Sustainability Appraisal (SA) for the Rutland Local Plan

Support

Representation ID: 6758

Received: 03/01/2024

Respondent: Natural England

Natural England has reviewed the Sustainability Appraisal (SA) and considers that it provides a comprehensive assessment of this stage of the Local Plan. We note that Alternatives have been assessed and cumulative impacts have been adequately addressed.
From the SA report we particularly highlight the following points where there is some uncertainty and may require further consideration in the next stage of the SA process:
• The section on Biodiversity & Geodiversity has identified development allocations which are in proximity to designated conservation sites and that some of these may require further consultation with Natural England as they have the potential to lead to significant negative
effects on biodiversity and geodiversity. This uncertainty has been acknowledged and we recognise that the SA shows that the policy framework would provide appropriate protection to designated sites and protected species. In addition policies on Green Infrastructure and
BNG would support and enhance ecological connectivity but would depend to an extent on the design and layout of development.
• On the section on Landscape we note that the SA finds the extent to which negative effects on landscape will be mitigated is uncertain and will depend on the adequacy of the design and layout of development.
We presume that the next stage of the SA for the Regulation 19 of the Local Plan will set out a monitoring programme to evaluate the ongoing effects of the plan.

Object

Representation ID: 6970

Received: 05/01/2024

Respondent: Cora Homes Limited

Agent: Jeakins Weir

Five growth options are considered by the SA with a number of sites considered across all five options. Quarry Farm (North of Stamford), for example, is a constant across all five options despite this site having no pre-existing planning status other than an undetermined planning application. Allocations within the Uppingham Neighbourhood Plan review are also treated as a constant across all of the options, despite the fact that examination of the Neighbourhood Plan has yet to conclude. Other sites include the Officers Mess at Edith Weston, despite falling outside of settlement boundaries and not having any pre-existing planning status. This does not represent a testing of genuine reasonable alternatives but rather different permutations of what is fundamentally the same spatial strategy. That problem is amplified by the fact that only a handful of rural settlements have been selected as playing host to development across all five growth options, and these all happen to be locations where the preferred strategy is apportioning growth.
There is similarly little clarity within the SA as to why some villages have been selected for testing as part of the overall spatial strategy whilst others in the same tier of the settlement hierarchy have simply been ignored. Given that many of the locations ignored happen to be Rutland’s larger rural settlements, it is hard to see how the SA has informed a sustainable pattern of growth that represents the most appropriate strategy when assessed against the reasonable alternatives.

The SA does not present an appropriately robust testing of the preferred spatial strategy against the reasonable alternatives and that therefore the emerging local plan’s spatial strategy is not justified.

Object

Representation ID: 7020

Received: 08/01/2024

Respondent: South Luffenham Parish Council

Present Population 41381, Projected population 2036: 45,038, 2041: 46,100. The plan projects dependent on option considered housing development between 3,500-4,500. Assuming minimum of 2 persons per dwelling then actual potential population for Rutland would be nearer 50,000, has this number been considered in delivering sustainable development of infrastructure and impact on local amenities.

Object

Representation ID: 7046

Received: 04/01/2024

Respondent: Oakham South Action Group

We believe that promoting Oak04 as a preferred site, runs counter to the following Sustainability Objectives in the “Sustainability Appraisal (SA) for the Rutland Local Plan” AECOM Nov 2023:

Strategic Objective 1:
More cars at an already congested crossing will increase pollution and increase the risk of harm to
people waiting there. Moreover, more cars on the congested roads around the crossing will increase
pollution as traffic is more likely to be stationary as the traffic cannot flow as it would on a main
arterial road.

Strategic Objective 2:

Development on Brooke Rd cannot meet “today’s needs” as the roads here are at capacity and the
schools are full, contrary to what RCC Officers are telling their Councillors. There is one space at Vale
of Catmose PS and three at Brooke Hill Academy. This means that, were there to be a development
on Brooke Road, the increase in congestion (and therefore carbon emissions) due to children being
taken to schools that are not full, would increase significantly.

Strategic Objective 3:

Taylor Wimpey’s proposed development does nothing to meet this requirement as the houses would
not be built with any particular aspect of the laudable objectives outlined above and would certainly
do nothing to meet the supply of what is actually needed here ie social housing that is “affordable”
and offered on a rental basis.

Strategic Objective 8:

This is an area of the town of historic significance where the Edwardian ribbon development gives a unique and significant backdrop, which in order to save Oakham’s heritage, should not be compromised. It is unfortunate
2 that modern development in the 1970s did not recognise the importance of this site and makes it all the more important that development does not further compromise the Edwardian feel enjoyed by the two halves of the road: into Mill Street and up to Brooke village.

Strategic Objective 9:

It is certainly not prudent use of agricultural land to build on this when it could be supplying food at a
time when food security is so important and runs counter to the Plan’s Policy EN6 - Protecting
agricultural land.
Much emphasis in the Plan is placed on the importance of building within the Planned Limits of Development (see below). According to the “Planned Limits to Development Final Report, Oct 2023”,
Brooke Road forms the edge of this and should therefore not be built on as it would contravene the
new PLD.

Strategic Objective 10:

There is no suggestion that there are any plans to improve the infrastructure here as the doctor’s surgery is at capacity, as are the local primary schools south of the crossing. The only infrastructure that could mitigate the highway congestion at the railway crossing, would be
a bridge. This has been assessed by Network Rail through a Cost Benefit Analysis and found not to be a viable option. The cost would be prohibitive for both RCC and the site promoter.

Object

Representation ID: 7349

Received: 08/01/2024

Respondent: Jeakins Weir

Agent: Jeakins Weir

The preferred spatial strategy has been tested alongside other reasonable alternatives by the Sustainability Appraisal Report to Accompany the Preferred Options Consultation Document produced by AECOM.
Five growth options are considered by the SA with a number of sites considered across all five options, that does not represent a testing of genuine reasonable alternatives but rather different permutations of what is fundamentally the same spatial strategy. That problem is amplified by the fact that only a handful of rural settlements have been selected as playing host to development across all five growth options, and these all happen to be locations where the preferred strategy is apportioning growth. The emerging local plan has opted to direct significant growth to settlements that are ranked as “larger villages,” but which are demonstrably less sustainable than other settlements within that same rung of the hierarchy and which are less sustainable than the main town of Oakham.
Therefore, the SA does not present an appropriately robust testing of the preferred spatial strategy against the reasonable alternatives and that therefore the emerging local plan’s spatial strategy is not justified.

Object

Representation ID: 7380

Received: 08/01/2024

Respondent: The Society of Merchant Venturers

Agent: Savills

The Sustainability Appraisal confirms the Council’s approach taken for housing delivery in the County – as
set out in Policy SS1 and equating to 123 dwellings per annum (2,460 over the 20-year period 2021- 2041).

The Sustainability Appraisal also highlights alternative growth strategy options by identifying constants
(‘components of the growth strategy options which would be similar across all the options’) and variables
(‘components which can vary across the options’).

In total, five alternative growth strategy options are detailed, ranging from 2,905 dwellings to 3,985 dwellings
to be provided over the Plan period. It is notable that the higher growth options are not predicted to result
in significant negative effects, or indeed are predicted to result in significant positive effects, against some
of the SA themes – e.g. the Communities, Health and Wellbeing SA theme (Table 7.6), the Transportation
SA theme (Table 7.7) and the Economic Vitality SA theme (Table 7.8).

In regards to Oakham, which is the focus for housing growth over the Plan period and the ‘main town of
Rutland’, the supply ‘constants’ equate to the delivery of 229 homes. ‘Land south of Stamford Road’ (ref.
H1.3) is included within the supply ‘constants’ for Oakham. In terms of the ‘variables’ for Oakham, these
equate to 464 homes across two reserve sites.

Notably, ‘Land at Uppingham Road’ is not included within the reserve sites for Oakham as the Sustainability
Appraisal seemingly places an emphasis on growth at larger villages when assessing the alternative growth
strategy options. This is however not considered to be in line with the spatial strategy which seeks to focus
growth within Oakham (and Barleythorpe) and Uppingham, and on land adjacent to Stamford. It is therefore considered that if alternative growth strategy options are pursued, then more growth could be directed
towards Oakham in line with the spatial strategy set out within Policy SS1. This would also have potential
to deliver additional significant positive effects against some of the SA themes, as referred to above.

In addition, it is noted that the Sustainability Appraisal is informed by the Landscape Character Assessment
(December 2022) and the RSLSS (July 2023). As noted in our response to Policy SC1, both assessments
were undertaken prior to the development at Oakham Pastures (located to the west of Uppingham Road
and south of Oakham). This notably changes the baseline position for the sites, and therefore it is important
that the Sustainability Appraisal is updated to accurately reflect the landscape position of the sites
(specifically in regard to the findings in the RSLSS for ‘Land at Uppingham Road’).

Object

Representation ID: 8007

Received: 08/01/2024

Respondent: Mr PJRS Hill and Pikerace Limited

Agent: Silver Fox Developments

Five growth options are considered by the SA with a number of sites considered across all five options. Quarry Farm (North of Stamford), for example, is a constant across all five options despite this site having no pre-existing planning status other than an undetermined planning application.

Allocations within the Uppingham Neighbourhood Plan review is also treated as a constant across all of the options, despite the fact that examination of the Neighbourhood Plan has yet to conclude.

Other sites include the Officers Mess at Edith Weston, which is a further constant across all growth options, despite falling outside of settlement boundaries and not having any pre-existing planning status.

To the extent that a large number of sites appear across all five options, that does not represent a testing of genuine reasonable alternatives but rather different permutations of what is fundamentally the same spatial strategy. That problem is amplified by the fact that only a
handful of rural settlements have been selected as playing host to development across all five growth options, and these all happen to be locations where the preferred strategy is apportioning growth. As set out above, the emerging local plan has opted to direct significant growth to settlements that are ranked as “larger villages,” but which are demonstrably less sustainable than other settlements within that same rung of the hierarchy and which are less sustainable than the main town of Oakham.

For the above reasons, the SA does not present an appropriately robust testing of the preferred spatial strategy against the reasonable alternatives and that therefore the emerging local plan’s spatial strategy is not justified.