Cotswold District Local Plan Update - Development Strategy Options and Preferred Options Topic Paper

The adopted Local Plan became more than 5 years old in August 2023 and at that point needed reviewing. Moreover, now that plan’s strategic policies are over 5 years old the Council is required to identify a 5 year housing land supply against its Local Housing Need calculated using the Standard Method in accordance with NPPF paragraph 77. 1.8. It is noted that the Council have carried out a footnote 42 review of the relevant policies in August 2023 and concluded that Policy DS1 does not require updating. On this basis, the Council propose to maintain the adopted housing requirement and only make minor changes to the development strategy through a partial update to the Local Plan. 1.9. This is however considered to be a flawed outcome. It is clear that the housing requirement in the adopted Local Plan is now out of date and the standard method Local Housing Need should be applied instead. 1.10. Paragraph 33 of the NPPF makes it clear that relevant strategic policies will need updating at least once every five years if their applicable local housing need figure has changed significantly. 1.11. Paragraph 62 of the Planning Practice Guidance (PPG) on Plan Making then states that: “Local housing need will be considered to have changed significantly where a plan has been adopted prior to the standard method being implemented, on the basis of a number that is significantly below the number generated using the standard method, or has been subject to a cap where the plan has been adopted using the standard method. This is to ensure that all housing need is planned for a quickly as reasonably possible (Reference ID: 61-062-20190315).” 1.12. The PPG on Housing and Economic Needs Assessment addresses whether or not the standard method is mandatory for strategic policy making purposes and states that: “No, if it is felt that circumstances warrant an alternative approach but authorities can expect this to be scrutinised more closely at examination. There is an expectation that the standard method will be used and that any other method will be used only in exceptional circumstances (Reference ID: 2a-003-20190220).” It is therefore clear that: a) the standard method should be used if the adopted Local Plan requirement is significantly below the generated figure b) Exceptional circumstances must be demonstrated if the Council is to follow an alternative approach and depart from the standard method, and this is to be closely scrutinised at examination. 1.14. As a measure for considering whether the housing need has changed significantly, the Council seeks to rely on the NPPF wording around the Housing Delivery Test which states that there has been a significant under delivery of housing where this was below 85% of the housing requirement over the preceding 3 years. The meaning of ‘significant’ within the context of under delivery therefore means a shortfall of more than 15% of the housing requirement over the previous three year period. 1.15. From this, the Council infer that 15% should be used as a benchmark for considering whether the applicable housing need has changed significantly. They conclude that the CDLP housing need is only 4.95% lower than the Standard Method Local Housing Need. 1.16. There are a number of issues with the approach and it is considered to represent a flawed assessment. Not only does the Council’s 15% benchmark have no basis in policy for this specific purpose, it can in any event be established that the Council’s Local Housing Need of 9,860 homes (493 dwellings per annum over a 20 year plan period) is 17.4% higher than local plan requirement of 8,400 homes. This equates to 1,460 additional homes over a 20 year plan period, or an additional 584 homes over the remaining 8 years of the current plan period. This is considered to be significant, 1.17. It appears that the Council have based their assessment in this regard on a review carried out by Opinion Research Services (ORS) on the Council’s behalf. 1.18. The ORS review is based on mismatching figures and is not considered to represent a reliable source of information. It states that the applicable local housing need figure was 8,665 dwellings at the time that the Local Plan was adopted. The updated housing need figure (Standard Method) has been calculated to be 9,094 dwellings. It therefore concludes that there is only a difference of 429 dwellings between the two specific figures (a 4.95% increase). It is noted however that 8,665 dwellings is not the housing requirement set out in adopted strategic policies for the purpose of NPPF paragraph 77. The correct figure is 8,400 homes. Furthermore, 9,094 dwellings is not the Council’s LHN and contradicts the Council’s own review document which indicates that this should be based on 493 dwellings per annum so 9,860 over a 20 year plan period. 1.20. In addition to the above, despite recognising that housing affordability is a particular issue facing the District, the Council consider there to be little (if any) relationship between housing supply and affordability. The Council’s August 2023 review makes it clear that housing is less affordable in Cotswold District compared to the county, regional and national averages. The Council states that it is keen to take action to enable people to afford a home in the district. 1.21. The August 2023 review also points out that, based on a supply of existing planning permissions, site allocations and windfalls, it is estimated that 1,051 affordable homes will be delivered between 2021 and 2031, which equates to 76% of the identified need for 1,378 affordable homes in this period. This indicates that there is likely to be a plan period shortfall in the delivery of affordable housing. 1.22. The Council note that the standard method includes a 188 dwelling per annum (62%) uplift to the household projections to help address the affordability of housing within district. However, despite the Council’s stated intention of taking action to enable people to afford a home in the district, and despite recognising that there is likely to be a plan period shortfall in the delivery of affordable housing, the Council have chosen not to follow the higher housing need produced by the standard method and the significant affordability uplift that it would bring. This is considered to be perverse logic. 1.23. The Council also consider that there are arguments for setting a housing requirement below the identified housing need due to the land constraints of the area (including 80% AONB). The Council also consider that it would be unsustainable for the housing requirement to be higher than the identified housing need as this would result in unsustainable rates of development for Cotswold District, which is a heavily constrained rural area. 1.24. We consider however that these are not appropriate considerations for a footnote 42 review. These matters are based on paragraph 11a and 11b of the NPPF which relate to the application of the NPPF’s presumption in favour of sustainable development to plan making. Using these matters to justify a constrained housing requirement that is lower than the identified housing need would need to be fully evidenced and rigorously tested at examination. If the Council is proposing to utilise a constrained housing requirement this must be done through a formal review of the Local Plan and not through a footnote 42 review. 1.25. In conclusion on this point, we dispute the whole premise against which the partial update to the Local Plan is based upon. It is clear that the partial update is not an appropriate response under the circumstances facing the District and instead a full scale review of the plan is needed. In light of the higher housing need produced by the standard method, this review would need to either allocate new sites to meet the remaining need, or demonstrate exceptional circumstances to justify a reduced housing requirement.

This topic paper has been produced alongside the policy updates. The paper discusses the amount of additional development that may be needed up until 2041 and proposes preferred development strategy options and areas for growth. 1.42. The paper proposes that a blend of Scenarios 1 (Additional non-strategic site allocations), 2 (main service centre focus), 6 (new strategic sites) and 7 (focus growth around transport modes) are believed to be the most appropriate way to accommodate the bulk of additional development needs up to 2041. 1.43. While a combination of development scenarios will lead to the most balanced delivery of homes, CO consider the incorporation of dispersed growth (Scenario 3) and village clusters (Scenario 4) to be necessary. These scenarios, particularly Scenario 4, whereby growth is dispersed across small groups of villages based in the services, facilities and infrastructure they offer, reflects the distinct nature in which the villages in the Cotswolds are visited and used. It would allow for a sustainable level of growth and new development to enhance the vitality of these settlements. It would also reflect the objectives of paragraph 83 of the NPPF. These development scenarios are also appropriate for small and medium scale sites and would assist the Council with meeting the requirement of paragraph 70 of the NPPF to identify 10% of their houisng requirement on sites no larger than a hectare. Small and medium sized sites can make an important contribution to meeting the housing requirement of an area, and are often built-out relatively quickly. Indeed this would assist the Council with maintaining a rolling supply of deliverable housing land going forward. 1.45. As previously explained, growth through non-principal settlements would welcome the opportunity for a wider range of housing types and tenure to be built, along with improving affordability of the area. It would also aid in the retention of the local facilities and services within the village; development within these rural areas would increase expenditure within the local area. 1.46. Small-scale development at small settlements is necessary in the vitality of communities, affordability, retaining newer generations in the area as well as positively and significantly contributing to housing supply. It is acknowledged a mixture of scenarios will be required to formulate the new development plan, however CO strongly recommend for the reasons outlined above that a greater level of dispersed growth should be allowed for in the Local Plan in order to readily address the issues of under-supply and affordability.

Affordable Housing 3.46 There has been no updated report relating to Affordable Housing need since 2016. Rather the Council seek to rely on and carry forward the proportion of affordable housing that the Inspector considered to be deliverable at the time, rather than the full need. The Council in their 2031 Housing Requirement review note that Plan has over-delivered on affordable housing requirement set out in the Plan, but without an up to date assessment of affordable housing need, it is not clear what the level of under-provision is against the actual need. In addition, given the higher levels of housing delivery in the early part of the plan period, it is to be expected that there would be a corresponding level of affordable housing, however given that nationally there is an affordable housing crisis due to undersupply, it is likely that the percentage of provision against need may well be significantly under that recommended by the Inspector. 3.47 This provides a further justification as to the need to review and increase the housing requirement.

The Vision, Objectives and Development Strategy Options Topic Paper considers whether the Plan period should be extended to 2041, covering a period of 15 years from 2026, albeit that it is not clear from the document how this relates to the partial review up to 2031. In setting out the calculations it is clear that the housing need of 7,400 dwellings over 15 years (which will now need to be updated to reflect the latest affordability ratio’s) was seeking to rely on past over delivery from the early part of the Plan period. However, in his Ministerial Statement the Secretary of State confirmed on 19 December 2023 that such over delivery is not to be taken into account when preparing new plans, stating: “The Government also considered allowing authorities to take account of past ‘over-delivery’ when preparing new plans. Having considered responses to the consultation, which raised questions over needing to also consider ‘under-delivery’ and the risk of double counting homes via the standard method, we are not proceeding with this change at this time.” As such, the housing figures to 2041 should take account of the Plans past provision, as is being proposed. 3.43 In addition, as set out above, given that the requirement to 2031 is being reviewed, it would be appropriate to remove the past oversupply from the stepped trajectory and for the Plan to make full provision to meet its annual requirement of 504 dwellings per annum or 4,032 dwellings over the next 8 years. 3.44 It is considered that given the government’s decision to not include over delivery in the housing requirement, provides a further justification for a full review of the Local Plan to be undertaken. 3.45 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.

Vision, Objectives and Development Strategy Options Topic Paper 1 The topic paper raises important matters for Lechlade in relation to its role as a Principal Settlement and its capacity to accommodate further housing growth. It presents a development strategy following consideration of a number of development scenarios, which are the focus of this response in terms of the implications of relevant scenarios for Lechlade and the delivery of its Neighbourhood Plan Vision and Objectives. 2 Eight potential development strategy options have been identified to accommodate the additional growth: 3 Scenario 1: Additional non-strategic site allocations 4 Scenario 2: Main service centre focus 5 Scenario 3: Dispersed growth • Scenario 4: Village clusters • Scenario 5: New settlement(s) • Scenario 6: New strategic site(s) • Scenario 7: Focus growth around transport nodes • Scenario 8: Request neighbouring authority to deliver some of the housing need • The Topic Paper suggests that ‘a blend of Scenarios 1, 2, 6 and 7 are believed to be the most appropriate way to accommodate the bulk of additional development needs up to 2041’. Under this combination of approaches, Lechlade would continue to be supported as a location where the principle of development would be supported. An important statement is also made, as follows….’ However, the updated development strategy would have a greater focus on reducing carbon emissions and focussing growth in locations with good transport connectivity and access to services, facilities and employment. Accordingly, having been reviewed as part of this process, some Non-Principal Settlements may become a Principal Settlement and some Principal Settlements may have their Principal Settlement rescinded’. • In relation to additional non-strategic site allocations at Principal Settlements, the aim would be to limit the scale and extent of development within the Cotswold National Landscape and to direct it away from areas with higher flood risk. Moreton-in-Marsh is suggested as capable of accommodating a strategic site allocations to accommodate over 1,500 additional dwellings and land for employment development. • Scenario 1 would focus the majority of growth at Principal Settlements. Whilst it is important that growth should be focused on sustainable settlement locations, it is right that the opportunity is taken to review the Principal Settlements, to examine their sustainability and their capacity for additional growth. A review of the position and future role of each current Principal Settlement is welcome. • Lechlade has recently faced a number of planning applications for significant amounts of housing development outside the development boundary of the town. This has raised concerns about where future growth might go if Lechlade remains a Principal Settlement. It has caused the community to ask whether the current development strategy is working (to deliver employment and strengthen services) and it is revealing the scale of potential impacts on surrounding countryside that could arise from new development outside the town. People are also questioning whether the stock of local services and infrastructure are sufficient to handle more population growth. • This response provides an initial review of the position of Lechlade with respect to the original assessment in 2012, the Made Neighbourhood Plan, recent Census information and issues revealed by recent planning applications. This is a starting point for considering the future role of Lechlade with the Local Plan Update to 2041.

Policy DS1 – Development Strategy OBJECT The Council proposes to update Policy DS1 (Development Strategy) to capture the following: • Update to clarify that the housing requirement will be monitored against a stepped (residual) requirement, which takes into account past completions; • Updated housing requirement for period between 2011-2031; • Update to confirm that the Standard Methodology will be employed from the period starting 1st April 2031; and • Updated housing land supply position. Hallam strongly objects to the proposed amendments based on the reasons set out below. Firstly, Hallam objects to the Council’s approach of counting past oversupply in its housing requirement calculations. This methodology is flawed as it precedes planning guidance on when and how past oversupply can be counted. Therefore, Paragraph 2 of Policy DS1 should be deleted, and the housing requirement should not rely on past oversupply. Secondly, the Council suggests that the housing requirement for the period 2011 – 2031 is based on the adopted housing requirement (8,400 dwellings) less completions over that period. However, the adopted Local Plan became five years old on 3rd August 2023, rendering Policy DS1 out of date. It is acknowledged that the Council published a “Review of the Cotswold District Local Plan 2011-2031 Housing Requirement” in August 2023. The Review concluded that the strategic housing requirement policies do not need updating because future housing needs (calculated as 9,094 homes) are not significantly different to those implicit in the Adopted Plan, and because the housing requirement of 420 per annum in the adopted plan is to be understood and regarded as a minimum figure. However, the latest Local Housing Need (LHN)* figure is approximately 90% higher than the current Local Plan target (504 vs 265 dwelling per annum). In addition, neither the Review nor the assumptions underpinning the Review have been tested through any consultation, let alone examination. Therefore, Policy DS1 is considered out of date and the Standard Methodology should be applied from August 2023. This should be reflected in Table DS1b, which currently shows Standard Methodology only being applicable from 2031. Based on the above, the Council’s housing land supply should also be updated to remove past oversupply and apply the Standard Methodology from August 2023. Past ”oversupply” of housing has already been fully accounted for in the assessment of the Local Housing Need. It remains the case that Cotswold District has the highest affordability ratio of all local authorities across the whole of the southwest region. Restricting the housing requirement to 265 dwellings – just 53% of current Local Housing Need – can only fail those in affordable housing need and conflicts strongly with the NPPF. *Cotswold’s LHN is currently 504 dwellings per annum following the release of the new affordability ratios on 25 March 2024. Suggested changes: • Remove past oversupply from housing requirement calculations; • Apply the Standard Methodology from August 2023, when the adopted Local Plan became five years old; • Apply the updated affordability ratios to the Standard Methodology; • Update the housing land supply to reflect the above changes.

Q5: Do you agree with the proposed development strategy (scenario combination)? No Q6: Tell us more about why you agree or disagree. Please see next section Hallam acknowledges that a combination of scenarios is likely required to meet local housing needs in the district. However, some of the Council’s preferred options are flawed and should not form part of the overall development strategy. This section provides Hallam’s response to each of the eight development scenarios. COUNCIL’S PREFFERRED OPTIONS Scenario 1 (Additional Non-Strategic Site Allocations) Hallam strongly supports Scenario 1, which seeks to focus the majority of additional growth in Principal Settlements, including allocating new sites outside existing development boundaries. This approach has already been tested through the examination process of the adopted Local Plan and also aligns with the Council’s ambition to be ‘green to the core’ by locating new development in areas with good access to transport, services and facilities. Principal Settlements benefit from existing facilities and services that can accommodate new development, with additional provision secured through development where required. The New Local Plan process also provides an opportunity to review existing Principal Settlement boundaries to ensure that sufficient land is allocated to meet housing needs within the district. These new allocations provide the most sustainable locations for development as they are already well-served by sustainable transport and infrastructure. Research undertaken by Planning and Development Consultancy Lichfields (Start to Finish, March 2024) indicates non-strategic sites have a significantly shorter planning approval period and planning to delivery period than larger strategic sites. For example, non-strategic sites of 50-99 homes typically obtain planning consent in less than 2 years, while protracted discussions on larger strategic sites mean that the planning approval period typically lasts for over 5 years (in some cases closer to 8 years). It is therefore estimated that non-strategic sites can be expected to deliver their first dwelling within 4 years of validation, while larger strategic sites can take over 8 years. Indeed, the research concludes that “only sites below 100 dwellings on average begin to deliver within a five-yar period from validation of an outline application”. This highlights the importance of allocating non-strategic sites to facilitate the delivery of local housing need within the Local Plan period. In addition to this, the Integrated Impact Assessment (IIA) for the Cotswold Local Plan Update (February 2024) states that many larger settlements, including Cirencester, Tetbury and Moreton-in-Marsh, have already absorbed significant housing development in recent years and/or have future growth already committed. The IIA therefore concludes that continued focus on housing growth in these locations has the potential to place additional pressure on existing services and facilities. Furthermore, the IIA highlights that the Cotswold National Landscape is a significant constraint to growth. In particular, settlements including Cirencester, Kemble, Tetbury and Moreton-in-Marsh re all either wholly or partly covered by the National Landscape. These sensitivities need to be factored into any development strategy. Subject to land availability and constraints, Hallam suggests that any Scenario 1 growth is focused in Principal Settlements that have not accommodated much growth in recent years, including Lechlade. Additional allocations in these locations will support the delivery of appropriate development to meet local needs. Growth should also be focused in areas with less constraints, especially as it relates to the National Landscape. A separate Call for Sites form has been submitted for a site in Lechlade that is suitable, achievable and available for development. Notwithstanding this point, Hallam recognises that the Council may not be able to deliver the indicative target number of additional homes by relying solely on Scenario 1. Therefore, the principle of applying a Development Strategy that combines multiple scenarios is supported. However, Hallam strongly objects to some of the Council’s preferred options, as detailed later in this section. Scenario 2 (Main Service Centre Focus) The Council seeks to focus the vast majority of development at Main Service Centres. These centres offer the greatest range of services and facilities, public transport accessibility and employment provision. As mentioned previously, the IIA states that many larger settlements, including Cirencester, Tetbury and Moreton-in-Marsh, have already absorbed significant housing development in recent years and/or have future growth already committed. The IIA therefore concludes that continued focus on housing growth in these locations has the potential to place additional pressure on existing services and facilities. In addition, the IIA highlights that the Cotswold National Landscape is a significant constraint to growth. In particular, settlements including Cirencester, Kemble, Tetbury and Moreton-in-Marsh are all either wholly or partly covered by the National Landscape. These sensitivities need to be factored into any development strategy. Therefore, subject to land availability and constraints, Hallam suggests that any Scenario 2 growth is focused in Main Service Centres that have not accommodated much growth in recent years. For example, Lechlade, which is identified in Paragraph 6.7 of the IIA as a Main Service Centre, has not accommodated much growth in recent years. Growth should also be focused in areas with less constraints, especially as it relates to the National Landscape. Therefore, additional allocations in areas such as Lechlade will support the delivery of appropriate development to meet local needs with little constraint. Scenario 6 (New Strategic Sites) Hallam has significant concerns that this Development Option is included within the Council’s preferred scenarios. Firstly, based on the current Standard Methodology (applying the latest affordability ratios published on 25 March 2024), Cotswold needs to identify land to deliver approximately 7,560dwellings between 2026 and 2041. The Council indicates that approximately 5,000 homes have already been identified, but applying a flexibility buffer still generates a requirement for approximately 3,470 additional dwellings within the plan period. As previously highlighted, the ‘Start to Finish’ report prepared by Lichfields indicates that large strategic sites typically need over 8 years from validation to the completion of the first dwelling on site. The build out of the rest of the scheme can then take another few years depending on the scale of the development. Therefore, the delivery of a strategic site typically requires a period of 10+ years, allowing for planning negotiations, reserved matters approvals, delivery of key infrastructure and then eventually completion of homes. A new strategic site is subsequently unlikely to be delivered in full until very late in the extended plan period, or potentially post-2041. This approach conflicts with the Council’s requirement to meet local needs and could affect the Council’s performance on the Housing Delivery Test. In addition to the above, strategic sites are typically land hungry. Cotswold is subject to landscape and other designations (notably the AONB) which constrain development in the district. Therefore, the delivery of this scenario is ambitious as appropriate land needs to be identified that meets sustainability objectives while avoiding the district’s constraints. The IIA also recognises the above challenges with delivering new strategic sites. Based on the long lead in time for delivering housing on these sites, the IITA concludes that “taking forward Option 5 or Option 6 may only form part of the housing land supply solution during the current plan period to 2041”. Based on the above, Hallam objects to both Scenario 6 (New Strategic Sites) and Scenario 5 (New Settlements), and particularly objects to the inclusion of Scenario 6 in the Council’s preferred strategy. Scenario 7 (Focus Growth around Transport Nodes) The principle of this scenario aligns with part of the Council’s Vision and Objectives, particularly as it relates to transitioning to a low carbon economy and reducing transport carbon emissions. However, Hallam is concerned that any reliance on this scenario could undermine the other parts of the Vision and Objectives, including those relating to maintaining a vibrant economy. Focusing growth around public transport hubs can be an effective means of encouraging sustainable forms of transport. However, this could also lead to increased out-commuting, which may then draw residents away from the district and negatively impact the vitality, viability and vibrancy of the Cotswold economy. The success of this scenario is reliant on significant consideration and investment in employment opportunities within the district to accommodate additional growth in these locations. The Council should also take measures to ensure that development around transport nodes does not place undue pressure on existing facilities and services, especially in relation to Moreton-in-Marsh and Kemble. OTHER SCENARIO OPTIONS Scenario 3 (Dispersed Growth) and Scenario 4 (Village Clusters) Hallam supports the Council’s approach to encouraging small scale development. These are typically quicker to deliver, which contributes positively to delivery rates and helps the Council to meet local needs more flexibly. However, it is imperative that major development is not permitted or encouraged in villages. This approach would not be in keeping with sustainability objectives and would place undue pressure on existing facilities and services in villages. Scenario 5 (New Settlements) Please refer to Scenario 6 (New Strategic Sites) above. Scenario 8 (Request Neighbouring Authority to Deliver some of the Housing Need) The Vision, Objectives and Development Strategy Options Paper states that if the full local housing need cannot be accommodated within Cotswold, then neighbouring Local Planning Authorities will be approached. While the Council has not yet confirmed whether this approach is necessary, it is important to ensure that housing need is met locally where it is required. The Council has set out a number of Development Strategy Options, some of which are suitable to deliver future housing needs. These should be explored to the full extent to identify locations that are sustainable, suitable, available and achievable. The Strategic Housing and Economic Land Availability Assessment (2021) identifies a significant number of sites that could deliver the district’s housing needs. In addition, the ongoing Call for Sites will undoubtedly present additional site options for consideration. These sites should be explored in full to ensure that the district’s needs are met locally. Finally, in the absence of a Duty to Cooperate, the mechanism to secure housing needs in neighbouring authorities is unclear. Suggested changes: • Focus majority of development on non-strategic site allocations (Scenario 1); • Consider additional allocations in Principal Settlements and Main Service Centres that have not accommodated much growth in recent years and are less constrained by the National Landscape; • Remove Scenarios 6 and 7 from the Council’s preferred options. • Ensure all local needs are met within the district.

Development strategy options Moreton-in-Marsh has been selected as a 'principle settlement' yet it has already see the largest increase in housing across the Cotswold District in the last 20 years (census date)

Vision and objectives The local plan pays very little regard to the climate crisis and making it green at the core. Moreton-in-Marsh is on a flood plain. There have been 635 hours of sewage being dumped into the Evenlode tis year. There has been no consideration of the effects of this development on the rivers or groundwaters.

Executive Summary Page 2 Paragraph 9. I am concerned about the effects on all areas of Moreton - includes infrastructure/density/overdevelopment. I am concerned about the burden on the road infrastructure and the effects this will have on the overused roads in Moreton. Please consider Kemble as this is the best alternative. Please do not build any more houses in Moreton.

6. Development Strategy Moreton cannot be viewed as a transport hub just as kingham choubury, honeybourne, over other must stop on the time between oxford and Worcester -. Oxford yes Moreton No! Just become the CDC has a cycle shed built at great expense does not make Moreton a transport hub. This factor disputes the CDCs plan for Moreton to be tangible for additional development. In addition during the autumn winter and spring months (3/4 of the year) when it's wet and miserable people will use their cars to travel, so destroying the through of this being a GREEN TO THE CORE plan.

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.

Development strategy - and Preferred options Topic Paper Executive Summary Page 2 Paragraph 1.9 Cover the over 1,500 proposed homes. Moreton-in-Marsh has a bustling and thriving market town but now it is mainly used by people buying houses to get to London. We have next to no shops to speak of. The doctors surgeries cannot cope with the people we have now. The primary schools will need to be extended. Little country roads that cannot cope with the traffic on them will struggle even more with more houses. We do not need any more houses or the Infrastructure Moreton-in-Marsh will collapse. The old Victorian sewers will not cope with more houses as they are not coping now. Moreton-in- Marsh is a market town and should stay a market town and not just on a whim of Cotswold District Councillors to build more houses. NO MORE HOUSES.

Fairford (Policy S5) Inset 4 This map is out of date as it does not include 3 large estates of recent construction literally doubling the size of Fairford. This outrageous number of new houses has totally overwhelmed the Town leading to significant loss of Greenfields and a huge and unwanted/unattained increase in the population, with no prior significant notification to the indigenous residents, in the town or in close proximity.

Delivering the strategy 7.2.8 The TOTAL incompatibility of 'Green to the core' within this statement i.e. 7.28. In the last 10 years the whole area has been subject of a series of housing developments which in many cases have swamped the area with new housing - sheet 1 Tetbury, Fairford, Stow, Moreton, Ashton Keynes, Northleach, Lechlade, Cirencester. This - has continued up to the present, leading to significant low of countryside and now against the prevailing you view that greenfield sites must be avoided. Stating that you will be 'Green to the core' is the total antithesis of any plan to 'develop' Chesterton - Comment 2 7.3.6 Not only is this an area which amounts to increasing the urban area of Cirencester by a third, the concomitant increase in population and - use will have a devastating 'urban' effect in an already - plagues town. General Comment I feel that the unique qualities of the Cotswolds have been significantly compromised in the last decade, almost solely due to insidious double-talk by Government and big builders. Local Corners have been effectively sidelined by' Objectives’ inspections who always promote more housing. Council must listen to their - and put a stop to this in areas such as ours. DELIVERING THE STRATEGY - 7.2.8. In summary, Cirencester MUST abandon the Chesterton Brief, as it is flying against all the present environmental and climate warmings in the most blatant 'anti-green' way. A moratorium on new estates in 'all' areas is vital to allow for some form of stable equilibrium to become established. The word 'DEVELOPMENT' must be expunged from the Council's lexicon!

Extract Point 6.7 Moreton-in-Marsh is a transport hub, which includes a railway station. There are various sites located to the south, east and north of the town that are available for development and that are located outside the Cotswolds National Landscape and areas at higher risk of flooding. These sites would likely have access to the level of services, facilities and employment opportunities of a Main Service Centre. It is estimated that a combination of these development plots could deliver over 1,500 additional homes by 2041. Moreton-in-Marsh would therefore be identified as a broad location for strategic scale growth (Scenario 6). This approach would enable further development in the town to be planned comprehensively (e.g. transport, water / wastewater, education, etc.). In addition, unlike single large strategic sites of 500+ dwellings(15), which typically have long development lead-in times, the combination of the smaller development parcels on offer would enable shorter lead-in times. A longer-term vision, including additional development, may be required to deliver some infrastructure items such as a secondary school. MTC looks forward to the establishment of a Transport Hub at its Railway Station. As previously stated, half of the Town is situated in the Cotswold National Landscape, the other half in the Special Landscape Area. To suggest that land within a single parish boundary can be subject to separate policy would probably fail an equalities impact assessment. The Special Landscape Area (SLA), designation provides protection for locally significant and attractive landscapes that are of comparable quality to Areas of Outstanding Natural Beauty (AONB). They should be protected and enhanced, particularly through the planning process. All the SLAs in the district border the Cotswolds AONB. Suggesting that one location in Cotswold District takes half of the District’s housing requirement over a ten-year period is a poor option unless the residents of Moreton see such development in the context of both District and County Council plans. If access to education, employment, highways, and public transport opportunities are to be delivered in support of strategic scale growth, the public will need to be convinced otherwise Moreton in Marsh will simply be subject to more of the same incremental development. Noting the point made in the Employment Development policy EC1 9.1.3. Cotswold District Council recognises that, whilst GFirst's Strategic Economic Plan (SEP) does not consider the District to be the key focus for economic growth in the County, it is committed to promoting growth and enhancement of the Gloucestershire economy. The competitive advantage of larger surrounding towns, such as Swindon, Cheltenham and Gloucester is recognised in the relevant Strategic Economic Plans, which identify them as key locations for growth. However, with a highly skilled population and key business assets, Cotswold offers a unique business location that offers a high quality of life in an outstanding natural and historic environment. It also has access to the strategic rail network at Kemble and Moreton-in-Marsh. The Local Plan seeks to support strong and sustainable economic growth while recognising that the District… Whilst the Local Planning Authority accepts the situation outlined above it should be noted that the needs of both the current and future population of Moreton reside within Gloucestershire and are equally entitled to the services provided by the County Council such as education, employment, highways and transport. Access to Employment opportunities should not be viewed simply in the context of the District and, as an approach, it is limited and unacceptable. As previously stated, development will need to be considered in the context of both District and County Council plans. Suggesting that 1,500 homes and listing Moreton in Marsh as a settlement suitable for strategic growth will avoid the impact of incremental development and that ‘This approach would enable the town to be planned comprehensively’ is not credible without the investment into a specific and masterplan for Moreton developed before 2026. Only proposing to comprehensively plan following significant development is to ignore the impact of 1,500 homes on the town and its residents, indeed it will be a dereliction of the Local Planning Authorities duty to its current and future residents.

Executive summary point 1.3 bullet 2 Extract: For example, more homes may be required to increase affordable housing delivery or fewer homes may be required to protect assets or areas of particular importance (e.g. the Cotswolds National Landscape). If you propose to update the Local Plan to 2031 increasing the percentage of affordable homes from 40% to 50% it is hard to see why more homes would be required? Extract Exec Summary point 1.3 bullet 3: Around 5,150 dwellings’ worth of housing land supply for the extended plan period has already been identified. CDC has yet to disclose the outcome of the SHELAA 2022 where presumably this land was identified. It would be helpful to share this with Town Councils who responded to the 2022 consultation. Extract Exec summary 1.3 bullet 5: The adopted Local Plan includes 14% more housing land supply than the housing requirement to provide flexibility in case any sites were not delivered as expected. This is the reason why Moreton in Marsh Town Council cannot understand the need to include upwards of 310 houses on the Fire Service College (FSC) site immediately in the Updated Local Plan proposal. Extract Exec Summary 1.9: Additional non-strategic site allocations for different types of development would be made at the Principal Settlements whilst ensuring that the scale and extent of development within the Cotswolds National Landscape (formerly the Cotswolds Area of Outstanding Natural Beauty) remains limited and that development is directed away from areas with higher flood risk. In addition, given that Moreton-in-Marsh is a transport hub, which has a railway station; good provision of services, facilities and employment; and has various sites outside the Cotswold National Landscape, the town would become a focus for strategic-scale growth of over 1,500 additional dwellings and additional land for employment development. A longer-term vision, including additional development, may be required to deliver some infrastructure items such as a secondary school. As half of the Town of Moreton in Marsh sits in the Cotswold National Landscape it is inevitable that the scale of proposed development will adversely impact on the National landscape and in particular the surrounding areas of the North Cotswolds. Moreton Town Council agrees that development should be directed away from areas with higher flood risk. Cotswold District Council Level 1 Strategic Flood Risk Assessment 2023 identifies Moreton in Marsh as being High Risk of Flooding as does Thames Water Ground Impact System Management Information Plan. Where SuDs connections are made to existing infrastructure the pressure increases causing increased use of a Land Treatment Area (LTA) for sewerage and discharge into the river Evenlode leading to increased flood risk to homes in Moreton and downstream to Bledington. Strategic scale growth suggested for Moreton in Marsh without a suitable specifically detailed impact assessment is not planning, without a detailed assessment, it will be a failure of the Local Planning Authority to plan effectively.

call for sites. The allocation of this site provides opportunity for residential growth in Didmarton. The following outlines why the Site is suitable to provide approximately 10 dwellings in this rural location. The development of this Site aligns with the Council’s proposed development scenarios 3 and 4, which are being considered by the Council to form part of their preferred development strategy. Location of Development and Proposed Use The site comprises approximately 0.65 hectares of agricultural land, of which is being promoted for residential use. We consider that a proportionate number of units can be delivered onsite. The anticipated number to be delivered is subject to technical work that will be undertaken to ensure all other relevant planning policies are considered. However, we consider up to 10 dwellings could comfortably sit on site in the context of the site’s edge of settlement location and the Landscape Technical Note that accompanies this representation. Whilst we acknowledge that the site is within open countryside, it is felt that this is a location that offers a logical rounding off to Didmarton which in turn offers a sustainable opportunity for housing growth within a rural area, particularly as it borders the existing built form from Arild’s Road. The site’s redevelopment benefits from the services and facilities that lie within the village of Didmarton, ensuring the vitality of those services and facilities are protected and enhanced. Notwithstanding the site’s proximity to Tetbury, Upton Hawkesbury, the M4, and the M5. Further, the site offers the ability to meet local housing needs, including the need for affordable homes, within this rural location of this part of the district that also sits within the AONB. The ability to deliver such development is considered to help retain and attract the younger population, further adding to the ability that existing settlements and their services are more likely to be sustained and enhanced, securing the sustainability and vitality of rural areas. Currently, the adopted Local Plan focusses development within 17 defined Principal Settlements with no development planned within the rural areas of the district, albeit the aim is to deliver a minimum of 8,400 new homes across the district. We note that policies are in place to help meet rural needs such as Policy DS3, but it is felt that rural villages can offer a valid and sustainable approach to accommodating the District’s growth. It is positive to see that the emerging development strategy recognises that from a plan-led approach, the emerging development strategy can help shape growth in rural areas in a proportionate and sustainable manner. This is reflected within Scenario 3 ‘Dispersed growth’ and Scenario 4 ‘Village clusters’ which both look to support the development of small to medium sized outside the Principal Settlements which would not only support the sustainability of the subject villages but would also have the opportunity to support other nearby villages. This is a principle reflected at Paragraph 83 of the NPPF which encourages the location of housing where it will enhance or maintain the vitality of rural communities. This is echoed in the PPG relative to rural housing, as above. Equally, Paragraph 70 of the NPPF makes clear that small and medium sized sites can make an important contribution to meeting the housing requirement of an area and are often built up relatively quickly. Overall, the provision of additional housing, including affordable housing, will have a significant benefit for the community of Didmarton and the wider district.

We fundamentally disagree with the underlying approach to the need for residential development and the calculation of the number of sites which need to be allocated in the future plan 2026 to 2041. We believe that the strategy for house building in Cotswold District in the period 2026 to 2041 should be one of restraint. To do otherwise would be unsustainable. Because it is very attractive, people will pay premium prices to live here and commute out of the area to work. Conversely the difficulty in building sufficient affordable houses means that people who work in the area cannot afford to live in the area resulting in commuting into the area. These commuting patterns are directly contrary to the spirit and provisions of the new proposed new plan policies on Sustainable Development in particular SD1(h), SD2 (4), SD4 note 5a.4.6 and Climate Change Mitigation CC8 on sustainable transport. Were the Council to restrict the number of free market houses then it would be easier to leverage high proportions of affordable housing without increasing the total number of houses beyond the assessed need. In addition it is clear both from the plan and residents’ the reactions, such as at the open meeting at Moreton in the Marsh, that the area is running out of space for significant further development. The limitations of the National Landscape on the one hand and the propensity to flooding both near Morton and in the south of the district mean that there are limited opportunities for any major strategic sites. We therefore urge the Council to adopt the number required to only meet local need and to ensure that the plan policies set stringent criteria to be met. However far from painting a picture of restraint, the numbers in Local Plan Update show that the rate of permitting and building up to 2023 has been far too high leading to an excess of some 1000 dwellings over assessed need by end 2031. This excess is all for the commuter market. In effect the Cotswold District has been meeting the needs of neighbouring authorities. It is essential that this overbuilding be deducted from calculations of future housing need and, if possible, negotiate with neighbouring districts to take a corresponding increase in their housing requirements. Further, in the strategy the number of dwellings to be approved has been increased by 14% to allow for allocated sites dropping out. This allowance is around 1150 dwellings. In practice the demand for housing in the Cotswolds is so high that very few sites allocated fail to be developed. The total number of dwellings allocated up to 2023 which have dropped out is 95. (about 1.5%). This has been more than covered by windfall sites which have greatly exceeded estimates. We understand the prudence in identifying contingency sites however it is quite wrong that these be included and allocated in the plan. They are there to be brought forward if and when the allocated sites fall out. We suggest therefore that the Council notes these contingency sites and records them in a document separate from the Local Plan or Development Strategy such as the SHLAA. They can then be brought forward if any of the allocated sites is removed or delivers substantially fewer dwellings than expected. Using this approach the housing need would be the lower number of 6330 and ,after deducting the 5150 already identified, would give a need for yet to be identified sites for 1180 dwellings up to 2041 plus a contingency reserve of say up to 150 held elsewhere. This compares to the CDC top estimate of 3290 on sites yet to be allocated. We recommend using the lower number in allocating sites in the plan as it more accurately reflects the current best estimate of future need. Paragraph 9 of the NPPF is quite clear that local circumstances should be taken into account to reflect the local character and overall the emphasis is on meeting local need. There is no statement encouraging or setting a level of contingency reserve and certainly not 14%.

Summary 4.38. To summarise, Rosconn support a development strategy which focusses on dispersed growth across the Principal Settlements (Scenario 1) for the reasons identified above. It was noted above that strategic allocations are also likely to be needed, although there should not be an overreliance on these, as this would represent a high-risk approach, particularly given the Chesterton experience. Sufficient sites need to be allocated in sustainable locations in all Principal Settlements to complement any strategic allocations.

Scenario 8: Request neighbouring authority to deliver some of the housing need 4.37. This option is not supported by Rosconn and should only be used as a last resort, and there is no evidence that other districts would agree to accommodate it. It is contended that, in part through sufficient allocations in Principal Settlements, the housing need over the 2026- 2041 period can be met within the district.

Scenario 5: New settlement(s) & Scenario 6: New strategic site(s) 4.29. Both these scenarios are similar in that they would introduce new large-scale development in the district, in line with Paragraph 110(c) of the NPPF which states that opportunities for this should be realised. However, relying heavily on larger sites is a high-risk approach. Firstly, they have a longer lead-in time, which means that their contribution towards the housing supply would likely be in the latter part of the plan period, and possibly into the next. This is acknowledged by the Council in Paragraph 5.27 of the Vision, Objectives and Development Strategy Options Topic Paper, which also notes that they can be more complex to assemble and deliver. In addition, large amounts of new infrastructure must be provided for these types of development. 4.30. These issues have been experienced in the case of the Chesterton site, the strategic allocation in the current Local Plan. As discussed below, it has experienced slippages, and is continuing to do so, affecting the district’s housing land supply as a result. If too much of the supply depends on sites like this, and they experience delays, the Council risks underdelivering housing. Rosconn therefore contend that it is imperative for dispersed development in settlements across the district to form the majority of the housing supply. 4.31. Notwithstanding, given the shortfall in housing need for the 2026-2041 period identified above, the allocation of a large-scale development site would clearly make a significant contribution towards addressing this. 4.32. It would be challenging to identify a suitable location for a new settlement which would not have adverse impacts on the Cotswold National Landscape, as well as other potential environmental, social, and economic consequences which could bring it in conflict with Paragraph 8 of the NPPF. Due to the uncertainty surrounding this option, the IIA does not score it, and it appears that the Council have already discarded the idea since it is not identified as one of their preferred options. Rosconn agree that a new settlement would not be an appropriate or effective approach in Cotswold given the circumstances and landscape sensitivities which exist in this district. 4.33. Any new strategic site(s) should complement allocations dispersed across Principal Settlements which should form a greater proportion of the supply as the primary development strategy for the district.

Scenario 4: Village clusters 4.26. This approach would cluster small villages together. It would contribute towards meeting the aspirations of Paragraph 83 of the NPPF, which sets out that policies should identify opportunities for villages to grow and thrive. However, given its similarities to Scenario 3, in encouraging dispersed growth but in clusters of smaller settlements, many of the same points raised above apply. This option likewise scores poorly in the IIA for similar reasons, with mixed to negative effects against the themes and objectives. 4.27. In practice, the approach does not reflect human nature and how residents would likely behave. For example, even if some services and amenities are provided locally within the clusters, people are still likely to travel further afield to larger centres where more choice is available. 4.28. It is unclear, within both the consultation material and the IIA, which villages would be clustered together and how. This suggests that the strategy has not been adequately thought through at this early stage. We contend that settlements should continue to be treated in isolation, with growth focused in the most sustainable locations.

Scenario 3: Dispersed Growth 4.23. Despite its name, this strategy would seek to steer growth away from Principal Settlements to smaller villages, enabling a more even spread of development across the district. Rosconn support dispersed growth across Principal Settlements, rather than every village in the district. The appraisal findings in the IIA suggest that this is the arguably worst of the growth scenarios in terms of the themes and objectives identified. There is poor public transport and less infrastructure in smaller settlements (Healthy and Vital Communities), restrictions on the amount of housing which could be delivered, not least due to the Cotswold National Landscape. 4.24. Major development is unlikely to come forward within the National Landscape, in line with Paragraph 183 of the NPPF and Policy CE11 of the Cotswolds National Landscape Management Plan 2023-25, unless exceptional circumstances could be demonstrated, and the development would be in the public interest. With only low numbers of dwellings and no affordable homes potentially being provided on each site, it could be challenging to meet housing need and address the shortfall for the plan period. As a result, this scenario if selected, would need to be accompanied by others. 4.25. Rosconn support dispersed growth but across the Principal Settlements rather than all the district’s smaller villages. Notwithstanding, Rosconn would not expect to object to any allocations in these villages, nor windfall development, as this would still help to meet the district’s need and would align with principle of dispersed development. For the strategy in the new Local Plan, however, dispersed growth across the Principal Settlements should be the preferred strategy.

Scenario 2: Main Service Centre focus 4.20. The Main Service Centres are yet to be established, but the IIA suggests that they could comprise the likes of Cirencester, Bourton on the Water, and Moreton in Marsh. As existing Principal Settlements, they are already established as optimal towns/villages for additional development, as argued above. Main Service Centres likewise score highly in the IIA, given that they share a lot of the same characteristics. It is acknowledged that they have the greatest range of services and employment opportunities, and are often more accessible (for example, Moreton in Marsh has a train station). 4.21. Whilst Rosconn agree that the Main Service Centres should be focal points for development, it should not be restricted solely to these locations; whilst the majority may take place here, allocations and housing delivery should be provided across all Principal Settlements, ensuring a distributed spread across the district to meet local need in different parishes and to support the retention of services in smaller settlements. To reiterate, this will lessen impacts, such as on built heritage and landscape, in and around the Main Service Centres which may be more acute if they absorb a greater amount of development which could otherwise have occurred in comparatively smaller Principal Settlements. 4.22. By identifying Main Service Centres, this will risk discouraging a more dispersed approach to growth in sustainable Principal Settlements which are able to accommodate more housing. At the very least, the new plan should make clear that growth should still be focused on Principal Settlements as well, with site(s) allocated in each accordingly.

Scenario 1: Additional non-strategic site allocations in Principal Settlements 4.16. Rosconn are supportive of this development strategy. It forms Cotswold District’s existing approach in the adopted Local Plan, which means that it has already been found sound at examination. The evidence set out elsewhere in these representations (paragraph 3.37) also suggests it has been effective to a degree. The existing Principal Settlements comprise towns such as Moreton in Marsh and Stow on the Wold and larger villages including Bourton on the Water and Mickleton. Notwithstanding, it is noted that the Council will be reviewing the list of Principal Settlements as part of the next review, which means that some may have their status rescinded, whilst others may be added (see paragraph 1.8 of the Topic Paper). Notwithstanding, it is considered that all the existing Principal Settlements should retain their status, as the largest settlements which remain sustainable locations for further growth. Indeed, this scenario performs exceptionally well against all the themes within the framework set out in the Integrated Impact Assessment (IIA) (February 2024), which is essentially the sustainability appraisal produced for the current round of consultation. There are significant positive effects associated with focusing growth at these settlements, as they offer a wide range of services (Healthy and Vital Communities); have high levels of accessibility, with better public transport provision, which could encourage lower car use (Housing, Transport, and Climate Change); and they often offer a wide range of employment opportunities (Economy and Employment). New development can support service provision within Principal Settlements. Paragraph 97 of the NPPF encourages an integrated approach to delivering housing and economic uses, as well as community facilities and services. A focus on Scenario 1, in locating new housing in the areas where there are greater employment opportunities, would therefore be consistent with national policy. 4.18. Crucially, a focus on Principal Settlements across the district will allow for a somewhat dispersed approach to growth across seventeen settlements which are sustainable and capable of accommodating more housing, as established throughout the IIA. This approach would at least lessen the amount of development which the larger settlements, such as Cirencester, Tetbury, and Moreton in Marsh, need to absorb, minimising potential impacts on the historic environment and the Cotswolds National Landscape, which may otherwise occur here. 4.19. The Council are therefore urged to allocate sufficient non-strategic sites across all Principal Settlements, with the list of 17 to remain unchanged. This strategy is already tried and tested, and has proved effective, having been found sound at examination. Principal Settlements are the most sustainable locations for growth in the Cotswold District and they should play a significant role in helping to meet the district’s housing need over the 2026 – 2046 period.

Housing Supply to 2041 4.4. Paragraph 3.20 of the Topic Paper suggests that a supply of 5,150 dwellings has already been identified for the 2026-2041 period, as set out within Appendix 1 and 3 of the Housing Land Supply Report (August 2023). Against the 7,400-dwelling requirement without the flexibility, they identify a shortfall of 2,250 dwellings or 1,180 dwellings if over-delivery is deducted from this. However, with our recommended revised need figure of 7,830 dwellings, we identify a shortfall of at least 2,680 dwellings or 1,610 dwellings deducting over-delivery With the 14% flexibility, the shortfall is as great as 3,476 dwellings. However, in reality, the shortfalls may be more severe than this, as outlined below. These shortfalls must be addressed to ensure a plan which is positively prepared and consistent with national policy, as Paragraph 8 of the NPPF states that a sufficient number of homes to meet the needs of present and future generations should be provided. 4.6. The Council have rounded the figures up within the Topic Paper, and the two sites added in the December 2023 addendum to Housing Land Supply report would only “likely” provide 130 dwellings, as acknowledged in paragraph 3.19. This figure may be lower in reality; indeed, we note that planning permission has only been granted for 87 dwellings (ref: 22/03770/OUT) on one of the sites to date, with the other, in Tetbury, having issues with access which has affected its deliverability. 4.7. In addition, the Council assume that 2,070 windfall dwellings will be delivered, based on data in Appendix 1 of the Housing Land Supply Report. At 40%, this constitutes a significant proportion of the identified supply. Appendix 1 reveals that the windfall allowance will be 138 from 2026/2027 onwards. The Council suggest that this will remain at 138 per year to 2041, providing the 2,070 total. However, in practice, this is figure highly unlikely to remain constant; indeed, a high-level analysis of recent monitoring reports indicates that this already varies year-to-year. Table 1 of the Housing Land Supply Report reveals that windfall delivery over the past decade has ranged from 76 to 208 dwellings. It is considered that there is an over-reliance on windfall sites. If significantly fewer windfall dwellings are provided, the shortfall will be more severe. Sufficient land needs to be allocated for housing to provide flexibility in this respect. 4.9. The largest proportion of new housing in the supply, at 43%, is to be provided at Chesterton Farm, Cirencester, which is a strategic allocation in the adopted plan. Planning permission for 2,350 dwellings on this site was granted in April 2019, (ref. 16/00054/OUT), and the scheme is currently being built out. With regards to deliverability, the Inspector of the Local Plan initially anticipated that 1,800 dwellings would be completed by March 2031. However, according to the Housing Land Supply Report (August 2023), only 1,043 dwellings are now expected to be completed across the site by this date, with the remainder (1,307) being delivered after 2031. Thus, it can be observed that the number of completions now expected by then is 757 lower than envisaged by the EIP Inspector. This is a slippage of 169 dwellings in a single year, with the July 2022 Housing Land Supply Report having stated that 1,212 dwellings would be delivered by 2031. According to Bathurst Development Limited, in Appendix 3 of the report, 2,217 dwellings will be delivered by 2041. Relying on a single strategic allocation is a fairly highrisk approach, as demonstrated within the existing plan period, as the cumulative total of any further slippages and/or issues which may arise could potentially threaten the scheme’s ability to successfully deliver all 2,217 dwellings by 2041. 4.11. The remainder of the supply constitutes 528 dwellings on sites with planning permission, and 203 on the adopted non-strategic site allocations. However, the latter are only “expected”, suggesting a lack of certainty that all sites be able to be developed or brought forward. In addition, the dwellings on sites which already benefit from planning consent may be completed prior to 2026, which means that they cannot directly contribute towards meeting the 7,830-dwelling need for the period 2026 to 2041. Whilst it is difficult to quantify how much greater the shortfall could be, given the uncertainty surrounding the windfall allowance and deliverability of Chesterton over the 15-year period, as well as the timescales and deliverability of other sites, it is possible that land for several hundred additional dwellings may need to be identified, to provide additional flexibility at the very least. 4.13. With a shortfall of at a minimum of 2,680 up to 3,476 dwellings, additional sites must be allocated for housing in the Cotswold District Local Plan 2026 – 2041, to boost the supply of homes, and provide a sufficient number to meet local need as required by Paragraphs 8 and 61 of the NPPF.

Housing Numbers 4.2. Paragraphs 3.33 – 3.39 have considered the district’s housing need and requirements over the current plan period, to 2031. This has already established that there are no exceptional circumstances which apply to Cotswold District, and therefore housing need must be calculated using the Standard Method, in line with Paragraph 61 of the NPPF. Based on the current Standard Method calculation of 493 dpa, the Vision, Objectives and Development Strategy Options Topic Paper identifies a need of 7,400 dwellings between the next plan period of 2026 - 2041. 4.3. However, as stated in Paragraph 67 and established above, this is only a starting point, and the requirement may, in fact, be higher. Due to inward migration, economic growth rates, and an increasingly high affordability ratio, it is contended that this is the case in Cotswold District. Taking this into account, a revised figure of at least 522 dpa was earlier suggested as a more appropriate requirement for the district to work towards. Over the fifteen-year plan period, this equates to a requirement of 7,830 dwellings. If a 14% degree of flexibility is added, as suggested in the Topic Paper as an option at paragraph 3.21, this figure would increase to 8,926 dwellings on the basis of 522 dpa.

Vision and Objectives 3.5. Rosconn are broadly supportive of the vision and objectives as drafted. The proposed revisions are set out within the Council’s Vision, Objectives and Development Strategy Options Topic Paper. The vision as drafted will include reference to responding to the climate crisis and taking account of nature recovery, which aligns with Paragraph 158 of the NPPF. The plan’s objectives expand on this, with additions making reference to delivering biodiversity net gains, climate adaptation and mitigation, providing affordable homes, a greater emphasis on supporting positive health outcomes, and supporting sustainable travel. It is considered that this all aligns with national policy, including Paragraphs 8, 20, 96, 157, and 158 of the NPPF. 3.6. Notwithstanding, the inclusion of an obligation for development to be zero carbon is not justified and is inconsistent with national policy which does not set such a requirement. It is important that the Development Plan's response to climate change is realistic and consistent with national legislation and policy provisions, setting standards within a timetable which is collectively understood and deliverable across the development industry. As such, net zero development should be a longer-term aspiration as in practice schemes will not be able to universally achieve this from the point of adoption (expected in around two years). This is discussed in more detail below. 3.7. The wider vision and objectives have already been found sound as part of the Local Plan’s examination, and it is not considered that these additions would otherwise change this given that they are consistent with national policy. Summary of the amendments required 3.8. The stipulation that new development needs to be zero carbon is not justified as this is not referenced in national planning policy and is unlikely to be achievable from the point of adoption.

Plan Period 3.1. Presently, the proposed New Local Plan period, as outlined, runs from 2026 until 2041. Paragraph 22 of the NPPF requires strategic policies should look ahead over a minimum 15- year period from the date of adoption. 3.2. The latest Local Development Scheme of the Council was published in January 2024 and suggests that the New Local Plan will be submitted for examination in Q2 2025 and adopted within c.15 months in Q3 2026. This is considered unrealistic, especially given the significant issues to be addressed in Cotswold District owing to its constraints and the current pursuit of what we consider to be an insufficient amount of housing. Indeed, since the NPPF was introduced in March 2012, the average time taken from submission to adoption of new local plans has been 1.68 years. 3.3. This has remained broadly consistent with those plans submitted between March 2012 and January 2019 under the transitional arrangements of paragraph 220 of the NPPF having taken 1.68 years on average and those submitted since having taken 1.65 years. Assuming that the Local Plan is submitted in Q2 as envisaged by the Local Development Scheme and that following this the examination takes 1.68 or 1.65 years, the Local Plan wouldn’t be adopted until the first part of 2027 at the very earliest. 3.4. Given the uncertainties around the timing of plan adoption, which include the prospect of a general election and change in government within the next 10 months, to accord with national policy and look ahead for 15 years from adoption we suggest the New Local Plan will need to cover the period to 2043 as an absolute minimum.

Summary 4.38. To summarise, Rosconn support a development strategy which focusses on dispersed growth across the Principal Settlements (Scenario 1) for the reasons identified above. It was noted above that strategic allocations may also be needed, although there should not be an overreliance on these, as this would represent a high-risk approach, particularly given the Chesterton experience. Sufficient sites need to be allocated in sustainable locations in all Principal Settlements to complement any strategic allocations.

Scenario 8: Request neighbouring authority to deliver some of the housing need 4.37. This option is not supported by Rosconn and should only be used as a last resort, and there is no evidence that other districts would agree to accommodate it. It is contended that, in part through sufficient allocations in Principal Settlements, the housing need over the 2026-2041 period can be met within the district.

Scenario 7: Focus growth around transport nodes 4.34. This strategy would concentrate growth in those parts of the district which are most accessible, with the best public transport links. The consultation document essentially suggests that this would mean focusing growth in Moreton in Marsh, as it has a train station. As a Principal Settlement, Rosconn do not object to further development in the town, and the IIA scores this option positively in terms of Healthy and Vital Communities, Housing, Economy, Equalities, Transport, and Climate Change. 4.35. However, the need for a strategy specifically focused on transport is questionable and may reduce the impetus to deliver public transport improvements across the whole district, in other Principal Settlements. In addition, this strategy would place increased pressure on Moreton to provide an even greater number of homes, when it has already experienced substantial growth relative to other Principal Settlements in recent years. It should also be noted that good transport links alone do not necessarily mean that a settlement is a more appropriate place for housing than another one, as there are other important factors to consider, not least access to employment and services, which are available in other Principal Settlements. 4.36. Whilst the objective is sustainable development, focusing a strategy on just one mode of transport, namely rail travel, cannot be correct. Therefore, Rosconn would object to a development scenario which places such as a strong emphasis on transport nodes, which would increase pressure on one specific town, rather than distributing this across the district.

Scenario 5: New settlement(s) & Scenario 6: New strategic site(s) 4.29. Both these scenarios are similar in that they would introduce new large-scale development in the district, in line with Paragraph 110(c) of the NPPF which states that opportunities for this should be realised. However, relying on larger sites on a high-risk approach. Firstly, they have a longer lead-in time, which means that their contribution towards the housing supply would likely be in the latter part of the plan period, and possibly into the next. This is acknowledged by the Council in Paragraph 5.27 of the Vision, Objectives and Development Strategy Options Topic Paper, which also notes that they can be more complex to assemble and deliver. In addition, large amounts of new infrastructure must be provided for these types of development. 4.30. These issues have been experienced in the case of the Chesterton site, the strategic allocation in the current Local Plan. As discussed below, it has experienced slippages, and is continuing to do so, affecting the district’s housing land supply as a result. If too much of the supply depends on sites like this, and they experience delays, the Council risks underdelivering housing. Rosconn therefore contend that it is imperative for dispersed development in settlements across the district to form the majority of the housing supply. 4.31. Notwithstanding, given the shortfall in housing need for the 2026-2041 period identified above, the allocation of a large-scale development site would clearly make a significant contribution towards addressing this. 4.32. It would be challenging to identify a suitable location for a new settlement which would not have adverse impacts on the Cotswold National Landscape, as well as other potential environmental, social, and economic consequences which could bring it in conflict with Paragraph 8 of the NPPF. Due to the uncertainty surrounding this option, the IIA does not score it, and it appears that the Council have already discarded the idea since it is not identified as one of their preferred options. Rosconn agree that a new settlement would not be an appropriate or effective approach in Cotswold given the circumstances and landscape sensitivities which exist in this district. 4.33. Any new strategic site(s) should complement allocations dispersed across Principal Settlements which should form a greater proportion of the supply as the primary development strategy for the district.

Scenario 5: New settlement(s) & Scenario 6: New strategic site(s) 4.29. Both these scenarios are similar in that they would introduce new large-scale development in the district, in line with Paragraph 110(c) of the NPPF which states that opportunities for this should be realised. However, relying on larger sites on a high-risk approach. Firstly, they have a longer lead-in time, which means that their contribution towards the housing supply would likely be in the latter part of the plan period, and possibly into the next. This is acknowledged by the Council in Paragraph 5.27 of the Vision, Objectives and Development Strategy Options Topic Paper, which also notes that they can be more complex to assemble and deliver. In addition, large amounts of new infrastructure must be provided for these types of development. 4.30. These issues have been experienced in the case of the Chesterton site, the strategic allocation in the current Local Plan. As discussed below, it has experienced slippages, and is continuing to do so, affecting the district’s housing land supply as a result. If too much of the supply depends on sites like this, and they experience delays, the Council risks underdelivering housing. Rosconn therefore contend that it is imperative for dispersed development in settlements across the district to form the majority of the housing supply. 4.31. Notwithstanding, given the shortfall in housing need for the 2026-2041 period identified above, the allocation of a large-scale development site would clearly make a significant contribution towards addressing this. 4.32. It would be challenging to identify a suitable location for a new settlement which would not have adverse impacts on the Cotswold National Landscape, as well as other potential environmental, social, and economic consequences which could bring it in conflict with Paragraph 8 of the NPPF. Due to the uncertainty surrounding this option, the IIA does not score it, and it appears that the Council have already discarded the idea since it is not identified as one of their preferred options. Rosconn agree that a new settlement would not be an appropriate or effective approach in Cotswold given the circumstances and landscape sensitivities which exist in this district. 4.33. Any new strategic site(s) should complement allocations dispersed across Principal Settlements which should form a greater proportion of the supply as the primary development strategy for the district.

Scenario 4: Village clusters 4.26. This approach would cluster small villages together. It would contribute towards meeting the aspirations of Paragraph 83 of the NPPF, which sets out that policies should identify opportunities for villages to grow and thrive. However, given its similarities to Scenario 3, in encouraging dispersed growth but in clusters of smaller settlements, many of the same points raised above apply. This option likewise scores poorly in the IIA for similar reasons, with mixed to negative effects against the themes and objectives. 4.27. In practice, the approach does not reflect human nature and how residents would likely behave. For example, even if some services and amenities are provided locally within the clusters, people are still likely to travel further afield to larger centres where more choice is available. 4.28. It is unclear, within both the consultation material and the IIA, which villages would be clustered together and how. This suggests that the strategy has not been adequately thought through at this early stage. We contend that settlements should continue to be treated in isolation, with growth focused in the most sustainable locations.

Scenario 3: Dispersed Growth 4.23. Despite its name, this strategy would seek to steer growth away from Principal Settlements to smaller villages, enabling a more even spread of development across the district. Rosconn support dispersed growth across Principal Settlements, rather than every village in the district. The appraisal findings in the IIA suggest that this is the arguably worst of the growth scenarios in terms of the themes and objectives identified. There is poor public transport and less infrastructure in smaller settlements (Healthy and Vital Communities), restrictions on the amount of housing which could be delivered, not least due to the Cotswold National Landscape. 4.24. Major development is unlikely to come forward within the National Landscape, in line with Paragraph 183 of the NPPF and Policy CE11 of the Cotswolds National Landscape Management Plan 2023-25, unless exceptional circumstances could be demonstrated, and the development would be in the public interest. With only low numbers of dwellings and no affordable homes potentially being provided on each site, it could be challenging to meet housing need and address the shortfall for the plan period. As a result, this scenario, if selected, would need to be accompanied by others. 4.25. Rosconn support dispersed growth but across the Principal Settlements rather than all the district’s smaller villages. Notwithstanding, Rosconn would not expect to object to any allocations in these villages, nor windfall development, as this would still help to meet the district’s need and would align with principle of dispersed development. For the strategy in the new Local Plan, however, dispersed growth across the Principal Settlements should be the preferred strategy.

Scenario 2: Main Service Centre focus 4.20. The Main Service Centres are yet to be established, but the IIA suggests that they could comprise the likes of Cirencester, Bourton on the Water, and Moreton in Marsh. As existing Principal Settlements, they are already established as optimal towns/villages for additional development, as argued above. Main Service Centres likewise score highly in the IIA, given that they share a lot of the same characteristics. It is acknowledged that they have the greatest range of services and employment opportunities, and are often more accessible (for example, Moreton in Marsh has a train station). 4.21. Whilst Rosconn agree that the Main Service Centres should be focal points for development, it should not be restricted solely to these locations; whilst the majority may take place here, allocations and housing delivery should be provided across all Principal Settlements, ensuring a distributed spread across the district to meet local need in different parishes and to support the retention of services in smaller settlements. To reiterate, this will lessen impacts, such as on built heritage and landscape, in and around the Main Service Centres which may be more acute if they absorb a greater amount of development which could otherwise have occurred in comparatively smaller Principal Settlements. 4.22. By identifying Main Service Centres, this will risk discouraging a more dispersed approach to growth in sustainable Principal Settlements which are able to accommodate more housing. At the very least, the new plan should make clear that growth should still be focused in Principal Settlements as well, with site(s) allocated in each accordingly.

Scenario 1: Additional non-strategic site allocations in Principal Settlements 4.16. Rosconn are supportive of this development strategy. It forms Cotswold District’s existing approach in the adopted Local Plan, which means that it has already been found sound at examination. The evidence set out elsewhere in these representations (paragraph 3.37) also suggests it has been effective to a degree. The existing Principal Settlements comprise towns such as Moreton in Marsh and Stow on the Wold and larger villages including Bourton on the Water and Mickleton. Notwithstanding, it is noted that the Council will be reviewing the list of Principal Settlements as part of the next review, which means that some may have their status rescinded, whilst others may be added (see paragraph 1.8 of the Topic Paper). Notwithstanding, it is considered that all the existing Principal Settlements should retain their status, as the largest settlements which remain sustainable locations for further growth. 4.17. Indeed, this scenario performs exceptionally well against all the themes within the framework set out in the Integrated Impact Assessment (IIA) (February 2024), which is essentially the sustainability appraisal produced for the current round of consultation. There are significant positive effects associated with focusing growth at these settlements, as they offer a wide range of services (Healthy and Vital Communities); have high levels of accessibility, with better public transport provision, which could encourage lower car use (Housing, Transport, and Climate Change); and they often offer a wide range of employment opportunities (Economy and Employment). New development can support service provision within Principal Settlements. Paragraph 97 of the NPPF encourages an integrated approach to delivering housing and economic uses, as well as community facilities and services. A focus on Scenario 1, in locating new housing in the areas where there are greater employment opportunities, would therefore be consistent with national policy. 4.18. Crucially, a focus on Principal Settlements across the district will allow for a somewhat dispersed approach to growth across seventeen settlements which are sustainable and capable of accommodating more housing, as established throughout the IIA. This approach would at least lessen the amount of development which the larger settlements, such as Cirencester, Tetbury, and Moreton in Marsh, need to absorb, minimising potential impacts on the historic environment and the Cotswolds National Landscape, which may otherwise occur here. 4.19. The Council are therefore urged to allocate sufficient non-strategic sites across all Principal Settlements, with the list of 17 to remain unchanged. This strategy is already tried and tested, and has proved effective, having been found sound at examination. Principal Settlements are the most sustainable locations for growth in the Cotswolds and they should play a significant role in helping to meet the district’s housing need over the 2026 – 2046 period.

Development Strategy Options 4.14. The Vision, Objectives and Development Strategy Options Topic Paper goes on to consider the various growth options within the district and the ways in which additional housing can be delivered. Eight development strategy options are being considered for the district: • Scenario 1: Additional non-strategic site allocations in Principal Settlements • Scenario 2: Main Service Centre focus • Scenario 3: Dispersed growth • Scenario 4: Village clusters • Scenario 5: New settlement(s) • Scenario 6: New strategic site(s) • Scenario 7: Focus growth around transport nodes • Scenario 8: Request neighbouring authority to deliver some of the housing need 4.15. The Council have indicated that, at this stage, a combination of the some of the above approaches is preferred, namely Scenarios 1 (Principal Settlements), 2 (Main Service Centres), 6 (New strategic site(s), and 7 (transport nodes). Comments on each of the options and their suitability are provided below.

Housing Supply to 2041 4.4. Paragraph 3.20 of the Topic Paper suggests that a supply of 5,150 dwellings has already been identified for the 2026-2041 period, as set out within Appendix 1 and 3 of the Housing Land Supply Report (August 2023). Against the 7,400-dwelling requirement without the flexibility, they identify a shortfall of 2,250 dwellings or 1,180 dwellings if over-delivery is deducted from this. However, with our recommended revised need figure of 7,830 dwellings, we identify a shortfall of at least 2,680 dwellings or 1,610 dwellings deducting over-delivery. With the 14% flexibility, the shortfall is as great as 3,476 dwellings. However, in reality, the shortfalls may be more severe than this, as outlined below. These shortfalls must be addressed to ensure a plan which is positively prepared and consistent with national policy, as Paragraph 8 of the NPPF states that a sufficient number of homes to meet the needs of present and future generations should be provided. 4.6. The Council have rounded the figures up within the Topic Paper, and the two sites added in the December 2023 addendum to Housing Land Supply report would only “likely” provide 130 dwellings, as acknowledged in paragraph 3.19. This figure may be lower in reality; indeed, we note that planning permission has only been granted for 87 dwellings (ref: 22/03770/OUT) on one of the sites to date, with the other, in Tetbury, having issues with access which has affected its deliverability. 4.7. In addition, the Council assume that 2,070 windfall dwellings will be delivered, based on data in Appendix 1 of the Housing Land Supply Report. At 40%, this constitutes a significant proportion of the identified supply. Appendix 1 reveals that the windfall allowance will be 138 from 2026/2027 onwards. The Council suggest that this will remain at 138 per year to 2041, providing the 2,070 total. 4.8. However, in practice, this figure is highly unlikely to remain constant; indeed, a high-level analysis of recent monitoring reports indicates that this already varies year-to-year. Table 1 of the Housing Land Supply Report reveals that windfall delivery over the past decade has ranged from 76 to 208 dwellings. It is considered that there is an over-reliance on windfall sites. If significantly fewer windfall dwellings are provided, the shortfall will be more severe. Sufficient land needs to be allocated for housing to provide flexibility in this respect. 4.9. The largest proportion of new housing in the supply, at 43%, is to be provided at Chesterton Farm, Cirencester, which is a strategic allocation in the adopted plan. Planning permission for 2,350 dwellings on this site was granted in April 2019, (ref. 16/00054/OUT), and the scheme is currently being built out. With regards to deliverability, the Inspector of the Local Plan initially anticipated that 1,800 dwellings would be completed by March 2031. However, according to the Housing Land Supply Report (August 2023), only 1,043 dwellings are now expected to be completed across the site by this date, with the remainder (1,307) being delivered after 2031. Thus, it can be observed that the number of completions now expected by then is 757 lower than envisaged by the EIP Inspector. This is a slippage of 169 dwellings in a single year, with the July 2022 Housing Land Supply Report having stated that 1,212 dwellings would be delivered by 2031. According to Bathurst Development Limited, in Appendix 3 of the report, 2,217 dwellings will be delivered by 2041. Relying on a single strategic allocation is a fairly high-risk approach, as demonstrated within the existing plan period, as the cumulative total of any further slippages and/or issues which may arise could potentially threaten the scheme’s ability to successfully deliver all 2,217 dwellings by 2041. 4.11. The remainder of the supply constitutes 528 dwellings on sites with planning permission, and 203 on the adopted non-strategic site allocations. However, the latter are only “expected”, suggesting a lack of certainty that all sites be able to be developed or brought forward. In addition, the dwellings on sites which already benefit from planning consent may be completed prior to 2026, which means that they cannot directly contribute towards meeting the 7,830-dwelling need for the period 2026 to 2041. 4.12. Whilst it is difficult to quantify how much greater the shortfall could be, given the uncertainty surrounding the windfall allowance and deliverability of Chesterton over the 15-year period, as well as the timescales and deliverability of other sites, it is possible that land for several hundred additional dwellings may need to be identified, to provide additional flexibility at the very least. With a shortfall of at a minimum of 2,680 up to 3,476 dwellings, additional sites must be allocated for housing in the Cotswold District Local Plan 2026 – 2041, to boost the supply of homes, and provide a sufficient number to meet local need as required by Paragraphs 8 and 61 of the NPPF.

Housing Numbers 4.2. Paragraphs 3.33 – 3.39 have considered the district’s housing need and requirements over the current plan period, to 2031. This has already established that there are no exceptional circumstances which apply to Cotswold District, and therefore housing need must be calculated using the Standard Method, in line with Paragraph 61 of the NPPF. Based on the current Standard Method calculation of 493 dpa, the Vision, Objectives and Development Strategy Options Topic Paper identifies a need of 7,400 dwellings between the next plan period of 2026 - 2041. 4.3. However, as stated in Paragraph 67 and established above, this is only a starting point, and the requirement may, in fact, be higher. Due to inward migration, economic growth rates, and an increasingly high affordability ratio, it is contended that this is the case in Cotswold District. Taking this into account, a revised figure of at least 522 dpa was earlier suggested as a more appropriate requirement for the district to work towards. Over the fifteen-year plan period, this equates to a requirement of 7,830 dwellings. If a 14% degree of flexibility is added, as suggested in the Topic Paper as an option at paragraph 3.21, this figure would increase to 8,926 dwellings on the basis of 522 dpa.

Vision and Objectives 3.5. Rosconn are broadly supportive of the vision and objectives as drafted. The proposed revisions are set out within the Council’s Vision, Objectives and Development Strategy Options Topic Paper. The vision as drafted will include reference to responding to the climate crisis and taking account of nature recovery, which aligns with Paragraph 158 of the NPPF. The plan’s objectives expand on this, with additions making reference to delivering biodiversity. net gains, climate adaptation and mitigation, providing affordable homes, a greater emphasis on supporting positive health outcomes, and supporting sustainable travel. It is considered that this all aligns with national policy, including Paragraphs 8, 20, 96, 157, and 158 of the NPPF. 3.6. Notwithstanding, the inclusion of an obligation for development to be zero carbon is not justified and is inconsistent with national policy which does not set such a requirement. It is important that the Development Plan's response to climate change is realistic and consistent with national legislation and policy provisions, setting standards within a timetable which is collectively understood and deliverable across the development industry. As such, net zero development should be a longer-term aspiration as in practice schemes will not be able to universally achieve this from the point of adoption (expected in around two years). This is discussed in more detail below. 3.7. The wider vision and objectives have already been found sound as part of the Local Plan’s examination, and it is not considered that these additions would otherwise change this given that they are consistent with national policy. Summary of the amendments required 3.8. The stipulation that new development needs to be zero carbon is not justified as this is not referenced in national planning policy and is unlikely to be achievable from the point of adoption.

Plan Period 3.1. Presently, the proposed New Local Plan period, as outlined, runs from 2026 until 2041. Paragraph 22 of the NPPF requires strategic policies should look ahead over a minimum 15-year period from the date of adoption. 3.2. The latest Local Development Scheme of the Council was published in January 2024 and suggests that the New Local Plan will be submitted for examination in Q2 2025 and adopted within c.15 months in Q3 2026. This is considered unrealistic, especially given the significant issues to be addressed in Cotswold District owing to its constraints and the current pursuit of what we consider to be an insufficient amount of housing. Indeed, since the NPPF was introduced in March 2012, the average time taken from submission to adoption of new local plans has been 1.68 years. 3.3. This has remained broadly consistent with those plans submitted between March 2012 and January 2019 under the transitional arrangements of paragraph 220 of the NPPF having taken 1.68 years on average and those submitted since having taken 1.65 years. Assuming that the Local Plan is submitted in Q2 as envisaged by the Local Development Scheme and that following this the examination takes 1.68 or 1.65 years, the Local Plan wouldn’t be adopted until the first part of 2027 at the very earliest. 3.4. Given the uncertainties around the timing of plan adoption, which include the prospect of a general election and change in government within the next 10 months, to accord with national policy and look ahead for 15 years from adoption we suggest the New Local Plan will need to cover the period to 2043 as an absolute minimum.

Stantonbury Building and Development Company (Stantonbury) support the proposals for further housing allocations to help meet the housing requirement to 2041. The number of dwellings to be allocated in the plan should be expressed as minimum figures. This is to help ensure a continuous supply of both market and affordable housing and in the context of the NPPF requirement for Local Plans to be positively prepared (Paragraph 35, NPPF). The adopted Local Plan includes 14% more housing over the housing requirement to provide flexibility and the continuation of this sensible approach to housing delivery is supported. The Local Plan consultation sets out 8 different development scenarios. It is recognised that the preferred strategy is a combination of Scenario 1 (additional non strategic site allocations) Scenario 2 (main service centre focus) Scenario 6: (New Strategic Site) Scenario 7 (Focus growth around transport nodes). Whilst this approach to the development strategy keeps many options open to identifying sites to deliver the allocations, it is not clear what the mix of scenarios would be and what the priorities would be. For example, it is not clear what constituents a strategic site (i.e what size) and what the intention is for the mix of strategic and non strategic sites. The next stage in the process is key to understanding this and Stantonbury reserve the right to comment further. Whilst a relatively large number of Principal Settlements have been identified, Cotswold District does not have cities or a number of very large towns which would ordinarily be the location for large strategic sites. The adopted Local Plan’s development strategy principally allocates development on non-strategic site allocations at Principal Settlements. There are no changes in circumstances since the Local Plan was adopted (in 2018) which would suggest a need to change this approach. Indeed, as this is a local plan update, rather that a new local plan, it would suggest that the existing strategy should be followed, with new allocations defined which accord with that. The approach to focusing allocations at Principal Settlements is supported. Principal Settlements have been recognised as the most sustainable locations within the district and are thus suitable for development. Proportional percentage increases to settlements (subject to suitability of sites), as per the adopted strategy, would seem to be a logical starting point for allocations. However, in the interests of increasing sustainability of settlements and identifying the most appropriate sites for development, further allocations within or adjacent to a settlement where the proportional percentage increase is exceeded should not be dismissed if the opportunity exists to deliver sustainable development. Stantonbury have interests in a number of sites which surround the settlement of Blockley. Blockley is designated as a Principal Settlement in the adopted Local Plan and should continue to be considered as an appropriate location for sustainable growth. It is acknowledged that the Council intend to review the designation of Principal Settlements as part of the update to the Local Plan, and we await to see how this will be undertaken. However, with the designation of Principal Settlements and the allocation of sites, it should be considered how additional development can help to maintain the sustainability of settlements, or make settlements more sustainable. For example, by maintaining/increasing populations to support existing/better facilities or services and providing more affordable housing. The attached plan (4471-1-001A) shows the range of sites Stantonbury have have interests in around Blockley which could come forward for housing. Depending on the number allocated to Blockley this could be a single site, all sites to capacity, or smaller developments on each site which could deliver the requirement for Blockley between them. This approach means the impacts of development can be mitigated with more sympathetic, organic development of the settlement being brought forward, but with a strategic overall approach and delivery. All 5 sites have been submitted to the Call for Sites process, and further, more in depth work will be needed to be undertaken to inform the next stages of the Local Plan. However, the sites outlined present varied opportunities for development on the edge of Blockley. Some of the boundaries of the sites are not clearly defined and can be subject to change - there is potential for these sites to be larger or smaller depending on the type and size of development required and the amount of ecology or landscape mitigation needed. One of the sites is included with the SHELAA already (BK1A and BK1B) and it is noted that this was discounted from consideration due to impact on the Conservation Area and AONB. However, it is considered that these issues could be overcome with sensitive development and thus the site should be reconsidered and subject to further more in depth assessment. The Integrated Impact Assessment (IIA) for the Cotswold Local Plan Update has also undertaken a “Points of the Compass” Appraisal of the main settlements (including Blockley) and identifies broad area assessments surrounding the town. This indicates that some of the sites identified are located within a wider groundwater protection zone. It should be noted, that the sites are greenfield with no known contamination and development could be delivered on them without any impact on groundwater. Whilst the wider studies of the area are useful, when assessing a site for development, it is important to consider each site individually rather than ruling out certain sites based on wider area assessments. Smaller development within larger areas with constraints may be feasible, not lead to wider issues, and can deliver other benefits to the area.

Proposed New Development Strategy The Vision, Objectives and Development Strategy Options Topic Paper explains that eight development strategy options have been identified to accommodate additional development up to 2041, but a hybrid of several of the development strategy scenarios is proposed (i.e. Scenarios 1, 2, 6 and 7). The preferred development strategy would continue the adopted strategy of identifying Principal Settlements and allocating land for different types of development in these locations. However, the Topic Paper goes on to state that it anticipated that the remaining need for additional development up to 2041 (beyond existing commitments and windfalls) could be delivered by additional non-strategic site allocations in accordance with Scenarios 1, 2, 6 and 7. It is agreed that the proposed combination of development scenarios, which would include the allocation of non-strategic sites outside existing development boundaries of Principal Settlements, would result in a sustainable development strategy, which the land at South Cerney could contribute towards. The site [call for site submission] is therefore considered suitable for residential development due to its location and ability to positively contribute towards the Development Strategy of the Local Plan.

Richborough consider that the Council should be undertaking a full review of the extant Cotswold District Local Plan (2011 to 2031) Local Plan to enable for proper planning for a period of 15-years after the adoption of the new Local Plan which may well be the year 2041. 4. A full review of the Local Plan, as advocated by Richborough, is consistent with the National Planning Policy Framework (the Framework) where strategic policies should look ahead over a minimum 15-year period from adoption, to anticipate and respond to long-term requirements and opportunities. The current partial updated Local Plan would still only have an end date of 2031 which, based upon the Local Development Scheme (LDS - January 2024), would be a plan period of less than 5-years. 5. Given the LDS indicates the same timetable for preparing the partial updating and the preparation of the Local plan review (i.e. adoption Q3 2026) it appears to Richborough that a lot of time and wasted resources will be incurred by the Council and the community in producing 2 Local Plans. 6. Further, the partial update is out of kilter with the neighbouring local planning authorities who are reviewing their plans for a longer time horizon. The approach is also out of kilter with the Gloucestershire Local Transport Plan (2020 – 2041).

The Topic Paper outlines the Council’s intention to build upon the existing vision and objectives within the adopted local plan. The updated Vision is supported and the emphasis on responding to the climate crisis and supporting nature recovery are welcomed. Regarding the updated objectives, the proposed changes are generally supported. However, updates to Objective 6 raise concerns regarding the intended scope of the local plan. As outlined previously in this representation, the Government is taking forward a national approach via the Future Homes Standard which will deliver a national standard for building, through building regulations, to achieve net zero carbon in construction. To reflect this approach, it is recommended Objective 6a is amended as follows: “Supporting new development to be net zero carbon and supporting the sympathetic retrofit of historic buildings.”

In respect of the growth scenarios presented as part of this consultation, it is considered that individually none of the scenarios will deliver suitable growth to support and sustain existing communities across the District. It is important to ensure the overarching growth strategy for the new local plan includes sufficient flexibility to adapt to changes during the plan period. Individually the proposed approaches are considered too restrictive, potentially preventing sustainable development coming forward and undermining the Council’s ability to demonstrate a robust housing supply and sustain existing communities. This is acknowledged by the Council which promotes a mix of scenarios 1, 2, 6 and 7 to deliver an appropriate growth strategy up to 2041. The scenarios supported by the Council include: • Scenario 1: Additional non-strategic site allocations, • Scenario 2: Main Service Centre Focus • Scenario 6: New strategic site(s), • Scenario 7: Focus growth around transport nodes. This approach is broadly supported noting that Mickleton would be considered an appropriate location for growth under the emerging preferred strategy. Mickleton is a settlement identified within the current adopted Local Plan as a ‘Principal Settlement’. The need identified in the Role and Function of Settlements Study 2012 to boost Mickleton’s ‘economically active population to help support the current employment role and maintain and support the community services function’ is still considered to be relevant and necessary. Additional market and affordable housing which provides a mix of housing types will help bring economically active people to the settlement, further supporting its role as a ‘Principal Settlement’. Therefore, Mickleton as a settlement, represents a sustainable location which provides services and facilities able to support future development as part of the emerging local plan to meet future housing needs.

In order to support Cotswold District Council’s Climate Pledge, development should be located in or at the edge of well connected, accessible settlements. Our client’s land interest provides an opportunity to not only meet this locational criteria but also provide a form of development which meets relevant sustainability aspirations. As part of the Local Plan Reg 18 Consultation Draft Policies Document, Moreton-in-Marsh is identified as one of the 17 ‘Principal Settlements’. Our clients welcome this presence in Policy DS1. Regarding the proposed development strategy options, our clients support the development strategy option “Scenario 1: Additional non-strategic site allocations” whereby Principal Settlements (such as Moreton-in-Marsh) are the focus for growth in the District. Furthermore, “Scenario 2: Main service centre focus” is also supported as it is envisaged that Moreton-in-Marsh (as a transport hub) would also be the focus for development under this scenario. This is supported by the NPPF (2023) Paragraph 11a, whereby plans should promote a sustainable pattern of development. Our client’s site at Land to the west of the A429 at Moreton in Marsh provides a clear opportunity to market dwellings towards meeting housing needs for older people, in the form of bungalows, in a sustainable location close to bus services that would serve the remainder of the town and wider area. This site further provides an opportunity to deliver homes close to essential healthcare services and a food store. In line with Cotswold District Council’s approach, to reduce car dependence, this site will allow for new residents to be connected to the wider area without relying on the car. The synergy with key support services, including the hospital sets the site apart from many other options. Taking this approach into account, in addition to supporting the development strategy options, our clients contend that the Council should go further to allow development to be focused on the most sustainable settlements. To do so the development boundary should be further amended to include site M28B which would allow the strategies (outlined above) to be realised. Further, amending the settlement boundary would allow the site to be developed to meet the needs of older people in the District, which is discussed further in this letter. This would allow for existing, well-placed services to support new homes and residents, whilst also gaining the critical investment that they require for future sustainability and enhanced service provision, in line with the preferred options outlined in the Local Plan.