No

ID sylw: 107067

Derbyniwyd: 07/03/2025

Ymatebydd: Cotswolds National Landscape Board

Over-riding concerns
The Board’s primary concern relates to Draft Policy Direction 1 (Meeting South Warwickshire’s Sustainable Development Needs).
Our concern is that there is not sufficient evidence or clarity to be able to identify whether the aspiration to meet the South Warwickshire’s objectively assessed needs (OAN) can be achieved without harming assets of particular importance, including the CNL. If meeting the area’s OAN cannot be achieved without causing harm 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 identified in the Government’s ‘standard method’.
This issue is complicated by three main factors, as outlined below.
Firstly, there is some ambiguity regarding exactly what OAN the SWLP is seeking to accommodate. For example, the SWLP states that provision will be made for at least the quantum of development identified in the Councils’ Housing and Economic Development Needs Assessment (HEDNA). However, it then goes on to say that that there will be ‘sufficient flexibility’ to accommodate the ‘standard method’ figure (which is significantly larger). As such, it sets two differing targets. If the intention is to accommodate the ‘standard method’ figure then this should be stated in a way that is unambiguously explicit and direct.
Secondly, there is considerable ambiguity regarding exactly which sites the South Warwickshire Councils intend to allocate for housing and other development. Some sites have been sifted out through the Housing and Economic Land Availability Assessment (HELAA) process. However, as we understand it, there are still far more sites currently in consideration than the Councils anticipate actually allocating.
Thirdly, through the HELAA process, the Councils have sifted out all sites that are located entirely within the CNL. This includes some sites that are allocated (or identified as reserve sites) in the relevant Neighbourhood Plan but have not yet been developed. We do not agree with the principle of sifting out potential allocations on the basis of being located 100% within the CNL. This is because, as outlined above, we recognise that a limited degree of development within the CNL may be appropriate in order to retain thriving and vibrant local communities. Therefore, we have reviewed and assessed nearly all of the sites within the CNL that have been sifted out through the HELAA process.
For some of these sites, we have recommended that they should remain in consideration, rather than being sifted out. As such, we are taking the unusual step of advocating a less restrictive approach to development in the CNL than the local authorities have proposed.
Conversely, there are a number of very large sites that overlap with the CNL boundary that have not been sifted out in the HELAA process. The Councils have indicated that such sites are unlikely to be allocated. However, given that they are still in consideration at this stage, it has still been necessary for the Board to review and assess them. We have recommended that all of these larger sites that overlap with the CNL boundary should not be taken forward (at least with regards to the CNL sections).

Other

ID sylw: 107068

Derbyniwyd: 07/03/2025

Ymatebydd: Cotswolds National Landscape Board

Intro summary: The potential allocations include New Settlement E1 - Long Marston Airfield, which would be adjacent to the CNL at its closest point. The settlement would accommodate nearly 10,000 homes and cover an area of approximately 750ha.
We recommend that this site should not be taken forward, at least not in its entirety, for the reasons outlined below.
The new settlement would be clearly seen in elevated views from public rights of way on Meon Hill, in the CNL. The section of the new settlement that is closest to the CNL, Meon Vale, is already developed. As such, the visual impacts are less significant than would be the case if this was a greenfield site. However, the scale and extent of proposed development means that there are still likely to be adverse visual effects on the CNL. An even more significant issue is likely to be the resulting increase in traffic movements on roads through - and along the boundary of the CNL. We also have concerns regarding potential impacts on the dark skies and cultural heritage of the CNL.

We recognise that there may still be some additional development at Meon Vale (including the Rail Innovation Centre) and within the existing settlement boundary of Long Marston Airfield. Appropriate landscape mitigation measures should be implemented to mitigate any adverse impacts on views from the CNL.

Full response:
No, the Cotswolds National Landscape (CNL) Board does not agree with the approach laid out in Draft Policy Direction 2 - Potential New Settlements. Our position, in this regard, relates specifically to New Settlement E1 (Long Marston Airfield). We do not agree with the proposed New Settlement E1 being considered for inclusion in the plan, at least not in its entirety.
We acknowledge that it might be appropriate to identify and consider one or more new settlements in the most sustainable locations, as proposed in Draft Policy Direction 2. However, as outlined in more detail later in our response, we are concerned about the potential impacts of New Settlement E1 (Long Marston Airfield) 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.9 (N.B. Underlining added for emphasis).
In particular, we consider that New Settlement E1 is likely to have an adverse effect on:
•the scenic beauty of the CNL, particularly with regards to impacts on views from the public rights of way on Meon Hill;
•the tranquillity of the CNL, particularly with regards to increased traffic movements on roads through - and along the boundary of - the CNL of New Settlement E1 on views from (and to) the CNL;
•the setting of the scheduled monument on Meon Hill (a multivallate hillfort);
•the dark skies of the CNL.
We recommend that further assessments should be undertaken in this regard.
If a revised iteration of New Settlement E1 is taken forward, we recommend that there should be no coalescence (i.e. no built development) 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 or northwards of Long Marston Airfield. The quantum of development 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%.

No

ID sylw: 107070

Derbyniwyd: 07/03/2025

Ymatebydd: Cotswolds National Landscape Board

Summary from intro:
Shipston-on-Stour, which is located within the setting of the CNL, has been identified, in the draft SWLP, as a strategic growth location. This includes two large sites on the east side of Shipston, which would bring built development considerably closer to the CNL and which would be clearly visible in views from the CNL.
We recommend that these two sites should not be taken forward, at least not in their entirety.

Full response:
Strategic Growth Location 17 (Shipston-on-Stour Group): Do you agree with the proposed Strategic Growth Location being considered for inclusion within the plan?
No, based on the evidence currently available, the Cotswolds National Landscape (CNL) Board does not agree with the proposed Strategic Growth Location (SGL) 17 (Shipston-on-Stour Group) being considered for inclusion within the Plan.
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.
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 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.
Given the quantum of development proposed for SGL 17, we are also concerned about the potential increase in traffic movements on roads within - and along the boundary of - the CNL.
We recommend that further assessments should be undertaken with regards to:
•the potential impact of SGL 17 on views from (and to) the CNL; and
•the extent to which SGL 17 would increase traffic movements on roads through - and along the boundary of - the CNL.
Overall, we recommend that Sites RefID 148, RefID 747 and RefID 689 should be sifted out.
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.

Yes

ID sylw: 107071

Derbyniwyd: 07/03/2025

Ymatebydd: Cotswolds National Landscape Board

Within the Cotswolds National Landscape
We consider that the following sites within the CNL potentially merit further consideration (despite them having been sifted out in the HELAA process):
• Brailes: RefID 849, 850 and 851 (and, if there is robust evidence of local need, RefID 11).
• Ilmington: RefID 815 and 854 (and, if there is robust evidence of local need, RefID 7).
• Long Compton: RefID 354/425 or Ref ID 666.

In the setting of the Cotswolds National Landscape
We consider that the following sites in the setting of the CNL potentially merit further consideration:
• Lower Quinton: RefID 822 (and, if there is robust evidence of local need, RefID 43 (northern half) and 508).
• Oxhill: RefID 29 and 754
• Tysoe: RefID 830 and 865 (and, if there is robust evidence of local need, RefID 24 and 296).
• Warmington: RefID 688 (assuming that our suggested mitigation measures are applied).

Other

ID sylw: 107072

Derbyniwyd: 07/03/2025

Ymatebydd: Cotswolds National Landscape Board

Assessments required for sites that are taken forward to the Regulation 19 (Pre-Submission) stage
For sites within the CNL and sites within the CNL’s 3km buffer zone that the Councils are 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, individually and / or collectively, 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.
9
• 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; 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: 107073

Derbyniwyd: 07/03/2025

Ymatebydd: Cotswolds National Landscape Board

Introduction summary: The Board supports the proposal to apply a 3km buffer to the CNL. The purpose of this buffer will be to ensure that CNL considerations are adequately addressed for development proposals within this buffer zone.
We have provided a template CNL policy in Appendix 2,

Full Response:
Yes, the Cotswolds National Landscape (CNL) Board agrees with the approach outlined in Draft Policy Direction 46.
Draft Policy Direction 46 mainly relates to the proposal to create a ‘buffer zone’ around the CNL. The Board support this approach for the reasons outlined below.
Development within the setting of the CNL has the potential to adversely impact on the natural beauty of the CNL. For example, such development has the potential to adversely impact views from (and to) the CNL and / or to increase traffic movements on roads through - and along the boundary of - the CNL.
National planning policy requires great weight to be given to conserving and enhancing the landscape and scenic beauty of National Landscapes. Case law has clarified that this great weight is a relevant consideration for development within the setting of National Landscapes.89
As mentioned in the consultation document, relevant authorities have a statutory duty to seek to further the purpose of conserving and enhancing the natural beauty of National Landscapes (the ‘seek to further’ duty).90 This duty also applies in relation to development in the setting of the CNL, as outlined in Defra’s guidance on the ‘seek to further’ duty.91
Further information on this topic is provided in the Board’s Position Statement on Development in the Setting of the CNL.92
Based on the above points, we consider that specifying a buffer zone around the CNL, within the Local Plan, would be an appropriate step to take. This would help to ensure that CNL considerations are taken into account for development proposals in the setting of the CNL. It would also help to ensure that the Board is consulted on relevant proposals. The thresholds above which the Board would like to be consulted, in the CNL and its setting, are provided on the Board’s website.93
What constitutes being in the setting of the CNL will depend on the development that is being proposed. However, we consider that applying a distance of 3km to the buffer will help to ensure that most relevant proposals will be identified and addressed. There may be circumstances where particularly large-scale proposals outside this 3km buffer would also be relevant but these could be dealt with on a case-by-case basis.
With regards to the wider CNL policy that will be included within the SWLP, a template policy is provided in Appendix 2, below. We recommend that the Councils should incorporate this template policy into the SWLP.

Yes

ID sylw: 107074

Derbyniwyd: 07/03/2025

Ymatebydd: Cotswolds National Landscape Board

Support

Yes

ID sylw: 107075

Derbyniwyd: 07/03/2025

Ymatebydd: Cotswolds National Landscape Board

The Cotswolds National Landscape Board agrees with the approach laid out in Draft Policy C.
In fulfilling its two statutory purposes the Board has a statutory duty to seek to foster the economic and social well-being of local communities within the CNL.28 Protecting community facilities is an essential component of achieving this.
The approach laid out is consistent with Policy CE15 of the CNL Management Plan, which states that ‘priority should be given to maintaining and enhancing local community amenities’.29

Yes

ID sylw: 107076

Derbyniwyd: 07/03/2025

Ymatebydd: Cotswolds National Landscape Board

Yes, the Cotswolds National Landscape (CNL) Board agrees with the approach laid out in Draft Policy F.
This approach aligns with the approach that is advocated in Policy CC1 (Climate Change - Mitigation) of the CNL Management Plan41 and in the Board’s Climate Change Strategy42.
We agree with the statement, in the Preferred Options consultation, that the Government’s Written Ministerial Statement does not inhibit local authorities in setting targets higher than the national targets if they are justified by robust evidence in terms of deliverability and do not have negative financial constraints on developments.

Yes

ID sylw: 107077

Derbyniwyd: 07/03/2025

Ymatebydd: Cotswolds National Landscape Board

Support