Yes

ID sylw: 107088

Derbyniwyd: 07/03/2025

Ymatebydd: Cotswolds National Landscape Board

Yes, the Cotswolds National Landscape (CNL) Board agrees with the approach outlined in Draft Policy Direction 43b.
In the context of the CNL it is worth noting that ‘country estates and parks’ are included in the following ‘special quality’ of the CNL:
• Significant archaeological, prehistoric and historic associations dating back 6,000 years, including Neolithic stone monuments, ancient drove roads, Iron Age forts, Roman villas, ridge and furrow fields, medieval wool churches and country estates and parks.88

Yes

ID sylw: 107089

Derbyniwyd: 07/03/2025

Ymatebydd: Cotswolds National Landscape Board

Yes, the Cotswolds National Landscape (CNL) Board agrees with the approach outlined in Draft Policy Direction 45.
In the context of settlements in the CNL, this policy approach could help to conserve and enhance the natural beauty of the CNL. For settlements in the setting of the CNL, it could help to protect views looking towards the CNL (particularly views that feature the Cotswold escarpment and / or escarpment outliers).

Yes

ID sylw: 107090

Derbyniwyd: 07/03/2025

Ymatebydd: Cotswolds National Landscape Board

Yes, the Cotswolds National Landscape (CNL) Board agrees with the approach outlined in Draft Policy Direction 47.
Two of the Special Landscape Areas (SLAs) are located directly adjacent to the CNL, as shown in the map below:
• Cotswold Fringe SLA (west, south and east of Shipston-on-Stour); and
• Ironstone Hill SLA (north east of the CNL).
Key:
• Green shading = Special Landscape Area
• Black hatching = Cotswolds National Landscape
• Grey shading = CNL 3km buffer
The Cotswold Fringe SLA is located within the Cotswolds National Character Area (NCA 107)94 and reflects many of the characteristics of the CNL, particularly Landscape Character Type (LCT) 17 - Pastoral Lowland Vale95. The Ironstone Hill SLA shares many of the characteristics of the north-eastern extremities of the CNL, particularly LCT 6 - Ironstone Hills and Valleys96. The key difference is that the SLAs are areas of particularly high landscape quality at a local level whereas the CNL is an area of particularly high landscape quality at a national level.
The designation of these SLAs helps to conserve and enhance the setting of the CNL and, by extension, helps to conserve and enhance the natural beauty of the CNL.

Yes

ID sylw: 107091

Derbyniwyd: 07/03/2025

Ymatebydd: Cotswolds National Landscape Board

Yes, the Cotswolds National Landscape (CNL) Board agrees with the approach outlined in Draft Policy Direction 48.
In the context of the CNL, this approach will help to conserve and enhance the natural beauty of the CNL.

No

ID sylw: 107261

Derbyniwyd: 07/03/2025

Ymatebydd: Cotswolds National Landscape Board

The CNL should not be expected to accommodate these growth needs.

The Board acknowledges that it is appropriate for the South Warwickshire Councils to give consideration to accommodating unmet needs arising from outside South Warwickshire. However, the approach taken by Draft Policy Direction 4 is, in the Board’s opinion, too permissive.
Paragraph 36 of the National Planning Policy Framework (NPPF) states, inter alia, that:
•
Plans are ‘sound’ if they are:
a)
Positively prepared … informed by agreements with other authorities, so that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development.10 (N.B. Added for emphasis).
We recommend that the underlined text should be reflected in Draft Policy Direction 4. In other words, the South Warwickshire Councils should only give consideration to accommodating unmet needs arising from outside South Warwickshire if it is practical to do so and if it is consistent with achieving sustainable development. This should include consideration of paragraphs 11b and 11d of the NPPF, which set out the circumstances in which objectively assessed needs (OAN) do not have to be met in full.
The Government’s Planning Practice Guidance on the Natural Environment states that National Landscapes ‘are unlikely to be suitable areas for accommodating unmet needs from neighbouring (non-designated) areas’.11 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 and unmet needs arising in local authority areas that do not overlap with the CNL’.12 In this context, it would not be appropriate to release reserve sites in the CNL on the basis of accommodating unmet needs from neighbouring local authority areas. This should be made explicit in Draft Policy Direction 4.

No

ID sylw: 107262

Derbyniwyd: 07/03/2025

Ymatebydd: Cotswolds National Landscape Board

The Cotswolds National Landscape (CNL) Board considers that the current wording of Draft Policy Direction 10 is too vague for us to be able to say whether we agree with the approach laid out.
Policy CE15 of the CNL Management Plan states that ‘housing delivery in the Cotswolds National Landscape (CNL) should be focused on meeting affordable housing requirements, particularly housing that is affordable in perpetuity such as social rented housing’.14
The justification for this approach is set out in the Board’s Housing Position Statement.15
The emphasis on social rent housing is reflected in the National Planning Policy Framework (NPPF), which now requires planning policies to ‘specify … the minimum proportion of Social Rent homes required’.16 This new requirement was introduced to support the Government’s objectives around boosting delivery of Social Rent. The Government expects that many areas will give priority to Social Rent in the affordable housing mix they seek, in line with their local needs, and this is something that the Government strongly supports.17 We consider that identifying the minimum proportion of Social Rent homes required is a key, measurable component of demonstrating consistency with Policy CE15 of the CNL Management Plan.
We recommend that Draft Policy Direction 10 should explicitly reflect the approach advocated in Policy CE15 of the CNL Management Plan.

No

ID sylw: 107263

Derbyniwyd: 07/03/2025

Ymatebydd: Cotswolds National Landscape Board

development in the setting of the CNL is not adequately addressed.

No, the Cotswolds National Landscape (CNL) Board does not agree with the approach laid out in Draft Policy D.
The over-arching principles set out in Draft Policy D are generally sound. However, we have a number of concerns about some of the detail of the Policy. These concerns include:
i.A lack of explicit reference to the CNL - and to how development within the CNL should be addressed - within Draft Policy D
ii.A lack of explicit reference to how development in the setting of the CNL should be dealt with.
iii.The fact that the identification of suitable areas for wind and solar energy does not factor in landscape sensitivity (other than by excluding the CNL).
Cotswolds National Landscape

Firstly, we are concerned that the Policy makes no explicit mention of the CNL. This is surprising given that the Renewables and Decentralised Energy Opportunities report, which is referred to in the Policy, rules out large-scale wind and solar energy development in the CNL.31 We support this approach, which is consistent with the Board’s Renewable Energy Position Statement32 and with the statutory duty to seek to further the purpose of conserving and enhancing the natural beauty of the CNL33. Large-scale wind and solar energy would constitute major development, in the context of paragraph 190 of the National Planning Policy Framework, which sets a presumption against such development.

Setting of the Cotswolds National Landscape
Secondly, we are concerned that neither Draft Policy D (or the Renewables and Decentralised Energy Opportunities report) address how development in the setting of the CNL should be addressed. Nor do they differentiate between development in the setting of the CNL and development that is not in the setting. This is an important consideration because development in the setting of the CNL has the potential to adversely affect the natural beauty of the CNL. Paragraph 189 of the NPPF states that great weight that should be given to conserving the landscape and scenic beauty of National Landscapes.35 Case law has clarified that this great weight applies in relation to the impact of development outside a National Landscape on views from the National Landscape.

Because of this lack of differentiation, several of the locations that have been identified as being suitable for large scale solar energy are located in very close proximity to the CNL boundary.
Map showing the areas that have been identified as being suitable for large scale solar energy in the vicinity of the Cotswolds National Landscape
Key:
•Green shading = areas identified as being suitable for large-scale solar energy development.
•Black hatching = Cotswolds National Landscape (CNL).
•Grey shading = CNL 3km buffer.

Many of the identified locations would be overlooked from elevated viewpoints on public rights of way (PROW) within the CNL. These elevated viewpoints are in landscape character types (LCTs) where the views that are experienced in (and from) these LCTs are one of the LCTs’ key features / characteristics. In some cases, the identified locations would be overlooked from viewpoints on the Cotswold escarpment (LCT 2) (for example, the locations near Oxhill and Avon Dassett). This is particularly significant as views from (and to) the escarpment are one of the ‘special qualities’ of the CNL.
Depending on the scale and proximity of potential solar energy schemes in these locations, and the elevation of the viewpoints from which they would be overlooked, such schemes could potentially have a significant adverse effect on these views from the CNL.
One option to address this issue would be to exclude large scape solar energy proposals on sites that are within, say, 1km of the CNL boundary or within 3km of LCTs that have ‘views’ as one of their key features / characteristics. An alternative approach would be to use a landscape sensitivity assessment to help direct the location of large-scale schemes (see below).
Similar principles apply in relation to large-scale wind energy development in the setting of the CNL, which, arguably would have a bigger adverse impact on the natural beauty of the CNL than large-scale solar energy development.

Landscape Sensitivity
Our third concern is that the Councils have not factored in landscape sensitivity into the identification of suitable sites or into Draft Policy C.
In the Board’s Renewable Energy Position Statement, we state that the identification of ‘suitable areas’ for wind and solar energy should be underpinned by a landscape sensitivity assessment (LSA) and by consideration of constraints that relate to the natural beauty of the CNL, including nature conservation and historic environment designations (in addition to infrastructure constraints and other technical considerations).38 The Position Statement recommends that:
•suitable area mapping should exclude areas of high landscape sensitivity (at least within the CNL) and key constraints;
•renewable energy schemes should be targeted towards areas of relatively low landscape sensitivity.
The extent to which locations would be overlooked from elevated views within the CNL should be taken into consideration in the LSA.
This is the approach that has been taken by Bath & North East Somerset Council, for example, who commissioned a landscape sensitivity assessment,39 which now underpins the renewable energy policies in their local plan (at least in relation to wind energy)40.
Not surprisingly, LSAs tend to identify that landscape character types within the CNL have a relatively high landscape sensitivity to large-scale wind and solar energy development. However, LSAs can be particularly useful in identifying areas of relatively low landscape sensitivity, particularly within the setting of the CNL.
Recommendations
The Board recommends that Draft Policy C should:
•explicitly state that large-scale wind and solar energy development in the CNL will not be supported;
•recognise that sites within the setting of the CNL are likely to have a higher sensitivity to large-scale wind and solar energy development than sites further afield;
•be underpinned by a landscape sensitivity assessment, with large scale wind and solar energy being steered towards areas of relatively low landscape sensitivity.

Yes

ID sylw: 107264

Derbyniwyd: 07/03/2025

Ymatebydd: Cotswolds National Landscape Board

Overall, the Cotswolds National Landscape (CNL) Board broadly supports the proposals in this chapter. However, we do have some suggested amendments to the Vision and Strategic Objectives as outlined below.
Vision
In our response to the Issues & Options consultation, we raised some concerns about the opening statement of the Vision - ‘to meet South Warwickshire’s sustainable development needs, while responding to the climate emergency’. We were concerned that the wording used would potentially skew the focus towards meeting development needs rather than ensuring that development was sustainable. However, on reflection, we consider that the wording is satisfactory.
We would still encourage this sentence to make explicit reference to the ‘ecological emergency’, given the huge loss of biodiversity that has been experienced at a global, national and local level.
The Vision has five overarching principles which will determine who development will be delivered. In later chapters, the CNL is addressed under the principle of:
•A biodiverse and environmentally resilient South Warwickshire – strengthening green and blue infrastructure and achieving a net increase in biodiversity across South Warwickshire
Although the CNL only covers a small part of South Warwickshire, its setting covers a much wider area (for example, factoring in the 3km buffer zone that is advocated in the draft Plan). The CNL, as with all National Landscapes, is an area whose distinctive character and natural beauty are so outstanding that it is in the nation’s interest to safeguard it.2 Relevant authorities, including the South Warwickshire Councils, have a statutory duty to seek to further the purpose of conserving and enhancing the natural beauty of the CNL.3 Therefore, the purpose of conserving and enhancing the natural beauty of our most important landscapes should be explicitly addressed in this principle.
Recommendations
We recommend that the end of the opening statement should be changed to:
•While responding to the climate and ecological emergencies. (N.B. New text underlined).
We recommend that the wording of the last overarching principle should be changed to:
•A biodiverse and environmentally resilient South Warwickshire - strengthening green and blue infrastructure, conserving and enhancing the natural beauty of our most important landscapes and achieving a net increase in biodiversity across South Warwickshire. (N.B. New text underlined).
Strategic Objectives
The Strategic Objective that is most relevant to the CNL is Strategic Objective 12:
•Strategic Objective 12: Protecting and enhancing our environmental assets (related to overarching principle - A biodiverse and environmentally resilient South Warwickshire) - Protecting what already exists and maximising opportunities for enhancement including improvements to the green space network through tree planting and other biodiversity initiatives.

As with the Vision, above, we consider the CNL merits explicit reference within the Strategic Objectives.
Recommendations
We recommend that the wording of Strategic Objective 12 should be changed to:
•Strategic Objective 12: Protecting and enhancing our environmental assets (related to overarching principle - A biodiverse and environmentally resilient South Warwickshire) - Protecting what already exists and maximising opportunities for enhancement including: improvements to the green space network through tree planting and other biodiversity initiatives; and furthering the purpose of conserving and enhancing the natural beauty of the Cotswolds National Landscape. (N.B. New text underlined).

Yes

ID sylw: 107265

Derbyniwyd: 07/03/2025

Ymatebydd: Cotswolds National Landscape Board

Overall, the Cotswolds National Landscape (CNL) Board, does agree with the approach laid out in Draft Policy Direction 5.
The last paragraph of Draft Policy Direction 5 states:
•
In addition to strategic infrastructure requirements, the Local Plan will identify development requirements that will apply to each of the allocated sites. This will include requirements relating to e.g. ecology, flood risk, heritage, active travel, highways, education, healthcare, renewables and utilities.
We recommend that the list of requirements should explicitly include requirements relating to landscape (including the CNL).

Yes

ID sylw: 107266

Derbyniwyd: 07/03/2025

Ymatebydd: Cotswolds National Landscape Board

Yes, the Cotswolds National Landscape (CNL) Board does agree with the approach laid out in Draft Policy Direction 6.
In particular, we support:
•Land safeguarded for the possible provision of a railway station at Long Marston Airfield site, adjacent to the former Stratford to Honeybourne line.
This is because the provision of a railway station at Long Marston Airfield would help to alleviate traffic movements on roads within - and along the boundary of - the CNL in this locality. In doing so, it would help to conserve and enhance the relative tranquillity of the CNL, which is one of the area’s ‘special qualities’.
It may also be worth explicitly safeguarding land along the former Stratford to Honeybourne line.