Object

Representation ID: 8222

Received: 29/11/2024

Respondent: McCarthy Stone (MS) and Churchill Living (CL)

Agent: The Planning Bureau Limited

Legally compliant? No

Sound? No

Duty to co-operate? Yes

The current assessment does not accurately model the unique characteristics and costs associated with older persons housing, leading to misleading conclusions about its viability. Important variables such as typical scheme size, longer sales periods, higher empty property costs, and increased marketing and professional fees have not been adequately considered. The council's interpretation of the National Planning Policy Guidance (NPPG) is criticised for suggesting that the viability of older persons housing should only be assessed at the development management stage, contrary to the guidance's intent.

Support

Representation ID: 8291

Received: 02/12/2024

Respondent: Stancliffe Homes Ltd

Agent: DLP Planning Ltd

We support the wording of Policy H7 as currently drafted. However, we stress the importance of addressing the ability to ensure delivery of affordable housing throughout the Local Plan area.

As outlined the Local Plan Foreword, Rutland suffers with issues of affordability due to its high proportion of large houses. The recognition of this policy failure as a result of multiple issues, should be addressed in the emerging Local Plan. An increase in the total housing requirement may need to be considered where it could help to deliver the required number of affordable homes, and so this Plan should increase its housing
requirement.

Object

Representation ID: 8362

Received: 02/12/2024

Respondent: Bowbridge Land Ltd

Agent: Pegasus group

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The policy duplicates policy within the NPPF and PPG with respect to viability assessments and therefore these elements should be removed.

Criterion d) outlines that affordable housing must

“achieve a minimum of 25% of all affordable homes secured through developer contributions as First Homes (with the exception of Oakham and Barleythorpe whilst they are covered by their Neighbourhood Development Plan which was 'made' on 24 June 2022), unless a contrary approach is justified by the relevant paragraph of the NPPF”

There is no justification provided for this exception.

Object

Representation ID: 8382

Received: 02/12/2024

Respondent: NHS Property Services

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

NHSPS support the principle of affordable housing provision, but we further recommend that as part of implementing Policy H7, the Council consider the need for affordable housing for NHS staff and those employed by other health and care providers in the local authority area.

Object

Representation ID: 8422

Received: 02/12/2024

Respondent: Maureen Thomas

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

For it to be effective regarding "affordable homes" RCC must insist or enforce developers to build upwards in character with historic 3 storey houses which can be easily split into flats and apartments.

Object

Representation ID: 8446

Received: 02/12/2024

Respondent: House Builders Federation

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy H7 is not considered to be sound as it is not justified, not effective and not consistent with national policy for the following reasons:

This policy states that all major residential developments comprising 10 or more dwellings will be required to make provision for a minimum of 30% of the schemes total capacity as affordable housing. It goes on to state that in the designated rural areas, developments of between 6 and 9 dwellings inclusive will also be required to make affordable housing provision for a minimum of 30% of the scheme’s total capacity.

54. The Housing Market Assessment (August 2023) identifies an affordable housing need of 78dpa. The Whole Plan Viability Assessment identifies the viability challenges in Rutland. Table 12.4a identifies the viability challenges in Oakham, Uppingham and wider Rutland, particularly for brownfield sites and large greenfield sites. Viability is an important consideration when setting affordable housing policies, as set out in the NPPF , and it is important that such policies should not undermine the deliverability of the Plan. The HBF has set out its concerns in relation to Viability and the Viability Assessment later in this response.

55. The HBF notes that the policy states that the 30% affordable housing requirement applies to Use Class C2 supported housing where these meet the Council Tax definition of a dwelling. The HBF notes that the Viability Assessment states that Extra Care Housing has capacity to bear affordable housing, however, this is unlikely to be at policy compliant levels.

Object

Representation ID: 8531

Received: 02/12/2024

Respondent: The Society of Merchant Venturers

Agent: Savills

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The overall approach to requiring provision of affordable housing on major housing developments aligns with the provisions of the NPPF (2023) and will help to support wider housing needs. Given that affordable housing needs are likely to change over the course of the Plan period and across the borough, it will be important that affordable housing is provided to meet local needs at the time of development coming forward and taking into account site-specific circumstances.

However, it is important the policy is not prescriptive and includes flexibility to ensure other new tenures can be included (e.g. in the event First Homes are replaced or new tenures are introduced). It is acknowledged that the policy makes reference to ‘unless a contrary approach is justified by the relevant paragraph of the NPPF’. It is however recommended that a minor amendment is made to refer broadly to national planning policy.

The wording of the policy is however unclear with reference to ‘affordable housing must…’ and then ‘…affordable housing will normally be…’. Given that affordable housing needs are likely to change over the course of the Plan period and across the borough, it will be important that affordable housing is provided to meet local needs at the time of development
coming forward and taking into account site-specific circumstances. It is that therefore recommended that reference to a specific tenure mix is deleted.

Object

Representation ID: 8645

Received: 01/12/2024

Respondent: CPRE Rutland

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

If it should be agreed that a commuted sum in lieu of onsite provision should be made, how will the Council ensure that this sum is then spent on providing the requisite affordable homes?

Confusion remains under the heading 'Why is this policy needed', including definitions of affordable housing and whether there is capacity to meet this need.

Object

Representation ID: 8703

Received: 02/12/2024

Respondent: Defence Infrastructure Organisation (DIO)

Number of people: 2

Agent: Montagu Evans on behalf of Secretary of State for Defence

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The DIO support the inclusion of detailed wording in respect of site-specific viability, in line with national guidance. However, given the continued and
evolving need for Service Family Accommodation in the County provision should be made for this, without the need for a viability assessment to avoid the affordable housing requirement.