Preferred Spatial Options Paper

see comments

see attached comments

Freeland has been identified as a ‘Large Village’ in the Local Plan. The recent approval for 60 homes (Application no 25/00333/OUT) will further increase the size of the village, yet it still doesn’t have a shop or a regular bus service. Therefore Freeland must surely be one of the least sustainable of the ‘Large Villages’ itemised in the plan. As such we consider every effort should be made to improve this situation when Section 106 funds are allocated to improve village sustainability.

HELAA
Freeland Parish Council would like to draw attention to two of the HELAA sites set out in the 2041 Local Plan within the village: FREE 002 and FREE 005.

FREE 002 – this plot of land is unsuitable for any housing development due to the impact on the Non-designated Heritage Assets including the Victorian farm buildings, walled garden and drive to Freeland House, as well as its impact on the setting of Freeland House. The importance of these was highlighted by the Planning Inspector in her report for the failed Appeal on the proposed development of a retirement village on the site.

Development of this site would also increase the linear development of the village, a argument against development noted for FREE 001.

FREE 005 – this is the existing, rather tired, Industrial Estate. This site has been assessed as suitable for housing in part, and we agree with the principle of this.

OVER-ARCHING CONSIDERATIONS FOR PROPOSED ALLOCATIONS IN THE COTSWOLDS
NATIONAL LANDSCAPE AND ITS SETTING
Development in the Cotswolds National Landscape and its setting
The Cotswolds National Landscape is a landscape whose distinctive character and natural beauty are so outstanding that it is in the nation’s interest to safeguard it.1 The statutory
purpose of its designation is to conserve and enhance the natural beauty of the area.2
The CNL is also a living and working landscape in which the social and economic well-being of local communities are important considerations. Maintaining vibrant and thriving local communities is essential to the long-term future of the CNL.
As such, the CNL Board recognises that some degree of development may be appropriate within the CNL and its setting. The challenge is to ensure that this is delivered in a way that is compatible with – and positively contributes to – the statutory purpose of designation.
1 linkregistration/areas-of-outstanding-natural-beauty-technical-support-scheme-england-2019-to-2020. 1.
Introduction.
2
Section 82 of the Countryside and Rights of Way Act 2000 (link).
6
Natural Beauty
Natural beauty encompasses everything that makes an area distinctive: geology, climate, soil, plants, animals, communities, archaeology, buildings, the people who live in it, past and present, and the perceptions of those who visit it.3
As outlined in Natural England’s guidance for assessing landscapes for designation as National Landscapes or National Parks, there are several factors that contribute to the natural beauty of a National Landscapes. 4 These include:
• Landscape quality.
• Scenic quality.
• Relative tranquillity.
• Natural heritage (including biodiversity).
• Cultural heritage (including the historic environment).
When the District Council is assessing potential impacts of the spatial strategy and individual allocations on the natural beauty of the CNL, they should factor in all of these considerations, not just landscape quality and visual quality.
Seek to Further Duty
Relevant authorities, including local planning authorities and the Planning Inspectorate, have a statutory duty to seek to further the purpose of conserving and enhancing the natural beauty of the CNL (the ‘seek to further’ duty).
The Board’s standing advice on the seek to further duty is provided in Appendix 2, below.
As part of the evidence base for the Local Plan, the District Council should explicitly set out how it has addressed the seek to further duty in relation to the Local Plan policies, settlement hierarchy, spatial strategy and individual allocations. In doing so, the District Council should
identify whether harm would be caused to the natural beauty of the CNL. If it would, then the purpose of conserving and enhancing natural beauty would not be furthered. The District Council should also identify how they have taken all reasonably practicable steps to further this purpose.
Landscape and Visual Sensitivity Assessment
The CNL Board acknowledges that landscape issues (and some of the other factors that contribute to natural beauty, such as biodiversity and historic environment) have been
addressed, to some degree in the Housing and Economic Land Availability Assessment and in Local Plan Sustainability Appraisal.
However, the Board recommends that the District Council should address landscape issues in more detail through a landscape and visual sensitivity assessment, or landscape and visual sensitivity and capacity study. This study should assess the sensitivity of the landscape to the types and scales of development that are being considered.
Where the sensitivity of the landscape to specific types and scales of development is identified as being high, or medium-high (and where any development impacts could not be fully
3 Countryside Agency (2001) Areas of Outstanding Natural Beauty Management Plans. A guide. (Link)
4 Natural England (2021) Guidance for assessing landscapes for designation as National Park or Areas of Outstanding Natural Beauty in England (link).
7
mitigated), the development should be deemed to exceed the capacity of the landscape to accommodate that development and should be considered unsuitable.5
The special qualities of the CNL and the key characteristics, or features, of the relevant landscape character types should be key considerations.
Proportionality
National planning policy states that, for development in National Landscape:
• the scale and extent of development should be limited; and
• permission should be refused for major development other than in exceptional circumstances and where it can be demonstrated that the development is in the public
interest.
In addition, guidelines in the Cotswolds National Landscape (CNL) ‘Landscape Strategy & Guidelines’ include the following point:
• Ensure new development is proportionate and does not overwhelm the existing settlement.6
Therefore, a key consideration is whether proposed development is proportionate. If it is not proportionate then it is likely to conflict with the requirement for the scale and extent of development to be limited. For development within the CNL, it is also likely to constitute major development.
The issue of proportionality is relevant to:
(i) development within the CNL;
(ii) development outside the CNL where:
a. the development is within, or adjacent to, a CNL settlement that has extended beyond the CNL boundary;
b. the development is both: (i) located in – or next to - a settlement that is directly adjacent to the CNL; and (ii) overlooked from viewpoints within the CNL.
The Board considers that, in scenario (i), if a development would increase the number of dwellings in a settlement, and / or increase the area of a settlement, by more than 5% then the development would:
• be disproportionate;
• conflict with the requirement for the scale and extent of development to be limited;
• be likely to constitute major development.
The way in which this 5% ‘rule of thumb’ threshold has been derived is outlined below.
5 This approach is applied in the South Downs National Park, as outlined in paragraph 4.19 of the Landscape
Background Paper (link) for the South Downs Local Plan: ‘A site assessed as having high landscape sensitivity, or
medium-high landscape sensitivity where any development impact could not be fully mitigated, were generally
found unsuitable for housing development’. A relevant example for the Cotswolds National Landscape would be
the ‘Cotswolds (Wychavon) AONB and Environs – Landscape and visual sensitivity study’, which forms part of
the evidence base for the South Worcestershire Development Plan.
6 The CNL Landscape Strategy & Guidelines provides a strategy and guidelines for each landscape character
type (LCT) within the CNL. The most relevant LCT, in this, instance, is LCT 7 (High Wold) – see Section 7.1.
Similar points are made in relation to
8
The Board’s Landscape-led Development Position Statement (Appendix 5)7 provides a checklist of factors to consider when assessing whether a proposal within the CNL constitutes major development. One of the questions in the checklist, relating to the scale of development, is:
• Would it exceed 5% of the size of - and / or the number of dwellings in - the existing settlement?
The 5% ‘rule of thumb’ threshold relating to size is based on what is now paragraph 76 and footnote 36 of the NPPF, which relate to community-led development and which provide the NPPF’s only definition of what constitute ‘proportionate’.8 Paragraph 76 states that exception
sites for community-led development should be adjacent to existing settlements and proportionate in size to them. Footnote 36 defines ‘proportionate’, in this context, stating that ‘community-led development exception sites should not … exceed 5% of the size of the existing settlement’.
We acknowledge that this threshold relates to a specific type of housing development, specifically community-led development exception sites. However, we consider it to be an appropriate threshold to use more widely in the CNL, where a more restrictive approach should apply (i.e. where the scale and extent of development in National Landscapes should be limited).
The 5% ‘rule of thumb’ threshold relating to number of dwellings is partly based on the same definition of what is proportionate. It is also based on the assessment that was undertaken by South Downs National Park Authority to identify whether their potential Local Plan allocations
would be major development in the context of what is now paragraph 190 of the NPPF.9
In that assessment:
• a potential allocation of 20 dwellings in the village of Coldwaltham (population of 850) was considered to be major development in relation to scale – there were 421 dwellings
in Coldwaltham, so 20 dwellings would be a 4.8% increase (i.e. a 4.8% increase was considered to be major development);
• a potential allocation of 30 dwellings in the village of Greatham, which had 400 dwellings, was considered to be major development in relation to scale (i.e. a 7.5% increase was considered to be major development).
Whilst the 5% threshold has been derived in the context of major development, we consider that it should also be applied in the context of whether a development is proportionate and whether the scale and extent of development is limited.
For scenarios (ii)(a) and (ii)(b), a slightly less restrictive approach may be appropriate. We consider that a 10% threshold is appropriate in these scenarios.
7 Cotswolds National Landscape Board (2021) Landscape-led Development Position Statement (link 1- main
document; link 2 - appendices (see Appendix 5)).
8 Ministry of Housing, Communities and Local Government (2024) National Planning Policy Framework (link).
Paragraph 76 and footnote 36.
9
South Downs National Park Authority (2015) Assessment of Site Allocations against Major Development Considerations (link).
9
Tranquillity
One of the ‘special qualities’ of the CNL is the area’s relative tranquillity.10 As such, it is important that development in the CNL, or in its setting, does not adversely impact on the
tranquillity of the CNL.
A key consideration, in this regard, is the extent to which the proposed allocation would increase traffic movements on roads within – and / or along the boundary of – the CNL. As
outlined in Section 4.5 of the Board’s Tranquillity Position Statement we consider that increases in traffic movements of 10% or more are significant and are likely to have an adverse impact on tranquillity.11
We recommend that, as part of the Local Plan evidence base, the District Council should undertake an assessment of the extent to which the allocations both within the CNL and
outside it are likely to increase traffic movements on roads within – and / or along the boundary of – the CNL, including whether the 10% threshold is likely to be exceeded.
Dark Skies
One of the ‘special qualities’ of the CNL is the area’s dark skies.12 As such, it is important that development in the CNL, or in its setting, does not increase levels of light pollution, including sky glow, within the CNL.
In our assessments of the proposed site allocations, we have referred to CPRE’s Light Pollution
& Dark Skies map13 and assessed whether the proposed allocations are likely to have an adverse impact on the dark skies of the CNL. Proposed allocations should be required to comply with best practice guidance relating to dark
skies in protected landscapes, including the lighting guidance that was adopted by the Board in early 2025.
Major Development
For all of the proposed allocations within the CNL, we recommend that the District Council should undertake an assessment of whether the allocations constitute major development, in the context of paragraph 190 and footnote 67 of the National Planning Policy Framework.
If the District Council identifies that any of the allocations do constitute major development, they should undertake a further assessment to identify if (i) exceptional circumstances apply and (ii) the development would be in the public interest. If this is not the case then the allocation should not be taken forward.
A useful reference point for such an assessment is the major development assessments that were undertaken by South Downs National Park Authority for the allocations that were being considered for the South Downs Local Plan.14
10 Cotswolds National Landscape Board (2025) Cotswolds National Landscape Management Plan 2025-2030
(link). Chapter 4 – The special qualities of the Cotswolds National Landscape.
11 Cotswolds National Landscape Board (2019) Tranquillity Position Statement (link). Section 4.5.
12 Cotswolds National Landscape Board (2025) Cotswolds National Landscape Management Plan 2025-2030
(link). Chapter 4 – The special qualities of the Cotswolds National Landscape.
13 link
14 South Downs National Park Authority – Assessment of Site Allocations against Major Development
Considerations – 2015 (link) and 2017 (link).
10
The Board has provided its own analysis, in this regard, at least in terms of identifying whether the CNL allocations constitute major development, as outlined in our comments on each of the relevant allocations, below.
Further information and guidance on the issue of major development is provided in the CNL Management Plan15 and in the Board’s Landscape-led Development Position Statement16
.

The Cotswolds National Landscape (CNL) Board is not convinced that Area R is a suitable location for non-strategic development. We consider that the proposed allocation constitutes major development in the context of paragraph 190 of the National Planning Policy Framework.
For this allocation to be retained, the District Council would need to demonstrate that exceptional circumstances apply and that the allocation would be in the public interest. The
sustainability of the location (i.e. proximity to train connections) might contribute to this case but we are not convinced that the threshold of exceptional circumstances has been met.
We have put forward an alternative option, in which development would only extend as far west as the site entrance, in line with a suggestion that is made in the Housing and Economic Land Availability Assessment(HELAA). As indicated in the HELAA, this option would help to
moderate the impacts of the allocation. However, there would still be the significant issue of the allocation bearing very little relation to the settlement form / pattern of Kingham. As such, in the Board’s opinion, even this option would still constitute major development, in the context of
paragraph 190 of the NPPF.
Context
The Area R allocation is for 70 dwellings on a site covering approximately 8.3ha, adjacent to Kingham Station, between the villages of Kingham, in West Oxfordshire, and Bledington, in Cotswold District. It is located within the Cotswolds National Landscape (CNL).
Figure 55. Area R – Kingham Station
It is worth noting that the Housing and Land Availability Assessment shows a smaller site boundary (Ref: KING 005), covering approximately 3.3ha, as shown in the map below. Unlike the site boundary shown in the consultation document, this boundary does not include the
extension to the parking area at Kingham Station or the land immediately to the north or south of it.
Figure 56. Kingham sites considered in the West Oxfordshire Housing and Land Availability
Assessment (with the Kingham Station site identified as site ref: KING 005)138
Landscape character
Proportionality
As outlined above, in response to consultation question 2, the Board considers that a development at a CNL settlement would be disproportionate if it increased the number of
dwellings in the settlement (or the area of the settlement) by more than 5%.
According to the 2021 census, there were 165 households in the built-up area of Kingham, or 332 households across the parish as a whole.139 A 5% increase on this baseline would be 8-16 dwellings. The proposed allocation of 70 dwellings would represent a 21-42% increase (i.e. at
least four time larger than the Board’s 5% threshold).
On this basis, we consider the allocation to be disproportionate to the current number of
dwellings in Kingham. This seems particularly disproportionate for a Tier 4 settlement.
138 West Oxfordshire District Council (2025) West Oxfordshire Local Plan 2042. Housing and Economic Land
Availability Assessment (HELAA) 2025 (link). Map on digital page 218.
139 link. Search for Kingham.
93
Landscape character type
The CNL Landscape Character Assessment identifies 19 landscape character types (LCTs) in the CNL. The Area R site is located in LCT 17 (Pastoral Lowland Vale). More specifically, it is located in landscape character area 17B (Pastoral Lowland Vale – Vale of Moreton). 140 The West Oxfordshire Landscape Assessment identifies the landscape character type as ‘5 – Upper Evenlode Valley’.141
Relevant key features / characteristics of these LCTs include:
• Extensive pastoral vale with flat …land.
• Generally human scale, intimate landscape.
• Productive and verdant landscape of lush improved and semi-improved pastures.
• Network of hedgerows of varying height.
The Area R site and the neighbouring land provides a representative example of these key features /characteristics.
A development of 70 dwellings, covering approximately 8.3ha, would represent quite a substantial alteration to – and erosion of - this landscape character.
Impacts on landscape character would be further exacerbated if the landform was altered (for example, if the land was raised to reduce the risk of flooding on site).
Settlement form
The West Oxfordshire Design Guide identifies Kingham as being a nucleated settlement.142 The Design Guide provides the following description of nucleated settlements:
• Nucleated settlements are compact, with less dense development on the periphery of the central core. The tight-knit form of nucleated settlements makes them particularly
vulnerable to loss of character if development takes place beyond the fringes of the settlement.143
The Design Guide goes on to describe Kingham as follows:
• Large village located in the north-west of the District, in an open setting above the 115m contour. Today’s relatively unified form belies its original poly-focal form, centring on
Church St., West End, and The Green. An oval of roads has attracted generally loose-knit infill.
The proposed allocation at Area R would bear no relation to this settlement pattern. This is because it would be located approximately 400m from the existing built development in the settlement of Kingham or approximately 1.1km via the road network. As such, it is well beyond the fringes of the settlement. It is actually closer to the village of Bledington, in Cotswold District, at approximately 800m via the road network.
140 Cotswolds National Landscape Board (2004) Cotswolds National Landscape – Landscape Character
Assessment (link). 17 – Pastoral Lowland Vale (link).
141 West Oxfordshire District Council (1998) West Oxfordshire Landscape Assessment (link). 5: Upper Evenlode
Valley Landscape Character. Digital pages 81-85.
142 West Oxfordshire District Council (2016) West Oxfordshire Design Guide. 5 – Settlement Type (link), page 8.
143 West Oxfordshire District Council (2016) West Oxfordshire Design Guide. 5 – Settlement Type (link), page 4.
144 West Oxfordshire District Council (2016) West Oxfordshire Design Guide. 5 – Settlement Type (link), page 16.
94
There is some existing residential development along Station Road (B4450) on the opposite (east) side of the train line. There is also some existing industrial / business use development on the opposite side of Station Road, to the south. The site is directly adjacent to Kingham Station,
which would provide the option of car-free travel for residents travelling in the direction of Oxford / Reading / London or, in the opposite direction towards Moreton-in-Marsh / Evesham / Pershore / Worcester / Malvern. As such, there is some logic to locating the allocation at this
site, in terms of sustainability (i.e. reducing depends on cars). However, overall, it would strongly conflict with the existing settlement pattern and form.
Dark skies
One of the ‘special qualities’ of the CNL is the area’s dark skies.145 As such, it is important that development in the CNL, or in its setting, does not increase levels of light pollution, including sky glow, within the CNL.
The image below is an extract from CPRE’s Light Pollution and Dark Skies map. It shows that the Kingham station area already experiences some light pollution (colour band 4 (‘green’). A development of 70 dwellings would potentially increase this to colour band 5 (‘yellow’) or 6 (‘orange’). It would also spread the light pollution (colour band 4 (‘green’) or brighter) further west, such that the properties at the west end of Station Road, or even in the settlement of
Bledington, could be affected. The light pollution could also potentially spread northwards, to the area of housing on the south-western fringe of Kingham, and further east along Station Road.
In other words, the dark sky quality in two settlements could potentially deteriorate as a result of the proposed allocation. This is potentially a significant issue.
If the allocation is taken forward, development should be required to comply with best practice guidance relating to lighting in protected landscapes, including the lighting guidance recently adopted by the Board. Consideration should be given to offsetting the impact of the additional
lighting by ensuring that the whole of the Kingham station area (including the car park and the premises to the south of Station Road) complies with best practice guidance in this regard.
145 Cotswolds National Landscape Board (2025) Cotswolds National Landscape Management Plan 2025-2030
(link). Chapter 4 – The special qualities of the Cotswolds National Landscape.
Figure 57. Extract from the CPRE Light Pollution & Dark Skies map showing light pollution at Kingham
Tranquillity
One of the ‘special qualities’ of the CNL is the area’s relative tranquillity.146 As such, it is important that development in the CNL, or in its setting, does not adversely impact on the
tranquillity of the CNL.
146 Cotswolds National Landscape Board (2025) Cotswolds National Landscape Management Plan 2025-2030
(link). Chapter 4 – The special qualities of the Cotswolds National Landscape.
96
A key consideration, in this regard, is the extent to which the proposed allocation would increase traffic movements on roads within – and / or along the boundary of – the CNL. As
outlined in Section 4.5 of the Board’s Tranquillity Position Statement we consider that increases in traffic movements of 10% or more are significant and are likely to have an adverse impact on tranquillity.147
Given that the proposed allocation would increase the number of dwellings in Kingham parish by 21%, there is a risk that this 10% threshold could be exceeded.
To address this issue, we recommend that the District Council should undertake an assessment of likely increases in traffic movements as part of the local plan evidence base. If the
assessment identifies that the 10% threshold would be exceeded then this would be a significant issue.
Overall landscape sensitivity
As outlined above, the proposed Area R allocation would be disproportionate to the existing quantum of development at Kingham and would not reflect the settlement pattern / form. It would also adversely affect relevant key features / characteristics of the landscape. On this basis we consider the overall landscape sensitivity to be at least ‘high-medium’.
Visual Impact
Starting at the train station, there are glimpsed views of the site from the train station car park through the intervening fencing and vegetation.
Along the approach road to the station, there are one or two gaps in the dense hedge that provide clear views of the site.
Figure 58. View looking north-west, across the site, from the approach road to Kingham Station
(@ Grid Reference: SP256226)
147 Cotswolds National Landscape Board (2019) Tranquillity Position Statement (link). Section 4.5.
97
There is also a dense hedge on the southern boundary of Area R, along Station Road. The main exception is at the site entrance, directly opposite the entrance to the commercial / industrial units on the south side of Station Road, which provides an expansive view of the site.
Figure 59. View looking north, across the site, from the site entrance on Station Road, on the southern boundary of Area R (@ Grid Reference: SP256226)
Views of the site, from the south-west corner of the site, are limited, as shown below.
Figure 60. View looking north-east, across the site, from the south-west corner of the site on Station Road (@ Grid Reference: SP255225)
Overall, views of the site from the Kingham Station area and from Station Road are quite limited.
Housing on the site would be visible to only a limited degree due to the screening providing by the hedgerow on the north side of Station Road.
It is worth noting thatthe vast majority of people using the station and / ortravelling along Station Road are likely to be commuters who will driving, rather than recreational walkers, which reduces the sensitivity of these visual receptors.
Continuing west along Station Road, there is a footpath to the right (north) that follows the west bank of the River Evenlode (Gloucestershire Public Right of Way (PROW) Ref: Bledington
Footpath 21). This PROW is approximately 300m to the west of the Area R site. There is a significant amount of intervening vegetation, which makes intervisibility with the site very
limited. There are just a few locations that provide glimpsed views towards the site (with buildings in the vicinity of Kingham train station visible in these views). Housing on the Area R site would, therefore, only be visible to a limited degree from this PROW.
Figure 61. View looking east, towards the site, from Bledington Footpath21, on the west bank of
the River Evenlode (@ Grid Reference: SP251227)
There are additional PROWs, approximately 400m to the north-west and north of the site, but views towards the Area R site from these PROWs are also likely to be very limited.
Overall visual sensitivity
Overall, given the limited intervisibility between the site and publicly accessible viewpoints, we consider that the visual sensitivity of this site / allocation is not likely to exceed ‘medium’, even given the relatively large scale and extent of the proposed allocation.
Major development
As outlined above, the proposed Area R allocation would increase the number of dwellings in Kingham parish by approximately 21%. This is four times larger than the Board’s 5% threshold for proportionality. On this basis, we consider that the allocation constitutes major development (in relation to scale), in the context of paragraph 190 of the NPPF.
The Area R site is seven times larger than the threshold for major development that is set out in the Town and Country Planning (Development Management Procedure) (England) Order 2015, in terms of number of dwellings (i.e. 70 dwellings compared to the major development threshold
of 10 dwellings). It is also approximately eighttimes larger than the threshold for major development, in terms of area (i.e. approximately eight hectares compared to a threshold of
one hectare). Although these aren’t deciding factors, they are relevant considerations and add to the case for classing the proposed allocation as major development (in relation to scale).
We consider that the proposed allocation is also likely to have a significant adverse impact on the purpose of conserving and enhancing the natural beauty of the CNL, particularly with regards to landscape character (with visual impacts being less significant).
Overall, we consider that the proposed allocation constitutes major development, in the context of paragraph 190 of the NPPF.
In order for the allocation to proceed, the District Council would have to demonstrate that exceptional circumstances apply and that the development would be in the public interest. The sustainability of the location (i.e. proximity to train services) would be one relevant factor but we
are not convinced that this is sufficient to reach the required threshold.
Alternative Option
The Housing and Economic Land Availability Assessment (HELAA) states:
• If development was limited to the eastern flank of the site this would limit its impact in the
countryside and mirror the existing industrial estate to south.
148
The Board agrees that this suggestion would help to moderate the impact of the proposed allocation. Assuming that the quantum of proposed development was reduced accordingly, the allocation would also be more proportionate to the current number of dwellings in Kingham (and
would potentially not constitute major development, in relation to scale).
The suggested boundary for this alternative option is shown in the map below. This factors in the HELAA suggestion and the northern boundary shown in the HELAA map.
Figure 62. Alternative option for the Area R allocation at Kingham Station
148 West Oxfordshire District Council (2025) West Oxfordshire Local Plan 2042. Housing and Economic Land
Availability Assessment (HELAA) 2025 (link). Site Reference KING 005 (land adjacent to Kingham Station), digital
page 223.
100
In this option, built development should only extend westwards as far as the east side of the current site entrance. Standing at the site entrance, views looking in a north-westerly direction across the site would maintain a rural character. This option would also help to limit visual
impacts when viewed from Station Road to the south-west of the site. This option would also help to avoid development taking place in Flood Zones 2 and 3.
The Board considers that this would be a preferable option to allocating the whole site shown in the consultation document map. However, there would still be the significant issue of the site bearing very little relation to the settlement form of Kingham. As such, in the Board’s opinion, even this option would constitute major development in the context of paragraph 190 of the NPPF (albeit with less harmful impacts than allocating the whole site).
Other issues
Sewage / sewerage
The Board is concerned about the capacity of the sewerage system to deal with the additional sewage from this site allocation. The Housing and Economic Land Availability Assessment makes the following statement in this regard:
• Chipping Norton STW (which serves the area) cannot manage incoming volumes of sewage resulting in untreated discharges during wet weather. Upgrades by Thames Water are due to be completed by 2027 to increase treatment capacity.
149
Provided that these upgrades are completed prior to the commencement of development – and that the increased capacity is demonstrated to be sufficient – we are satisfied that this issue would be adequately addressed.
Facilities
In order to reduce the number of short car journeys from the allocation, once developed, the Board recommends that the District Council should require a shop / convenience store as part of this allocation. This could potentially be located at the train station, if there is capacity to do so. Presumably, pedestrian access would be provided directly between the allocation and the train station, rather than residents having to access the train station via Station Road.
Bus services between Kingham village, Bledington village, the allocation, the train station and settlements further afield, such as Chipping Norton, should also be improved to help reduce private car use.

The Cotswolds National Landscape (CNL) Board considers that the Area P option is potentially a suitable location for non-strategic development but not as currently proposed.
119 West Oxfordshire District Council (2025) West Oxfordshire Local Plan 2042. Housing and Economic Land
Availability Assessment (HELAA) 2025 (link). Site Ref: CHAR 004, digital page 100.
We acknowledge that the site is identified as being suitable for housing in the Housing and Economic Land Availability Assessment.
120 However, we consider that Area P would only be the
suitable if one of the Board’s two suggested alternative options is used (with Option 1 being preferable from a CNL perspective).
Even with these options, we have some residual concerns regarding pedestrian access, particularly if this was to involve upgrading access along Fawler Road. Further clarity is required on this issue.
Context
The proposed allocation at Area P is for a residential development of 40 dwellings on the southern edge of Charlbury, within the Cotswolds National Landscape (CNL). It is one of two proposed allocations at Charlbury, the other being Area O (Jeffersons Piece) at the northern edge of Charlbury, which also has an indicative capacity of 40 dwellings. As such, the total quantum of development proposed for allocations at Charlbury is 80 dwellings.
From the map in the consultation document (see below), it is not clear exactly what the southern or eastern boundaries of the site. Based on the boundary shown in this map, the
boundary is approximately three hectares.
Figure 42. Charlbury site allocations, including Area P
However, the Housing and Land Availability Assessment identifies a larger area for this site (Ref: CHAR 006), covering approximately 5.4ha, as shown below:
120 West Oxfordshire District Council (2025) West Oxfordshire Local Plan 2042. Housing and Economic Land
Availability Assessment (HELAA) 2025 (link). Site Ref: CHAR 006, digital page 102.
Figure 43. Charlbury sites in the West Oxfordshire Housing and Land Availability Assessment (with the relevant site being CHAR 006)121
Landscape character
Proportionality
As outlined above, in response to consultation question 2, the Board considers that a development at a CNL settlement would be disproportionate if it increased the number of
dwellings in the settlement (or the area of the settlement) by more than 5%.
According to the 2021 census, there were 1,276 households in the built-up area of Charlbury, or 1,396 households across the parish as a whole.122 A 5% increase on this baseline would be 67-69 dwellings. The proposes allocation of 40 dwellings would represent a 3.1% increase (i.e. below
the 5% threshold). However, when both Charlbury allocations are factored in (i.e. 80 dwellings), the increase would be 5.7-6.3% (i.e. just above the 5% threshold).
So, individually, the allocations would not be disproportionate. However, collectively, they would
exceed the 5% threshold (albeit to a limited degree).
Landscape character types
The CNL Landscape Character Assessment identifies 19 different landscape character types across the CNL. Area O is located in LCT 16 (Broad Floodplain Valley), as is the whole of
121 West Oxfordshire District Council (2025) West Oxfordshire Local Plan 2042. Housing and Economic Land
Availability Assessment (HELAA) 2025 (link). Map on digital page 96.
122 link. Search for Charlbury.
Charlbury.123 More specifically, it is located in Landscape Character Are 16B (Broad Floodplain
Valley – Lower Evenlode Valley). In the West Oxfordshire Landscape Assessment, it is located in LCT 6 (Lower Evenlode Valley), within a section that is identified as ‘semi-enclosed limestone wolds (large-scale)’.124
Key features / characteristics of these LCTs that are relevant to the allocation site include the following:
• Intimate, small scale, settled … landscape.
• Gentle convex slopes.
• Valley sides cloaked in improved pasture and arable land.
• Fields defined by hedgerows and some stone walls.
The landscape character of the site, in relation to land use, has been somewhat obscured by the recent earthworks that have taken place on site (see photographs below), However, from Google Earth satellite images, it appears that the north-western half of the site has had an agricultural land use (although it is not clear if this was pastoral or arable). It appears that the southern and eastern sections of the site have had an equestrian land use (i.e. paddocks)
associated with the adjacent Pioneer Equestrian Coaching business, to the south. This equestrian land use is not a characteristic feature of this landscape character type.
The site has the gentle convex slopes that are characteristic of this landscape character type, with the land sloping down in a south-westerly direction. However, from a site visitin November 2025, it appears that the landform has already been altered, to some degree, in recent months.
This can be seen by comparing a Google Street View image of the site entrance, from April 2025, with a site visit photograph from November 2025.
Figure 44. Google Street View image of the Area P site, viewed from the site entrance on Fawler Road, April 2025
123 Cotswolds National Landscape Board (2004) Cotswolds National Landscape – Landscape Character
Assessment (link). 16 – Broad Floodplain Valley (link).
124 West Oxfordshire District Council (1998) West Oxfordshire Landscape Assessment (link). 6: Lower Evenlode
Valley (digital pages 87-91).
Figure 45. Panoramic view of the north-western section of the Area P site from the site entrance on Fawler Road, November 2025
The earthworks can also be seen in westward looking views from the Oxfordshire Way, just to the south of Charlbury, at the east end of the site, as shown below.
Figure 46. View looking west, towards the Area P site, from the Oxfordshire Way bridleway (PROW Code: 156/21/20), at the east end of the site (@ Grid Reference: SP364186)
In this photograph, it looks like the north-western corner of the site (on the right hand side of the photograph, in the middle distance) has been raised and the sloping topography levelled.
We are very concerned that these works have taken place when there is no planning permission for residential development and the site has not yet been allocated. We suspect this to be a breach of planning regulations.
The site currently has residential development to the north and one property (Baywell House) and an equestrian centre to the south. The land to the west and east is undeveloped. The allocation would clearly be a southern extension to the settlement, albeit contained, to some degree, by the existing development to the south.
It is not clear, from the map in the consultation document, exactly what, or where, the southern and eastern boundaries of the site would be. For example, it is not clear if the boundaries wold confirm to the existing field pattern. This is an important consideration because the West
Oxfordshire Landscape Assessment states that:
• ‘smaller-scale, limestone wold landscapes [within the Lower Evenlode Valley landscape character type] on the immediate fringes of the larger settlements are potentially more
tolerant of development if it conforms to existing field pattern, is sensitively designed and does not significantly alter settlement form’.
If the allocation does not conform to the existing field pattern, that would make the allocation less acceptable. However, if the allocation occupies the full area shown for site CHAR 006 in the Housing and Economic Land Availability Assessment, that would also increase the significance
of any adverse impacts.
Further clarity is required, from the District Council, on the exact allocation boundaries.
One straightforward option, in this regard, would be to limit development to the most northwesterly field (shown in the images / photographs above) and reduce the quantum of
development accordingly
Settlement form
The West Oxfordshire Design Guide identifies Charlbury as being a nucleated settlement.125
The Design Guide provides the following description of nucleated settlements:
• Nucleated settlements are compact, with less dense development on the periphery of the central core. The tight-knit form of nucleated settlements makes them particularly
vulnerable to loss of character if development takes place beyond the fringes of the settlement.126
The Design Guide goes on to that that:
• Charlbury forms a relatively compact valley-side settlement, lying mainly between the 91m and 122m contours. Development is constrained by the river Evenlode and the railway line to the south-west.
127
The existing housing on the south side of Woodstock Road / Stonesfield Lane at the south end of Charlbury sets a clearly defined southern boundary / limit to the extent of built development in Charlbury. Area P lies to the south of this housing. As such, Area P could be said to be beyond
the fringe of the settlement. However, this is moderated, to a limited degree, by the presence of Baywell House and Pioneer Equestrian Coaching to the south of the site. It would be a more obvious extension to the settlement than the proposed allocation at Area O.
125 West Oxfordshire District Council (2016) West Oxfordshire Design Guide. 5 – Settlement Type (link), page 6.
126 West Oxfordshire District Council (2016) West Oxfordshire Design Guide. 5 – Settlement Type (link), page 4.
127 West Oxfordshire District Council (2016) West Oxfordshire Design Guide. 5 – Settlement Type (link), page 13.
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Dark skies
One of the ‘special qualities’ of the CNL is the area’s dark skies.128 As such, it is important that development in the CNL, or in its setting, does not increase levels of light pollution, including sky glow, within the CNL.
The image below is an extract from CPRE’s Light Pollution and Dark Skies map. It shows that Charlbury already has fairly high levels of light pollution, with the town centre being in colour band 7 (‘pink’), which is the third highest level of brightness on the brightness scale. The effects
of this light pollution extend to the allocation site, most of which is in colour band 4 (‘green’).
Figure 47. Extract from CPRE’s Light Pollution and Dark Skies maps showing light pollution at Charlbury
128 Cotswolds National Landscape Board (2025) Cotswolds National Landscape Management Plan 2025-2030
(link). Chapter 4 – The special qualities of the Cotswolds National Landscape.
The development of the allocation site would increase light pollution levels to a limited degree.
For example, colour bands 5 (‘yellow’) and 4 (‘green’) are likely to extend further south / southwest as a result of the development.
Overall, this is not likely to be a deciding factor in whether or not the allocation is acceptable.
However, adverse impacts on dark skies could be moderated by only allocating the most northwesterly field in the Area P area.
If the allocation is taken forward, development should be required to comply with best practice guidance relating to lighting in protected landscapes, including the lighting guidance recently adopted by the Board. Consideration should be given to offsetting the impact of the additional
lighting by ensuring that the whole of Burford complies with best practice guidance in this regard.
Tranquillity
One of the ‘special qualities’ of the CNL is the area’s relative tranquillity.129 As such, it is important that development in the CNL, or in its setting, does not adversely impact on the
tranquillity of the CNL.
A key consideration, in this regard, is the extent to which the proposed allocation would increase traffic movements on roads within – and / or along the boundary of – the CNL. As
outlined in Section 4.5 of the Board’s Tranquillity Position Statement we consider that increases in traffic movements of 10% or more are significant and are likely to have an adverse impact on tranquillity.130
Given that the proposed allocation would increase the number of dwellings in Charlbury by less
than 10%, it is unlikely that the 10% traffic movement threshold would be exceeded, at least on
Charlbury’s through roads.
On this basis, we do not consider that the impact of increased traffic movements is likely to be a
deciding factor in whether or not the allocation is acceptable, at least from a CNL perspective.131
Other landscape considerations
The consultation document does not clarify where the vehicular access for this allocation would be. Presumably it would be via the current entrance on Fawler Road. Upgrading the access to the 129 Cotswolds National Landscape Board (2025) Cotswolds National Landscape Management Plan 2025-2030
(link). Chapter 4 – The special qualities of the Cotswolds National Landscape.
130 Cotswolds National Landscape Board (2019) Tranquillity Position Statement (link). Section 4.5.
131 These comments do not factor in issues such as road safety or the practicalities of providing access via
Jefferson Piece eastern site entrance, on the Oxfordshire Way, via Stonesfield Lane would not be appropriate.
Such an upgrade would significantly increase the landscape impacts of the allocation. It wouldalso conflict with the CNL Landscape Strategy & Guidelines, which addresses the implications of road upgrading and improvements.132
With regards to pedestrian access, the consultation document states:
• The site area is a little isolated from the settlement due to lack of pavement connections, but this could be achieved via the public right of way off Woodstock Road to the north.
However, if the only pedestrian access point is via this public right of way (PROW) this would make it a very long walk into town (approximately 1.6km) for those people who live in the
western part of the site.
Pedestrian access via the north west corner of the site would enable quicker access to the town centre facilities, cutting the walking distance from approximately 1.6km to approximately 900m.
However, there are no access points along Woodstock Road and there would be significant challenges with providing pedestrian access from Fawler Road.
In its current state, Fawler Road would not provide safe pedestrian access because of the lack of a pavement and because of cars approaching, at speed, around curves in the road (particularly south of the 20mph speed limit sign). However, if a pavement is installed along Fawler Road this
would entail earthworks into the steep-sided road verge and would have a suburbanising effect on the currently rural, ‘sunken lane’ perception of this road. These works would also potentially increase the extent to which the Hydac buildings could be seen from Fawler Road. Such changes
would have a significant, adverse landscape and visual impact, particularly if the pavement extended to the current site entrance on Fawler Road.
In the Board’s opinion, these factors severely limit the practicalities of allocating this site.
Landscape sensitivity ranking
The overall landscape sensitivity depends, to some degree, on whether the allocation would follow existing field patterns. If the allocation extended mid-way between field boundaries (as indication on the map in the consultation document) and / or extended, uphill, to the eastern entrance on the West Oxfordshire Way, we consider that the landscape sensitivity would be high-medium. If existing field patterns are followed, we consider thatthe landscape sensitivity is not likely to exceed medium.
Visual Impact
The number of locations from where the site can be (clearly seen) is relatively limited. The main locations are:
• the site entrance on Fawler Road;
• the site entrance on the Oxfordshire Way, to the east of the site; and
• the footpath that runs through Lower Park, in the Grade II* Cornbury Park, on the opposite side of the Evenlode valley.
•
132 For example, the issue of road upgrading and improvements is addressed in Section 16.7 of the CNL
Landscape Strategy & Guidelines for Landscape Character Type 16 – Broad Floodplain Valley (link)
View from Fawler Road
As one heads south, out of Charlbury, on Fawler Road (i.e. the B4022), the roadside verge on the east side of Fawler Road rises up above the road level, creating the perception of a sunken lane.
The height of the verge, combined with the hedge that is at the top of the verge means that car users are unlikely to see housing that is built on the Area P site, especially if the housing is set back from the road.
The only point on Fawler Road where the site can be clearly seen is at the site entrance, as shown in Figure 45 above. The magnitude of change in this view would be large. However, this would only be a glimpsed view for motorists who would be passing by at some speed. There are unlikely to be many pedestrians, or recreational walkers, passing this entrance as it is not a safe section of road to walk on (because of fast moving vehicles approaching rounds bends in the
road) and because there are no public rights of way connecting with this road further south.
The most north-westerly corner of the site can be briefly seen, across this entrance, when one is approaching Charlbury from the south. However, these would also be very brief, glimpsed views.
Overall, the visual impact of the development, when viewed from Fawler Road is not likely to be significant.
View from the Oxfordshire Way
The Oxfordshire Way heads south-east out of Charlbury and passes by an entrance to the site just after the housing and gardens to the south of Stonefield Lane have been passed. The view that is experienced at this site entrance is shown in Figure 46 above. Whilst this would just be a glimpsed view, for walkers passing by, it is notable (and merits a stop) because of the expansive view that it provides across the Evenlode valley to Cornbury Park on the west side of the river.
The visual impacts of the development would depend on the extent of built development, which is not clear from the map that is provided in the consultation document. For example, if
development just took place in the most north-westerly field on the Area P site, the impacts would be fairly limited (i.e. the visual sensitivity would not exceed medium) However, if
development extended all the way to this point, the expansive view across the Evenlode Valley would partially, or potentially completely, blocked (i.e. the visual sensitivity would be highmedium to high).
At the moment, Stonesfield Lane and the section of the Oxfordshire Way to the north of this site entrance are very minor tracks / lanes. However, if it was intended that this entrance would provide vehicular access then the visual impacts, the upgrades that would be required would
increase the visual impacts significantly.
Heading further south on the Oxfordshire Way, there is a fairly dense hedge that blocks views onto the site, so the main visual impact is at the site entrance location.
View from public right of way at Lower Park
The photograph from the site entrance on the Oxfordshire Way shows a high level of intervisibility between the site, especially its more elevated sections, and Cornbury Park on the far side of the Evenlode valley to the west.
This is reflected in the fact that the site is partially visible from PROW 175/1/40 (and National Cycle Network Route 442) in Cornbury Park, as shown in the photograph below.
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Figure 48. View looking east, towards the Area P site, from PROW 175/1/40 (and National Cycle Network Route 442) in Cornbury Park (@ Grid Reference: SP355186)
In this photograph (and in the wider panorama from this viewpoint), some of the residential development in the vicinity of Woodstock Road is visible but Charlbury, as a whole, is well screened. Just to the south of this housing (to the right on the photograph) the most northwesterly field of the Area P site can be seen as bare earth. The intervening vegetation screens the rest of the site to a large degree, although the more elevated sections of the fields can be
seen.
If the whole of the site is developed, the housing on the upper slopes and in the north-western field would be clearly seen. Although this new housing would only a relatively small part of a wider panorama, it would make the settlement of Charlbury a more prominent feature in these views. In this scenario, we would consider the visual sensitivity to be high-medium.
If only the lower slopes are developed, then the visual sensitivity would probably not exceed medium (as long as appropriate landscape mitigation measures are implemented).
Visual sensitivity ranking
The overall visual sensitivity depends on whether the allocation / built development would include the upper elevations of the site. If it does, we would consider the visual sensitivity to be ‘high-medium’. If it doesn’t, we consider that the visual sensitivity would probably not exceed ‘medium’.
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Historic Environment
Charlbury Conservation Area
The Area P site is located within the Charlbury Conservation Area.
Figure 49. Charlbury Conservation Area (with the Area P site shown with a red boundary)133
Policy EH10 of the adopted West Oxfordshire Local Plan 2031 states that ‘proposals for development in a Conservation Area or affecting the setting of a Conservation Area will be
permitted where it can be shown to conserve or enhance the special interest, character, appearance and setting’.134
The Board considers that the proposed development is potentially acceptable in this regard.
However, we recommend that the District Council should seek expert advice on this issue to identify whether the proposed allocation would be appropriate in the Conservation Area.
Cornbury Park and Cornbury House
The Area P site is located in the setting of:
• Cornbury Park, which is Grade II* listed on the Register of Parks and Gardens;
133 link
134 West Oxfordshire District Council (2018) West Oxfordshire Local Plan 2031 (link). Policy EH10 (Conservation
areas), page 136.
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• Cornbury House, which is a Grade I listed building.
As outlined above, in relation to visual impacts, development on the Area P site would have and adverse visual impact on views from public rights of way (PROW) within Cornbury Park. In the context of the historic environment, impacts on views from across the wider Park are also a relevant consideration. The Park rises to approximately 150m AOD in the vicinity of Tower Light / Towerlight Gate. This is 55m higher than the PROW near the eastern boundary of the site and
25m higher than the highest point of the Area P site.
As such, it is likely that the Area P site could be seen more clearly than at the PROW near the eastern edge of the Park. For example,the intervening vegetation, in the vicinity of Fawler Road, would not block these views. The trees in Cornbury Park itself would filter the views to some
degree. However, there are likely to be some locations within the Park that have relatively clear views of the Area P site.
Cornbury House, itself, has a relatively elevated position at approximately 125m AOD, so there may be clear views of the Area P site from Cornbury House, particularly from the upper floors of the house.
We recommend that the District Council should undertake an assessment of the likely visual impact on these heritage assets.
Grim’s Ditch
The scheduled monument of Grim’s Ditch is located on the opposite (western) side of Fawler Road from Area P, close to the site entrance, as shown in the Charlbury allocations map, above.
This section of Grim’s Ditch is part of a larger set of Iron Age earthworks know as the north Oxfordshire Grim’s Ditch, as shown in the map below.
The dashed red line from this section of Grim’s Ditch to the section in the vicinity of Ditchley Park indicates that the Ditch may have run through Area P. As such, Area P is an important
component of the setting of Grim’s Ditch, with development on the site potentially having an adverse impact in this regard. Further historic environment assessments may be required to determine the impacts of the proposed allocation on the setting of Grim’s Ditch.
If the site is allocated and developed this may require improvements to Fawler Road in the vicinity of the site entrance (for example, road widening). This could potentially have a direct adverse impact on the Grim’s Ditch scheduled monument. If the site is allocated, this issue should be explicitly addressed in the site allocation information in the Local Plan.
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Figure 50. Grim’s Ditch in north Oxfordshire135
Major development
The Area P site is four times larger than the threshold for major development that is set out in the Town and Country Planning (Development Management Procedure) (England) Order 2015,
in terms of number of dwellings (i.e. 40 dwellings compared to the major development threshold of 10 dwellings). It is also approximately five times larger than the threshold for major
development, in terms of area (i.e. approximately five hectares compared to a threshold of one hectare). However, whilst these are relevant considerations, they are not necessarily deciding factors for what constitutes major development in the context of paragraph 190 of the NPPF.
A more significant factor, with regards to scale, is whether the allocation is proportionate to the settlement. In this instance, the allocations would be below the Board’s 5% threshold for
proportionality. As such, we do not consider the allocation to be major development, in terms of scale. However, consideration should also be given to the cumulative amount of housing that the two proposed allocations in Charlbury would provide, which would exceed this 5% threshold
(albeit to a limited degree).
If the allocation boundary does not follow existing field patterns and / or if the allocation include the higher elevations of the site,then there could be a significant adverse impact on the purpose of conserving and enhancing the natural beauty of the CNL. In this scenario, we
consider that the allocation would constitute major development. If the allocation follows
135 link
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existing field boundaries and does not include the higher elevations of the site, we consider that the allocation would not constitute major development.
Overall, whether the allocation constitutes major development, in the context of paragraph 190
of the NPPF, depends on the points outlined above.
Alternative Options
As outlined above, the Board considers that the allocation should follow existing field boundaries but should not extend onto the higher elevations of the site. This calls into question
what the appropriate boundary would be when both of these considerations are factored in.
To address this issue, it is useful to consider the historical field boundaries in this locality. The image below shows a merged extract from two Ordnance Survey six-inch maps published in 1923 – Oxfordshire Sheet XXI136 and Oxfordshire Sheet XXVI137
.
Figure 51. Extract from Ordnance Survey six-inch maps published in 1923.
An almost identical field pattern is shown in the Google Earth Pro image below, from 1945.
136 link
137 link
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Figure 52. Google Earth Pro image from 1945
Based on these historic field patterns and the points outlined above, we consider that the following two options could be suitable.
Option 1
In the Option 1 scenario, the allocation would be confined to the most north-westerly field. The total quantum of housing would need to be reduced accordingly.
The most easterly boundary would not extend into the far eastern corner of the field. Instead, it would (briefly) follow the line of the historic field boundary shown in the images above.
One residual concern with this option is the issue of pedestrian access (see comments above).
This would need to be resolved in a way that does not entail upgrading pedestrian access along Fawler Road.
Figure 53. Alternative Option 1 (with the allocation boundary shown as a red line).
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Option 2
In Option 2, the allocation would extend southwards towards Baywell House and Pioneer Equestrian Coaching. The total quantum of housing would need to be amended accordingly.
The eastern boundary would follow the historic field boundary shown in the images above. This eastern boundary approximately follows the 115m contour line.
As with Option 1, a residual concern is the issue of pedestrian access (see comments above).
This would need to be resolved in a way that does not entail upgrading pedestrian access along Fawler Road.
Figure 54. Alternative Option 2 (with the allocation boundary shown as a red line).
Conclusions and recommendations
The Board conclusions on the Area P allocation depend on the proposed extent of the allocation (which is not clear from the map provided in the consultation document).
If the allocation does not follow existing (or historic) field boundaries and / or if it includes the more elevated slopes (for example, above the 115m contour line) we consider that the landscape and visual sensitivity is likely to be ‘high-medium’. Impacts on the historic environment would also be significant. In these scenarios, we consider that the allocation would constitute major development in the context of paragraph 190 of the NPPF.
However, we consider that the alternative options outlined above would potentially be acceptable (if appropriate landscape mitigation measures are implemented). In these scenarios, we consider that the landscape and visual sensitivity would not exceed ‘medium’ and the
impacts on the historic environment would not be significant. In this scenario, the allocation would not constitute major development in the context of paragraph 190 of the NPPF.
Even with these two options, we would still have some concerns about the issue of pedestrian access and how this would be addressed. In particular, we would be concerned about any potential upgrading of pedestrian access along Fawler Road. Further clarity is needed on how this issue would be resolved.

The Cotswolds National Landscape (CNL) Board considers that Area O potentially is a suitable location for non-strategic development, subject to the recommendations and landscape mitigation measures that we have outlined below.
Context
The proposed allocation at Area O is for a residential development of 40 dwellings on a site covering approximately two hectares, on the northern edge of Charlbury, within the Cotswolds National Landscape (CNL). It is one of two proposed allocations at Charlbury, the other being Area P (Land south of Hydac), at the southern edge of Charlbury, which also has an indicative
capacity of 40 dwellings. As such, the total quantum of development proposed for allocations at Charlbury is 80 dwellings.
106 linkplanning-decisions#ancient-woodland
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Figure 36. Charlbury site allocations, including Area O
Landscape character
Proportionality
As outlined above, in response to consultation question 2, the Board considers that a development at a CNL settlement would be disproportionate if it increased the number of
dwellings in the settlement (or the area of the settlement) by more than 5%.
According to the 2021 census, there were 1,276 households in the built-up area of Charlbury, or 1,396 households across the parish as a whole.107 A 5% increase on this baseline would be 67-69 dwellings. The proposes allocation of 40 dwellings would represent a 3.1% increase (i.e. below
the 5% threshold). However, when both Charlbury allocations are factored in (i.e. 80 dwellings), the increase would be 5.7-6.3% (i.e. just above the 5% threshold).
So, individually, the allocations would not be disproportionate. However, collectively, they would
be (albeit to a limited degree).
Landscape character types
The CNL Landscape Character Assessment identifies 19 different landscape character types across the CNL. Area O is located in LCT 16 (Broad Floodplain Valley), as is the whole of
Charlbury.108 More specifically, it is located in Landscape Character Are 16B (Broad Floodplain
Valley – Lower Evenlode Valley). In the West Oxfordshire Landscape Assessment, it is located in
107 link. Search for Charlbury.
108 Cotswolds National Landscape Board (2004) Cotswolds National Landscape – Landscape Character
Assessment (link). 16 – Broad Floodplain Valley (link).
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LCT 6 (Lower Evenlode Valley), within a section that is identified as ‘semi-enclosed limestone
wolds (large-scale)’.109
Key features / characteristics of these LCTs that are relevant to the allocation site include the
following:
• Intimate, small scale, settled … landscape.
• Gentle convex slopes.
• Valley sides cloaked in improved pasture and arable land.
• Fields defined by hedgerows and some stone walls.
However, the West Oxfordshire Landscape Assessment indicates that the semi-enclosed limestone wolds section of the Lower Evenlode Valley are characterised by large-scale farmland and the land use being dominated by intensive agriculture with only occasional pasture.
The site has an improved pasture character, rather than large-scale, intensive agriculture. The allocation would result in the loss of this improved pasture land. However, this is probably not of sufficient significance, in its own right, to over-ride the need for the development.
The site slopes down in a north-westerly direction. However, the topography is probably gentle enough that development could be accommodated without significantly changing the landform.
Presumably, characteristic field boundaries, including hedgerows and stone walls, would be retained and, where appropriate, restored.
The West Oxfordshire Landscape Assessment states that ‘smaller-scale, limestone wold landscapes [within the Lower Evenlode Valley landscape character type] on the immediate fringes of the larger settlements are potentially more tolerant of development if it conforms to existing field pattern, is sensitively designed and does not significantly alter settlement form’. In the context of potential impacts on key features / characteristics, we consider that this is probably
true of Site O.
Overall, we consider that the proposed allocation would have a limited impact on the key features / characteristics of the relevant landscape character types.
Settlement form
The West Oxfordshire Design Guide identifies Charlbury as being a nucleated settlement.
110
The Design Guide provides the following description of nucleated settlements:
• Nucleated settlements are compact, with less dense development on the periphery of the central core. The tight-knit form of nucleated settlements makes them particularly
vulnerable to loss of character if development takes place beyond the fringes of the settlement.111
The Design Guide goes on to that that:
109 West Oxfordshire District Council (1998) West Oxfordshire Landscape Assessment (link). 6: Lower Evenlode
Valley (digital pages 87-91).
110 West Oxfordshire District Council (2016) West Oxfordshire Design Guide. 5 – Settlement Type (link), page 6.
111 West Oxfordshire District Council (2016) West Oxfordshire Design Guide. 5 – Settlement Type (link), page 4.
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• Charlbury forms a relatively compact valley-side settlement, lying mainly between the 91m
and 122m contours. Development is constrained by the river Evenlode and the railway line
to the south-west.
112
Whilst Area O is on the north-eastern edge of the settlement, it wouldn’t be classed as ‘beyond the fringes of the settlement’. This is because there is existing built development to the east of the site and a couple of houses to the north of the site, along Hundley Way. In fact, with the
existing residential development to the south and east, and with the couple of houses to the north, development of the site could, arguably, be classed as infill development.
However, the site is located above the 122m contour, referred to about, with most of the site being above 135m in elevation. This would make it the most elevated development in Charlbury, with the exception of the housing immediately to the south and east. A larger area exceeds the
122m contour threshold, including all the housing between the site and ‘The Slade’ (the B road that goes around the eastern side of the town centre).
Given that the neighbouring built development already exceeds these thresholds, we do not consider that the proposed allocation would adversely affect the settlement form (at least not to a significant degree).
Dark skies
One of the ‘special qualities’ of the CNL is the area’s dark skies.113 As such, it is important that development in the CNL, or in its setting, does not increase levels of light pollution, including sky glow, within the CNL.
The image below is an extract from CPRE’s Light Pollution and Dark Skies map. It shows that Charlbury already has fairly high levels of light pollution, with the town centre being in colour band 7 (‘pink’), which is the third highest level of brightness on the brightness scale. The effects of this light pollution extend to the allocation site, most of which is in colour band 4 (‘green’).
The development of the allocation site would increase light pollution levels to a limited degree.
For example, colour bands 5 (‘yellow’) and 4 (‘green’) are likely to extend further north and east as a result of the development. The relatively ‘contained’ nature of the site would help to moderate these impacts.
Overall, this is not likely to be a deciding factor in whether or not the allocation is acceptable.
However, the Board’s suggestion of only allocating the eastern half of the site would help to further moderate these impacts as this would avoid the more exposed western slopes of the site.
If the allocation is taken forward, development should be required to comply with best practice guidance relating to lighting in protected landscapes, including the lighting guidance recently adopted by the Board. Consideration should be given to offsetting the impact of the additional
lighting by ensuring that the whole of Burford complies with best practice guidance in this regard.
112 West Oxfordshire District Council (2016) West Oxfordshire Design Guide. 5 – Settlement Type (link), page 13.
113 Cotswolds National Landscape Board (2025) Cotswolds National Landscape Management Plan 2025-2030
(link). Chapter 4 – The special qualities of the Cotswolds National Landscape.
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Figure 37. Extract from CPRE’s Light Pollution and Dark Skies maps showing light pollution at Charlbury
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Tranquillity
One of the ‘special qualities’ of the CNL is the area’s relative tranquillity.114 As such, it is important that development in the CNL, or in its setting, does not adversely impact on the
tranquillity of the CNL.
A key consideration, in this regard, is the extent to which the proposed allocation would increase traffic movements on roads within – and / or along the boundary of – the CNL. As
outlined in Section 4.5 of the Board’s Tranquillity Position Statement we consider that increases in traffic movements of 10% or more are significant and are likely to have an adverse impact on tranquillity.115
Given that the proposed allocation would increase the number of dwellings in Charlbury by less than 10%, it is unlikely that the 10% traffic movement threshold would be exceeded, at least on Charlbury’s through roads. However, there may be some localised increases in traffic
movements on the residential streets through which vehicle access to the site would be provided (such as Chartwell Drive, The Green, Kendal Piece, Elm Crescent and Jeffersons
Piece).
Provided that the impact of additional traffic on the roads referred to above can be made acceptable, we do not consider that the impact of increased traffic movements is likely to be a deciding factor in whether or not the allocation is acceptable, at least from a CNL perspective.
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Visual Impact
A public right of way (PROW), a bridleway, that runs along the north-western boundary of the site (PROW Code: 156/10/10), on Hundley Way. There are views into the site along the full
length of this boundary (a distance of approximately 140m) although the views are partially filtered by the vegetation (primarily trees) along the boundary, as shown below.
The existing built development beyond the site boundary, to the south, can be seen on the skyline. The allocation would make residential development more prominent in these views.
There are no other publicly accessible viewpoints directly adjacent to the settlement.
The allocation could potentially affect views from the PROW (a footpath) to the north of the B4022, north-west of the site (PROW code: 156/8/1). However, in reality, this impact is likely to be negligible, as outlined below.
114 Cotswolds National Landscape Board (2025) Cotswolds National Landscape Management Plan 2025-2030
(link). Chapter 4 – The special qualities of the Cotswolds National Landscape.
115 Cotswolds National Landscape Board (2019) Tranquillity Position Statement (link). Section 4.5.
116 These comments do not factor in issues such as road safety or the practicalities of providing access via
Jefferson Piece.
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Figure 38. View, looking south, into the Area O site, from PROW 156/10/10 on Hundley Way
Approaching the B4022 along this PROW from the north, as it starts to descend into the valley, the existing housing on Hundley Way, including the house immediately to the west of the Area O site, is clearly visible straight ahead. However, the Area O site is, to a large degree, obscured by the hedgerow that is adjacent to the PROW. There would be some visual intervisibility but this would be mainly the upper stories and roofs of a few of the houses closest to Hundley Way.
Figure 39. View looking south-east, towards the Area O site, from PROW 156/8/1 near the top of the slope to the north of the B4022 (@ Grid Reference: SP359203)
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Heading further south on this PROW, down the valley slop, the existing housing on Hundley Way is clearly visible straight ahead but the Area O site is even more obscured by the hedgerow adjacent to the PROW. Only a few houses at the most south-westerly corner of the Area O site are likely to be visible.
Figure 40. View looking south-east, towards the Area O site, from PROW 156/8/1 near the top of the slope to the north of the B4022 (@ Grid Reference: SP360202)
Heading further south along this PROW, into the valley to the B4022, views of Area O site are obscured by vegetation.
Development on the site would not be visible from the PROW that are located to the west of PROW 156/8/1. Nor would it be visible from more elevated viewpoints on Ditchley Road, to the east.
Overall, we consider that the visual impact of the allocation would be relatively minor (subject to the mitigation measures outlined below). As such, we consider the visual sensitivity of the allocation to be no higher than moderate. On this basis, we consider that the allocation is potentially acceptable with regards to visual impacts.
Historic Environment
The Area O site is located within the Charlbury Conservation Area.
Figure 41. Charlbury Conservation Area (with the Area O site shown with a red boundary)117
117 link
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Policy EH10 of the adopted West Oxfordshire Local Plan 2031 states that ‘proposals for
development in a Conservation Area or affecting the setting of a Conservation Area will be permitted where it can be shown to conserve or enhance the special interest, character,
appearance and setting’.118
One of the requirements of Policy EH10, in this regard, is that ‘the proposals are sympathetic to … other gaps or spaces between buildings … which make a positive contribution to the character in the Conservation Area’. It could be argued that the Area O site, in its current state, is such a gap /
space. However, the significance of this is not clear.
The Board considers that the proposed development is potentially acceptable. However, we recommend that the District Council should seek expert advice on this issue to identify whether the proposed allocation would be appropriate in the Conservation Area.
Conclusions and recommendations
The Board considers that the landscape and visual sensitivity of this site is relatively low and that the Area P allocation is potentially acceptable.
However, we recommend that consideration should be given to reducing the total quantum of development at both the Area O site and the Area P site to make the total quantum of
development less than the Board’s 5% threshold for proportionality (i.e. fewer than 70 dwellings in total, or fewer than 35 dwellings on each site).
118 West Oxfordshire District Council (2018) West Oxfordshire Local Plan 2031 (link). Policy EH10 (Conservation
areas), page 136.
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On a related point, development should be at a relatively low density to reflect the fact that the site is on the outskirts of a nucleated settlement.
As stated in the consultation document, Hundley Way is considered inappropriate for access (with vehicular access likely to be from the south of the site instead). With this in mind, we recommend that the allocation should be designed in such a way that the north-western boundary along Hundley Lane should retains its country lane feeling, with additional landscape mitigation measures being provided along this boundary.
It appears that there are remnants of a dry stone wall along this boundary. In principle, the wall should be restored. However, a more pragmatic approach would be to remove the remnants of the wall and plant a hedgerow along the full length of this boundary (and along the other boundaries, where appropriate) instead. The loss of the dry stone wall should be compensated for by restoring damaged or derelict dry stone walls in the local vicinity.
The existing trees on the boundary should be retained and incorporated into this hedge, where appropriate. There should be no gaps in the hedge, except for pedestrian access at each end of this boundary. The hedge should be allowed to grow to approximately 2m in height (to screen views of the development) and should be managed, longer term, for wildlife. The curtilage of the properties should not extend directly to this hedge, so as to avoid individual property owners removing or damaging the hedge.
Built development should be set back from the boundary along Hundley Lane with the provision of some green space and / or habitat connectivity. There could potentially be additional tree planting in this green space.
Our recommendations relating to trees aligns with what is said, regarding this site, in theHousing and Economic Land Availability Assessment:119
• It will have some landscape impact unless existing trees are protected, and additional tree planting is incorporated.
Any changes in landform should be minimised.
In addition, the housing design should incorporate locally-sourced Cotswold stone and locally distinctive vernacular architecture. In particular, it should reflect the special interest, character and appearance of the Charlbury Conservation Area.
The development should also be required to comply with best practice guidance relating to lighting in protected landscapes, including the lighting guidance recently adopted by the Board.

The Cotswolds National Landscape (CNL) Board considers that the site is potentially a suitable location for non-strategic development, but not as currently proposed.
We acknowledge that the Housing and Economic Land Availability Assessment identifies that the site is suitable for housing.82 However, we consider that the allocation, as currently proposed:
• constitutes major development, in the context of paragraph 190 of the NPPF;
• is disproportionate to the settlement of Burford;
• would have a significant adverse visual impact (with regards to views looking north-west from the southern boundary of the site);
• would have a significant adverse effect on the setting of the Burford Conservation Area.
As such we do not support the allocation as currently proposed.
However, we consider that a smaller scale allocation that just the eastern half of the site, east of the entrance to Priory Wood, would potentially be acceptable (in the context of a Tier 2 settlement) subject to appropriate landscape mitigation and development criteria.
The quantum of housing would need to be reduced proportionately (i.e. at least halved).
Context
The Area N allocation is for a residential development of 70 dwellings on a site covering approximately 3.4ha, on the south side of Sheep Street, on the west side of Burford. It is located within the CNL, in Landscape Character Type (LCT) 16 (Broad Floodplain Valley). More specifically, it is located in Landscape Character Area 16B.
82 West Oxfordshire District Council (2025) West Oxfordshire Local Plan 2042. Housing and Economic Land
Availability Assessment (HELAA) 2025 (link). Site Ref: BUR 002a, digital page 70.
Figure 25. Burford Preferred Non-Strategic Development Location (Area N – South of Sheep Street, Burford)
Landscape character
Proportionality
As outlined above, in response to consultation question 2, the Board considers that a development at a CNL settlement would be disproportionate if it increased the number of
dwellings in the settlement (or the area of the settlement) by more than 5%.
According to the 2021 census, the built-up area / parish of Burford has 688 dwellings.83 A 5% increase on the baseline would be 34 dwellings. The proposed allocation of 70 dwellings is double that figure (10.2%). As such, we consider that the proposed allocation is:
• is disproportionate;
• conflicts with the guidance provided in the CNL Landscape Strategy & Guidelines that development in the CNL should be proportionate (and, by extension, it conflicts with
Policy CE1 of the CNL Management Plan);
• conflicts with the requirement, in paragraph 189 of the NPPF, for the scale and extent of development in National Landscapes to be limited;
• constitutes major development, in the context of paragraph 190 of the NPPF, in terms of scale (please see below for further commentary on this issue).
83 link. Search for Burford.
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Landscape character type
The CNL Landscape Character Assessment identifies 19 different landscape character types (LCTs) within the CNL. The allocation site is located in LCT 16 (Broad Floodplain Valley).84 In the West Oxfordshire Landscape Assessment, it is in LCT 8 (Upper Windrush Valley) in semienclosed valley-side farmland.
Relevant key characteristics are the gentle, convex valley slopes and arable fields that are defined by hedgerows and some stone walls.
Development on the allocation site could result in some alteration to the landform, which would detract from the characteristic gentle, convex valley slopes. The agricultural / arable land use would also be lost. The stone wall along the southern boundary of the site would presumably be
retained (and, ideally, restored).
The site is relatively contained, with woodland to the north and west, built development to the east and valley slopes to the south. As such, any impacts on landscape character would be relatively localised.
The West Oxfordshire Landscape Assessment states that Priory Wood is a key landscape feature in relation to the settlement of Burford. 85 Development on the allocation site would potentially have a significant adverse effect the setting of Priory Wood (which forms part of the Burford Conservation Area). It could also potentially result in a deterioration of the ancient woodland of Priory Wood, although these impacts could be moderated.
Settlement form
The West Oxfordshire Design Guide identifies Banbury as being a linear settlement.86 The Design Guide provides the following description of linear settlements:
• Linear settlements have a distinctive ribbon form and develop along both main roads and
the smaller side roads that branch off these routes.
87
The Design Guide goes on to describe Burford as follows:
• Exceptionally well preserved medieval town located in the west of the District. Burford’s main axis runs up the valley side away from the Windrush, and is intersected by a secondary axis that follows a hill terrace to give a cruciform plan. The High Street, which is lined by early houses, most of which are Listed, is especially distinctive.
88
The secondary axis, referred to above, is presumably along Sheep Street, to the west of the high street, and Witney Street, to the east of the high street. On this basis, the allocation site would be on this secondary axis. However, built development along Sheep Street currently only
extends approximately 350m to the west of the high street (which it has done since at least the 1990s89). The allocation would extend built development approximately 290m further west 84 Cotswolds National Landscape (2004) Cotswolds National Landscape – Landscape Character Assessment
(link). 16 – Broad Floodplain Valley (link).
85 West Oxfordshire District Council (1998) West Oxfordshire Landscape Assessment 1998 (link). Key Settlement
Burford. D: West of Burford (digital page 171)
86 West Oxfordshire District Council (2016) West Oxfordshire Design Guide. 5 – Settlement Type (link), page 6.
87 West Oxfordshire District Council (2016) West Oxfordshire Design Guide. 5 – Settlement Type (link), page 4.
88 West Oxfordshire District Council (2016) West Oxfordshire Design Guide. 5 – Settlement Type (link), page 13.
89 The current extent of built development along Sheep Street was present in a 1999 image of Burford on
Google Earth Pro.
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along the high street. In other words, it would almost double the extent to which built development extends along Sheep Street from the high street.
On this basis, we consider that the proposed allocation does not reflect the settlement form and pattern at Burford. This conflict would be less severe if only the eastern half of the site (east of the entrance to Priory Wood) was allocated.
Dark skies
One of the ‘special qualities’ of the CNL is the area’s dark skies.90 As such, it is important that development in the CNL, or in its setting, does not increase levels of light pollution, including sky glow, within the CNL.
The image below is an extract from CPRE’s Light Pollution and Dark Skies map. It shows that Burford already has fairly high levels of light pollution, with the town centre being in colour band 7 (‘pink’), which is the third highest level of brightness on the brightness scale. The effects of this light pollution extend to the allocation site, most of which is in colour band 6 (‘orange’), and beyond.
The development of the allocation site would increase light pollution levels to a limited degree.
For example, colour bands 6 (‘orange’) and 5 (‘yellow’) are likely to extend further west as a result of the development, including to the hamlet of Upton. The relatively ‘contained’ nature of the site would help to moderate these impacts.
Overall, this is not likely to be a deciding factor in whether or not the allocation is acceptable.
However, the Board’s suggestion of only allocating the eastern half of the site would help to further moderate these impacts as this would avoid the more exposed western slopes of the site.
If the allocation is taken forward, development should be required to comply with best practice guidance relating to lighting in protected landscapes, including the lighting guidance recently adopted by the Board. Consideration should be given to offsetting the impact of the additional
lighting by ensuring that the whole of Burford complies with best practice guidance in this regard.
90 Cotswolds National Landscape Board (2025) Cotswolds National Landscape Management Plan 2025-2030
(link). Chapter 4 – The special qualities of the Cotswolds National Landscape.
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Figure 26. Extract from CPRE’s Light Pollution and Dark Skies map showing light pollution levels at Burford (with the Cotswolds National Landscape boundary shown as a pink line)
Tranquillity
One of the ‘special qualities’ of the CNL is the area’s relative tranquillity.91 As such, it is important that development in the CNL, or in its setting, does not adversely impact on the
tranquillity of the CNL.
91 Cotswolds National Landscape Board (2025) Cotswolds National Landscape Management Plan 2025-2030
(link). Chapter 4 – The special qualities of the Cotswolds National Landscape.
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A key consideration, in this regard, is the extent to which the proposed allocation would increase traffic movements on roads within – and / or along the boundary of – the CNL. As
outlined in Section 4.5 of the Board’s Tranquillity Position Statement we consider that increases in traffic movements of 10% or more are significant and are likely to have an adverse impact on tranquillity.92
Given that the proposed allocation would increase the number of dwellings in Burford by approximately 10% it is unlikely that this threshold would be exceeded (given the contribution that through traffic also makes to the overall traffic movements).
On this basis, we do not consider that the impact of increased traffic movements is likely to be a deciding factor in whether or not the allocation is acceptable.
Visual impacts
The site has a footpath along the western and southern boundaries (PROW Code: 149/6/10). As one accesses this path from the north-west corner of the site on Sheep Street there are glimpsed views of the western half of the site through the vegetation.
Figure 27. View looking south-east, towards Area N, from the north-west corner of the site, at the junction of PROW 149/6/10 and Sheep Street.
As one heads south on the footpath, along the western boundary of the site, views of the site are restricted by the intervening vegetation. Views of the site open up as one reaches the south-west corner of the site.
92 Cotswolds National Landscape Board (2019) Tranquillity Position Statement (link). Section 4.5.
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From here it can be seen that the site rises over a shallow ridge, in the middle of the site, before descending on the other side of the ridge towards Burford. There is very little impression of the relatively close proximity of the built development of Burford at this viewpoint with just a couple
of chimneys and rooftops visible over the ridge.
Figure 28. View looking north-east, across Area N, from PROW149/6/10 at the south-west corner of the site
As one heads in an easterly direction on PROW 149/6/10 along the southern boundary of the site, the view across the whole site opens up. The woodland belt of Miletree Clump and the buildings on Little Rissington airfield can be seen, in the distance,to the north-west.
93 It is these views, looking north-west, that would be most adversely affected by the proposed allocation, particularly if housing is built on the upper slopes of the western half of the site.
Views looking directly north, across the site, are restricted by the woodland of Priory Wood on the north side of Sheep Street. Conversely, this woodland would, presumably, also restrict views of the site in south-facing views from the north side of the valley, especially when viewed from lower elevations.
The housing along the west side of Tanners Lane, to the east, is clearly visible but the rest of Burford is not visible.
Figure 29. Panorama view, looking north across the site, from PROW 149/6/10, approximately half way along the southern boundary of the site

93 Given the limited number of public rights of way (PROW) between Burford and Upper Rissington there are unlikely to be many locations where the site could be seen in south-eastward facing views to the north-west of the site.
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Figure 30. View, looking north-west across the site, from PROW 149/6/10, approximately half way along the southern boundary of the site, with the woodland belt of Miletree Clump the buildings on Little Rissington airfield visible in the distance
Views looking north-westwards across the site, from the south-east corner of the site are more limited, as shown below.
Figure 31. View looking north-west, across Area N, from PROW 149/6/10 at the south east corner of the site.
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The site is also visible from Sheep Street, along the northern boundary of the site. In some sections there is very little vegetation along the northern boundary of the site, providing clear views across the site. In other sections, the intervening vegetation makes the views more intermittent. The entrance to Park Wood, which is within Burford Conservation Area, provides a notable viewpoint as there is seating on either side of the entrance. Just to the east of the Park
Wood entrance, the approach to Burford is demarcated by signage and ‘traffic calming’ fencing.
Figure 32. View looking south, across the site, from Sheep Street at the entrance to Park Wood
The entrance to Priory Wood is roughly the point where the topography of Sheep Street and of the allocation site changes. To the east, the site slopes down in a north easterly direction towards Burford, whereas to the west, the site slopes down in a north-westerly direction, away
from Burford. So, if you are approaching the Park Wood entrance from the west, you are walking or driving up hill with very little perception of the settlement ahead, whereas when you head further east along Sheep Street, you are walking or driving downhill into Burford.
Based on the above points, we consider that the visual impact on views from publicly accessible locations adjacent to the site are likely to be significant.
With regards to impacts on views from the wider area:
• It is unlikely that housing on the site would be seen from the A40 – if there is any potential intervisibility this should be addressed in the design of the site to ensure that there is no intervisibility.
• There are glimpsed views of the site as one approaches Burford from the north west, on the A424, but the vast majority of visual receptors would be in motor vehicles so the
views would be very brief.
• There is very little, if any, intervisibility with publicly accessible viewpoints / locations at the bottom of the valley because of the intervening woodland at Priory Wood.
• There are glimpsed views of the site as one approaches Burford from the north, on the
footpaths on Westhall Hill, although the site is partly screened by intervening vegetation.
Based on the above points, we consider that the impact on views across the wider area are likely to be very limited.
Historic environment
Cultural heritage (including the historic environment) is one of the factors that contributes to the natural beauty of the CNL. One of the ‘special qualities’ of the CNL is the ‘distinctive
settlements, developed in the Cotswold vernacular with high architectural quality and integrity’.94
94 Cotswolds National Landscape Board (2025) Cotswolds National Landscape Management Plan 2025-2030
(link). Chapter 4 – The special qualities of the Cotswolds National Landscape.
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CNL settlements, or parts of settlements, that are designated as Conservation Areas, are prime examples of this special quality. This includes the Burford Conservation Area.
Most of the section of Sheep Street that runs along the northern boundary of the site is included in the Burford Conservation Area, as is Priority Wood. The houses along Tanners Lane, to the east of the site, are also within the Conservation Area.
Figure 33. Burford Conservation Area95
This section of Sheep Street is one of the few publicly accessible locations within the Conservation Area where one can look out across undeveloped farmland. As such, it makes a positive contribution to the setting of the Conservation Area. The opportunity to admire these views out of the Conservation Area are enhanced by the provision of south-facing seating (benches) at several locations along the north side of Sheep Street, including on each side of the
entrance to Priory Wood.
Development on the allocation site would be detrimental to views out of the Conservation Area (i.e. from Sheep Street) and, to a lesser degree, to view into the Conservation Area (i.e. from the footpath on the southern boundary of the allocation site). This would be particularly significant
if the whole site was developed. This is because, in this scenario, there would no longer be any direct views from the Conservation Area, along Sheep Street, onto open countryside.
Development on the site would not conserve or enhance the setting of the Conservation Area.
For these reasons, the allocation, as currently proposed, would conflict with the current policy on Conservation Areas in the West Oxfordshire Local Plan (Policy EH10).96 It would also conflict with Policy CE7 (Historic environment and cultural heritage) of the CNL Management Plan.97
95 link
96 West Oxfordshire District Council (2018) West Oxfordshire Local Plan 2031 (link). Policy EH10 – Conservation
Areas. Page 136.
97 Cotswolds National Landscape Board (2025) Cotswolds National Landscape Management Plan 2025-2030
(link). Policy CE7 (Historic environment and cultural heritage).
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We consider this to be a significant adverse effect.
These impacts would be less significant, although still adverse, if only the eastern half of the site (i.e. east of the entrance to Priory Wood) was developed, as this would allow for some direct views from the Conservation Area onto open countryside to be retained. Currently, the western
half of the northern boundary of the site has quite a few trees, which limit the views looking south across the open countryside. These trees (or at least some of them) should be removed to open up these views. The loss of these trees would have to be compensated for by planting
additional trees
Biodiversity
Natural heritage (including biodiversity) is one of the factors that contributes to the natural beauty of the CNL. In particular, one of the CNL’s ‘special qualities’ is the area’s ancient broadleaved woodland.98 This is a relevant consideration in this instance because the Defra
MAGIC website shows that the Priory Wood, on the north side of Sheep Street, is ancient woodland.
Figure 34. Extract from Defra MAGIC map showing ancient woodland at Priory Wood
Development of the proposed allocation site wouldn’t result in the direct loss of ancient woodland at Priory Wood. However, it could potentially result in the deterioration of the ancient woodland, for example, as a result of damaging the roots of trees in the ancient woodland which might spread under the road and under the allocation site.
Paragraph 193c of the NPPF states that:
• Development resulting in the … deterioration of irreplaceable habitats (such as ancient woodland and ancient or veteran trees) should be refused, unless there are wholly
exceptional reasons and a suitable compensation strategy exists.
99
This policy approach is reflected in Policy EH3 of the adopted West Oxfordshire Local Plan100
and in Policy CE8 of the CNL Management Plan101
.
98 Cotswolds National Landscape Board (2025) Cotswolds National Landscape Management Plan 2025-2030
(link). Chapter 4 – The special qualities of the Cotswolds National Landscape.
99 Ministry of Housing, Communities and Local Government (2024) National Planning Policy Framework (link).
Paragraph 193c.
100 West Oxfordshire District Council (2018) West Oxfordshire Local Plan 2031 (link). Policy EH3 – Biodiversity
and geodiversity. Page 114.
101 Cotswolds National Landscape Board (2025) Cotswolds National Landscape Management Plan 2025-2030
(link). Policy CE8 (Nature recovery and biodiversity), sub-paragraph CE8.6.
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The Government / Natural England / Forestry Commission guidance on ‘Ancient woodland, ancient trees and veteran trees: advice for making planning decisions’
102 makes the following
recommendations regarding buffer zones around ancient woodland.
• For ancient woodlands, the proposal should have a buffer zone of at least 15 metres from the boundary of the woodland to avoid root damage (known as the root protection area).
Where assessment shows other impacts are likely to extend beyond this distance, the proposal is likely to need a larger buffer zone. For example, the effect of air pollution from
development that results in a significant increase in traffic.
• For ancient or veteran trees (including those on the woodland boundary), the buffer zone should be at least 15 times larger than the diameter of the tree. The buffer zone should be 5 metres from the edge of the tree’s canopy if that area is larger than 15 times the tree’s diameter. This will create a minimum root protection area.
The guidance also states that ‘a buffer zone should consist of semi-natural habitats such as: woodland; [or] a mix of scrub, grassland, heathland and wetland’.
The boundary of the ancient woodland is approximately 12m from the boundary of the allocation site. Therefore, the first few metres along the northern boundary of the allocation
site should consist of semi-natural habitat. On that basis, the built development would need to be set back from Sheep Street rather than edging directly onto it.
Major development
The Board considers this allocation to constitute major development in the context of paragraph 190 of the NPPF. The main reasons for this are as follows:
• The allocation has twice the number of dwellings that the Board would consider to be proportionate.
• It is seven times larger than the threshold for major development, in terms of number of dwellings, in the Town and Country Planning (Development Management Procedure)
(England) Order 2010 (i.e. 70 dwellings, compared to the threshold of 10 dwellings).103
• It is three times larger than the threshold for major development, in terms of area (hectares), in the Town and Country Planning (Development Management Procedure)
(England) Order 2010 (i.e. three hectares, compared to the threshold of one hectare).104
• It would have a significant, adverse visual impact, particularly in relation to views looking
north-west from the footpath on the southern boundary of the site.
• It would have a significant adverse effect on the setting of the Burford Conservation Area.
No exceptional circumstances have been set out to justify this major development.
It is worth noting that, in the planning inspector’s report on the examination of the West Oxfordshire Local Plan 2031, the planning inspector stated:
102 linkplanning-decisions#ancient-woodland
103 link. This is a relevant consideration although it
is not necessarily, in isolation, a deciding factor.
104 link. This is a relevant consideration although it
is not necessarily, in isolation, a deciding factor.
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• In the absence of a specific housing need figure for the sub-area, it is not possible to identify that new dwellings, over and above existing completions and commitments, are as a matter of principle, necessary specifically in the context of the AONB or the Burford – Charlbury sub-area.
105
As such, this is a relevant consideration in relation to the question of whether exceptional circumstances apply to justify this allocation.
We consider that if the allocation was reduced in scale, such that it occupied the eastern half of the site, to the east of the entrance to Priory Wood, it would not constitute major development.
This is because it would be more in line with the Board’s 5% threshold and it would have a less significant adverse effect on the setting of the Conservation Area and on views that are
currently experienced from the footpath on the southern boundary.
Conclusions and recommendations
The Board does not support the allocation as currently proposed.
This is primarily because we consider it to be major development, in the context of paragraph 190 of the NPPF. However, even if it was deemed not to constitute major development, the adverse visual impacts and the adverse impacts on the setting of the Conservation Area would
provide sufficient justification for excluding the proposed allocation.
However, we consider that there is scope for a smaller quantum of development on this site.
The Board recommends that, if this allocation is progressed, only the eastern half of the site (east of the Priory Wood entrance) should be allocated, as shown below.
Figure 35. The Board’s suggested boundary for the Area N allocation (with the boundary shown by the red line)
105 Planning Inspectorate (2018) Report on the Examination of the West Oxfordshire Local Plan 2031 (link).
Paragraph 219, page 55.
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This would help to ensure that:
• the increase in the number of dwellings in Burford would be below the Board’s 5% threshold;
• the allocation does not constitute major development, in the context of paragraph 190 of the NPPF;
• the north-westerly views, towards Upper Rissington, that are experienced from the footpath along the southern boundary of the site are not adversely affected;
• adverse impacts on the Conservation Area and its setting are minimised;
• adverse impacts on the ancient woodland at Priory Wood are minimised.
To avoid any deterioration of the ancient woodland at Priory Wood, the Local Plan should specify that development must comply with the Government / Natural England / Forestry Commission guidance on ‘Ancient woodland, ancient trees and veteran trees: advice for making planning decisions’.106
Any dry stone walls or hedgerows that form the boundary of the site should be restored.
If the District Council is minded to allocate the site in full, they should explicitly set out the exceptional circumstance that they think apply to justify this major development.

The Cotswolds National Landscape (CNL) Board considers that, from a CNL perspective, Area K is potentially a suitable location for strategic scale development. However, given the close proximity of the allocation to the CNL boundary, consideration will need to be given to the potential impacts of the proposed allocation on the natural beauty of the CNL, particularly with regards to:
77 This should not be left until the planning application stage. This is because, if the increase in traffic movements is likely to be 10% or more, there is a higher likelihood that such a development would not be permitted because of the harm that it would cause to the CNL. In such a scenario, the allocation would be unsound.
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• visual impact;
• impact on dark skies; and
• impact on tranquillity.
Context
The proposed allocation at Area K is for a residential development of approximately 300 dwellings. It would be located to the south of Hanborough Station and to the north east of Pinsley Wood, as shown below.
Figure 23. Area K allocation – Land South West of Hanborough Station (with the boundary of the Cotswolds National Landscape added as a red line)
Visual impact
The allocation site comes within approximately 300m of the CNL boundary, at the point where the CNL boundary follows the norther edge of the A4095 near Hanborough Business Park.
However, development on the allocation site would not be perceptible from the CNL boundary at this point because of the intervening built development.
The only other location where development on the allocation site might be perceptible from publicly accessible viewpoints in the CNL is the public rights of way (PROW)to the north-east of Combe Station, east of Bolton’s Lane. However, the Board’s Planning Lead has made a site visit to this location and concluded that development on the allocation site would not be perceptible from these PROW. This is because of the intervening topography and development, particularly
the housing alongside the A4095, which follows the elevated ridge line between the centre of Long Hanborough village and Hanborough Station. The woodland in the more elevated section of Pinsley Wood is visible beyond this ridge line but not the currently undeveloped fields to the north of Pinsley Wood.
Overall, we do not consider that there would be any direct intervisibility between the CNL and development on the proposed allocation site.
Dark skies
One of the ‘special qualities’ of the CNL is the area’s dark skies.78 As such, it is important that development in the CNL, or in its setting, does not increase levels of light pollution, including sky glow, within the CNL.
The image below is an extract from CPRE’s Light Pollution and Dark Skies Map. It shows that Long Hanborough already has some degree of light pollution, particularly in the vicinity of
Hanborough Business Park and Hanborough train station. For example, most of the settlement is in colour band 4 (‘green’) but the business park area is in colour band 6 (‘orange’). This light pollution extends into the adjacent corner of the CNL.
Figure 24. Extract from CPRE’s Light Pollution and Dark Skies Map showing light pollution at Long Hanborough (with the Cotswolds National Landscape boundary shown as a pink line)
A development of 300 dwellings would increase the number of dwellings in the settlement of Long Hanborough by approximately 24%, compared to the 2021 census baseline of 1,238 households.79 A development of this scale is likely to exacerbate these light pollution issues. For example, lighting associated with development on the allocation site, combined with the existing lighting in the business park area, could potentially result in colour band 6 (‘orange’) extending into the CNL and colour band 4 (‘green’) extending further into the CNL, possibly as far as East End.
These impacts are probably not sufficient to outweigh the benefits of allocating this site.
However, development on the allocation site should comply with best practice guidance on lighting, including the lighting guidance that has recently been adopted by the Board.
Consideration should also be given to offsetting the additional lighting associated with the allocation by reducing existing levels of light pollution in the settlement, particularly in the vicinity of the business park and train station.
Tranquillity
One of the ‘special qualities’ of the CNL is the area’s relative tranquillity.80 As such, it is important that development in the CNL, or in its setting, does not adversely impact on the
tranquillity of the CNL.
A key consideration, in this regard, is the extent to which the proposed allocation would increase traffic movements on roads within – and / or along the boundary of – the CNL. As
outlined in Section 4.5 of the Board’s Tranquillity Position Statement we consider that increases in traffic movements of 10% or more are significant and are likely to have an adverse impact on tranquillity.81
Given that the proposed allocation would increase the number of dwellings by approximately 24%, there is a risk that the allocation could, in fact, increase traffic movements within – and / or along the boundary of – the CNL by 10% or more. For example, the minor roads towards Combe
and Stonesfield could potentially be affected in this way.
To ensure that the allocation is sound, we recommend that an assessment of the potential increase in traffic movements should be undertaken as part of the local plan evidence base. It this assessment identifies that the allocation(s) are likely to increase traffic movements on
link. Use search facility to create a profile for Long
Hanborough.
80 Cotswolds National Landscape Board (2025) Cotswolds National Landscape Management Plan 2025-2030
(link). Chapter 4 – The special qualities of the Cotswolds National Landscape.
81 Cotswolds National Landscape Board (2019) Tranquillity Position Statement (link). Section 4.5.
52
roads within – and / or along the boundary of – the CNL by 10% or more, consideration should be given to reducing the quantum of development proposed on these sites.

The Cotswolds National Landscape (CNL) Board does not support the allocation of a strategicscale residential development (or strategic development area (SDA)) at Chipping Norton, as outlined above in our response to Questions 2, 5, 13 and 14, above. As such, we do not consider
that this is a suitable location for strategic scale development. Our reasons against strategic scale development are set out below.
As outlined in response to Question 14, we acknowledge that an allocation for 750 dwellings would be a substantially reduced quantum of development compared to the current allocation, which is for 1,200 dwellings, as shown in the maps below. However, this reduced quantum is more than twice as large as what the Board would consider to be proportionate, in the context of a development at Chipping Norton that is located outside of the CNL (please refer to our response to Questions 2 and 5 for further details).
Figure 10. East Chipping Norton Strategic Development Area (SDA) as allocated in the current Local Plan 2031 (1,200 homes)
We consider that the proposed allocation is likely to have a significant adverse effect on the natural beauty of the CNL. Key concerns relating to the proposed allocation, from a CNL
perspective, are outlined below.
Impacts on landscape character (in the context of the Cotswolds National Landscape)
Context
The proposed allocation is located outside of the CNL but within its setting. For example, the northern boundary of the preferred site option (as shown in the consultation document) is located on the opposite side of Banbury Road from the CNL boundary. The allocation extends
southwards from Banbury Road, away from the CNL boundary. The allocation is also approximately 220m from the CNL boundary, at its closest point, along London Road.
Most of Chipping Norton, including the historic core of the town, is located in Landscape Character Type (LCT) 5 (Farmed Slopes), as described in the CNL Landscape Character
Assessment and in the CNL Landscape Strategy and Guidelines.49 In the West Oxfordshire Landscape Assessment (WOLA) this landscape character is classed as ‘Northern Valleys and Ridges’.50
However, the CNL LCT that is most closely aligned with the landscape character of the land on which the proposed allocation would be located is LCT 7 (High Wold). More specifically, the site is located in Landscape Character Area 7F (High Wold – Over Norton Plateau). In the WOLA, both Landscape Character Area 7F and the land on which the proposed allocation would be located form part of the ‘Enstone Uplands’,51 with the particular parcel of land on which the proposed allocation would be located being identified as ‘semi-enclosed limestone wolds
(large-scale)’52
.49 link
50 West Oxfordshire District Council (1998) West Oxfordshire Landscape Assessment (link). Part Two – Character
Areas – 1 – Northern Valleys and Ridges (digital pages 56-61). Chipping Norton is identified as being the key
settlement in this landscape character area.
51 West Oxfordshire District Council (1998) West Oxfordshire Landscape Assessment (link).Part Two – Character
Areas – 3 – Enstone Uplands (digital pages 68-73).
52 West Oxfordshire District Council (1998) West Oxfordshire Landscape Assessment (link). Map of Enstone
Uplands (digital page 136)
Figure 12. Extract from the Cotswolds National Landscape Interactive Landscape Character
Map (dark green shading = Landscape Character Type 5 (Farmed Sloped); light green shading =
Landscape Character Tupe 7 (High Wold); unshaded areas = land outside the CNL53).
53 The land to the east of Chipping Norton and west of the A44 has a plateau type landform, similar to LCT 7
(High Wold).
54 West Oxfordshire District Council (1998) West Oxfordshire Landscape Assessment (link). Map of Enstone
Uplands (digital page 136).
Proportionality
As outlined in response to Question 2, the Board considers that, in the context of a National Landscape settlement (including settlements that overlap with the CNL boundary), residential development allocations or proposals are disproportionate if they increase the number of dwellings in a settlement – or the area of a settlement - by more than 5%, within the CNL, or, for parts of Chipping Norton that are located outside the CNL, 10%. Given that this proposed
allocation would be located outside of the CNL, the 10% threshold would apply.
According to the 2021 census, Chipping Norton has between 3,151 dwellings (in the built-up area) and 3,251 dwellings (in the parish).55 A 10% increase would be 312-324 dwelling. In
contrast, the proposed allocation of 750 dwellings would be a 23-24% increase compared to this baseline. This is nearly 2.5 times larger than the Board’s 10% ‘rule-of-thumb’ threshold (for parts of Chipping Norton that are located outside the CNL).
Therefore, the proposed allocation of 750 dwellings would significantly conflict with the CNL Landscape Strategy & Guidelines, which state:
• Ensure new development is proportionate and does not overwhelm the existing settlement.56
By extension, it would significantly conflict with Policy CE1 of the CNL Management Plan, which states that proposals should be compatible with the CNL Landscape Strategy & Guidelines.57
Settlement pattern / form
The West Oxfordshire Design Guide identifies Chipping Norton as being both nucleated and linear in character.
58 The Design Guide provides the following description of nucleated settlements:
• Nucleated settlements are compact, with less dense development on the periphery of the central core. The tight-knit form of nucleated settlements makes them particularly
vulnerable to loss of character if development takes place beyond the fringes of the settlement.59
It provides the following description of linear settlements:
• Linear settlements have a distinctive ribbon form and develop along both main roads and the smaller side roads that branch off these routes.
The Design Guide goes on to describe Chipping Norton as follows:
• Market town located in the north-west of the District, in an unusually elevated valley-side setting mainly between the 183m and 213m contours. Linear, historical core with large
55
link. Use the search facilities to find 2021 census housing data for Chipping Norton.
56 The CNL Landscape Strategy & Guidelines provides a strategy and guidelines for each landscape character
type (LCT) within the CNL. The most relevant LCT, in this, instance, is LCT 7 (High Wold) – see Section 7.1.
Similar points are made in the Landscape Strategy & Guidelines in relation to other LCTs.
57 Cotswolds National Landscape Board (2025) Cotswolds National Landscape Management Plan 2025-2030
(link). Policy CE1 (Landscape), sub-paragraph CE1.1.
58 West Oxfordshire District Council (2016) West Oxfordshire Design Guide. 5 – Settlement Type (link), page 8.
59 West Oxfordshire District Council (2016) West Oxfordshire Design Guide. 5 – Settlement Type (link), page 4.
60 West Oxfordshire District Council (2016) West Oxfordshire Design Guide. 5 – Settlement Type (link), page 4.

volumes of C20 estate development (mainly along the 185m contour, but with some undue spillage over the hill top).
The Landscape and Visual Review of Chipping Norton Strategic Site Option, dated May 2014, provides a similar commentary, with the following additional points:
• The approaches into the town still retain a strong contrast between rural approach and the town character (as found along the A44 and B4026) with the absence of a suburban
interface between the two. The form and layout of any new development on the town edge is therefore an important factor in integrating any new development into the town and its landscape setting.
Since these documents were published there has been some further housing development on the south side of town, to the west of Burford Road, and the north-east side of town, along the south side of Banbury Road, resulting in further ‘spillage’ onto the ‘hill top’ (i.e. onto the high wold plateau). These changes can be seen by comparing Figure 14 and Figure 15 below.
However, the settlement pattern and built form is still primarily on the western facing slopes of the ridge.
Figure 14. Google Earth Pro image of Chipping Norton, dated April 2015
61 West Oxfordshire District Council (2016) West Oxfordshire Design Guide. 5 – Settlement Type (link), page 19.
62 Kirkham Landscape Planning (2014) West Oxfordshire LDF Local Plan – Landscape and Visual Review of
Chipping Norton Strategic Site Option 204 (link). Paragraph 6.1, page 4 (digital page 5).
Figure 15. Google Earth image of Chipping Norton, dated 2025.
The proposed allocation would significantly alter this settlement character and form as it would result in a much larger proportion of Chipping Norton’s built form being located on the high wold / plateau landscape. This would erode the valley-side character of the settlement to a much
greater degree than development to-date.
Therefore, we consider that the proposed allocation of 750 dwellings would significantly conflict with the CNL Landscape Strategy & Guidelines, which state:
• Ensure that new development does not adversely affect settlement character and form.63
By extension, it would significantly conflict with Policy CE1 of the CNL Management Plan, which states that proposals should be compatible with the CNL Landscape Strategy & Guidelines.64
Extent to which the allocation intrudes negatively into the countryside
The WOLA identifies key landscape and visual characteristics and key sensitivities and considerations in relation to Chipping Norton.65 The parcel of land on which the proposed allocation would be located is classed as ‘D: North East of Chipping Norton’. For this area, one of
the identified landscape characteristics in the WOLA is ‘helps form an attractive approach to the town on London Road, important to the setting of Chipping Norton’. One of the identified visual characteristics in the WOLA is ‘avenue landscape very important to the quality of the approach
63 The CNL Landscape Strategy & Guidelines provides a strategy and guidelines for each landscape character
type (LCT) within the CNL. The most relevant LCT, in this, instance, is LCT 7 (High Wold) – see Section 7.1.
Similar points are made in the Landscape Strategy & Guidelines in relation to other LCTs.
64 Cotswolds National Landscape Board (2025) Cotswolds National Landscape Management Plan 2025-2030
(link). Policy CE1 (Landscape), sub-paragraph CE1.1.
65 West Oxfordshire District Council (1998) West Oxfordshire Landscape Assessment (link). Part Three – Key
Settlements – Chipping Norton (digital pages 163-165, in reverse) and the setting of the town’. One of the identified key sensitivities and considerations, in this regard, is ‘need to maintain the quality of the approach into town’.
The fact that this area helps to form an attractive approach to Chipping Norton and is very important to the setting of the town are also important considerations in a CNL context. This is because it is an important component of how people experience Chipping Norton as a whole.
An important component of the attractiveness of this approach into Chipping Norton is that the land either side of this ‘avenue’ is currently undeveloped, with a rural feel. For example, when approaching Chipping Norton from the junction of London Road with the A44 / A430, there is
currently no development for approximately 1.3km along London Road. However, if the proposed allocation is developed, the distance along London Road which has no development would be reduced by approximately half.
There are two ‘kink’s in the section of London Road that is currently undeveloped. When approaching Chipping Norton from the A44 / A3400 the edge of built development at Chipping Norton is currently beyond (i.e. west of) both these kinks. This helps to limit the extent to which the built area of Chipping Norton is seen on this approach. However, the proposed allocation would extend built development, eastwards, beyond these two kinks in London Road and
alongside the straight section of London Road. As such, it is likely that the built development of Chipping Norton would be noticeable from a greater distance.
These factors would significantly reduce the sense of approaching Chipping Norton through undeveloped, rural countryside. In turn, they would significantly reduce the attractiveness of this approach, compared to the current, undeveloped baseline.
Therefore, we consider that the proposed allocation of 750 dwellings would significantly conflict with the CNL Landscape Strategy & Guidelines, which state:
• Avoid development that will intrude negatively into the landscape and cannot be successfully mitigated.
By extension, it would significantly conflict with Policy CE1 of the CNL Management Plan, which states that proposals should be compatible with the CNL Landscape Strategy & Guidelines.67
Extent to which the landscape character of the proposed allocation site is complementary to the landscape character in the Cotswolds National Landscape
The Government’s planning practice guidance (PPG) on the ‘Natural Environment’ states that ‘land within the setting of [National Landscapes] often makes an important contribution to maintaining their natural beauty’.68 The PPG states that ‘this is especially the case … where the
landscape character of land within and adjoining the designated area is complimentary’.
As outlined above, the high wold landscape within the CNL (Landscape Character Type 7) and the site of the proposed allocation both form part of the Enstone Uplands in the West
66 The CNL Landscape Strategy & Guidelines provides a strategy and guidelines for each landscape character
type (LCT) within the CNL. The most relevant LCT, in this, instance, is LCT 7 (High Wold) – see Section 7.1.
Similar points are made in the Landscape Strategy & Guidelines in relation to other LCTs.
67 Cotswolds National Landscape Board (2025) Cotswolds National Landscape Management Plan 2025-2030
(link). Policy CE1 (Landscape), sub-paragraph CE1.1.
68 link. Paragraph 042.
Oxfordshire Landscape Assessment. The landscape character of both areas is very complementary, as shown in the table below.
Table 3. Comparison of characteristic features for the high wolds landscape character type in the Cotswolds National Landscape and the Enstone Uplands in the West Oxfordshire
Landscape Assessment (with similar words and phrases underlined)
The table shows that the landscape character of the land within the CNL (i.e. LCT 7) and the land adjoining the CNL (i.e. the site of the proposed allocation) are complementary to a significant degree. As such, the site makes an important contribution to the setting of the CNL.
It is important to note that, the proposed allocation would result in the urbanisation of almost the entire area of ‘semi-enclosed limestone wolds (large-scale)’ in this part of the Enstone Uplands. This makes the adverse impacts on landscape character even more significant.
However, the allocation site is not contiguous with the CNL (unless the last remaining undeveloped field along Banbury Road, to the west of the A3400, is included in the allocation).
The land between the allocation site now mainly consists of residential development. As such, there is little direct continuity, or (as outlined below) visually interconnectivity, between the characteristics features of LCT 7 and this section of the Enstone Uplands. This moderates the adverse impacts on landscape character (in the context of the CNL) to a significant degree.
Overall, we consider the adverse impacts on landscape character, in this regard, to be moderate. However, if the fields immediately to the west of the A3400, to the south of Banbury Road, were to be included in the allocation, the impacts would be more significant.
Dark skies
One of the ‘special qualities of the CNL’ is the area’s dark skies. These dark skies are already affected by light pollution at Chipping Norton, as shown in the map below.
The key shows nine bands of light pollution, with band 1 (‘dark blue’) being the darkest areas and band 9 (‘brown’) being the brightest. The centre of Chipping Norton is in band 7 (i.e. ‘pink’ - the third brightest band). As a result of this light pollution, the western end of the allocation site is in
band 5 (‘yellow’) and the rest of the site is in band 4 (‘green’) even though there is currently no development on site.
However, with the quantum of proposed development (i.e. 750 dwellings), which would increase the total number of dwellings in Chipping Norton by nearly a quarter, light pollution in this locality is likely to significantly worsen. For example, light pollution at the allocation site is likely
to be in band 6 (‘orange’), whilst bands 5 (‘yellow’) and 4 (‘green’) are likely to extend further outwards, including further into the CNL to the north of Banbury Road. This is likely to include the whole of Over Norton (the southern half of which is currently in band 4 (‘green’). As a result,
it would no longer be possible to see the Milky Way from anywhere in Over Norton
Figure 16. Extract from CPRE’s Light Pollution & Dark Skies Map72
These increased levels of light pollution are likely to be noticeable from the Rollright Stones ancient monument, which is designated as a Dark Sky Discovery Site. Whilst the light pollution might not affect stargazing views from the Rollright Stones when looking directly up into the
night, it could potentially affect stargazing views closer to the horizon when looking in a southeasterly direction from the Rollright Stones, particularly given that the allocation would be on top of the high wold plateau.
72 link
42
Tranquillity
One of the CNL’s ‘special qualities’ is the area’s relative tranquillity (i.e. absence of noise and visual clutter).73
A key consideration in relation to tranquillity, is the extent to which a proposed development would increase traffic movements on roads within – and / or along the boundary of – the CNL.
As outlined in the Board’s Tranquillity Position Statement, the Board considers an increase of 10% or more to be significant.
Given that the proposed allocation would increase the number of dwellings in Chipping Norton by almost a quarter, we consider that there is quite a high likelihood that the 10% threshold would be exceeded.
Visual impact (CNL context)
An important consideration is the impact that the proposed allocation might have on views from the CNL. Case law has established that great weight should be given to such impacts, in line with paragraph 189 of the NPPF. The potential impacts of views looking towards the CNL is
also a relevant material consideration.
Impact on views from the CNL
The CNL boundary runs along the north side of Banbury Road, to the north of the proposed allocation. Figure 18 in the consultation document (shown in this consultation response as Figure 11) indicates that the northern boundary of the site allocation would extend eastwards along Banbury Road, from approximately Bowen Way (to the west of the Chipping Norton & District Cricket Club) towards the junction with the A3400. If this was the case, then the allocation would be directly adjacent to the CNL, on the opposite side of Banbury Road.
However, we assume that this will not actually be the case, as outlined below.
Firstly, we assume that the Chipping Norton Cricket Club site would not be developed (and so would not be included in the allocation). Secondly, we are aware that planning permission has been granted for 86 dwellings to the east of the Cricket Club (Ref: 23/00536/OUT – Land South of Hit or Miss Farm) and that this development is currently in progress, as shown in the image below. As such, we assume that this site would also not be included in the site allocation.
If the Cricket Club site and the Land South of Hit or Miss Farm site are not included in the allocated site, that just leaves one field, between the Land South of Hit or Miss Farm site and the petrol station at the roundabout on the A3400, where the allocation could potentially run alongside Banbury Road, which it could do for a distance of approximately 110m metres.
73 Cotswolds National Landscape Board (2025) Cotswolds National Landscape Management Plan 2025-2030
(link). Chapter 4 – The special qualities of the Cotswolds National Landscape.
43
Figure 17. View looking south-west, from the pavement on the north side of Banbury Road, towards the Land South of Hit or Miss Farm (@ Grid Reference: SP326281).
As can be seen in the image below, this field can be clearly seen from the pavement that runs along the north side of Banbury Road, on the CNL boundary, as shown in the image below. As such, development in this field would be clearly visible from this location. The hedgerow at the southern end of this field and the land beyond that hedgerow can also be seen. As such, development in the field to the south would also be visible.
The northern boundary of this field extends approximately 110m along the south side of Banbury Road. This is the only section of the 1.5km length of Banbury Road, between the centre of Chipping Norton and the A3400, that now provides clear visual connectivity between the CNL and the adjacent and complementary plateau landscape to the south. If the field is developed, this visual connectivity would be completely lost. This would be a significant visual impact. If this field is left undeveloped but the land to the south is developed, this development would detract from the currently expansive view looking south from the CNL boundary in this location, albeit to a lesser degree.
44
Figure 18. View looking south-west, from the pavement on the north side of Banbury Road, towards the field on the south side of Banbury Road, east of the Land South of Hit or Miss Farm site (@ Grid Reference: SP327282
It is worth noting that the eastern third of the Land South of Hit or Miss Farm is not being developed for housing. Instead, the northern and eastern sections of this eastern strip of land, including the land closest to Banbury Road, is being planted with trees to turn it into woodland.
Presumably, this is intended to help screen the new development in views from further east along Banbury Road and from the A3400. This screening would be completely undermined if the field to the east of the Land South of Hit or Miss Farm site was allocated and developed.
Impact on views looking towards the Cotswolds National Landscape
There is a public right of way (PROW), a restricted byway, that runs along the eastern boundary of the proposed allocation (Path Code: 166/5/10). The built development of Chipping Norton is currently located approximately 750m to the west of this PROW. Given this distance, across relatively flat land with intervening vegetation, it is unlikely that the built development of Chipping Norton is currently visible in westward views from this PROW. However, the proposed
allocation would bring built development directly adjacent to this PROW, making this CNL settlement much more visually intrusive.
Alternative Options
The Boad has identified three alternative options for the site allocation, in relation to the land north of London Road.74
74 For these options, it is assumed that if the allocation was to include land along the south side of London Road, development on the south side of London Road would not extend any further east than development on
the north side of London Road.
45
Option 1
In Option 1, built development would cover approximately 5ha and would extend no further eastwards than the small fields to the east of Russel Way, north of London Road. There would be a relatively narrow belt of woodland on the east side of the allocation. This option would be consistent with the Board’s rule-of-thumb threshold of not increasing the number of dwellings in a CNL settlement by more than 5% (i.e. the allocation wouldn’t exceed 160 dwellings). It
wouldn’t extend development further east along London Road than the existing built development on the south side of London Road.75
However, an allocation of this size would potentially be considered too small for a Tier 1 settlement.
Figure 19. Option 1 (red boundary = limit of built development; green boundary = area for landscape mitigation)
Option 2
Option 2 would extend one field further eastwards along London Road than Option 1. The most easterly section of this field would be used for planting a woodland belt, aligning with the woodland belt to the south of London Road.
The area on which built development would take place would cover approximately 12ha. The scale of development could be kept below the threshold for strategic-scale development (i.e. fewer than 300 dwellings). This would align with the rule-of-thumb threshold of not increasing the number of dwellings in a settlement by more than 10%, which the Board considers is appropriate for the sections of CNL settlements that extend beyond the CNL boundary.
75 Given that development on the north side of London Road would not extend further east than the existing development on the south side of London Road, there would be no further development on the south side of London Road.
46
In Option 2, built development would only extend built approximately 250m beyond the current limit of built development along London Road,76 rather than the 660m that the proposed allocation would entail. It would only extend to the first ‘kink’ in London Road (as you head east,
away from Chipping Norton) and would be approximately 340m from the PROW to the east (and well screened in views from that PROW). These factors would help to maintain an attractive approach to Chipping Norton.
An allocation of this size might be considered relatively small for a Tier 1 settlement. However, it would be more compatible with Chipping Norton’s status as a CNL settlement than the proposed allocation.
Option 2 is the Board’s recommended option.
Figure 20. Option 2 (red boundary = limit of built development; green boundary = area for landscape mitigation)
Option 3
Option 3 would extend the north-eastern section of the allocation into the field to the south of the Land South of Hit or Miss Farm site. The edge of built development in this field would align with the edge of built development on the Land South of Hit or Miss Farm site. The eastern section of this field would be used for landscape mitigation (e.g. woodland) as would the southern edge of the field. On this basis it would provide, approximately, an additional 3.5ha of
land for built development compared to Option 2. Development along London Road itself would extend no further than for Option 2.
This option would allow for more housing than Option 2 but the quantum of housing is likely to become strategic-scale development and would exceed the Board’s 10% rule-of-thumb
76 If the allocation include land to the south of London Road, it is assumed that this would extend along London Road to the same point as development on the north side of London Road (i.e. up to the tree belt).
threshold. As such, it is likely to have a more significant adverse impact on the CNL. It would also bring development closer to the PROW to the east than Option 2.
Figure 21. Option 3 (red boundary = limit of built development; green boundary = area for landscape mitigation)
Conclusions and recommendations
The Board considers that the proposed allocation would have a significant adverse effect on the natural beauty of the Cotswolds National Landscape, as outlined above.
We recommend that the allocation should be significantly reduced in scale and extent. We recommend the Option 2 scenario that we have outlined above should be used as the basis for the allocation. In effect, we do not think that the allocation should extend beyond the area that is already covered in the strategic-scale allocation in the adopted Local Plan, in relation to the section north of London Road.
We recommend that the following areas should be excluded from any allocation proposal north of London Road:
(i) The field to the east of the Land South of Hit or Miss Farm site, to the south of Banbury Road – development here would have significant adverse impacts on views from the
CNL and would erode the extent to which the landscape character in the CNL and adjacent to the CNL are complementary.
(ii) The field to the south of (i), between the Land South of Hit or Miss Farm site and PROW 1 – as per (i), albeit to a lesser degree.
(iii) The field to the west of PROW 166/5/10, north of London Road – development here would make Chipping Norton significantly more intrusive in views looking towards the
CNL.
These areas are outlined in red in the image below.
48
Figure 22. Area, within the preferred site option area, that the Board considers should not be developed in any allocation scenarioAdditional recommendations:
• The ‘avenue landscape’ along London Road (and Banbury Road), including the avenues of trees, should be retained in any allocation scenario.
• Any boundary features within – and / or along the boundary of – the allocated site, such as dry stone walls and / or hedgerows, that are currently in a bad state of repair should
be restored.
• Lighting in the allocated site development should comply with relevant best-practice guidance, including the lighting guidance recently adopted by the Board. To help offset
any increase in lighting associated with the allocation, consideration should be given to ensuring that all lighting in Chipping Norton complies with best-practice guidance.
• An assessment should be undertaken, during the local plan preparation, to identify if the allocation would result in traffic movements on roads within – and / or along the boundary of – the CNL increasing by 10% or more.77

The Cotswolds National Landscape (CNL) Board considers that, from a CNL perspective, Areas E and F are potentially suitable locations for strategic scale development. However, we are concerned that the total quantum of development proposed could potentially have an adverse impact on the dark skies of the CNL, as outlined below.
The proposed allocation at Area E is for a residential development of 700-800 dwellings and the proposed allocation at Area F is for a residential development of 1,500-2,500 dwellings.
Together they would provide up to 3,300 dwellings. As the names suggest, both allocations are on the north side of Carterton, as shown on the map below.
Area F comes within approximately 500m of the CNL boundary, which runs along Burford Road
(B4047) to the north. Area E comes within approximately 1km of the CNL boundary, which runs along the A40 to the north.
The map below is an extract from CPRE’s Light Pollution and Dark skies map. It shows that Carterton and the surrounding area already experience high levels of light pollution. Partes of Carterton are in the brightest colour band (band 9 – ‘brown’). The current northern limit of built development at Carterton is currently nearly 2km away from the CNL boundary. However, light pollution levels are such that light pollution from Carterton already spreads northwards into the
CNL in the vicinity of the roundabout at The Farmer’s Dog pub (where the A40 and the B4047 meet), which is in colour band 4 (‘green’).
The proposed allocations would bring the built development of Carterton approximately 1.5km closer to the CNL. As a result, are larger area of the CNL is likely to be affected by the resulting light pollution. For example, it is likely that colour band 4 (‘green’) is likely to extend further into the CNL, at least to Asthall and possibly beyond. At these levels of light pollution, it will not be possible to see the Milky Way. The light pollution at the edge of the CNL, in the vicinity, of the
A40 roundaboutis likely to increase to colour band 5 (‘yellow’), 6 (‘orange’) or even 7 (‘pink’). The area of relatively dark sky in the CNL (i.e. colour bands 3 (‘light blue’), 2 (‘dark blue’) and 1 (‘black’) would shrink.
With these points in mind, we recommend that the allocations should not come so close to the CNL boundary. For example, it may be appropriate to ensure that the allocations do not come within, say, 1k of the CNL boundary.
To help offset any increase in lighting / light pollution, it may be appropriate to address existing levels of lighting / light pollution in Carterton (i.e. ensure that lighting complies with relevant best practice lighting guidance).
Consideration should also be given to the extent to which the overall quantum of development proposed at Carterton (but particularly with regards to Areas E and F) is likely to increase traffic movements on roads within the CNL and / or along its boundary. Relevant roads include the A40, the B4047 to Minster Lovell and Witney and the A361 through Burford. As outlined in the Board’s Tranquillity Position Statement, we consider an increase in traffic movements of 10% or
more to be significant, particularly with regards to the tranquillity of the CNL.
We recommend that this assessment should be undertaken as part of the local plan evidence base.

The Cotswolds National Landscape (CNL) Board considers that, from a CNL perspective, Areas E and F are potentially suitable locations for strategic scale development. However, we are concerned that the total quantum of development proposed could potentially have an adverse impact on the dark skies of the CNL, as outlined below.
The proposed allocation at Area E is for a residential development of 700-800 dwellings and the proposed allocation at Area F is for a residential development of 1,500-2,500 dwellings.
Together they would provide up to 3,300 dwellings. As the names suggest, both allocations are on the north side of Carterton, as shown on the map below.
Area F comes within approximately 500m of the CNL boundary, which runs along Burford Road
(B4047) to the north. Area E comes within approximately 1km of the CNL boundary, which runs along the A40 to the north.
The map below is an extract from CPRE’s Light Pollution and Dark skies map. It shows that Carterton and the surrounding area already experience high levels of light pollution. Partes of Carterton are in the brightest colour band (band 9 – ‘brown’). The current northern limit of built development at Carterton is currently nearly 2km away from the CNL boundary. However, light pollution levels are such that light pollution from Carterton already spreads northwards into the
CNL in the vicinity of the roundabout at The Farmer’s Dog pub (where the A40 and the B4047 meet), which is in colour band 4 (‘green’).
The proposed allocations would bring the built development of Carterton approximately 1.5km closer to the CNL. As a result, are larger area of the CNL is likely to be affected by the resulting light pollution. For example, it is likely that colour band 4 (‘green’) is likely to extend further into the CNL, at least to Asthall and possibly beyond. At these levels of light pollution, it will not be possible to see the Milky Way. The light pollution at the edge of the CNL, in the vicinity, of the
A40 roundaboutis likely to increase to colour band 5 (‘yellow’), 6 (‘orange’) or even 7 (‘pink’). The area of relatively dark sky in the CNL (i.e. colour bands 3 (‘light blue’), 2 (‘dark blue’) and 1 (‘black’) would shrink.
With these points in mind, we recommend that the allocations should not come so close to the CNL boundary. For example, it may be appropriate to ensure that the allocations do not come within, say, 1k of the CNL boundary.
To help offset any increase in lighting / light pollution, it may be appropriate to address existing levels of lighting / light pollution in Carterton (i.e. ensure that lighting complies with relevant best practice lighting guidance).
Consideration should also be given to the extent to which the overall quantum of development proposed at Carterton (but particularly with regards to Areas E and F) is likely to increase traffic movements on roads within the CNL and / or along its boundary. Relevant roads include the A40, the B4047 to Minster Lovell and Witney and the A361 through Burford. As outlined in the Board’s Tranquillity Position Statement, we consider an increase in traffic movements of 10% or
more to be significant, particularly with regards to the tranquillity of the CNL.
We recommend that this assessment should be undertaken as part of the local plan evidence base.

The Cotswolds National Landscape (CNL) Board considers that Area D is potentially a suitable location for strategic scale development.
However, as with Area A, we have several concerns about the proposed allocation including:
• visual impact;
• impact on dark skies; and
• impact on tranquillity.
To address these issues, we recommend that the development should be more restricted in scale and that key criteria should be applied in order to (i) avoid and (ii) minimise any potential adverse impacts on the natural beauty of the CNL, as outlined below.
Context
The Witney preferred strategic spatial locations are shown on the map below. To provide some context we have added the CNL boundary onto the map.
Figure 6. Witney Preferred Strategic Spatial Locations and the Cotswolds National Landscape (shaded in red in the top left corner of the map)
Based on the map, it looks like Area D, which is intended to accommodate 600-800 dwellings, comes within approximately 280m of the CNL boundary. Area D would extend the built development of Witney further west along the south side of Burford Road (B4047) towards Minster Lovell.
Potential impacts in relation to the Cotswolds National Landscape
Visual impacts
The northern edge of the proposed allocation, along Burford Road, is at, or close to, the top edge of the slope on the south side of the Windrush Valley. The highest point of the allocation site is at the southern end of the most northerly fields. As these northerly fields, on the south side of Burford Road, are already gently dipping down towards the Windrush Valley before reaching the edge of the valley slopes at Burford Road.
Because of this topography, there could potentially be some intervisibility between built development on the site and publicly accessible viewpoints in the CNL, for example, in the
vicinity of Minster Lovell.
To avoid (or at least minimise) this intervisibility, we recommend that the two most northerly fields, on the south side of Burford Road, should not be allocated (or, at the very least should not be developed), as shown below.
To reduce the perception of coalescence with Minster Lovell, to the west, we also recommend that development should not extend as far west as the 115m contour line near Charterville
Allotments
Dark Skies
Please see our comment on dark skies relating to Area A.
Allocating Area D would potentially exacerbate light pollution issue in the Minster Lovell section of the CNL. However, this would be moderated, to some degree, by using our suggested alternative option, shown above.
Tranquillity
Please see our comments on tranquillity relating to Area A

Summary
The Cotswolds National Landscape (CNL) Board considers that, from a CNL perspective, Area A is potentially a suitable location for a strategic scale development.
However, we have several concerns about the proposed allocation including:
• visual impact;
• impact on dark skies; and
• impact on tranquillity.
To address these issues, we recommend that the development should be more restricted in scale and that key criteria should be applied in order to (i) avoid and (ii) minimise any potential adverse impacts on the natural beauty of the CNL, as outlined below.
Context
The Witney preferred strategic spatial locations are shown on the map below. To provide some context we have added the CNL boundary onto the map.
Figure 1. Witney Preferred Strategic Spatial Locations and the Cotswolds National Landscape
(shaded in red in the top left corner of the map)
Based on the map, it looks like Area A, which is intended to accommodate 600-800 dwellings,comes within approximately 500m of the CNL boundary. The boundary of Area A appears to extend northwards, from the B4047, past Hill Grove Farm and onto the upper slopes of the Windrush valley, on the south side of the valley.
Potential impacts in relation to the Cotswolds National Landscape
The potential impacts on the CNL primarily relate to the section of Area A to the west of Dry Lane.
The area to the east of Dry Lane is of less concern from a CNL perspective, although we recommend that the allocation should not extend to the east of the public rights of way (PROW) that are on the eastern valley slopes. This would help to ensure that views from these PROW, looking north eastwards across the Windrush valley. would not be adversely affected.
Visual impacts
If the allocation extends northwards past, or even as far as, Hill Grove Farm there are likely to be direct visual impacts on views from the CNL.
As shown in the photograph below, Hill Grove Farm can be clearly seen on the skyline when viewed from various locations along the minor road between Minster Lovel and Crawley, on the north side of the Windrush valley. The minor road marks the boundary of the CNL.
Figure 2. View looking south-east, from the minor road north-east of Minster Lovell, on the boundary of the Cotswolds National Landscape, towards Hill Grove Farm (with the farm on the skyline)
The buildings at Hill Grove Farm are agricultural farm buildings. As such they have a rural context. However, residential development extending onto this skyline would look particularly incongruous as there is no such development currently in these views. Extending Area A as far
north as Hill Grove Farm would, therefore, have a significant adverse impact on these views.
Even if built development is restricted to the land to the south of the track between the B4047 and Hill Grove Farm there could still be some direct visual impact.
The contour lines on the 1:25,000 scale Ordnance Survey map indicate that there is a ridge line to the south of Hill Grove Farm. As a minimum, we recommend that built development should not extend northwards of this ridge line. Ideally, built development would be set below this ridge
line, on the south side of the ridge.
The best option for avoiding any direct intervisibility between the allocation and the CNL
(Option 1) would be to have no development on the west side of Dry Lane (i.e. only the eastern half of Area A would be allocated).
The second best option from a CNL perspective (Option 2), with regards to the part of Area A that is located west of Dry Lane, would be to only allocate the field to the east of Curbridge Downs Farm, excluding the north west corner of the field that rises above the 110m contour
line.
Figure 3. Option 2 for Area A (red outline = limit of built development)
The third best option from a CNL perspective (Option 3) would be to plant a woodland belt along the south side of the track between the B4047 and Hill Grove and have built development to the south of this tree belt. Ideally, the woodland belt would be planted first and be allowed to
become well established before the residential development begins.
Figure 4. Option 3 for Area A (red outline = limit of built development; green outline = woodland belt / landscape mitigation)
The Board preference would be for Options 1 or 2. However, Option 3 could potentially be acceptable, provided that it can be clearly evidenced that there would be no direct intervisibility between the built development on site and publicly accessible viewpoints in – or along the boundary of – the CNL. However, consideration also needs to be given to potential impacts on dark skies and tranquillity, as outlined below.
Dark skies
One of the ‘special qualities’ of the CNL is the area’s dark skies.45 As such, it is important that development in the CNL, or in its setting, does not increase levels of light pollution, including sky glow, within the CNL.
The image below is an extract from CPRE’s Light Pollution & Dark Skies map. It shows that Witney, as a whole, already experiences high levels of light pollution, reaching the second
highest brightness band (colour band 8 – ‘red’) in the town centre and in the industrial areas.
In the vicinity of Minster Lovell, some light pollution already extends into the CNL (colour band 4 – ‘green’). If Area A is developed, the ‘green’ level of light pollution (colour band 4) that is currently shown to the north of this site would potentially be extended, northwards, into the CNL. Similarly, the ‘orange’ level of light pollution (colour band 6) that is shown to the west of the site would also potentially be extended into the CNL. In other words, the allocation has the
potential to adversely affect the dark skies of the CNL.
Figure 5. Extract from CPRE’s Light Pollution & Dark Skies Map showing levels of light pollution in the vicinity of Witney (with the Cotswolds National Landscape boundary shown as a pink line)
This light pollution could be exacerbated by the fact that the development would be on, or approaching, the skyline, when viewed from the CNL. As such, ‘sky glow’ would be a particular
concern. This makes it particularly important not to extend built development over the ridge that we referred to in relation to visual impacts, above.
To help address this issue, it is essential that built development should comply with best practice lighting guidance, particularly guidance relating to protected landscapes, including the lighting guidance that has recently been adopted by the Board.
To help offset any increase in lighting / light pollution, it may be appropriate to address existing levels of lighting / light pollution in Witney (particularly the industrial area to the west of Deer Park Road) and in Minster Lovell (i.e. ensure that lighting in these locations also complies with relevant best practice lighting guidance).
Tranquillity
One of the ‘special qualities’ of the CNL is the area’s relative tranquillity.46 As such, it is important that development in the CNL, or in its setting, does not adversely impact on the
tranquillity of the CNL.
A key consideration, in this regard, is the extent to which the proposed allocations, both individually and collectively, would increase traffic movements on roads within – and / or along
the boundary of – the CNL. As outlined in Section 4.5 of the Board’s Tranquillity Position Statement we consider that increases in traffic movements of 10% or more are significant and are likely to have an adverse impact on tranquillity.47
Given the quantum of development proposed at Area A (600-800 dwellings), there is a risk that the traffic movements resulting from the proposed allocation would exceed this 10% threshold, for example, on Burford Road (B4047) and on the minor roads north of Minster Lovell.
This is likely to be further exacerbated when Area D (which would provide a further 600-800 dwellings is factored in).
To ensure that the allocation is sound, we recommend that an assessment of the potential increase in traffic movements should be undertaken as part of the local plan evidence base. It this assessment identifies that the allocation(s) are likely to increase traffic movements by 10% or more, consideration should be given to reducing the quantum of development proposed on these sites.

No, the Cotswolds National Landscape (CNL) Board does not support the principle of updating and refreshing the existing allocation for the East Chipping Norton SDA as part of the Local Plan 2043.
As outlined in our response to questions 2 and 5, above, we consider that strategic scale residential development at Chipping Norton is not appropriate. Therefore, rather than updating and refreshing the existing allocation, we recommend that the Local Plan should not include a
strategic-scale residential development (or strategic development area (SDA)) at Chipping Norton. Instead, we recommend that the Council should consider allocating a quantum of development that is smaller than strategic-scale (i.e. smaller than 300 dwellings).
Much, if not all, of the existing allocation to the south of London Road is clearly no longer viable as an allocation, given that: (i) part of the site is now allocated as a scheduled monument; and (ii) the primary landowner (Oxfordshire County Council Property and Facilities) has indicated that it
no longer wishes to bring forward the whole of the land it owns to the south of London Road.
As such, we support the principle of reviewing and refreshing the options for allocating residential development (just not at a strategic scale).

Meeting identified needs in full
No, the Cotswolds National Landscape (CNL) Board does not agree with the principle of West Oxfordshire meeting its identified housing and employment development needs in full. We support the principle of seeking to meet these needs in full but that is not necessarily the same thing as actually being able to meet them.
When considering this question, it is important to distinguish between housing ‘need’ and housing ‘requirement. The Government’s planning practice guidance (PPG) on Housing and economic needs assessment states that ‘housing need is an unconstrained assessment of the minimum number of homes needed in an area’,33 whereas ‘the housing requirement is the minimum number of homes that a plan seems to provide during the plan period’
34 (N.B. Underlining added for
emphasis).
This PPG also states (N.B. Underlining added for emphasis):
• Assessing housing need is the first step in the process of deciding how many homes need to be planned for. It should be undertaken separately from assessing land availability,
establishing a housing requirement figure and preparing policies to address this such as site allocations.
• The standard method … identifies a minimum annual housing need figure, and ensures that plan-making is informed by an unconstrained assessment of the number of homes needed in an area. It does not produce a housing requirement figure.
• Once local housing need has been assessed …authorities should then make an assessment of the number of new homes that can be provided in their area. This should be justified by evidence on land availability, constraints on development and any other relevant matters.
So, a key difference between housing need and housing requirement is that the housing need figure is unconstrained, whereas the housing requirement figure factors in relevant constraints.
The way in which constraints should be addressed once a housing need figure has been identified is set out in the Government’s Housing and Economic Land Availability Assessment
PPG.38 Key extracts from this PPG are provided in Appendix 1 of the Board’s Housing Position
Statement.
This issue is also addressed in Paragraph 11b(i) of the National Planning Policy Framework
(NPPF), which states:
(b) strategic policies should, as a minimum, provide for objectively assessed needs for housing and other uses … unless:
(i) the application of policies in this Framework that protect areas or assets of particular importance provides a strong reason for restricting the overall scale, type or distribution of development in the plan area…
Footnote 7 of the NPPF clarifies that these areas or assets of particular importance include National Landscapes, for which the relevant paragraphs of the NPPF are, primarily, paragraphs 187(a), 189 and 190.
So, if the application of NPPF policies relating to National Landscapes provides a strong reason for restricting the overall scale, type or distribution of development in the plan area, then it would be appropriate to set a housing requirement figure that is lower than the housing need
figure. The same principle applies in relation to employment development needs.
In effect, allocations and spatial development strategies that conflict with paragraph 11b(i) would not constitute sustainable development. As such, they would also conflict with the purpose of the planning system, which is ‘to contribute to the achievement of sustainable
development’.
This ‘exemption’ from meeting the assessed housing and employment needs in full is also reflected in the Government’s Natural Environment PPG, which states that the NPPF’s policies for protecting National Landscapes ‘may mean that it is not possible to meet objectively assessed
needs in full through the plan-making process’.
This exemption is also acknowledged in the Government’s response to the proposed reforms to the NPPF and other changes to the planning system, which states:
• It is recognised that there may be local constraints on land and delivery that could justify a lower housing requirement figure.
In effect, allocations that conflict with paragraph 11b(i) would not constitute sustainable development. As such, they would also conflict with the purpose of the planning system, which
is ‘to contribute to the achievement of sustainable development’.
Based on the above points, we consider that the key question is whether the application of NPPF policies that protect the areas or assets of particular importance that are referred to in Footnote 7 of the NPPF provides a strong reason for restricting the overall scale, type or distribution of development in the plan area.
Based on the draft Local Plan, we consider that the application of NPPF policies relating to National Landscapes does provide a strong reason for restricting the overall scape, type or distribution of development in the plan area.
Environmental and infrastructure constraints
Yes, the Board considers that there are environmental and infrastructure constraints, beyond those referred to in Section 6, that should influence the development requirements for the Plan.
From the Board’s perspective, the most important environmental ‘constraint’that should influence the development requirements for the Plan is the Cotswolds National Landscape (CNL).
Section 6 does refer to relevant considerations such as ‘valued landscapes’, ‘the intrinsic character and beauty of the countryside’ and ‘an attractive natural landscape’. It could be the District Council’s intention that these references cover CNL considerations. However, we recommend that explicit reference should be made to the CNL in Section 6.
The CNL is particularly significant, in this regard, because:
• National Landscapes are one of the assets / areas of particular importance that are listed in Footnote 7 of the NPPF.
• One third (33.9%) of West Oxfordshire overlaps with the CNL.
• The CNL overlaps with:
o One out of three Tier 1 settlements;
o Two out of seven Tier 2 settlements;
o Three out of 11 Tier 3 settlements;
o 10 out of 19 Tier 4 settlements.
It may also be appropriate to explicitly refer to other relevant assets / areas of particular importance, in the context of paragraph 11d and footnote 7 of the NPPF.
In this regard, we are disappointed to see the following statement in paragraph 6.37 of the consultation document:
• Although the environmental qualities of West Oxfordshire will not have a bearing on calculating housing and economic needs for the district (the district council intends to meet
its development requirements in full), it will have a strong influence on how development is distributed in the district.
Firstly, this sentence inappropriately conflates housing need and housing requirement – please refer to our comments on this issue in our response to the first part of Question 6. Secondly, it ignores the exemptions that are provided for in paragraph 11d(i) of the NPPF. It is too early in the
Local Plan process – with an insufficient evidence base - to rule out these exemptions and to categorically state that West Oxfordshire could, or should, meet its development requirements in full.

No, overall,the Cotswolds National Landscape (CNL) Board does not support the revised spatial
strategy.
We do support some aspects of the spatial strategy. For example, we support the following points in Core Policy 3 – Spatial Strategy:
• Delivering a sustainable pattern of development that … enhances the environment and recovers nature [and] protects the unique identify and character of West Oxfordshire’s towns, villages and countryside.
• Conserve and enhance the Cotswolds National Landscape, with great weight given to landscape and scenic beauty and a limit on development.
• Prioritise sustainable travel and infrastructure alignment.
However, we consider that some of the proposed scales of development are excessive for some of the individual CNL settlements within the different tiers of the settlement hierarchy, as outlined below.
Principal Towns (Tier 1)
As indicated in our response to Question 2, we consider that developments or allocations at Chipping Norton would be disproportionate if they exceed approximately 160 dwellings (or approximately 320 dwellings for parts of the settlement that are located outside the CNL). As such, we consider that strategic-scale residential development (i.e. 300+ units) would not be appropriate at Chipping Norton. If the Board’s five scales of development are applied, we consider that residential development at Chipping Norton should not exceed ‘large-scale’ sites (51-150 units).
The draft Core Policy 3 (Spatial Strategy) states that ‘Witney, Carterton and, to a lesser extent, Chipping Norton will be the primary focus for growth’ (N.B. Underlining added for emphasis). We are pleased to see that this indicates that a more restrictive approach will be taken in Chipping
Norton, compared to Witney and Carterton. However, the current wording is too vague.
We recommend that this more restrictive approach should be made more explicit. In particular, we recommend that the policy should explicitly state that strategic-scale sites will not be considered appropriate at Chipping Norton, other than in exceptional circumstances. If the Board’s five scales of development are applied, the same principle should also apply to ‘very large scale’ sites (i.e. 151-300 units) for proposals within the CNL part of the settlement (i.e.
such proposals will not be considered appropriate, other than in exceptional circumstances).
It should also be explicitly stated that a more restrictive approach is appropriate at Chipping Norton because it is located in the CNL (with the parts of Chipping Norton that lie outside the CNL still forming part of what is, essentially, a CNL settlement).
The proposed East Chipping Norton Strategic Development Area (SDA) has an estimated development capacity of 750 homes, which would represent a 24% increase compared to the 2021 baseline. This, on its own, far exceeds what the Board would consider to be proportionate (i.e. it is nearly 2.5 times larger than the 10% rule of thumb threshold that we consider should apply for proposals in the parts of Chipping Norton that are located outside of the CNL).
The extent to which Chipping Norton should be expected to accommodate further housing, over and above this allocation, within the Plan period should be limited. Ideally, it should not include anything over ‘medium-scale’ (i.e. 11 to 50 units).
Service Centres (Tier 2)
The draft Core Policy 3 states that:
• the Tier 2 settlements ‘will accommodate a proportionate level of growth appropriate to the size of each settlement’;
• the scale and extent of development at Burford and Charlbury will be limited in accordance with national policy (due to their location within the CNL);
• it is anticipated that future development include a combination of small and medium-scale sites.
The Board supports these principles as they are consistent with national planning policy relating to National Landscapes. With regards to what is meant by ‘a proportionate level of growth’, we recommend that our 5% ‘rule of thumb’ threshold should be applied for settlements in the CNL31 – please refer to our response to Question 2 for further details.
However, we are concerned by the following statement:
• …with additional large and strategic-scale development only taking place through existing permissions and allocated sites.
The presumption against major development, that is set out in paragraph 190 of the NPPF, should be applied to Local Plan allocations, not just to future windfall development. With this in mind, we consider that our 5% ‘rule of thumb’ threshold should be applied to allocations as well as to future windfall development – please refer to our response to Question 2 for further details So, in principle, even the proposed allocations should not exceed medium scale in Tier 2 settlements in the CNL.
The proposed South of Sheep Street allocation at Burford, which is within the CNL, has an estimated development capacity of 70 homes, which would represent a 10.2% increase compared to the 2021 baseline. This, on its own, is double what the Board would consider to be proportionate.
The extent to which Burford should be expected to accommodate further housing, over and above this allocation, within the Plan period should be limited. Ideally, it should not include developments larger than ‘small-scale’ (i.e. 1 to 10 units).
With regards to Charlbury, the proposed Land South of Hydac allocation (40 dwellings) and the proposed Jefferson Place allocation (40 dwellings) have a combined estimated development capacity of 80 dwellings, which would represent a 5.7-6.3% increase compared to the 2021 baseline. These allocations, on their own, exceed what the Board would consider to be proportionate.
The extent to which Charlbury should be expected to accommodate further housing, over and above this allocation, within the Plan period should be limited. Ideally, it should not include developments larger than ‘small-scale’ (i.e. 1 to 10 units) and certainly not more than ‘mediumscale’ (i.e. 11-50 units).
Residential development proposals outside the settlement boundary should be focussed on meeting identified affordable housing needs specific to the settlement or parish.
Large Villages (Tier 3)
The draft Core Policy 3 states that ‘small and medium scale growth will be supported’ in Tier 3 settlements ‘where proportionate to the size of the settlement’. It also states that ‘the scale and extent of development within the Cotswolds National Landscape will be limited in accordance with
national policy’.
In principle, we support this approach.
However, the policy allows for larger scale allocations ‘where infrastructure capacity existing to address the identified local circumstances and needs’. In this context, it is important to bear in mind that the presumption against major development should be applied at the plan-making
stage (i.e. for allocations) as well as for development management. So, in principle, even the allocations should not exceed medium scale in Tier 3 settlements in the CNL.
Residential development proposals outside the settlement boundary should be focussed on meeting identified affordable housing needs specific to the settlement or parish.
Medium Villages (Tier 4)
The draft Core Policy 3 states that ‘a more restrictive policy will be applied to villages recognising the relative sustainability of these communities’. More specifically, it states that ‘new residential development at Tier 4 Medium Villages will typically be expected to be small scale only’.
In principle, we support this approach.
However, the policy allows for larger scale allocations ‘where infrastructure capacity existing to address the identified local circumstances and needs’. In this context, it is important to bear in mind that the presumption against major development should be applied at the plan-making stage (i.e. for allocations) as well as for development management. So, in principle, even the allocations should not exceed small scale in Tier 4 settlements in the CNL.
With this in mind, it is important to note that the draft Local Plan proposes an allocation of 70 dwellings between Kingham and Bledington. The 2021 census indicates that Kingham has a baseline housing figure of between 165 households (in the built-up area) and 332 households (in the parish as a whole). Appling the Board’s 5% ‘rule of thumb’ threshold for proportionality means that development of more than 16 dwellings should be considered disproportionate
(compared to the baseline figure for the parish as a whole). The allocation of 70 dwellings exceeds this figure by more than four-fold. On this basis, the Board considers that the proposed allocation definitely constitutes major development, in the context of paragraph 190 of the
NPPF.
Residential development proposals outside the settlement boundary should be focussed on meeting identified affordable housing needs specific to the settlement or parish.
Focus growth along the A44 Corridor Draft Core Policy 3 proposes strategic-scale growth at Chipping Norton.
As outlined in response to Questions 2 and 5 above, in relation to Tier 1 settlements, we do not consider that strategic-scale growth would be appropriate at Chipping Norton.
We acknowledge that the services and facilities that Chipping Norton provides, including good public transport provision, make it a focal point for development. However, that has to be balanced within its status as a CNL settlement. Even if future development is primarily focussed on parts of the settlement that lie outside the CNL, this could still have a significant adverse effect on the character of this CNL settlement as a whole.
As indicated above, we consider that Chipping Norton should not be expected to accommodate more than approximately 300 dwellings (including allocated sites), primarily outside the CNL, during the Plan period. In the context of a CNL settlement, we consider that this is still a very substantial level of growth
For these reasons, we do not support section 2b of Core Policy 3 as it currently stands.
We recommend that section 2b should be changed such that the level of growth specified for Chipping Norton does not exceed large-scale (or, if the Board’s suggested five scales of
development is used, very large scale).

Test

No, the Cotswolds National Landscape (CNL) Board does not support the four proposed scales of residential development.
We support the definitions of ‘small’ and ‘medium’ scale development (1-10 units and 11-50 units respectively). However, we consider that the ‘large’ scale category 51-300 units is too broad and should be further sub-divided. A relevant consideration, in this regard, is that one of
the thresholds for urban development projects in Schedule 2 of the Environmental Impact Assessment regulations is 150 dwellings.
On this basis, we recommend that there should be five scales of residential development, rather than four, as follows:
• Small-scale residential development – 1 to 10 units
• Medium-scale residential development – 11 to 50 units
• Large-scale residential development – 51 to 150 units
• Very large scale residential development – 151 to 300 units
• Strategic-scale residential development – 300+ units
With all of these scales, there is a risk that developers would seek to apply the higher end of the relevant thresholds, which could be disproportionate to the specific settlement in question.
Therefore, the Board’s ‘rule of thumb’ thresholds for proportionality, referred to in our response to Question 2, should also be taken into account in relation to CNL settlements (including settlements that overlap with the CNL boundary).

Yes, the Cotswolds National Landscape (CNL) Board thinks that the settlements listed in Table 2 have been classified in the correct tier, based in a combination of population and each settlement’s sustainability score in the Council’s Settlement Sustainability Report (SSR).
However, as outlined above, in our response to Question 2, we recommend that there should be separate columns for (i) settlements within the CNL and (ii) settlements outside the CNL.
The Board’s ‘rule of thumb’ thresholds for proportionality, referred to in our response to Question 2, should also be taken into account in relation to CNL settlements (including
settlements that overlap with the CNL boundary).

Yes, in principle, the Cotswolds National Landscape (CNL) Board supports the concept of introducing an additional tier into the local plan settlement hierarchy to distinguish between large and medium-sized villages.
As stated in paragraph 4.9 of the consultation document, this would help to ‘distinguish between larger villages within which communities can largely meet their day-to-day needs for goods and services and medium and smaller villages that are relatively less sustainable in terms of communities meeting their day-to-day needs’.
We agree with that rationale.
However, the implications for CNL settlements need to be carefully considered and explicitly addressed, as outlined below.
Many of the settlements in the top three tiers of the new hierarchy are located within the CNL, as shown below:
• Tier 1 – Principal Towns: Chipping Norton (one out of three Tier 1 settlements)
• Tier 2 – Service Centres: Burford and Charlbury (two out of seven Tier 2 settlements)
• Tier 3 – Large Villages: Milton-under-Wychwood, Shipton-under-Wychwood and
Stonesfield (three out of 14 Tier 3 settlements)
There are additional CNL settlements within Tiers 4 and 5 of the settlement hierarchy.
For all of the settlements within the CNL, regardless of their position in the settlement hierarchy:
(i) the scale and extent of development should be limited;
(ii) permission should be refused for major development other than in exceptional
circumstances and where it can be demonstrated that the development would be in the public interest.
We recommend that these policy principles should be explicitly addressed in the settlement hierarchy. For example, we recommend that the settlement hierarchy table should haveseparate columns for (i) settlements within the CNL and (ii) settlements outside the CNL, as shown below.
Table 1. Settlement Hierarchy, differentiating between settlements outside the Cotswolds
National Landscape (CNL) and settlement that are within – and / or overlap with – the CNL.
The following points should also be taken into consideration and explicitly addressed in the supporting text.
Policy CE1 of the CNL Management Plan states that:
• Proposals that have the potential to impact on … the landscape of the Cotswolds National
Landscape (CNL) should be delivered in a way that is compatible with and seek to further the conservation and enhancement of the landscape character of the location, as described in the CNL Board’s Landscape Character Assessment and Landscape Strategy and Guidelines.
The CNL Landscape Character Assessment and CNL Landscape Strategy & Guidelines address each of the 19 different landscape character types (LCTs) within the CNL individually. Many of the guidelines in the Landscape Strategy & Guidelines are common to all of the LCTs. These
include:
• Ensure new development is proportionate and does not overwhelm the existing settlement.
• Ensure that new development does not adversely affect settlement character and form.
• Avoid development that will intrude negatively into the landscape and cannot be successfully mitigation.
In the context of the CNL, the Board considers allocations and / or development proposals to be disproportionate if they would increase the size of a settlement, or the number of dwellings in a settlement by more than 5%.22 Where this is the case, the allocation, or development proposal:
• would also conflict with the requirement, in paragraph 189 of the NPPF, for the scale and extent of development to be limited; and
• is likely to constitute major development, in the context of paragraph 190 of the NPPF.
Most settlements are either entirely within the CNL or entirely outside the CNL. However, for Burford and Chipping Norton, the historic core of the settlements is within the CNL, as is the majority of existing built development, but the settlements have extended beyond the CNL boundary (i.e. into the setting of the CNL). Development, in these settlements, that is located outside the CNL has the potential to adversely affect the natural beauty of the CNL. Therefore,
the question of proportionality is still a key consideration.
However, it could be argued that a slightly less restrictive approach to proportionality would be appropriate in the parts of these two settlements that are located outside the CNL (depending, to some degree, on the extent to which they are overlooked from viewpoints within the CNL).
As such, a threshold of 10% might be more appropriate in these locations.
In Table 2, below, we have identified the baseline number of households for each CNL settlement and the number of additional dwellings that would be represented by a 5% increase.
The baseline 2021 census data has been obtained from the ‘build a custom area profile’ of the Office for National Statistics website.
The above considerations, in relation to CNL settlements (including Burford and Chipping Norton), have significant implications for the extent to which CNL settlements, including those in Tiers 1 to 3, should be expected to accommodate larger scales of development. We address
this in our comments on the proposed spatial strategy and on the individual settlements, later in this consultation response.

OCC controls the land that is proposed to be allocated under AREA U – Rousham
Road, Tackley for approximately 70 dwellings. We support this draft allocation and are looking forward to work together with the West Oxfordshire District Council Planning Policy Team to deliver a development proposal that aligns with the most recent press release from the Ministry of Housing, Communities and Local Government, The Rt Hon Steve Reed OBE MP and The Rt Hon Rachel Reeves MP, which highlighted the significance of boosting high density housebuilding by
providing high-quality homes in areas that are well-connected with train stations.
It is considered that the site has the capacity to accommodate approximately 70 dwellings with a policy compliant affordable housing mix and also include the
provision of other important elements, such as public open space and commercial uses.
We would also like to highlight that we are currently in the process of arranging a meeting with the Parish Council to better understand the needs of the local area and
to ensure that the community-led proposal that is submitted for this site in the future is fully supported by both the Parish Council and the local community.

OCC controls the southern part of the land that is proposed to be allocated under AREA M for approximately 40 dwellings. The allocation of the OCC-controlled land is also supported in-principle; however, we strongly object to the suggestion that this land parcel should be delivered jointly with the adjoining land to the north, which is not owned by OCC.
It is significant to highlight that an outline application in relation to the OCC-controlled land for nine market and three affordable homes together with land reserved for
community use is currently live and based on recent discussions we have had with the case officer, it is understood that a positive decision is imminent in the new year.
This community-led proposal was put forward after lengthy discussions with key stakeholders and is supported by both the Parish Council and the local community and aims to deliver much needed homes, community open space and a community hub to meet an identified local need in the short term.
On the contrary, the development of the northern part of the draft allocation site is not supported by either the Parish Council or the local community, and therefore it is
considered unfair to require from all relevant parties to collaborate with each other.
We are concerned that the current draft allocation will result in a residential scheme which will not meet an identified local housing and community need and will also significantly delay the delivery of much needed homes and provision of community open space and a community hub due to the negotiations which will need to be conducted between the landowners to agree a joint masterplan.

We agree with updating the allocation and focusing development on the OCCcontrolled land north of London Road which lies within and immediately adjacent to
the existing SDA in the short term, as the archaeological evaluations that have been undertaken for this area indicate that the site has very limited archaeological potential, with any remains likely to be of local archaeological significance only.
It is considered that this site can support the Council’s housing targets for Chipping
Norton by delivering at least 350 homes. The housing figure has been carefully calculated by taking into account local context, planning constraints and findings of all of the technical surveys that have been carried out to inform the proposals at this stage.
Notwithstanding this, it is also considered that the land to the south of London Road can also accommodate a large number of homes immediately to the south of London Road. This number is considered to be in the region of 100 to 150 units, which would increase the indicative capacity of the updated SDA area to 800-850 homes in total.
The archaeological investigation that has been carried out for this site demonstrates that the site is likely to have limited archaeological potential. Therefore, it is unlikely that archaeology could prevent its development in the medium term.

OCC owns the northern part and an area of the southern part that falls within the land east of Chipping Norton Strategic Development Area (SDA), part of which is currently allocated for about 1,200 homes under policy CN1 in the adopted West
Oxfordshire Local Plan 2031.
The principle of updating and refreshing the existing allocation is supported, as it is acknowledged that the decision of Historic England to designate part of the southern
part of the SDA as a Scheduled Monument has had an impact on the wider commitments that would be delivered in the SDA. Whilst the land controlled by OCC to the south of London Road is unaffected by the Scheduled Monument designation, it has impacted on its delivery in the short term due to the need for significant archaeological fieldwork.
Paragraph 7.75 states that:
“Importantly, the primary landowner (Oxfordshire County Council Property and Facilities) has indicated that it no longer wishes to bring forward the whole of the land it owns to the south of London Road.”
It is important to highlight that this statement is not accurate and we would like to make clear that the OCC-controlled land to the south of London Road and within the SDA continues to be available to meet the local needs of the community, such delivering residential development in the region of 100 to 150 homes in a broad area roughly in line with the Parker Knoll development immediately to the west, biodiversity enhancements in accordance with OCC’s Local Nature Recovery Strategy (LNRS), providing public open space and new school site. As highlighted earlier above, due to the need to undertake further exploratory archaeological work,
this site is anticipated to come forward in the medium term.

Strategic Planning
It is understood that at this stage, the employment floorspace figures provided are indicative and would need updating to match the plan period until 2043. OCC supports and encourages employment coming forward close to existing housing or as part of mixed-use developments in order to maximise containment of trips and in turn reduce transport impacts. Employment sites should be well connected with existing and planned housing and enable sustainable travel options.
Consideration should be given to increased densities in the most accessible locations (i.e. near town centres and bus/train stations) which would assist delivering additional housing, in line with growth aspirations which are expected to be set out in the draft NPPF to be published at the end of
2025.
A number of proposed allocations conflict with the OMWLP for which an objection is raised, in particular for Kilkenny Farm, Upper Norton and Land north of Brize Norton and Carterton, Foxbury Farm. As currently proposed, these two allocations have the potential to significantly sterilise
valuable mineral resources.
Education
Witney (Proposed allocations A – D)
Using the housing mix outlined in draft policy DM27 and the affordable/market split outlined in draft policy DM28 of the WODC Local Plan Preferred Policy Options Consultation Paper (June 2025), it is estimated that the proposed new strategic housing allocations in Witney (adding up to between
1800-2400 new homes) will generate:
• Between 500 – 700 primary and nursery pupils
• Between 350 and 450 secondary and sixth form pupils
• Between 10 and 20 pupils requiring education at a special school.
These estimates will be refined as further information (e.g. on anticipated trajectories) becomes available. Education capacity would be provided through a mix of new and expanded schools.
OCC notes that four new strategic housing allocations are being considered in Witney. As the Education Authority, OCC is responsible for providing pupil places to meet the needs arising from these new developments. Additionally, OCC needs to address the demand for pupil places for
Special Educational Needs (SEN). OCC would welcome the opportunity to explore the direct delivery or co-location of SEN provisions on any school sites proposed for these new allocations or the repurposing of any existing school sites for this purpose.
Carterton (Proposed allocations E – I)
Using the housing mix outlined in draft policy DM27 and the affordable/market split outlined in draft policy DM28 of the WODC Local Plan Preferred Policy Options Consultation Paper (June 2025), it is estimated that the proposed new strategic housing allocations in Carterton (up to 4,300 new
homes) will generate:
• Up to 1300 primary and nursery pupils
• Up to 850 secondary and sixth form pupils
• Up to 30 pupils requiring education at a special school
These estimates will be refined as further information (e.g. on anticipated trajectories) becomes available. Education capacity would be provided through a mix of new and expanded schools.”

AREA W – Welch Way, Witney
Strategic Planning
This is a location close to services and amenities which could benefit from increased densities and adequate placemaking as part of a regeneration project. The development of a project brief or masterplan should be considered as part of the allocation to assist setting the vision for the area.
Place Planning
Support the Local Plan process in developing targeted policy to guide any regeneration of the Welch Way area. There is significant opportunity to enhance the place-making of this area and policy should guide high quality spaces between the buildings as much as the potential development parcels themselves. Bus accessibility in this part of Witney is limited and this should be enhanced through this scheme.
Landscape and Nature Recovery
This area as mapped currently includes parcels of priority deciduous woodland and good quality semi-improved grassland. These ecological features need to be carefully considered alongside the LNRS when considering inclusion of this allocation and the allocation boundary.
Public Health
Whilst it is supported in principle that this represents a brownfield site in a sustainable location for new housing, there are some concerns about the loss of healthcare facilities. This site currently includes a GP surgery and hospital, providing a vital recourse for local residents. It will be essential that any proposals to develop here include mitigations for existing healthcare facilities.

AREA V – Enstone Airfield
Minerals & Waste
There is a permitted waste management facility within the proposed allocation for employment use.
Should the site progress, we would expect the future Local Plan Policy for this site to include wording to ensure future developments demonstrate that they will not directly or indirectly prevent or prejudice the use of the waste facility.
Place Planning
The nearest bus service route does not run past the site at Enstone airfield. The nearest bus stop is over a 20 minute cycle away and over an hours walk away. It is unrealistic therefore to assume that employees would use public transport or walk from nearby residential areas.
There is no cycling provision to the site. The B road has large volumes of traffic and a high speed limit of 50mph. This does not create a safe environment for cyclists.
For the development to be suitable, there would need to be consideration of where employees travel to/from. At present, the site encourages car reliance. There would be an expectation for the site to improve active travel connections or have a bus/mini-bus service to/from Enstone bus stops,
so there is opportunity for employees to use public transport.
Archaeology
A barrow cemetery is recorded c. 450m south of the proposal site and a geophysical survey recorded ring ditches with associated features c. 725m northwest of the proposal site. A small Iron Age settlement was recorded c. 760m northeast of the proposal site. This grouping of previously
recorded features could suggest that further remains lie within the proposal site. Though the site was used as an airbase from 1942, the western area, within the limits of the airbase, remained relatively undeveloped. This leaves the possibility for archaeological remains to survive in this
area.

AREA U – Rousham Road, Tackley
Strategic Planning
Please see Appendix 2: OCC Estates response to the draft local plan consultation, as it contains useful information on the proposed allocation from OCC Estates perspective.
Place Planning
Improvements to walking and wheeling infrastructure link between Tackley Station and site required. Current layout on Nethercote Road is unsuitable for pedestrians - especially for people with accessibility issues, significant improvements would be required.
Archaeology
Cropmarks have been identified within the site, though they have not been investigated in the ground. An archaeological desk based assessment will be required to support any planning application for this site.

AREA T – The Downs Standlake
Minerals & Waste
Mineral deposits are finite resources and can only be worked where they exist in the ground. It is Government policy that important mineral resources should be safeguarded for the long term.
Oxfordshire County Council are the Mineral Planning Authority, and we are required to identify Mineral Safeguarding Areas so that resources are not sterilised by non-mineral development. This is undertaken through the Oxfordshire Minerals and Waste Local Plan Part 1: Core Strategy.
This potential allocation within the forthcoming West Oxfordshire Local Plan falls within a Mineral Safeguarded Area for Sharp Sand and Gravel, and therefore Policy M8 of the adopted Minerals and Waste Local Plan Part 1: Core Strategy applies and should be considered.
It should also be noted that this safeguarded area is identified as a strategic resource area, and therefore a principal location for future mineral extraction, for sharp sand and gravel in Policy M3.
This proposal could prevent the mineral that falls within the proposed allocation area from being worked, unless it was proposed to be worked ahead of any mixed use development.
Considering Policy M8, the site is not allocated for development in an adopted local plan or neighbourhood plan; nor has it been shown that the need for the development outweighs the economic and sustainability considerations relating to the mineral resource; nor is it proposed that the mineral will be extracted prior to the development taking place.
Therefore, at this stage, without any further evidence or information, the proposal is contrary to Policy M8 of the adopted Minerals and Waste Local Plan Part 1: Core Strategy and we object to this site being included as a proposed allocation and should not be included within the draft West
Oxfordshire Local Plan. It is recommended that a Mineral Resource Assessment to assess the impact on the Mineral Safeguarding Area is prepared to provide evidence to enable full consideration of this potential site.
Place Planning
This site at Standlake is removed from the existing amenities in the village centre and significant improvement in walking, wheeling and cycling access to the main village will be required to reduce car dependency. Improvements in public transport services, and access to bus stops will also be
required.
Transport Strategy and Policy
There is very little information on sustainable access to the site. We would we request that this allocation is updated to include the need to provide walking, wheeling and cycling and public transport improvements accessibly are suitable and what improvements would be required to
support a development at this location.
Archaeology
An archaeological evaluation has been undertaken on part of this site which recorded Late Bronze Age to Iron Age occupation, represented by pits, postholes, gullies and ditches. A concentration of Late Iron Age/Early Roman deposits were identified in the easternmost corner of the field and an Early Saxon sunken feature building and Late Saxon/Early medieval pit were also identified.
Standlake has a very rich archaeological potential and numerous cropmarks have been recorded in the area representing occupation from the Neolithic period. The remainder of the site will need to undergo an evaluation ahead of any planning application.

AREA S – Middle Barton
Minerals & Waste
Mineral deposits are finite resources and can only be worked where they exist in the ground. It is Government policy that important mineral resources should be safeguarded for the long term.
Oxfordshire County Council are the Mineral Planning Authority, and we are required to identify Mineral Safeguarding Areas so that resources are not sterilised by non-mineral development. This is undertaken through the Oxfordshire Minerals and Waste Local Plan Part 1: Core Strategy.
The northern boundary of this site, identified for the potential allocation within the forthcoming West
Oxfordshire Local Plan just falls within a Mineral Consultation Area for an identified Mineral Safeguarded Area for Soft sand, and therefore Policy M8 of the adopted Minerals and Waste Local Plan Part 1: Core Strategy applies and should be considered.
However upon reviewing the proposed allocation, the top corner within the consultation area is just over 250m away from the safeguarded area, and so we do not feel that it would prevent the working of any future mineral, however to avoid any hindering of any future mineral working,
mitigation for this should be incorporated into any future allocation.

AREA R – Kingham Station
Strategic Planning
The District is encouraged to explore the potential for increased densities close the station, subject to other planning and environmental considerations.
Place Planning
The provision of facilities and amenities will be largely located in Kingham and Bledington which are a significant walking distance from the proposed site (circa 2km). Improvement to active travel infrastructure on Station Road is required to facilitate walking and wheeling between the proposed
site and the facilities in the adjacent villages.
Transport Strategy and Policy
While the location of the site within proximity to Kingham station is good, the local facilities (shops, school, take-away, etc) will be located between 1-2km from he site. Walking, wheeling and cycling links to these facilities should be given more emphasis. As should public transport access to the
key local service centre of Chipping Norton.
Landscape and Nature Recovery
This area as mapped is currently located immediately adjacent to a parcel of priority deciduous woodland habitat. This ecological feature will need to be carefully considered alongside the LNRS when considering inclusion of this allocation and the allocation boundary.
Archaeology
Though the site lies outside the historic core of Kingham, the archaeological potential will need to be assessed as part of any planning application on the site.

AREA Q – South of Ducklington
Minerals & Waste
Mineral deposits are finite resources and can only be worked where they exist in the ground. It is Government policy that important mineral resources should be safeguarded for the long term.
Oxfordshire County Council are the Mineral Planning Authority, and we are required to identify Mineral Safeguarding Areas so that resources are not sterilised by non-mineral development. This is undertaken through the Oxfordshire Minerals and Waste Local Plan Part 1: Core Strategy.
Please also see Minerals and Waste Policy and Strategy teams response to 25/00423/OUT.
This site, identified for the potential allocation within the forthcoming West Oxfordshire Local Plan falls within a Mineral Consultation Area for an identified Mineral Safeguarded Area for Sharp Sand and Gravel.
It should also be noted that this safeguarded area is identified as a strategic resource area and therefore a principal location for mineral extraction for crushed rock in Policy M3.
Due to the close proximity of this proposal for residential use to the Mineral Safeguarded area, it could hinder the mineral from being worked.
Considering Policy M8, the site is not allocated for development in an adopted local plan or
neighbourhood plan; nor has it been shown that the need for the development outweighs the economic and sustainability considerations relating to the mineral resource; nor is it proposed that the mineral will be extracted prior to the development taking place.
At this stage, without any further evidence or information, we consider that the proposal could hinder the working of mineral within the Safeguarded area and is therefore contrary to Policy M8 of the adopted Minerals and Waste Local Plan Part 1: Core Strategy. As such we object to this site
being included as a proposed allocation and should not be included within the draft West Oxfordshire Local Plan. It is recommended that a Mineral Resource Assessment to assess the impact on the Mineral Safeguarding Area is prepared to provide evidence to enable full consideration of this potential site.
Place Planning
The site is quite isolated from the village. Some wording should be added regarding footpath connections to the main village centre will be required, plus improvements to bus stops to ensure the site connects to the village centre.
Transport Strategy and Policy
There is very little information on sustainable access to the site. We would we request that this allocation is updated to include the need to provide walking, wheeling and cycling and public transport improvements accessibly are suitable and what improvements would be required to support a development at this location.
Landscape and Nature Recovery
This area as mapped is currently located immediately adjacent to parcels of floodplain grazing marsh priority habitat and near to Ducklington Mead SSSI. These features will need to be carefully considered alongside the LNRS when considering inclusion of this allocation and the allocation
boundary.
Archaeology
The site has been subject to a trenched evaluation which recorded a Roman trackway, an enclosure with internal subdivisions, an outlying field system and quarry pits containing Roman pottery, as well as two pits dating from the Saxon period. Mitigation excavation must be undertaken
ahead of development.

AREA P – Land south of Hydac, Charlbury
Place Planning
Whilst there are public transport options in Charlbury, these are not frequent, reducing the convenience and usability of public transport. This site is not connected by a footpath to the rest of Charlbury and whilst there is a public right of way, this is not currently accessible for all users and
is unlit, reducing the appeal of walking, wheeling and cycling. Access to the station and other amenities is within a reasonable walking, wheeling or cycling distance, but current infrastructure is substandard, particularly on approach to the station. This acts as a deterrent to travelling by such
modes.
Investment is needed to make walking, wheeling and cycling a realistic option in this location and given the level of development proposed it is unlikely infrastructure improvements would be viable, therefore careful consideration should be given to this allocation.
Archaeology
Site immediately adjacent to a scheduled section of Grim's Ditch. Potential for significant archaeological remains to continue into the allocation site - an archaeological investigation will be required before any application submitted.

AREA O – Jeffersons Piece, Chalbury
Place Planning
Access to the site (via the garage court at Jeffersons Piece) does not appear appropriate and would likely have a detrimental impact on the existing residential streets. The existing road network to access Jeffersons Piece, including Ditchley Road, is unsuitable for more vehicles due to its
narrowness and residential nature. Suitable access needs to be demonstrated.
An LCWIP is in development for Charlbury. This has revealed several safety issues with walking, wheeling and cycling provision that need to be addressed if sustainable travel for local trips, or as part of longer trips is to be a realistic option for residents.

AREA N – South of Sheep Street, Burford
Minerals & Waste
This site allocation is over 400m from a Mineral Safeguarded area. We have no objection to this proposed allocation. Mitigation could be incorporated into any future design to limit any impact of potential future Mineral working.
Place Planning
The site will require integrating with walking routes to existing Burford. Whilst the main access could be from Sheep Street, consideration of increasing traffic on less suitable roads needs mitigation. More detail is required on using the site for town centre car parking.
Transport Strategy and Policy
The buses from Burford Town centre (233/234) no longer provide a link to Hanborough, only Witney and Carterton. For Woodstock a change in Witney is required. The text should be updated to reflect this change.
Landscape and Nature Recovery
This area as mapped is currently located immediately adjacent to a parcel of ancient woodland.
This ecological feature will need to be carefully considered alongside the LNRS when considering inclusion of this allocation and the allocation boundary.
Archaeology
The allocation site is part of the site of Battle Edge, where the king of Mercia was defeated by the king of the West Saxons in 752AD. Finds of human remains have been recorded in the field.
Archaeological investigation would be required ahead of any proposal for development.

AREA M – North of Aston
Strategic Planning
Please see Appendix 2: OCC Estates response to the draft local plan consultation, as it contains useful information on the position of OCC Estates regarding this allocation.
Place Planning
It is unrealistic to assume residents would walk to Witney/Carterton from Aston. There is no continuous provision for walking and/or cycling between Aston and these areas.
The same bus from Bampton also runs through Aston. 1 service an hour per route - no late evening service and no Sunday service. Encourages car reliance.
As above, Witney LCWIP features several schemes identified to mitigate issues with walking, wheeling and cycling provision. These would need to be addressed if sustainable travel for local trips, or as part of longer trips is to be a realistic option for residents.
Transport Strategy and Policy
There is very little information on sustainable access to the site. We would we request that this allocation is updated to include the need to provide walking, wheeling and cycling and public transport improvements accessibly are suitable and what improvements would be required to support a development at this location.
Archaeology
The site has been subject to a recent archaeological evaluation which recorded a range of features. The report for this work is forthcoming, however, a further phase of archaeological mitigation will be required ahead of any development.

AREA L – East of Bampton
Minerals & Waste
The site falls within the Mineral Safeguarding Area, and Policy M8 of the adopted Minerals and Waste Local Plan Part 1: Core Strategy applies and should be considered.
The site has not been allocated for development in an adopted local plan or neighbourhood plan;
nor has it been shown that the need for the development outweighs the economic and sustainability considerations relating to the mineral resource; nor is it proposed that the mineral will be extracted prior to the development taking place. Therefore, at this stage, the proposal is contrary to Policy M8 of the adopted Minerals and Waste Local Plan Part 1: Core Strategy and we object to this site being included as an allocation within the new West Oxfordshire Local Plan. It is
recommended that a Mineral Resource Assessment to assess the impact on the Mineral Safeguarding Area is prepared to provide evidence to enable full consideration of this potential site for Regulation 19 stage.
Place Planning
Bampton is isolated from its nearest towns, Carterton and Witney in terms of access by active travel. It is unrealistic to assume anyone would walk and those who would cycle, would have to be more confident cyclists. There is no continuous provision for walking and cycling between Bampton and Witney/Carterton. This means residents will largely be reliant on their cars.
Similarly, bus services in Bampton are limited. With only 1 service providing 1 an hour per route between Witney and Carterton. Buses do not run past 19:40 and there is no Sunday service. This makes bus not the obvious choice and suggests residents will be car reliant. The bus stops closest
to the site do not have shelter or seating provision.
Witney LCWIP features several schemes identified to mitigate issues with walking, wheeling and cycling provision. These would need to be addressed if sustainable travel for local trips, or as part of longer trips is to be a realistic option for residents.
Transport Strategy and Policy
There is very little information on sustainable access to the site. We would we request that this allocation is updated to include the need to provide walking, wheeling and cycling and public transport improvements accessibly are suitable and what improvements would be required to support a development at this location.
Archaeology
An archaeological evaluation to the immediate west of this allocation site recorded a Roman ditch,
pits and cremation burials. It is likely that any proposals for this allocation site will require an archaeological investigation. The Portable Antiquities Scheme records one Roman find spot in the centre of the site.

Place Planning
The allocation should be updated and refreshed to reflect the current and more up to date conditions in the 2043 Local Plan. However, there should be further investigation into the impact an additional 25 dwellings would have on traffic, transport and placemaking.
Archaeology
The site lies just outside the historic core of Witney. Any application on the site will need to be supported by a desk-based assessment to provide more information on past impacts on the site.
Archaeological investigations on Woodford Way and at Marriotts Walk recorded limited archaeological remains.

AREA K – Land South West of Hanborough Station
Strategic Planning
The District is encouraged to explore the potential for increased densities close to the station, subject to other planning and environmental considerations.
Minerals & Waste
Mineral deposits are finite resources and can only be worked where they exist in the ground. It is Government policy that important mineral resources should be safeguarded for the long term.
Oxfordshire County Council are the Mineral Planning Authority, and we are required to identify Mineral Safeguarding Areas so that resources are not sterilised by non-mineral development. This is undertaken through the Oxfordshire Minerals and Waste Local Plan Part 1: Core Strategy.
Part of this site, identified for the potential allocation within the forthcoming West Oxfordshire Local Plan falls within an identified Mineral Safeguarded Area for Sharp Sand and Gravel and therefore
Policy M8 of the adopted Minerals and Waste Local Plan Part 1: Core Strategy applies and should
be considered.
It should also be noted that this safeguarded area is identified as a strategic resource area and therefore a principal location for mineral extraction for sharp sand and gravel in Policy M3.
This proposal would prevent and hinder the mineral that falls within the proposed allocation area from being worked, unless it was proposed to be worked ahead of any residential development.
Considering Policy M8, the site is not allocated for development in an adopted local plan or neighbourhood plan; nor has it been shown that the need for the development outweighs the economic and sustainability considerations relating to the mineral resource; nor is it proposed that the mineral will be extracted prior to the development taking place.
Therefore, at this stage, without any further evidence or information, the proposal is contrary to Policy M8 of the adopted Minerals and Waste Local Plan Part 1: Core Strategy and we object to this site being included as a proposed allocation. It is recommended that a Mineral Resource
Assessment to assess the impact on the Mineral Safeguarding Area is prepared to provide
evidence to enable full consideration of this potential site.
Place Planning
Whilst removed from Area K, there is undeveloped land to the north of Regent Drive, Long Hanborough and South of the railway line, which we suggest is safeguarded for "railway uses" in order to deliver the rail plan relating to Hanborough Station.
Landscape and Nature Recovery
This area as mapped is currently located immediately adjacent to Pinsley Wood LWS and priority habitats including ancient woodland, deciduous woodland and floodplain grazing marsh. These ecological features need careful consideration alongside the LNRS when considering inclusion of this allocation and the allocation boundary.
OCC’s summary position
Part of this allocation falls within a Mineral Safeguarding Area and therefore a Mineral Resource Assessment to assess the impact on the Mineral Safeguarding Area is recommended for the next stage of the plan however it is acknowledged this is a sustainable location which could benefit from
increased densities subject to other planning considerations including adequate infrastructure and active travel links to Hanborough. It is also recommended that consideration is given to the inclusion within this allocation of safeguarded land for "railway uses" in order to deliver the rail plan
relating to Hanborough Station to the north of Regent Drive, Long Hanborough and South of the railway line.

AREA J – East Chipping Norton
Strategic Planning
Please see Appendix 2: OCC Estates response to the draft local plan consultation, as it contains useful information on the proposed allocation and its potential for additional housing.
Landscape and Nature Recovery
This area as mapped currently includes a parcel of traditional orchard. This ecological feature needs to be carefully considered alongside the LNRS when considering inclusion of this allocation and the allocation boundary.
Archaeology
It is foreseen that the Scheduled Monument located within the allocation will be a considerable constraint. Proactive engagement by OCC/WODC with OCAS and Historic England is ongoing on this matter. The area North of Scheduled Monument still requires evaluation as geophysical survey
has suggested there may be archaeological features in this area but not as densely concentrated as in the area which has been scheduled. A geophysical survey of land to the north of London Road has recorded limited archaeological anomalies, but this will need to be verified via an
evaluation should an application be submitted for this site.

AREA I – Land at West Carterton (Alvescot)
Place Planning
There is potential to add additional bus stops to existing services that already route along the boundary of the site on Alvescot Road, for example, Pulhams 19 and 64. However, it is noted that these would be a significant distance from services to Oxford.
Motor vehicles travelling east likely to have a negative impact on Carterton road network as routes involve travelling through the town centre or via Upavon Way and Carterton Community College.
Potential to impact villages to the south of Carterton too with vehicles routing through these villages to travel south. Robust traffic modelling will be required for this site.
It is noted that there is a relatively short distance from the allocation to Carterton town centre and schools. Improvements to active travel delivered by the developer could make walking, wheeling and cycling an attractive option for short journeys. However, access from Upavon Way to the site will be required across the Shillbrook to integrate the development into existing Carterton and provide high quality active travel routes which are coherent, safe, direct, comfortable and attractive.
Transport Policy and Strategy
It is noted that there is no reference to walking, wheeling and cycling. We would recommend this allocation is updated to note the need for walking, wheeling and cycling improvements with the western boundary of Carterton.
Landscape and Nature Recovery
This area as mapped currently includes a parcel of priority deciduous woodland and is located immediately adjacent to Carterton Grasslands LWS. These ecological features need to be carefully considered alongside the LNRS when considering inclusion of this allocation and the allocation boundary.
Archaeology
It is noted that an archaeological excavation in the southeast corner of the allocation site recorded a Romano British drying oven, and to the immediate south of the site, a square enclosure has been recorded from cropmarks. A desk-based assessment was undertaken over 10 years ago for the
site so this should be updated, should planning permission be sought. It is likely that the assessment will need to be supported by a geophysical survey and trenched evaluation.

AREA H – East of Brize Norton
Place Planning
There is a concern that the focus of Area H being conceived as a ‘standalone community’ may mean that sustainable connectivity between communities may be overlooked; the more disjointed a community is the more challenging sustainable travel is.
Any development in this location will need to consider mass rapid transit and improvements/ mitigations along the A40, not just large-scale development. Any mass rapid transit scheme should be delivered prior to occupation.
Mitigations should not just be highways focused but include high quality walking, wheeling and cycling routes also. Development should not preclude delivery of a safe walking, wheeling and cycling connection between Carterton and Witney via Witney Road.
The cumulative impact of this site and sites G and F will need to be considered.
Transport Policy and Strategy
It is recommended that this is updated to include the need to provide walking, wheeling and cycling improvements to the local area in particular towards the key local facilities and town centre. The allocation is a significant distance from the centre of Carterton to sustainable transport links need
to be considered in more detail.
Landscape and Nature Recovery
This area as mapped is currently located adjacent to parcels of ancient woodland, priority deciduous woodland, traditional orchard and Huck's Copse LWS. These ecological features need to be carefully considered alongside the LNRS when considering inclusion of this allocation and the allocation boundary.
Archaeology
It is noted that a geophysical survey recorded three areas of clear archaeological activity in the centre and south-east of the site. The activity recorded in the centre of the site correlates with the position of an enclosure recorded on the historic environment record, although the survey provided
further detail on the extent and complexity of the remains. The two other areas of archaeological activity were not previously known and comprise enclosures and a possible trackway. An archaeological evaluation will be required on the site prior to granting of any permission for
development.

AREA G – North East of Carterton (Brize Norton) [Employment]
Mineral & Waste
This proposed allocation is within very close proximity of the Mineral Safeguarding Area for Crushed Rock. Mitigation should be incorporated into any future design to limit any impact of potential future Mineral working.
Place Planning
This allocation highlights the issue with considering only the option of CWORC for a future mass rapid transit provision. This option has not been proven to be deliverable and OCC are exploring all Mass Rapid Transit options before identifying a preferred option.
Proximity to A40 and employment at Witney makes this a good location, however, sustainable travel for all trip types needs greater consideration. Longer distance journeys have been considered, for example, via Mass Rapid Transit. However, shorter distance journeys, for example,
between surrounding residential areas and the employment site have not and should. These journeys can be made by walking, wheeling and cycling, and greater consideration needs to be given to this. It is the expectation that any development will deliver and/or contribute to these
improvements. This development will also be required to deliver a new/ improved junction onto the
A40 and make improvements to the A40.
Transport Policy and Strategy
The lack of information on sustainable access to the site should be addressed. The allocation should be updated to include the need to provide walking, wheeling and cycling and public transport improvements accessibly are suitable and what improvements would be required to
support a development at this location.
Landscape and Nature Recovery
This area as mapped currently includes a parcel of land within an area for the restoration of river diversity and management of rivers and their riparian (riverside) habitats to achieve good ecological condition that supports species. This ecological feature needs to be considered
alongside the LNRS when considering inclusion of this allocation and the allocation boundary.
Archaeology
It is noted that no archaeological investigations have been undertaken in this allocation site though the historic Environment Record records cropmarks of a possible Bronze Age ring ditch and a rectangular enclosure at the eastern edge of the area. An Anglo-Saxon inhumation cemetery is
recorded at Astrop Farm, to the immediate south of the allocation site. This is also the location of Astrop Shrunken Medieval Village. A geophysical survey will need to be undertaken so more specific archaeological advice can be provided.

AREA F – North East of Carterton (Brize Norton) [Housing]
Minerals & Waste
Mineral deposits are finite resources and can only be worked where they exist in the ground. It is Government policy that important mineral resources should be safeguarded for the long term.
Oxfordshire County Council are the Mineral Planning Authority, and we are required to identify
Mineral Safeguarding Areas so that resources are not sterilised by non-mineral development. This
is undertaken through the Oxfordshire Minerals and Waste Local Plan Part 1: Core Strategy.
This site, identified for the potential allocation within the forthcoming West Oxfordshire Local Plan falls within an identified Mineral Safeguarded Area for Crushed Rock and therefore Policy M8 of the adopted Minerals and Waste Local Plan Part 1: Core Strategy applies and should be
considered.
It should also be noted that this safeguarded area is identified as a strategic resource area and therefore a principal location for mineral extraction for crushed rock in Policy M3.
This proposal could prevent the mineral that falls within the proposed allocation area from being worked, unless it was proposed to be worked ahead of any mixed use development. Considering Policy M8, the site is not allocated for development in an adopted local plan or neighbourhood
plan; nor has it been shown that the need for the development outweighs the economic and sustainability considerations relating to the mineral resource; nor is it proposed that the mineral will be extracted prior to the development taking place.
This proposed allocation also falls in close proximity to an existing permitted mineral working and other permitted operations including stone processing, block making, inert recycling and concrete batching plant at Burford Quarry. It is considered that this proposed allocation for mixed use could
prejudice or jeopardise this site continued use by creating incompatible land uses nearby and therefore Policy M9 should be considered.
The proposed allocation is not in accordance with a site allocation for development in an adopted local plan or neighbourhood plan nor has it been demonstrated that the existing infrastructure is no longer needed, nor has it been demonstrated that the infrastructure can be appropriately and sustainably provided elsewhere.
Therefore, at this stage, without any further evidence or information, the proposal is contrary to Policy M8 and M9 of the adopted Minerals and Waste Local Plan Part 1: Core Strategy and we object to this site being included as a proposed allocation and should not be included within the
draft West Oxfordshire Local Plan. It is recommended that a Mineral Resource Assessment to assess the impact on the Mineral Safeguarding Area is prepared to provide evidence to enable full consideration of this potential site.
Waste
In addition, Oxfordshire County Council are also the Waste Planning Authority, and we safeguard existing and permitted Waste Management sites through Policy W11 Safeguarding Waste
Management Sites of the Minerals and Waste Local Plan Part 1: Core Strategy.
It should be noted that the proposed allocation is just over 300m away to an existing recycling waste facility at Worsham Quarry, and we would suggest that any future allocation should consider mitigation to ensure that the allocation does not directly or indirectly prevent or hinder the use of
the waste site.
Place Planning
There is a concern that the focus of Area F being conceived as a ‘standalone community’ may mean that sustainable connectivity between communities may be overlooked; the more disjointed a community is the more challenging sustainable travel is.
Any development in this location will need to consider mass rapid transit and improvements/ mitigations along the A40, not just large-scale development. Any mass rapid transit scheme should be delivered prior to occupation.
It is also noted that walking, wheeling and cycling connectivity is not mentioned despite being of great importance. It should be possible to make internal journeys and journeys between
settlements including to Witney across the A40, from this development. The emphasis on rail ignores the local journeys that people will more typically be making and risks these not being facilitated.
Transport Policy and Strategy
It is recommended that this is updated to include the need to provide walking, wheeling and cycling improvements to the local area in particular towards the key local facilities and town centre. The allocation is a significant distance from the centre of Carterton to sustainable transport links need
to be considered in more detail.
Landscape and Nature Recovery
This area as mapped currently includes a parcel of priority deciduous woodland. This ecological feature needs to be carefully considered alongside the LNRS when considering inclusion of this allocation and the allocation boundary.
Archaeology
It is noted that a geophysical survey recorded three areas of clear archaeological activity in the centre and south-east of the site. The activity recorded in the centre of the site correlates with the position of an enclosure recorded on the historic environment record, although the survey provided
further detail on the extent and complexity of the remains. The two other areas of archaeological activity were not previously known and comprise enclosures and a possible trackway. An archaeological evaluation will be required on the site prior to granting of any permission for
development.

AREA E – North of Carterton (Brize Norton and Shilton)
Minerals & Waste
Mineral deposits are finite resources and can only be worked where they exist in the ground. It is Government policy that important mineral resources should be safeguarded for the long term.
Oxfordshire County Council are the Mineral Planning Authority, and we are required to identify Mineral Safeguarding Areas so that resources are not sterilised by non-mineral development. This is undertaken through the Oxfordshire Minerals and Waste Local Plan Part 1: Core Strategy.
This site, identified for the potential allocation within the forthcoming West Oxfordshire Local Plan falls within an identified Mineral Safeguarded Area for Crushed Rock and therefore Policy M8 of the adopted Minerals and Waste Local Plan Part 1: Core Strategy applies and should be
considered.
It should also be noted that this safeguarded area is identified as a strategic resource area and therefore a principal location for mineral extraction for crushed rock in Policy M3.
This proposal could prevent the mineral that falls within the proposed allocation area from being worked, unless it was proposed to be worked ahead of any mixed use development.
Considering Policy M8, the site is not allocated for development in an adopted local plan or neighbourhood plan; nor has it been shown that the need for the development outweighs the economic and sustainability considerations relating to the mineral resource; nor is it proposed that the mineral will be extracted prior to the development taking place.
This proposed allocation also falls adjacent to an existing permitted mineral working and other permitted operations including stone processing, block making, inert recycling and concrete batching plant at Burford Quarry. It is considered that this proposed allocation for mixed use could
prejudice or jeopardise this site continued use by creating incompatible land uses nearby and therefore Policy M9 should be considered.
The proposed allocation is not in accordance with a site allocation for development in an adopted local plan or neighbourhood plan nor has it been demonstrated that the existing infrastructure is no longer needed, nor has it been demonstrated that the infrastructure can be appropriately and sustainably provided elsewhere.
Therefore, at this stage, without any further evidence or information, the proposal is contrary to
Policy M8 and M9 of the adopted Minerals and Waste Local Plan Part 1: Core Strategy and we object to this site being included as a proposed allocation and should not be included within the draft West Oxfordshire Local Plan. It is recommended that a Mineral Resource Assessment to
assess the impact on the Mineral Safeguarding Area is prepared to provide evidence to enable full consideration of this potential site.
Place Planning
Traffic from this development is likely to have a negative impact on the existing highway network
and wider place in Carterton, including Upavon Way (a key corridor for routes to school, employment and the town centre), with people likely to travel east via Upavon Way, Monahan Way and the B4477 (as the most direct route). This is further exacerbated by the relocation and
expansion of Carterton Football Club. Access to Carterton measures are some distance from this site, and would still result in traffic routing through Carterton to reach these measures.
Walking, wheeling and cycling provision from this site to key services and amenities in Carterton is currently substandard. Investment will be needed to make it a realistic choice for people to travel by modes other than motor vehicle and for any additional motor vehicle traffic to not exacerbate
existing issues e.g. severance. Furthermore, this site is some distance from public transport services. The sustainability of this site without significant investment is therefore questionable.
Another concern raised is that of the impact of this development on the setting of Kilkenny Country
Park and the erosion of a valuable green space.
Transport Policy and Strategy
The paragraph refers to the requirement to “to link effectively to public transport services to the east of the area at Monahan Way”. The location of the site is likely to mean that even the eastern most extents allocation is likely to be 400m from Monahan Way, with the middle and western part
of the allocated in excess of 1-1.25km from Monahan Way. Therefore, more emphasis on getting public transport access within the site is needed as the distances involved at present would prioritise car movements.
Landscape and Nature Recovery
This area as mapped currently includes parcels of priority deciduous woodland. These ecological features need to be carefully considered alongside the LNRS when considering inclusion of this allocation and the allocation boundary.
Archaeology
It is noted that an archaeological evaluation has been undertaken which recorded a range of Roman and later Iron Age settlement features. A further stage of archaeological mitigation will be required before any development on the site.

AREA D – Land West of Witney
Place Planning
It is noted that the geographical context of the Area D being close to employment areas but some distance from the town centre means there is a risk residents of this development could feel they are not part of Witney. This means that placemaking will be of special importance here.
Comprehensive and realistic options for walking, wheeling and cycling will be needed to make this a sustainable location. Distance from bus stops makes bus travel less convenient. There is also concern that this site is not sustainable without significant investment in walking, wheeling, cycling and bus infrastructure/ services. Although, cumulative transport impact of this development and
site A is required and mitigation may be shared.
Transport Policy and Strategy
Same concern as raised in comments for Areas A and B. It is recommended that this is updated to include the need to provide walking, wheeling and cycling improvements as well as ensuring that public transport improvements are provided.
Landscape and Nature Recovery
This area as mapped currently includes parcels of priority deciduous woodland. These ecological features need to be carefully considered alongside the LNRS when considering inclusion of this allocation and the allocation boundary.
Archaeology
It is noted that no archaeological investigations have been undertaken in this allocation site though the Portable Antiquities Scheme have recorded a relatively high number of Roman period finds within the site. Neolithic and other prehistoric finds have also been recorded within the site. A
geophysical survey will need to be undertaken so more specific archaeological advice can be provided

AREA C – Land South of Witney
Strategic Planning
Given the location of this site at the junction of the A40 and A415, consideration should be given within this potential allocation to safeguard land for a mobility hub related to the MRT, as a way to provide access to sustainable modes of transport to this site. The closeness to the Witney
Strategic Sewerage Treatment Works will also need to be taken into account as part of a refined boundary into Regulation 19 stage. It is acknowledged that that this might result in lower capacity for development which could be overcome by providing additional density at the most accessible locations (i.e. near mobility hubs/stations), which will need to be considered in the round alongside
placemaking and other planning considerations.
Minerals & Waste
This draft site area includes the Witney Strategic Sewerage Treatment Works (STW) which is safeguarded by Policy W11 of the Oxfordshire Minerals and Waste Local Plan - Core Strategy (2017). Residential development in this area could prejudice the use of the existing waste facility
and its future uses and would be contrary to Policy. Therefore, as it stands we object to this draft
allocation. Should the site progress, we would expect future Local Plan Policy for this site to include wording to ensure future developments demonstrate that they will not directly or indirectly prevent or prejudice the use of the STW. This could be through appropriate mitigation, including a
suitable buffer zone and planting to minimise any potential impact on the amenity to future residents.
Place Planning
As proposed, Area C is severed from Witney by the A40 and Ducklington by the A415, making the site relatively isolated from local amenities and services. Without significant investment in safe, coherent, attractive, desirable walking, wheeling and cycling routes the site could be very car
dependent. Mixed used development across the site could help create a sense of place. Serving the site with public transport routes could be challenging and consideration of how/where the site is accessed should focus on public transport routing.
Transport Policy and Strategy
The severance caused by the A40 is a significant concern in terms of ensuring a good level of sustainable transport access. It is recommended that this is updated to include the need to provide walking, wheeling and cycling improvements as well as ensuring that public transport
improvements are provided especially over the A40. These will be required to mitigate the impact of the development, in line with decide and provide.
It is also noted that the X9 bus does not serve the eastern part of the site, with this terminating in Witney town centre. This should instead be serviced by the X15 bus, which runs via Ducklington alongside the 19 service.
Landscape and Nature Recovery
This area as mapped currently includes parcels of priority deciduous woodland. These ecological
features need to be carefully considered alongside the LNRS when considering inclusion of this allocation and the allocation boundary.
Archaeology
It is noted that a geophysical survey on part of the site revealed potential archaeology in the form of anomalies that seemed to represent oval enclosures, a linear anomaly that may be a ditch and field boundaries that correspond with historic mapping.
OCC’s summary position
There are a number of physical barriers between the site and rest of Witney (A40 and A415) which could compromise the potential for the site in terms of placemaking for this site however, if current constraints, which include closeness to Witney Strategic Sewerage Treatment Works and potential
for archaeological remains, can be properly addressed, this site could present an opportunity to deliver a mobility hub in this location which can tie MRT proposals with increased densities close to a station.

AREA B – Land west of Downs Road, Witney (Peashell Farm)
Place Planning
Reference has been made to residential use for Peashell Farm. It should be noted that there is a live outline planning application for the site. There is no preference towards either residential or employment expressed at present, but the same consideration should be taken to the connections
via public transport and active travel for either residents or employees to be able to travel to and from the site in a sustainable way without too great of a focus on car travel.
Contribution to mass transit solution on the A40 would be expected from this development. Active travel connectivity between this development and Witney town centre/ residential areas and connections to Carterton will be important to consider and deliver improvements alongside highway mitigations.
Transport Policy and Strategy
The same concern raised for Area A is also a concern for this allocation. Similar, it is recommended that this is updated to include the need to provide walking, wheeling and cycling
improvements as well as ensuring that public transport improvements are provided. This is particularly important given the number of people within Witney and the surrounding area that travel relatively short distances to get to work.
Archaeology
It is noted that an archaeological evaluation has been undertaken on the eastern half of the site
recording a possible banjo enclosure and associated droveway, a sub-square enclosure, subrectangular enclosures, and pits. The features appear to be of Iron Age to Roman date. Late medieval and post-medieval features were revealed in the form of ridge and furrow, field boundaries and a large quarry pit. Further mitigation will be required.

AREA A – Land North of Burford Road, Witney
Strategic Planning
There is a current an outline planning application for 450 new homes, community facilities, public open space, landscaping, drainage, and other associated works to the west of Dry Lane (ref. 25/02116/OUT). Should a separate application be submitted to the east of Dry Lane for a similar
proportion of housing, this would exceed the envisioned housing for Area A. As such, the District is encouraged to review this allocation to identify if this would need reviewing in light of this current application.
Place Planning
It should be noted that although the Oxford bus services do not stop near the site, the 234 service stops at the Market Square stops in Witney Town Centre where the S1/H2 services can be caught from. This means that travel to Oxford via public transport is possible. However, there are
significant concerns the site is not suitable for development without further thought into the impact on the road network and improvements to walking and cycling infrastructure.
Specific reference should be made to the need to facilitate better walking, wheeling and cycling connections. Furthermore, the distance from the development to bus stops makes bus travel less convenient. The development will be expected to directly deliver some of these improvements and not just contribute. The impact of this development should be understood in the context of other
proposed developments e.g. Site D and mitigations determined accordingly.
There is also concern about the impact of this development on the surrounding road network including Bridge Street, and the consequent impact on air quality. Any development here must be supported by robust transport modelling and package of mitigation. It is imperative that realistic
alternatives to the car are delivered prior to occupation, and that measures to prevent rat running
e.g. via Dry Lane and Fiveways Roundabout are also fully explored.
Transport Policy and Strategy
It is noted that when discussing the need to mitigate the impact of the development, only 'highway infrastructure' and the' road network' are listed. It is instead recommended that this is updated to include the need to provide walking, wheeling and cycling improvements as well as ensuring that
public transport improvements are provided. These will be required to mitigate the impact of the development, in line with decide and provide, and should be afforded greater priority over the road network, in line with transport user hierarchy.
Landscape and Nature Recovery
This area as mapped currently includes and is immediately adjacent to a large area of multiple different priority habitats and multiple Local Wildlife Sites that border the river Windrush. These ecological features will need to be considered carefully alongside the LNRS when considering
inclusion of this allocation and the allocation boundary.
Archaeology
The inclusion of the archaeological implications of development at Land North of Burford Road is
welcomed. It is noted that an evaluation at Curbridge Downs Farm, the western end of the site recorded the presence of a complex Roman Farmstead that originated from Iron Age features. The remainder of the site will require evaluation, then mitigation of any archaeological remains which
will be impacted by development site.