The Plan allocates around 30 homes and a car park of up to 200 spaces on highly sensitive land in the Cotswolds National Landscape. It never judges whether this is "major development" or applies the NPPF §190 exceptional circumstances test, which would risk the site being undeliverable.
The landscape sensitivity, transport and sustainability evidence all consider the site as housing only. The car park, which would be larger than Burford's biggest existing car park, has had no proper assessment of its landscape, traffic, heritage or air quality impacts .
Brownfield sites were rejected even though they were assessed as suitable and would deliver almost as many homes. No alternative car park or coach parking sites were assessed either, despite land north of the A40 (including BUR005) offering direct access to the road most visitors use.
The appraisal still assesses the previous 70-home scheme and leaves out the car park. This undermines its conclusions and raises doubt over the Plan's compliance with the SEA Regulations 2004
Residents estimate the car park at around £1m, while 30 homes would generate only about £450,000 in CIL. Neither the Plan nor its Viability Assessment shows how the shortfall would be funded or that the scheme remains viable.
BUR3 favours a greenfield site over suitable brownfield land, contrary to NPPF §§124, 125 and 128. It also fails to address cumulative traffic impacts (§109) or give neighbourhood planning its proper role (§§29–30).

Deleting BUR3 and setting an indicative 30-home target for the Burford Neighbourhood Plan in Policy BUR1 would resolve the unsoundness. There is precedent for this modification at examination, and residents already know of land that could provide both the housing and a larger car park with coach parking.
WOLP Reg 19 Rep_Burford residents (pdf)
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