Cotswold District Local Plan Update consultation. Draft Policies: Tracked changes updated to include EN18

CO recognise the important contribution of open spaces and gaps to the distinctive
character of the District’s smaller settlements and believe this added wording is useful
within the supporting text to Policy DS3. However, it is considered the proposed
updates to Policy DS3 – Small-scale Residential Development in Non-Principal
Settlements are more restrictive and appear to contradict the Council’s objective to
address the issue of affordability, particularly in regard to the under-delivery of homes
in the Local Plan as explained above.
1.34. A new set of accessibility standards have been proposed to Policy DS3. The standards
set out in DS3(e) requires sites for new residential development to be within specified
journey times between 20 – 40 minutes by foot or public transport to at least six
services and facilities. The purpose of the standards is to, supposedly, help new
housing developments to have reasonable access to services, facilities and employment and to reduce social isolation vehicle dependence/cost of living issues and
transport emissions.
1.35. Whilst it is understood that residents of non-principal settlements should have
reasonable access to some services and facilities, the proposed standards are
unnecessarily complex for potential applicants and planning case officers to navigate.
1.36. Furthermore, CO consider that they disregard the rural nature that makes the
Cotswolds distinctive. The prevalence of small, intimate villages across the Cotswolds
makes the district nationally distinctive. These standards will be unachievable for new
development in many hamlets and villages and will result in the exclusion of
appropriately scaled new residential development from small villages.
1.37. Excluding residential development from the smaller non-principal settlements goes
against national policy objectives to support the vitality of rural communities.
Paragraph 83 of the NPPF states that “Planning policies should identify opportunities
for villages to grow and thrive, especially where this will support local services. Where
there are groups of smaller settlements, development in one village may support
services in a village nearby.” The accessibility standards proposed will not be
achievable for many smaller villages and will halt the sustainable development of these
settlements. Without new residential development, these smaller settlements will
stagnate and lose their key services and facilities.
1.38. Examples of smaller settlements which are established as Non-Principal settlements
but cannot meet the proposed accessibility standards include Compton Abdale,
Cowley, Cold Aston, Longborough, to name a few. These settlements have 4/5 services
within the village as well as bus route, however the bus routes only run 1-2 days per
week and would not allow for a day of ‘normal’ working hours. Small-scale residential
development in these villages would enhance their vitality and comprise sustainable
development. However, the proposed accessibility standards would entirely exclude
new-build open market housing from these areas.
1.39. National policy recognises that in rural areas, smaller settlements have an element of
dependency on other villages nearby. However, the proposed standards have no
regard for this. In the Cotswolds, clusters of smaller villages are often linked by narrow
county lanes with no footways or streetlighting and often no bus routes. Local residents
will be reliant on the private car to travel between numerous villages to use different
local services. While there will be some services and facilities accessible by walking or bus routes, it is unlikely that six will be achievable. This, however, does not make a
village unsustainable, and national policy recognises this. Appropriately scaled
residential development across all non-principal settlements is key to promote
sustainable development within rural areas, in accordance with paragraph 83 of the
NPPF.
1.40. CO also recognise that younger generations and first-time buyers are being socially
excluded from the non-principal settlements across the district due to the lack of
availability of affordable and lower cost housing. Policy DS3 needs to facilitate growth
in non-principal settlements in order to welcome the opportunity for a wider range of
housing types and tenure to be built, along with improving affordability of the area.
More affordable and starter homes need to be delivered in these areas to allow younger
generations to stay in or close to the areas they grew up, work or have close
connections with. This demographic is fundamental for the vitality, viability and
ultimately, the retention of existing services and facilities in non-principal settlements.
These settlements need to be given opportunities to support starter homes to retain
key village services and facilities.

The proposed changes to Policy DS1 are somewhat confused. Amended paragraph
6.1.1 states that the need for the period 1 August 2023 to 31 March 2031 is based on
the standard method for calculating housing need, but then the plan makes no update
to the housing requirement at Policy DS1 and Tables DS1A – both still state 8,400
dwellings. Furthermore, the annualised requirements at Table DS1B show that the
standard method Local Housing Need is not proposed to be applied until 2031/32 (i.e.
after the end of the current plan period).
1.27. It is CO’s position for the reasons set out at paragraphs 1.13 to 1.31 above, that the
standard method Local Housing Need must be applied now. Thus, if the Council is
seeking to demonstrate a 5 year supply through the partial update (notwithstanding
our objections to the Council’s approach in this regard), this should be based on the
Local Housing Need of 493 dwellings per annum.
1.28. Instead, the Council are seeking to persist with the adopted Local Plan requirement,
but with a significant reduction to factor in previous over delivery during the plan
period. A reduced annualised requirement of 265 dwellings per annum is used which
is some 228 dwellings/annum lower than the standard method requirement.
1.29. The Housing and Economic Needs Assessment PPG makes it clear that the standard
method identifies a minimum annual housing need figure. Basing a five year housing
land requirement on a figure that is below the minimum annual requirement (multiplied
by five) is therefore clearly inconsistent with the Government’s intended approach.
Moreover, having regard to paragraph 77 of the NPPF and the expectation at paragraph 33 for strategic policies to be updated at least once every five years if their
applicable local housing need figure has changed significantly, including past delivery
against a now out of date housing requirement is not considered to be a sound
approach. This approach has recently been endorsed at a number of appeal decisions
at Malvern and Wychavon Districts including Land at Leigh Sinton Farms
(APP/J1860/W/21/3289643) and Land off Morris Road, Broadway
(APP/H1840/W/21/3289569) amongst others.
1.30. Thus, it is considered that first, the higher figure of 493 dwellings/year should be used
as the basis for calculating 5 year supply, and, second, the Council’s previous over
supply should not be deducted from the requirement.
1.31. The five year housing requirement used at Table DS1C should therefore be 2,465
dwellings. The Council’s identified housing supply of 1,918 dwellings for the period
2023-28 would therefore equate to a 3.89 years supply – a shortfall of 547 dwellings.
1.32. It is clear therefore that Policy DS1 is now out of date. It is no longer able to equip the
Council with a 5YHLS. The plan is unable to meet the Local Housing Need for the remainder of the plan period and additional allocations are required. The Local Plan Update significantly under delivers on housing and a more in-depth, whole scale review is required moving forward.

LPU Q35 POLICY H4 - SPECIALIST ACCOMMODATION FOR OLDER PEOPLE
LPU Q35 - We have made various updates to policies H1 to H7 and have introduced policies H8 to H11. Are there any reasons why these updates and new polices shouldn’t be included in the Local Plan?
Draft Policy H4 - Specialist Accommodation for Older People
5.1
Draft Policy H4 details the requirements Specialist Accommodation for Older People developments must meet to secure planning permission. It also repeats the Districts housing requirements for such developments, using the same requirement as set out in the adopted Local Plan.
Paragraph 8.4.1 Requirement
5.2
Paragraph 8.4.1, states that there is a requirement for ‘665 (C3 use class) sheltered and extracare housing units between 2017 and 2031’It is stated that the 665 figure is arrived from the SHMA Update (April 2016). The SHMA is an outdated data source and should not be relied upon for setting housing requirements. It is considered that the requirement figure should be updated and revised to reflect actual need and not just repeat the adopted Plan requirement.
5.3
As a minimum the requirement should be updated to reflect the Gloucestershire County Council (GCC) Local Housing Needs Assessment (LHNA) (2020) although an up to date assessment to support the LPU should be undertaken. This is a particularly critical issue given the changing demographics of Cotswold District. The GCC LHNA models the demand for ‘Older Persons Housing’, and at Figure 74, sets out an additional sheltered accommodation housing need of 1,699 owned and 440 rented homes up to 2041, totalling 2,139 homes.
5.4
It is further stated in paragraph 8.4.1 that the Council propose in future housing requirement figures should be based on Residential Land Monitoring Statistics Reports stating:
“The requirement figures provides a snapshot in time and applicants must refer to the Council’s latest monitoring evidence, provided by future updates to the Residential Land Monitoring Statistics report, when submitting planning applications, in order to determine the remaining requirement(s) and to help determine the need for the development proposal."
5.5
The proposed amendments to the policy wording, completely change the approach to addressing the need for specialist accommodation. The adopted Local Plan acknowledges that the SHMA provided a snapshot in time and that it would be necessary to refer to the latest evidence when submitting planning applications. The Council now appear to be dismissing the likely changes in need and are seeking to restrict the delivery of specialist accommodation to the levels of need identified in the 2016 SHMA, which is completely unjustified.
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5.6
Given that the SHMA (2016) identified a dramatic growth in the older population in Cotswold, this approach would appear to be completely contrary to the actual need as well as the draft LPU’s Vision and Objectives as well as being contrary to national planning policy and guidance which seeks to ensure provision is made for older people.
5.7
It is therefore clear that the housing requirements referenced in paragraph 8.4.1 is not justified and needs to be revised as based on an update to date Local Housing Needs Assessment.
Paragraph 8.4.1 Vacant Units
5.8
Draft paragraph 8.4.1 (last sentence) introduces new wording stating:
“Consideration should also be given to vacant units within existing stock, especially in the location the development is proposed. Specialist accommodation for older people should include a range of tenures and should not contribute to unbalanced communities.”
5.9
The proposed wording related to vacant units needs to be amended to provide greater clarity, if indeed it should be included at all, particularly given the anticipated demand for older persons accommodation and the increasing proportion of residents 75+ years in the District. As currently worded, the ‘test’ is vague and as it does not form part of the policy it is not clear as to whether this can be required. It is also unclear as to what would even constitute a vacant unit.
5.10
If to be retained, the proposed amended wording should provide a number of clarifications such as that the ‘comparison’ would only be relevant where it relates to accommodation of the same type as that being proposed. This could be based on the three descriptions of older persons accommodation as set out in the NPPF at Paragraph 63 “retirement housing, housing-with-care and care homes”. Further to which, any ‘comparison’ should also only relate to the type of accommodation being applied for by Use Class. A blanket approach based on the current wording would be inappropriate and unjustified and would fail to ensure that specific housing needs are being met.
5.11
The ‘comparison’ should also consider whether the vacant stock is comparable in terms of dwelling mix i.e. apartments or cottages/houses as this can have considerable bearing on this particular market sector.
5.12
The Council need to set out how they will make such an assessment and what evidence an applicant would need to provide and what threshold they will apply. It is considered that this amendment is not robust nor justified. Indeed, there appears to be no evidence base to support this amendment, it is therefore recommended that the wording is deleted.
Policy H4 Wording
5.13
Newlands of Stow agrees that the Plan needs to deliver a range of different types of accommodation for older people. However, at limb ‘1’, the type of older persons accommodation is not consistent with the provision stated at paragraph 63 of the NPPF, as follows:
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“…including those who require retirement housing, housing-with-care and care homes…”
5.14
It is therefore recommended that the policy (as well as paragraph 8.4.2) is reworded as follows to be consistent with the NPPF’s recognised range in typologies of older persons accommodation:

“Proposals for specialist accommodation for older people, including retirement housing, housing-with-care and care homes and other appropriate models of accommodation for the elderly older people and those with particular needs, will be permitted provided that the development:”

Limb 1 criterion a states that older persons accommodation will be permitted where it “meets a proven need for that type of accommodation in both the District and the settlement”. The Draft LPU is not supported by any up to date evidence base which defines either District-scale or individual settlement-scale older persons housing need. Paragraph 8.4.1 states that identified need is based on Residential Land Monitoring Statistics Reports, however, as indicated the Reports measure past delivery, rather than assessing future housing needs and planning accordingly. It is therefore anticipated that Need assessments will be submitted with each application, however this is not what the policy sets out.
5.16
As stated at Paragraph 61 of the NPPF, housing need calculations are required to be informed local housing needs assessments, conducted using the standard method in national planning guidance. Furthermore, Paragraph 61 states that such assessments should reflect current and future demographic trends and market signals. To this end, Paragraph 63 states that within the context of establishing need, the size, type and tenure of housing needed for different groups in the community should be assessed and reflected in planning policies. As stated above, different types of older persons accommodation (including those who require retirement housing, housing-with-care and care homes) should be specifically accounted for in such assessments.
5.17
As detailed above, the GCC LHNA (2020) goes some way to breaking down particular needs of older persons accommodation typologies. However, that document itself is outdated, and it is recommended that CDC or GCC prepare an up to date assessment of housing need to forecast accurate figures going up to 2041. For example, the accompanying Planning Needs Assessment (Appendix 2) finds there to be a need for 1,067 open market retirement living units by 2026, based on latest analysis.
5.18
As such, the stated figures which limb ‘1.a’ of Draft Policy H4 refers to (as detailed in paragraph 8.4.1) are not justified or consistent with national policy. The draft policy therefore needs to be backed by an evidence base which is consistent with national policy. It is also critical that evidence clearly defines up to date housing need for not just the district, but also each individual settlements, if limb 1 criterion a is to include the reference to ‘settlement’.
5.19
Newlands of Stow agrees with limb 1 criterion d insofar that older persons accommodation should adhere to good practice in design principles, especially taking account of design for people with dementia. However, given limb ‘d’s’ direct linkage to limb ‘1’ which encompasses
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all older persons accommodation, the wording of the
criterion ‘d’ could be interpreted that all older persons accommodation needs to take into account design for people with dementia. It is neither justified or assumedly intended that the policy requires all developments to account for people with dementia, given it is neither viable or practical for all older persons development to account for such provisions.
5.20
It is therefore recommended that criterion ‘d’ is reworded to distinguish that the emphasis in design principle for dementia care is unlinked from the all-encompassing limb ‘1’.
5.21
The newly introduced criterion g is confusing and unclear. The amendment proposes a significant change, however the wording is difficult to understand and requires greater clarification.
5.22
While there is no objection that affordable housing that is to be provided is to be occupied by people with a local connection, there is confusion as to what the Council’s expectation is in relation to those occupiers. Criterion g should clarify that such persons should also be subject to the same age restriction as the remainder of that development.
5.24
If under Criterion g and h it is the Council’s intention that any such affordable housing to be provided on site, is not age restricted then it is not clear as to how such provision is expected to work operationally. Affordable Housing providers do not like to build and then manage properties that are part of a wider community, particularly where the number of units is relatively low, making such a proposition unviable for them.
5.25
Clarification is also required in relation to Policy H2’s First Homes requirement as it highly unlikely that any First Homes could work operationally on a site for a retirement or integrated care community, where clearly it would undermine the very purpose of the community to allow for any age occupier, who would in any event be required to contribute to the service charge making such a proposition untenable. The Council must therefore ensure the Policy allows for such provision off-site where viable. Further clarification should be provided in Paragraph 8.4.8 on this matter, which appears to have been ignored.
5.26
It has been accepted by Inspectors in various Appeal Decisions that it is not always practicable or desirable to include affordable housing on schemes for specialist accommodation for a number of reasons, but not least due to the service charge that would still be applicable on any affordable housing within a wider Integrated Retirement Community (IRC). Please see our further relevant comments as set out in relation to Policy H2 in these representations, which also apply to Criterion g and h. It is not clear that the proposed amendments are fully justified nor what evidence supports the requirement and how the issues raised above have been assessed.
5.27
As set out in our representations made in relation to Draft Policy DS1, there is a need to allocate development sites for specialist accommodation for older people. In the absence of such a policy, it is imperative that Draft Policy H4 remains the permissible policy for establishing the principle of permitting such development schemes through compliance of the set criteria and should explicitly recognise that there are not always sites within development boundaries.

Site Allocations for ‘Retirement Housing’ and Specialist Accommodation for Older People
3.48
Newlands of Stow strongly encourages the Council to reconsider the unjustified decision to neglect consideration of allocating sites to deliver specialist housing to meet the identified needs of a specific group within the community, as required by the NPPF and PPG. In particular, Newlands of Stow recommends that the Council allocate specific sites to meet the identified need for retirement housing, housing with care, and care homes.
3.49
As a result of CDC seeking to minimise both the plan period and housing requirements, Draft Policy DS1 proposes to make no further site allocations to meet housing need. Of further concern, is that despite the NPPF being revised in December 2023 to promote housing needs assessments to identify a range of housing for strategic development, Draft Policy DS1 remains unchanged notwithstanding it now being clearly inconsistent national policy. As further detailed below in response to Draft Policy H4, The National Planning Policy Framework (‘NPPF’) at paragraph 63 is clear that (emphasis added):
“Within this context of establishing need, the size, type and tenure of housing needed for different groups in the community should be assessed and reflected in planning policies. These groups should include (but are not limited to) those who require affordable housing; families with children; older people (including those who require retirement housing, housing-with-care and care homes); students; people with disabilities; service families; travellers; people who rent their homes and people wishing to commission or build their own homes.”
3.51
Newlands of Stow considers that the Draft LPU, as currently formulated, is unsound. The absence of site allocations to accommodate development specifically seeking to address the identified needs for specialist accommodation results, in our view, in a plan that is neither positively prepared nor effective in meeting the housing needs of different groups in the community. In addition, Draft Policy DS1 is inconsistent with national policy which includes the specific identification of the need to assess the needs of older persons ‘including for retirement housing, housing-with-care and care homes’ and reflect this within planning policies. National Policy clearly requires the specific consideration of need for ‘retirement housing’ and specialist older persons accommodation and the allocation of sites to meet this need.
3.52
There has been no justification from the Council with regard to the decision to neglect the allocation of sites to meet the needs of older persons. Indeed, it is noted that paragraph 3.11 of the 2023 Regulation 18 Draft Local Plan consultation document did not make it clear that such sites have been discounted from the SHELAA, simply on the basis they have been promoted for specialist accommodation. However, the 2022 Regulation 18 ‘Issues and Options’ consultation summary report (page 57) confirms that sites for such a use will not be allocated, but no reason is given to justify the position.
3.53
In relation to the current Draft LPU Regulation 18 consultation, the concept of allocating or even considering alternative strategies to specifically meet the needs of specialist accommodation for older people, is neither assessed nor even presented as alternative development strategy in evidence base papers. The Integrated Impact Assessment (IIA) (February 2024) states itself at Section 3 in the context of assessing different development strategy options for the District, that:
“An overview of further reasonable alternatives work that will be undertaken prior to Regulation 19 consultation on the pre-submission version of the Local Plan Update is also provided in Chapter 0.”
3.54
It is further stated in Section 7, in the context of housing, that:
“The spatial development strategy for the Plan remains largely the same (albeit a couple minor updates at Cirencester and Andoversford). Therefore, the positive effects concluded in the 2017 SA are considered likely to remain, reflective of a housing delivery plan that meets forecasted needs in full, delivering development in accessible and connected locations, and providing for a range of housing types and tenures to address varying needs across the district.”
3.55
It is therefore evident that CDC have not undertaken a robust assessment of reasonable alternatives development strategies since the 2017 Sustainability Appraisal was undertaken, despite the subsequent revisions to the NPPF, which have significant implications on development strategies.
3.56
It is noted that CDC are planning to undertake further reasonable evidence base assessments to consider alternatives to accompany the Regulation 19 consultation. However, it is clear that any alternative strategies assessed at this stage of the local plan making process cannot be significant enough to redress the inconsistencies with National policy in the context of planning to positively planning to address the needs of older persons, as noted above. The reason for this being, as stated in the Procedure Guide for Local Plan Examinations (8th edition), LPA’S should “rigorously assess the plan before it is published under Regulation 19 to ensure that, in their view, it is sound and meets all the necessary legal requirements.” The timings of the strategy proposed in the IIA would clearly not allow for a rigorous assessment, without making comprehensive changes to the Draft LPU which would revert it back to a Regulation 18 Consultation.
3.57
The Gloucestershire Local Housing Needs Assessment (2020) (‘LHNA’), which forms an essential part of the evidence-base supporting the emerging plan, identifies that there is a clear and ‘substantial’ need for housing to accommodate the needs of older persons up to 2041. We consider the LHNA requires further updating to inform the Regulation 19, particularly given the evidence as set out in the Carterwood Needs Assessment for retirement accommodation, as included in Appendix 2.
3.58
To summarise the position set out in the LHNA, Paragraphs 4.2 – 4.3 of the LHNA raise fundamental issues for the Local Plan to address, given the significant projected increase in the population of older people within the Cotswold District. The LHNA confirms, at Paragraph 23, that the projected population increase within Gloucestershire of persons aged 75+ alone is set to see an additional 52,232 individuals entering the bracket. This is almost twice the baseline population of 68,131 persons and results in an additional need of just over 14,500 sheltered houses in that period.
3.59
The LHNA further confirms, at Figure 68, that of the total projected population change in Cotswold District of 13,838 persons up to 2041, 11,957 of those relates to the increase in people aged 65+. This comprises 86% of the entire population increase for Cotswold District, in a group in which many individuals hold specific housing requirements.
3.60
Given the total projected population increase within this community group, the LHNA models the demand for ‘Older Persons Housing’, at Figure 74, to comprise additional sheltered accommodation housing of 1,699 owned and 440 rented homes up to 2041.
3.61
Therefore, there is a clear and substantial need within Cotswold District to accommodate the specific housing needs of older persons. However, Cotswold District have decided to exclude consideration of site allocations for these forms of development within the Draft LPU. Newlands of Stow is not aware of any specific justification for the exclusion of sites on this
basis.
3.62
Planning Practice Guidance (‘PPG’) is clear that ‘it is up to the plan-making body to decide whether to allocate sites for specialist housing for older people’ . However, PPG provides that “allocating sites can provide greater certainty for developers and encourage the provision of sites in suitable locations. This may be appropriate where there is an identified unmet need for specialist housing” (Paragraph: 013 Reference ID: 63-013-20190626).
3.63
Newlands of Stow considers that for the LPU to be considered sound, Draft Policy DS1 must include consideration of a requirement specifically to meet the needs of specialist accommodation, including affordable housing, as part of an effective, positively prepared and justified approach. In neglecting to consider the allocation of sites to meet these identified needs, the emerging plan leaves the direction of ‘retirement accommodation’ and other specialist accommodation to chance, relying on speculative planning applications coming forward within the plan period.
3.64
Cotswold District Council planning officers have recently indicated in relation to later living accommodation that the introduction of development beyond established development boundaries of towns would raise significant concerns, albeit that Policy H4 which relates to older persons housing, is a permissive policy. If no site allocations are proposed to meet this identified need, and the development of sustainable sites adjacent to the existing principal settlements within the District are problematic for officers, the District is reliant upon the conversion of land within existing settlements to provide the need, which is not likely to happen, given the lack of available sites and the competition that operators face from residential developers who do not incur the same development and operating costs as an operator.
3.65
In line with the Councils’ spatial strategy principles of selecting sustainable Use Class C3 housing sites for allocation, it is notable that if the same principles were to be applied to specialist accommodation, such as for older persons and those with care needs, the extension of Newlands of Stow would form a preferable site for allocation, particularly as it complies with the requirements of Policy H4.
3.66
The NPPF is clear at paragraph 182 that ‘great weight should be given to conserving and enhancing landscape and scenic beauty in […] Areas of Outstanding Natural Beauty, which have the highest status of protection in relation to these issues’. Furthermore, the NPPF is clear that ‘planning policies and decisions should contribute to and enhance the natural and local environment by [inter alia] protecting and enhancing valued landscapes’.
3.67
Given the extent of Cotswold District that is covered by the Cotswolds National Landscape, it is clear that in the context of the substantial identified need for development, some extent of that development will be required to come forward within the Cotswold National Landscape. As such, the District’s proposed Spatial Strategy, which Draft Policy DS1 is instrumental in implementing, becomes even more significant, insofar as it is essential to ensure that the right types of development are directed to the right locations to avoid greater harm to the
broader landscape and character of the Cotswolds National Landscape.
3.68
The Draft LPU presents an opportunity to ensure that the requisite development is directed toward the most sustainable locations, such as Stow-on-the-Wold, thereby avoiding and/or minimising adverse impacts to the broader designated area. The Council’s decision not to consider site allocations for ‘retirement accommodation’ and specialist accommodation for older persons, and consequent reliance on speculative development outside the direction of the District’s development strategy, represents an approach that is unsound.
3.69
Newlands on Stow supports the Council’s proposed continuation of the adopted spatial strategy, insofar as development is directed toward the 17 Principal Settlements within Cotswold District, including Stow-on-the-Wold. However, the Council’s decision to simply ignore the allocation of sites to meet the identified needs for ‘retirement accommodation’ and specialist accommodation generally serves to undermine the purpose of the development strategy.
3.70
The Council’s decision in this regard is not consistent with the Vision set out in the adopted Local Plan, to which this update is related, to support ‘the delivery of a range of housing that helps to meet the requirements of all sections of the community’ .
3.71
It is therefore clear from the Council’s own evidence base that there is a substantial need for accommodation for older persons within Cotswold District. Without specific consideration through the LPU process, it is also clear that this need will not be met within the plan period and that any development coming forward in these uses would not benefit from direction under the District’s development strategy.
3.72
As such, Newlands of Stow strongly encourage the Council to consider identifying specific site allocations within the Local Plan update to meet these needs. To assist in meeting the identified needs, Newlands of Stow promote the Land at Newlands of Stow Care Village for the development of 24 ‘retirement accommodation’ dwellings as an extension to the existing Care Village. The site has been duly submitted in the ‘Call for Sites’ process which accompanies this consultation.

Policy DS1 as proposed to be amended, indicates that development will be direct to the Principal Settlements and will deliver at least 8,400 (C3 use class dwellings over the Plan period to 2031. This figure excludes a proportion of the C2 use class requirement, as set out in the evidence base documents but not reflected in the revised Policy wording.
3.2
The draft text also seeks to introduce a new part to the policy, indicating that the housing requirement will be monitored against a stepped (residual) requirement for the remaining years of the plan period as set out in the newly proposed housing trajectory.
3.3
The supporting text set out in relation to Policy DS1 has also been significantly updated and notes that the District’s OAN is 9,094, based on the standard method for calculating need for the period 1 August 2023 to 31 March 2023.
3.4
The basis for these amendments are set out in a number of Topic Papers and other evidence based documents, although it is very unclear as to what documents are actually form part of the evidence base on the Council’s website and no list is provided. Greater clarity would ensure that consultees are not disadvantaged by not being able to locate the relevant information.
3.5
In principle, Newlands of Stow considers that the Council’s current ‘Development Strategy’ is likely to be found unsound at an Examination in Public. The reasons that have informed this view are discussed below in turn.
3.6
Newlands of Stow supports the majority of CDC’s criteria set out to inform the Development Strategy, which seeks to deliver sustainable development. However, Newlands of Stow considers that there are several flaws and omissions within the Development Strategy and its evidence base, including the housing requirement and application of the Standard Method, past over-delivery, the use of a stepped trajectory, the plan period, the spatial strategy and site allocation methodology, which the Council are strongly encouraged to reconsider before progressing the plan any further.
Reviewing the Housing Requirement
3.7
Draft Policy DS1 identifies a Housing Requirement for the District comprising 8,400 dwellings over the Plan period, which relates to an average of 420 dwellings per annum (‘dpa’). This is the same requirement as that calculated in the adopted Cotswold District Local Plan (2011 – 2031).
3.8
Following the Plans adoption in 2018, a Review under Regulation 10A was undertaken in 2020, which identified a number of policies which required updating. However, following the Review, the Council paused the implementation of the changes required and eventually determined not to update the housing requirement in line with the Governments Standard
Method.
3.9
A further Review of the Plans policies was undertaken in the summer of 2023, when the adopted Plan reached 5 years old and automatically triggered a review as required by the NPPF / PPG to ensure the Plan remains effective. The 2023 Review suggested that while the adopted housing requirement was lower than the updated housing need, the Council would not update the housing requirement set out in Policy DS1.
3.10
Opinion Research Services (ORS) were appointed by the Council to review whether the housing need figure for Cotswold had changed significantly. The report is clear to stress that the although the adopted housing requirement reflected a housing need figure of 8,400 dwellings at the time, it is important to recognise that this was never intended as a definitive assessment of the precise level of housing need and goes on to explain the 8,400 figure was a midpoint between two separate assessments. The figure was derived as a mid-point of a range a considered the most appropriate figure at the time.
3.11
The report states at Paragraph 16 that although the standard method figure (455 dpa) (based on the relevant data for March 2016) was higher than the housing need figure that informed the adopted Local Plan (430 dpa (taking account of the need for Use Class C2 as well as C3 hence above 420 dpa)). The figure was considered to be within the range that had been identified when setting the requirement (390 to 475 dpa).
3.12
The Council agreed with the findings of the ORS Report which concluded that as the increase in local housing need was less than 15% and it did not constitute a significant change, for the purposes of the triggering a need to a review the housing requirement.
3.13
The Council’s Housing Requirement Evidence Paper (August 2023) provided an update on the ORS findings and notes that the Local Housing Need for Cotswold District, as derived through the Government’s Standard Method for calculating housing need, comprised a minimum of 493 dpa (as derived from the Gloucestershire Local Housing Needs Assessment (September 2020) equivalent to 9,094 dwellings (rather than 8,400 dwellings).
3.14
The Requirement Evidence Paper concludes that the change in local housing need is not large or important enough to have an effect or be noticed and goes on to state that the adopted Local Plan housing requirement(s) already fully delivers the increased need. The Council do indicate it would continue to maintain that the housing requirement is a minimum, not a maximum, when determining planning applications. However, the clear consequence of not updating the housing requirement, in light of the need, is insufficient housing delivery to address the housing needs of Cotswold Districts’ residents.
3.15
Having undertaken a review of the Government’s Standard Method calculation to derive Cotswold District’s current minimum Local Housing Need figure following the release of new affordability ratios on 25 March 2024, the District’s current minimum housing requirement figure has increased to 504 dpa. This calculation applies the 2014-based household projections from 2024 to 2034 and includes the latest available median workplace-based housing affordability ratio figure for the District of 14.88. Consequently, the District’s local housing need figure is clearly continuing to take an upward trajectory, reflecting persistent under-delivery of housing within the area based on an under-estimate of the housing need. As a result, it is considered that the District’s Housing Requirement should now be fully reviewed and updated to reflect the most up-to-date calculation, as set out above, of 504 dpa. This comprises 84 homes per year of shortfall that the District is not delivering based simply on the Council’s decision not to review and update the housing requirement. The Council do not appear to argue in the Housing Requirement Evidence Paper (August 2023) that the adopted local plan housing requirement of 420 is up to date, rather just that the increase in need is not considered to be significant. We do not consider that this is the right approach in planning to meeting future housing needs and nor does it reflect the Council’s view that the requirement represents a minimum number.
3.17
The Council’s departure from using the Standard Method is inconsistent with national policies insofar that paragraph 61 of the NPPF requires “The outcome of the standard method is an advisory starting-point for establishing a housing requirement for the area”. To this end, the Council’s Housing Requirement Evidence Paper (August 2023) specifically defines no exceptional circumstance to deviate from the standard method, despite it being a significant deviation of 20%.
3.18
Furthermore, the Standard Method is based on population projections undertaken from 2014-based estimates, which derived their projections from the 2011 census, 12 years ago. Data released from the most recent Census, undertaken in 2021, demonstrates that there are 1,396 households within Cotswold District above the projected figure of 39,204 households based on the 2014 projections, which is 3.6% higher than the projections.
3.19
Population growth and household formation rates have therefore clearly grown at a considerably greater rate than anticipated within the 2014-based population projections. This indicates that the demand for housing within Cotswold District has clearly outstripped the delivery of new homes which is itself based on the lower 2014-based household projections. To redress this issue, the Council must update the housing requirement to reflect more appropriate housing need estimates.
3.20
A further Review is due to take place in August 2026. It is notable that the Cabinet Report of 11 January 2024 related to the Cotswold District Local Plan Update states at paragraph 3.3 that without a Review:
“the council may become increasingly dependent on the government’s ‘standard method for calculating the housing needs’.”
3.21
Clearly the Council are seeking to minimise the overall housing requirement, rather than seeking to address the actual housing needs of the District. Given the significant increase in minimum housing needs beyond the adopted requirement, the adopted Development Strategy (Policy DS1) is clearly underproviding in relation to the District’s needs and this should be addressed through a full review of the plan. There is a significant difference between 420 dpa and 504 dpa and while the supporting text of Policy DP1 notes a revised requirement of 9,094 this is not included in the Policy which reflects the existing Local Plan figure. In any event the 9,094 will now have to be increased to 9,245 based on the March 2024 standard method calculation. In any event, by not properly planning to provide sufficient housing to meet the need, the Council will exacerbate the housing shortage in the District and make it more difficult for local people to remain in the area.
3.23
The Council’s decision to limit the scope of the local plan review to merely reflect a ‘partial update’ presents a missed opportunity to plan positively to meet the clear and substantial identified housing needs above the adopted requirement for the residents of Cotswold District over the immediate future.
3.24
Newlands of Stow therefore strongly encourages the Council to undertake a comprehensive review of the adopted local plan to update the housing requirement to reflect the most up-to-date evidence. Five Year Supply and the Use of a Stepped Trajectory
3.25
Draft Policy DS1 not only seek to resist any increase in the overall requirement to meet the identified housing need, but it also seeks to introduce a stepped trajectory whereby the delivery of the housing requirement will be monitored against a stepped (residual) requirement for the remaining years of the plan period. The purpose of the stepped trajectory is to minimise the housing requirement and to avoid having to update the figure.
3.26
A stepped trajectory is usually used in circumstances where a Local Plan moves from a relatively low housing requirement figure to a much higher housing requirement, so that there is sufficient time for the market to respond to the increase and in recognition that it can take time for sites to come forward. However, the Council are clearly seeking to introduce a stepped trajectory in this instance to reduce its overall requirement.
3.27
The Council’s application of the stepped trajectory is to deduct the completions from the Local Plan requirement of 8,400. Taking account of previous oversupply results in an annualised average stepped (residual) requirement is 2,123 or 265 dwellings per annum, which is calculated by dividing the total residual requirement by the 8 remaining years of the Plan period. This method is similar to the ‘Liverpool approach’, whereby any shortfall in delivery is equally distributed across the remainder of the Plan period. Multiplying the stepped (residual) annual requirement by five gives a five year requirement of 1,327 dwellings (i.e. 265 x 5 years = 1,327 (5)) – but then after five years it becomes a combination of residual requirement and the standard method.
3.28
Clearly, by taking the decision to not formally update the overall housing requirement either in 2020, 2023 nor in 2024 to reflect the increased housing need, the figures set out in the stepped trajectory are not reflective of the actual need. The figures will all require updating annually so it is not clear why the figures have been explicitly included in the Plan. In any event, it is considered that in calculating housing land supply, there is no basis to include past ‘over delivery’ and this notion should be removed. The Plan should make full provision to meet its annual requirement of 504 dwellings per annum or 4,032 dwellings over the next 8 years. This is reflective of the revised Government advice related to over-delivery.
3.30
This approach also aligns with Paragraph 60 of the NPPF which sets out the government’s objective of significantly boosting the supply of homes and the Council’s own view that the requirement figure is a minimum not a maximum.
3.31
It is clear however, that through deviation of the standard method and introduction of a stepped trajectory to monitor housing requirements, the Draft Policy DS1 forms a clear change in strategy to the adopted Local Plan. Such an approach would require a comprehensive review of the local plan to test its soundness.
3.32
It is notable that the Vision, Objectives and Development Strategy Options Topic Paper notes that if the Standard Method were applied then the Council would not be able to demonstrate a 5 year housing land supply. Nor meet its housing delivery target. It is imperative that the District plans to meet its housing need.
The Plan Period
3.33
As detailed in the Development Strategy, Newlands of Stow considers that the Council’s approach in undertaking a ‘partial update’ of the Cotswold District Local Plan (2011 – 2031) is problematic at this stage of the adopted plan’s life cycle. While, the Council appear to also be preparing to undertake a more comprehensive review of the Local Plan in order to ensure that development in the District is planned positively over the near future, the approach taken is not based on a full review in terms of calculating the housing requirement, rather seeking to carry forward the current requirement, in order to minimise the housing figures as opposed to positively planning to meet housing need.
3.34
This would be reflective of the approach set out in “The Vision, Objectives and Development Strategy Options Topic Paper” which considers the amount of additional development that may be needed if the Local Plan period is extended to 2041.
3.35
The NPPF is clear, at paragraph 22, that ‘…strategic policies should look ahead over a minimum 15 year period from adoption’. The Council’s existing adopted plan period runs to 2031 and the Partial Update version of the Plan does not appear to extend the plan period. It is noted that, confusingly, the new Local Plan would extend to 2041. However, if, as indicated in the Council’s Local Development Scheme (‘LDS’) (January 2024), the plan is submitted for examination in Q2 2025 to Q2 2026, it is likely that the adoption of the Plan would not take place in Q3 2026, at the very earliest and this is considered to be highly ambitious. It would be more realistic to anticipate adoption in 2027/2028 and allow for a 15 year period (albeit noting that 30 years should be considered).
3.36
The NPPF states at Paragraph 33 that:
“Policies in local plans and spatial development strategies should be reviewed to assess whether they need updating at least once every five years, and should then be updated as necessary. Reviews should be completed no later than five years from the adoption date of a plan, and should take into account changing circumstances affecting the area, or any relevant changes in national policy. Relevant strategic policies will need updating at least once every five years if their applicable local housing need figure has changed significantly; and they are likely to require earlier review if local housing need is expected to change significantly in the near future.”
3.37
The Cotswold Plan Regulation 10A review in September 2020 indicated that the Plan requires Review, however the decision to review the Plan was stalled. Given the passage of time, it is considered that it would now be more appropriate to prepare a new Local Plan, rather than a partial update.
3.38
Providing for only 5 years from the adoption of the Plan to the end of the plan period, is well below the minimum 15-year period from adoption. It does not allow for a full review of housing need to be undertaken and it also skews the residual calculation in terms of 5 year housing land supply, particularly given that the local plan figure of 8,400 was not considered determinative by ORS.
3.39
Newlands of Stow considers that the approach taken does not represent a plan-making process that is either positively prepared, or effective. The Council’s decision to simply leave the comprehensive review of the Local Plan to the end of the current plan period leaves the District open to the prospect of facing a period between Local Plans, where speculative unplanned development could come forward.
3.40
To redress this, Newlands of Stow recommends that the Council progresses with the full review of the adopted Local Plan, with an extended plan period up to approximately 2043/44 for robustness, wherein a minimum of 15 years since adoption would likely be maintained post-adoption. In simply undertaking a partial review of the adopted plan, the Council is missing an opportunity to positively plan for the identified needs of the District over the foreseeable future.

Further Restriction of Small-Scale Residential Development at Non-Principal
Settlements – Policy DS3
1.33. CO recognise the important contribution of open spaces and gaps to the distinctive
character of the District’s smaller settlements and believe this added wording is useful
within the supporting text to Policy DS3. However, it is considered the proposed
updates to Policy DS3 – Small-scale Residential Development in Non-Principal
Settlements are more restrictive and appear to contradict the Council’s objective to
address the issue of affordability, particularly in regard to the under-delivery of homes
in the Local Plan as explained above.
1.34. A new set of accessibility standards have been proposed to Policy DS3. The standards
set out in DS3(e) requires sites for new residential development to be within specified
journey times between 20 – 40 minutes by foot or public transport to at least six
services and facilities. The purpose of the standards is to, supposedly, help new
housing developments to have reasonable access to services, facilities and employment and to reduce social isolation vehicle dependence/cost of living issues and
transport emissions.
1.35. Whilst it is understood that residents of non-principal settlements should have
reasonable access to some services and facilities, the proposed standards are
unnecessarily complex for potential applicants and planning case officers to navigate.
1.36. Furthermore, CO consider that they disregard the rural nature that makes the
Cotswolds distinctive. The prevalence of small, intimate villages across the Cotswolds
makes the district nationally distinctive. These standards will be unachievable for new
development in many hamlets and villages and will result in the exclusion of
appropriately scaled new residential development from small villages.
1.37. Excluding residential development from the smaller non-principal settlements goes
against national policy objectives to support the vitality of rural communities.
Paragraph 83 of the NPPF states that “Planning policies should identify opportunities
for villages to grow and thrive, especially where this will support local services. Where
there are groups of smaller settlements, development in one village may support
services in a village nearby.” The accessibility standards proposed will not be
achievable for many smaller villages and will halt the sustainable development of these
settlements. Without new residential development, these smaller settlements will
stagnate and lose their key services and facilities.
1.38. Examples of smaller settlements which are established as Non-Principal settlements
but cannot meet the proposed accessibility standards include Compton Abdale,
Cowley, Cold Aston, Longborough, to name a few. These settlements have 4/5 services within the village as well as bus route, however the bus routes only run 1-2 days per
week and would not allow for a day of ‘normal’ working hours. Small-scale residential
development in these villages would enhance their vitality and comprise sustainable
development. However, the proposed accessibility standards would entirely exclude
new-build open market housing from these areas.
1.39. National policy recognises that in rural areas, smaller settlements have an element of
dependency on other villages nearby. However, the proposed standards have no
regard for this. In the Cotswolds, clusters of smaller villages are often linked by narrow
county lanes with no footways or streetlighting and often no bus routes. Local residents
will be reliant on the private car to travel between numerous villages to use different
local services. While there will be some services and facilities accessible by walking or bus routes, it is unlikely that six will be achievable. This, however, does not make a
village unsustainable, and national policy recognises this. Appropriately scaled
residential development across all non-principal settlements is key to promote
sustainable development within rural areas, in accordance with paragraph 83 of the
NPPF.
1.40. CO also recognise that younger generations and first-time buyers are being socially
excluded from the non-principal settlements across the district due to the lack of
availability of affordable and lower cost housing. Policy DS3 needs to facilitate growth
in non-principal settlements in order to welcome the opportunity for a wider range of
housing types and tenure to be built, along with improving affordability of the area.
More affordable and starter homes need to be delivered in these areas to allow younger
generations to stay in or close to the areas they grew up, work or have close
connections with. This demographic is fundamental for the vitality, viability and
ultimately, the retention of existing services and facilities in non-principal settlements.
These settlements need to be given opportunities to support starter homes to retain
key village services and facilities.

An additional general comment is that new planning approvals for dwellings should include a condition that the dwellings are occupied full time and not used as second homes or holiday lets.

Policy DS1 and the Five Year Housing Land Supply (5YHLS)
1.26. The proposed changes to Policy DS1 are somewhat confused. Amended paragraph
6.1.1 states that the need for the period 1 August 2023 to 31 March 2031 is based on
the standard method for calculating housing need, but then the plan makes no update
to the housing requirement at Policy DS1 and Tables DS1A – both still state 8,400
dwellings. Furthermore, the annualised requirements at Table DS1B show that the
standard method Local Housing Need is not proposed to be applied until 2031/32 (i.e.
after the end of the current plan period).
1.27. It is CO’s position for the reasons set out at paragraphs 1.13 to 1.31 above, that the
standard method Local Housing Need must be applied now. Thus, if the Council is
seeking to demonstrate a 5 year supply through the partial update (notwithstanding
our objections to the Council’s approach in this regard), this should be based on the
Local Housing Need of 493 dwellings per annum.
1.28. Instead, the Council are seeking to persist with the adopted Local Plan requirement,
but with a significant reduction to factor in previous over delivery during the plan
period. A reduced annualised requirement of 265 dwellings per annum is used which
is some 228 dwellings/annum lower than the standard method requirement.
1.29. The Housing and Economic Needs Assessment PPG makes it clear that the standard
method identifies a minimum annual housing need figure. Basing a five year housing
land requirement on a figure that is below the minimum annual requirement (multiplied
by five) is therefore clearly inconsistent with the Government’s intended approach.
Moreover, having regard to paragraph 77 of the NPPF and the expectation at paragraph 33 for strategic policies to be updated at least once every five years if their
applicable local housing need figure has changed significantly, including past delivery
against a now out of date housing requirement is not considered to be a sound
approach. This approach has recently been endorsed at a number of appeal decisions
at Malvern and Wychavon Districts including Land at Leigh Sinton Farms
(APP/J1860/W/21/3289643) and Land off Morris Road, Broadway
(APP/H1840/W/21/3289569) amongst others.
1.30. Thus, it is considered that first, the higher figure of 493 dwellings/year should be used
as the basis for calculating 5 year supply, and, second, the Council’s previous over
supply should not be deducted from the requirement.
1.31. The five year housing requirement used at Table DS1C should therefore be 2,465
dwellings. The Council’s identified housing supply of 1,918 dwellings for the period
2023-28 would therefore equate to a 3.89 years supply – a shortfall of 547 dwellings.
1.32. It is clear therefore that Policy DS1 is now out of date. It is no longer able to equip the
Council with a 5YHLS. The plan is unable to meet the Local Housing Need for the
remainder of the plan period and additional allocations are required. The Local Plan
Update significantly under delivers on housing and a more in-depth, whole scale
review is required moving forward.

I am pleased to see that the dark skies policy which hitherto has lacked enforcement is to be beefed up

I believe that significantly more than 36 dwellings are proposed on land at Aston Road. An alternative site for new houses within Chipping Campden parish is the old Polish Camp on the A44. A sizeable new village could be accommodated here complete with a convenience store and some social amenities. This would avoid the detrimental effect of significant new housing within Campden itself which does not have the road infrastructure to accommodate many additional dwellings and most sites would add to the drainage and flooding problems experienced by the town.

17.19.3
In my opinion the building of more houses doesn't "enable young people to take up local employment opportunities" because local jobs are by-and-large low paid and houses in Campden are generally expensive. Social housing at 80% of market price is often still out of the reach of lower paid workers. At the Moreton event I was told that this 80% is fixed by central government, so a discussion needs to be had between local councils and the government to review this. CPRE have suggested that "affordable" be redefined in line with local incomes not market rates and it seems to me that this has merit.

17.19.8
Such a review of HGVs is vital and indeed a paper has been submitted by Campden Town Council outlining concerns and solutions regarding both HGVs and road signage.

17.19.9
A railway station at Campden would serve little purpose as the site is some distance from the town. Residents would therefore drive to the station, in which case they might as well drive to Moreton or Honeybourne. An additional station on the line would slow train times.

Response from Lechlade Town Council to CDC Local Plan Update Consultation with a focus on responding to Scenario 1 of the Vision, Objectives and Development Strategy Options Paper
1 The CDC Local Plan Update Consultation comprises a number of documents published for consultation, as follows:
2 Executive Summary, Consultation Instructions and Questions
3 Local Plan Reg. 18 Consultation Draft Policies Tracked Changes (and a version with changes accepted)
4 Vision, Objectives and Development Strategy Options Topic Paper
5 Towards a Framework Masterplan SPD for Cirencester Town Centre (Draft)
6 Integrated Impact Assessment (IIA) Cotswold LPU Interim IIA Report 2024
7 Integrated Impact Assessment (IIA) Points of Compass Appraisal
8 Strategic Flood Risk Assessment Level 1 Draft Report 2023 with updated mapping (2023 update)
9 Lechlade Town Council previously responded to consultation on CDC SHELAA Lechlade Site Assessments in January 2022. Its response made clear that the Lechlade Neighbourhood Plan was fully supportive of existing local plan allocations to 2031. It sought the opportunity to more fully consider the sustainability of making significant allocations for the period beyond in relation to an update to the Local Plan.
10 This response focuses on the opportunity to start to review the position of Lechlade as a Principal Settlement, within the context of Scenario 1 of the Vision, Objectives and Development Strategy Options Topic Paper, which considers meeting future housing needs through allocations in Principal Settlements.
Review of the position of Lechlade as a Principal Settlement
1. A key point needs to be recognised at the outset, which is that for the most part, notions of sustainability in relation to the Principal Settlements of the Cotswolds are mostly relative to the development strategy of the Cotswolds, in common with many other rural districts, was more about making the best of a poor situation – dispersed development, too few employment opportunities, poor public transport. This is not a criticism but reflects reality.
1 Lechlade is an excellent case in point. It was made a Principal Settlement in the adopted Local Plan and attracted some housing site and employment site allocations to support housing delivery. At the time, it was one of the nine largest settlements in the district with over 2,000 population (based on the broader area covered by the two LSOA which make it up) – the built-up area of the settlement itself now has around 2,200 people (2021).
2 The CDC Role and Function of Settlements Study (2012) used information from 2001 and 2011 Census, and other survey data, to assess the role and functions of the larger settlements. This supported the designation of Principal Settlements. Some of this data shows how, at the time, the sustainability of Lechlade as a location for significant development was questionable.
3 The study examined settlements from the perspective of employment and people, retail and community facilities, and in terms of travel relationships. The sections below examine in more detail and provide updated information.

Employment and People
1. The 2012 study said that employment analysis is one of the key considerations for settlement role and function. The location of existing employment, the number of economically active people and the potential for economic growth have a strong influence on the sustainability of existing settlements.
2. In employment terms, at the time of the study, Lechlade exhibited a slightly lower economic activity rate (67%) than the rest of the district (then at 70%) based on 2001 data. Employment density (the number of jobs available for the number of economically active workers) was 0.5 meaning there were twice as many workers as jobs available and the town leaked significant numbers of workers who out-commuted to areas outside the district. ‘Self-containment’ was low at 34% indicating Swindon and West Oxfordshire as the main destinations for work.
3. Planned development in Lechlade was based on a hope that this would improve self-containment and employment density, against prevailing trends.
4. The Adopted Local Plan allocated sites for housing and for employment. So far, the employment sites remain undeveloped. Housing development in the Lechlade has occurred with around 150 dwellings expected to be completed over the plan period 2011-2031.
5. According to the 2021 Census, in 2021, percentage of the population who were economically active in Lechlade (the built-up area of the settlement itself and not the wider LSOAs 208 and 210), had declined markedly to 55.1%. Of those in work, 68.7% were working full-time. The pie charts below illustrate the position.

Retail
1. The 2012 study said that the retail facilities analysis focused on identifying retail and service provision to help define settlements which act as retail centres. In Retail terms, only around 23% of the food shopping spend was retained in the area (combined with Fairford), meaning people travelled (drove in cars) to other locations, mainly Cirencester. Only around 4% of Comparison Goods spend was retained in the area (combined with Fairford). As a service centre, it appeared that most people travelled elsewhere to do their main shopping. At the time of the study in 2012, 36 retail units were counted, 4 of which were convenience stores.
2. Since the adoption of the Local Plan, emerging trends to internet-based shopping have become firmly established, strengthened quickly and greatly by stay-at-home restrictions during the Covid pandemic.
3. Today, the presence of ‘enterprises’ on the A361 from the roundabout at Perrinsfield to the north of Lechlade through to the High Street (ending at the Vet Clinic) was as follows in September 2023 (according to Google Street View). 49 separate enterprises including all services and including the visitor information centre. Some premises provided a service and also sold food or goods retail (two functions). Of these: 17 retail shops selling general goods – goods sold include antiques, gifts, flowers, furniture, bridalwear, petrol, pharmacy, kitchen showroom.
5 retail shops selling food – Co-op Food at petrol filling station, Budgeons, Cutler and Cashin, The Health Box, Sourdough Revolution.
19 premises providing services – services include the doctors surgery, two dental clinics, visitor information, legal, building contracting, motor repair, car detailing, estate agency, hairdressing/barbering, legal services, veterinary services, boat hire, marina.
13 premises serving food and drink – 3 take aways, 5 pub/hotels, 5 café/restaurant

Lechlade town centre has retained a strong role despite wider trends and this reflects the positive focus on leisure shopping and eateries which attract local and tourist visitors to the town in combination with its position at the head of the navigable River Thames. Development which has taken place also increases footfall. This is a positive feature of change. However, this has placed existing town centre infrastructure under considerable pressure. The town would like to be able to accommodate the increased activity, but the present reality is that there are insufficient bus services and car parking to serve the town centre. Promised car parking has not been provided.
The potential for change (more development) is therefore constrained by the inability of the town centre to cope with increases in visitors arriving by car.

Community Facilities
1. For Community facilities, the 2012 assessment focused on identifying community service provision to help define settlements which act as local service centres. The study indicated the presence or absence of a range of community facilities, indicating a wide range of services/facilities in Lechlade, ranking eight in the district. Quality and capacity were not discussed fully in the study as this would relate partly to the scale of planned development which at that point was not known.
2. The development boundary was later drawn in order to ensure that future development would be proportionate to the level of services on offer in the settlement. Whilst the town is designated as a Principal Settlement, it has a limited range of services on offer. It does not host a secondary school, hospital, leisure centre, main foodstore or employment estate. The development boundary ensured that development in the Local Plan period will be at a level appropriate for the services and facilities on offer.
3. Today, local community services remain much as they were in 2012. Development has occurred, more people have come to Lechlade, demands are greater on local community services from this (but also from the changing age profile of the population) and yet the capacity of local services has not expanded to cater for them. In short, with every new development that brings in more population to Lechlade, local community services are sweated more and more.


1. Policy 7 of the Adopted Local Plan identified infrastructure projects to support development strategy based on strengthening the role of Lechlade as a Principal Settlement. This is based on a recognition that, for a town of such status, it lacks services, community infrastructure and employment. The planned development strategy is necessarily limited to two small housing site allocations totalling 18 dwellings and a small employment site of 1.25 hectares, supported with additional car parking provision through a further small site allocation.
2. Unplanned development has already occurred in Lechlade without attendant investment in community infrastructure and services. The proposed development is further unplanned development which will create immediate ‘essential’ community infrastructure requirements in the form of additional school places and more patients registering with the GP. It will also create impacts on Lechlade Town Centre and environment.

3. Policy H8 of the Lechlade Neighbourhood Plan requires that development proposals for new residential development will need to demonstrate that sufficient infrastructure (including community infrastructure) exists or can be provided to support the development. This is discussed further below.


4. The capacity of local schools - There is one primary school in Lechlade, which is St Lawrence Primary School, located on the eastern side of the town around 1.5km from the application site (or 1km if using the proposed pedestrian link). The school is part of a Multi-Academy Trust. It is a one form per year entry school with a capacity of 7 years x 30 pupil class giving a capacity of 210 pupils. The school is normally within 5% of being full and is often at capacity. Currently it is at 95% capacity. There is a physical constraint on expansion of the school. There is no space within the school property apart from its play area, which is required for its current use. Land outside the property, adjacent is within Flood Zone 2 and 3 in the open countryside. In this context, further development within Lechlade will most likely exhaust primary school places without a clear means of addressing that through expansion of the existing provision.

5. The capacity of local health services - The Lechlade Medical Centre is located on Oak Street. It is the only GP surgery in Lechlade and serves Lechlade and a larger population in surrounding villages. The practice contains four full-time equivalent Doctors and a nursing team of four.


6. Lechlade has a population of around 3,000 people. The Medical Centre has around 5,000 patients registered. Existing health services are approaching capacity. Post-pandemic, services are increasingly stretched as demands on health services have increased. The Practice is understood to be operating at around 120% capacity in terms of appointments. The latest 2021 census results indicate that average household size in England is 2.4 per people per household – further planned housing development would require corresponding improvements to local health services.

7. The capacity of the town centre and wider traffic environment - The Adopted Local Plan set a limited development strategy for Lechlade reflecting the residential development which has already occurred in recent times and the capacity of the town to accommodate further development. Supporting text in paragraphs 7.8.1 to 7.8.6 recognised this as a function of the town’s lack of local employment which creates daily outflows of traffic, the limited range of services that should be in place to support growth, and the impact of increased development on key road routes which pass


1 Neighbourhood Plan highlights the capacity constraints to receive car-based traffic in the town centre.
2 Policy S7 of the Adopted Local Plan at (b) and (f) allocated a site for a small car park to serve the town centre (LEC3) and proposed improvements to the public realm at the entrances to Lechlade and the town centre. Nothing has changed to alter these constraints since the adoption of the Local Plan.


Travel Relationships
1. The 2012 Study said that the degree of self-containment is important to the role and function of a settlement and also its sustainability. Travel patterns were investigated for the District and its surrounding area, and in particular the influence of surrounding larger urban areas were explored.
2. As already noted, Lechlade had a low employment density and low self-containment, with clear destinations for residents to go to work outside the district. A loss of workers to adjacent districts on a daily basis on the scale apparent could be accommodated in the study owing in part to Lechlade being assessed as having ‘Good’ public transport links to places of employment and to leisure.
3. This outcome was based on a local methodology for assessing the public transport accessibility of settlements in Cotswold District relative to each other and not to a more objective notion of public transport accessibility. In this way, quite poor public transport services might be regarded as good in a rural Cotswold District context. Again, this approach reflected the need to distribute development to a clear requirement in difficult circumstances and so is not criticised, but it should not form the basis for future assessment of settlement accessibility.
4. The 2021 Census was undertaken during COVID-19 and during this time a significant proportion of people in work were working wholly or partly from home. The 2021 Census indicated that 37.9% of people in employment worked mainly from home. Since then, working from home has become embedded more into regular working practices. People who previously commuted out from Lechlade every day are now much more likely to work a significant amount of time at home. Whilst employment density remains low (the jobs are not Lechlade jobs), self-containment is likely to have improved (people are not physically travelling away as much) and it improves sustainability by reducing the need to travel.
5. For people who work away from home, the graphs below indicate how far they travel to work and which modes of travel are used. 14.8% work within 10km of Lechlade – 8.1% of workers walk or cycle to work and it would be reasonable to assume that nearly everyone who does that travels less than 10km (there might be the odd cyclist going further). Only 0.5% of workers use the bus to get to work. Once those working from home or walk/cycle to work are taken out of the equation, almost everybody else in work uses some form of private motor transport to get to work.

Summary position for Lechlade
1. The main attributes in favour of Lechlade as a Principal Settlement were its size (one of the nine largest settlements) and the availability of local community services. Its role as a retail centre and as an employment centre were minor and undermined by the reality of how people behaved for work and shopping, but it could meet limited daily needs.
2. The potential for significant housing development in Lechlade to lead to people from outside the district to relocate to Lechlade and then commute back to West Oxfordshire or Swindon was recognised as undesirable. If employment development took place in Lechlade the inherent low self-containment meant that the likelihood that it would reduce out-commuting was also highly uncertain i.e. there is a low probability that all new jobs will be taken by people living in the settlement - new market housing requires high household incomes, but new jobs are often lower paid and lower skilled, creating a mismatch.

The Potential for Change to 2041
1. A further key consideration was the potential for change in settlements. In relation to Lechlade, the potential for increasing or decreasing employment was assessed. The 2012 study concluded that Lechlade had the potential for its employment role to increase with a higher proportion of jobs in growth employment sectors. However, its employment role could also diminish through an imbalance in terms of more workers than jobs and through a decreasing economically active population which could undermine the economy in the future. A clear need was identified to support the current employment role of Lechlade and to facilitate the potential increase in employment tailored to the skills of the local workforce.
2. For these reasons, whilst designating Lechlade a Principal Settlement, the adopted local plan strategy did recognise the desirability of limiting housing growth. It said new employment development must accompany new housing (notwithstanding inherent uncertainty over who takes the jobs). In Lechlade the opportunities for employment development were small and the amount of housing allocations were correspondingly small. This principle was also enshrined in Policy H2 of the Lechlade Neighbourhood Plan. Recently, CDC has confirmed the importance of this principle in the determination (refusal) of a planning application for housing and care development at the Wern outside the west of Lechlade.
3. In practice, the town saw housing development and no employment development. Within Lechlade, there is an anticipated delivery of 150 dwellings for the plan period 2011-2031. By 31st March 2023, 108 dwellings were built and 8 were consented but not built. A further 16 dwellings could be delivered through local plan allocations and 18 dwellings through windfalls between 1 April 2023 and 31 March 2031. A total of 9 dwellings have been discounted from Local Plan housing supply up to 2031 because the allocation site concerned (T31B – Land adjacent to Orchard Close, Downington) is unavailable.
4. The potential trends indicated previously have come to pass – the population is ageing fast and it is less economically active. There has been an important change in working practices – employment density and self-containment are likely to remain low, but the impacts of this may be moderated by a sustained increase in working from home.


1. Equally, the impacts of low self-containment in terms of food shopping and comparison goods shopping may be moderated by the firm establishment of home delivery services and internet shopping. Lechlade Town Centre appears vibrant for a leisure market which meets some daily needs. The constraint is in space for expansion and in terms of car parking to meet demand.
2. From a local community services perspective, it is clear that whilst there are a wide range of services available in Lechlade, they remain provided at a level and scale to cater for only a small population. If better and expanded services are not forthcoming, then more housing growth should not be either.
3. As to the future, in any event, suitable sites for more development would be needed. It is not clear where these would be found around Lechlade that are considered suitable. The prospects for further expansion through planned development in the Local Plan Update are limited by significant constraints, as follows:

Develop to the North
1. The Cotswold Water Park lies to the north of current development limits at Perrinsfield. This is also an area of ecological significance based on restored lakes. Development to the north of Lechlade would constitute ribbon development and is not desirable.

Develop to the East
1. Appendix 7 of the Lechlade Neighbourhood Plan (2016) provides Town Character Assessments of different parts of Lechlade and its surroundings. Land parcels previously put forward in a call for sites are located to the east of the A361 behind houses in agricultural fields with views through development to the countryside beyond. These overlap character areas 3, 5 and 6 and the assessment for these areas (particularly area 5) places significant value on the close-in nature of the countryside as a strong reminder of the village character of Lechlade. The development of land in this location would remove this and create a harmful impact on the character of the area as assessed within the Neighbourhood Plan.
2. A core objective of the Neighbourhood Plan is to meet future housing needs whilst maintaining the town’s character. 1.3.2 of the Neighbourhood Plan speaks to the character of the town under this objective….’a countryside setting where greenery in the form of open frontages, trees and hedgerows merge with the buildings to create a sense of openness right into the heart of the town. This sense of greenery and openness is as fundamental a part of the Lechlade character as the natural materials used in the buildings and the town’s countryside setting.’
3. In the section 2.1 policies, under the ‘Design and Character of New Development’, this is expanded upon in supporting text to Objective 5 ‘The setting of the Town within the surrounding countryside and how the countryside extends into the town is a key feature which needs to be protected and enhanced.’ It goes on to say that ‘Because the town occupies a prominent location on the River Thames, there are many opportunities within the town to glimpse the surrounding countryside. This also helps to define its special character.’
4. Policy D1 Design Principles says that applications for new development will only be permitted where these:

a) Respect views into and out of the Town.
b) Would not adversely affect the character of the town.
c) Conform to the Cotswold Design Code or its successor document.
d) Conform to the character of the local area as set out at Appendix 7.
1. The Neighbourhood Plan and the town council does not support development to the east of the A361 as it would impacts on views out of the town from between development on the east side of the A361 and would affect the character of the town and the local area as defined in the Appendix 7 Character Assessment and in section 1.3.2 and section 2.1 of the Neighbourhood Plan. This area is one of the last remaining areas of countryside that extend into the heart of the town and its development would significantly undermine a key foundation of the Lechlade Neighbourhood Plan.

Develop to the South
1. Land to the south of the current settlement of Lechlade is limited by the River Thames and areas of significant flood risk zones. In accordance with the proposed approach set out in the Vision, Objectives and Development Strategy Options Topic Paper, development should be steered away from such locations.

Develop to the West
1. Undelivered Local Plan allocations lie to the north and east of the Wern Roundabout to the west of Lechlade. This location has the been the focus of considerable speculative development interest in recent years, resulting in several planning applications. The proposals brought forward have revealed the scale of potential impacts the wrong type of development could bring to the area west of Lechlade. The edge of Lechlade is exposed to open countryside, significant ecological resources and scheduled monuments. Extending the urban edge of Lechlade northwards and westwards into this area has been proven to be too impactful. Space needs to be left to protect the setting of the Scheduled Monument and in effect should respect current development boundary limits.
2. Lechlade Neighbourhood Plan policy D1 is clear in attaching significant value to the open views to the countryside from the west of the town and in the importance of open areas on the approach to the town from the west (defined in Character Area 4 in the Appendix 7 Local Character Assessment), both of which would be impacted by development in open countryside to the west of Lechlade.
3. Land outside the west of Lechlade also forms the site of or the setting for the Scheduled Monument located in this area. The land here is also susceptible to change through development due to its position within open countryside beyond the existing settlement edge. Development here would encroach into a characteristically rural landscape around the Lechlade settlement and would likely form a prominent addition to views. Development beyond the existing settlement will have an urbanising effect on the rural landscape.
4. Previous SHELAA consideration of land parcels promoted to the west of Lechlade considered these sites to be variously constrained by flood risk, ecological constraints, heritage constraints or landscape constraints.

Conclusions
It is welcomed that future development strategy for the Cotswold District will consider the current and future role of Principal Settlements based on realistic assessment of their performance and potential to grow and develop. Lechlade Town Council contends that Lechlade was never a location that could sustain significant amounts of development, but it is an important place. It does clearly exhibit strong local services and now a (apparent) stronger retail performance than it used to, but it remains porous in employment terms with significant out-commuting – despite allocations, employment development has not occurred. The Good public transport position of the town (based on a couple of bus services) was not entirely real-world and this is borne out by journey to work information in the Census, showing overwhelming reliance on private motor transport. Greater homeworking and home delivery services are two positive trends worthy of note which reduce impacts from car use.
The Adopted Local Plan Strategy sought to limit housing growth in order to ensure that local services (which are provided at a small scale) could continue to cope. Based on the employment position and the local services position, nothing has changed to alter that. In relation to potential future areas for expansion beyond sites already allocated, then there are significant environmental constraints on further expansion of the town in any direction.
Lechlade is an important location which can cater for the needs of a limited population and so whilst it meets certain criteria for Principal Settlement designation on the previous approach, it is clear to the people of Lechlade that the town was only ever a Principal Settlement IN NAME ONLY.
The town does not have the capacity to expand beyond its boundaries due to environmental constraints. The level of services and facilities exist a scale that (just about) meets the needs of the current population - already, growth has occurred which places these under severe strain.
Through the Local Plan Update, the status of Lechlade as a Principal Settlement should be reviewed critically based on its poor potential for further development and the damaging effects that poor employment density and self-containment would have in leading to out-commuting by car.
Also, the principal should be reinforced that Lechlade town development boundaries should not be changed further whilst required community, employment and transport infrastructure remains undelivered.

CC7 point 3 A BNG spatial operating strategy combined or overlaid with a spatial development strategy within the District would at least enable residents to understand how their environment is being planned and managed in support of nature recovery, wellbeing and climate emergency.

In order to ensure BNG is retained a hierarchy needs to be established as follows by amending point SD1c: Settlement (priority 1), District (priority 2), County (priority 3) in support of SD1 point 6.


Noting the intention to update Appendix H Strategic Principles for Green Infrastructure in Gloucestershire to be included or updated in next Local Plan consultation, A BNG spatial operating strategy combined or overlaid with a spatial development strategy within the District would at least enable residents to understand how their environment is being planned and managed in support of nature recovery, wellbeing and climate emergency.

5.1.2 MTC supports points under the 4th bullet and notes the intention to update Appendix H Strategic Principles for Green Infrastructure in Gloucestershire to be included or updated in next Local Plan consultation, however the final point under the 4th bullet is unclear.

CDC has signed up to the Gloucestershire Nature and Climate Fund (GNCF) linked to biodiversity net gain (BNG) principles and spatial operating strategy.

Policy (EN7, EN8, EN9) needs to be clearer about developer contributions to BNG and links to the CDC Green Infrastructure Strategy December 2023 and GNCF in order to ensure BNG is retained in a hierarchy needs to be established as follows by amending point SD1c: Settlement (priority 1), District (priority 2), County (priority 3) in support of SD1point 6.

Policy point 1
Where such infrastructure is required, it must be in place prior to the occupation of the development, or, if it is demonstrated that delivery within that timetable is not possible, within a timeframe that has first been agreed by the LPA. (vi) Proposals will be subject to conditions to ensure that the first and/or subsequent occupancy is aligned with the delivery of the necessary infrastructure upgrades; (vii)

MTC notes the policy wording, however reference vii from Thames Water includes: ‘…which result in the need for off-site upgrades…’ Should this wording be included in the policy?

vii Thames Water Representation example policy clause – used in part (I&O Reg 18 consultation, 2021) We recommend the Local Plan include the following policy: “Where appropriate, planning permission for developments which result in the need for off-site upgrades, will be subject to conditions to ensure the occupation is aligned with the delivery of necessary infrastructure upgrades.”; NPPF 2023, para 11; SFRA L1 draft also recommends the phasing of development.

MTC support policy CC5 and notes point 5b.5.1 citing the NPPF:

“Inappropriate development in areas at risk of flooding should be avoided by directing development away from areas at highest risk, … Where development is necessary in such areas, the development should be made safe for its lifetime without increasing flood risk elsewhere”.

1. Too much traffic in Broadway Lane and the Leaze.

2. No public transport runs in Broadway Lane and nearest bus stop too far to walk to for the elderly or infirm.

3. Condition of roads very poor.

4. Amount of traffic in the Leaze since new estates built. Further building planned. Road needs to be opened again to achieve two entrances.

5. Look at car parking in High Street on shopping areas.

6. I have been informed that building will continue for another 3 years. The Leaze can not cope.

In order to ensure BNG is retained a hierarchy needs to be established as follows by amending point SD1c: Settlement (priority 1), District (priority 2), County (priority 3) in support of SD2 point 6.

1. Is it easy to travel where you need to:
1x Cheltenham + retun bus 608 + 2x Hedgehog buses.

2. Do you feel like part of the community:
I did until the locals vanished, the village regularly feels empty. No community at the moment 2024.

3. Do you have access to green spaces:
Not as issue in Ashton Manga the contryside is lovely.

4. What would you change:
Where the popultation recovers: better use of the bus shelter x2 per information + book susps etc. The Blockley news + free monthly - very useful. Some structure to bring the community together again.

The concerns of the Towns residents and those living in the surrounding area have been significant, resulting in the need for an additional meeting hosted by yourselves at the Fire Service College (FSC - a site to be considered in the Local Plan Update) and a Parish Meeting hosted by the Town Council. Proposals for development at the FSC in the Updated Local Plan to 2031 and the suggested development strategy for Moreton in Marsh have resulted in disquiet in the Town.
Moreton in Marsh Town Council believes that the opportunity to engage at an earlier stage might have aided CDC in commencing the Regulation 18 Consultation process to meet the suggestion outlined in the National Planning Policy Framework (NPPF) Chapter 3 paragraph 16c:
• Plans Should:
be shaped by early, proportionate and effective engagement between plan makers and communities, local organisations, businesses, infrastructure providers and operators and statutory consultees.
The consultation itself has proved difficult for residents to voice their concerns. The 394 page document containing Local Plan Consultation Draft Policies Tracked Changes, requiring it to be read in conjunction with the Local Plan Development Strategy Options and Preferred Strategy Option Topic Paper and the Executive Summary Consultation Instructions and Questions document seems to fall short of the expectations set out in CDCs Statement of Community Involvement: Extract page 6 CDC Statement of Community Involvement January 2024: Consultation publications will be clear and concise and will not include avoidable jargon, without understanding the complexities of any decision.
As a supporting document, the Integrated Impact Assessment (IIA) Cotswold LPU Interim IIA report 2024, at the current stage of plan making, suggests delivering growth in sustainable locations as a key tenet. In terms of Moreton in Marsh, it is incredible to believe the impact of significantly increasing population density will have no impact in terms of access to healthcare and employment even though reference is made to healthy places and specialist housing…Given the reference to improved flood management measures yet omitting the River Evenlode, subsequently mentioned in an updated version of the report made during the formal consultation period, further undermines the credibility of the Initial Impact Assessment and its scored, underpinning Appraisal Findings.
Expecting residents to answer questions such as question 15 relating directly to Moreton in Marsh without providing sufficient information such as a map or sight of the 2022 Strategic Housing Economic Land Availability Assessment (SHELAA) is only one example of a shortfall in this consultation. Indeed, as a number of issues specifically related to proposals for Moreton in Marsh have emerged in response to this consultation, the Council request that CDC engage in a further, specific consultation exercise, prior to Regulation 19 commencement.
If CDC intend to implement the Development Strategy to run from 2026 to 2041, the Town Council proposes that the current proposed development at the FSC is postponed pending inclusion into a resourced, fully developed Masterplan specifically determined for Moreton in Marsh prior to 2026.
Please regard this letter as part of the consultation process and acknowledge its acceptance and respond accordingly.
In respect of the Council’s submission and thoughts on the policies and Local Plan Update, we look forward to seeing updated versions as a result of the consultation exercise, prior to Regulation 19.

6.12 Impact Assessment
Matthew Britton continues that assessment of crime ant safety would be carried out by the country and especially rural a communities in the police is at all time low (theft of rural farm machinery up to 300%) my view of this process in not one of faith and trust that fast a box ticking exercise.
I attended the Redesdale Hall drop-in, and the Fire Services College meeting in an attempt to learn more of the CDC's plans for Moreton, and have been struck by the level of inconsistency with the data provided by the . This has made the process extremely confusing, at a time when the CDC needs to provide us with clear and concise information. The main discrepancies include:
1) From a video posted by the CDC covering a recent meeting, it highlights a rather upset Cllr Harris discussing his annoyance at certain individuals who had indicating that Moreton may be assigned 10,000 dwellings as part of the plans for the town. It is my opinion that this comes directly from the rhetoric used by CDC indicating that Moreton could become a Garden Village. It was interesting to note that Mr Weaver (CEO CDC) stated that a Garden Village is 'technically smaller strategic developments up to around about 3 to 4,000 homes'. This does not relate to the UK Government website on this subject which states 'Garden Villages as being between 1,500 and 10,000 homes in size'. Garden Towns have a number of dwellings exceeding 10,000 homes. What may not be know, and what hasn't been described to those who attended the Fie College meeting, is that the 2016 Locally-Led Garden Village, Towns and Cities prospectus suggests that 'local authorities should decide themselves how to define what a Garden Village is'.
2) During the Redesdale Hall drop in Matthew Britton and James Brain both discussed the Government's standard methodology for calculating the number of houses for the District during this extended planning period to be around 7,400 dwellings. This is backed up by the leaflet I took away from the drop-in. During the meeting at the Fire College the number of 7,400 was never discussed, only a figure of 3,300, of which 1,500 would relate to Moreton. Are we being fed on a diet of contradictions?
3) Around 5,150 dwelling's worth of land supply for the extended planning period has already been identified however, this still requires land for a further 2,250 to bring us up to the 7,400 figure. If land for the vast majority of dwellings has already been identified, and that includes the segments of land listed in the 2026-2042 Plan for the development in Moreton, why would time be spent looking for additional land, or a plan for 'Village Clusters' to be considered. Politically, I feel that this is already a 'done deal', a factor that CDC have vociferously denied. It appears we have walked into a smoke¬ screen of misnomers and differences in data that has brought me to the decision that we are not being told the full story.

2.2 Development Strategy

The need for village clusters and the planning village clusters has not be appropriately effectively and fully investigating the planning team as in my view potential decisions by the council have already agreed to Moreton to be come a garden village.

Investigate other sections on the district for construction of the required number of homes, with the - the AONB and request the acquired building land in Mickleton, Willersey and south carney.

Lechlade

Carpark: I am strongly opposed to any car park at LEC 3 which will not be used. It will despair the previous views the town and church as a[[reached from the east and must be cherished. (It is also very wet) I am not convinced that Lechlade has a parking problem. 1 before the 2 hour limited ford trades parking at memorial hall 2 parking in riverside - park for general areas 3 - riverside park over the bridge 4 formalise the mudding parking which are '-' on the Farringdon road.

CDC Local Plan for Moreton-in-Marsh

S18
7.21.6 7.21.7 18.3 ha site
Affordable housing is needed by huge houses are built infrastructure and overdevelopment

Huge houses no local person can afford - school planned on contaminated land on fire college land.

Pollution on Fire College Site - Infrastructure, Over-development, Huge houses in Moreton.

CDC mentions affordable housing in their plans for building 310 houses on fire college land - they mention the housing crisis in the Cotswolds in the CDC newsletter March 2024 - but - WHAT GETS BUILT? Enormous houses no local person can afford even the smaller ones on Evenlode road are £400,000 plus - impossible for a local person to buy. The huge houses that are built will be rented out as Air BNB or second homes that only people from London can afford to buy making lots of money for developers who gobble up greenfield provide no infrastructure - then take the money and walk away. The Fire Service College land is polluted - a school should not be built there - and sat David's primary school has not reached full capacity.

CDC should find out how many houses are second homes or let out as Airbnb's instead of building enormous houses local people cant afford developers should be made to provide more infrastructure and the proportion of affordable houses should be greater than huge unaffordable ones!

S18
5.5.1
7.21.8
Wastewater - overloading existing water infrastructure by over development

More building more houses more concrete more hard services on what is a flood plain - sewage and drainage already cant cope houses will get flooded!

Flooding - Drainage - Water supply - Moreton.

Moreton-in-Marsh is prone to flooding (the clue is in the name MARSH!) CDC is allowing new houses to be build on a flood plain (spitfire development on stow road) etc. The Moreton waste water system is already overloaded with regular release of sewage and contaminants into the Evenlode river and other waterways locally. They are all dead with no wildlife in them at all. Global warming with increasing flooding and thousands of new houses will put massive pressure on an already overloaded sewage system. Existing houses and new ones will get flooded with dirty sewage and water. Building new houses is IRRESPONSIBLE!

Stop the over development of Moreton-in-Marsh it is on a flood plain and residents don't want lots of new houses!

S18
CDC allowing Developers to build on Greenfield Sites - Good Agricultural Land.

SAFE GUARDING OF VALUABLE FARMLAND IN Moreton IN MARSH

Greenfield Sites - Valuable resources. Moreton-in-Marsh.

I object to CDC's plan to build hundreds more houses on productive farmland. Fields should be used for growing food, crops and for agriculture not concreated over. It is madness to allow fields to be built over. This is not an environmentally sustainable policy. CDC should be doing their bit to ensure the OK is self-sufficient in producing food not concreating over fields because developers want to make lots of money building huge houses unaffordable for the local population. It is government policy that Greenfields should be avoided when planning applications are made - who is the CDC allowing it?!

HIGHWAY SAFETY ISSUES IN Moreton
S18
7.21.5
7.21.12

Severe traffic congestion issues already more development will make it much worse. Air pollution.

Highway safety issues. Moreton-in-Marsh. Moreton houses = More cars!

Moreton already has a massive problem with traffic congestion! Traffic density is very bad with long queues of cars entering Moreton on the Fosseway (A429) and passing along the high street and stow road. Traffic density is causing air pollution - this will get worse with hundreds/thousands more houses. The roads in Moreton cannot cope with more traffic generated by hundreds of new houses being build and subsequent increase in cars.

Over-development, design, positioning, landscaping
7.21.5
7.21.7 + Executive Summary P2 Para 19

THOUSANDS MORE HOUSES AND OVER DEVELOPMENT WILL TURN Moreton FROM A PRETTY COTSWOLD MARKET INTO A SPRAWLING FACELESS SUBURBIA!

Over-development, Design, Landscaping - (Moreton) Tourism affected.

Moreton is still and attractive market town that tourists want to visit in spite of CDC's best efforts to win it by allowing more and more development. Tourism is extremely important in Moreton and other Cotswold towns and villages. Over-development and CDC plans to build thousands more houses around Moreton and extra roads will carve the heart out of this pretty rural town. The uncontrolled building policies of CDC is rapidly turning a modest sized attractive market town into an ugly sprawling suburbia that no tourist will want to come and visit! Beware of spoiling a favourite tourist destination.

Do not spoil a pretty market town. You will turn it into a dead suburbia and spoilt it forever.

Highway safety issues in Moreton
S18
7.21.5
7.21.12
Cycling and walking in and around Moreton is already dangerous.

More houses and development in Moreton will lead to accidents and put people off cycling and walking into Moreton and around the area.

Road safety issues - with more houses and more cars.

It is dangerous cycling into and around Moreton because of the density of traffic and cars being driven too fast by impatient drivers. Cars often cut in - in front of cyclists to get in front before the road narrows. There are already too many cars on the high street making cycling dangerous. More houses leads to more cars and more danger for cyclists and pedestrians in Evenlode Road where often walk or cycle cars sped by often very clos and going much too fast. Evenlode road will become more dangerous when all backhouse houses are occupied!

Moreton should have lots of cycle lanes - there are none!

Moreton - Nature conservation.
Nature depletion because of thousands more houses and loss of habitat.
S18
7.21.9
7.21.7

A huge amount of houses being built and trees, hedgerows being grubbed up for houses/roads - No thought in plan for habitat loss biodiversity loss!

Nature conservation - Loss of habitats and biodiversity.

There is hardly any mention of conservation on the CDC plan which will have a devastating impact on nature, habitat loss will result from CDC's plans to build over 1500 houses driving the next 17 years including 310 on the Fire Service capita land alone. Where will wildlife go when fields are built on, trees and filled and hedgerows grubbed up to built more houses and roads? What little wildlife we have left will be further depleted. Birds, insects and all animals including hedgehogs are all declining at an alarming rate - as Moreton morphs from a pretty market town of modest size into a sprawling ugly urban jungle. Where will wildlife be able to go?

Moreton should have many more green spaces and its own nature reserve not more and more houses and concrete!

Re: Comments/objections to CDC's plans to over develop Moreton-in-Marsh

I enclose filled in forms about the main issues relating to CDC's plan for Moreton

I must say that the whole process online was made very difficult for Moreton to make objections and comments especially if they do not have access to the internet or e-mail. The forms are badly designed in my opinion. I think it is unreasonable to expect people to go through pages and pages to find exact pages to address their concerns about the plan.

I hope my comments/objections will be properly and taken notice of .

Flooding and pollution.

As an angler, dumping sewage into the Evenlode stream, will make all the fish and wildlife lifeless.
Tell me why the rainwater and sewage are mixed together

If our population has increased by 43% in 13 years why cant we have new houses in Kemble. It has less than 1000 population and a train station

Enough is enough, we have had more than our quota here in Moreton-in-Marsh you have ruined this Cotswold town by your neglect and not listening to the local people and people of Moreton, who do not have the infrastructure for what you want.

I am very elderly do not have a computer so this form was very different for me to answer it properly so I am using it to tell you how I feel and sincerely hope you will listen to the people Moreton who are working hard to try and explain that these future plans are not right.

Policy EN18 Sherborne Park Estate Masterplan - The whole Policy

EN18: a new policy in tandem with the National Trust's plans for the Estate. Concerns about traffic, parking, and privacy see attached sheet.

EN 18 SHERBORNE PARK ESTATE MASTERPLAN

- LPW Q49. There is not enough detail in the policy to be able to gauge its effect on the village, other parts of the Estate & surrounding roads. So I can only support so far the landscape protection and natural habitat recovery plans, and continued farming within the estate.
The Conservation Management Plan is not yet available to see.

- Comments concerns about effects on village residents of increased traffic, parking on village street & possible loss of privacy.

- All six arms in the village (bar one from the A40) are unsuitable for increased traffic - being single track for all or part of the way from the nearest main road (A40/bypass)
The village street has 2 blind corners & for some of its length is single track due to local parked cars, working vans etc.
Village traffic includes that for the Primary school, The shop, farmers & estate staff, and cyclists following the National & North Leach Northward Cycle route. In the event of an accident on the local A40 traffic is redirected through the village. Horse riders also come through.
For most of its length the verges on south sides of the street are very narrow; & pavement along the north side and walls of varying heights along both sides all the way.
Any traffic entering the west end of the village from the only two way road would reach the Northfield/ water meadow car park to the north east by going through the village.
Already some visitors choose to park on the village street rather than in the 2 car parks and this can cause problems for safety and residents.
Access to walks from the village street results at time on street parking at those points - there are 2 (to south) one of which is by the school shop; only further access by works or the park from the street would increase this problem.
Further public access to areas in the village could mean some residents being overlooked on all sides, resulting is loss of privacy. Too great an increase in number can change the level of visitor's expectation - who might feel free to roam at will including into private areas (such as gardens)
It is not clear whether a Country Park at Sherborne is envisaged by CDC or if so what that would involve or mean for management priorities, funding, how promoted and the effect on local area / communities.
Obviously there is, besides all the above, concern about the effect on the natural flora & fauna of many visitors (and dogs) especially if some are not aware of how damage can be done. As much as anyone, the Trust knows this & so would manage access accordingly.
= Built in to any Policy or Masterplan should be a requirement to prevent the increase of visitor traffic and parking throughout the Estate, and to protect privacy of residents, along with the flexibility to alter access plans if damage was being done

Response to Cotswold District Local Plan via the template of the
LGA response to the Government's 2023 NPPF Consultation.

Policy EN16. Dark Skies
The supporting paragraphs 10.16.13 to 10.16.23 include many important requirements. As we understand it as they are notes they have only the force of guidance. We suggest they are sufficiently important for the implementation of the policy that they are referenced in the policy by adding “ 2.c. Details of requirements to implement this hierarchy are given in the paragraphs following this policy “.

Policy EC12. Equestrian Related Development.
This was previously a gap in the plan which needed addressing. However the provision allowing a dwelling for a staff member needs tightening. As drafted the provision to allow a dwelling for one staff close to the stables is very flexible (it for instance includes family) and “close” is subjective. This could lead to substantial isolated houses being built in the open countryside contrary to policy DS4.

Policy DS3. Small Scale Residential Development in Non-Principal Settlements.
We support the substantial modifications to the policy to be more specific in some respects. In particular that small scale development is defined as not more than 5%. However it should be clear that this covers both a single development and the total cumulative development over the plan period. Otherwise multiple applications for 5% would be possible.

The policy also requires that development is no further by foot/public transport than defined times from a list of facilities. We are concerned that this list is so all-encompassing that it will be easy for proposals to meet at least 6 of them and result in many of the smaller villages becoming targets for development. We suggest the list be truly that of essential services namely; employment, primary and secondary schools, banking and/or post office, a GP surgery/pharmacy, and food shops and that all are required to be within a reasonable distance in terms of time by foot, bicycle or regular (say 3 times a week) public transport.

Policy DS1. This sets out the housing numbers. The total need for 2011 to 2031 is raised from 8400 to 9094. This is mostly because the number now includes nursing and residential care home bed space and student accommodation (C2 use category). The two categories (C2 and C3) need to be kept separate in terms of site allocation and planning application approval as the C2 category uses far less space per head than a normal housing provision and has rather different locational requirements and arises from a quite different type of need. A fall off in C2 demand should not allow an increase in C3 housing supply.

The table giving housing demand and land supply show that a total of circa 9700 dwellings will have been delivered by 2031. Substantially exceeding the target. The table however is confusing as it appears to add up to 10700. The explanation may be double counting of the Chesterton site. The implications of this over supply are that there should be restraint on approving further windfall sites and delay of development on approved sites to later years.

This requires adequate waste water treatment capacity to be in place before the first unit is occupied. We would support this approach. It also covers management of water consumption to a target rate per person and demonstration that development will not pollute existing water sources. More details need to be given as to how both will be monitored; without this the policy is simply an aspiration.

We support the amendment to this policy to cover flooding from sewer overflows and surface water flooding. Pollution of local rivers is a continuing concern and reinforces the need for the Council to rigorously enforce the provision that occupancy of new development cannot take place until and unless the required infrastructure is in place.

Similarly to SD1 this is long list of worthy objectives. However the introduction is unclear whether applications which do not deliver the principles will be rejected and whether all criteria should or could apply to all developments. It would be clearer if the introductory paragraph read “Developments will only be approved which, where appropriate, deliver:”. We support the list of requirements.

It is unclear how many of the sustainable criteria a new development has to deliver. They are introduced as aspirations rather than requirements. It is clear that not all can be delivered as some will have no relevance to a particular development or if they did then it is likely that development cost would be substantially increased and it will be a major burden on minor development.

Firstly, MMH continues to support the purpose of Policy DS3 which has proven successful over the years in allowing small-scale, incremental and sustainable growth to be achieved at Non-Principal Settlements.
2.48 However, the amendments proposed to this policy are recognised as comprising a more stringent criterion. These can be summarised as follows: Criteria b) attaches an exact size limit to development under this policy, proposing sites to be no larger than one hectare and to not exceed 5% of the size of the existing settlement.
Criteria c) adds that the proposed development should complement the existing pattern of development and should not negatively affect the contribution that open spaces and breaks in development, such as gardens, green wedges and green corridors, make to the built environment.




一. Criteria e) is new, requiring that development “has a journey time by foot and/or public transport from the centre of the site to six of the following core or primary services that is no longer than the following: 40 minutes to employment area(s) offering 500+ jobs;
一. 30 minutes to a secondary school;
一. 20 minutes to any of the following:” The policy then lists a number of services.
一.
一.
一. 2.49 The reasons for these changes are then set out on pages 91 and 92. MMH wishes to respond to amendments to criterion b) and criterion e).
一. 2.50 We have no objection to including the ‘%’ requirement in criterion b) as it is recognised that this will allow for proportionate growth commensurate to the size of the settlement.
一. 2.51 However, it is contended that the addition of restricting the development of sites to 1 ha is overly restrictive. The size of development should be based on the size of the settlement itself and the services and not the facilities that lie within it but close by, notwithstanding any sustainable transport connections and environmental designations.
一. 2.52 Moreover, given the requirement to now deliver 10% biodiversity net gain on both major and minor developments and the opportunity to deliver landscape enhancements may be restricted if an upper limit on the size of the site is adopted. Finally, this restriction could further restrict the ability for residential developments to give back to the community, such as deliver public open space, play spaces and allotments. We therefore respectfully request this amendment be removed.
一. 2.53 With regards to Criterion e) – this looks to introduce time-limited restrictions by foot and/or public transport. It’s not yet understood what evidence has been utilised to support the prescribed journey times. It is not clear why a 20-minute journey time to 6 has been decided upon; yet the access to employment areas is 40-minutes. It’s unclear why the two prescribed benchmarks have been selected and why one is considered less sustainable than the other. We would welcome further evidence on this proposed policy.
2.54 In addition to the above, we wish to object to the addition of paragraph 6.3.5 which states: “In non-Principal Settlements” means that developments should be located inside the developed part of the settlement. This excludes agricultural fields on the edge of




. the residential settlement edge.
.
. 2.55 This has only been included ‘for clarity’. This restriction does not enable the sustainable and proportionate growth of settlement limits in principle which, in some cases, may be acceptable. Instead, this judgement should be made on a case-by-case basis by officers for when each application is submitted.
. 2.56 Otherwise, the addition of this paragraph could restrict what would otherwise be sustainable and proportionate growth of a Non-Principal settlement that can help retain and enhance their role as sustainable locations for small-scale residential development.

Firstly, TGE continues to support the purpose of Policy DS3 which has proven successful over the years in allowing small-scale, incremental and sustainable growth to be achieved at Non-Principal Settlements.
2.3
However, the amendments proposed to this policy are recognised as comprising a more stringent criteria. These can be summarised as follows:
-
Criteria b) attaches an exact size limit to development under this policy, proposing sites to be no larger than one hectare and to not exceed 5% of the size of the existing settlement.
-
Criteria c) adds that the proposed development should complement the existing pattern of development and should not negatively affect the contribution that open spaces and breaks in development, such as gardens, green wedges and green corridors, make to the built environment.
-
Criteria e) is new, requiring that development “has a journey time by foot and/or public transport from the centre of the site to six of the following core or primary services that is no longer than the following:
1.
40 minutes to employment area(s) offering 500+ jobs;
2.
30 minutes to a secondary school;
3.
20 minutes to any of the following:” The policy then lists a number of services.
2.4
The reasons for these changes are then set out on pages 91 and 92. TGE wishes to respond to amendments to criterion b) and criterion e).
2.5
We have no objection to including the ‘%’ requirement in criterion b) as it is recognised that this will allow for proportionate growth commensurate to the size of the settlement. However, it is contended that the addition of restricting the development of sites to 1 ha is overly restrictive. The size of development should be based on the size of the settlement itself and the services and
facilities that lie within it but close by, notwithstanding any sustainable transport connections and
environmental designations.
2.6
Moreover, given the requirement to now deliver 10% biodiversity net gain on both major and minor developments and the opportunity to deliver landscape enhancements may be restricted if an upper limit on the size of the site is adopted. Finally, this restriction could further restrict the ability for residential developments to give back to the community, such as delivering public open space, play spaces, allotments, or improvements to Temple Guiting’s Village Hall. We therefore respectfully request this amendment be removed.
2.7
With regards to Criterion e) – this looks to introduce time-limited restrictions by foot and/or public transport. It’s not yet understood what evidence has been utilised to support the prescribed journey times. It is not clear why a 20-minute journey time to 6 facilities/services has been decided upon; especially when access to employment areas is defined as 40 minutes. It’s unclear why the two prescribed benchmarks have been selected and why one is considered less sustainable than the other. TGE would welcome further evidence on this proposed policy.
2.8
In addition to the above, we wish to object to the addition of paragraph 6.3.5 which states:
-
“In non-Principal Settlements” means that developments should be located inside the developed part of the settlement. This excludes agricultural fields on the edge of settlements, farmyards (whether active or not) or any buildings or land separated from the residential settlement edge”.
2.9
This has only been included ‘for clarity’. This restriction does not enable the sustainable and proportionate growth of settlement limits in principle which, in some cases, may be acceptable. Instead, this judgement should be made on a case-by-case basis by officers for when each application is submitted.
2.10
Otherwise, the addition of this paragraph could restrict what would otherwise be sustainable and proportionate growth of a Non-Principal settlement that can help retain and enhance their role as sustainable locations for small-scale residential development.

Response to amendments to Policy DS3

Firstly, the Estate continues to support the purpose of Policy DS3 which has proven successful over the years in allowing small-scale, incremental and sustainable growth to be achieved at Non-Principal Settlements.

However, the amendments proposed to this policy are recognised as comprising a more stringent criterion. These can be summarised as follows:

The policy then lists a number of services. Statement of reasons for these changes are then set out on pages 91 and 92. The Estate only wishes to respond to amendments to criteria b).
We have no objection to including the ‘%’ requirement in criteria b) as it is recognised that this will allow for proportionate growth commensurate to the size of the settlement. In light of this, it is contended that the addition of restricting the development of sites to 1 ha is overly restrictive. The size of development should be based on the size of the settlement itself and the services and facilities that lie within it but close by, notwithstanding any sustainable transport connections and environmental designations. Moreover, given the requirement to now deliver 10% biodiversity net gain on both major and minor developments and the opportunity to deliver landscape enhancements may be restricted if an upper limit on the size of the site is adopted. Finally, this restriction could further restrict the ability for residential developments to give back to the community, such as deliver


Criteria b) attaches an exact size limit to development under this policy, proposing sites to be no larger than one hectare and to not exceed 5% of the size of the existing settlement.
Criteria c) adds that the proposed development should complement the existing pattern of development and should not negatively affect the contribution that open spaces and breaks in development, such as gardens, green wedges and green corridors, make to the built environment.
Criteria e) is new, requiring that development “has a journey time by foot and/or public transport from the centre of the site to six of the following core or primary services that is no longer than the following:
40 minutes to employment area(s) offering 500+ jobs;
30 minutes to a secondary school;
20 minutes to any of the following:…”


public open space, play spaces and allotments. We therefore respectively request this amendment is removed.
In addition to the above, we wish to object to the addition of paragraph 6.3.5 which has only be included ‘for clarity’. This restriction does not enable the sustainable and proportionate growth of settlement limits in principle which, in some cases, may be acceptable. Instead, this judgement should be made on a case by case basis by officers for when each application is submitted. Otherwise, the addition of this paragraph could restrict what would otherwise be sustainable and proportionate growth of a Non-Principal settlement that can help retain and enhance their role as sustainable locations for small-scale residential development.

I am not a resident of Moreton-in-Marsh, but am local to the area, and wish to stand with the good people of the town to oppose the plans to turn Moreton-in-Marsh into a Garden Village. I have raised my family in the Cotswolds since leaving the British Military some thirty years ago, and I can appreciate the need for additional housing, as both my daughters are not in a financial position to buy their own homes locally, especially with the ludicrous prices of property in this part of the country, but not at the expense of Moreton-in-Marsh.

I attended the Redesdale Hall drop-in, and the Fire Services College meeting in an attempt to learn more of the CDC's plans for Moreton, and have been struck by the level of inconsistency with the data provided by the . This has made the process extremely confusing, at a time when the CDC needs to provide us with clear and concise information. The main discrepancies include:
1) From a video posted by the CDC covering a recent meeting, it highlights a rather upset Cllr Harris discussing his annoyance at certain individuals who had indicating that Moreton may be assigned 10,000 dwellings as part of the plans for the town. It is my opinion that this comes directly from the rhetoric used by CDC indicating that Moreton could become a Garden Village. It was interesting to note that Mr Weaver (CEO CDC) stated that a Garden Village is 'technically smaller strategic developments up to around about 3 to 4,000 homes'. This does not relate to the UK Government website on this subject which states 'Garden Villages as being between 1,500 and 10,000 homes in size'. Garden Towns have a number of dwellings exceeding 10,000 homes. What may not be know, and what hasn't been described to those who attended the Fie College meeting, is that the 2016 Locally-Led Garden Village, Towns and Cities prospectus suggests that 'local authorities should decide themselves how to define what a Garden Village is'.
2) During the Redesdale Hall drop in Matthew Britton and James Brain both discussed the Government's standard methodology for calculating the number of houses for the District during this extended planning period to be around 7,400 dwellings. This is backed up by the leaflet I took away from the drop-in. During the meeting at the Fire College the number of 7,400 was never discussed, only a figure of 3,300, of which 1,500 would relate to Moreton. Are we being fed on a diet of contradictions?
3) Around 5,150 dwelling's worth of land supply for the extended planning period has already been identified however, this still requires land for a further 2,250 to bring us up to the 7,400 figure. If land for the vast majority of dwellings has already been identified, and that includes the segments of land listed in the 2026-2042 Plan for the development in Moreton, why would time be spent looking for additional land, or a plan for 'Village Clusters' to be considered. Politically, I feel that this is already a 'done deal', a factor that CDC have vociferously denied. It appears we have walked into a smoke¬ screen of misnomers and differences in data that has brought me to the decision that we are not being told the full story.

Prior to joining the Military, I served as a Colonial Police Officer in Hong Kong. Today I work in a sector providing advice on crime within a specific arena. Recent data suggests that crime clear-up rates of the UK for each Force was between 5% to 18%, which cannot be viewed as healthy. In the US, 52.3% of homicides, 36.7% of violent crime, and 23.2% of robberies are successfully investigated. If the CDC propose to increase the number of residents in Moreton by 100% +, crime will inevitably increase. Moreton's Police Station was recently converted for housing, and the Stow-on-the-Wold Police Station is closed, and only used as a watering hole for Officers. Our nearest Police Station is almost twenty miles away in Cirencester. Moreton and Stow need a permanent Police Station, especially as statistics indicate that rural crime and the theft of farm machinery has increased by 300%.
The infrastructure of Moreton is failing, but building continues. The Cotswolds has become a cash¬ cow for the construction industry, and they are not playing the game to provide our communities with the requisite infrastructure. Cllr Harris and others have complained that the reason for the sufferings of Moreton has been due to the fact the 'Council has not had an up-to-date Local Plan for decades'. This came as a bit of a shock as, during the Fire College meeting, Matthew Britton talked about being in 'a strong position' with the adopted Local Plan 2011-2031, which he held up for us all to see. Is this just another case of inaccurate information.
I'm a countryman at heart. I was brought up by a farm manager mum and Land Girl during WW2, and soldier dad, to respect the countryside. I used to ride my horse around Moreton, Evenlode and Chastleton, but now keep my dear old boy on the Stanway Estate. The proposed Local Plan will decimate wildlife if significant changes are not made, and the number of house planned for construction considerably reduced. On driving to the Redesdale Hall drop-in I passed one dead deer and several pheasants on the Fosse, so I can only imagine what horrors there will be on our roads with the additional building. I have watched the barn owls fly along the hedgerows between Broadwell and Moreton in the late evenings, which, one of these days may well be ripped up to make way for new houses, or a new road. What measures have and will be taken to protect wildlife? Where are the
conservation warriors when you need them?

My thoughts raised in this email, I'm sure, are just the tip of the iceberg (and covered in greater detail both others who oppose this plan), but I'm keen to support the opposition to the current Local Plan for Moreton. Matthew Britton told me during the Redesdale Hall drop-in that no building can be carried out on AONBs, so as the District is 80% AONB, building had to take place on the remaining 20%. I know this is not accurate, especially as Stow Council are considering 250+ homes to be built at the back of Tesco's (another scandal which I'm currently opposing). I can just imagine the traffic congestion in Stow if this planning is agreed. I'm aware that the CROW Act allows for Local Authorities, or the Secretary of State, to permit development on AONB, so this is another misnomer. However, that being the case, should the CDC not be looking at the very north of the District to building for new homes, that is to say, in and around Mickleton and Willersey. Such areas, from mapping, are outside of the AONB, have good links to the train station at Honeybourne, are close to the larger
conurbation of Evesham, and has better links to the MS motorway. All of these matters are championed by CDC Planning as far as Moreton is concerned, but has anyone considered links to areas outside of our district?

I will end my rather long email (apologies for that) with reference to an article in the Gloucestershire Standard written by Sam Krayem-Wood and Leigh Boobyer, in October 2020. 'Government plans to building nearly BOO extra homes a year in the Cotswolds have been branded 'bonkers' by the leader of the CDC', Cllr Harris. Mr Harries goes on to say, 'Cirencester and Moreton-in-Marsh would take the brunt of the rising housebuilding targets'. The report later quotes him saying that these 'are staggering numbers. And the thing is they are not deliverable'. It would appear that even in 2020, a Political decision by the CDC to target Moreton-in-Marsh for mass construction, had already been taken.

It is interesting to note that of the two Moreton based Cllrs, the one who is not fighting these plans is a member of the Liberal Democrats, who have a controlling interest in the CDC. It was also noted that very little appears to have been planned for 'Cluster Villages', that is to say acquisition of land in those areas where perhaps 'Cluster Villages' can be positioned, and there are already proposals for a new road to be built to divert traffic from Moreton. Does this mean that a Political decision has already been taken for Moreton to become a Garden Village irrespective of any objections, and that this consultation process is purely a box-ticking exercise.

Media reports continues that our planets temperature core to a pre-monstural level by 148% last year changing the global climate. If this means we will have great levels of precipitation then by its very name Moreton-in-the-Marsh is not the place to build more homes.

Carpark: I am strongly opposed to any car park at LEC 3 which will not be used. It will despair the previous views the town and church as a[[reached from the east and must be cherished. (It is also very wet) I am not convinced that Lechlade has a parking problem. 1 before the 2 hour limited ford trades parking at memorial hall 2 parking in riverside - park for general areas 3 - riverside park over the bridge 4 formalise the mudding parking which are '-' on the Farringdon road.

My objection is related to Highway's safety issues, particularly the current and proposed number of new houses which will directly impact on this. Already the roads in the town are gridlocked on a daily basis because of throughout traffic on the A419 and A44 and this problems also occurs at Stow-on-the-Wold. Our roads are dangerous because of the amount of traffic and in many cases narrow footpaths (Over the railway bridges x2) (or no footpaths up to Fosseway garden center) The amount of traffic also creates real pollution problems (air) The proposed increase in number of dwellings will make this problem also worse due to the disproportionate extra number of cars that will be driving in and through our town from and to the new proposed developments. Already it is too dangerous to cycle and as a runner it is dangerous running over the railway bridge on the A419 and down Todenham road to the new avenue estate and beyond. On the A44 there is no footpath beyond the fire station college so that is very dangerous to run, walk take a pushchair on the very narrow overgrown path. A proposed by pass for HGV's ad heavy traffic will not stop the extra number of cars from the new houses (2 cars per household = 3620 cars minimum extra) and parking which is already hazardous on our high street and town center car park would be even worse. Build some new houses but only those that highways infrastructure can support both current and future,

I am seeking a reduction in the number of new houses proposed for Moreton-in-Marsh. Our town should have its fair share but not be expected to take the lions share just because it is views that we have the necessary infrastructure and because there is available land. The building of new houses should be proportional and Moreton has already has a disproportional amount built in the last 20 years with over 1800 built - even more than Cirencester.

I am commenting on the effects such over development will have on Moreton-in-Marsh, both for new residents and existing the town infrastructure (water, road, health services etc) but primarily the rural character of the town. The massive increase (310 on the FCS plus a further 1500+) will change the town, making it a commuter town devoid of community with 2 counties if the neighbourhood center hot public houses and primary schools goes ahead.

Currently the town is struggling to incorporate the new developments in respect of shopping & leisure facilities, because people commuting by car to other nearby towns (e.g. Evesham, Stratford, Stow-on-the-Wold) for their daily needs. This influx of additional housing will densely populate areas that are rurally characterful, enabling the current residents to enjoy the countryside with numerous footpaths and fields that people and their dogs use and appreciate daily. These rural will no longer be there to enjoy by all through built up residential areas which is already the case in relation to the new developments in the Avenue for example which is not attractive, being a development of very similar looking houses, which could belong to any town, not a quaint market town like Moreton who's heritage and architect and community and rural aspect should be preserved by fewer houses (I am not against all new housing) and better designed layout and landscapes. Again I urge you to look at the backhouse and The Avenue developments to see how it shouldn't be done.

Thank you for reading this & taking my views into account.

S18 Moreton in Marsh

Wider transport infrastructure - are not close to Moreton-in-Marsh e.g. M40, A34, M4, M5 with limited alternative transport of trains. Only N/S connection by GWR with the proposed Honeybourne Stafford link not on FWR's planned route expansion. Any development of land for employment will need - an interrogated transport, network of infrastructure and these are already developed in nearby centers such as Banbury, Evesham, Oxford and Stratford. Even with a proposed by-pass the current - the proposed transport infrastructure of support the number of proposed homes.

Reduce the number of proposed dwellings which is disproportional to the towns location as employment and/or transport hub.
Look for alternative locations with better transport infrastructure and/or proximity to major transport links e.g. Cirencester, Kemble, Fairford with the M4, A417, A419, M5 access (Birmingham NQ) to Bristol SW, Cheltenham, Swindon.

On a flood plain - Flooding: Moreton-in-Marsh has experienced flooding in 2007 when the whole of the town center was under a meter of water and again in 2022 when east street was flooded. The proposed number of new dwellings resulting in hectares of current farmland that helps absorb the rainfall and maintain the already high water table (less than 0.5 in under GL56 0LA as per flood assessment) will exacerbate the potential for flooding either from Evenlode, it's tribulates (some of which are main roads in the specific development) and the high water table. The - of drawings from the projected number of dwellings cannot be coped with -

A reduction in the disproportion number of dwellings proposed for Moreton-in-Marsh
A full flood risk assessment - independent - to be undertaken
A full appraisal by the Environment Agency as to their views (they provide regular alerts of potential floodings to the properties in the GL56 area)

Public services are not just for purpose of the existing population of Moreton.
- Sewage pumping station - over capacity of pumping raw sewage in the towns waterways including the Evenlode river.
- Doctors surgeries - there are 2 and both are over subscribed
- Dentists - there is no NHS dentist in the town to have to go to other towns.
NC Hospital - does not cover most medical referrals which mean already we have to travel to Stow, Cirencester or Gloucester.

A reduction in the number of proposed houses in the local plan for Moreton
A new sewage pumping system for Moreton to stop ever increasing sewage release (Note Thames Water has approved a CSO for Moreton so eve more sewage can be realised and the new P.S has been put back again from 2026 to as least 2028.

The proposed development is in a special landscape areas (SLA) which has been given because of the exceptional distinctive landscape. This area of SLA is turned over to housing will destroy/remove the hedgerows and trees that are distinctive to this areas. In doing so the natural habitats of many plants and animals (including the great crested newts in this area) will be gone forever, as will the beautiful areas we in Moreton have the privilege to walk through. Nature preservation within the SLA will not take place and biodiversity will be compromised by so many extra houses.

A reduction in the number of houses proposed for Moreton.
Building on brown sites and not the designated SLA that lies to the north, south and east of the town.
Specific proposals to increase biodiversity, minimise removal of hedgerows and trees - minimising the destruction of plant and animal ecosystems.

Employment Opportunities: The FCS proposes to encourage business development in
- general industrial - this is a rural areas
- storage distribution - the road infrastructure will not support ant distribution capacity plus this is already provided by Bambury, Evesham, Oxford, Stratford, all of which are more advantages because of their transport - This type of business would not therefore be attracted to Moreton as a set up business.

The overdevelopment of modern will not advances the already high level of support the proposed local plan. The employment strategy so the continued number of new dwellings should be reduced and therefore the general employment "mix" be revisited in the light of my comments & writings.

Office, research & development business would also not be attracted to set up in Moreton because the town cannot (even with the additional houses) provide the specialist employment pod that these business require. They are there for draw not to rural towns but to high tech/ research to develop countries such as Oxford, Cirencester, Cheltenham.

Light industrial uses are already available on the current light industrial estates and interestingly there are a number of vacant sites. Moreton cannot support the current requirement for light industry so why would business want to invest here with it's lack of specialised employment -.

Conclusion
The majority of current residents of working age in Moreton commute either by car out of the town and/or by train. Those that travel by train to work drive to Moreton station so that if the proposed level of development takes places all it will do is increase significantly the number of car drivers/commuters in and out of the town.

Development - Moreton, Stow or Bourton do NOT have the infrastructure for the homes, Doctors, Schools, roads, SEWAGE etc. The houses are not for the people that want/need to work in the areas too expensive for basic salaries. We do not need more executive homes at nearly £400,000.

Doctors - already long need times
School - already full and any new build would be an important school playing grounds.
Sewage - already beyond breaking point.
Roads - Fosseway cannot cope.
Housing - NOT for young/ or most jobs available in the area that have a lower salary.
BNG should be in the areas not sat somewhere totally different.

Houses should be affordable to those earning 25k a year. They should be fully sustainable with solar panels / re-use water / sustainable heating. Big sites should have the infrastructure to support the numbers of people and cars. Houses should be built on brown sites – not - farmland.

Development - Moreton, Stow or Bourton do NOT have the infrastructure for the homes, Doctors, Schools, roads, SEWAGE etc. The houses are not for the people that want/need to work in the areas too expensive for basic salaries. We do not need more executive homes at nearly £400,000.

Doctors - already long need times
School - already full and any new build would be an important school playing grounds.
Sewage - already beyond breaking point.
Roads - Fosseway cannot cope.
Housing - NOT for young/ or most jobs available in the area that have a lower salary.
BNG should be in the areas not sat somewhere totally different.

Houses should be affordable to those earning 25k a year. They should be fully sustainable with solar panels / re-use water / sustainable heating. Big sites should have the infrastructure to support the numbers of people and cars. Houses should be built on brown sites – not - farmland.

Development - Moreton, Stow or Bourton do NOT have the infrastructure for the homes, Doctors, Schools, roads, SEWAGE etc. The houses are not for the people that want/need to work in the areas too expensive for basic salaries. We do not need more executive homes at nearly £400,000.

Doctors - already long need times
School - already full and any new build would be an important school playing grounds.
Sewage - already beyond breaking point.
Roads - Fosseway cannot cope.
Housing - NOT for young/ or most jobs available in the area that have a lower salary.
BNG should be in the areas not sat somewhere totally different.

Houses should be affordable to those earning 25k a year. They should be fully sustainable with solar panels / re-use water / sustainable heating. Big sites should have the infrastructure to support the numbers of people and cars. Houses should be built on brown sites – not - farmland.

Page 64 Policy CC6 Paragraph 5.6.11

AGREE

AT PRESENT THE INFRASTRUCTURE IN Moreton IS WOEFULLY INADEQUATE AND, NOTHING HAS BEEN ADDRESSED FOR YEARS DESPITE THE CENSUS FIGURES SHOWING AN ALREADY MARKED INCREASE IN THE POPULATION OF Moreton, ANY INCREASE IN BUILDING MORE PROPERTIES, WILL ONLY SEE MATTERS GETTING MUCH WORSE.

Before Any New Builds Are Considered, Thames Water Must Address And Greatly Improve The Waste Water Treatment Works, Thus Drastically Upgrading The Works To Cover The Whole Of Moreton, At Present Thames Water is Discharging Polluted Water into the River Evenlode Daily, The Effect Is Killing Fish And Wild Life for the whole length of the river, The Pollution Is Causing Great Distress to Everyone