Object
Regulation 18 draft Local Plan
Representation ID: 4766
Received: 06/12/2023
Respondent: Matt Parkinson
RCC has adopted a positive attitude towards disability and the transforming adult community care agenda (homes not hospitals for people with a learning disability or Autism).
However I am not convinced that the provisions are in place to meet this growing need WITHIN Rutland and that any new local plan should cater for this need.
Comment Noted. The 2019 update of the Rutland Housing Market Assessment identified that there is a need to increase the supply of Extra Care, Enhanced & Sheltered accommodation for and this is estimated to be for around 190 dwellings in the period to 2036 – around 10 per annum. Housing Policy H4 addresses Meeting all housing needs.
Support
Regulation 18 draft Local Plan
Representation ID: 4824
Received: 20/12/2023
Respondent: Mr Nigel Roberts
Should not CIL monies collected by RCC be used for the benefit of the Village/Town where the development took place not just be put into a central pot for use anywhere. Parish Councils do get a proportion of the CIL money (10%.25%), but this is normally not enough to any major infrastructure projects.
CIL is a national legislation in which all funds collected go into a central pot for all of the County. As the Charging Authority RCC decides how to spend CIL on infrastructure across the County and it must allocate the ‘Neighbourhood Portion’ of CIL to Parish and Town Councils. Those Parish or Town Councils which have adopted neighbourhood plans receive a higher proportion of Neighbourhood CIL. These funds can be used to spend on infrastructure or anything else that addresses the demands that development places on an area. Strategic priorities for the spend of the charging authority portion of CIL will be for critical infrastructure to support the priorities as identified by Policy INF 1. Lists of infrastructure issues or proposals that have been prioritised for investment or specific types of work to develop a proposal (e.g. a feasibility study) to decide whether and how it can be implemented, should be included in the Neighbourhood Plan.
Support
Regulation 18 draft Local Plan
Representation ID: 4853
Received: 21/12/2023
Respondent: ANCER SPA Ltd
If Rutland County Council wants housing and employment targets to be met, it will have to take a realistic attitude to the extent that CIL, planning obligations and other policy principles costs can be borne by a development. Therefore, robust viability assessments of proposed developments will be critical. The Council’s Whole Plan Viability Study should be seen as a flexible document that needs to be updated on a periodic basis.
Comment Noted. The Viability Assessment for the Local Plan has been prepared in close co-ordination with the Infrastructure Delivery Plan.
Support
Regulation 18 draft Local Plan
Representation ID: 4874
Received: 22/12/2023
Respondent: Burley Parish Meeting
You can put in the infrastructure but if the Doctors are not going to be there, what's the point. It is so hard to get an appointment perhaps you need to provide a combined NHS and Private Doctors Centre, otherwise the Pharmacies are going to become a larger provider of our needs, this will have major implications for the quality of care for our residence especially those who need special care. Its not money, it not buildings it is the lack of activity inside the buildings.
Comment Noted. Health and Wellbeing is a strategic objective for the new Local Plan and the healthcare needs of planned growth have been considered in detail as part of the Infrastructure Delivery Plan in consultation with the Leicestershire and Rutland Integrated Care Board. Allocation for a new Medical Centre in Empingham is to be included within the Reg 19 plan.
Object
Regulation 18 draft Local Plan
Representation ID: 4926
Received: 29/12/2023
Respondent: Mr Murdo Ross
Utilisation of Oakham Rail Crossings - a medium-term forecast of rail transport movements by hour should be published in support of any planned housing development in Oakham (eg. Brooke Road) that will increase the use of the existing crossings and the associated traffic congestion
Comment Noted. A transport model has been prepared by AECOM to support the preparation of the Local Plan and test the impacts of planned growth on the local and strategic road networks. The model considers the cordoned AM Peak hour (08:00 to 09:00) and PM Peak hour (17:00 to 18:00) models covering Rutland (plus a buffer of ~10km) and has been locally calibrated using data readily from Leicestershire County Councils' Pan Regional Transport Model . Following analysis an assessment of development impacts and suggested broad mitigation options and when these might be needed in the Plan period (the first five years of delivery is key) will be set out in a Forecasting Report. The cumulative impacts of proposed Oakham site allocations on the local network within the town (including the impacts on the rail crossing) will be identified.
Support
Regulation 18 draft Local Plan
Representation ID: 5001
Received: 02/01/2024
Respondent: Define (on behalf of William Davis Homes)
WDH is committed to funding and delivering the infrastructure required to support development, and in that regard WDH’s response to Policy SS3 highlights how an increased level of growth in the large villages will support existing and new services and facilities.
Policy INF1 makes reference to CIL. However, the plan is likely to be subject to the forthcoming planning policy reforms, which have made reference to a new Infrastructure Levy, which the RLP will need to consider. Notwithstanding that, WDH note the importance of ensuring that CIL Schedules (or their replacement) are kept up to date throughout the plan period.
Comment Noted. Section 106 agreements, the Community Infrastructure Levy (CIL) and the proposed Infrastructure Levy are all similar in that they impose additional conditions on the developer, linked to planning permission. Section 106 is bespoke and negotiated and Section 106 contributions can be used for a number of purposes, including schools, clinics, or affordable housing. The Community Infrastructure Levy is a financial obligation, based on a published tariff schedule and based on the square meterage of a development. The advantage of this for both developers and local authorities is that it gives more cost certainty and reduces ambiguity. It is proposed that IL will replace CIL and potentially accommodate all financial contributions currently dealt with by way of section 106 agreements and CIL. IL would be “values based” (including consideration of increase in land value) whereas CIL is a fixed charge broadly based on net additional floor space. However, IL may not be taken forward.
Support
Regulation 18 draft Local Plan
Representation ID: 5024
Received: 02/01/2024
Respondent: Mrs Sara Glover
But there needs to be very clear plans as to how healthcare provision will be increase to meet a growing population so this plan must tie in with health service developments, plans for dentists and other non medical health provisions especially with the age of the resident population of Rutland
Comment Noted. The plans of both the Leicestershire and Rutland and Lincolnshire ICB's and the local GP and Dental Practices have been taken into consideration within the Infrastructure Delivery Plan supporting Policy INF1. Allocation for a new Medical Centre in Empingham is to be included within the Reg 19 plan as is a new policy in the Infrastructure Chapter regarding this allocation.
Support
Regulation 18 draft Local Plan
Representation ID: 5127
Received: 03/01/2024
Respondent: National Highways
National Highways is unlikely to support S106 contributions for infrastructure improvements to the Strategic Road Network in most cases. The text should be expanded to include highways improvements secured under Section 278 of the Highways Act.
Comment Noted. Amendment to text to make reference to Section 278.
Support
Regulation 18 draft Local Plan
Representation ID: 5222
Received: 03/01/2024
Respondent: Mr Frank Brett
Supported
Support Noted.
Object
Regulation 18 draft Local Plan
Representation ID: 5653
Received: 05/01/2024
Respondent: Ashwell Parish Council
It is all too easy for a developer to pay CIL and then create a development without appropriate infrastructure. There needs to be a much more robust statement in the Plan from Rutland County Council which states that the CIL collected on a specific development will be used to enhance the infrastructure on that particular site. If CIL is banked and then used for appropriate facilities somewhere else in the county, rather than in accessible distance from the development, then we are just creating more traffic and another estate without local facilities and opportunities to interact as a vibrant community.
CIL is a national legislation in which all funds collected go into a central pot for all of the County. As the Charging Authority RCC decides how to spend CIL on infrastructure across the County and it must allocate the ‘Neighbourhood Portion’ of CIL to Parish and Town Councils. Those Parish or Town Councils which have adopted neighbourhood plans receive a higher proportion of Neighbourhood CIL. These funds can be used to spend on infrastructure or anything else that addresses the demands that development places on an area. Strategic priorities for the spend of the charging authority portion of CIL will be for critical infrastructure to support the priorities as identified by Policy INF 1. Lists of infrastructure issues or proposals that have been prioritised for investment or specific types of work to develop a proposal (e.g. a feasibility study) to decide whether and how it can be implemented, should be included in the Neighbourhood Plan.
Support
Regulation 18 draft Local Plan
Representation ID: 5787
Received: 06/01/2024
Respondent: Mrs Dinah Hurwood
On the subject of transport connectivity I suggest that the A6003 be subject to HGV weight limit between the A47 roundabout outside Uppingham through to the roundabout at the top of the hill in Rockingham so that they use the A43 link; thereby stopping the thunderous lorries which pass through Uppingham town every day, Caldecott and Rockingham and other smaller villages when there is a blockage on the A6003.
Noted. This falls outside the scope of the Local Plan. The Road Traffic Act 1984 and its amendments give powers to the Council as the Highways Authority to impose Traffic Regulation Orders on the local road network across the County. Such orders are subject to legal procedures which are specified in the Local Authorities Traffic Orders (procedure) Regulations 1996 and all restrictions must be signed in accordance with the Traffic Regulations and General Directions 2002. The introduction of a weight restriction on a public road will be considered either for environmental protection (for example, a narrow village road) or where there is a need to protect a structure (for example, a bridge or culvert) from the effects of heavy goods vehicles. Where a weight restriction is considered necessary, consideration must be given to a suitable alternative route and the likely effect on other communities.
Object
Regulation 18 draft Local Plan
Representation ID: 5899
Received: 07/01/2024
Respondent: Ms Carol Brys
It's all well and good that you are talking about adding facilities for health care, but unless doctors are paid an actual living wage that reflects the value and gravity of their roles, there will be no one to fill them. Despite the wealth of this county, pensioners should NOT be forced into using private health care.
It is not just new developments that need safety measures for pedestrians and cyclists. Our village has no effective safety measures on its main road and it is a matter of when, not if, someone is gravely injured or worse.
Comments noted. This falls outside the scope of the Local Plan.
Object
Regulation 18 draft Local Plan
Representation ID: 6006
Received: 07/01/2024
Respondent: Jane Ellis
The Priorities listed do not appear to reflect those highlighted by respondents to the June 2022 Local Plan Public Consultation
CIL money does not appear to have been used for "major infrastructure development", to date. GP provision and the development of an effective, value for money Council are priorities
CIL money needs to make an impact for all Rutlanders. Use must be transparent. CIL must not be wasted on white elephants, or non-essential community projects. In a rural area car use is going to be high and people are not going to cycle or walk to towns to shop
Comment Noted.
Priorities should not be numerically ranked, numbering will be removed from INF1. Infrastructure spending will be specific to the location, scale and mix of proposals.
CIL can be used to fund a wide range of infrastructure, including transport, flood defences, schools, hospitals, and other health and social care facilities. The legislation allows the levy to be used to fund a very broad range of facilities such as play areas, open spaces, parks and green spaces, cultural and sports facilities, healthcare facilities, academies and free schools, district heating schemes and police stations and other community safety facilities. This flexibility gives local areas the opportunity to choose what infrastructure they need to deliver their relevant plan. RCC may not use the levy to fund affordable housing. The levy can be used to increase the capacity of existing infrastructure or to repair failing existing infrastructure, if that is necessary to support development. The neighbourhood portion can be spent on a wider range of things than the rest of the levy, provided that it meets the requirement to ‘support the development of the area – and such need may be articulated in the relevant Neighbourhood Plan. The wider definition means that the neighbourhood portion can be spent on things other than infrastructure (as defined in the Community Infrastructure Levy regulations) provided it is concerned with addressing the demands that development places on the parish’s area. We would recommend that parish or town councils work closely with their neighbouring parishes and RCC to agree on infrastructure spending priorities. If the parish or town council shares the priorities of the charging authority, they may agree that the charging authority should retain the neighbourhood funding to spend on that infrastructure. It may be that this infrastructure is not in the parish or town council’s administrative area but will support the development of the area. If a parish or town council does not spend its levy share within 5 years of receipt, or does not spend it on initiatives that support the development of the area, RCC may require it to repay some or all of those funds to reallocation to other projects.
Object
Regulation 18 draft Local Plan
Representation ID: 6244
Received: 07/01/2024
Respondent: Mr Peter Johnson
The Issues and Options consultation referred to in the plan showed that improving healthcare infrastructure provision was the number one priority and affordable housing number two.
Why, therefore, is Healthy and Well priority three and not one?
Also, why is a County for Everyone, (affordable housing), priority four and not two?
Should not Rutland’s five infrastructure priorities be aligned with those from the Issues and Options consultation?
Noted. Priorities should not be numerically ranked, numbering will be removed from INF1. Infrastructure spending will be specific to the location, scale and mix of proposals.
Support
Regulation 18 draft Local Plan
Representation ID: 6366
Received: 08/01/2024
Respondent: Mr Chris Read
The CIL should be prioritised towards the communities most affected by the development.
CIL is a national legislation in which all funds collected go into a central pot for all of the County. As the Charging Authority RCC decides how to spend CIL on infrastructure across the County and it must allocate the ‘Neighbourhood Portion’ of CIL to Parish and Town Councils. Where Parish or Town Councils have adopted neighbourhood plans, the percentage of CIL received from developments within their parish areas will be increased. These CIL payments can be spent on infrastructure or anything else that addresses the demands that development places on an area. Strategic priorities for the spend of the charging authority portion of CIL will be for critical infrastructure to support the priorities as identified by Policy INF 1. Lists of infrastructure issues or proposals that have been prioritised for investment or specific types of work to develop a proposal (e.g. a feasibility study) to decide whether and how it can be implemented, should be included in the Neighbourhood Plan.
Object
Regulation 18 draft Local Plan
Representation ID: 6401
Received: 08/01/2024
Respondent: Little Casterton Parish Council
There is much in this Local Plan that needs complete rethinking as it appears the only objective is to meet a housing quota by dumping the proposal on a local community area that cannot support it, as such we cannot support this aspect of the plan.
Noted. The Local Plan provides a list of 11 Strategic Objectives which are addressed via an array of detailed policies for all aspects of society.
Support
Regulation 18 draft Local Plan
Representation ID: 6494
Received: 08/01/2024
Respondent: Bill Deayton
The words in the policy are supportable but the reality has to support stated objectives. There should be no further housing development, regardless of size, without contribution to the development of services. Medical and dentistry are the obvious ones but schools, roads, leisure facilities, cycle and walking routes all apply, as does economic development to offer suitable levels of employment.
Noted. The Infrastructure to support the new housing development proposed is in the accompanying Infrastructure Development Plan and is addressed through out the detailed Policies within this Local Plan. CIL and S106 agreements provide the mechanism for funding infrastructure improvements.
Object
Regulation 18 draft Local Plan
Representation ID: 6598
Received: 08/01/2024
Respondent: Mrs Susan Shepherd
In the consultation , healthcare was identified as the number 1 priority yet comes in at number 3 in this plan policy. With the focus on the environment and housing provision the critical needs of both healthcare and education within the county has been overlooked.
Noted. Priorities should not be numerically ranked, numbering will be removed from INF1. Infrastructure spending will be specific to the location, scale and mix of proposals.
Object
Regulation 18 draft Local Plan
Representation ID: 6630
Received: 08/01/2024
Respondent: Defence Infrastructure Organisation (DIO)
Agent: Montagu Evans LLP
The DIO do not agree with the statement in Policy INF1 that 'it is assumed that all development proposals will be viable' as this will not be the case for all sites. Some locations, especially brownfield opportunities such as St George’s Barracks bear significant abnormal costs associated with demolition and site remediation. These will have an impact upon scheme viability and the ability for all measures to be delivered on site and in full. Given this is discussed at the National Level, there is no need to duplicate this point within Local Plan Policy and it should be removed.
Comments noted. Remove final sentence of paragraph.
Support
Regulation 18 draft Local Plan
Representation ID: 6639
Received: 08/01/2024
Respondent: NHS Leicester, Leicestershire and Rutland ICB
Rutland's Infrastructure Priorities - We understood healthcare to be top priority which the IDP (Section 18.2) has indicated however reading the list it reads as though this is in a priority 3. Could it be made clear if this is a list in order of priority or simply a list of the top priorities in no particular order.
Noted. Priorities should not be numerically ranked, numbering will be removed from INF1. Infrastructure spending will be specific to the location, scale and mix of proposals.
Object
Regulation 18 draft Local Plan
Representation ID: 6723
Received: 07/01/2024
Respondent: Amanda Bloomfiled
Health: I feel the health aspirations are vague. We have an ageing population, and we need to be attracting healthcare research and outreach centres for medicine and dentistry into the county. Medical provision is over stretched and our own teaching facility, with a walk in clinic would be really useful instead of having to go to Corby for urgent care- which is difficult to get to if you haven't got a car. We need to harness rural health solutions such as mobile buses for dental, audio and medical screening and basic treatments. Village halls could also be utilised for health promotion.
The special school should not be shut- this would be a crime to all special care populations.
State schools need to be supported and the leisure centre reinstated to reduce obesity and prevent alzheimer's through movement and excercise. You could put a multi-disciplinary health clinic in the leisure centre.
Comments Noted.
Allocation for a new Medical Centre in Empingham is to be included within the Reg 19 plan as is a new policy in the Infrastructure Chapter regarding this allocation.
The Infrastructure Delivery Plan supporting Policy INF 1 covers these issues in more detail as part of the Local Plan evidence base. State schools and the leisure centre fall outside the scope of the Local Plan.
Object
Regulation 18 draft Local Plan
Representation ID: 6930
Received: 08/01/2024
Respondent: Caldecott Parish Council
The proposed local plan does not recognise the impact of growth upon infrastructure outside of the immediate area. This applies particularly to the impact of development on arterial roads such as the A6003 which travels through Caldecott and which cannot cope with the inappropriate nature and quantity of traffic from recent growth and further significant issues (safety/quality of life) which will be caused by the development levels proposed within this plan and those of neighbouring authorities.
This point should be explicitly referenced in relation to policy INF1 in the local plan and addressed in the Infrastructure Delivery Plan. The Infrastructure Delivery Plan should prioritise the specific projects related to the issue of arterial roads though historic village settings and identify the funding mechanisms to support improvements and/or bypass routes during the life time of this Local Plan.
Comment Noted. A transport model has been prepared by AECOM to support the preparation of the Local Plan and test the impacts of planned growth on the local and strategic road networks. The model considers the cordoned AM Peak hour (08:00 to 09:00) and PM Peak hour (17:00 to 18:00) models covering Rutland (plus a buffer of ~10km) and has been locally calibrated using data readily from Leicestershire County Councils' Pan Regional Transport Model . Following analysis an assessment of development impacts and suggested broad mitigation options and when these might be needed in the Plan period (the first five years of delivery is key) will be set out in a Forecasting Report. The cumulative impacts of proposed site allocations on the A6003 will be identified and mitigation identified in the Infrastructure Delivery Plan (if required).
Object
Regulation 18 draft Local Plan
Representation ID: 7035
Received: 08/01/2024
Respondent: Mr John Fowler
Firstly I would like to state that I think the tone and content of the plan is very good.
I would however like to see a sharper focus on infrastructure. Particularly provision of another GP practice for Oakham. It’s obvious that the current practice is already overwhelmed.
Secondly indirect developmental assistance. Many go to Stamford for “more upmarket supermarkets such as Waitrose and Sainsbury’s “ Both have in the past sought sites in Oakham. The model has been proved many times with for example a John Lewis or M&S coming to a location. It feeds footfall and encourages others to invest and visit.
I hope this is useful
Support Noted. The Infrastructure Delivery Plan supporting Policy INF 1 covers these healthcare needs of Rutland and planned growth in more detail as part of the Local Plan evidence base. The Reg 19 Plan allocates land for a new Medical Centre in Empingham. The need for additional supermarket provision in Rutland has not been identified through the Call for Sites process.
Object
Regulation 18 draft Local Plan
Representation ID: 7108
Received: 02/01/2024
Respondent: Stamford Civic Society
Policy INF 1 – Infrastructure and connectivity This policy identifies the requirement of developers to pay CIL. However, it is not clear to what extent CIL contributions from the developers of Quarry Farm/Monarch Park will contribute to the wider infrastructure costs of SKDC and LCC in relation to the North Stamford development.
Currently, SKDC has not adopted CIL and uses Section 106 agreements and obligations to mitigate the impacts of development. CIL charges will be payable on the proportion of the North Stamford Urban Extension that are in the Rutland administrative area and will be spent on infrastructure within Rutland impacted by the development.
Object
Regulation 18 draft Local Plan
Representation ID: 7118
Received: 08/01/2024
Respondent: Tim Maskell
A priority policy of the RCC Local Plan should be to ensure excellence of the provision of NHS and wider medical service in Rutland. A further GP surgery is badly needed in Rutland.
Comments Noted. The Infrastructure Delivery Plan supporting Policy INF 1 covers these healthcare needs of Rutland and planned growth in more detail as part of the Local Plan evidence base. It is proposed that the Reg 19 Plan allocates land for a new Medical Centre in Empingham.
Object
Regulation 18 draft Local Plan
Representation ID: 7144
Received: 03/01/2024
Respondent: Jacqueline Towl
We need better medical provision, GP's and better use of Rutland Memorial Hospital.
Comments Noted. The Infrastructure Delivery Plan supporting Policy INF 1 covers these healthcare needs of Rutland and planned growth in more detail as part of the Local Plan evidence base. It is proposed that the Reg 19 Plan allocates land for a new Medical Centre in Empingham.
Support
Regulation 18 draft Local Plan
Representation ID: 7177
Received: 08/01/2024
Respondent: Leicestershire Police
Key Points:
Rutland County Council are requested to work with Leicestershire Police by consulting with them on large-scale applications, firstly to gain their perspective from a
design front and secondly to understand whether the associated growth would produce a need for additional policing infrastructure. If this is the case then Leicestershire Police will assess each application on an individual basis, by looking at the current level and location of available officers and then the demand associated with that development.
Areas including public space, shop frontages and appropriate security such as shutters should include sympathetic design and be in keeping with local architecture, whilst still providing effective security. Other key areas where planning can support the local
businesses includes the night time economy. Effective planning including lighting and use of CCTV, if required will reduce the risk of crime and disorder.
Currently Rutland County Council have a number of S106 Agreements in respect to new developments within the Rutland County Council area in support of Policing. Also, no CIL funding is provided towards Policing, resulting in only statutory funding via the Policing precept and Government and S106 obligations. Where new demand is placed on Policing resources due to expansion Leicestershire Police, Rutland County Council and people within Rutland County area would benefit from support of the provision of S106/CIL and future S106 bids will be considered in support of Policing provision within the Rutland County Council area.
Comment Noted. The Infrastructure Delivery Plan reflects these comments and sets out more detail to support policy INF 1 with respect to the funding of emergency services .
Object
Regulation 18 draft Local Plan
Representation ID: 7198
Received: 08/01/2024
Respondent: Allison Homes
AH is supportive of this policy aspiration, however, considers that for the delivery targets to be met, a flexible approach is required. Robust assessments of the viability of proposed developments will be critical and should be considered alongside and as updates to the Council’s Whole Plan Viability Study.
Comment Noted. The Whole Plan Viability Study supporting the Local Plan has been updated to reference the priority infrastructure requirements specified in the Infrastructure Delivery Plan .
Object
Regulation 18 draft Local Plan
Representation ID: 7267
Received: 08/01/2024
Respondent: Manton Parish Council
The Plan states that “ It is recognised that improving accessibility and providing realistic alternatives to car travel in a rural area like Rutland is particularly challenging. Residents without access to a private car can be isolated and have significant issues in accessing employment, education and training as well as other services and facilities. Therefore, the location of new development can have significant impact on achieving sustainable patterns of travel and accessibility”. We believe that significant new development in rural areas, such has Manton, has not taken into account the substance of the above statement.
Comment Noted. The NPPF reiterates that Local Plans should “set out an overall strategy for the pattern, scale and quality of development”. The settlement hierarchy plays an important role in identifying sustainable locations for development and is a way of categorising the settlements in Rutland and grouping together those that have similar characteristics. At the top of the hierarchy are the larger settlements that have the best infrastructure in terms of facilities and services and are the most accessible by sustainable forms of travel. The smaller settlements with the least facilities, services and accessibility to public transport will be towards the bottom of the hierarchy. The settlement hierarchy does not in itself determine the appropriate level of growth a particular settlement can support but does seek to identify the most sustainable places where growth could be directed. Manton is defined as a Small Village in the Rutland settlement hierarchy. These villages tend to have only some of the key facilities and/or are less accessible to higher order centres than villages in the Local Service Centre category, such as Edith Weston, which comprise those that have most of the ‘key facilities’ and also score well in terms of either ‘other services’ provision or are more accessible in terms of frequent public transport provision or close proximity to the main settlements.
Object
Regulation 18 draft Local Plan
Representation ID: 7280
Received: 07/01/2024
Respondent: Mrs Marilyn Clayton
As Rutland's retired population is 36% healthcare for the elderly should have priority.
It has been sometimes difficult to access in the past for my late husband.
Comments Noted. The Infrastructure Delivery Plan supporting Policy INF 1 covers these healthcare needs of Rutland and planned growth in more detail as part of the Local Plan evidence base