Q-B9: Should the plan include a policy requiring the safeguarding of sites of national importance, sites of local importance, and other non-designated sites known to make a positive contribution to biodiversity or geodiversity; unless the benefits of the
Q-B3: Please select the option which is most appropriate for South Warwickshire 7.1. Special Landscape Areas currently only exist within Stratford-on-Avon District and were introduced in the currently adopted Core Strategy (2016), as a result of information provided in the Special Landscape Area Study (2012). 7.2. Such designation has no basis in national guidance or policy and are not included in Natural England's approach. Rather, paragraph 174 of the NPPF and others seek to conserve and enhance the local environment, ensure that policies take into account landscape implications arising from development, consider landscape and visual impacts, and protect 'valued landscapes'. 7.3. Any landscape policy should reflect the content of national guidance, rather than continuing with or introducing additional policies and designations that have no policy basis, as they are not necessary, are not consistent with national policy and are not justified. Q-B4: Please select the option which is most appropriate for South Warwickshire 7.4. Paragraph 176 of the NPPF requires 'great weight' to be given to conserving and enhancing 'landscape and scenic beauty' in, inter alia, Areas of Outstanding Natural Beauty (AONB). It also requires "…development within their setting should be sensitively located and designed to avoid or minimise adverse impacts on the designated areas.” 7.5. The requirement for development within the 'setting' of AONBs to be sensitively located and designed renders the provision of a policy on this matter unnecessary. National policy guidance seeks to protect AONBs and their setting, and a policy on this matter would be repetitive and is unnecessary. Q-B8.1: Do you agree that the plan should include a policy avoiding development on the best and most versatile agricultural land, unless it can be demonstrated that the harm to agricultural land is clearly outweighed by the benefit of development? 7.6. Para 174 b) of the NPPF states that "planning policies and decisions should contribute to and enhance the natural and local environment by … recognising the intrinsic character and beauty of the countryside … including the economic and other benefits of the best and most versatile agricultural land.” In addition, PPG paragraph 001 Ref ID 8-001-20190721 states that the quality of farmland should be utilised to inform choices about its future use within the planning system. 7.7. Any policy should avoid taking a blanket approach as there will be circumstances where development on best and most versatile land is appropriate. This may also apply to some allocations. The policy should be sufficiently flexible and allow for cases when the planning balance favours approval.
Q-B5: With a target of more than 10%. A target of 10% is not sustainable from a wildlife point of view. Habitats and species will be too fragmented to maintain healthy populations. We know there are many species struggling and decreasing in number now so this trend can only be reversed if more wild habitats are preserved and enhanced. Q-B6: Yes. Designate areas of Wildbelt across the Local Plan Area to support nature’s recovery and the Wildlife Trust’s goal to have 30% of our land and sea managed for nature by 2030.
Q-B3: Special Landscape Areas currently only exist within Stratford-on-Avon District and were introduced in the currently adopted Core Strategy (2016), as a result of information provided in the Special Landscape Area Study (2012). 7.2. Such designation has no basis in national guidance or policy and are not included in Natural England's approach. Rather, paragraph 174 of the NPPF and others seek to conserve and enhance the local environment, ensure that policies take into account landscape implications arising from development, consider landscape and visual impacts, and protect 'valued landscapes'. 7.3. Any landscape policy should reflect the content of national guidance, rather than continuing with or introducing additional policies and designations that have no national basis in policy or support, as they are not necessary, are not consistent with national policy and are not justified. Q-B4: Paragraph 176 of the NPPF requires 'great weight' to be given to conserving and enhancing 'landscape and scenic beauty' in, inter alia, Areas of Outstanding Natural Beauty (AONB). It also requires "…development within their setting should be sensitively located and designed to avoid or minimise adverse impacts on the designated areas.” 7.5. The requirement for development within the 'setting' of AONBs to be sensitively located and designed renders the provision of a policy on this matter unnecessary. National policy guidance seeks to protect AONBs and their setting, and a policy on this matter would be repetitive and is unnecessary.
Q-B3: Please select the option which is most appropriate for South Warwickshire Special Landscape Areas currently only exist within Stratford-on-Avon District and were introduced in the currently adopted Core Strategy (2016), as a result of information provided in the Special Landscape Area Study (2012). Such designation has no basis in national guidance or policy and are not included in Natural England's approach. Rather, paragraph 174 of the NPPF and others seek to conserve and enhance the local environment, ensure that policies take into account landscape implications arising from development, consider landscape and visual impacts, and protect 'valued landscapes'. Any landscape policy should reflect the content of national guidance, rather than continuing with or introducing additional policies and designations that have no grounding in national policy, as they are not necessary, not consistent with national policy and are therefore not justified. Q-B4: Please select the option which is most appropriate for South Warwickshire Paragraph 176 of the NPPF requires 'great weight' to be given to conserving and enhancing 'landscape and scenic beauty' in, inter alia, Areas of Outstanding Natural Beauty (AONB). It also requires "…development within their setting should be sensitively located and designed to avoid or minimise adverse impacts on the designated areas." The requirement for development within the 'setting' of AONBs to be sensitively located and designed renders the provision of a policy on this matter unnecessary. National policy guidance seeks to protect AONBs and their setting, and a policy on this matter would be repetitive and is unnecessary. Q-B8.1: Do you agree that the plan should include a policy avoiding development on the best and most versatile agricultural land, unless it can be demonstrated that the harm to agricultural land is clearly outweighed by the benefit of development Para 174 b) of the NPPF states that "planning policies and decisions should contribute to and enhance the natural and local environment by … recognising the intrinsic character and beauty of the countryside … including the economic and other benefits of the best and most versatile agricultural land…" In addition, PPG paragraph 001 Ref ID 8-001-20190721 states that the quality of farmland should be utilised to inform choices about its future use within the planning system. If a specific policy is to be proposed for the emerging Local Plan then it should be fully evidenced by information to demonstrate that it is justified and does not unduly prevent sustainable development from coming forward in accordance with relevant considerations regarding the NPPF and Development Plan. Given the rural nature of both districts within the Plan there will be development proposals and allocations where there will be a loss of some agricultural land. In respect of the deliveryof new settlements there is likely to be loss of some BMV agricultural land due to the scale of the proposals and the siting of the proposed new settlement locations. The location of BMV land should be recognised to inform choices in the location of development proposals but the wider sustainability benefits of developing certain areas of BMV land, particularly for strategic developments such as new settlements may significantly outweigh its loss. Any policy should avoid taking a blanket approach as there will be circumstances where development on best and most versatile land is appropriate. This may also apply to some allocations. The policy should be sufficiently flexible and allow for cases when the planning balance favours approval.
Q-B1: We would suggest it should be either B1a or B1b as B1c would lead to differences within the plan area. Q-B4: The Cotswold AONB is defined and there appears to be little logic the create a buffer effectively leading to an artificial extension that could prejudice otherwise acceptable rural housing or economic growth. Any concerns can be covered through a general landscape protection policy. Q-B5: The national approach should be adopted. Q-B6: Wildbelt is inadequately defined. It suggests the allocation of land for nature conservation. This would need clearly worded objectives and scrutiny/examination over the areas identified, as well as thought on how it could be delivered. Q-B9: This should be consistent with national policy.
Q- B.5 Please select the option which is most appropriate for South Warwickshire. Option B5a: Explore and pursue an integrated Environmental Net Gain Policy. I am disappointed to see such a low minimum target for proposed biodiversity net gain. Other councils such as Greater Cambridgeshire have been more ambitious requiring 20% Biodiversity net gain. This would be more in keeping with mitigating our environmental state of emergency Q B.6 Should the South Warwickshire Local Plan introduce Wildbelt designations? Yes, absolutely but this should not push development to the North of South Warwickshire, instead all areas have wild belt designations. Q B 9 Yes. In order to meet national requirements and targets set out in the 25 year Environment Plan, COP15 biodiversity framework targets, and the Governments commitment to have 30% more land In nature recovery by 2030, and Councils NERC duties there clearly needs to be a specific policy protecting biodiversity and importantly other non-designated sites such as Potential Local Wildlife Sites, Nature Reserves and Ecosites. It is also very important to include a policy on enhancing these sites, the words ‘unless clearly outweighs..’ should be removed as this waters down the requirement, and will greatly affect the Councils ability to achieve the Government and COP targets. BQ. 10. The biodiversity and environmental assessments for Henley presented in the current consultation documents are inadequate and have not identified a number of considerable environmental areas of conservation and protected species, along with a lack of understanding about the geology of the Henley area which leaves it open to flood related issues which are unlikely to be fully addressed by developers. In Henley the infrastructure in general including the sewer provision is not able to meet the needs of large scale development in the area.
Q-B4: The Cotswold AONB is defined and there appears to be little logic the create a buffer effectively leading to an artificial extension that could prejudice otherwise acceptable rural housing or economic growth. Any concerns can be covered through a general landscape protection policy. Q-B5: The national approach should be adopted. Q-B6: Wildbelt is inadequately defined. It suggests the allocation of land for nature conservation. This would need clearly worded objectives and scrutiny/examination over the areas identified, as well as thought on how it could be delivered. Q-B9: This should be consistent with national policy.
Q-B3: Please select the option which is most appropriate for South Warwickshire 7.1. Special Landscape Areas currently only exist within Stratford-on-Avon District and were introduced in the currently adopted Core Strategy (2016), as a result of information provided in the Special Landscape Area Study (2012). 7.2. Such designation has no basis in national guidance or policy and are not included in Natural England's approach. Rather, paragraph 174 of the NPPF and others seek to conserve and enhance the local environment, ensure that policies take into account landscape implications arising from development, consider landscape and visual impacts, and protect 'valued landscapes'. 7.3. Any landscape policy should reflect the content of national guidance, rather than continuing with or introducing additional policies and designations that have no policy basis, as they are not necessary, are not consistent with national policy and are not justified. Q-B4: Please select the option which is most appropriate for South Warwickshire 7.4. Paragraph 176 of the NPPF requires 'great weight' to be given to conserving and enhancing 'landscape and scenic beauty' in, inter alia, Areas of Outstanding Natural Beauty (AONB). It also requires "…development within their setting should be sensitively located and designed to avoid or minimise adverse impacts on the designated areas.” 7.5. The requirement for development within the 'setting' of AONBs to be sensitively located and designed renders the provision of a policy on this matter unnecessary. National policy guidance seeks to protect AONBs and their setting, and a policy on this matter would be repetitive and is unnecessary. Q-B8.1: Do you agree that the plan should include a policy avoiding development on the best and most versatile agricultural land, unless it can be demonstrated that the harm to agricultural land is clearly outweighed by the benefit of development? 7.6. Para 174 b) of the NPPF states that "planning policies and decisions should contribute to and enhance the natural and local environment by … recognising the intrinsic character and beauty of the countryside … including the economic and other benefits of the best and most versatile agricultural land.” In addition, PPG paragraph 001 Ref ID 8-001-20190721 states that the quality of farmland should be utilised to inform choices about its future use within the planning system. 7.7. Any policy should avoid taking a blanket approach as there will be circumstances where development on best and most versatile land is appropriate. This may also apply to some allocations. The policy should be sufficiently flexible and allow for cases when the planning balance favours approval.
Q-B8.1: Agricultural land: I feel all agricultural land should be deemed as the best and most versatile when it is tenant farm land as this provides a much needed route for young farmers or other new entrants to start work in this nationally important industry creating food security for the nation and County. This need for food security has been shown to be even more important in the post-Brexit era and the current Ukraine/Russia conflict.
Q-B8.1: Agricultural land: I feel all agricultural land should be deemed as the best and most versatile when it is tenant farm land as this provides a much needed route for young farmers or other new entrants to start work in this nationally important industry creating food security for the nation and County. This need for food security has been shown to be even more important in the post-Brexit era and the current Ukraine/Russia conflict.
Issue B1: Areas of Restraint: The current greenbelt designation concerns openness, inappropriate development, and traffic generation, but the new plan should also include biodiversity enhancement. Any development in the greenbelt / area of restraint should only be permitted if there is a measurable increase in biodiversity, in addition to the other conditions. Planners must develop unambiguous and consistent policies to protect special landscapes and enhance biodiversity. Issue B5: Environmental Net Gain: The concept of Environmental Net Gain should be preferred to Biodiversity Net Gain as it includes air quality and water quality as well as biodiversity. Carbon offsetting must go beyond tree planting, for example, committing to retrofitting existing houses to make them more energy efficient. Definitions of offsetting need to be absolutely clear to prevent greenwashing.
Q-B8.1: Agricultural land: I feel all agricultural land should be deemed as the best and most versatile when it is tenant farm land as this provides a much needed route for young farmers or other new entrants to start work in this nationally important industry creating food security for the nation and County. This need for food security has been shown to be even more important in the post-Brexit era and the current Ukraine/Russia conflict.
Q-B8.1: Agricultural land: Research (e.g. by Cambridge University (Institute for Sustainable Leadership) has shown that the UK faces a major shortfall of at least 2 million hectares of farmland for food production, and potentially a shortfall of up to 7 million hectares, by 2030, because farmland is being rapidly lost to, inter alia, development. The need for food security has become even more critical post-Brexit and because of the war in Ukraine. The land put forward for potential development to the north of the River Leam between Weston under Wetherley and Hunningham, comprises two farms owned by Warwickshire County Council. I expect Local Authorities above all to act responsibly in helping to reduce, not increase, the growing threat to food security. Also, I feel that all agricultural land should be deemed as the best and most versatile when it is tenant farmland, as this provides a much-needed route for young farmers or other new entrants to start work in such a nationally and locally important industry, remembering that buying locally produced food is also an important contributor to counteracting the climate emergency.
Q-B8.1: Agricultural land: I feel all agricultural land should be deemed as the best and most versatile when it is tenant farm land as this provides a much needed route for young farmers or other new entrants to start work in this nationally important industry creating food security for the nation and County. This need for food security has been shown to be even more important in the post-Brexit era and the current Ukraine/Russia conflict.
Issue B5: Environmental Net Gain. Q-B5: Please select the option which is most appropriate for South Warwickshire The Church Commissioners states that Option B5c is appropriate in relation to Environmental Net Gain. The Church Commissioners appreciates and acknowledges the requirement of the Environmental Act, for 10% biodiversity net gain, however cannot support either Option B5a or B5b as it is unclear how either option would work in practice. Clarity is required to understand how Air Quality, Water Quality and Carbon Capture can feed into the environmental net gain concept, and further evidence is required to show how this would work in practice, but also from a viability perspective. As a result, The Church Commisioners reserves the right to comment on any future policy later in the plan making process. Issue B6: Wildbelt designations Q-B6: Should the South Warwickshire Local Plan introduce Wildbelt designations? The South Warwickshire Local Plan should not introduce Wildbelt designations, to enable the goal of 30% of land to be managed for nature by 2030. As Issue B6 sets out, ‘the idea of Wildbelt is that it protects the space that nature needs for the future,’ however The Church Commissioners questions how the Council are aware of what areas require protecting at this stage, due to the lack of evidence produced at this point. The Councils need to undertake further work, including that to understand their housing and employment land requirements prior to introducing further designations. Any proposed Policy in relation to Wildbelt designations, including the identification of land needs to be fully consulted and engaged upon if the Council proceed on this basis.
Q-B8.1: Agricultural land: I feel all agricultural land should be deemed as the best and most versatile when it is tenant farm land as this provides a much needed route for young farmers or other new entrants to start work in this nationally important industry creating food security for the nation and County. This need for food security has been shown to be even more important in the post-Brexit era and the current Ukraine/Russia conflict.
Q-B8.1: Agricultural land: I feel all agricultural land should be deemed as the best and most versatile when it is tenant farm land as this provides a much needed route for young farmers or other new entrants to start work in this nationally important industry creating food security for the nation and County. This need for food security has been shown to be even more important in the post-Brexit era and the current Ukraine/Russia conflict.
Q-B8.1: Agricultural land: I feel all agricultural land should be deemed as the best and most versatile when it is tenant farm land as this provides a much needed route for young farmers or other new entrants to start work in this nationally important industry creating food security for the nation and County. This need for food security has been shown to be even more important in the post-Brexit era and the current Ukraine/Russia conflict.
Q-B8.1: Agricultural land: I feel all agricultural land should be deemed as the best and most versatile when it is tenant farm land as this provides a much needed route for young farmers or other new entrants to start work in this nationally important industry creating food security for the nation and County. This need for food security has been shown to be even more important in the post-Brexit era and the current Ukraine/Russia conflict.
Q-B8.1: Agricultural land: I feel all agricultural land should be deemed as the best and most versatile when it is tenant farm land as this provides a much needed route for young farmers or other new entrants to start work in this nationally important industry creating food security for the nation and County. This need for food security has been shown to be even more important in the post-Brexit era and the current Ukraine/Russia conflict.
Q-B8.1: Agricultural land: I feel all agricultural land should be deemed as the best and most versatile when it is tenant farm land as this provides a much needed route for young farmers or other new entrants to start work in this nationally important industry creating food security for the nation and County. This need for food security has been shown to be even more important in the post-Brexit era and the current Ukraine/Russia conflict.
Q-B8.1: Agricultural land: I feel all agricultural land should be deemed as the best and most versatile when it is tenant farm land as this provides a much needed route for young farmers or other new entrants to start work in this nationally important industry creating food security for the nation and County. This need for food security has been shown to be even more important in the post-Brexit era and the current Ukraine/Russia conflict.
Q-B8.1: Agricultural land: I feel all agricultural land should be deemed as the best and most versatile when it is tenant farm land as this provides a much needed route for young farmers or other new entrants to start work in this nationally important industry creating food security for the nation and County. This need for food security has been shown to be even more important in the post-Brexit era and the current Ukraine/Russia conflict.
Q-B8.1: Agricultural land: I feel all agricultural land should be deemed as the best and most versatile when it is tenant farm land as this provides a much needed route for young farmers or other new entrants to start work in this nationally important industry creating food security for the nation and County. This need for food security has been shown to be even more important in the post-Brexit era and the current Ukraine/Russia conflict.
Q-B8.1: Agricultural land: I feel all agricultural land should be deemed as the best and most versatile when it is tenant farm land as this provides a much needed route for young farmers or other new entrants to start work in this nationally important industry creating food security for the nation and County. This need for food security has been shown to be even more important in the post-Brexit era and the current Ukraine/Russia conflict.
QB4. The Parish Council believes that in general our environmental quality needs to be protected and maintained, however these issues should be raised with the relevant statutory agencies involved. The Local Plan part 1 does not seem to be the correct place to have this debate. QB5 The Parish Council would support option B5a. The core idea is sound, but more research should be undertaken to consider the impact of where this might push more development. QB8.1 The Parish Council consider the Plan should include a policy avoiding development on the best and most versatile agricultural land. Nationally agricultural land will more than ever be needed to feed the country. QB8.2 The Parish Council does not have the expertise to respond at this stage QB8.3 The Parish Council would support the proposal, but it seems doubtful that duplication is essential at this stage. QB6 The Parish Council does not have expertise to respond to this point QB7 The Parish Council does not have expertise to respond to this point
1 Issue B1 – Environmental Net Gain 5.21.1 St. Modwen support Option B5a to explore and pursue an integrated Environmental Net Gain Policy. This approach should advocate flexible and workable net gain solutions to facilitate on site and off site solutions that maximise the benefits to the SWLP. It should apply an integrated approach, utilising ENG whilst still achieving a 10% net gain for biodiversity. This would be the most logical tactic, particularly considering the holistic nature of the approach required to halt and reverse biodiversity loss, which is a core focus of the SWLP.
Q-B5: As a general view, in ecology advice we have delivered a net gain position where possible, in line with the NPPF changes in 2019. Stratford policy position is in line with this (Core Strategy 2016). Warwick DC policy position is also in line (NE3 Local Plan 2017), both stating no net loss, net gain where possible. Ecology planning advice support the position of 10% BNG to further develop this long-standing approach. Whilst the natural capital approach and biodiversity offset are closely linked, it is worth noting that the biodiversity offset process within planning advice is very well established (10 years); therefore a separate policy may be quicker and easier to adopt. This does not prevent integration of approaches. Q-B6: Ecology Planning advice strongly support the principle of wildlife corridors and buffers, in order to mitigate and adapt species and habitat movement as a result of climate change. Whilst we appreciate that Wildbelt is a new concept, it is broadly in line with this intention. We would encourage a district or borough, as part of the Local Plan process, to provide evidence supporting a percentage goal. Q-B7: Ecology Planning advice supports good quality signposting in policy documents; this makes policy position clearer for both applicants and consultees. It also provides consistency because it helps to avoid conflict in policy. Q-B8.1: N/A Q-B9: Ecology Planning advice would like to emphasise the importance of regionally important sites for nature conservation, such as Local Wildlife Sites and Local Geological Sites. We support alignment across the Plan area, with a similar approach for both Stratford and Warwick. Whilst we appreciate the need for flexibility, we would like to see locally-designated sites being adequately valued when balancing harm against benefit of development. Q-B10: The NPPF supports ‘wins’ across all three Economic, Social and Environmental themes. Therefore, the SWLP should look to formulate an Environmental Net Gain (ENG) policy to demonstrate an objective to be in conformity with the national framework. An ENG policy could incorporate Biodiversity Net Gain and Carbon Offsetting with the aims to enable nature_based solutions as ways to both mitigate and compensate developmental impacts as evidence to the adherence to the Mitigation Hierarchy. SDC and WDC continue to work with WCC EHEL to develop Natural Capital markets that will enable development to become environmentally sustainable should residual impacts be identified. It should be expected that conditions and obligations will be used to ensure ENG is achieved. CSWAPO has agreed that as Biodiversity Net Gain and other markets are developed, both locally and nationally, supplementary guidance will be produced through the Warwickshire Ecosystem Services Trading Protocol, an annex to the Warwickshire, Coventry and Solihull Green Infrastructure Strategy.
For your information we have set out some general guidelines and relevant policy wording that may be useful to you in the development of your plan. Blue Green Infrastructure We are supportive of the principles of blue green infrastructure and plans that aim to improve biodiversity across our area. Looking after water means looking after nature and the environment too. As a water company we have launched a Great Big Nature Boost Campaign which aims to revive 12,000 acres of land, plant 1.3 million trees and restore 2,000km of rivers across our region by 2027. We also have ambitious plans to revive peat bogs and moorland, to plant wildflower meadows working with the RSPB, National Trust, Moors for the Future Partnership, the Rivers Trust, National Forest and regional Wildlife Trusts and conservation groups. We want to encourage new development to continue this theme, enhancing biodiversity and ecology links through new development so there is appropriate space for water. To enable planning policy to support the principles of blue green Infrastructure, biodiversity and protecting local green open spaces we recommend the inclusion of the following policies: Blue and Green Infrastructure Policy Development should where possible create and enhance blue green corridors to protect watercourses and their associated habitats from harm. Supporting Text: The incorporation of Sustainable Drainage Systems (SuDS) into blue green corridors can help to improve biodiversity, assisting with the wider benefits of utilising SuDS. National Planning Policy Framework (2018) paragraph 170 States: “Planning policies and Decisions should contribute to and enhance the natural and local environment by: a) protecting and enhancing valued landscapes, sites of biodiversity or geological value and soils (in a manner commensurate with their Statutory Status or identified quality in the development plan); b) recognising the intrinsic character and beauty of the countryside, and the wider benefits from natural capital and ecosystem services – including the economic and other benefits of the best and most versatile agricultural land, and of trees and woodland; c) maintaining the character of the undeveloped coast, while improving public access to it where appropriate; d) minimising impacts on and providing net gains for biodiversity, including by establishing coherent ecological networks that are more resilient to current and future pressures;” Green Open Spaces Policy Development of flood resilience schemes within local green spaces will be supported provided the schemes do not adversely impact the primary function of the green space. Supporting Text: We understand the need for protecting Green Spaces, however open spaces can provide suitable locations for schemes such as flood alleviation schemes to be delivered without adversely impacting on the primary function of the open space. If the correct scheme is chosen, the flood alleviation schemes can result in additional benefits to the local green space through biodiversity and amenity benefits.
Q-B5: Caddick Land states that Option B5c is appropriate in relation to Environmental Net Gain. Caddick Land appreciates and acknowledges the requirement of the Environmental Act, for 10% biodiversity net gain, however cannot support either Option B5a or B5b a s it is unclear how either option would work in practice. Clarity is required to understand how Air Quality, Water Quality and Carbon Capture can feed into the environmental net gain concept, and further evidence is required to show how this would work in practice, but also from a viability perspective. As a result, Caddick Land reserves the right to comment on any future policy later in the plan making process. Q-B6: Should the South Warwickshire Local Plan introduce Wildbelt designations? 9.2 The South Warwickshire Local Plan should not introduce Wildbelt designations, to enable the goal of 30% of land to be managed for nature by 2030. As Issue B6 sets out, ‘the idea of Wildbelt is that it protects the space that nature needs for the future,’ h owever Caddick Land questions how the Council are aware of what areas require protecting at this stage, due to the lack of evidence produved at this point. The Councils need to undertake further work, including that tounderstand their housing and employment land requirements prior to introducing further designations. Any proposed Policy in relation to Wildbelt designations, including the identification of land needs to be fully consulted and engaged upon if the Council proceed on this basis.