'landlocked' Site 123 would reduce Site 400's capacity and only one route for potentially 1,000 vehicle movements per day is neither safe nor practical.

Access to Site 590 via Oaktree Close and Grange Road or via Old Snitterfield Road and School Lane is undesirable for the same reasons as for Site 123. Part of the boundary borders Snitterfield Road but there is no access, the land is approx. 1m above Snitterfield Road, and given proximity to the Ash Lane junction, the blind bend by St Mary’s Church, and the Church Lane junction, an access road would make a hazardous section more dangerous.

Development of Site 673 would exacerbate frequency and volume of flooding on Church Lane, Bearley Green estate, and increase volumes of water channelling over Ash Lane and on to proposed Site 765. The only access is via Church Lane and a farm track. Development would intensify use of a narrow and poorly aligned highway and cause danger to traffic and pedestrians (there is no room to incorporate a pavement).

Parts of Site 765 are prone to flooding already. It receives runoff from the A3400 due to its topography. Land should be set aside for SUDs and a green buffer zone in case later expansion is needed. Parts of the site may be required for expansion of waste water treatment works. Access to the A3400 is feasible but would require significant upgrades, particularly if a new school is provided. Traffic would be increased through Wootton Wawen, Henley-in-Arden and at the A46 at Bishopton roundabout. Measures will be needed to prevent Snitterfield Road and Gospel Oak road becoming worse "rat-runs". Most residents will use cars due to flexibility and convenience over public transport outside of a city.

This is Green Belt land, the vast majority never developed. Bearley Bushes is a SSSI to the east. Together with three designated LWS these cover approx 31 ha. There are four potential wildlife sites within 1km of St Mary's Church. These sites support a range of protected species, including common and soprano pipistrelle, brown long-eared bats, lesser horseshoe bats, bats of other (indeterminable) species, grass snakes, and badgers; butterfly species of white admiral, small heath, grizzled skipper, and white letter hairstreak; and great crested newts. Bearley Bushes would lose its last natural border if Site 673 was developed. One of the proposed uses at Site 673 is renewable energy. A study at University of Bristol suggests solar farms are severely detrimental to bats.

LIDAR surveys suggest Roman Fort foundations beneath one of the fields of Site 123.

More realistic capacities are listed below:

Site 123 | 0 dwellings
Site 327 | 37 dwellings
Site 400 | 49 dwellings
Site 590 | 0 dwellings
Site 595 | 46 dwellings
Site 609 | 66 dwellings
Site 632 | 159 dwellings
Site 673 | 0 dwellings
Site 765 | 4685 dwellings

Capacity is therefore c.5000 dwellings - below the 10,000 needed for a sustainable new development and the 6,000 for a new settlement. Proposal BW should therefore no longer be considered.

Yes

ID sylw: 107308

Derbyniwyd: 07/03/2025

Ymatebydd: Campaign to Protect Rural England - Warwickshire

CPRE Warwickshire are giving their support to objections raised by local residents and businesses in Blunts Green to the proposed mixed use development at Little Hallend Farm, Blunts Green, Henley in Arden, included in the South Warwickshire Local Plan Preferred Options Consultation (ID: 737).

1. Introduction
This document presents a formal objection to the proposed mixed-use development at Little Hallend Farm, Blunts Green, Henley-in-Arden, as identified in the Housing and Economic Land Availability Assessment (HELAA) (RefID: 737) and included in the South Warwickshire Local Plan Preferred Options Consultation.
The site is currently under assessment and has not yet reached the formal planning application stage. However, its inclusion in the Local Plan Preferred Options would significantly increase the likelihood of future development. Given the numerous constraints identified in the HELAA and other supporting planning documents, this objection sets out the key material planning concerns that justify the removal of the site from the Local Plan.

2. Access Constraints and Highways Impact
The proposed access to the site is via Hall End Road, a single-track road, only accessible via another single- track road with a 4.1m railway bridge, restricting larger vehicle access. It is wholly unsuitable for increased traffic volume associated with a mixed-use development. Key concerns include:
Limited road width: Hall End Road is a narrow, single-track rural lane, making it unsuitable for construction traffic, delivery vehicles, and the increased number of residential or commercial vehicle movements.
Equestrian Facilities: The lane serves existing equestrian facilities and a veterinary practice, with regular use by horse riders, making increased traffic a significant safety risk.
Lack of pedestrian footpaths and lighting: The road has no pedestrian infrastructure, making it unsafe for increased pedestrian movement that would result from development.
Impact on emergency services access: The limited width and lack of alternative routes would severely impact emergency service response times.
Conflict with Local Transport Policies: The proposal conflicts with policies requiring safe and suitable access for all users under National Planning Policy Framework (NPPF) Paragraph 110 and 111. The potential for increased vehicle movements along an inadequate rural lane is contrary to Warwickshire Local Transport Plan and Stratford-on-Avon's adopted Core Strategy Policy CS.26.

3. Environmental and Landscape Impact
The site is currently pastureland and contributes to the open countryside character of the area. The proposed development would:
Harm rural landscape character, conflicting with NPPF Paragraph 174, which requires the protection of valued landscapes.
Impact biodiversity: The site is within proximity to Local Wildlife Sites, as identified in the HELAA assessment, and development would result in loss of habitat and hedgerows.
Increase flood risk: Any development would need to ensure no adverse impact on local drainage patterns, given Stratford-on-Avon District Council's Strategic Flood Risk Assessment considerations.

4. Lack of Infrastructure Capacity
No local public transport connections: The site lacks bus or rail access, leading to increased car dependency, contrary to NPPF sustainable transport objectives.
Limited school and healthcare provision: Local primary and secondary schools are oversubscribed, and additional housing would place unacceptable strain on healthcare services.

5. Non-Compliance with Planning Policies
The proposed site allocation conflicts with multiple planning policies, including:
National Planning Policy Framework (NPPF) Paragraphs 110, 111, 174 (regarding access, landscape, and environmental impacts).
Stratford-on-Avon Core Strategy Policies CS.1, CS.5, CS.9, CS.26 (protecting countryside, transport access, and rural character).
Warwickshire Local Transport Plan (promoting sustainable transport and road safety).

6. Conclusion
The inclusion of Little Hallend Farm (RefID: 737) in the Local Plan should be reconsidered due to severe highway constraints, environmental concerns, infrastructure inadequacies, and policy conflicts.
Given the material planning issues outlined above, it is requested that the site is removed from the Local Plan Preferred Options to prevent significant adverse impacts on the surrounding area and local community..

No

ID sylw: 107314

Derbyniwyd: 03/03/2025

Ymatebydd: Exhall Parish Council

There is a submission under Refid 16 which will affect the villages of Exhall & Ardens Grafton given the elevated location of the fields in an area of high visual impact. It is also important to note that whilst being in the parish of Exhall the proposal falls under the village of Ardens Grafton which is a non-service village.

No

ID sylw: 107349

Derbyniwyd: 05/03/2025

Ymatebydd: Alcester Town Council and Arrow with Weethley Parish Council

Alcester needs affordable housing but the proposed sites in the SWLP are unsuitable.

There is no nearby train service. The most accessible is Stratford Parkway, which takes 42 minutes via bus. Busses run approximately hourly. It takes approximately half-an-hour to get to Stratford-upon-Avon or Redditch. Getting to Warwick Hospital takes 90 minutes and 3 bus journeys.

Local primary and secondary schools in Alcester are at capacity. Alcester Academy and St Benedict’s are Academies so cannot be forced to expand by the Local Education Authority. According to available information on school places, local schools can manage demand from already-permitted sites but not the level envisaged under SG21.

The IDP indicates doctors' surgeries have 2349 patients per GP, exceeding national averages. Anecdotal evidence suggests difficulty in getting routine appointments in 3 weeks. Thousands more dwellings would increase demand. Warwick Hospital recently declared a critical emergency. Increasing population in Alcester would put further pressure on local hospitals. No dentists in Alcester are taking NHS patients.

The Alne and Arrow join on Alcester's outskirts and when they flood they engulf part of the town. Alcester has flooded 22 times since 1864. The flooding in 2007 was the worst flood event for 250+ years and 200 homes were left uninhabitable. There are regular flood alerts/warnings. The storage tank as part of the Alcester flood scheme only gives 12 minutes warning when full. The SFRA highlights considerable issues from pluvial and fluvial flooding. Alcester Town Council understands the Environment Agency's flood defence assets need considerable work due to little investment since installation.

Except for Site 411 and Site 512, sites proposed for development absorb surface water and act as flood plains. Development could increase the risk of flooding in areas already at high risk in Alcester and further downstream. The built-up boundary provides limited housing development opportunity due to the flood plain. Most proposed sites outside SG21 scored poorly due to flooding constraints.

Other

ID sylw: 107372

Derbyniwyd: 05/03/2025

Ymatebydd: Alcester Town Council and Arrow with Weethley Parish Council

Alcester Town Council is aware of the potential of some of the Allimore Lane sites. The NDP working group is looking at potential sites for affordable local needs housing - one or more of the Allimore Lane sites may be suitable. However there are still some issues that would need to be overcome, particularly given the scale of 772 dwellings across the five locations.

The sites are on the edge of town, some distance from local amenities, schools and doctors. Policy NE4 of the adopted NDP protects Valued Landscape 4 around Allimore Lane. The bridge would be insufficient for significant additional traffic so another vehicles access route would be required into Alcester. A pavement isn't possible due to the narrowing at the bridge. A shared pedestrian/vehicle space isn't suitable if there is increased traffic.

The sites score amber in the HELAA due to greenfield status, the minerals safeguarding area, because some parts are in Flood Zone 2 and 3, they are within 500m of a listed building and a scheduled monument, and within 25m of a Local Wildlife Site. There are many trees protected by Tree Preservation Orders on adjoining land. Allimore Lane is part of the route of the historic Monarch’s Way. Any development close to this nationally recognised public footpath must be sensitive to avoid impacting the route's amenity.

No

ID sylw: 107373

Derbyniwyd: 05/03/2025

Ymatebydd: Alcester Town Council and Arrow with Weethley Parish Council

REFID 445

Some of this land is in the parish of Arrow & Weethley. There are significant flooding issues – the HELAA states that 22% is within Flood Zones 2 & 3 and subject to surface water flooding. A significant amount of space around the flood zone is required. None of this site lies within 200m of a primary school. The site would fall outside of the ‘20-minute neighbourhood’ principle.

ATCAW does not consider that this is 12.72 hectares of developable land.

Public footpath AL49 runs across the site. Access would have to be from the A435 dual carriageway or Evesham Street which would be unviable and prohibitively expensive. It would not be possible to develop the whole site with only access via Allimore Lane. The site contains a Valued Landscape location looking towards the bridge on Allimore Lane, protected by Policy NE4 of Alcester’s NDP. Appendix 3 explains that preservation of Allimore Lane, which has little traffic and is extensively used by walkers, is important.

100% of this site is in a minerals safeguarding area. 2% of this site is located within 500m of a rural scheduled monument and 19% is within 500m of rural listed buildings. 14% of this site is within 25m of a known or potential Local Wildlife Site. Furthermore, 100% of the site intersects with an area with a baseline habitat score of 40-80.

Yes

ID sylw: 107387

Derbyniwyd: 04/03/2025

Ymatebydd: Mr & Mrs - Blackhurst

Asiant : Frampton Town Planning

The site benefits from nearby access to Lapworth Station. Access to the station is located 0.2 km from the site and would take 3 minutes to walk. There are existing footpaths running from the site access to the station.
Lapworth Station provides direct services to Birmingham, Solihull, Warwick and Leamington Spa. Indirect journeys are available to London.
Lapworth Primary School and Pre-school are 0.1 km from the site, with Lapworth Village Shop 0.3 km walk and the Navigation Inn Pub 0.55 km from the site. Lapworth Village Hall and Lapworth Surgery are located within 0.55 km of the site. Access to the Stratford Canal is also located within 0.5 km.
The site benefits from close access to a range of existing facility as well as public transport connections.
The nearest bus stop is 0.3 km from the site, and served by the 514 service between Solihull and Hatton Green with a single morning and afternoon service Monday to Friday.
The site is centrally located and within a 10-minute walk of the majority of village services.
The site provides an opportunity to deliver an appropriate amount of development in a sustainable location close to a railway station. It is well connected to existing services which would support daily life. However, in the context of Policy Direction 1 and 2 would not be considered (situated outside the 24 Strategic Growth Areas and not within
the 12 possible New Settlements). We would urge the LPA to consider potential sustainable sites, which may be missed by not undertaking a detailed assessment of all
promoted sites.

Yes

ID sylw: 107460

Derbyniwyd: 05/03/2025

Ymatebydd: Temple Grafton Parish Council

Regarding the land proposed in Ardens Grafton and Temple Grafton Refid 16
· The developments are in open countryside in an elevated area
· High visual impact
· Situated in Grade 1 & 2 agricultural land which is currently being actively farmed
· Refid 16 suggests that the land currently has no purpose which is incorrect
· 78% of Refid 16 is within minerals safeguarding area
· 100% is within 25m of Rural listed buildings

Yes

ID sylw: 107462

Derbyniwyd: 05/03/2025

Ymatebydd: Temple Grafton Parish Council

It is sited within an area of high visual impact

· Coalescence between Bidford and Ardens Grafton will result

· The Graftons are non-service villages, with no street lighting, limited sewerage system only in main population areas.

· Land is currently actively farmed – grade 1 & 2

· 2021 SHLAA Land Parcels previously rejected some of the proposed fields (BD03 & BD04) nominated in SG20 on the grounds of environmental suitability, landscape impact , settlement character and agricultural land quality . Due to the elevated and exposed approach of the parcels of land means that effective mitigation cannot be achieved. Nothing has changed in the landscape since the last proposal.

Little Haven Nature Reserve focussing on moth conservation by the old railway line. Part of Warwickshire County Council Local Biodiversity Action plan

Significant increase in the requirement for healthcare primary, social, adult healthcare, screening services, A&E & dental which is already under huge pressure

Yes

ID sylw: 107499

Derbyniwyd: 07/03/2025

Ymatebydd: Suzanne Ross

Asiant : Savills

Site 492 and 827 have been assessed. However, an additional area of land to the west (4.23ha) is submitted for assessment as part of this submission. A Site Location Plan accompanies this submission, the total site area is 8.2ha. See appendix letter. The site is identified as a Reserve Housing Site in the Site Allocations Plan Preferred Options Document (June 2022) – site reference STR.C – South of Alcester Road. The site was identified as having an indicative capacity of 56 dwellings with just the northern part of the site identified for built development. Our client supports the consideration of the site.

The site scores highly in the HELAA (2024) under HELAA reference 492 and 827. Both of these scores are well below the average scores for the sites assessed which demonstrates the Site could be suitable to identify as a small-scale allocation. The additional land falls within the same ownership and the landowner wishes to put forward this as additional land. It is acknowledged that this western parcel of land is more sensitive in terms of heritage, being located within the Shottery Conservation Area rather than
adjacent to it. Notwithstanding this, it is considered that a sensitive development could realistically be developed e.g the western part of the site could provide a large area of public open space and/or land for achieving biodiversity net gain - see Shottery Conservation Area Report findings. 13/02784/FUL context and Heritage Assessment by Purcell which concluded that housing development on the northern part of the site identified as a Reserve Housing Site, would lead to a ‘low level’ of ‘less than substantial harm’ to the character of the conservation area. The site provides opportunities for SMEs which typically face significant barriers.

Yes

ID sylw: 107533

Derbyniwyd: 07/03/2025

Ymatebydd: Warwickshire Wildlife Trust

WWT is extremely concerned regarding the vast number of allocations on and near to important Local Wildlife sites, PLWSs, SSSI, nature reserves, AONB and ancient woodlands and stingly advice the Councils to reassess their sites considering the LWS designation, to avoid impacting legally protected species and designations such as SSSIs and Landacape Areas as well as important wildlife sites.
Below we have listed all of the key allocated Local Wildlife Sites which would be impacted, if the Councils don’t reassess the sites and reconsider. The Council should also be using the most up to date Local Wildlife Site layer and appears to be using old mapping data:
Allocation Housing Sites:
SG01
LWS Whitefield Coppice, Tocil Wood and Brookstray, The Pools Wood, Broadwells Wood, Kenilworth Greenway, Black Waste Wood, Wainbody and Kenilworth Road Woods.
pLWS Old Brickyard Plantation, Bockendon Grange Pond.
Within 50m of the following Local Wildlife Sites Crackley Wood
SG02
LWS River Avon and Tributaries
pLWS Stoneleigh Park, Stonehouse Farm Pools, Dalehouse Lane, Road Verge, River Sowe & Finham Brook & lakes, Hares Parlour & Brick Kiln Spinney, Motslow Hill
Within 50m of the following Local Wildlife Sites Stareton Wood & Stare Hill,
Within 50 m of the following potential Local Wildlife Sites the Rough, Glasshouse Wood.

SG03
pLWS Rowley Lane

SG04
LWS River Avon and Tributaries
pLWS Cattle Brook
Within 50 m of the following potential Local Wildlife Sites Black Spinney

SG06
LWS River Avon and Tributaries

SG07
LWS River Avon and Tributaries
pLWS Budbrooke Farm Woodlands and Black Brake Plantation
Within 50 m of the following potential Local Wildlife Sites Budbrook House Meadows

SG08
LWS River Avon and Tributaries
pLWS Warwick Racecourse

SG09
LWS River Avon and Tributaries
pLWS Plestowes Spinney and Hareway Lane Woodland
Within 50m of the following Local Wildlife Sites Oakley Wood
Within 50 m of the following potential Local Wildlife Site Greys Mallory

SG10
LWS River Avon and Tributaries
pLWS Greys Mallory


SG011
LWS River Avon and Tributaries, Mollington Hill
pLWS Highdown Farm & Highdown Hill Plantation, Field at Fosse Farm, Railway Cutting, Whitnash Meadow.
Within 50m of the following Local Wildlife Site Oakley Wood
Within 50 m of the following potential Local Wildlife Site Chesteron Mill Pool

SG012
LWS Southam Meadow South, Southam Bypass Cutting,
pLWS Mature Elm, Hill Farm Wood
Within 50m of the following Local Wildlife Sites Long Itchington Quarry

SG13
LWS Gaydon Coppice
pLWS Gaydon Proving Ground, Castle Farm Meadows, Kingston Grange Plantation, Bishop's Gorse, Gaydon Covert, Buttercup Meadow, Poolfield Ponds, Chadhunt Hall, Kingston Grange Pools, Chadshunt Spinney
Within 50m of the following potential Local Wildlife Sites River Derve, Gaydon Meadows

SG14
pLWS Itchington Holt, Green Lane, Long Meadows
Within 50 m of the following potential Local Wildlife Sites Castle Farm Meadows
River Itchin - tributaries run throughout this SG14 area.
SG15
LWS Wellesbourne Dene Meadows, River Avon and Tributaries
pLWS River Dene, Firtree Hill Spinney
Within 50 m of the following potential Local Wildlife Sites Charlecote Park, River Dene Floodplain Meadows

SG16
LWS Wellesbourne Dene Meadows, Wellesbourne Woods
pLWS Dene Valley, River Dene Floodplain Meadows, River Dene, Wellesbourne Woods

SG17
pLWS River Stour, Shipston on Stour River Meadows, Sewage Bed

SG18
LWS River Avon and Tributaries, Bordon Hill Old Rifle Range, Clopton House Meadow
pLWS The triangle Hedgerow, Wildmoor, Bishopton Meadow, Woodland near Bishopton Lodge, Site Adjacent to Canal, Oxfordshire, Wolverhampton & Warwickshire Dismantled Railway, Disused Railway
Within 50m of the following Local Wildlife Sites Cadle Pool Farm Meadow,
Within 50 m of the following potential Local Wildlife Sites Drayton Manor Solar Farm, Stratford-upon-Avon Canal, Bordon Hill Field, Drayton Bushes, Welcombe Estate, Billesley Wood, Seven Meadows and Stratford Steeplechase Meadow.


SG19
LWS Bridgetown Fields, River Avon and Tributaries,
pLWS Disused Railway

SG20
LWS River Avon and Tributaries, Broom Old Quarry
pLWS Bidford Golf Course, Summer Hill Roadside Verge and Grassland, Plantation at Waterloo Road
Within 50m of the following Local Wildlife Sites Alcester - Broom Disused Railway

SG21
LWS River Arrow
Within 50m of the following potential Local Wildlife Sites Arrowlane Plantation, Coldcomfort Wood

SG22
LWS River Arrow
pLWS Dismantled Railway

SG23
LWS River Alne, Henley Sidings Nature Reserve, Henley Meadows
pLWS Henley Golf Club Lake site, Dismantled Railway Line

SG24
LWS River Alne
pLWS Hockley Heath Meadow, Stratford on Avon Canal
Within 50m of the following potential Local Wildlife Sites Spring Coppice, School Lane Marsh

Yes

ID sylw: 107546

Derbyniwyd: 05/03/2025

Ymatebydd: Ellis Machinery Ltd

Asiant : Frampton Town Planning

Site ID 444
The site provides an opportunity to deliver an appropriate amount of development in a sustainable location close to existing services and employment opportunities. It is also in a location which is identified as a Strategic Growth Area. We urge the LPA to consider this site, and the opportunity it provides, for inclusion within the SWLP.

Yes

ID sylw: 107551

Derbyniwyd: 26/02/2025

Ymatebydd: Hunningham Parish Council

SWLP Site 569 (Weston under Wetherley South)
In relation to Site 569 (Weston under Wetherley South), it is difficult to understand why this site remains under consideration for the Local Plan as it meets few of the criteria for acceptable development set out in the draft plan.
It does not form part of a proposed Strategic Growth Location, nor does it fall within an identified potential New Settlement Location.
Its HELAA part B ‘harmfulness’ score of 55.27 is well above the mean (44.72) of the 672 sites considered.
Although the HELAA rates the employment prospect of the proposal as AMBER, the actual conclusion of the Employment Land Study (Iceni Projects 2024, App 1, p.201) was that the site was ‘not suitable for employment use on its own’, although ‘some employment land could be provided if a residential development is pursued’. This study also highlighted the proposal’s ‘low-medium market attractiveness’ and ‘poor accessibility’.
The proposed development site is very extensive (92ha). A residential development on this scale would dwarf the adjacent village of Weston under Wetherley and could not possibly be viewed as an extension to an existing settlement.
Intrusion into the Green Belt
The site lies wholly within the Green Belt. Although some development within the Green Belt may be acceptable, a proposal on this scale here would represent a major extension of urban sprawl eastwards from Leamington of the kind Green Belt policy is designed to prevent. It would represent an unfortunate precedent, creating a significant bridgehead for large-scale development beyond the sensible limit for the spread of Leamington now being set by the line of HS2.
Where development within the Green Belt is permitted, it should be as a result of careful consideration and directed towards a particular well-defined purpose. The purpose/rationale for this proposal is, in contrast, notably vague. Its HELAA proposed uses cover the full range from ‘Housing/Residential’, ‘Employment/Industrial/Commercial’, ‘Retail’, ‘Leisure/Community’, to ‘Open space/Biodiversity/Green Infrastructure’. The intention would appear to be primarily to gain planning permission for any purpose that will provide a development capital gain for the landowner, Warwickshire County Council. This is not an exceptional factor justifying development in the Green Belt
Loss of significant agricultural land
This development would involve the loss of 92ha of agricultural land along with the associated farming employment opportunities. The land has added significance as the two farms involved form part of the Warwickshire County Farms and Smallholdings Estate. Although the Estate is seen partly as a source of potential capital receipts, the ‘key purpose of the Estate is to provide an entry into the [farming] industry for young aspiring farmers and to provide opportunities for rural enterprise. The Estate contributes significantly to the county in terms of promoting sustainable rural communities, biodiversity, local food production and the protection and enhancement of the Warwickshire landscape (Warwickshire County Farms and Smallholdings Strategy 2010-2025, Foreword).
Inadequate local infrastructure
The proposed development area has poor transport links. Despite HS2 passing within 600m the nearest railway station is Leamington (6km) and local bus services are extremely limited. The development would therefore rely on road vehicles and result in a large increase in local road traffic.
The main road into the site from the south, from the Fosse Way and M40, runs across the River Leam over the medieval Hunningham Bridge, a Scheduled Ancient Monument. The bridge is single-track, unsuitable for large delivery or construction vehicles and vulnerable to traffic damage. Because of the narrowness of the bridge and the need for specialist heritage masonry repairs recurrent vehicle damage results in complete closure of the road lasting weeks or months. Of the next nearest Leam bridges, Offchurch Bridge is regularly closed by flooding, and Eathorpe Mill Bridge is also unsuitable for large vehicles and reached along narrow country roads.
The local sewage treatment system is already under strain. The local Weston-under-Wetherley Sewage Treatment works recorded 25 spills of untreated sewage into the River Leam lasting a total of 277.78 hours in 2023, and 26 spills lasting 249.02 hours in 2022 (theriverstrust.org/key-issues/sewage-in-rivers, Permit S/12/26152/R).
Risk of flooding
The HELAA assessment seems to understate the risks to the site from flooding. In addition to the regularly flooded areas in the south-east corner by the River Leam within Flood Zones 2 and 3, there are also areas susceptible to surface water flooding scattered across the site, including areas adjacent to existing buildings. With climate change bringing heavier rainfall this situation will only become worse. Development here would inevitably increase run-off into the Leam exacerbating flooding problems downstream.
Landscape and heritage
The site lies within the rural landscape of the valley of the River Leam, an area characterised by farmland, occasional areas of woodland, interspersed with small villages and individual farms. The area is popular with walkers, cyclists and horse riders who come from surrounding towns to enjoy its rural character and amenity. A development of this scale would represent a quite alien intrusion into this valued landscape. It would dwarf the adjacent existing village of Weston under Wetherley, and would be very prominent in views from the southern side of the river valley, particularly, for example, in views along the Hunningham to Offchurch Road.
The Scheduled Ancient Monument of Hunningham Bridge would faced a much increased risk of physical damage from increased traffic and its rural riverine setting would be marred by intrusive development to its north west.
For all these reasons this site (569) should not remain in consideration for the Local Plan.
Hunningham Parish Council

No

ID sylw: 107559

Derbyniwyd: 07/03/2025

Ymatebydd: Baginton Parish Council

The HELAA review for each development around Baginton assesses the feasibility of each site in isolation. This was a point we made during WDC’s 2011 to 2029 Local Plan consultation. Whilst HELAA indicates that roads and utilities can be upgraded to accommodate each single development, if multiple sites are developed around Baginton it becomes increasingly difficult to provide the infrastructure to accommodate all of them.

Other

ID sylw: 107566

Derbyniwyd: 07/03/2025

Ymatebydd: Coventry City Council

Coventry City Council strongly objects to intensified and significant growth in the SG01 area
beyond those schemes which are already consented. It is important to emphasise that
growth of this scale would have significant impacts not only in relation to the development
itself but also in terms of the infrastructure which would be needed to support it.
The Green Belt in this area has been assessed as having a moderate / strong function and
indeed all parcels score as having a strong contribution regarding their role in checking the
unrestricted sprawl of the built up area. The assessment for parcels COV2, COV3, and
KEN1, KEN 13 and KEN 14 recognises the strong function of the Green Belt in that area.
However, in relation to COV4, this is assessed as ‘moderate’ whereas Coventry City Council
would contest this and considers that it should be increased to a ‘strong’ function especially
in terms of checking unrestricted sprawl and preventing neighbouring towns merging and
given that this sits adjacent to an existing allocation. This principle also applies KEN3 and
KEN4 which are adjacent to Kenilworth. Cumulatively the development of these parcels
would serve to merge Kenilworth with Coventry, undermining the significant role of the
Green Belt here.
SG01 is also an area with particular ecological significance, including SSSI, Local Nature
Reserves and Ancient Woodland. These ecological designations should be protected and
green infrastructure links strengthened and development proposals have the potential to
cause harm and fragmentation.
The Sustainability Appraisal assesses SG01 as one of the worst performing options,
identifying it as is identified as being the worst performing for biodiversity (SA Objective 3)
and has also been identified to be amongst the worst performing options for landscape (SA
Objective 4), pollution (SA Objective 6), and natural resources (SA Objective 7). It is not in
the top five best performing for any objective. Coventry City Council welcomes this
conclusion and trusts that the results of this assessment will be used to shape the next
stage of plan making and that this option for growth will be rejected as being unsustainable.

Individual sites
• Site REFID47 ‘Westwood Heath Garden Suburb’ and sites in the vicinity being promoted through SG01
Please see previous comments objecting to SG01.

• Other sites: general comments
Coventry City Council notes that assessment has been undertaken of a number of sites
which cross over into Coventry’s boundary (Strategic Growth Locations SG01 and SG03)
and strongly objects to this approach.

Whilst it is understood that growth locations do not necessarily follow administrative areas,
it is considered they should be depicted differently on a spatial map so that the reader is
aware that some areas fall under a different administration (eg ‘greyed out’), and that there
should be no assessment undertaken of those sites without the express agreement of the adjoining Council.
As such, the City Council objects to the process of the assessment of some sites / parcels of land and these are set out below.

Site REFID 227 University of Warwick main campus
Within this assessed site, it is essential that the SWLP reflects the provisions of the
University of Warwick Campus Framework Masterplan which was jointly adopted by
Coventry City Council and Warwick District Council on 3 December 2024.
those parts of the Framework Masterplan which sit within Coventry’s
administrative boundary should be ‘greyed out’ as whilst there are cross boundary matters
to consider, the SWLP cannot make decisions on behalf of another area. At present this
has not been done: Site REFID227: University of Warwick Main Campus needs amending to delineate between the two administrative areas and with a clear contextual link to the
adopted SPD.

Development proposals for this site must accord with the SPD. It is noted under Draft Policy
Direction 14 Major Investment Sites reference is made to ‘further development in the south
of this site will be explored but may require a link road from the A46 depending on the nature
of development due to access through a residential area’. This is not in accordance with the
SPD.

Site REFID 122 Land at Gibbet Hill Coventry
This site as a whole sits within the Green Belt. The element of land to the top north east of
the site sites within Coventry’s administrative area but this is not referenced anywhere and
should not have been included in the assessment process.
Coventry City Council objects to the SWLP having assessed a site within its boundaries
and outside of the SWLP area. Furthermore this site forms part of a wider Green Belt parcel
(COV2 in the South Warwickshire Green Belt Review), an area assessed as making a
strong contribution to the five purposes of Green Belt. It is also in close proximity to ancient
woodland and local wildlife sites to the north (in Coventry) and any development could
fragment wider ecological connectivity. Coventry City Council therefore objects to the
inclusion of REFID 122 as a potential development site

Site REFID 103 Land South of Stoneleigh Road / Kenilworth Road
This site as a whole sits within the Green Belt. The element of land to the north west of the
site sites within Coventry’s administrative area but this is not referenced anywhere and
should not have been included in the assessment process.
Coventry City Council objects to the SWLP having assessed a site within its boundaries
and outside of the SWLP area. Furthermore, this site forms part of wider Green Belt parcels
(COV3 and COV4 in the South Warwickshire Green Belt Review), an area assessed as
making a strong / moderate contribution to the five purposes of Green Belt. It is also good
quality agricultural land.
Coventry City Council therefore objects to the inclusion of REFID 122 as a potential
development site.

SG03 Coventry Airport Group
REFID43
The allocation of the Airport REFID43 is welcomed and supported and already has outline
planning consent.

Other

ID sylw: 107569

Derbyniwyd: 04/03/2025

Ymatebydd: James Bushell

LAND OFF OLD WARWICK ROAD AND MILL LANE, KINGSWOOD REFID: 53
The site has the capacity to provide 66 dwellings (including 38 affordable homes – 57%) (see Illustrative Masterplan at Appendix 3). A mix of shared ownership, social rent, and first-time buyer properties, catering to local housing needs could be provided.
The proposals benefit from two access point, one from Old Warwick Road and a second from Mill Lane.
The site also benefits from nearby access to Lapworth Station. Access to the station is located 0.65 km from the proposed Old Warwick Road access and would take 9 minutes to walk. There are existing footpaths running from the site access to the station.
Lapworth Station provides direct services to Birmingham, Solihull, Warwick and Leamington Spa. Indirect journeys are available to London.
The Lapworth Village Hall, Lapworth Village Shop and Lapworth Surgery are located within 0.2 km of the site (less than 5-minute walk). Access to the Stratford Canal is also located within 0.2 km.
Lapworth Primary School and Pre-school are 0.3 km from the site, with the local pub 0.4 km. Other services within 0.4 km are Lapworth Wines, Lapworth Garage, Solihull Tiles and Navigation Inn Public House. The Boot Inn Public House is located within 0.65 km. Clearly, the site benefits from close access to a range of existing facility as well as public transport connections.
The site is centrally located and within a 5-minute journey of the majority of village services. It is the most sustainable site being located within Kingswood.
In terms of bus services, Lapworth is served by the 514 service between Solihull and Hatton Green with a single morning and afternoon service Monday to Friday. The 511 service runs between Claverdon and Leamington Spa on Wednesday and Saturday.

Other

ID sylw: 107593

Derbyniwyd: 07/03/2025

Ymatebydd: National Highways

We have reviewed the Interactive Map provided as part of this consultation which sets
out the locations of the 24 strategic growth locations. We note that there are a large
number of sites in close proximity to the SRN, including Sites SG01, SG02, SG03,
SG04, SG07, SG08, SG09, SG10, SG11, SG13, SG14, SG18, SG20, SG21, SG24,
with some of these sites also directly abutting the SRN. We acknowledge that the
scale and specific land use of these sites is yet determined and that further work will
be undertaken prior to the publication of the Regulation 19 Local Plan on the sites that
are proposed to be allocated.

We expect that all of the sites identified will be accompanied with a suitable transport
evidence base. Any potential site that is anticipated to have an impact on the SRN in
the area is recommended to be subject to consultation with National Highways, and
appropriately assessed in line with the Department for Transport (DfT) Circular
01/2022 to determine the extent of their potential impacts on the SRN in the area.
Depending on the scale of likely impact on the SRN in the area, the
applicant/developer may need to identify suitable mitigation measures (if required).
It is to be noted that the cumulative impact of the proposed site allocations also needs
to be assessed in line with the Circular for understanding the likely traffic impacts on
the SRN in the area in terms of capacity & safety and identifying any possible
mitigation measures (if required).