Key Issues in the Draft Plan
The Council's own evidence reveals fundamental problems with this Local Plan. Here's what you need to know.
For issues specific to your area, see the area pages.
The Big Picture: A Contradiction in National Policy
The Council is caught between two conflicting government requirements. The standard method demands 1,036 homes per year — but the same government's NPPF protects National Landscapes from major development.
Government Planning Practice Guidance even acknowledges that councils with these constraints "may not be able to meet objectively assessed needs in full."
Delivers 104% of target — but requires major development in the National Landscape, which the NPPF restricts to "exceptional circumstances". The Council says this is not a viable option.
Delivers only 79% of target. Falls below the 80% threshold, meaning from July 2026 the council must demonstrate a 20% buffer on housing land supply — effectively 6 years instead of 5. This makes it harder to refuse speculative applications.
"Reflecting the Council's current understanding of site deliverability and developability across the district, Scenario 6 is the only approach which would meet the government's standard method calculation. However, given this option is contrary to national planning policy on restricting major development within National Landscapes, Scenario 6 is not considered to be a viable option."
— Integrated Impact Assessment, Page 46
The council wrote to the government twice asking them to resolve this contradiction. Both requests were refused, leaving Cotswold and similar constrained districts to navigate between impossible choices.
The 7 Development Scenarios
The council tested seven different approaches to meeting housing need. Here's what each delivers and why most were rejected.
Existing Settlements Only
Allocate sites only in Principal and Non-Principal Settlements.
7,840 homes — Less than half the target
Include Rural Settlements
Add allocations in smaller rural settlements too.
8,230 homes — Creates unsustainable travel patterns
Main Service Centres
Focus on 7 towns with best services (Cirencester, Moreton, Tetbury, etc).
9,420 homes — 6 of 7 centres in National Landscape
Transport Nodes
Focus growth at railway stations (Kemble, Moreton) and bus corridors.
9,190 homes — Public transport "sporadic or non-existent"
Strategic Sites + Settlements
Existing settlements plus 8 strategic sites including Driffield new settlement.
14,660 homes — Realistically ~11,730 (63%)
National Landscape Development
Major development within the protected National Landscape.
19,320 homes — "Contrary to national planning policy"
Maximum Growth
All possible sites including those assessed as unsuitable (e.g. Cotswold Airport).
16,200 homes — Includes sites deemed unsuitable
What Can You Say in Your Response?
This is a consultation, not a vote. You're not limited to picking one scenario — you can support, challenge, or propose alternatives.
Support
- • "I support Scenario 5 as the best available option"
- • "The council has balanced competing pressures well"
- • "I support growth in my area with conditions"
Modify
- • "I support the approach but object to specific sites"
- • "Growth should be distributed differently"
- • "This site needs different conditions"
Challenge
- • "None of these scenarios are acceptable"
- • "The housing target itself should be challenged"
- • "The government must resolve the policy conflict"
All responses are summarised publicly and reviewed by an independent planning inspector at examination.
Infrastructure is Already Failing
The Council's own evidence says parts of the district are "already suffering from overdevelopment"
Sewage Crisis
- • Thames Water has £17 billion debt — can't fund upgrades
- • Fairford ranked 7th worst nationally for sewage spills (4,332 hours in 2023)
- • Down Ampney: 13 new homes sitting empty — no sewage connection
- • Grampian conditions restricting occupation until upgrades complete
Water Stress
The entire Thames Water catchment is designated "seriously water stressed" by the Environment Agency.
The IIA states there is "likely to be an issue supplying water to these locations in the future" — yet thousands more homes are proposed.
Car Dependency
- • Public transport "sporadic or non-existent" in rural areas
- • Driffield new settlement: only one bus, 3 days a week
- • EV infrastructure "not currently in place"
- • Highway capacity already exceeded in some areas
Schools & Healthcare
The IIA warns that higher growth scenarios have "potential to put pressures on the capacity of existing services and facilities."
Many villages targeted for major growth have no GP surgery, limited school capacity, and are miles from the nearest hospital.
"Many larger settlements have already absorbed a large amount of housing growth... some infrastructure is already lacking in these areas (e.g. sewage treatment works and highway capacity), and as a result some parts of the district are already suffering from overdevelopment."
— Integrated Impact Assessment, Page 26
Villages Tripling and Quadrupling in Size
Disproportionate growth threatens the character and identity of small communities
The Most Extreme Growth Figures
What the Council's Own Evidence Says
The IIA explicitly warns about the impact of this growth:
"The level of growth proposed at Down Ampney and Preston would result in these villages almost tripling in size... This could lead to significant adverse effects on community vitality, including the quality of life of existing residents... This level of growth would also likely have an adverse impact on the 'sense of place' of these villages."
— IIA Page 25
Scenario 6 Warning
Under the only scenario that meets housing targets, Chipping Campden would quadruple in size and North Cerney would grow by 1,597%. This is why Scenario 6 was rejected.
Questions to Ask
- • Is this growth proportionate to the settlement?
- • Can infrastructure keep pace?
- • What happens to community identity?
- • Were residents meaningfully consulted?
Strategic Sites Take Decades to Deliver
The Steadings proves the council's own strategic sites don't deliver on time
Case Study: The Steadings, Cirencester
Peak delivery is expected 20 years after the site was first identified. And this was a single landowner site — simpler than most.
The 20% Buffer Admission
The Council's own Development Strategy Options admits:
"Although 14,660 homes are planned, we realistically expect around 20% fewer homes to be built during the Local Plan period, meaning Scenario 5 would be expected to deliver around 11,730 homes."
That's just 63% of the target.
Why Strategic Sites Fail
- • 6-7 years from planning application to first home
- • Infrastructure must be installed before homes built
- • Complex landownership and legal issues
- • Multiple sites compete for same builders/materials
- • External infrastructure providers (Thames Water) don't deliver
The Implication
If 8 strategic sites only deliver 48% of their capacity by 2043, the housing land supply will collapse. This could trigger the "presumption in favour of sustainable development" — meaning speculative applications get approved automatically.
The 84% Constraint Problem
Most of the district is off-limits for strategic development
- • 80% within Cotswolds National Landscape
- • Flood Zone 3 areas
- • Heritage assets and Conservation Areas
- • Ecological designations (SSSIs, SACs)
This 16% is concentrated in the south-east corridor (around Cirencester) and the north-east (Moreton-in-Marsh area). That's why these communities face disproportionate growth.
What "National Landscape" Protection Means
National Landscapes (formerly AONBs) have the highest level of landscape protection in England. NPPF paragraph 183 requires "great weight" be given to conserving their landscape and scenic beauty.
Major development should only be permitted in "exceptional circumstances" AND where it's demonstrated to be in the "public interest". Case law confirms this is a "very high bar" — housing need alone doesn't qualify.
Crucially, government Planning Practice Guidance acknowledges that National Landscape constraints "may mean it is not possible to meet objectively assessed needs for development in full" — yet the standard method makes no adjustment for this.
Meeting the Target Would Require Inner London Density
The maths simply doesn't work for a rural district
"The housing density of 106 dwellings per hectare, which is needed from Scenario 5 to deliver the government's full housing target, reflects a highly urbanised form of development, typically characterised by apartment blocks and flatted schemes with limited private outdoor space. This level of intensity is comparable to parts of inner London, such as Woodberry Down in Hackney and Stratford Halo in Newham... While such densities may be appropriate in city centre contexts, they are generally out of character with the district."
— Development Strategy Options, Page 48
The Official Conclusion
"While increasing density may provide some further housing land supply, it is not considered to be a realistic solution to deliver the full housing target."
Neighbourhood Plans Being Overridden
Communities spent years creating local plans that may now be swept aside
10 communities in Cotswold District have "made" (adopted) Neighbourhood Plans, with more in development. These represent years of community effort and were approved by local referendums.
The Problem
The new Local Plan allocates housing numbers that far exceed what many Neighbourhood Plans allocated. Once the Local Plan is adopted, it takes precedence.
Examples
- • Fairford NP: Allocated 114 homes, now facing 1,252
- • Down Ampney NP: Approved 95.6%, now 180% growth proposed
- • Kemble NP: Made 2021, now 284% growth proposed
What This Means for You
If your community has a Neighbourhood Plan, check how the Local Plan proposals compare to what you planned. You can argue that your community has already engaged with the planning system and made democratic choices about local growth.
How to Use This Information
Identify Relevant Issues
Focus on issues that affect your area. Check your area page for specific local concerns.
Quote the Evidence
Use the Council's own documents. Responses citing official evidence carry more weight than personal opinions alone.
Ready to have your say?
The consultation closes 2 January 2026. Your response matters.
Sources
All information on this page is drawn from the Council's own evidence base documents, including the Integrated Impact Assessment (November 2025), Development Strategy Options Technical Report (November 2025), and the Draft Local Plan Preferred Options Consultation (November 2025).
Last updated: December 2025. For definitive information, refer to official consultation documents.