Other

ID sylw: 107277

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 36.
However, with regards to irreplaceable habitats, the Board recommends that the following habitats should be explicitly classed as irreplaceable habitat, in line with Policy CE8 (Nature recovery and biodiversity) of the CNL Management Plan:70
i.
ancient and veteran trees;
ii.
ancient woodland (continually wooded since 1600);
iii.
ancient unimproved grassland (surviving since 1945);
iv.
ancient hedgerows (present since before the Enclosure Acts, passed mainly between 1720 and 1840).
We acknowledge that (iii) and (iv) are not included in the list of irreplaceable habitats in the Biodiversity Gain Requirements (Irreplaceable Habitat) Regulations 2024.71 However, the list in the Regulations is not definitive and discussions with Defra are ongoing, at a national level, to try and secure the inclusion of these habitats within the Regulations. In the meantime, we consider that it would be good practice to align with Policy CE8 of the CNL Management Plan.

Other

ID sylw: 107278

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 38.
We are pleased to see that the Councils intend to explore evidence to seek a higher percentage of biodiversity net gain (BNG) above the statutory 10% requirements to achieve greater biodiversity benefits. As stated in Policy CE8 (Nature recovery and biodiversity) of the CNL Management Plan, development proposals within the CNL should provide at least 20% BNG, particularly with regards to the species and habitats listed in Appendix 8 of the Management Plan.75 Reasons why this higher level of BNG is justified in the BNG are provided in Appendix 9 of the Management Plan.76
We recommend that Draft Policy Direction 38 should require at least 20% BNG for development in the CNL.

Other

ID sylw: 107279

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 39.
The principle of environmental net gain was embedded in Government policy in the Government’s ‘25 Year Plan to Improve the Environment’, published in 2018, in which it pledged that we would be the first generation to leave the environment in a better state than that in which we inherited it.77 This principle is maintained in the Government’s Environmental Improvement Plan (EIP) 2003, which is the Government’s first revision of the 25 Year Plan.78 The production of the EIP and annual reviews of the EIP is a legal requirement, under the Environment Act 2021.79
In the context of the CNL, a key component of delivering environmental net gain will be to meet the ambitious targets that are set out in the Protected Landscapes Targets and Outcomes Framework (PLTOF).80 The new CNL Management Plan 2025-2030, which was adopted by the Board in February 2025, sets out these targets and outcomes specifically in relation to the CNL.81
Achieving the PLTOF targets and outcomes is a key component of fulfilling the statutory duty to seek to further the purpose of conserving and enhancing the natural beauty of the CNL.82
We recommend that Draft Policy Direction 39 should set a requirement for development in the CNL to contribute to achieving the PLTOF targets and outcomes that are set out in the CNL Management Plan.
We also recommend that the supporting text should make reference to the EIP and to the PLTOF.

Other

ID sylw: 107280

Derbyniwyd: 07/03/2025

Ymatebydd: Cotswolds National Landscape Board

In principle, the Cotswolds National Landscape (CNL) Board agrees with the approach outlined in Draft Policy Direction 42.
The last part of Draft Policy Direction 42 specifies the standards / strategies / guidance that tree planting needs to be in line with. We recommend that, for proposals in the CNL, this list should also include:
• the Board’s Position Statement on ‘Woodland Creation and Tree Planting in the Cotswolds National Landscape - Tree Species and Provenance’;85
• the CNL Landscape Strategy & Guidelines (within which advice is provided on woodland creation and tree planting within each landscape character type).86
We also recommend that Draft Policy Direction 42 should also explicitly refer to the Government’s guidance for making planning decisions in relation to ancient woodland, ancient trees and veteran trees.87 In particular, we recommend that the Draft Policy Direction should explicitly refer to (and advocate) the buffer zone recommendations that are set out in this guidance.

Yes

ID sylw: 107281

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 43c.

Other

ID sylw: 107282

Derbyniwyd: 07/03/2025

Ymatebydd: Cotswolds National Landscape Board

In principle, the Cotswolds National Landscape (CNL) Board agrees with the approach outlined in Draft Policy Direction 49.
However, we have some concerns regarding the statement that ‘the large-scale renewable energy development will be prioritised on the poor-quality agricultural land (Grades 3b, 4 and 5)’. This statement should be framed in a more qualified / less absolute way to ensure that large-scale energy development isn’t inadvertently directed towards assets of particular importance, such as the CNL.
The National Planning Policy Framework (NPPF) gives great weight to conserving and enhancing the landscape and scenic beauty of National Landscapes.97 In contrast, it just says that areas of poorer quality land should be preferred to those of a higher quality.98 In other words, the weighting given to conserving and enhancing the landscape and scenic beauty of National Landscapes is stronger than the weighting given to using poorer quality land.
It is also important to note that the NPPF frames the preference for using poorer quality land in the context of ‘where consistent with other policies in this Framework’.99 We recommend that Draft Policy Direction 49 should explicitly reflect this wording.
Large-scale renewable energy schemes would constitute major development in the context of paragraph 190 of the NPPF. Such development should only be permitted in exceptional circumstances and where it can be demonstrated that the development would be in the public interest.100 A key consideration, in this regard, is whether the scheme would meet a need that could not be addressed elsewhere (i.e. outside the CNL) or in some other way.101 There is no equivalent ‘exceptional circumstance’ in relation to BMV land.
Furthermore, relevant authorities have a statutory duty to seek to further the purpose of conserving and enhancing the natural beauty of National Landscapes. There is no equivalent legislative requirement in relation to BMV land.
All other things being equal, if there was a choice between allocating or permitting a large-scale renewable energy scheme on (i) poorer quality land in the CNL (or in the setting of the CNL, where views from the CNL would be adversely affected) or (ii) higher quality (BMV) land outside the CNL, preference should, in principle, be given to (ii).
It is also important to note that the phrase ‘poor-quality’ land can also be misleading. Land that is not classed as ‘best and most versatile’ (BMV) can be just as productive as BMV land. The main difference is that BMV land is more versatile.

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.