Regulation 18 draft Local Plan

Object

Representation ID: 7815

Received: 07/01/2024

Respondent: CPRE Rutland

At the outset there is no analysis of population data. With the benefit of the 2021 Census, some sort of demographic
account would have been expected.

Population figures seem to have increased markedly since the last (draft) plan, in 2020. The population is projected
now to rise to 45,038 by 2036 and 46,100 by 2041, against 41,700 and 42,200 respectively in those years from the previous plan, although the source of these projections - the 2021 Census results perhaps - is not stated. So, a roughly 6% rise forecast in the 2020 plan has now become an increase of over 11%. This will clearly have implications in many areas and must be fully explained. These figures should feed into the justification/requirement for extra housing, infrastructure, etc.

We are told that 36% of the population is retired and that by the end of the plan period 30% will be aged 80+. Again,
what is the source of these statistics and what are the implications? Where will the residential homes/serviced
apartments be located? If we need affordable homes for the less well off, then we also need bungalows and small
serviced apartments. The implications in terms of medical care and transport for the elderly are glossed over in this
plan when they should be central to the vision and policies for caring for our population.

The population projections are clearly fundamental to planning for the future of the county and for any new
developments needed. Full explanations and justifications for the figures are therefore essential to ensure that the
right housing is provided in the right timescales.

Comments noted. Chapter 2 sets out the main characteristics of Rutland in terms of current population and projected population growth. This is used to calculate development needs in the county over the plan period and further analysis is used in some of the supporting evidence for the Local Plan. References to the statistics given in Chapter 2 are given in the footnotes. Meeting housing needs for different sectors of the population is addressed in Policy H4 on the basis of evidence set out in the Housing Market Assessment. A detailed Infrastructure Delivery Plan will be published alongside the Regulation 19 consultation plan which will set out the detailed infrastructure needed to support development.

Object

Representation ID: 7816

Received: 07/01/2024

Respondent: CPRE Rutland

The first paragraph is unclear. The section headed 'Why are the Vision and Strategic Objectives needed?’ should be moved to a position before the vision itself to improve the flow of the narrative.

The Vision statement reads almost as if the Plan is intended to build up from a pretty low base; it needs to be more positive about where we are now and how we hope to move on from there. It would probably also be useful to set out how the various policies and objectives will contribute to achieving the vision – see comments below against the Spatial Strategy Chapter.

Comments noted however we consider it more appropriate to read the Vision and Objectives early on in the chapter with the justification for them coming afterwards with the same layout order used in the other chapters. In accordance with the NPPF, the Local Plan provides a positive vision for the future and acknowledges that Rutland generally has a high quality of life. It is more effective and efficient to set out the rationale for the policies at the start of the chapters and after each policy.

Object

Representation ID: 7817

Received: 07/01/2024

Respondent: CPRE Rutland

This should also include a bullet on waste management/recycling and also mention the need to minimise demolition, etc. in developments.

As Strategic Objective 1 is focused on climate change, reference to waste management is not required here. Strategic Objectives are intended to be overarching and not repeat the detailed policies. Policy CC5 -Embodied Carbon - addresses the need to minimise demolition.

Object

Representation ID: 7818

Received: 07/01/2024

Respondent: CPRE Rutland

add '…the right houses in the right places' or some such qualification.

Objection noted.
The suitability of development is considered under Strategic Objective 2. Additionally, the assessments undertaken for the site allocation process ensure that only suitable developments in suitable locations are considered.
No change is required.

Object

Representation ID: 7819

Received: 07/01/2024

Respondent: CPRE Rutland

an explanation of ‘landscape connectivity' would be helpful.

Question noted. Landscape connectivity refers to landscape linkages for both biodiversity to be able to move and for people being able to access the natural environment.

Object

Representation ID: 7820

Received: 07/01/2024

Respondent: CPRE Rutland

– surely it is not just new development that must be supported by appropriate infrastructure, but all
aspects of life in the county (economy and business, recreation, health, education, etc.) as the population grows and evolves.

The Strategic Objectives need to be expanded to cover:
i) Healthcare and well-being, physical, mental or spiritual
ii) Protecting open countryside and preserving our rural environment
iii) Need to co-ordinate the use of available space and prevent unnecessary and unwelcome urban sprawl
iv) Matching additional developments, both residential and commercial, with projected population changes
v) Cooperation with adjoining regions.

Comments noted. The Local Plan rightly focusses on the provision of infrastructure in relation to new development delivered through s106/CIL. The provision of infrastructure for existing development, residents and businesses falls largely outside the remit of the Local Plan and would be funded and planned for by other council departments and bodies such as utility providers and the NHS.
Point i) covered by SO5; point ii) covered by SO8; point iii) covered by SO2 and SO3; point iv) covered by SO2, and; point v) covered by the Duty to Co-operate set out in Chapter 2.

Object

Representation ID: 7821

Received: 07/01/2024

Respondent: CPRE Rutland

There should be more emphasis on the standards required for effective insulation of new buildings and a
requirement to include renewable energy features, including solar panels, heat pumps and the like, unless good reason
not to can be demonstrated.

Disagree. Policy CC2 sets out the approach to ensuring that new buildings have the highest possible thermal efficiency and lowest possible expected energy use. The Plan acknowledges that a key consideration for Policy CC2 is its impact on the viability of new developments (that would include affordable housing). It is intended that further work to update the cost evidence will be undertaken to inform the next stage of the local plan. This will build on the Whole Plan Viability Assessment (2023) and will inform the policies at the next stage of the local plan. Any changes to the draft policies, such as setting standards for energy efficiency, arising from consultation responses and/or new evidence on viability in relation to the climate change policies will be consulted on through the Reg 19 consultation. Following this work there may be sufficient, robust evidence to set an energy use limit such as that used in other adopted local plans.
It would not be appropriate to require all new buildings to have solar panels/heat pumps through a prescriptive local plan policy as there are a number of factors that would need to be taken into account such as location, efficiency, viability and whether other forms of renewable energy are more appropriate. Such provision is, however, supported and encouraged in policy documents such as the NPPF and PPG, the National Design Guide (2021), Design Guidelines for Rutland (2021) and Local Plan Policies CC2 and CC4 seeks to maximise energy generation from on-site renewable sources.

Support

Representation ID: 7822

Received: 07/01/2024

Respondent: CPRE Rutland

This is an important and welcome inclusion.

Support noted.

Object

Representation ID: 7823

Received: 07/01/2024

Respondent: CPRE Rutland

Is this just for new residential buildings or should it apply equally to commercial developments? It should
also address waste water disposal.

Comments noted. Agree. There is currently no standard in water efficiency in non-residential development and, without such a standard, this would not help to mitigate the problem of Rutland being classified as being in a serious water stressed area. Agree there should be a limit for non-residential development by encouraging new developments to achieve full credits for category Wat 01 of BREEAM unless demonstrated impracticable. (similar to approach in Greater Cambridge Local Plan). This is also highlighted in the Rutland Draft Water Cycle Study (2023) that states that: ‘Non-domestic consumption can also be reduced by encouraging new developments to be built to ‘Very Good’ or ‘Excellent’ BREEAM standards.’
Infrastructure relating to waste water disposal and treatment is considered under Policy INF1.

Object

Representation ID: 7824

Received: 07/01/2024

Respondent: CPRE Rutland

It is accepted that current government policy on EPCs is as reflected here, but it is also the case that EPCs
in practice relate more to energy cost than energy performance, such that some changes or new measures
recommended to improve energy performance actually have the effect of making the EPC rating worse. There is talk of reviewing EPCs and the plan should perhaps note this possible future revision and not place too much reliance on the current EPC regime.

Comments noted regarding EPC rating. Reference to EPC rating is not set out in the Policy itself but is referenced in the supporting text. The text also sets out the Council’s intention to bring forward supplementary guidance on energy efficiency with regarding to retrofitting existing buildings. Regarding setting of efficiency targets, such as EPC rating, it is intended that further work to update the cost evidence for a number of options for the wording of CC7 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 climate change will be consulted on through the Reg 19 consultation.