General comments

Object

Representation ID: 4961

Received: 31/12/2023

Respondent: Mrs Claire Champion

- Increased pressure on existing infrastructure
- more demand for same number of doctors
- Increased traffic on a road that already struggles at times
- further reduction of green space
- Increased flood risk to existing properties

Object

Representation ID: 5030

Received: 02/01/2024

Respondent: Mr Frank Brett

The Style and Format of the document does not lend itself to general consumption, and seems very formal, legalistic and complex. it really would help the reader greatly to cross-reference policies. rather than simply suggesting that the whole plan document has to be examined. A 'Future Rutland Shared Vision' was produced in 2022 - it is disappointing that this is apparently not even mentioned in the Introduction. It would be even better if the Local Plan could be seen to align with the Shared Vision. Otherwise, what was the point?

Object

Representation ID: 5031

Received: 02/01/2024

Respondent: Mr Frank Brett

I would like to modify my previous comments about the Future Rutland Vision as I see this is referenced in Vision and Objectives chapter. It would still be nice to have a mention in the Introduction though.

Object

Representation ID: 5123

Received: 22/12/2023

Respondent: Empingham Parish Council

HRA COMMENTS:

The eastern end of Rutland Water and the Dam are in Empingham Parish. The Habitats Regulations Assessment was a desk study. It fails to take account of recent developments which affect the Reg18 document.

The Habitats Regulations Assessment of November 2023 states at 4.3.32 that Rutland Water is fed primarily by abstraction from the river Nene upstream from Peterborough and from the river Welland upstream from Stamford. The natural upstream catchment is small with minimal inputs from the river Gwash and Engleton brook. Long standing village residents also advise that during reservoir construction there was concern that the significant volume of water abstracted would exceed the design specification for the project.
EPC and local landowners consider that water from land to the north and south of the Whitwell Road drains into the river Gwash and does not contribute to supplying the Rutland Water reservoir, a protected wetlands area (RAMSAR etc). The RAMSAR website records that the most interesting semi-terrestrial habitats occur mainly at the western end of the lake and include lagoons, reed swamp, marsh and damp meadows. Land at the eastern end of Rutland Water in the immediate vicinity of the civil cemetery in Whitwell Road is not owned or managed by Anglia Water. This includes land to the south of the Whitwell Road that also encompasses the five ponds

Object

Representation ID: 6055

Received: 07/01/2024

Respondent: Jane Ellis

The Draft Local Plan needs review in the light of the updated NPPF issued in December 2023, not least concerning housing need and the requirements for housing land supply. The 5YHLS is now advisory and as RRC has reached Reg 18 of stage for Local Plan a 4 year housing supply is now required

Policies may require updating in the light of the updated NPPF. Settlement hierarchy and PLDs may require further review

Object

Representation ID: 6057

Received: 07/01/2024

Respondent: Jane Ellis

An outcome focus for the Local Plan may make it more meaningful. What is each objective going to actually achieve and by when. There appear to be no success measures to ensure the residents and Council Tax payers of Rutland are achieving measurable outcomes and value for money

Object

Representation ID: 6058

Received: 07/01/2024

Respondent: Jane Ellis

It would be useful to know how much the Local Plan has cost to develop, to date, and what the overall anticipated spend is estimated to be

Object

Representation ID: 6874

Received: 08/01/2024

Respondent: Colin Dodd

There are a few elements that require some attention to ensure that the new Local Plan complies with National Planning policy Framework paragraph 16 (d) which states that policies be clearly written and unambiguous, so it is evident how a decision maker should react to development proposals;

I believe that this should be the overriding consideration, or test, when reviewing every element of the new local plan. If a planning policy cannot pass this test, then it should be reworded so that it complies with paragraph
16 of the National Planning Policy Framework.

Object

Representation ID: 6879

Received: 07/01/2024

Respondent: Phil Skipper

The plan does not provide sufficient robustness to preserve the uniqueness of the county.
I am concerned with the looseness of the terminology and the clear opportunity to find an exception to every rule. We need to have robust priorities for development that can be actively used not simply stop development but to ensure that it is of an appropriate scale, there is a need that can not satisfied elsewhere (e.g brown field) and it is in keeping with local preferences, village plans and can be supported by the affected community.
The plan feels like an attempt to create yet another generic UK town with all the normal out of town chain stores, facilities, litter and social issues. Failing to create the right balance between the past, the present and the future and leaving Rutland open to more speculative development that will further dilute the uniqueness of the country and fail to capture value within our boundaries.

Object

Representation ID: 6921

Received: 08/01/2024

Respondent: Avant Homes

It is noted that the Consultation was prepared and released in advance of the recent (December 2023) changes to the NPPF. The Council, therefore, need to consider whether any information contained within that guidance has any impact on the emerging Plan. If so, it is likely that further consultation will be required.

Object

Representation ID: 6931

Received: 05/01/2024

Respondent: Hugh C Palmer

- The draft LP is completely at variance with the Gove future proposals for planning as set out in his updated NPPF effective Dec 19th HCWS 161( to House of Commons/Lords).
- The Draft LP is not fit for purpose when assessed against the latest NPPF and should be withdrawn in its entirety. A NEW Draft Local Plan is required adopting a more imaginative and visionary approach in line with the Gove/NPPF proposals. See for example his proposals for the future development for Cambridge.
- Beauty: NPPF seeks to emphasise the Role of Beauty in housing proposals .Although I have not run a word check, I doubt that the words beauty/beautiful appear anywhere in the Draft LP. Although beauty 'lies in the eyes of the beholder’ it is not a term that many would use to describe any of the housing estates built over recent decades in Rutland.

Object

Representation ID: 6947

Received: 07/01/2024

Respondent: Cottesmore Parish Council

we have also understood that the plan is still a work in progress and that other supporting documents are being published for consultation after the commencement of this Reg.18 process. For example, to develop climate change and environment policies (see comments on Chapter 4 below) and the further work to be done on the infrastructure requirements. This is clearly totally unsatisfactory and flies in the face of other commitments from the new Leadership that have consistently said that this Reg. 18 document is the only significant opportunity for consultation, in that the next draft (Reg. 19) will be more limited consultation priorities around soundness and viability. Whilst hoping the Reg. 19 will be different, to reflect representations made during this consultation process, it is surely unacceptable to issue a document at this stage, which is not even a finalised Reg.18 document, more a work in progress!

Object

Representation ID: 6951

Received: 06/01/2024

Respondent: RCC Expert Panel on Carbon Reduction

Rutland County Council (RCC), in using phrases like “highest possible”, “where appropriate”, “practically and viably possible” suggests a very defensive, over-cautious response to the required Viability Assessment. Clear, measurable, but challenging targets are the only way that the Local Plan can be a leading example to “address the impacts of climate change and the need to become carbon net zero”.

Object

Representation ID: 6954

Received: 05/01/2024

Respondent: The British Horse Society

data relating to road incidents involving horses are provided to illustrate the importance of protecting, improving and extending safe off-road provision to help prevent these numbers from increasing in the future.
Several of the policies refer to 'active travel'. The Society seeks assurance that Rutland CC recognises the inclusivity of active travel in terms of movement for all vulnerable road users. Jesse Norman MP, Parliamentary Under -Secretary of State for Transport in a House of Commons debate on Road Safety, 5 November 2018 Ill stated: "We should be clear that the cycling and walking strategy may have that name but is absolutely targeted at vulnerable road users, including horse-riders

Object

Representation ID: 6960

Received: 06/01/2024

Respondent: RCC Expert Panel on Carbon Reduction

Viability
An average uplift on build costs of about 6%, as indicated in the Viability Assessment, is a small price to pay over the next 20 years. Without this upfront uplift, the build costs for future Local Plans beyond 2040 will be much higher, and RCC will have failed to provide the lead stated in its Vision. Frankly, it is naive to believe that there will be no initial uplift. Despite the Government’s recent instruction to local authorities about not applying local energy efficiency standards (Dec 13, 2023) we believe this is a small price to pay for the future of Rutland and its younger generations to come.
‘Whole Plan Viability Assessments’ for such extended periods, as covered by Local Plans, must, as of necessity, strike balances between innovative vision and apparent viability suggested by projected data. Such data should be largely rooted in averages derived from previous experience and related statistics.

We would therefore draw Rutland County Council’s attention to three key points appearing in their own ‘RCC Draft Local Plan – Whole Plan Viability Report’ which are pertinent to striking that balance.

Support

Representation ID: 6963

Received: 06/01/2024

Respondent: RCC Expert Panel on Carbon Reduction

Cooperation with neighbouring local authorities is especially relevant in terms of a small local authority like RCC tackling climate change, which respects no boundaries. For example, landscape and ecological corridors should be enabled to cross the River Welland from Leighfield Forest to Rockingham Forest. In addition to the statutory requirement cooperation would be a cost-effective way of tackling some of the challenging aspects of carbon reduction.

Object

Representation ID: 6966

Received: 06/01/2024

Respondent: RCC Expert Panel on Carbon Reduction

Additional comments on the Whole Plan Viability Assessment

The Report states that the Plan contains “no strategic sites”, this seems bizarre given the references made to St. Georges Barracks.

There is little detailed argument about how the + of EUV+ might be impacted in the context of rapidly changed adverse market conditions, the Report relying on historic market averages. Even the most optimistic forecasts do not predict a return to sustained long-term all-time low borrowing rates over the next decade.

Similarly, the calculation of Development returns is estimated at between 15 to 20%, such figures being the product of historic perspectives which reflect a buoyant purchasing housing market.

Policies based on historic approaches to viability and housing land usage will not achieve the necessary changes.

Object

Representation ID: 6988

Received: 06/01/2024

Respondent: Greetham Parish Council

Overview
Prior to, or subsequent to the Vision and Objectives section, there should have been a clear, succinct, statement of the intended anticipated County wide vision for Rutland. It is difficult to find any connectivity between all the various aspects of a Local Plan and it’s primary objective. Where are we now and where we hope to be by the end of the plan date with brief explanations of how the ensuing pages lead us to that aim, is missing.
The plan should note our pride in Rutland and that our key objective is to retain it’s beautiful and unique character over the period of the plan.

Object

Representation ID: 6989

Received: 06/01/2024

Respondent: Greetham Parish Council

There should be clear directive of where housing will and won’t be developed and why Neighbourhood Plan ambitions for development may have been over-ridden (e.g. Uppingham is keen to expand as per their Local Plan, but have been capped without a clear explanation of Rutlands Strategy.

We believe that all current Neighbourhood Plans should have been central to the planning strategy and where NP’s indicate a willingness to take developments, these should have formed the basis for housing numbers. This reinforces the effectiveness of Neighbourhood Plans and is an encouragement to other Parish’s to prepare their own.
This also reinforces your aim to take on board feedback from consultations.
We understand that the Local Plan should be developed from the roots upwards, however it appears to be the reverse, Local Plan downwards and Neighbourhood Plan aspirations ignored.

Object

Representation ID: 6995

Received: 06/01/2024

Respondent: Greetham Parish Council

Consultation Process
Far too restrictive: In most cases Parish Councils will have had only one opportunity at a Parish Council Meeting to review, debate, invite the public. The document is over 400 pages and not easy to ensure all aspects are covered in responses. It is a huge analytical task to review this number of pages. A paper copy, at cost, should have been printed for each Parish Council to pick up from RCC.
Greetham has many older residents who have been unable to participate in this electronic process of reading the document and responding via the portal. Our elderly residents feel they have been excluded from this consultation process.

The Issues and Options responses provided by Consultees in February are only “noted” and no clarity given as to whether they have influenced the plan and if not why not. Without this positive feedback, future consultations will probably yield less and less response.

Object

Representation ID: 7039

Received: 08/01/2024

Respondent: Edith Weston Parish Council

The plan lacks coherent linkage between the various parts of the proposed plan (for example climate change and the reduction in carbon with infrastructure and the better use of mass/public transport).

There is no feel for how the plan will be implemented, or details on timelines, deliverables, and performance measurement.

Object

Representation ID: 7063

Received: 08/01/2024

Respondent: Wing Parish Council

The Viability Report, concerned primarily with the production of ‘Housing’ in the context of the present
situation in Rutland, is wide-ranging and comprehensive. However, we have a number of seriously critical comments, as follows

1. At clause 1.17, there is a vital and substantial caveat on interpreting the Report – part of which states “No part of this Report constitutes a valuation and should not be relied upon in that regard.” Much of the viability calculation relates to relative valuations in determining yield, the Report thereby cannot be relied on and effectively falls at the first hurdle.

3.2. Similarly, the Report clearly states that the Consultant does not warrant the estimates and projections made, which again are key to comprehending the range and levels of risk inherent to the Assessment. The second hurdle is failed because the caveat is absolute.

3.3. These opening clauses also make clear, and it is repeated at certain junctures throughout the paper, that much of the data and information used to underpin the
Assessment has been provided by the Local Authority (RCC), or its “contractors” (unspecified), for which HDH carries no responsibility. This caveat potentially invalidates the notion of ‘third party opinion being independent and based on objective technical and professional review’ in the Assessment. A third fundamental hurdle is failed.

3.4. The Report states that the Plan contains “no Strategic Sites”. Does this mean that RCC have ruled out of their consideration all potential Strategic Sites in determining
the Plan and its viability, if so, clearly closing the door on such option for a considerable period? St. Georges Barracks is mentioned and even the reduced number of houses cited, as a percentage of RCC’s total housing estimates would clearly have strategic impact on all other RCC Policies. This appears contradictory.

3.5. Whilst the EUV+ is a recognised and accepted approach to forecasting development costs, there is little detailed argument about how the + element might be impacted in the context of rapidly changing adverse market conditions, the Report relying instead on historic averages.

3.6. Similarly, the calculation of Development Returns is estimated at between 15 to 20%, such range of figures being associated with a buoyant purchasing housing
market and taking no account of either the changes referred to at (5) or the additional statutory demands made by Government environmental commitments that are yet fully to feed into Development Costs.

3.7. Rutland already has ‘outlier’ status in terms of the number of ‘four bedroom plus’ houses, and in terms of under-occupancy, it has high average house prices in
total all partly as a product of the above planning/market distortions. However there is no indication of attempting to correct these figures related to expressed housing needs. This will be compounded by the estimates being suggestive of those existing market outlier size distortions being the most capable of meeting the expressed demands related to enhanced environmental and energy measures, which could reinforce those market distinctions/distortions, creating an even greater scarcity of affordable housing to both rent and buy within Rutland.

Object

Representation ID: 7068

Received: 08/01/2024

Respondent: Mr Roderick Morgan

The online form response is very unwieldy for offering input of a general nature, which touches on several policy areas.

• A proper strategy for Solar PV and onshore Wind renewable energy, that focuses on rooftop PV for domestic and commercial, small-scale community supported generation schemes on appropriate sites, and ensures community benefits and sustainability. I do not support industrial-scale commercial developments on productive farmland without local support, input and benefit, where there is no guarantee that the site will be reverted to natural or agricultural use after the lifespan of the project (e.g. 40 years).
• Would like to see provision for new paths, accessways, linking useful routes between settlements, focus on health giving 'commons'.
• Opportunity for a coherent system of cycle paths (scooters, ebikes), complementing footpaths
• No plan for a strategy for Onshore wind, particularly community wind schemes - just 'passive' planning responses to applications.
• No strategy for enhanced public transport and associated infrastructure - net zero transport is impossible with EVs alone
• Separation of agricultural traffic from general road traffic, minimising damage, mud and congestion.
• No plan for increasing tree cover, water and wetland habitats- i.e. natural carbon stores, increased flood resilience, nature corridors. Should be at least up to national averages and targets
• Biodiversity gain of 15% - from a very low level is meaningless. Need a target level, fitting with healthy local ecosystem
• Overall, the lack of specific dates, metrics and actions is striking, and indicates this is not a plan, in the sense of a set of outcomes that are deliverable.

The general sense is that Plan as it stands is contradictory and potentially self-defeating (as the development proposals illustrate). Partly this is due to very poor data and lack of local knowledge as a basis for sensible proposals.

Object

Representation ID: 7094

Received: 08/01/2024

Respondent: Frank Johnstone

I am in agreement with the CPRE response including: "Hard copies of the Plan should have been made available at least to each Parish so that a meaningful response to the document could be made. This would enable all members of the community to appraise themselves more readily of the content; not everyone has access to the internet or to a library. An executive summary should also have been made available."

I for one found it almost impossible to read, digest and understand a lot of the information contained in your Draft Plan on my small computer screen and any attempt to print the whole document on my small desktop printer would have taken an extremely long time, not to mention the high cost of the ink cartridges. Surely a full hard copy of your document could have been made available to each parish council in Rutland, which would then have been available to the general community as a whole

Object

Representation ID: 7111

Received: 08/01/2024

Respondent: Tim Maskell

The version of the Rutland Local Plan under review is a comprehensive and complex document and it is very difficult for an interested ‘amateur’ Rutland resident to read, fully understand and comment on all of its many detailed and diverse aspects and their implications. Realistically, therefore, my ability to make detailed comment is limited to those few parts of the Plan of which I have knowledge, experience or interest. This makes rational comment on the Local Plan as a whole difficult, if not impossible, with the added danger that aspects of a particular topic may be covered by more than one section of the plan without being adequately cross referenced and therefore be incorrectly interpreted or challenged by me.
Overtly the draft Rutland Local Plan is impressive.
But … nowhere in it did I see any reference to cost, and to what extent the ability to implement the Plan as a whole, or of sections within it, could be subject to limitations or variations in the assumed sources of available funding. This must question the ability of the RCC to deliver stated objectives.
There is no attempt to assess the risks involved in achieving the declared ambitions, nor to any contingency provisions. Nor of prioritising the deliverables.

Object

Representation ID: 7122

Received: 08/01/2024

Respondent: Mr Neil Tunstall

The “contact us” link which should open to an email form doesn’t seem to work, making it difficult to access how to comment.
I note several residents have put “support” on the website comments section and then their comments object to the specifics of the developments in the plan. This also seems to have caused confusion with the process.

Object

Representation ID: 7140

Received: 08/01/2024

Respondent: Alicia Kearns

The Local Plan will determine Rutland’s development and trajectory until 2041 and requires widespread community support if it is to be accepted and succeed. Given the size and complexity of the documents making up the Local Plan, any local engagement requires adequate time and access. Unfortunately, eight weeks over the festive period does not give residents a realistic opportunity to properly engage with and respond to the proposals.
The Council’s Statement of Community Involvement (April 2022) sets out how the Local Plan will consult and incorporate the views of the community. There is a list of recommended actions in Section 4, Table 1 to ensure this aim is met, including webinars, newsletters and summary pamphlets, meetings, workshops and focus groups, amongst others. Many of these do not appear to have been implemented in the consultation process.
Another round of consultation should be added after changes are made to the Local Plan from comments received as part of the Regulation 18 consultation and the update to the National Planning Policy Framework which was revised mid-way through this consultation.

Support

Representation ID: 7202

Received: 08/01/2024

Respondent: Mr David Lawson

I support the general direction of the plan, but am not sure how much is going to be possible to deliver.

Object

Representation ID: 7309

Received: 08/01/2024

Respondent: Ketton and Tinwell Joint Neighbourhood Plan Steering Group

The availability of documentation.
It is slightly disconcerting that information that appears to have been in documents at the beginning of the consultation period is no longer available. In the case of Ketton, a map that was available for the employment sites under policy EN 1 which was on the website at the start of the consultation process was not there on 8th January.

Another example of this is that originally the list of made neighbourhood plans on page 6 failed to include Ketton and Tinwell. It now does. Whilst we are grateful that this error has been rectified, overall these instances do not engender confidence in the permanence of the text of the Local Plan consultation.

The relationship between the Local Plan and Neighbourhood Plans
We are pleased to see that in respect of a number of important policies e.g. EN8 and EN 9, and CC 8, there is specific reference to additional requirements within neighbourhood plans that need to be taken into account. We feel that it would be appropriate for all policies as necessary to make this kind of reference (e.g. EN 7 on blue and green infrastructure) as well as having an overall clear explanation within the opening text of the plan about how the specific local requirements of neighbourhood plans will be addressed (as opposed to the current generalities about the existence of neighbourhood plans).

Sustainability
When so much development has been crammed into the larger villages over recent years, with Ketton being a particular example of this, it is encouraging that there is wording in the Spatial Strategy section that is far more reflective of the fact that larger villages are not necessarily more sustainable for development; they just have a few more than amenities than the very small villages. In particular, the existence of one very sporadic bus service has frequently has in the past been deemed, quite unrealistically in our view, to make a larger village an inherently sustainable location.

We welcome that the emphasis is that such development that comes forward in the larger villages in future will be small-scale. We hope this will truly be the case in future, as it has clearly not been so up until this point, with very large developments being forced into Ketton during recent years.

It would be helpful to for the Local Plan to be worded more strongly in this respect. This would help guard against unrealistic statements within developers’ proposals which imply that all that larger villages are, by definition, sustainable locations for more development.

We would also like to note, context of INF 1, that whilst provisions within this policy in themselves appear acceptable, this does not address the chronic under-provision of basic infrastructure in many villages for services such as water and sewerage. Whilst developers may be required to provide drainage/sewerage in the context of their own sites, we feel insufficient attention is still being paid to how that interacts with the overall water/sewerage infrastructure, and how the effect is exacerbated by the significant increase in development over recent years. We would welcome a clearer indication from the Local Authority that these issues and impacts, both cumulative as well as individual, will be addressed.

Flood risk
While the risk of flooding is referenced in a number of policies, the Strategic Flood Risk Assessment (SFRA) appears to us to be out of date for the areas to the South East of the county along the Welland Valley. The draft 2023 assessment available on the RCC web site is based on a 2009 SFRA with updates carried out using a desktop assessment process.

Given the increase in flooding over recent years from the Chater, Welland, Surface Water and Underground Springs we do not believe that the Local Plan is robust enough in this respect to ensure additional flood problems with new developments over the period covered by the new Local Plan will be addressed.

The draft SFRA also includes a list of reported flooding events over the period Jan 2018 to June 2023. While there are a number of entries from Ketton, these do not cover the full impact of the flood events over the period. The RCC website does not include a reporting mechanism for flooding.

Object

Representation ID: 7426

Received: 07/01/2024

Respondent: Cottesmore Parish Council

December 2023 NPPF has flagged up a number of potential changes to the planning system. These relate, for example, to the treatment of the 5 year land supply; bolstering protection from speculative development; greater reflection on local character; and respecting the ‘democratic voice of local communities’. It would seem inevitable that this may well necessitate yet more changes to the current draft, which are likely to require further community consultation.