Principal Settlement Has Neighbourhood Plan

Lechlade-on-Thames

What the Local Plan means for Lechlade

150 new homes proposed Reg 19 Expected June 2026

1,241

Current homes

220

Proposed 2025-2043

150

Main allocation

18%

Growth increase

The Numbers

The Draft Local Plan (November 2025) identifies Lechlade as a Principal Settlement and proposes 220 new homes over the plan period (2025-2043).

Source Homes
Planning permissions already granted 10
Remaining allocations from current LP 9
Windfall allowance 51
New allocation proposed 150
Total 2025-2043 220

Source: Local Plan Review Preferred Options Consultation, Table 2, page 21

The Neighbourhood Plan

Made Neighbourhood Plan

October 2016 | 88% support

Homes allocated (2011-2031) 114
Homes built (2011-2024) ~113
Remaining to complete NP ~1

NP: Delivered

The Neighbourhood Plan (2011-2031) allocation has been effectively delivered in full.

The new Local Plan (2025-2043) extends beyond the NP period, but proposes 150 additional homes at Ferrers Park on top of what the community already planned and delivered.

Combined Impact

114

NP allocation

Delivered

+

150

LP new allocation

Proposed

= 264 homes

Combined total for Lechlade

CDC's Own Evidence

From the Council's published evidence base documents

The following findings come from CDC's own technical studies. You can cite these in your consultation response.

SHELAA Site Assessment (April 2021)

Before the current housing pressures emerged, Cotswold District Council assessed this site in their Strategic Housing and Economic Land Availability Assessment. These are the Council's own findings.

SHELAA Indicative Capacity:

86 dwellings

"based on a density multiplier assumption for half the site area"

— SHELAA April 2021, Site L33

86

SHELAA capacity

150

Current proposal

+74%

Increase

Five "Key Actions Required" Before Allocation

The SHELAA explicitly listed five actions required before this site could be allocated:

Highway capacity: Confirmation from County Highways that access is suitable
Groundwater flood risk: Further investigation (>75% risk identified)
SSSI impact: Further assessment of impact on SSSI to the north
Agricultural survey: Establish whether BMV agricultural land
Farm viability: Whether development would jeopardise existing business

FOI responses confirm none of these specialist assessments have been completed.

Source: SHELAA April 2021, Site Assessment L33

Heritage: What the Council Said Then vs Now

SHELAA 2021

"The development of L33 would therefore have a harmful impact on the setting of Manor Farmhouse. It would be difficult to mitigate the impact of this harm."

EIA Screening 2025

"Unlikely to have significant effects on the setting of listed buildings"

Key fact: FOI responses confirm no Heritage Impact Assessment was undertaken between these two conclusions. Historic England Advice Note 12 recommends HIAs for developments affecting heritage assets.

Groundwater Flood Risk

SHELAA identified:

"High ground water flood risk (greater than 75% risk) – further investigation would be required"

EIA Screening addressed:

"The site falls within Flood Zone 1 which is the lowest designation of Flood Zone"

Important: These are two different things. Flood Zone 1 relates to risk from rivers and sea (low). Groundwater flooding is a separate risk category - and the SHELAA identified >75% risk on this site. The "further investigation" required has not been done.

Landscape Sensitivity Assessment

Source: Broad Zones 10a-b (Around Lechlade)

Zone 10a (East)

M-H to HIGH Sensitivity

  • • Historic parkland features
  • • Association with Lechlade Manor
  • • Sensitive landscape character

Zone 10b (West)

MEDIUM (small scale)

  • • Some capacity for extension
  • • Northern areas ecologically sensitive
  • • Careful design required

Zone 10b offers "some capacity" with careful design, but northern areas remain ecologically sensitive due to proximity to Cotswold Water Park.

— Landscape Sensitivity Assessment, November 2025

Habitat Regulations Assessment (HRA)

Source: CDC HRA, October 2025

"Cotswold Lakes identified as functionally linked habitat for Severn Estuary qualifying bird species"

— Habitat Regulations Assessment, October 2025

Relevant concerns for Lechlade:

  • Cotswold Water Park SSSI ~80m from proposed site
  • Development could affect recreational pressure on ecologically sensitive areas
  • All scenarios could have "likely significant effects on Habitats Sites"

Site-Specific Constraints (Zones 10a-b)

Source: Site Assessment Sheets, November 2025

Heritage Assets

  • Multi-period settlement Scheduled Monument (NHLE 1003434) immediately adjacent to Zone 10b
  • Anglo-Saxon cemetery at Butler's Field - nationally significant remains may extend into area
  • Listed buildings at Lechlade, Manor Farm, Lechlade Mill, Little Faringdon

Ecological Designations

  • 100% of both zones in Cotswold Water Park NIA
  • Cotswold Water Park SSSI adjacent to Zone 10a north boundary
  • Eric Richardson Nature Reserve (LGS) adjacent to Zone 10b
  • Priority habitats: Floodplain Grazing Marsh, Deciduous Woodland

Flood Risk & Minerals

  • Zone 10a: "Large areas fall into Flood Zone 2"
  • Zone 10a: Almost wholly in Mineral Safeguarding Area
  • Zone 10b: All development types intersect MSA

Infrastructure Capacity

  • Wastewater capacity: Only ~250 properties (both zones)
  • No rail station within 5km
  • Bulk Supply Point needs upgrading

Accessibility Assessment (Both Zones)

IMPOSSIBLE

Supermarket

IMPOSSIBLE

Hospital

10-20 min

GP

No Station

Within 5km

By public transport. ~15,000 jobs accessible within 45 mins by PT.

Strategic Context from IIA

District-wide Constraints

  • Only 16% of district land is unconstrained
  • District is "seriously water stressed"

Housing Need Gap

  • Scenario 5 delivers only 79% of need
  • Only Scenario 6 meets need (but "breaks planning law")

How to use this evidence: When responding, reference the proximity to the SSSI, the HRA's identification of functionally linked habitat, and the fact that even CDC's own assessment shows Zone 10b only has capacity for "small scale" development with careful design.

Infrastructure Delivery Plan Gap

The Council is consulting on site allocations for up to 14,660 homes. The Infrastructure Delivery Plan that will assess whether infrastructure can support this growth is not scheduled for publication until Summer 2026.

Current IDP

April 2016

493 homes/year

New IDP

Summer 2026

1,036 homes/year

Key point: Sites are being allocated before infrastructure capacity is assessed. The existing IDP was prepared for a housing target less than half the current requirement.

The Proposed Site

Land South of Ferrers Park

Site Reference: Site L1

9.87

Hectares

150

Dwellings

Station Road (A361)

Access point

The site is located south of existing Ferrers Park residential area, bordered by residential development to the north and west, agricultural land to the south and east, and Station Road (A361) to the east.

Environmental Context

Ecology

  • Assessed as "national importance" for foraging/commuting bats
  • 11 bat species recorded on site
  • Includes lesser horseshoe and barbastelle (Annex II species)

Nearby Designations

  • Cotswold Water Park SSSI ~80m north
  • Conservation Area immediately adjacent
  • 3 Grade II listed buildings within 130m
  • 110 heritage assets within 1km

Agricultural Land: Approximately 8.1 hectares (82% of the site) is classified as Best and Most Versatile (BMV) Grade 3a agricultural land.

Sources: Turley EIA Screening Report (October 2025); North Lechlade Residents Group Technical Representations (November 2025), citing CDC Screening Opinion documentation and publicly available records

Questions the Council Must Answer

Based on the Council's own evidence base, residents may wish to ask:

Evidence Base Questions

  • 1 What evidence justifies increasing capacity from 86 homes (SHELAA 2021) to 150 homes - a 74% increase?
  • 2 Which of the five "Key Actions Required" in the SHELAA have been completed before this allocation?

Assessment Questions

  • 3 Why was no Heritage Impact Assessment undertaken when the SHELAA acknowledged "harmful impact" that would be "difficult to mitigate"?
  • 4 Why was no SSSI specialist assessment undertaken when the SHELAA stated this was required?
  • 5 Why was no groundwater flood investigation undertaken when the SHELAA identified >75% risk?
  • 6 Why was no Landscape and Visual Impact Assessment undertaken for a 9.87-hectare greenfield development?

Consistency Questions

  • 7 Why were sites L16A, L35, and L13 rejected for constraints (groundwater flood risk, CA impact, biodiversity) that equally apply to this site?
  • 8 Why does CDC require "sufficient biodiversity information" for 54 homes at The Wern, but accept limited assessment for 150 homes at a site of "national importance" for bats?
  • 9 How can site allocations be justified when the Infrastructure Delivery Plan assessing infrastructure capacity won't exist until Summer 2026?

Soundness Question

If these assessments haven't been completed and these questions can't be answered, how can this allocation be considered "sound" under NPPF tests?

The NPPF requires Local Plans to be positively prepared, justified, effective, and consistent with national policy.

Related Planning Decision

Land North of The Wern - Refused

July 2025 | Ref: 24/03501/OUT | 54 dwellings

In July 2025, the Council refused 54 dwellings at another Lechlade site. Reasons included:

  • "Significant adverse impact on listed buildings' settings"
  • "Harm to Conservation Area setting"
  • "Insufficient information to assess biodiversity impacts"

Source: CDC Planning Decision Notice

CDC's Inconsistent Approach to Biodiversity

The Wern (July 2025)

54 homes

Planning refused partly due to "insufficient information to assess biodiversity impacts"

Ferrers Park (November 2025)

150 homes

Local Plan allocation proposed despite "national importance" for bats with 11 species including two rare European protected species

Consistency question: Why does CDC apply different standards to biodiversity evidence across sites? This raises questions about whether the Local Plan allocation is "sound" under NPPF tests.

Sites the Council Rejected

The SHELAA assessed multiple sites around Lechlade. Some were rejected for constraints that equally apply to Land South of Ferrers Park (L33).

Rejected Site Reason for Rejection Does L33 have same issue?
L16A (90 homes) "High ground water flood risk" Yes - >75% risk
L16A "Negative impact on surrounding landscape" Yes - medium sensitivity
L35 "High ground water flood risk (>75%)" Yes - identical
L35 "Forms part of rural setting of Conservation Area" Yes - CA adjacent
L13 (45 homes) "Significant harmful impact on Conservation Area" Yes - CA adjacent
L13 "Important biodiversity interest" Yes - "national importance" for bats

Key question: Why were other sites rejected for constraints that equally apply to Land South of Ferrers Park?

Source: SHELAA April 2021, Lechlade Site Assessments

What Local Residents Did

North Lechlade Residents Group challenged the EIA screening decision

Request for Secretary of State Screening Direction

In November 2025, the North Lechlade Residents Group (NLRG) submitted detailed technical representations to the Secretary of State requesting a screening direction under Regulation 5(6) of the EIA Regulations 2017.

NLRG raised concerns including:

  • The site is documented as being of "National Importance" for bats, which they argued was inadequately assessed
  • The screening opinion did not provide reasoning for: heritage impacts, environmental designations, Best Most Versatile land loss, and cumulative development
  • While EIA screening doesn't require consistency with other planning decisions, CDC's approach to biodiversity evidence varies significantly between sites (e.g. The Wern was refused for "insufficient biodiversity information" for 54 homes)

Secretary of State's Response

Planning Casework Unit, MHCLG | Ref: PCU/EIASCR/F1610/3376245 | 2 December 2025

"I have considered the points you raise in your letter of 18 November and the content of the Cotswold District Council's screening opinion and associated consultation and do not consider these indicate a need for the Secretary of State to exercise his power under regulation 5(6), and therefore the Secretary of State declines to issue a screening direction in response to your request."

— Jake Dodgson, Senior Planning Manager (on behalf of the Secretary of State)

What this means: Both CDC and the Secretary of State have determined that the development does not require a full Environmental Impact Assessment under the EIA Regulations 2017. However, this is separate from the Local Plan process. Residents can still object to the allocation through this consultation and at Regulation 19. The same evidence gaps (no HIA, no LVIA, SHELAA contradictions) remain valid grounds for objection.

EIA Screening Timeline

1

5 November 2025

CDC issued screening opinion - EIA not required

2

18 November 2025

NLRG submitted technical representations to Secretary of State

3

2 December 2025

Secretary of State declined to make a screening direction

What Assessments Have Been Done?

Not Undertaken

  • Landscape and Visual Impact Assessment (LVIA)
  • Heritage Impact Assessment

Undertaken

  • EIA Screening Opinion
  • Strategic Landscape Sensitivity Assessment (district-wide)

Context: The site is immediately adjacent to a Conservation Area and within 130m of three Grade II listed buildings. CDC's own evidence records 110 heritage assets within 1km of the site.

A Point of Comparison

Residents have noted a contrast in decision-making:

Land North of The Wern

54 homes | July 2025

Planning refused - reasons included "insufficient information to assess biodiversity impacts"

Land South of Ferrers Park

150 homes | November 2025

Local Plan allocation proposed - despite documented "national importance" for bats

These are different processes (planning application vs Local Plan allocation), but both involve CDC's approach to biodiversity evidence. Residents question the consistency.

Questions You May Wish to Raise

  • Should a site-specific Landscape and Visual Impact Assessment be required given the documented landscape sensitivity?
  • Should a Heritage Impact Assessment be undertaken given proximity to the Conservation Area and listed buildings?
  • How does the Council reconcile refusing 54 homes for insufficient biodiversity information while allocating 150 homes on a site documented as having "national importance" for bats?
  • What cumulative impact assessment has been made for the 150 homes combined with existing commitments and the ~113 homes already delivered?

These questions relate to process and transparency. The aim is to ensure decisions are properly evidenced and consistent.

Sources: CDC EIA Screening Opinion (5 November 2025); MHCLG Planning Casework Unit letter ref PCU/EIASCR/F1610/3376245 (2 December 2025); CDC Decision Notice 24/03501/OUT; North Lechlade Residents Group Technical Representations (18 November 2025)

Want to Get Involved?

Contact the North Lechlade Residents Group for further information and to show your support in ensuring the right development comes forward in your area.

Timeline

October 2016

Lechlade Neighbourhood Plan adopted (88% referendum support)

April 2021

SHELAA published: Site L33 assessed at 86 homes with 5 investigations required

2011-2024

~113 homes delivered against NP target of 114

July 2025

The Wern refused (54 homes) - "insufficient biodiversity information"

October 2025

Turley EIA Screening Report acknowledges "national importance" for bats

5 November 2025

CDC Screening Opinion: EIA not required

14 November 2025

Local Plan consultation opens - 150 homes proposed at this site

18 November 2025

Technical Representations submitted to Secretary of State

2 December 2025

Secretary of State declines to make screening direction

December 2025

FOI response confirms: No HIA or LVIA undertaken

2 January 2026

Reg 18 closed

Summer 2026

Infrastructure Delivery Plan publication (scheduled)

Stay Informed

The Reg 18 consultation closed on 2 January 2026. This information remains useful for the Reg 19 consultation expected June 2026. This is your opportunity to comment.

Key Consultation Questions

  • Q1: Which scenario do you prefer?
  • Q4: Is the proposed level of development sustainable?

Submit Your Response

Get Involved Locally

North Lechlade Residents Group

NLRG is a local residents' group actively engaging with planning matters affecting north Lechlade. In November 2025, they submitted detailed technical representations to the Secretary of State challenging the EIA screening decision for the Ferrers Park site.

Their submission raised concerns about bat habitat assessment, heritage impacts, and consistency with previous Council decisions. The information in the "What Local Residents Did" section above is drawn from their publicly available submissions and the official MHCLG response.

northlechladeresidentsgroup@gmail.com

Lechlade Town Council

The Town Council will be submitting a response to the Local Plan consultation and may hold public meetings.

lechladetowncouncil.gov.uk

Your voice matters: Individual responses to the Local Plan consultation carry weight. The more residents who respond with well-evidenced concerns, the stronger the case for the Inspector to consider.

Last updated: December 2025. This page summarises publicly available information to help residents understand and engage with the planning process. For definitive information, refer to official consultation documents on the Council's website.

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