Object

Representation ID: 7528

Received: 08/01/2024

Respondent: Bowbridge Land Ltd

Agent: DLP Planning Ltd

There is a significant mismatch between the SS1 employment land requirement of 27ha and the 40+ ha proposed in policy E1 the mismatch between these two figures that needs to be resolved.

There is a further mismatch between either of these figures and the much lower level of employment growth that would be supported by the minimum level of housing provision proposed in Policy SS1.
Policy SS1 should be amended to reflect the level of employment land being proposed in Policy E1 and the level of housing should be increased to that which will support the level of employment growth that is being pursued. At a minimum this should be at least 185 dwellings per annum (dpa).

Comments noted. The matter of housing need and requirement is considered in detail under Policy H1

Object

Representation ID: 7529

Received: 08/01/2024

Respondent: Bowbridge Land Ltd

Agent: DLP Planning Ltd

Given the risks with regard to the delivery of some of the larger proposed allocations (see below) and the significant mismatch of housing and the economic growth strategy of the plan it is considered that the part of Policy SS1 which includes the test of “exceptional circumstances” for proposals for housing development on greenfield sites adjoining the Planned Limits of Development should be removed and replaced with
“Proposals for housing development on greenfield sites adjoining the Planned Limits of Development of Oakham and Barleythorpe, Uppingham and the Larger Villages will only be released where it is demonstrated that they are needed to maintain a sufficient supply of deliverable and developable land.”.

Agree. Remove the last paragraph of Policy SS1b) to remove reference to "exceptional circumstances"

Object

Representation ID: 7541

Received: 08/01/2024

Respondent: House Builders Federation

Although HBF does not comment on individual sites or allocations, we believe that the Plan should provide for a wide range of deliverable and developable sites across
the Borough in order to provide competition and choice to ensure that housing needs are met in full. HBF would wish to see the Plan set out a logical settlement hierarchy
which meets all the housing needs and addresses all areas of the housing market, with a range of sites proposed for allocation.

The NPPF requires Local Plans to identify land to accommodate at least 10% of the housing requirement on sites no larger than one hectare, unless there are strong
reasons why this cannot be achieved.

HBF would therefore wish to see the 10% small sites allowance delivered through allocations (and not windfall). Such sites are important for encouraging the growth in
SME housebuilders who will tend to develop these sites but rarely see the benefits that arise from the allocation of sites in a local plan.

Although a policy that sets criteria to enable housing is smaller settlements is welcomed, HBF would support a Local Plan that included sites allocated sites in rural areas. HBF supports this being done through plan-making process in the Local Plan
which provides certainty in meeting rural housing needs.

The Plan needs to set out how and when monitoring will be undertaken, and more is needed on what action(s) will be taken when if monitoring shows under delivery of
housing.

The housing requirement is 123 per annum x 20 years plus 10% buffer = 2706. Of this total 193 have already been built leaving a requirement of 2513 dwellings.

The plan is to include a section on monitoring and what actions would be triggered if a lack of housing delivery was reported. Although Policy SS1 does provide this in the last paragraph of SS1b)

Object

Representation ID: 7542

Received: 08/01/2024

Respondent: Mr Roderick Morgan

The categories of Large and Small village are really problematic, as small villages will have no development boundary, critical for planning and managing quality enhancing sustainable development.

PLDs are not critical to managing development provided that a clear and appropriate policy framework is in place. Policy SS1 and SS4 together provide this for villages which are not identified with a PLD where the presumption will be that development is not acceptable unless it meets the tests set out in policy SS4.

Object

Representation ID: 7611

Received: 08/01/2024

Respondent: Paula Johnstone

I strongly object to the re-classification of the county into two categories, i.e. either a Large or a Small Village.
Moreover, the removal of Permitted Limits of Development (PLD) from the Smaller Village category is an error. The potential for uncontrolled growth of Small Villages rather than organic growth through infill should be avoided by the restoration of PLD as existing.

The removal of PLDs from the small village category actually provides these settlements with greater protection from inappropriate development as it removes the presumption in favour of development and placed these settlements within the countryside where development will only be acceptable if it meets the tests set out in policy SS4.

Object

Representation ID: 7651

Received: 08/01/2024

Respondent: Stancliffe Homes Ltd

Agent: DLP Planning Ltd

In full accordance with the PPG it is recommended that the housing requirement is increased to the average rate of 185 dpa. This is at the top of the range of demographically led projections in the HMA but falls significantly short of the level of housing needed to support the economic policy of the Reg18 plan and as such is likely to be required to be adjusted upwards.

Comments noted. The matter of housing need and requirement is considered in detail under Policy H1

Object

Representation ID: 7652

Received: 08/01/2024

Respondent: Stancliffe Homes Ltd

Agent: DLP Planning Ltd

There is a significant mismatch between the SS1 employment land requirement of 27ha and the 40+ ha proposed in policy E1 the mismatch between these two figures that needs to be resolved.

There is a further mismatch between either of these figures and the much lower level of employment growth that would be supported by the minimum level of housing provision proposed in Policy SS1.
Policy SS1 should be amended to reflect the level of employment land being proposed in Policy E1 and the level of housing should be increased to that which will support the level of employment growth that is being pursued. At a minimum this should be at least 185 dwellings per annum (dpa).

The housing requirement will be considered under policy H1

Object

Representation ID: 7654

Received: 08/01/2024

Respondent: Stancliffe Homes Ltd

Agent: DLP Planning Ltd

Given the risks with regard to the delivery of some of the larger proposed allocations (see below) and the significant mismatch of housing and the economic growth strategy of the plan it is considered that the part of Policy SS1 which includes the test of “exceptional circumstances” for proposals for housing development on greenfield sites adjoining the Planned Limits of Development should be removed and replaced with
“Proposals for housing development on greenfield sites adjoining the Planned Limits of Development of Oakham and Barleythorpe, Uppingham and the Larger Villages will only be released where it is demonstrated that they are needed to maintain a sufficient supply of deliverable and developable land.”.

Agree. Remove the last paragraph of Policy SS1b) to remove reference to "exceptional circumstances"

Support

Representation ID: 7738

Received: 08/01/2024

Respondent: Anglian Water

Anglian Water agrees that a hierarchy of settlements Policy (SS1) enables the Plan to focus development on the more sustainable locations. Increasingly development will towards the end of the Plan period need to deliver net zero (embodied and operational) carbon from day 1 to build in net carbon negative solutions from 2050 onwards. Looking at wastewater recycling centre (WRC) permitted dry weather flow (DWF) capacity Anglian Water suggests the most locations and quantum of development could be deliverable based on WRC permitted dry weather flow alone. (table provided).
Anglian Water suggest that in the second stage Water Cycle Study, the Council’s consultants consider the option of reprioritising the timing and/ or quantum of growth within the four WRC catchments where P-TAL may constrain growth. The revised option could include additional growth at north Stamford as the Stamford WRC is in Peterborough and serves Stamford in South Kesteven as well as small areas in Peterborough and Rutland. Stamford’s WRC is not a TAL site, and its dry weather flow indicates it could serve circa 9,200 additional homes.

Anglian Water’s Pre-Development team advise that growth at Stamford presents network capacity issues, in part due to the location of the WRC and pumping station. A technical solution though is feasible to address the water recycling network issues.
A further option would be additional growth in the Empingham WRC catchment including Edith Weston which has circa 1,550 homes capacity.

We will continue to work with Anglian Water through the IDP and future development of the evidence base to ensure development can be supported by infrastructure.

Object

Representation ID: 7830

Received: 07/01/2024

Respondent: CPRE Rutland

CPRE Rutland supports the focus on development within the Planned Limits of Development.
We also welcome the statement that delivery of 123 dwellings per annum being the minimum requirement for the whole of Rutland.
The proposal to allocate land for 123 dwellings per annum is inconsistent with Policy H1, where, it is made clear that the minimum requirement is for just 1347 houses (including a 10% buffer), which equates to just 75 per annum until 2041. The availability of reserve sites could provide the buffer but the 657 listed would amount to almost 50%, which is beyond excessive.

The possible development at St George's Barracks would add considerably to the total. Taken together with the proposals for the Officers' Mess site, would lead to significant imbalance in housing distribution around Edith Weston.
Will smaller villages not be permitted to expand? Perhaps one or two of them might have aspirations to become larger villages, particularly if they are already approaching the stated size threshold?
Larger villages often also have a church or other place of worship, which residents from other villages might wish to use – this should be included in the text (e.g. Page 61).

Comments noted - These issues are considered under Policy H1.

Object

Representation ID: 7847

Received: 08/01/2024

Respondent: Alicia Kearns

Where is the Spatial Strategy itself? It is currently missing and does not adequately address the use of land other than for development. If the current leadership sees the Local Plan as solely a development platform, crucial opportunities will be missed to improve Rutland as a place to live, work and enjoy leisure.

Additionally, the Local Plan needs to be more alive to our having two towns, and the strengths of investing in our villages.

The Spatial Strategy is clearly set out in policy SS1, setting out where both the scale of development expected during the plan period and the locations where the development should take place as well as those location where development is not considered appropriate. This identifies the need to support both of the towns in the County and supporting the vitality of villages of all sizes.

Object

Representation ID: 8000

Received: 08/01/2024

Respondent: Mr PJRS Hill and Pikerace Limited

Agent: Silver Fox Developments

The figure of 123 dpa is Rutland’s Local Housing Need figure calculated using the Standard Method. The PPG makes clear that the LHN is only a starting point. The Standard Method does not produce a housing requirement and there are instances where it may be appropriate for the housing requirement to be greater than the LHN.

The Standard Method does not predict the impact of future government policies, changing economic circumstances or other factors might have on demographic behaviour. Additionally, growth strategies that are likely to be deliverable, strategic infrastructure improvements and
requirements to accommodate unmet needs from neighbouring areas may also indicate a housing requirement greater than the minimum LHN figure.

Previous assessments of need and housing delivery have been significantly greater than suggested by the LHN and this provides a compelling reason for an upward adjustment to the housing requirement to 190 dwellings per annum, requiring an additional 3,800 dwellings in the plan period 2021-2041.

The Employment Land Review concludes that an employment land requirement of between 18.2ha and 34.9ha is appropriate and specifies 18.2ha as the
“absolute minimum.”

The emerging local plan has adopted as its employment land requirement a figure of 27ha, which is towards the upper end of the range specified within the ELR, and certainly quite considerably in excess of the absolute minimum. As a result, in order to ensure an integrated
approach between homes and jobs, the employment land requirement suggests that it is appropriate to plan for a higher housing

Comments Noted. The Housing requirement will be considered as part of Policy H1

Object

Representation ID: 8001

Received: 08/01/2024

Respondent: Mr PJRS Hill and Pikerace Limited

Agent: Silver Fox Developments

SS1 indicates that proposals for housing development on greenfield sites adjoining the planned limits for development of the main towns and larger villages will only be released in “exceptional circumstances,” where they are needed to maintain a sufficient supply of deliverable and developable land.

This element of Policy SS1 is plainly unsound for want of
consistency with national planning policy.
Sites outside of but adjoining built-up areas do not require anything approaching “exceptional circumstances” for release in circumstances of inadequate five-year housing land supply or inadequate housing delivery.

This limb of Policy SS1 should be reviewed accordingly and should adopt wording that conforms to national policy.

SS1 indicates that the majority of new development will be focused within the PLDs of Oakham and Uppingham. Cross referencing with the draft allocations identified at Policy H1, it is apparent that practically all of the
allocations and reserve sites identified at Oakham save for one are outside of the PLD and so the statement in Draft Policy SS1 is entirely inaccurate.

However, the LPA presently proposes allocations outside of the PLDs amply testify to the fact that there is plainly insufficient available, deliverable and suitable land within the existing PLD of Oakham to accommodate growth needs arising over the plan period. Axiomatically, the
fringes of Oakham will therefore play a key role in delivering the emerging local plan’s spatial strategy and this should be acknowledged within Draft Policy SS1.

Agree. Remove the last paragraph of Policy SS1b) to remove reference to "exceptional circumstances"

Object

Representation ID: 8025

Received: 08/01/2024

Respondent: Messrs J, P & P Turner; Scott & Scott (Ayston) Limited; Peterborough Diocesan Board of Finance

Agent: Silver Fox Developments

Policy SS1 makes provision for at least 123 dwellings per annum (dpa) over the plan period from 2021 to 2041 calculated using the Standard Method to calculate Local Housing Need (LHN); and about 27ha for new employment generating uses over the same period.

The Standard Method does not predict the impact of future government policies, changing economic circumstances or other factors might have on demographic behaviour.

In the context of this Site, it is also importantly noted that paragraph 67 of the NPPF includes a new statement that “The requirement may be higher than the identified housing need if, for example , it includes provision for neighbouring areas, or reflects growth ambitions linked to economic development or infrastructure investment”

Previous assessments of need and housing delivery have been significantly greater than suggested by the LHN and this provides a compelling reason for an upward adjustment to the housing trajectory to 190 dwellings per annum, requiring an additional 3,800 dwellings in the plan period 2021-2041.

The emerging local plan has adopted as its employment land requirement a figure of 27ha, which is quite considerably in excess of the absolute minimum.

In order to ensure an integrated approach between homes and jobs, the employment land requirement suggests that it is appropriate to plan for a higher housing requirement.

Housing and employment land need will be considered separately under policies H1 and E1

Support

Representation ID: 8043

Received: 08/01/2024

Respondent: Ketton and Tinwell Joint Neighbourhood Plan Steering Group

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.

Support noted