Other

ID sylw: 107267

Derbyniwyd: 07/03/2025

Ymatebydd: Cotswolds National Landscape Board

As outlined above, the Cotswolds National Landscape (CNL) Board:
•
does not broadly support the proposals relating to Draft Policy Directions 1,2 or 4 or the proposals relating to Strategic Growth Location 17.
•
does broadly support the proposals relating to Draft Policy Directions 3, 5 and 6.
There are some additional proposals in Chapter 4 that we do not broadly support, as outlined below.
Windfall allowance
Firstly, we are concerned about the proportion of the overall housing need that the Councils anticipate being met by a ‘windfall allowance’ (i.e. sites that are not allocated in the Local Plan). Table 3 indicates that 9,375 dwellings out of the 54,700 that are needed over the plan period will be provided via a windfall allowance (i.e. 17%). When existing commitments (17,068 dwellings) are taken out of the equation, the windfall allowance makes up 25% of the remaining housing need. This seems like a high percentage, particularly given that there are supposedly more sites currently in consideration than the Councils will actually need to meet the identified housing need.
Paragraph 75 of the NPPF states that:
•
Where an allowance is to be made for windfall sites as part of anticipated supply, there should be compelling evidence that they will provide a reliable source of supply. Any allowance should be realistic having regard to the strategic housing land availability assessment, historic windfall delivery rates and expected future trends.13
If there are more sites in consideration than the Council will actually need then, presumably, the Councils could set a lower windfall allowance percentage.
Priority Area buffer zones
Secondly, we are concerned about the way that Priority Area ‘buffer zones’ are shown in Figure 5 (Spatial Growth Strategy Priority Areas). For example, the Meon Vale area is identified as being a Priority Area 1 zone. This Priority Area 1 zone is surrounded by a Priority Area 2 buffer zone, which extends into the CNL and includes the CNL settlement of Upper Quinton. In the Board’s opinion, the CNL should not be included within this buffer zone, not least because National Landscapes ‘are unlikely to be suitable areas for accommodating unmet needs from adjoining (non-designated) areas’. The same principle applies to the Priority Area 3 buffer zone around Moreton-in-Marsh, which extends into the CNL, including the CNL settlement of Barton-on-the-Heath. We consider that the mapping of the Priority Area buffer zones should be more nuanced to take account of this by not extending these buffer zones into the CNL.

Yes

ID sylw: 107268

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 B.
In particular, we support the following requirement relating to unallocated self-build and custom build housing:
•Suitable sites within the … Cotswolds National Landscape and adjacent to defined settlement boundaries would only be supported to meet a local need identified by the local community.

Other

ID sylw: 107269

Derbyniwyd: 07/03/2025

Ymatebydd: Cotswolds National Landscape Board

In principle, the Cotswolds National Landscape (CNL) Board agrees with the approach laid out in Draft Policy Direction 13. However, we have some concerns about the detail of the Core Opportunity Area (COA), as outlined below.
The COA, as shown in Figure 10, overlaps slightly with the CNL boundary, in the vicinity of Meon Hill. We acknowledge that the map is diagrammatic and is not 100% accurate. However, we recommend that the boundary of the COA should not overlap with the CNL. Ideally, it should not extend eastwards of the B4632 (Campden Road) in the vicinity of the CNL (i.e. within the 3km buffer) or southwards of the current southern boundary of existing development at Meon Vale (i.e. the Langate Fields road).
Part of the COA would be in the setting of the CNL and would be visible from public rights of way (PROW) on Meon Hill, within the CNL. The panoramic views that are experienced from the Cotswold escarpment outliers, including Meon Hill, are one of the key features / characteristics of Landscape Character Type 1 (Escarpment Outliers).18 Great weight should be given to the potential impact of development within the COA on views from the CNL. Development in this part of the COA should also be sensitively located and designed to avoid or minimise impacts on the CNL, in line with paragraph 189 of the National Planning Policy Framework (MPPF).19
We recommend that explicit reference should be made to the above points in Draft Policy Direction 14 and in the supporting text.

Other

ID sylw: 107270

Derbyniwyd: 07/03/2025

Ymatebydd: Cotswolds National Landscape Board

In principle, the Cotswolds National Landscape (CNL) Board agrees with the approach laid out in Draft Policy Direction 14.
Of particular relevance to the CNL are the proposed Major Investment Sites (MIS) at Long Marston Airfield (MIS.2) and Long Marston Rail Innovation Centre (MIS.3). In principle, we do not object to these sites being developed as Major Investment Sites. However, we do have some recommendations as to how any adverse effects on the CNL can be avoided and minimised, as outlined below.
The MIS at Long Marston Rail Innovation Centre comes within approximately 900m of the CNL boundary and within approximately 1.7km of elevated views from Public Rights of Way (PROW) on Meon Hill within the CNL. The MIS lies entirely within the 3km CNL buffer. The MIS at Long Marston Airfield comes within approximately 1.6km of the CNL boundary and within approximately 2km of elevated views from PROW on Meon Hill within the CNL. The vast majority of the site lies within the 3km CNL buffer.
Map showing the Major Investment Sites at Long Marston Airfield and Long Marston Rail Innovation Centre
Key:
•Yellow shading = Major Investment Sites
•Black hatching = Cotswolds National Landscape
•Grey shading = 3km buffer around the Cotswolds National Landscape
•Black lines = settlement boundary
•Area with no hatching or shading = other counties (including Gloucestershire and Worcestershire)
As such, these two MIS are clearly in the setting of the CNL. The panoramic views that are experienced from the Cotswold escarpment outliers, including Meon Hill, are one of the key features / characteristics of Landscape Character Type 1 (Escarpment Outliers).20 Great weight should be given to the impact of development at the two MIS on these views. Development at the two MIS should also be sensitively located and designed to avoid or minimise impacts on the CNL, in line with paragraph 189 of the National Planning Policy Framework (NPPF).21
We recommend that explicit reference should be made to the above points in Draft Policy Direction 14 and in the supporting text.
In views from the CNL, the MIS at Long Marston Rail Innovation Centre lies beyond the existing built development at Meon Vale, which helps to limit potential visual impacts. The potential visual impacts would be further mitigated by the woodland in the Meon Vale Local Wildlife Site (LWS), which lies between the existing built development at Meon Vale and the Rail Innovation Centre. The triangle of land to the south west of the LWS and to the south east of the Rail Innovation Centre is identified, in the consultation interactive map, as a potential LWS. We recommend that the LWS should be expanded to include this land and that the trees here should be retained (not least, to help screen the Rail Innovation Centre in views from the CNL).
The existing development at Long Marston Airfield is clearly visible in views from the CNL, particularly from the Monarch’s Way and Centenary Way to the south east of Upper Quinton. Further development at the Long Marston Airfield MIS would increase the prominence of Long Marston Airfield in these views, albeit at some distance and in the context of existing development. Adverse impacts on these views could be mitigated, to some degree, by appropriate landscape mitigation measures (including tree planting and planting of hedgerows) along the southern and south-eastern boundaries of the site and within the site.
We recommend that the above recommendations should be explicitly addressed within Draft Policy Direction 14.
We acknowledge that Long Marston Airfield is already allocated as a new settlement in Stratford-on-Avon’s adopted Core Strategy.22 The site boundary for the MIS is the same as that used in the Core Strategy.23

Other

ID sylw: 107271

Derbyniwyd: 07/03/2025

Ymatebydd: Cotswolds National Landscape Board

In principle, the Cotswolds National Landscape (CNL) Board agrees with the approach laid out in Draft Policy Direction 17.
The approach laid out aligns with the Board’s aspirations for mitigating the impacts of climate change, as set out in Policy CC1 (Climate change - mitigation) of the CNL Management Plan24 and in the Board’s Climate Change Strategy.25
The requirement for renewable energy generation to be appropriate to the location and type of development is consistent with Board’s Renewable Energy Position Statement.26
Draft Policy Direction 18 - Supporting Rural Employment and Diversification (link): Do you agree with the approach laid out?
In principle, the Cotswolds National Landscape (CNL) Board agrees with the approach laid out in Draft Policy Direction 18.
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.27 Supporting rural employment and diversification is an important component of this. In the context of development in the CNL and its setting, this should be done in a way that is compatible with - and positively contributes to - the purpose of conserving and enhancing the natural beauty of the CNL. The requirements that are set out in the Draft Policy Direction will help to facilitate this.
Draft Policy C - Protecting Community Facilities (link): Do you agree with the approach laid out?
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’.

Other

ID sylw: 107272

Derbyniwyd: 07/03/2025

Ymatebydd: Cotswolds National Landscape Board

In principle, the Cotswolds National Landscape (CNL) Board agrees with the approach laid out in Draft Policy Direction 24.
This approach aligns with the approach that is advocated in Policy CC1 (Climate Change - Mitigation) of the CNL Management Plan47 and in the Board’s Climate Change Strategy48.
However, in the context of the CNL (and the World Heritage Site) consideration will need to be given to how this can be achieved whilst also ensuring that new development reflects the local distinctiveness of the built environment (for example, the use of locally sourced Cotswold limestone and the use of vernacular architecture).

Other

ID sylw: 107273

Derbyniwyd: 07/03/2025

Ymatebydd: Cotswolds National Landscape Board

In principle, the Cotswolds National Landscape (CNL) Board agrees with the approach laid out in Draft Policy Direction 23.
This approach aligns with the approach that is advocated in Policy CC1 (Climate Change - Mitigation) of the CNL Management Plan49 and in the Board’s Climate Change Strategy50.
However, in the context of the CNL consideration will need to be given to how this can be achieved whilst also ensuring that new development reflects the local distinctiveness of the built environment (for example, the use of locally sourced Cotswold limestone / ironstone and the use of vernacular architecture).

Other

ID sylw: 107274

Derbyniwyd: 07/03/2025

Ymatebydd: Cotswolds National Landscape Board

In principle, the Cotswolds National Landscape (CNL) Board agrees with the approach laid out in Draft Policy Direction 25.
However, we do not think that the Draft Policy Direction has adequately addressed the issue of ‘local distinctiveness’.
Local distinctiveness is concerned with celebrating the unique characteristics of a place. The policy refers to creating ‘distinctive’ neighbourhoods. However, the word ‘distinctive’, in this context, could be interpreted as just meaning ‘different’, rather than being interpreted in the context of local distinctiveness.
Local distinctiveness is particularly important in the context of the CNL. This is because several of the CNL’s ‘special qualities’ relates to the local distinctiveness of the CNL as a whole. Relevant special qualities include:51
•The unifying character of the limestone geology - its visible presence in the landscape and use as a building material.
•Distinctive dry stone walls.
•Variations in the colour of the stone from one part of the National Landscape to another which add a vital element of local distinctiveness.
•Distinctive settlements, developed in the Cotswold vernacular with high architectural quality and integrity.
Local distinctiveness is also important in the context of the key features / characteristics of the individual landscape character types within the CNL, as detailed in the CNL Landscape Character Assessment52 and in the CNL Landscape Strategy & Guidelines53.
Local distinctiveness is explicitly addressed in Policy CE4 of the CNL Management Plan, which says that development proposals within the CNL should have regard to, be compatible with and reinforce the local distinctiveness of the CNL.54 The topic of local distinctiveness is also addressed in more detail in the Board’s report on Local Distinctiveness and Landscape Change.55
Recommendations
To address this issue, we recommend that Draft Policy Direction should include the following principle, under the heading of ‘Designing adaptable, diverse and flexible places’:
•Ensuring that development reflects the local distinctiveness of the built environment in the settlement, particularly with regards to its historic character, including building materials, vernacular architecture and settlement pattern and form.

Other

ID sylw: 107275

Derbyniwyd: 07/03/2025

Ymatebydd: Cotswolds National Landscape Board

In principle, the Cotswolds National Landscape (CNL) Board agrees with the approach laid out in Draft Policy Direction 27.
The approach laid out is consistent with Policy CE7 (Historic Environment) of the CNL Management Plan.56
However, in the context of the CNL, we consider that reference should be made to the fact that:
•cultural heritage (including heritage assets / the historic environment) is one of the factors that contributes to the natural beauty of the CNL;57
•the ‘special qualities’ of the CNL include:58
o 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;
o a vibrant heritage of cultural associations, including the Arts and Crafts movement of the 19th and 20th centuries, famous composers and authors and traditional events such as the Cotswolds Olimpicks, cheese rolling and woolsack races.
In particular, we recommend that the list of heritage assets at the end of the Draft Policy Direction should include the following, additional bullet point:
•heritage assets that contribute to the ‘special qualities’ of the Cotswolds National Landscape.

Other

ID sylw: 107276

Derbyniwyd: 07/03/2025

Ymatebydd: Cotswolds National Landscape Board

Overall, the Cotswolds National Landscape (CNL) Board agrees with the approach laid out in Draft Policy Direction 29.
However, we recommend that additional policy direction should be provided in relation to lighting. In particular, we recommend that any proposals involving outdoor lighting should be required to:
• Apply the five key principles of outdoor lighting:59
o Needed: Lighting should be clearly justified, appropriate for the area with a clear purpose and benefit without presenting unacceptable intrusion.
o Targeted: Light should be directed to where it is needed and not spill into neighbouring spaces, or in a direction that causes a nuisance to neighbours, wildlife or the night sky.
o Low light: Light should be no brighter than necessary and provide appropriate illuminance for the activity.
o Colour: Warm colour lights should be used to reduce the impact on sky glow, wildlife and human health.
o Controlled: Lights should be shielded, dimmed or turned off when not required.
•Comply with relevant best practice guidance, such as the guidance published by the Institution of Lighting Professionals.
The dark skies of the CNL are one of the area’s special qualities. As such, lighting is a particularly important consideration in the CNL and its setting. The Board has recently adopted its own lighting guidance which will be made available on the CNL website shortly. Ideally, the policy and / or supporting text should make explicit reference to this guidance.