Issue and Options 2023
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Q-H2-2. Please select the option which is most appropriate for South Warwickshire: Option H2-2c. This is an important consideration for the Cotswolds National Landscape, which is a designated Area of Outstanding Natural Beauty (AONB). Paragraph 176 of the National Planning Policy Framework (NPPF) states that the scale and extent of development in AONBs (and National Parks) should be limited. As such, these protected landscapes are not suitable locations for unrestricted housing. Instead, ‘the expectation is that new housing will be focussed on meeting affordable housing requirements’18 (and supporting local employment opportunities and key services). The term ‘affordable housing’ covers various types of housing, some of which are intended to be affordable in the longer term and some of which are not. A key priority in the protected landscapes is to ‘ensure that affordable housing remains so in the longer term’.19 Paragraph 64 of the NPPF allows for on-site provision of affordable housing on sites of 5 units or fewer in designated rural areas, including in AONBs. The Government-commissioned Landscapes Review recommends that ‘local planning authorities in AONBs should also make use of the provision that allows them to demand on-site affordable housing contributions on all sites [in AONBs], including developments of five homes or fewer’.20 Based on the above points – and based on best practice within protected landscapes21 - we would like to make the following recommendations with regards to (affordable) housing development in the Cotswolds National Landscape: . Housing provision in the Cotswolds National Landscape should be focussed on – and prioritise – meeting affordable housing requirements. . Within the context of Government requirements and locally identified needs, priority (in the Cotswolds National Landscape) should be given to the provision of housing that is affordable in perpetuity, including social rented housing. . The South Warwickshire Local Plan should require: o At least 50% affordable housing in market housing developments within the Cotswolds National Landscape. o 100% affordable housing on Rural Exception Sites (at least within the Cotswolds National Landscape), with a lower percentage only being permitted in exceptional circumstances and the absolute minimum being 75%; o On-site affordable housing provision for housing developments of five units or fewer (ideally, on developments of two or more units). Further guidance on this topic is provided in the Board’s Housing Position Statement.22 18 Defra (2010) English National Parks and the Broads – UK Government Vision and Circular 2010 Paragraph 79. AONBs are afforded the same level of protection as National Parks in national planning policy and are subject to the same requirement for the scale and extent of development to be limited. As such, the same principles that are set out in Circular 2010, in this regard, should also apply to AONBs. 19 Defra (2010) English National Parks and the Broads – UK Government Vision and Circular 2010. Paragraph 79. 20 Defra (2019) Landscapes Review Final Report. Proposal 18: A new National Landscapes Housing Association to build affordable homes. 21 Cotswolds National Landscape Board (2021) Housing Position Statement). Appendix 2 – Case Studies. 22 Cotswolds National Landscape Board (2021) Housing Position Statement
The criteria listed in the Issues and Options consultation document provide a useful starting point. Other key considerations include grid connectivity, the additional infrastructure that may be required to facilitate delivery of a renewable energy scheme and cumulative impacts. Question Q-C1.2 is focussed on the criteria that should be considered when assessing proposals. However, it is also important to identify (and consult on) the methodology that would be used for identifying ‘suitable areas’. We recommend that the identification of suitable areas should be underpinned by a combination of: . a landscape sensitivity assessment (LSA); . constraints mapping (e.g., proximity to: designated nature conservation and historic environment designations; priority habitats; existing infrastructure, etc., with buffer zones being applied where appropriate; . technical considerations (e.g., wind speed, grid connectivity, etc.). Areas of high landscape sensitivity should be excluded from the suitable areas, especially in the Cotswolds National Landscape and its setting. Within the Cotswolds National Landscape and its setting, the LSA should have regard to the ‘special qualities’ of the Cotswolds National Landscape24 and to guidance published by the Cotswolds National Landscape, including the Cotswolds AONB Landscape Character Assessment (including the key features / characteristics of the relevant landscape character types) and the Cotswolds AONB Landscape Strategy & Guidelines. 24 The ‘special qualities’ of the Cotswolds National Landscape are listed in Chapter 2 of the Cotswolds AONB Management Plan
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Q-C1.1. Please select the option which is most appropriate for South Warwickshire Option C1.1c. We consider that it is appropriate to identify land that is considered suitable for wind or solar energy generation schemes. However, we are not convinced that it is necessary, or appropriate, to ‘allocate’ such land. It would be sufficient for the option to be: . Identify land that is considered suitable for wind or solar energy generation schemes. An allocation normally relates to a specific site (rather than area) where a specific type and scale of development is considered to be both suitable and deliverable (i.e., likely to be available, developed and built open within the plan period). In many cases, such sites will have been put forward by a developed in a ‘call for sites’. If allocated sites are not deliverable then the development plan would not be ‘effective’ and, by extension, would not be ‘sound’. There is nothing in national planning policy or guidance to say that areas that are identified as being suitable for wind or solar energy have to be deliverable, in the context outlined above. In other words, it doesn’t have to be likely that the land would be available, or that the development would be delivered, within the plan period. Nor would it be appropriate to limit the identification of suitable areas to those locations that would be deliverable, in this context. Suitable areas, in the context of paragraph 155 and footnote 54 of the National Planning Policy Framework (NPPF), could potentially cover substantial areas of land. As such, they could potentially be larger than the area that might be required for individual wind or solar energy development proposals. Allocating suitable areas would potentially give the impression that the whole of the suitable area would, or should, be developed, which may not be appropriate. Instead of allocating land, it may be more appropriate to treat suitable areas as ‘areas of search’ – spatial areas that are identified as being potentially suitable for wind and solar energy subject to more detailed assessment at the project stage. We do not think that it would be appropriate to not identify suitable areas as this would, in effect, rule out wind energy proposals. However, again, this does not mean that the suitable areas have to be allocated. Q-C2. Please select the option which is most appropriate for South Warwickshire It would be better to have a requirements for decentralised energy systems for development over a relevant size thresholds than a more generic policy encouraging the consideration of such systems. We acknowledge that, for Option C2a to be effective, it may be necessary to concentrate planned growth into a smaller number of larger developments. However, development of this scale would not be appropriate in the Cotswolds National Landscape and is not likely to be appropriate within the immediate setting of the National Landscape. Q-C3.1. Do you think we should develop a carbon offsetting approach to new developments where it is demonstrated that it is not possible to achieve net carbon zero requirements on site? Yes. Within the Cotswolds National Landscape and its setting, such offsetting schemes should be delivered in a way that is compatible with - and, ideally, positively contributes to – the natural beauty of the National Landscape.
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Q-C4.1. Please select all options which are appropriate for South Warwickshire Option C4.1c. Option C4.1c provides the opportunity to impose more stringent requirements, which reflect best practice, than the minimum legal requirement. Q-C5.2. Please select all options which are appropriate for South Warwickshire Option C5b. Option C5b encourages the retrofit of climate change measures whilst allowing for a more flexible approach in more sensitive locations where it will be important for solutions to be sought to minimise adverse impacts on local surroundings. This consideration of sensitive locations is particularly important in the Cotswolds National Landscape, where cultural heritage (including the historic environment) is one of the features that contributes to the natural beauty of the area and where the local distinctiveness of the built environment (including the vernacular architecture and use of local Cotswold stone) is one of the area’s special qualities. An alternative option would be to apply Option C5b in the Cotswolds National Landscape, Conservation Areas and in listed buildings and their settings and to apply Option C5a elsewhere. Q-C9.1. Please select the option which is most appropriate for South Warwickshire Option C9.1a. The Environment Act 2021 sets targets for new development to provide a minimum of 10% biodiversity net gain (BNG). This statutory requirement should be reflected in the South Warwickshire Local Plan. Consideration should be given to setting higher BNG requirements than the statutory 10% BNG. Research in Kent has identified that a shift from 10% to 15% or 20% BNG will not materially affect viability in the majority of instances when delivered onsite or offsite.25 High BNG requirements are particularly relevant in the Cotswolds National Landscape. For example: . Natural heritage (including biodiversity) is one of the factors that contributes to the natural beauty of AONBs – as such, there is a statutory requirement to have regard to conserving and enhancing natural heritage / biodiversity in AONBs. . The Government-commissioned Landscapes Review has stated that AONBs and National parks should form the backbone of Nature Recovery Networks - joining things up within and beyond their boundaries;26 The Prime Minister has committed to protect 30% of UK land for nature by 2030 (30 by 30)27 … Achieving 30 by 30 will rely on improvements in how these areas [AONBs and National Parks] are protected and managed for nature recovery.28 High BNG requirements are also particularly relevant in areas that are identified as being a priority for nature recovery. We recommend that the South Warwickshire Local Plan should set a BNG requirement of 20%, at least in the Cotswolds National Landscape and in areas identified as being high priority for nature recovery. 25 Kent County Council (2022) Viability Assessment of Biodiversity Net Gain in Kent – Final Report. 26 Defra (2019) Landscapes Review Final Report.Proposal 4, page 52. 27 https://www.gov.uk/government/news/pm-commits-to-protect-30-of-uk-land-in-boost-for-biodiversity. This press release implies that the 30% figure includes the entirety of AONBs: ‘Existing National Parks, Areas of Outstanding Natural Beauty and other protected areas already comprise approximately 26% of land in England. An additional 4% … will be protected to support the recovery of nature’. However, the Government’s response to the Landscapes Review states that ‘at present, under their current statutory purposes, level of protection and management, protected landscapes cannot be said to contribute towards 30 by 30 in their entirety’. 28 Landscapes review: government response Since the publication of the review - nature and climate.
