Local Plan - background to the consultation

Introduction

Cotswold District Council is partially updating its adopted Local Plan to make it “Green to the Core”. The adopted Local Plan covers a period from 2011 to 2031. At the same time, the Council is also considering development needs up to 2041 and options for how these may be delivered.

This is a Local Plan ‘Regulation 18’ consultation. It builds on the consultation responses we received in 2022 at the previous ‘Issues and Options’ stage of plan-making. The consultation also responds to changes in national guidance and new evidence base studies undertaken to inform the Local Plan Update.

This document contains a summary of:

• the proposed Local Plan policy updates;
• the development strategy options for the period up to 2041, as well as a preferred development strategy and broad locations for future growth; and
• a Call for Sites to deliver different types of potential development needs up to 2041, such as market housing, Affordable Housing, employment and commercial development.

Background to the Consultation

The Cotswold District Local Plan 2011 – 2031 was adopted in 2018. Local Plans need to be periodically reviewed to keep them up to date. Housing requirements, for example, must now be reviewed at least once every five years. This does not necessarily entail a full-scale update – effectively a replacement Local Plan – but can be a targeted update focussing on specific issues. However, although the Local Plan is performing well with delivering its adopted requirements and current needs, the Council is taking the opportunity to consider development needs and development strategy options beyond the current Local Plan period before these become a problem.

This does not mean that the previous ‘Issues and Options’ (Regulation 18 stage) consultation undertaken in 2022 was unnecessary ([1]). What is now being consulted upon continues and builds upon that initial work, albeit now in the context of a potentially more comprehensive and wide-ranging update to the Local Plan.

The process of updating a Local Plan involves several stages. The initial stages involve issues, options and policy proposals being discussed with stakeholders, including the public (formally known as a Regulation 18 stage). This is followed by a finalised replacement Local Plan (formally known as a Regulation 19 stage). The next step is then an Examination in Public where an independent Inspector appointed by the Planning Inspectorate assesses the soundness and legal compliance of what’s proposed and considers representations made in response to the formal consultations. At each stage there is an opportunity for stakeholders to participate in the process and have their views heard.

In this second Regulation 18 stage consultation, the Council is putting forward its draft policies and policy objectives. What is different and indicative of this consultation, however, is that consideration is also being given to development needs / requirements up to 2041 and the potential development strategy for this period. This strategy would dictate how and where any land for additional development that is needed to meet identified requirements to 2041 should be allocated. This includes broad areas of the district where growth in, for example, housing and employment provision may take place. The identification of specific development sites will follow in the next iteration of the emerging Local Plan.

A Local Plan may need to be updated or entirely replaced for a variety of reasons. It may be because legislation has changed or because important new data or evidence has emerged that means existing policies are weakened or are even unsound – these can broadly be termed as ‘technical updates’. Ensuring that the Council can maintain a 5 year housing land supply ([2]) is an example of a more strategic reason for revision.

Updates can also address issues that have emerged or intensified since the Local Plan was adopted that really must be tackled without delay and which are either not covered by existing policy or existing policy is no longer adequate. An example of a key issue in the second category derives from the Council’s declarations of Climate Change and Ecological Emergencies.

In reflecting these declarations in its Corporate Plan, the Council has committed to making its Local Plan ‘Green to the Core’ with an aim to: “Develop an updated Local Plan that delivers our corporate priorities and promotes both carbon neutral development and infrastructure”. Stated actions include “Draft new policies and updating existing policies to give effect to new Council strategies, such as the Economic Recovery Strategy, the Climate and Ecological Emergency Action Plans and the Renewable Energy Strategy.” While this can be carried out as a partial update to the Local Plan, the there is an opportunity to take proactive action now in planning to meet future housing and other development needs beyond 2031, which cannot be done through a partial update.

Please note, the all references to the National Planning Policy Framework (NPPF) in this consultation are made to the NPPF (September 2023). However, on 20 December 2023, the government published the NPPF (December 2023). Unfortunately, it was too late to incorporate this updated version of the NPPF into the Local Plan consultation, although an initial assessment of the updated NPPF highlights that it does not fundamentally alter the plan-making system or the basis of this Local Plan consultation. The updated NPPF and any other changes to national policy will be taken into consideration in the next iteration of the Local Plan update.

The Council encourages anyone to participate in the consultation to help inform the next stage of the Local Plan process. This includes whether you are a resident, business, landowner, town or parish council or anyone else. In taking part in the discussion, it is important to bear in mind the last step of the process – the Examination in Public. The Inspector will be focusing on whether the Local Plan is sound, and one key consideration for the Inspector will be whether there is sufficient evidence to support the proposals. If you do suggest new alternative policy suggestions, please remember that if we take them on board we need to be confident we can robustly and justifiably support them when the Local Plan is examined.

[1] The initial “Issues and Options” Regulation 18 consultation centred on eighteen Topic Papers dealing with a range of different issues. These remain relevant and can be accessed via the Council’s website: Accessibility of New Housing Development; Biodiversity; Responding to the Climate Crisis; Design; Economy and Employment; Green Infrastructure; Health, Social and Cultural Wellbeing; Historic Environment; Housing Affordability; Housing Need, Requirement, Land Supply and Delivery; Infrastructure; Landscape; Natural Capital and Ecosystem Services; Neighbourhood Development Plans; Retail and Town Centres; Sustainable Tourism (to follow); Sustainable Transport and Air Quality; and Water Quality, Water Resources and Flooding.

[2] A 5 year housing land supply is a supply of specific deliverable housing sites sufficient to provide a minimum of five years' worth of housing against the housing requirement set out in the adopted Local Plan.

Development Strategy, Vision and Objectives

Vision and Objectives

The adopted Vision has been updated to also include:

• Responding to the climate crisis;
• Providing more socially rented homes;
• Making the Local Plan Green to the Core;
• Supporting health and well-being; and
• Enabling a vibrant economy.

The adopted Objectives have been updated to also include:

• Zero carbon developments;
• Transitioning to a low carbon economy whilst maintaining a vibrant economy;
• Providing more opportunities to access affordable housing, particularly social rented housing;
• Delivering Biodiversity Net Gain;
• Ensuring that development supports positive health outcomes; and
• Reducing transport carbon emissions.

It is first important to note that the council is partially updating its adopted Local Plan to make it “Green to the Core”. The adopted Local Plan covers a period from 2011 to 2031. At the same time, the council is also considering development needs up to 2041 and options for how these may be delivered as part of a Development Strategy and Site Allocations Plan (2026-41).

The consultation proposals discussed here include both minor updates to the adopted development strategy as part of the Local Plan Partial Update (2011-31) and a new development strategy for the period up to 2041.

What is a Development Strategy?

The development strategy of the Local Plan identifies the requirements for different types of development over the Local Plan period. It also includes policies that set out how and where the development requirements will be delivered.

Proposed minor changes to adopted Local Plan Development Strategy (done by Local Plan Partial Update 2011-31)

The adopted Local Plan development strategy, which is located at Chapter 6 of the adopted Local Plan, has successfully delivered the district's development requirements from 2011 up to this point. The minor improvements to the adopted development strategy proposed within the partial update of the adopted Local Plan do not fundamentally alter the adopted development strategy (e.g. they do not update the development requirements up to 2031). These updates are summarised as follows:

DS1 - Development Strategy

This update does not include proposals from the Development Strategy Options and Preferred Option Topic Paper and instead includes only minor updates. The development requirements are not updated. The five year housing land supply position is proposed to be updated (currently 7.2 years as of December 2023). Similarly, the overall Local Plan housing land supply / delivery is proposed to be updated to show the position between 2011 and 2031 (currently around 9,700 (C3 use class) dwellings). Clarity is provided to confirm that the housing requirement will be monitored against a residual ‘stepped’ requirement, which factors in the number of dwellings completed since the beginning of the plan period. Clarity is also provided to confirm that, in the absence of a housing requirement for the period from 1 April 2031, the housing need figure calculated using the government’s standard methodology will instead be used to measure the five year housing land supply for that period.

DS2 - Development within Development Boundaries

Confirmation is provided that development should not harm open spaces or gaps that make a positive contribution to the character of the settlements, which makes this policy consistent with DS3. Development boundaries are proposed to be updated to exclude undeliverable Local Plan site allocations and other undeveloped land and include built-up land.

DS3 - Small-Scale Residential Development in Non-Principal Settlements

New accessibility standards are provided to help new housing developments to have reasonable access to services, facilities and employment and to reduce social isolation, vehicle dependence / cost of living issues and transport CO2 emissions. Further clarity provided to help applicants and case officers with determining what land qualifies as being ‘in a non-principal settlement’, as well as what is meant by ‘proportionate scale to the settlement’ and ‘complements the form and character of the settlement’.

DS4 - Market Housing Outside Principle and Non-Principal Settlements

Minimal changes (e.g., clarification of the types of housing development that are supported in the open countryside).

Proposed new Development Strategy (done by Development Strategy and Site Allocations Plan 2026-41)

There are now just over seven years remaining until 2031 when the adopted Local Plan period ends. The council is required to plan for the delivery of development needs and continually maintain a five year housing land supply. Whilst the adopted Local Plan development strategy is expected to continue to work successfully for a few further years, the council needs to ensure that the Local Plan continues to do so in future. It is therefore proposed to proactively address this issue now before a problem arises. Consideration is therefore being given to development needs for the period 2026 to 2041 and options for how these needs can be delivered. Further detail is provided in the Vision, Objectives and Development Strategy options Topic Paper.

Based on current estimations:

• The local housing need for this period is around 7,400 dwellings ([1]). This would reduce to 6,330 dwellings if past over delivery is deducted from the number that needs to be planned for (note, despite recent changes to national planning policies, the government has said it will provide clarity on how the over-delivery issue should be dealt at a later date).
• The local housing need is the starting point for determining the housing requirement. The housing requirement may be higher or lower than the local housing need. 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). The requirement would be determined further down the line and the local housing need is used as the basis of this analysis for indicative purposes.
• Around 5,150 dwellings’ worth of housing land supply has already been identified for the period 2026 to 2041.
• Sites capable of delivering around 2,250 additional dwellings would be needed to fully deliver the local housing need or around 1,180 dwellings if past over delivery is deducted from the number that needs to be planned for.
• 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. If the same flexibility were to be provided in the housing land supply up to 2041, around 3,290 additional dwellings would be needed or 2,070 additional dwellings if past over delivery is deducted.
• The number of homes that need to be planned for may increase or decrease as further evidence comes to light (e.g. the housing need is updated annually). However, these figures provide an indication of the scale of development that may be needed up to 2041.
• The needs / requirements and land supply for other types of development would be further assessed and will form part of the updated development strategy.

Eight development strategy options have been identified to accommodate additional development up to 2041. These include:

• Scenario 1: Additional non-strategic site allocations: This option would roll forward the adopted Local Plan development strategy of focussing the majority of additional growth at Principal Settlements, including allocating some sites outside existing development boundaries. The supporting evidence for identifying Principal Settlements would be updated. This may result in some settlements no longer being a Principal Settlement and / or other settlements becoming a Principal Settlement.
• Scenario 2: Main service centre focus: This option would focus the majority of future development (beyond existing commitments) at main service centres. The main services centres have not yet been determined but they would offer the greatest range of services and facilities, public transport accessibility and employment provision.
• Scenario 3: Dispersed growth: This option would disperse development across the district across larger and smaller settlements.
• Scenario 4: Village clusters: Like Scenario 3, this option would also disperse growth. However, settlements would be considered collectively in small groups or ‘clusters’ based on their combined offer of services, facilities, employment provision and transport accessibility. Each village ‘cluster’ would then be the focus for an appropriate and proportionate amount of growth. 
• Scenario 5: New settlement(s): This option would initiate the development of one or more new settlements in the district. The new settlement(s) would grow to include all the services, facilities, employment provision and accessibility standards found within a Main Service Centre. The size criteria of the new settlement and the potential location are yet to be determined.
• Scenario 6: New strategic site(s): This option would deliver one or more new strategic sites at a Principal Settlement(s) at a level that meets Main Service Centre expectations. As with a new settlement, strategic sites have a long lead in time from conception of the idea to the first spade being put in the ground. A new strategic site(s) would therefore be expected to deliver housing towards the mid to end of the updated Local Plan period and would likely continue delivering into the following Local Plan period.
• Scenario 7: Focus growth around transport nodes: This option would focus future growth (beyond existing commitments) along key public transport corridors and around public transport hubs (e.g. rail stations). In so doing, people would be less likely to use their car, helping to reduce congestion and carbon emissions.
• Scenario 8: Request neighbouring authority to deliver some of the housing need: If it is not possible to deliver the full local housing need within the district, it would be necessary to enquire with neighbouring Local Planning Authorities whether they could accommodate some of the district’s need. It has not yet been determined whether this option is necessary.

A combination of Scenarios 1, 2, 6 and 7 is proposed to accommodate additional development needs up to 2041. The adopted development strategy of identifying Principal Settlements would continue where the principle of development is supported. However, the strategy would have a greater focus on reducing carbon emissions and focussing growth at locations with good transport connectivity and access to services, facilities and employment. Accordingly, some settlements may become a Principal Settlement and other settlements may have their Principal Settlement status rescinded.

Additional non-strategic site allocations 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 up to 2041. A longer-term vision, including additional development, may be required to deliver some infrastructure items such as a secondary school.

The adopted development strategy of enabling small-scale residential development in Non-Principal Settlements (Policy DS3) would also continue, although it would have an increased emphasis on settlements that have better access to services, facilities and employment. Consideration may be given to whether some sites could be allocated in Village Clusters (Scenario 4). Together, development in Non-Principal Settlements, Village Clusters and windfall sites ([2]) would provide additional flexibility within the housing land supply should any site allocations not come forward as planned.

Market housing would continue to be prohibited outside Principal and Non-Principal Settlements (i.e. in open countryside) unless it is in accordance with other policies that expressly deal with residential development in such locations.

An assessment of potential broad locations for growth is provided in the accompanying document titled, ‘Cotswold District Local Plan Update: Integrated Impact Assessment’. Available from the 12 February 2024.

The feedback received on the development strategy options will be considered alongside relevant evidence as it emerges and used to refine the preferred approach.

[1] Based on the Government’s ‘standard methodology for assessing housing need, although an alternative methodology may be used if there is an exceptional circumstance for doing so.

[2] Windfall sites are sites not specifically identified in the development plan. The windfall allowance for the new Local Plan period is based on the assumption that the current windfall allowance of 138 dwellings per annum will be rolled forward.

Chapter 5A: Sustainable Development (New Chapter)

SD1 - Sustainable Development

A new overarching policy is being introduced, which commits the Council to working proactively with applicants, stakeholders and other partners to support proposals that improve the economic, social and environmental conditions of Cotswold District. The policy sets out the expectations that developments will need to deliver. For example, mitigating climate change (including adaptation measures); protecting, enhancing and creating opportunities to improve access to nature and green spaces; secure measurable and ecologically meaningful Biodiversity Net Gain, as locally as possible; and so on.

SD2 - The Climate and Ecological Emergencies

A new overarching policy that confirms the Council’s support for development proposals that deliver various climate and ecological principles. For example, minimising emissions resulting from the construction and lifetime use of buildings; maximising the use of renewable energy and resources; incorporating measures that provide climate change adaptation and increased climate resilience; and maximising opportunities to encourage a modal shift in transportation from fossil fuelled transportation to more active travel and sustainable forms of transport.

SD3 - The Cotswold Design Code (formerly EN2)

The former Policy EN2 (Design of the Built and Natural Environment) is substantially updated and relocated within the Sustainable Development chapter, which provides the policy hook for the forthcoming update to the Cotswold Design Code. The policy sets out key design principles that will be required of developments, such as creating safe and accessible environments that are not vulnerable to crime, that encourage active travel and make it easier for people to walk, wheel and cycle in their neighbourhoods, as well as improving access to public transport. The policy also includes a set of additional overarching requirements: for example, avoiding or minimising light pollution; reuse existing buildings rather than constructing new ones; and be designed to be adaptable to prolong the useful life of the development. The Council has commissioned LDA to prepare an updated Design Code which will be delivered as a new Supplementary Planning Document in 2024. This policy will require further revisions to reflect this work. It will also need to be updated to reflect other evidence studies that justify the inclusion of new policies that seek to ensure new development is able to adapt and mitigate the effects of climate change (e.g. see Climate Mitigation and Adaptation chapter).

SD4 - Health and Wellbeing

The environment in which we live affects our health and well-being, and as a social objective, it is a key component of sustainable development. The Council will support development proposals that promote health and well-being and maximise opportunities to ensure healthy and inclusive communities for all, by creating environments that encourage healthy lifestyles and appropriate health infrastructure. Proposals must consider and prioritise health outcomes, meeting the needs of different groups in the community, including older, younger people and those with disabilities. The policy includes both a requirement for a Health Impact Assessment (HIA) and the provision (and guardianship) of a defibrillator(s) for qualifying developments.

Chapter 5B: Climate Mitigation and Adaptation (New Chapter)

CC1 - Retrofitting Existing Buildings

Retrofitting existing buildings with energy efficiency and adaptability to climate change measures often does not require planning permission. However, a new policy is provided to support the responsible retrofitting of buildings when planning permission is required. This includes the fitting of energy efficiency measures and the appropriate use of micro-renewable energy generation. The policy promotes the use of an energy hierarchy, which prioritises measures that reduce energy demand, followed by measures that increase energy efficiency and finally measures that generate renewable energy. The policy also requires retrofit measures to avoid compromising permeability, ventilation or structural stability, whilst also minimising harm to the heritage significance of buildings. There is policy for retrofitting different types of building, community scale retrofit, as well as encouraging low(er) carbon retrofit.

CC2 - Renewable Energy (including sub policies CC2a-CC2d)

Elements of this draft policy – particularly regarding identification of “broadly suitable areas” for deployment of facilities and the deployment target to 2050 - await completion of the Renewable Energy Strategy. The policy, its supporting text and the Policies Map will be updated when that is complete.

The policy is in two parts. The first part of the policy is more generally applicable and sets out criteria for all standalone renewable and low carbon energy-generation, energy storage proposals and distribution networks. Subsequent parts of the policy set technology specific criteria / suitable areas applying to specific types of project, e.g. wind, solar, hydro, energy storage and community renewable energy schemes.

It should be noted that the first part of the policy sets out a provisional deployment target for the District to generate 20% of its electricity demand from renewable sources by 2050. This is subject to completion of the Renewable Energy Strategy and may be revised upwards. The supporting text for the policy explains how this target has been formulated.

CC3 - Net Zero Carbon New Buildings (including sub policies CC3a-CC3f)

A suite of new policies that sets sustainable construction requirements for all new build residential developments. Net Zero carbon buildings in operation are supported by five core principles: energy efficiency, low carbon heat, Renewable energy generation, embodied carbon and no carbon offsetting and very limited role for energy offsetting. These principles have been used to inform the proposed policies. This includes a requirement for zero operational emissions and supplying energy demand through onsite renewables. Specific requirements are set for space heating demand; total energy use; on-site renewable energy generation; connection to a low- or zero-carbon District heating network where available; and for new developments to be fossil fuel free. There is also a requirement for developments to make a financial contribution to the Council’s carbon offset fund where the use of onsite renewables to match total energy consumption is not feasible.

CC4 - District Heating

District heating, also known as a heat network, is a system that uses a singular central heat source to distribute hot water through a network of insulated pipes to multiple individual buildings. The structure is commonly used to fulfil heating and hot water requirements in apartment complexes and densely populated areas.

Cotswold District is less densely populated than more urban areas and district heating schemes will not always be the best solution. However, they can be an effective means of cutting carbon emissions where conventional systems are unsuitable. A new policy is therefore introduced to ensure that the district heating schemes are well-designed, equitable and are low carbon.

CC5 - Managing Flood Risk (formerly EN14)

Formerly EN14, policy CC7 has been updated and moved to the ‘climate change’ (CC) chapter within the updated Local Plan. Extreme weather events and the future demands of development from population increase, are likely to increase flood risk to both development itself and areas downstream; and the policy will form a part of the overall response to the mitigation of, and adaptation to, climate change. The existing flood risk policy is updated to promote and trigger investigation into natural methods of flood mitigation, such as targeted woodland planting; and consideration of flood risk from all sources of flooding including that from surface water; a new clause to safeguard (in policy) two areas with the potential for flood storage near Cirencester; and to take into account the multi-functional benefits of Sustainable Urban Drainage Systems (SuDS) for all developments, to manage and help reduce the rate of water run-off.

CC6 - Water Infrastructure Management (formerly INF8)

This policy has been moved to the ‘climate change’ (CC) chapter within the updated Local Plan. There is increasing conflict between climate change scenarios (such as increased storm events and dry periods) and the future demands of development from population increase; on water resources in a ‘seriously water stressed’ area and water quality, with increased or concentrated pollutants entering watercourses. The policy seeks to ensure that there is adequate water and wastewater infrastructure to serve all new developments, and that development is designed to be water efficient and reduce water consumption. It also promotes Sustainable Urban Drainage Systems (SuDS) that can help limit as far as possible surface water entering the public sewer system. The policy requires the use of conditions to ensure where there is insufficient water/wastewater infrastructure capacity, the occupancy of new homes should not be permitted; and development that results in a new residential dwelling will be required to incorporate water conservation measures to achieve a maximum water consumption of 110 litres per person per day.

CC7 - Green Infrastructure (formerly INF7)

This policy has been comprehensively updated to take account of the new guidance in the NPPF, including the new definition of Green Infrastructure. The increased importance of linking new and existing GI using intelligence from the Nature Recovery Mapping, the Network and forthcoming Strategy all of which are mandatory under the Environment Act 2021. It has also considered new National guidelines and best practice, which are set out in Natural England’s GI Framework published in 2021 and Building with Nature, an industry Best Practice Guide. The update also refers to the Cotswold District GI Strategy and Cotswold Design Code.

CC8 - Sustainable Transport (formerly INF3)

Formerly INF3. Comprehensive update. Amongst the many policy proposals, the policy links to the Gloucestershire Transport Decarbonisation Plan and Cotswold Transport Decarbonisation Strategy and includes targets from both documents. It includes a requirement for the early delivery of sustainable transport infrastructure. It also provides a hierarchy of road users for the design and layout of sites.

Chapter 7: Delivering the Strategy

S1 and S4 to S19 - Principal Settlements

It is proposed to delete development allocations from the Local Plan that are now under construction. The following development allocations would also be deleted as they have been reassessed and are no longer deliverable / developable:

• Cirencester (C17): 42-54 Querns Lane, as the site cannot deliver 5 or more dwellings.
• Fairford (F35B): Land behind Milton Farm and Bettertons Close, as the site is unavailable.
• Fairford (F44): Land to rear of Faulkner Close, Horcott, as the site is now unsuitable due to the neighbouring Site of Special Scientific Interest and because the access is unachievable.
• Kemble (K2A): Land at Station Road, as the site is unavailable and will become part of Kemble Community Gardens.
• Lechlade (L18B): Land west of Orchard Close, Downington, as the site is unavailable.
• Willersey (W1A and W1B): Garage Workshop and Garden behind the Nook, Main Street, as the site cannot deliver 5 or more dwellings.

Policy S18 (Moreton-in-Marsh) proposes to allocate land at the Fire Service College for a new primary school, as well as enabling developments of 310 homes, a neighbourhood centre and employment development. In addition, a route is proposed to be protected for a new road, which would futureproof the transport strategy for Moreton.

Further site allocations would be made for different types of development if the Local Plan period was extended to 2041. The Sustainability Appraisal that accompanies this consultation identifies broad locations for potential growth of settlements. See Policy INF1 of this document where infrastructure requirements of additional growth are discussed.

S3 - Cirencester Central Area Strategy (and subsidiary policies S3(a) to S3(d))

Revised Policy S3 and its subsidiary policies features a fundamental redraft of the existing strategy for Cirencester Central Area. All but one of the land allocations that were formerly in Policy S1 have been carried forward and incorporated into the revised policy.

Several important (and ongoing) changes have taken place since the Local Plan was adopted in 2018:

• The Council has a new Corporate Strategy that places great emphasis on meeting the challenges of the Climate and Biodiversity Emergencies, requiring the Local Plan to now be “Green to the core” – this has many implications for the future planning of the town centre including modal shift in transport and renewable energy that sit alongside orthodox issues such as conservation of the historic environment.
• Changes in the nature of the “traditional high street” due primarily to internet shopping are challenging the dominance of retail as a keystone policy for town centres. To be resilient and robustly meet the challenges of a rapidly changing future, town centres need to have a broader mix of “main town centre uses” and be more flexible and responsive to change.
• Work to progress a Framework Masterplan SPD for the Central Area – a requirement of the adopted Local Plan – has progressed significantly and is a major driver behind the changes to the Town Centre Strategy.

Taken together the cumulative effect is that the current retail-dominated town centre strategy is out of date. It is inadequate to meet the challenges of the future and assist in delivering the Framework Masterplan SPD. Please note that a separate consultation and survey questionnaire on the emerging Framework Masterplan SPD is being carried out concurrently with consultation on the Local Plan Update – see your.cotswold.gov.uk

The revised Strategy is a significant departure from the adopted version. In blunt terms it is far more specific and directional about what the council wants to see when redevelopment takes place. For example, it proposes to divide the town into porously demarcated precincts (the subsidiary policies), each with their own distinctive mix of uses that mirror the proposals in the emerging Framework Masterplan.

Officers have worked closely with consultants Mace and with Cirencester Town Council in development of the Framework Masterplan and the revised policy.

It should be noted that Government changes to the Use Classes Order and Permitted Development Rights have made it more difficult for LPAs to be in complete control of how their town centres develop. Shops, some other main town centre uses together with some employment and light industrial uses are now lumped together in Use Class E. Change of use from Class E to Class C3 (dwelling houses) is possible as permitted development (subject to prior approval). A survey undertaken two years ago by officers indicated that up to 50% of premises in the town centre could be susceptible to this change. To date this existential threat has not materialised (probably due to the robust economic health of Cirencester’s town centre) but it does serve as an unhelpful “wild card” in the planning of our town centres.

Chapter 8: Housing to Meet Local Needs

H1 - Housing Mix and Tenure to Meet Local Needs

Removal of references to the scrapped government Starter Homes scheme. New requirement for accessible housing to enable people to live longer at home in older age.

H2 - Affordable Housing

Various proposals to increase affordable housing delivery. Includes: increasing the affordable housing requirement from 30% to 40% on brownfield and from 40% to 50% on greenfield sites; changing the requirement for a financial contribution in the Cotswolds National Landscape and any future ‘designated rural areas’ from 6-10 dwellings to 3-9 dwellings with all developments of 10 or more homes requiring on-site affordable housing provision; removing a loophole for avoiding affordable housing contributions by submitting several smaller schemes; a new policy for entry-level exception sites; and many more.

H3 - Rural Exception Sites

Minimal changes, including defining a “strong local connection”.

H4 - Specialist Accommodation for Older People

No changes to the housing requirements. Clarity on how the requirements will be monitored. New requirements for developments to promote active lifestyles and older peoples’ engagement in community life. Changes also proposed in the Design Code.

H5 - Dwellings for Rural Workers Outside Principal and Non-Principal Settlements

Various proposals to ensure new dwellings for rural workers and extensions to those dwellings do not go beyond what is needed and do not enable the creation of market housing in locations that would otherwise be unsuitable.

H6 - Removal of Occupancy Conditions

Merger of different policies that deal with the removal of occupancy conditions. Requirement for newly created dwellings to comply with the Nationally Described Space Standard.

H7 - Gypsy and Traveller Sites

Updated need for Traveller pitches, as well as updates to the supporting text to identify how needs are being accommodated.

H8 - Replacement Dwellings

New policy, ensuring that replacement dwellings are not inappropriately large. It also closes a loophole where applicants gain permission through permitted development rights or a Certificate of Lawful Existing Use of Development and build a new replacement dwelling in a location that would otherwise be unsuitable. The new policy reinstates several aspects of a revoked policy from the former adopted Local Plan.

H9 - Extensions and Alterations to Dwellings

New policy, which supports extensions but sets some limitations on the size of extensions to help protect the unspoilt character of the Cotswolds and the wider district and to maintain a range of housing types, particularly the stock of smaller / typically lower priced house types to meet the needs of Cotswold communities.

H10 - Community-Led Housing

New policy providing further support for community-led housing developments to deliver more genuinely affordable housing, whilst providing a further boost to the housing land supply.

H11 - Homelessness Housing Provision

New policy requiring all major housing development (for example, 10 or more dwellings) to contribute towards homeless housing provision to meet the identified need in the District and address the Council’s strategic objectives on meeting affordable housing. Contributions will be by way of a financial contribution from the developer.

Chapter 9: Economy, including Retail and Tourism

EC1 - Employment Development

Minor textual changes to improve comprehension. An additional requirement for applicants to encourage travelling to and from work by sustainable methods of transport.

EC2 - Safeguarding Employment Sites

As noted in the summary of Policy S1, the government’s changes to the Use Classes Order and subsequent amendments to Permitted Development rights have had a significant impact on policy planning. And not just in town centres. It has presented a major challenge to the council’s long-standing policy of safeguarding employment sites to ensure the district’s economic prosperity and resilience. Unless an industrial unit is classed as B1 or B8, all other existing units on an established employment or industrial estate are within Class E and could, with prior approval, change use to residential (Class C3). It hardly requires detailed explanation to see the myriad difficulties this can cause, not least for the people and families who may end up living in one of these conversions.

Our powers of control are limited. The use of Article 4 Directions is possible but can attract prohibitive levels of compensation. Officers have surveyed extant employment and industrial estates. The egregious ones have been identified and the policy is now amended thus:

Appendix E identifies established employment sites that are important for general or heavy industry, waste management, storage and distribution, or a mix of such uses. These sites and their locations are likely to raise compatibility issues with residential use and proposals for change of use need to be scrutinised carefully. Consequently, to safeguard both the employment uses and the living conditions of any prospective residential occupiers of converted premises, some Appendix E sites are identified as requiring prior approval and may require express planning permission for a change of use.

Having regard to new employment development on established or allocated sites, it is proposed to prevent automatic permitted change to residential by requiring that conditions are imposed restricting the use and requiring express planning consent for any subsequent change.

Other alterations to the policy and supporting text are minor textual amendments to bring it up to date with legislative and related changes.

EC3 - Proposals for all types of Employment-Generating Uses

Minor textual amendments to bring the policy and supporting text up to date with legislative and related changes.

EC4 - Special Policy Areas

The proposals primarily relate to the Royal Agricultural University (RAU) in Cirencester and the Fire Service College (FSC) in Moreton-in-Marsh. The policy is still under development but the policy proposal shows the direction of travel.

• The RAU is seeking to grow its role as the UK’s global agricultural university, including the delivery of a new Innovation Village and growing its student population. The update makes Policy EC4 more flexible to accommodate the RAU’s growth plans by broadening the types of use that will be supported on the site and requiring purpose-built student accommodation to support the expansion of the RAU.
• The FSC proposal allocates 2ha of the existing site for a new primary school, which would be in addition to the existing St David’s Primary School. The existing 7ha employment site allocation (ref: MORE6) would be expanded to around 10ha and the uses would be broadened from office to also include general industrial and storage and distribution uses (B2, B8 and E(g) use classes). The proposal also includes some ‘enabling’ housing development, the profits from which would be secured towards redeveloping life expired buildings on the FSC site and regenerating the wider site. Mitigating highway impact on the town centre is a key aspect of this proposal with a potential new road connecting Todenham Road to London Road (A44).

EC5 - Rural Diversification

Minor changes to ensure new rural buildings are necessary and, where they are built, safeguards are in place to remove a loophole for subsequent redevelopment into housing in an otherwise unsuitable location.

EC6 - Conversion of Rural Buildings

Clarification that this policy does not apply to conversions to dwellings. Clarification that works must not go beyond what might sensibly or reasonably be described as a conversion, as opposed to a rebuild, which is not supported.

EC7 - Retail (deleted policy)

Policy deleted. The discussion regarding Policy S3 touched on the need for town centres to diversify and not be “monocultures” revolving around a dominant retail use. It is important however to note that retail remains, plainly, a very important town centre use. But it can no longer be seen as the keystone. A broader mix of “main town centre uses” will help to ensure our centres remain healthy, vibrant places that are able to flex and adapt to changing economic, environmental and other circumstances. Revised Policy EC8 retains policy “essentials” regarding retail: the baby has not been thrown out with the bathwater.

EC7 - Agricultural and Forestry Buildings

A new policy for (typically larger scale) agricultural building proposals, which are not covered by permitted development rights.

EC8 - Town Centres

Formerly “Main Town Centre Uses” this policy is a significant revision in respect more of emphasis than textual addition or amendment. It incorporates elements of EC7 retail.

In a nutshell this revised policy plays down the dominance of retail while elevating the profile of other main town centre uses. It is, in other words, an attempt to level the playing field. The reason for this has been explained earlier in relation to S1. “Main town centre uses” do not include residential use but the policy is explicit that, in certain circumstances, this may be acceptable.

The revision also encourages towns preparing or revising Neighbourhood Development Plans to consider preparing strategies for their town centres to make them more resilient to change. While this is not a compliance requirement for NDPs it would represent good strategic planning if this general move away from retail dominance was adopted across the district.

EC9 – Retail and Leisure Impact Assessment

This remains a requirement of the NPPF and is retained for that reason. Minor textual amendments to bring the policy and supporting text up to date with legislative and related changes. This includes amending the title to “Retail and Leisure Impact Assessments”.

EC10 - Development of Tourist Facilities and Visitor Attractions

Policy amended to close a loophole where attractions are proposed that are alleged to only be viable if they are accompanied by accommodation. DM advises that the accommodation is often the main business interest rather than the attraction. Effectively therefore the amendments seek to prevent market housing proposals coming forward by the back door. This is at present a “hot topic” as the current government consultation on further changes to permitted development rights includes a proposal to enable change from short-term lets to permanent dwellings and vice versa.

EC11 - Tourist Accommodation

This policy has been completely redrafted from the title “Tourist and Visitor Accommodation” onwards.

The existing policy is not coherent in places. It has inherent contradictions and has proved challenging for DM colleagues to use.

From hotels to caravans and “glamping” sites the revised policy is far more systematic, rigorous and straightforward in addressing the various permutations and types of accommodation available for visitors. For example, the revised policy follows national policy (NPPF (2023) Annex 2) in identifying hotels as “main town centre uses”. In that context the sequential approach to assessing proposals is embedded in the revised policy. Therefore, hotels should be in designated town centres. Proposals outside designated centres – sequentially edge of centre and then out of centre - are subject to progressively more rigorous assessment and planning hurdles.

Apart from straightforward compliance with the NPPF, there are sound planning reasons for taking this approach. The need to diversify the mix of uses in our town centres has been pointed out elsewhere, and hotel accommodation will assist greatly in that. The need to encourage modal shift in transport means that concentrating uses of this type in centres may reduce the need for car journeys because public transport or other forms of movement are more available and attractive. Concentrating this type of use in designated centres, and discouraging their development in other areas, is more sustainable in the long term.

EC12 - Equestrian Related Development

Policy EC12 is a new policy, incorporating former Policy 31 from the Local Plan (2006), to support equestrian related development; to ensure new uses for traditional buildings and reduce the pressure for new, isolated buildings in the countryside. In permitting private and commercial enterprises, the policy seeks such development to be in keeping with and prevent an adverse (and/or cumulative) impact on the landscape and surrounding environment, including existing buildings, dwelling(s) (residential amenity), or highways and to take into account local biodiversity and habitats. Dwellings proposed in connection with equestrian related development will only be permitted following certain criteria, to prevent the creation of such a development as a pretext for future housing/building in the countryside.

Chapter 10: Built, Natural and Historic Environment

EN1 - The Built, Natural and Historic Environment

Minimal changes. The changes made to EN1 are for points of clarity.

EN3 - Local Green Spaces

Extend LGS6 Kemble – Community Gardens at Station Road to include the land that was formerly allocated for residential development (ref: K2A).

EN4 - The Wider Natural and Historic Landscape

The policy, which applies to the whole District, (including Special Landscape Areas and the Cotswolds National Landscape), remains unchanged. Additional supporting text is included to clarify the holistic role of the landscape as recommended by Natural England, where it not only has aesthetic value but also plays a key role in health, biodiversity, the local economy, tackling the climate and ecological emergencies, as well as providing a clear sense of place; and the opportunities and challenges in often competing needs i.e. when balancing the need for new development (residential or renewable energy proposals), with the conservation and enhancement of the high quality landscape.

Retaining all the landscape policies broadly as is (EN4, EN5, EN6), they remain a counterweight to increased pressures for development and can be considered on a case-by-case basis.

EN5 - Cotswolds National Landscape

The policy remains unchanged. On 22nd November 2023, the Government rebranded Areas of Outstanding Natural Beauty (AONBs) as National Landscapes. In Cotswold District the Cotswolds AONB becomes the Cotswolds National Landscape. This retains the same designation and status in practical terms. Consequential changes have been made to EN5 to reflect the rebranded name. We are aware that other references to the AONB in the emerging Local Plan update will also need to be updated. This will be done in the next iteration of the Local Plan update.

EN6 - Special Landscape Areas

The policy remains unchanged. Consequential change in the supporting text due to the more recent review of Special Landscape Area (SLA) designations.

EN7 - Trees, Hedges & Woodlands

New guidelines have emerged since the adoption of the Local Plan and the policy has been updated to reflect these changes. In particular, the NPPF 2023, The England Tree Action Plan 2021-2024, the Gloucestershire Tree Strategy 2021 and forthcoming Action Plan and the Gloucestershire Nature Recovery Network and forthcoming Nature Recovery and Action plan. The NPPF specifies that the plan should provide street trees in new developments, to recognise the contribution trees play to climate change, the environment and Green Infrastructure (GI) and the opportunities to incorporate trees in new development such as parks and community orchards. Veteran trees and woodlands are referenced in the policy, but their role as irreplaceable habitats is new. The policy now includes intelligence from The Gloucestershire Tree Strategy, which highlights the deficit of trees in the Cotswold District and the number needed to address the deficit. The definition of ‘trees hedgerows and woodland’ has been updated and broadened to include small copses, orchards, linear belts, and woodland blocks. New guidelines from the Gloucestershire Nature Recovery Network and forthcoming Nature recovery and Action plan provide the ecological mapping data needed to plant more trees it the right places, this along with the Cotswold Design Code, and Cotswold GI Strategy. Missing and now added from the original policy was the need to plant more trees and their long- term maintenance.

EN8 - Biodiversity & Geodiversity: Features, Habitats & Species

There are four key updates to the policy.

1) The need to provide at least 10 % Biodiversity Net Gain (BNG) in line with the expected mandatory figure required by Government via the Environment Act 2021.

2) Reference to the mitigation hierarchy, (avoidance, mitigation, competition) which developers will need to apply. The mitigation hierarchy is the principle that environmental harm resulting from a development should be avoided, adequately mitigated, or, as a last resort, compensated for.

3) The Ten Biodiversity Net Gain Good practice principles have also been included in the policy. For development these are:

• Principle 1. Apply the Mitigation Hierarchy
• Principle 2. Avoid losing biodiversity that cannot be offset by gains elsewhere
• Principle 3. Be inclusive and equitable
• Principle 4. Address risks Principle
• Principle 5. Make a measurable Net Gain contribution
• Principle 6. Achieve the best outcomes for biodiversity
• Principle 7. Be additional
• Principle 8. Create a Net Gain legacy
• Principle 9. Optimise sustainability
• Principle 10. Be transparent

4) Added to the policy is the requirement for all new housing to provide three swift bricks and opportunities for bat roosts within each new dwelling, located on a suitable elevation.

EN9 - Biodiversity & Geodiversity: Designated Sites

The updated policy includes specific reference to habitat sites in or near the Cotswold District. As a point of clarity the hierarchy of UK nature conservation designations and two maps illustrating where these are, are also included. Also, new to the policy is the reference to the mitigation strategy for recreational effects on North Meadow and Clattinger Farm and Cotswold Beechwoods Special Areas of Conservation (SAC). To enable development to come forward that might otherwise cause likely significant recreational effects on the North Meadow and Clattinger Farm SAC or the Cotswold Beechwoods SAC, the Council has worked with Natural England and neighbouring Local Authorities to prepare recreation mitigation strategies for the SACs.

EN10 - Historic Environment Designated Heritage Assets

The policy remains ‘sound’ and no update is proposed.

EN11 - Historic Environment Designated Heritage Assets (Conservation Areas)

Very minor alterations requested by the Council’s Development management and Heritage and Design teams to do with the significance of heritage assets.

EN12 - Historic Environment: Non-designated Heritage Assets

Textual amendments to bring the policy and supporting text up to date with legislative and related changes. Additional requirement for assessment of land prior to submission of applications included at the request of DM/specialist officers.

EN13 - Historic Environment: The Conversion of Non-Domestic Historic Buildings

Textual amendments to bring the policy and supporting text up to date with legislative and related changes.

EN15 - Pollution and Contaminated Land

The policy remains unchanged. Additional text in the reasoned justification to highlight overlapping issues, such as water quality, and links to other policies elsewhere in the Local Plan i.e. to provision of green infrastructure, biodiversity net gain and water management infrastructure.

EN16 - Dark Skies

A new policy to recognise the importance of Dark Skies in the Cotswold District. The Cotswolds National Landscape has relatively dark skies at night, compared to other parts of the country. The District is ranked 13th in terms of the darkest skies in England. The policy aims to protect the dark skies of the Cotswold District, to reduce light pollution by requiring development to use the latest lighting technology and the retrofitting of old lighting. This policy reflects the policy stance of the National Cotswold Landscape.

EN17 - Management of Accessible Open Green Spaces

A new policy to address concerns about the long-term management of these spaces, by providing clarity regarding what is required by applicants. How and what will be managed for how long, the source of funding and by who and the approach taken to manage the space.

EN18 - Sherborne Park Estate Masterplan

A new policy is provided for the Sherborne Park Estate near Northleach. The policy enables the production of a masterplan for the estate, which will provide the framework for determining planning application(s) on the estate in future. The policy identifies the various things the masterplan will include. It also specifies that small-scale development will be supported where it is consistent with the masterplan for nature-based tourism; rural land use-based employment; education; access improvements; habitat creation; and climate change mitigation and adaptation.

Chapter 11: Infrastructure

INF1 - Strategic Infrastructure Delivery (formerly policies SA1, SA2 and SA3)

It is proposed to merge the three strategic infrastructure policies into one and remove completed infrastructure projects from the Local Plan. An update of the Infrastructure Delivery Plan will be undertaken to assess the strategic infrastructure requirements of any additional planned growth (e.g. health care, education, water and wastewater, transport, flood risk, libraries, etc.). Additional required infrastructure items will be specified in the next iteration of the Local Plan.

The proposals at Moreton-in-Marsh come with some high priority infrastructure considerations (e.g. education, water infrastructure and highways). Discussions are ongoing with the lead education authority (Gloucestershire County Council) and the water infrastructure provider (Thames Water). We are aware of the need for a new primary school and the desire for a new secondary school in Moreton.

Highway congestion in Moreton is believed to be an issue, especially in and around the town centre. Transport modelling is being undertaken to confirm the situation. First and foremost, options are being explored to reduce traffic and deliver modal shift from private vehicle trips to more sustainable forms of transport. A new road may be required to direct some through traffic away from the town centre. This would need to be planned in combination with the future movement strategy for Moreton town centre. The route of the road has not been confirmed but it would likely be via the east of the town where the land and landscape are less constrained. The type of road and the road users also require further consideration. We are working the cost and viability of this proposal.

A plan for the delivery of required delivery will be included in the new Infrastructure Delivery Plan and the next iteration of the Local Plan.

INF2 - Infrastructure Delivery (formerly Policy INF1)

Textual amendment to delete clause 3 which requires applicants to submit viability assessments where infrastructure requirements are a threat to scheme viability. In effect an “exceptions” trapdoor. Deleted because, following advice in Planning Practice Guidance, the Local Plan is subject to a viability assessment that includes the infrastructure requirements identified during plan preparation and included in relevant policies. It follows that proposals that are fully in accordance with the policies of the Local Plan are deemed to be compliant and, by extension, viable. If proposals are not viable, they are not compliant with the Local Plan. It is a matter for the applicant to address that – and that may include submitting a viability assessment in certain circumstances - rather than seeking an exception to a policy requirement as a matter of course.

INF3 - Social and Community Infrastructure (formerly Policy INF2)

Textual amendments for clarification and to tighten up the policy requirements.

INF4 - Highway Safety

Various updates to optimise highway safety in new developments. For example, requiring: design that constrains vehicle speeds; avoids the severance of communities; installs footpaths along ‘desire lines’; and requiring development sot be designed in accordance with the Manual for Streets guides, LTN1/20 and guidance issued by Active Travel England.

INF5 - Parking Provision

Various updates, which will include: a requirement for electric vehicle charging points; revised parking standards; a requirement for developments to also include parking for bicycles, eBikes, micro-mobility modes, shared vehicles and Blue Badge holders at preferential locations; a new requirement that car parking in developments does not dominate the street scene or public realm and should be located in non-preferential locations; and a requirement for parking for delivery vehicles.

INF6 - Vale of Evesham Heavy Goods Vehicle Control Zone (deleted policy)

This policy is shared by Cotswold District, Stratford-on-Avon and Wychavon Councils. Wychavon has confirmed that the policy will be deleted from its Local Plan (the South Worcestershire Local Plan, currently under review) because the county council deems it unnecessary. The policy is therefore not implementable. Consequently, it is proposed to delete it from the Local Plan. There is no reference to the policy in the Gloucestershire Local Transport Plan (LTP) and Gloucestershire County Council has not objected to the policy being deleted.

INF6 - Telecommunications Infrastructure (formerly INF9)

The policy and supporting text have been updated to avoid reference to specific technologies (given the pace of change); including consequential changes to remove out of date references, for clarity, and in response to development management suggestion for the use of a condition and seek the optimum infrastructure available. This will enable the development to be ‘future proofed’ in respect of digital connectivity as far as possible and provide future occupiers for example, the opportunity to work at home, reduce car use/emissions and enhance the provision of local services. The changes help clarify and support the policy as beneficial to the environment, economic growth and social wellbeing, in line with the NPPF.

Chapter 12: Other Spatial Issues

SP1 - Gloucester and Cheltenham Green Belt

This policy remains ‘sound’ and no update is proposed.

SP2 - Cotswold Airport

This policy remains ‘sound’ and no update is proposed.

SP3 - The Thames and Severn Canal

This policy has adjusted to include a reference to the need for infrastructure contributions to support the operation of the canal. The supporting text now reflects that the River Thames is a key Green Infrastructure asset in the District and as such offers opportunities for wildlife and biodiversity. The supporting text reiterates the Council’s support for the reopening of the Thames and Severn canal and its wider potential for wellbeing including active travel.

SP4 - The River Thames

The supporting text now reflects that the River Thames is a key Green Infrastructure asset in the District and as such offer opportunities for wildlife and biodiversity. A reference to Gloucestershire Nature Recovery Network and Cotswold Green Infrastructure are signposted for when environmental improvements are made.

SP5 - Cotswold Water Park Post-Mineral Extraction After Use

The policy remains unchanged. Additional text in the reasoned justification both notes the recent expansion of the Sites of Special Scientific Interest (SSSI) to reflect the ecological importance of the Cotswold Water Park; and to consider future guidance and agreements that relate to this cross-boundary area.

SP6 - Former Cheltenham to Stratford-upon-Avon Railway Line

The policy remains ‘sound’ and no update is proposed.

Appendices

Appendix E - Established Employment Sites

Appendix E has been updated to show know updates to Established Employment Sites. Work is ongoing to reappraise the Established Employment Sites, which will inform the next iteration of the emerging Local Plan. Particular consideration is being given to whether sites are important for general or heavy industry, waste management, storage and distribution, or a mix of such uses, or where there may be an unacceptable impact on intended occupiers resulting from the introduction of residential uses either now or in the future, which has an impact on permitted development rights.

Appendix K - Glossary

The Glossary is updated to include revised or new definitions that are important for the Local Plan. For example, a new Affordable Housing definition is provided, which reflects national policy.

Appendix M - Vacant Building Credit Calculation Methodology

The Council has already adopted a methodology setting out how Vacant Building Credit is calculated in the District. It is being incorporated within the Local Plan.

Appendix N - Schedule of Strategic and Non-Strategic Policies

National policy now requires Local Plans to identify strategic and non-strategic sites. This schedule does this job.

Appendix O - Map of Biodiversity & Geodiversity Designated Sites

A map of the main Biodiversity & Geodiversity Designated Sites has been provided, which supports Policy EN9.

Appendix P - Schedule of Biodiversity and Geodiversity Designated Sites

Because some of the Biodiversity & Geodiversity Designated Sites are so small and are not easily identifiable on a District-scale map, a schedule of the sites has also been provided. This includes coordinates of the sites. This currently only contains Sites of Special Scientific Interest but the schedule will be expanded to include other types of Biodiversity & Geodiversity Designated Sites to further support Policy EN9.

Appendix Q - Light Pollution and Dark Skies

A map showing the areas of the District with light pollution and dark skies has been provided to support of Policy EN16.

Policies Map

A schedule of changes to the Policies Map is provided at the end of the Draft Policies (Tracked Changes) document. This will be updated to reflect any additional site allocations or further evidence prior to the next iteration of the emerging Local Plan. This schedule of changes includes the following proposals:

• Changes to Principal Settlement Development Boundaries (Policies DS1 and DS2) to exclude undeveloped land or include developed land / proposed site allocations.
• Changes to Policies S1-S19, H7 and EC4 to remove deleted site allocations and include new or extended site allocations.
• Changes to the boundaries of Established Employment Sites (Policy EC2). For example, to include extensions of sites or where land has been lost to residential development.
• Update to the Chipping Campden Key Centre boundary (Policy EC7) to incorporate some additional Main Town Centre Uses.
• Extension to Kemble Community Gardens at Station Road, Kemble (Policy EN3).
• Revision of the Special Landscape Area at Moreton-in-Marsh (Policy EN6) to exclude land that is now developed.
• Inclusion of the location of designated biodiversity and geodiversity sites.
• Inclusion of new Cotswold District Dark Sky areas (Policy EN16).

Local Plan sections to be included / updated in next Local Plan consultation

Please note, the following sections of the adopted Local Plan may be updated in the next iteration of the emerging Local Plan:

• Introduction
• Portrait
• Issues
• Appendix A - Local Green Space at Church Westcote
• Appendix B - Vision and Objectives
• Appendix C - Gypsy and Traveller Accommodation
• Appendix D - Cotswold Design Code
• Appendix F - Parking Standards and Guidance
• Appendix G - Natural and Historic Environment Objectives
• Appendix H - Strategic Principles for Green Infrastructure in Gloucestershire
• Appendix I - Index of Policies v Local Plan Objectives
• Appendix J - Monitoring Indicators
• Appendix L - Replacement of 'Saved' Policies