Object

Representation ID: 7427

Received: 07/01/2024

Respondent: Cottesmore Parish Council

The Parish Council Objects to the lack of Community engagement during the preparation of the Local Plan; considers the consultation process has been made very difficult and cumbersome for residents to engage with; and the Interactive Map is far too complicated and we think many people will give up trying to understand it. Given the bulk of the documents and the complexity of the content, the lack of reasonable access to hard copy paper plans is not acceptable; neither is the total reluctance seemingly to even entertain the very reasonable suggestion, promoted by many parts of the community, that the consultation period should be extended to the end of January 2024.

Comments noted. Under the Town and Country Planning (Local Planning (England) Regulations 2012, the statutory consultation period for Regulation 18 is six weeks. The Council chose to extend this by two weeks to a total of eight weeks to allow for the festive period. The consultation followed the requirements set out in the Council's Statement of Community Involvement (SCI). The experience of the Issues and Options consultation and the Call for Sites exercise has been that local councils and the general public have generally responded well to the online platforms without the need for paper hard copies. A short video guide on use of the online consultation was also created to assist users navigate the system. Nonetheless, in recognition that not all members of the community may be able to access these resources, paper copies were made available at the Council offices and all public libraries. A paper copy was available on request at cost price. The Local Plan chapters were available to read or download from the Council website without needing to access the consultation portal. We also accepted representations by email and post for those who were unable to access or navigate the online consultation system.

Object

Representation ID: 7475

Received: 08/01/2024

Respondent: Preston Parish Meeting

Firstly, as a local Village meeting, we lack the resources and expertise to fully evaluate this complex document. The structure and style of writing makes the document virtually impossible for a lay person to assimilate and fully understand what is proposed.

Comments noted. The Local Plan must deliver a significant level of detail and understand that some of this can be complex. Every effort has been made within the structure of the plan to explain the purpose of the policies proposed.

Support

Representation ID: 7632

Received: 08/01/2024

Respondent: Environment Agency

Overall, we support this update of the Local Plan. However we did find the Plan was difficult to navigate online, as it was separated into individual sections rather than being a single PDF. Therefore, you could not carry out a search to find a particular item within the overall Local Plan.

Support noted.

Object

Representation ID: 7635

Received: 08/01/2024

Respondent: Peter Vickers

The online response form is an absolute nightmare, and looks a like a great attempt to make it impossible for us to comment. Please ask any passing teenager about user-friendly online feedback tools.

Comments noted. The experience of the Issues and Options consultation and the Call for Sites exercise has been that local councils and the general public have generally responded well to the online platforms without the need for paper hard copies. A short video guide on use of the online consultation was also created to assist users navigate the system. Nonetheless, in recognition that not all members of the community may be able to access these resources, paper copies were made available at the Council offices and all public libraries and the Local Plan chapters were available to read or download from the Council website without needing to access the consultation portal. We also accepted representations by email and post for those who were unable to access or navigate the online consultation system.

Object

Representation ID: 7636

Received: 08/01/2024

Respondent: Peter Vickers

I'm afraid the plan, and its rushed timetable, will expose the council to frequent and possibly justified litigation and delay tactics from
- planning law specialists (lack of process)
- construction companies (over-demanding and uneconomic environmental requirements)
- homeowners (unreasonable and costly changes to older houses to meet environmental requirements)
The plan is a work in progress. It is thin on detail, and
absolutely lacking information about criteria for success, execution, timelines, budget, risk analysis, and performance measurement.
I do not accept that it needs to be rushed though in this way. If the council has run out of time, that is either the fault of the councillors, who should own up, or the CEO of the RCC

Comments noted. The Reg 18 Plan sets out the preferred options for growth, supported by evidence, as part of the Local Plan making process. The Plan policies are based on robust evidence and are clearly structured. They link to the Local Plan Vision and Objectives set out in Chapter 3 and address the issues identified by residents as being important. Indicative timescales for the progression of the Plan are given and it is made clear that the Plan will cover the period to 2041. Whilst the Plan has sought to ensure that delivery of allocated sites will take place during the Plan period, monitoring (‘performance management’) will take place and an Authority Monitoring Report is produced. Under the Local Plan Regulations, the statutory consultation period for the Reg 18 Plan is six weeks. The Council chose to extend this by two weeks to a total of eight weeks to allow for the festive period and this began well in advance of the festive season on 13th November. The consultation followed the requirements set out in the Council's Statement of Community Involvement (SCI).

Object

Representation ID: 7688

Received: 05/01/2024

Respondent: De Merke Estates

Agent: Stantec

Details comments made about the Housing Site Assessment Report conclusions in respect of the site called “Land at North West Oakham” (previously known as “The Lookout” via a recent Outline Application and then withdrawn S78 Appeal) which concludes the site is deliverable but unsuitable for allocation.

We therefore consider the Council has not adequately or accurately considered the suitability of the Site to accommodate the development options that we have put forward. Further consideration should be given to what would be appropriate on the Site, including whether a distinct area of it (ie. eastern parcels) could be suitable, plus whether any further services/facilities could be provided for in addition to simply housing.

Comments noted. Representation covered under 7687 for Policy H1.

Object

Representation ID: 7709

Received: 08/01/2024

Respondent: Vistry Group c/o Pegasus Group

Agent: Pegasus group

the draft policies set out in the Preferred Options consultation document are considered to be too detailed, in some cases unclear and with a significant amount of unnecessary repetition of both national policy and between the draft local plan policies themselves. The policies need to be simplified and consolidated to ensure the aims of the policies are clear to applicants and the decision makers. It would be useful to undertake a benchmarking exercise with other local authorities to help highlight how policies can be made more focused and concise to support the objectives of the plan.
An example is the ecology policies. There are three ecology policies proposed (EN1, 2, & 3) when it is possible to cover the same range of issues in a single more concise policy. There is further overlap with Policy EN7.

Comments noted. Where specific policies are highlighted in the representation this will be covered under the policy. Following the Reg 18 Plan consultation process detailed scrutiny of the wording of the policies will take place and any repetition between them, or where repetition of national guidance is noted, amendments will be made prior to the publication of the Reg 19 Plan. Regarding the Environment policies: EN1 is a standalone policy covering the protection of sites, habitats and species whereas EN2 and EN3 deal specifically with the Local Nature Recovery Strategy and biodiversity net gain. Biodiversity net gain is a relatively complex issue and so it is appropriate to have a single policy dealing with it. Policy EN7 is based on the evidence set out in the GBI Study (2023) however it has been reviewed alongside policy SC7 to ensure consistency and avoid repetition.

Object

Representation ID: 7768

Received: 08/01/2024

Respondent: McCarthy Stone

Agent: The Planning Bureau Limited

Our assessment of the viability of older persons housing identifies a number of characteristics of older persons housing that add additional cost to the typology that have not been included within the Viability Assessment. It is our view that the older persons housing typology should be re-run using all characteristics and if older persons housing is found to not to be viable to deliver 30% affordable housing the policy should be amended to reflect the outcome. This would accord with the typology approach detailed in Paragraph: 004 (Reference ID: 10-004-20190509) of the PPG on viability which states that. “A typology approach is a process plan makers can follow to ensure that they are creating realistic, deliverable policies based on the type of sites that are likely to come forward for development over the plan period.” If this is not done, the delivery of much needed specialised housing for older people may be significantly delayed with protracted discussion about other policy areas such as affordable housing policy requirements which are wholly inappropriate when considering such housing need.

Comments noted. It is important that the Council puts forward deliverable policies in this plan that enable viable development to take place and further work to update the cost evidence for a number of options for the wording of the housing policies will be undertaken to inform the next stage of the Local Plan. This will build on the Whole Plan Viability Assessment (2023). Any changes to the draft policies arising from consultation responses and/or new evidence on housing will be consulted on through the Reg 19 consultation.

Object

Representation ID: 7771

Received: 08/01/2024

Respondent: McCarthy Stone

Agent: The Planning Bureau Limited

Viability Assessment

The Preferred Options is supported by a Biodiversity Assessment, Johns Associates, May 2023 (Biodiversity Assessment). The non-technical biodiversity report, supporting the Biodiversity Assessment at page 21 para 5.2.3 recommends a BNG policy which suggests a minimum of 10% is used rather than 15% detailed in policy EN3. In addition, the Preferred Options is supported by the Rutland County Council Whole Plan Viability Assessment, August 2023, HDH (Viability Assessment). The Viability Assessment makes an assumption of BNG costs taken from a DEFRA biodiversity net gain impact assessment as well as research undertaken by Kent County Council in 2022. The Viability Assessment at para 8.74 states that ‘The Council has not undertaken specific research into the costs in this regard and there are no published England wide data in this regard. Research by Kent County Council has indicated that the additional cost of providing 15% or 20% BNG is relatively modest where it can be delivered on-site’. However, the Council should note that on 27th July 2023 the price of statutory biodiversity credits were published (available from: Statutory biodiversity credit prices - GOV.UK (www.gov.uk)). This has enabled it to be determined how much BNG may cost and it is considered that the costs per dwelling put forward within the Viability Assessment have greatly underestimated the costs, with brownfield site BNG costs often being more substantial than Greenfield but this very much depends on the site characteristics. As a result of credit prices having been published, the Council should re-run the Viability Assessment that includes a more realistic assessment of BNG costs and reduce the BNG requirement accordingly.

Comments noted. It is important that the Council puts forward deliverable policies in this plan that enable viable development to take place and further work to update the cost evidence for a number of options for the wording of the BNG policy will be undertaken to inform the next stage of the Local Plan. This will build on the Whole Plan Viability Assessment (2023). Any changes to the draft policies arising from consultation responses and/or new evidence on BNG will be consulted on through the Reg 19 consultation.

Object

Representation ID: 7833

Received: 08/01/2024

Respondent: Alicia Kearns

It is also pertinent to note that there is no requirement to submit a Local Plan under the old system or under the timeline the County Council is proposing. Our current Local Plan sets out planning policies until 2026. There is no requirement for Rutland County Council to submit its plan before 30th June 2025 as set out in an email from Government Ministers which stated: “There is no requirement that all local authorities must submit a new local plan before Summer 2025.”
Councils who are close to completing their Local Plans are permitted to submit under the old rules, with those at the Regulation 18 first-stage of their Local Plan consultation required to adopt the new rules. The Council has provided no justification for the decision to proceed under the old rules.
Also for clarity, the duty to cooperate has been abolished by the Levelling Up and Regeneration Act.

Comments noted. The Government had indicated that it will intervene in the short term where councils have failed to put an up -to- date Local Plan in place and has set a deadline of 30th June 2025 for the submission of the plan. Whilst the council is not compelled to submit a plan by this date, not doing so would mean that the council lacks the policies to prevent inappropriate or damaging development. The council is confident that it can meet the deadline for submitting the plan to the Secretary of State in early January 2025 thereby meaning that it will not have to wait until the guidance on the style of the new local plans are published (potentially later in 2024). With regards to Duty to co-operate, this will remain in place until the flexible alignment policy takes effect as part of a future revised NPPF.
Noted that there is currently consultation of further changes to the NPPF which may need to be considered through the examination process.

Object

Representation ID: 7834

Received: 08/01/2024

Respondent: Alicia Kearns

The NPPF was revised in December 2023 to include changes brought by the Levelling-up and Regeneration Bill. It is likely that Rutland’s Local Plan will require changes to accommodate the NPPF revisions. Time should be taken to ensure the Local Plan aligns with the NPPF and for any necessary revisions to the current draft Plan to be made.

The changes to the NPPF are positive and designed to give communities more control over their areas. The Council should view the changes as an opportunity to enhance Rutland’s Local Plan rather than as an obstacle to the current draft’s adoption.
There are instances in the proposed Local Plan that contradict agreed policies and land allocations in existing or developing Neighbourhood Plans. The new NPPF guidelines are clear that Neighbourhood Plans cannot be overridden by Local Plans. RCC must revisit the proposed Local Plan to ensure it fully incorporates both existing and developmental Neighbourhood Plans.

Comments noted. It is not unusual for changes to be made to Government guidance during the Local Plan process. Consultation on the revised Reg 19 Plan will incorporate the updates to the NPPF made in December 2023.
It should be noted that the government is currently consulting on further changes to the NPPF and therefore transition arrangements may be relevant to this Local Plan.

Object

Representation ID: 7850

Received: 08/01/2024

Respondent: Alicia Kearns

It is vital that Rutland County Council adopt a Local Plan which has a vision for our uniquely wonderful community – this does not do this. We need a plan that ensures development within Rutland is undertaken in a regulated, proportionate, and sustainable manner.
It is frustrating that the current draft of the Local Plan is overly focused on housing development, rather than presenting a positive and holistic vision for Rutland’s future. The Local Plan should focus on place, people, space, and community, rather than acting as a simple designating authority for where houses are to be built.
Finally, care should be taken to ensure that the commendable sentiments and aims within the Plan are matched by practical policies and clear criteria for development. Parts of the plan are currently too vague and need to be strengthened to ensure objective clarity in future planning decisions absent from subjective interpretation.

Comments noted. The Future Rutland Vision is described in some detail in Chapter 3 and there it is appropriately tied into the overall vision for the Local Plan. The Local Plan is not overly focused on housing development but must, in accordance with Government guidance, allocate sufficient land to meet the minimum housing needs of the county. As the vision and objectives for the Local Plan in Chapter 3 detail, the document takes into account the uniqueness and quality of life that residents enjoy beyond just allocating land for housing. The policies are based on robust evidence and are clearly structured. They link to the Local Plan Vision and Objectives set out in Chapter 3 and address the issues identified by residents as being important.

Object

Representation ID: 7975

Received: 08/01/2024

Respondent: Ms Tracey Lawson

Where does the plan provide for affordable housing?

Why doesn't Public transport feature anywhere in the plan?

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

Support noted. The criteria for providing affordable housing is set out in Policy H7. Public transport is covered under Policy INF2. The deliverability of the Local Plan, particularly in relation to allocated housing and employment sites, was a key part of the site selection process. The deliverability and effectiveness of the policies will be monitored with the council required to produce an Authority Monitoring Report (AMR) which monitors the timetable and progress of the preparation of the Local Plan and the effectiveness of policies using a number of monitoring indicators.

Object

Representation ID: 7990

Received: 03/01/2024

Respondent: R S Hurwood

Energy
I can’t see mention of the proposed solar farm at Woolfox: where is mention of this in the document?

Crime and Policing
Where is mention of this in the document?

I can’t find speech bubbles to talk about health: where are the 4 GP surgeries? Is the medical centre at Kendrew Barracks included? What is the future for Oakham Hospital? What about the proposed MRI scanner?

Comments noted. Health: The Local Plan must include the appropriate provision of infrastructure, including health facilities, to support growth. A detailed Infrastructure Delivery Plan will be published alongside the Reg 19 consultation plan which will set out the detailed infrastructure needed to support development. It is not the role of the Local Plan to consider details of health provision such as proposed medical scanners. Agricultural land: The best and most versatile land for food production is protected under Policy EN6. Solar Farm at Woolfox: Current proposals that may be in the planning application system would not be included in the Local Plan as such information can quickly become out of date. Crime and policing: Policy SC3 includes design criteria to ensure that new development provides a safe environment. Levels of policing would normally fall outside the remit of the Local Plan.