Object
Regulation 18 draft Local Plan
Representation ID: 7418
Received: 08/01/2024
Respondent: Mrs Nicola Vickers
I welcome the reduced number of houses planned for the SGB. I don't understand why Edith Weston also gets additional sites for future housing way in excess of the needs of the county as a whole - does the rest of the county get a free ride?
All site appraisals have been reviewed in the light of comments and further evidence received to determine their suitability for allocation.
Support
Regulation 18 draft Local Plan
Representation ID: 7423
Received: 05/01/2024
Respondent: Mr Andrew Sheriff
Agent: Silver Fox Developments
Approach to Reserve Sites is supported and will allow some flexibility for sites assessed as acceptable in principle to come forward for development if required in due course.
However, if the Council accepted that there should be an increase in the LHN requirement to 190 as suggested elsewhere, we suggest that the presently proposed Reserved Sites, together with this additional site (at Glebe Road, North Luffenham) could become allocations in their own right (i.e. no longer Reserve Sites) under Policy H1 with the site adjoining, given the principle of development having already been established.
Support noted.
Object
Regulation 18 draft Local Plan
Representation ID: 7424
Received: 05/01/2024
Respondent: Mr Andrew Sheriff
Agent: Silver Fox Developments
Additional site is suggested for allocation adjacent to the reserve site proposed at land South of Glebe Road, North Luffenham. We demonstrate through these representations that the Site is acceptable in principle for small-scale development (4 dwellings) and suitable, available, and achievable. It can be delivered without delay. There are no technical or other constraints to preclude the allocation of the Site as proposed. Accordingly, it should be allocated as a Reserve Site in the RLP as proposed or as a housing allocation in its own right together with the land adjoining it to the east, albeit they are two distinct development sites. Both sites are well related to the existing character and form of the North Luffenham would form a logical rounding-off in this part of the form of the village.
All site appraisals have been reviewed in the light of comments and further evidence received to determine their suitability for allocation.
Object
Regulation 18 draft Local Plan
Representation ID: 7425
Received: 05/01/2024
Respondent: Mr Andrew Sheriff
Agent: Silver Fox Developments
A number of the sites relied upon as either allocations or reserve have not been assessed fully or appropriately. Some appear to be undeliverable while others will struggle to come forward appropriately for the scale of development envisaged without generating material harm.
Details of these issues are provided in the full submission
All site appraisals have been reviewed in the light of comments and further evidence received to determine their suitability for allocation.
Object
Regulation 18 draft Local Plan
Representation ID: 7428
Received: 07/01/2024
Respondent: Cottesmore Parish Council
The whole way that the site allocation has been done in preparation for the Reg.18 Plan is thrown into stark relief by the relationship to parishes in the allocation of sites for development. It is quite correct when RCC states that Neighbourhood Plans ‘cannot propose less development than that allocated in the Local Plan with which it has to conform’. However, what seems to be conveniently forgotten is the right for local communities to influence the location of new development through the mechanisms of the Neighbourhood Plan. By identifying sites without any direct engagement with local communities, it is in effect short-circuiting an important element of the whole underlying rational behind establishing Neighbourhood Plans in the first place.
All site appraisals have been reviewed in the light of comments and further evidence received to determine their suitability for allocation.
Object
Regulation 18 draft Local Plan
Representation ID: 7438
Received: 07/01/2024
Respondent: Cottesmore Parish Council
As we stated earlier, neither the residents of Cottesmore or the CPC are NIMBY. We accept our role in the settlement hierarchy and that this will include some development. However we have comments on all the specific site proposals in the parish, both those included and excluded.
Our starting point is that we are of the opinion that there has not been a sufficiently rigorous or consistent approach to the assessment of the suitability of the sites for inclusion in the Plan or otherwise, following the Call for sites consultation. We had offered, as have many parishes, to engage with this process in advance of the preparation and publication of the Reg.18 Local Plan – an example we thought of good community engagement. CPC has considered your appraisal and outcomes for the individual sites. We think it important to address and respond on all of them, not just those selected for the Reg.18 Plan, as it is important for CPC to provide our views on all of them, including making RCC aware of where we appear to be in agreement.
All site appraisals have been reviewed in the light of comments and further evidence received to determine their suitability for allocation.
Object
Regulation 18 draft Local Plan
Representation ID: 7440
Received: 07/01/2024
Respondent: Cottesmore Parish Council
CPC have made comments on all call for site sites and conclude the following:
COT 01 (H1.8) - Object (see detailed objection)
COT03 - Object to exclusion consider site is suitable for allocation
COT04 - agree with site assessment conclusion not suitable
COT05 - agree with site assessment conclusion not suitable
COT07 - agree with site assessment conclusion not suitable
COT12 - Agree outside PLD therefore not suitable
COT 13 and COT 15 (H1a) - object - see detailed objection
COT 14 (H1.5) Object site unsuitable for residential use (see detailed objection)
All site appraisals have been reviewed in the light of comments and further evidence received to determine their suitability for allocation.
Object
Regulation 18 draft Local Plan
Representation ID: 7445
Received: 07/01/2024
Respondent: Cottesmore Parish Council
Reserve sites
in our opinion this element of Policy H1 is unworkable, as well as creating untold issues for the residents close to the site with effectively ‘planning blight’ in place for many years to come. a Local Plan should be about creating certainty and clarity about future decisions within its orbit – this policy does the reverse in effectively holding a potential (but not certain) threat of development over many years. By putting these sites in the plan, albeit on a notional reserve list, it will give land owners and developers the important and clear message that the principle of development has been established – it is just a matter of timing. They won’t wait – why should they? Even if they do wait, the blight is still there. Furthermore, RCC correctly has not identified sites for the full plan period – identifying 1,347 units out of the total plan requirement of 2,706 (Table 4). Therefore it will be difficult to argue against a site, identified as meeting the in- principal test, being refused on grounds of prematurity.
The approach should be to exclude reserve sites and await the first review of the Plan.
All site appraisals have been reviewed in the light of comments and further evidence received to determine their suitability for allocation.
Object
Regulation 18 draft Local Plan
Representation ID: 7465
Received: 08/01/2024
Respondent: Clipsham Parish Meeting
The fact that no provision for any development at St George’s Barracks during the plan period to 2041 has been allowed for in table 4 provides misleading and unrealistic information. Therefore, there would seem to be a strong likelihood that the site allocations for Oakham, Uppingham and the larger villages are too many and that reductions should be made to allow for a carefully assessed small development at SGB. All of the reserve sites should be excluded from the Plan.
All site appraisals have been reviewed in the light of comments and further evidence received to determine their suitability for allocation.
Object
Regulation 18 draft Local Plan
Representation ID: 7489
Received: 08/01/2024
Respondent: Mr James Preston
I object to both the quantum and spatial distribution of the housing allocations. The draft Plan has no evidence for the proposed spatial distribution which, in the past, has been summarised as a ratio of 70:30 as between the towns and villages. After allowing for 650 units at Quarry Farm, Stamford, the draft Plan distribution is 75:25 between the towns and villages although smaller Uppingham will be providing the lion’s share at 44%. However, the 25% allocated for the Larger Villages (LSC) is not properly distributed with nearly half the entire LSC allocation for 7 villages being applied to just Edith Weston.
In calculating a provision of 3,934 dwellings versus need at 2,460, a 10% buffer was used. Under the previous version of the NPPF, all local planning authorities were required to build a buffer of 5% or 10% into their calculations on five-year housing land supply. That requirement has now been dropped from the Framework.In addition to a 10% buffer, the need was increased by 27% to allow for ‘reserve sites’. Most comparable authorities use either reserve sites or a buffer and generally allow 20% of need for reserve sites. However, this draft Plan uses both. Finally, a further 20% of need was added as the SGB ‘Opportunity Area’ giving a total of a 47% of need increase and thus reaching the number of 3,934 or over-provision of 1,474 dwellings.
All site appraisals have been reviewed in the light of comments and further evidence received to determine their suitability for allocation.
Object
Regulation 18 draft Local Plan
Representation ID: 7515
Received: 08/01/2024
Respondent: Wing Parish Council
The list of sites proposed for development in larger villages should include the preferred site for development in Wing, as detailed in the Wing Neighbourhood Plan, which will shortly to subject to referendum.as per comment re
SS1
All site appraisals have been reviewed in the light of comments and further evidence received to determine their suitability for allocation.
Object
Regulation 18 draft Local Plan
Representation ID: 7531
Received: 08/01/2024
Respondent: Bowbridge Land Ltd
Agent: DLP Planning Ltd
The overall level of allocations is almost an exact match to the minimum level housing provision advised by the Standard Method 2706 (123 x 20 plus 10%). Evidence provided on past rates of completions and the impact of the Council’s economic strategy the level of housing to be planned for should be substantially above the minimum requirement.
The total level of housing to be planned for should be amended as follows, taking into account the recommended extended time period above:
a) 185 dpa x 23 (to take the plan to 2043) plus 10%.
b) a total to be allocated of 4,680 dwellings (203dpa)
The Plan does not contain a trajectory to demonstrate that the allocations will deliver in a timely manner to meet the level of housing required to support the council’s economic strategy.
All site appraisals have been reviewed in the light of comments and further evidence received to determine their suitability for allocation.
Object
Regulation 18 draft Local Plan
Representation ID: 7532
Received: 08/01/2024
Respondent: Bowbridge Land Ltd
Agent: DLP Planning Ltd
The site at Main Road, Barleythorpe site has not been considered in the context of the Local Plan.
Taking into account the need for additional dwellings and the desirability of locating them close to the main employment centre it is proposed that a part of this site be considered for residential development - of a reduced size from that considered at the appeal.
The development of suitable parts of this site could accommodate some 50 – 75 dwellings and would protect a perceived gap between Oakham and Barleythorpe; while it would still have an impact on the intrinsic character of the countryside this impact would be little different from those other greenfield sites being promoted for development, such impact being substantially outweighed by the sustainability of the location in close proximity to the principal areas of employment, public transport and town centre facilities offered by Oakham.
The appeal Inspectors conclusions on the impact of the development of the site are insufficient to exclude the site from consideration given the need to identify additional land in this location.(APP/A2470/W/22/3312763)
All site appraisals have been reviewed in the light of comments and further evidence received to determine their suitability for allocation.
Object
Regulation 18 draft Local Plan
Representation ID: 7544
Received: 08/01/2024
Respondent: House Builders Federation
The standard method LHN should be the minimum starting point for establishing the housing requirement and the Council should then considers if there are issues that result in the need for a higher housing requirement, including the need to provide a range and choice of sites, the need for flexibility, viability considerations and whether higher levels of open-market housing are required in order to secure increased delivery of affordable housing.
HBF suggests that Council should consider if these factors, individually and/or cumulatively result in the need for a higher housing requirement for Rutland, and a subsequent need for additional allocations.
HBF note that the consultation acknowledges that
“some or all of the reserve sites may still need to be allocated in the final version of the plan if the minimum housing need increases or if any of the preferred sites
become unavailable or undeliverable. HBF suggest reserve sites should be allocated so they that can be easily and quickly brought forward to address any under-delivery of housing supply.
HBF believe that the Plan should provide for a wide range of deliverable and developable sites, including a buffer and small site allocations across Rutland in
order to provide competition and choice to ensure that housing needs are met in full.
All site appraisals have been reviewed in the light of comments and further evidence received to determine their suitability for allocation.
Object
Regulation 18 draft Local Plan
Representation ID: 7656
Received: 08/01/2024
Respondent: Stancliffe Homes Ltd
Agent: DLP Planning Ltd
The overall level of allocations is almost an exact match to the minimum level housing provision advised by the Standard Method 2706 (123 x 20 plus 10%). Evidence provided on past rates of completions and the impact of the Council’s economic strategy the level of housing to be planned for should be substantially above the minimum requirement.
The total level of housing to be planned for should be amended as follows, taking into account the recommended extended time period above:
a) 185 dpa x 23 (to take the plan to 2043) plus 10%.
b) a total to be allocated of 4,680 dwellings (203dpa)
The Plan does not contain a trajectory to demonstrate that the allocations will deliver in a timely manner to meet the level of housing required to support the council’s economic strategy.
All site appraisals have been reviewed in the light of comments and further evidence received to determine their suitability for allocation.
Object
Regulation 18 draft Local Plan
Representation ID: 7658
Received: 08/01/2024
Respondent: Stancliffe Homes Ltd
Agent: DLP Planning Ltd
The failure to consider suitable alternative sites in the background evidence: College Close, Great Casterton
This site is currently subject to a planning application that has recently been refused. The reasons for refusal are not particularly relevant to the consideration of the site for allocation to meet the level of housing required to meet the Council’s economy strategy.
Great Casterton is one of the Larger Villages which is not identified to have any housing provision made over the period of the plan.
The site is part of a much more extensive area assessed in the “Landscape Sensitivity Part 2 a” (GCA1) and the Report appears to support development in this more specific location. The SHLA’s conclusion on landscape impact does not align with the findings of the landscape assessment which concluded development could be suitably accommodated on this site within certain parameters.
Given the need to identify further housing allocations the Council should reconsider the allocation of this site.
All site appraisals have been reviewed in the light of comments and further evidence received to determine their suitability for allocation.
Object
Regulation 18 draft Local Plan
Representation ID: 7661
Received: 08/01/2024
Respondent: South Luffenham Parish Council
Site Allocation Assessment: Appendix C -larger Villages SHLAA SOU 02 Site ID 50 Development Agricultural Land Grade 3 -North of A6121 Stamford Road. States Indicative Capacity 44 based on Standard Calculation in SH LAA methodology. In the Conclusion however 152 dwellings are indicated in the report, is this a typo as based on 152 dwellings this number would be disproportionate to the present number of dwellings in South Luffenham and present significant unrealistic pressures on current infrastructure and access to the current road system.
All site appraisals have been reviewed in the light of comments and further evidence received to determine their suitability for allocation.
Object
Regulation 18 draft Local Plan
Representation ID: 7680
Received: 08/01/2024
Respondent: South Luffenham Parish Council
The plan identifies the extent of residential development but fails to identify how existing schools and healthcare providers will cater for the increased footfall of what are already stretched providers.
Noted. The infrastructure delivery plan (IDP) identifies Rutland's infrastructure requirements including social, physical and green infrastructure. The IDP sets out what is needed, where it is needed and when it is needed.
Object
Regulation 18 draft Local Plan
Representation ID: 7687
Received: 05/01/2024
Respondent: De Merke Estates
Agent: Stantec
Land at North West Oakham is an available site which provides a ‘blank canvas’ for the delivery of a truly mixed-use development comprising homes, alongside local services and facilities to meet the needs of both existing residents of Oakham and future residents too.
The Site has been assessed within RCC’s “Housing Site Assessment Report (October 2023)” with a potential capacity across the Site of 833 dwellings. We wholeheartedly disagree (and object) to such an assessment.
Whilst this level of development could potentially be achievable, it bears no regard whatsoever to wider environmental or technical assessments that have been undertaken by our Client (and the LPA previously).
Nor has it had any regard to our “Supplementary Call for Sites Submission” (July 2023), which set out a series of alternative (smaller) schemes that could come forward separately and/or evolve over time.
The Site can readily accommodate additional facilities and services to not only enhance its sustainability criteria, but also benefit the existing nearby residents with improved access to much desired local facilities and services. This would be wholly in line with the Vision of the Plan.
All site appraisals have been reviewed in the light of comments and further evidence received to determine their suitability for allocation.
Object
Regulation 18 draft Local Plan
Representation ID: 7692
Received: 08/01/2024
Respondent: Cllr Abigail West
In Market Overton – adjacent to the existing inclusion there is a small paddock to the East. Immediately adjacent. I would like to see this included as it has been brought forward before and had the broad support of the village.
I am disappointed to see no housing allocations in Braunston (behind Lammas close). Uppingham also appears to have a paucity of allocation.
All site appraisals have been reviewed in the light of comments and further evidence received to determine their suitability for allocation.
Object
Regulation 18 draft Local Plan
Representation ID: 7698
Received: 08/01/2024
Respondent: Vistry Group c/o Pegasus Group
Agent: Pegasus group
The proposed housing distribution to Stamford north, Oakham and Uppingham and larger villages combined with the proposed housing requirement and buffer (both of which are challenged elsewhere in this representation), means it is proposed to distribute a total of 514 homes in the plan period to the Larger Villages including Ketton. This is a modest scale of development given there are 21 villages identified as sustainable Larger Villages capable of supporting growth, it is the equivalent of 25 homes each.
4.6. It is noted that, taking account of commitments and completions, the minimum indicative target housing supply to deliver the housing requirement for Larger Villages is 153 homes over the 20 year plan period. This is the equivalent of 7 homes if this figure was split equally between the Larger Villages.
The Council should be planning to exceed the standard method local housing need figure, it is important the capacity of the Larger Villages to support growth is not underestimated.
There are nine proposed allocations in the Larger Villages, and eight of these sites are between 6 and 20 dwellings, three are less than 10 dwellings i.e. not defined as major sites and not meeting the threshold for on-site affordable housing, mix or open space policy. This is a missed opportunity to plan and direct development in a way that delivers more for communities i.e. new open spaces, new affordable homes and a good mix of homes.
All site appraisals have been reviewed in the light of comments and further evidence received to determine their suitability for allocation.
Object
Regulation 18 draft Local Plan
Representation ID: 7701
Received: 08/01/2024
Respondent: Vistry Group c/o Pegasus Group
Agent: Pegasus group
Policy H1 includes sufficient sites to provide a contingency buffer of 10% to aid delivery of the minimum housing requirement.
The Local Plans Expert Group report, 2016, set out recommendations for a 20% allowance of developable reserve sites to provide extra flexibility to respond to change. Harborough District Council, includes a 15% contingency in their Local Plan, over and above their minimum housing requirement which the Local Plan Inspector specifically commented was to provide resilience.
It is suggested that a 20% buffer is used in the case of Rutland given the relatively low housing requirement and the potential for unforeseen circumstances to mean sites are not brought forward and the significant impact this could quickly have on the Council’s ability to deliver sufficient housing.
All site appraisals have been reviewed in the light of comments and further evidence received to determine their suitability for allocation.
Object
Regulation 18 draft Local Plan
Representation ID: 7702
Received: 08/01/2024
Respondent: Vistry Group c/o Pegasus Group
Agent: Pegasus group
Policy H1 spreads development over a larger number of smaller sites and this is not supported. This approach, removes the benefits of a local plan for the Larger Villages, as it fails to create a critical mass that would support communities in the way intended and instead supports incremental growth of communities which brings minimal benefits.
A total of 150 homes proposed on brownfield sites, many within the planned limits to development of the Larger Villages. The deliverability of all the sites proposed needs to be demonstrated, but this is particularly important for brownfield sites. The principle of development is already acceptable on those brownfield sites within the planned limits to development, so it is questionable whether allocating these sites will overcome the reason they haven’t already been brought forward.
As proposed, Policy H1 has an overreliance on brownfield sites within the Larger Villages, without sufficient evidence presented on the deliverability of these sites or the impact the number of brownfield sites will have the delivery of affordable housing, open spaces and developer contributions through CIL payments, which are reduced on brownfield sites.
It is also noted that the only substantial sized allocation made at St George's Barracks Officers Mess in Edith Weston overestimates the scale of development that is achievable.
All site appraisals have been reviewed in the light of comments and further evidence received to determine their suitability for allocation.
Object
Regulation 18 draft Local Plan
Representation ID: 7703
Received: 08/01/2024
Respondent: Vistry Group c/o Pegasus Group
Agent: Pegasus group
reserve sites
The potential for deliverability issues appears to be acknowledged by the unusual inclusion of eight greenfield reserve sites, all but one of which are located in the Larger Villages.
There are however also questions about the deliverability of the reserve sites which need to be considered further, in particular where planning permission has recently been refused on such sites
All site appraisals have been reviewed in the light of comments and further evidence received to determine their suitability for allocation.
Object
Regulation 18 draft Local Plan
Representation ID: 7704
Received: 08/01/2024
Respondent: Vistry Group c/o Pegasus Group
Agent: Pegasus group
Additional site at Land North of Luffenham Road, Ketton shuld be allocated. The site is approx. 7 ha and is currently in use for agricultural purposes and is capable of delivering 130 dwellings (including 39 affordable homes). (Appendix 1 site plan) in a sustainable village, the site is well located in relation to a number of local facilities in the surrounding area which would be available for use by future residents of the site. The site is 10 minutes walk from Ketton C of E Primary School. It is also within walking distance of the village Post Office and General Store, sport facilities, Public House, Community Hall and Library. The village also benefits from a regular bus service, the number 12, which runs between Stamford and Uppingham.
The Site Allocation Assessment Appendix C concludes that the scale of the proposed development is not suitable for allocation.
It is unclear how a site, identified as having capacity for 126 homes in the assessment, can be of a scale that excludes it from further consideration when the proposed housing requirement, even just within the Larger Villages is greater than this amount.
All site appraisals have been reviewed in the light of comments and further evidence received to determine their suitability for allocation.
Object
Regulation 18 draft Local Plan
Representation ID: 7719
Received: 08/01/2024
Respondent: Class Q Ltd
I believe that some sites have been inaccurately assessed. I have detailed discrepancies in the RAG scoring that have arisen due to incorrect and inconsistent evaluations. Based on the above, the Council have been incorrect to omit the sites at Brooke Road, Braunston, Normanton Road, Edith Weston and Pickworth Road, Great Casterton as housing allocations. These would be more suitable and realistic than proposed sites which have also been inaccurately assessed. (see analysis provided)
All site appraisals have been reviewed in the light of comments and further evidence received to determine their suitability for allocation.
Support
Regulation 18 draft Local Plan
Representation ID: 7741
Received: 08/01/2024
Respondent: Anglian Water
Anglian Water notes (Table 4, page 84) an additional 2,056 dwellings are identified over and above the 650 Rutland Local Plan allocation for Stamford North. In addition, if P-TAL proved to a bar on growth in the catchments affected then circa 2,830 new homes could be served by catchments and WRC which are not so constrained. With reference to page 83 and ‘infrastructure needs’ Anglian Water recognises that in assessing the climate change and carbon implications for growth that water supply and water recycling is approximately two (2) percent of capital and operational UK emissions. Anglian Water proposes to support the Council in quantitatively assessing the whole life GHG emissions for the preferred spatial distribution and quantum of growth during the next stage of the plan’s progression.
Support noted.
Support
Regulation 18 draft Local Plan
Representation ID: 7762
Received: 08/01/2024
Respondent: McCarthy Stone
Agent: The Planning Bureau Limited
We support policy H1 in its identification that Uppingham will deliver 316 dwellings over the plan period to be allocated through the Uppingham Neighbourhood Plan.
Support noted.
Object
Regulation 18 draft Local Plan
Representation ID: 7763
Received: 08/01/2024
Respondent: Exeter Court 1 Limited
Agent: Freeths LLP
This representation promotes Land off Braunston Road, Oakham for the residential development of up to 10no. dwellings as a sustainable development to the edge of a market town at the top tier of the settlement hierarchy.
A number of the Larger Villages are unsustainable locations for additional development. On this basis, our client objects to the allocation of sites in the unsustainable Larger Villages
It is imperative that a variety of size and types of sites are allocated for housing across Oakham and the County in order to provide choice to the market and headroom for delivery.
It is therefore considered that additional smaller sites should be allocated in Oakham in order to ensure delivery in the earlier stages of the plan period, and also direct development to the most sustainable location.
The site is considered to be suitable, available and achievable.
All site appraisals have been reviewed in the light of comments and further evidence received to determine their suitability for allocation.
Object
Regulation 18 draft Local Plan
Representation ID: 7839
Received: 08/01/2024
Respondent: Alicia Kearns
The 2021 census suggests population growth for Rutland up to 46,100 by 2041, rather than 42,200 as forecast in 2020 in the previous draft Plan. Has the 2021 census data been included in the Local Plan? There seems to be a disparity between actual and likely population growth and new housing provision.
Given the importance of housing development in informing other areas of the Plan, such as health, education, and infrastructure, it is vital that the Council gets this right. I would suggest that it is revisited and the data from the 2021 census is used as a basis for population predictions and resulting policies.
All site appraisals have been reviewed in the light of comments and further evidence received to determine their suitability for allocation.