Regulation 18 draft Local Plan

Object

Representation ID: 7825

Received: 07/01/2024

Respondent: CPRE Rutland

There needs to be much restraint on the use of land for renewable energy installations, in particular solar panels. There are already proposals for solar farms in Rutland which would cover far more than the Government's target for the use of land for this purpose; there must be some practical limit imposed and measures to ensure that Best and Most Versatile land remains available for agricultural purposes.

Reference is made to the installation on existing roofs. Consideration must also be given to requiring solar panels to be fitted on all new buildings, not just residential, unless there is good reason not to.

The introduction includes heat pumps in the list of possible technologies, but there seems to be no mention of these at all in the policy itself. The Council's policy on heat pumps should be made clear.

Under 'Additional matters for wind-based energy proposals', what are 'criteria (i)-(iii)'? Also the charity has concerns about how the phrase “Single small to medium wind turbines will be in principle be supported throughout Rutland” will be interpreted.

A comprehensive SPD to support development control of solar energy installations is required as part of the Local Plan and should be subject to consultation before the Regulation 18 consultation can be considered complete.

Similarly, the Wind Turbines SPD from November 2012 needs to be fully revised and consulted upon in order to ensure effective protection for the landscape of the county with respect to the location of any associated developments.

CPRE Rutland objects to this policy as currently drafted.

As national policy is to maximise renewable generation then it would not be appropriate to set a limit on area for ground mounted solar. In terms of targets, para 003 of the PPG states that ‘The National Planning Policy Framework explains that all communities have a responsibility to help increase the use and supply of green energy, but this does not mean that the need for renewable energy automatically overrides environmental protections and the planning concerns of local communities.’ It also states that: ‘The UK has legal commitments to cut greenhouse gases and meet increased energy demand from renewable sources. Whilst local authorities should design their policies to maximise renewable and low carbon energy development, there is no quota which the Local Plan has to deliver.’ The Rutland Renewable Energy Study that identifies areas of opportunity for potential solar pv and wind turbine generator developments excluded Grades 1 and 2 in the Agricultural Land Classification (ALC). For solar pv developments Policy CC8 includes a criterion that sets a number of additional tests where the proposal is on Best and Most Versatile agricultural land (Grades 1, 2 and 3a in the ALC.). This is in line with para 180 of the NPPF that recognises the economic and other benefits of the best and most versatile agricultural land.

There is a presumption in favour of granting permission for solar panels on all existing buildings set out in Policy CC8 and this is also supported and encouraged in policy documents such as the NPPF and PPG, the National Design Guide (2021), Design Guidelines for Rutland (2021) and also in Local Plan Policy CC7. Policy CC2 seeks to maximise renewable energy generation on new build.

ASHPs are often permitted development (particularly on existing dwellings) but where planning permission is required such proposals would be supported under Policies CC2, CC7 and CC8.

Agree. Criteria (i) – (iii) should read criteria a) – c). The support in principle for single small to medium wind turbines in the policy accords with national planning policy, and the wording of CC8 makes it clear that such proposals would still be assessed against criteria a) – c).

Policy CC8 includes reference to a SPD as part of the assessment under criteria a). This would update the current Wind Turbines SPD that will no longer form part of the Local Plan. Consultation with this revised SPD would be carried out as part of the Local Plan consultation process and in accordance with the Council’s Statement of Community Involvement. It would become a material consideration in determining planning applications for renewable energy developments. `

Object

Representation ID: 7826

Received: 07/01/2024

Respondent: CPRE Rutland

Is there a requirement for some form of Carbon Sink Net Gain approach? Otherwise, how can we actually know whether a development will result in adding or removing carbon?

Comments noted. Policy CC11 requires a proportionate evaluation of the impact of the development on the carbon sink and seeks to reduce harm of carbon sink loss to a minimum, supporting proposals that strengthen carbon sinks. It would not be appropriate or proportional to always require a carbon sink net gain and this would also need to be part of the viability assessment of the policy (which may form part of the updated viability assessment to inform the Reg 19 Plan.)

Object

Representation ID: 7827

Received: 07/01/2024

Respondent: CPRE Rutland

Is there a requirement for some form of Carbon Sink Net Gain approach? Otherwise, how can we actually know whether a development will result in adding or removing carbon?

Comments noted. Policy CC12 gives material weight where there is significant gain in nature-based carbon sequestration and weight against where there is harm. This is a proportionate approach. It would not be appropriate or proportional to always require a carbon sink net gain and this would also need to be part of the viability assessment of the policy (which may form part of the updated viability assessment to inform the Reg 19 Plan.)

Object

Representation ID: 7828

Received: 07/01/2024

Respondent: CPRE Rutland

Are facilities required for charging e-bikes/scooters safely, not just storing them? Should there be more emphasis on charging points in public car parks, supermarket car parks, etc.

How will progress towards net-zero be measured?

Comments noted. The charging of e-bikes/scooters would normally be carried out indoors and so would fall outside the scope of the Local Plan. Policy CC13 supports proposals that go beyond the requirements of current Building Regulations and Appendix 5 sets out the standards for charging points in commercial developments. The provision of charging points in public car parks would fall outside the remit of the Local Plan as such provision would normally constitute permitted development.

Object

Representation ID: 7829

Received: 07/01/2024

Respondent: CPRE Rutland

It would not seem unreasonable to expect this chapter to state clearly what the Spatial Strategy actually is. As written, it is simply a collection of policies, although some of the material in those policies might be better forming part of the strategy. The strategy should, in principle, set out the intentions regarding all possible uses of the land and the corresponding implications for transport and other infrastructure, and the policies should then derive from this. This point was made in comments on the earlier consultation on the Issues and Options Paper.

Comments noted - It is felt that the Vision and objectives chapter does this however some additional text can be added to the introduction of this section setting out linking to the Vision and Objectives and the spatial strategy set out in policy SS1

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: 7831

Received: 07/01/2024

Respondent: CPRE Rutland

Policy SS4 is inconsistent with Policy SS1 and greatly increases the scope for development in the small villages beyond that indicated by Policy SS1.

Disagree that PLDs have not been defined for the small villages and hamlets. Planned limits should be retained.

Policy SS4 is most likely to lead to a massive increase in the development of small sites, mostly around the
periphery of the small villages.
If small villages and hamlets should have incremental growth, then the planned limits should be reappraised. The PLD’s as already defined for the small villages should remain as they stand at present.

Conditions (a) to (g), because of their lack of clarity and the very different interpretations which can be placed
upon them, will impose an impossible determination task on Development Control and is confusing and does not protect the countryside.

Concern noted. policy to be revised to provide greater clarity and certainty.

Object

Representation ID: 7832

Received: 07/01/2024

Respondent: CPRE Rutland

Planned Limits of Development (PLD) are a Material Planning Consideration when determining applications for new build and extensions in the small villages. There is a presumption against planning consent for developments outside of the planned limits of development. PLD’s therefore have a most important role in preventing continuous expansion and enlargement of small villages, and also in ensuring that unauthorised development is not permitted in the open countryside which by definition lies beyond the immediate boundary of the PLD. Some villages, furthermore, might wish to retain their PLD.

It is not clear that removing PLDs has ever been asked for in community feedback; if it has, this needs to be brought
out clearly. The only evident reference to such a move is in the Spatial Strategy Evidence Report, which assumed that PLDs would be removed from smaller villages but did not actually recommend such a change.

Comments noted.
It is considered that policy SS4 (now SS3) provides sufficient restrictions to prevent large scale development in small villages whilst allowing for appropriate small scale infill and redevelopment. It should be noted however that the policy has been amended in response to other representations.

Object

Representation ID: 7853

Received: 07/01/2024

Respondent: CPRE Rutland

Housing development on this site of up to 500 dwellings would account for a considerable proportion of
the assessed housing need. The strategy for, and the implications of, such development should be set out clearly, in particular the impact on overall housing numbers and the possible deletion of other sites if this development should go ahead. The site could, presumably, also be used for non residential purposes, such as renewable energy facilities, academic research, etc. The policy should allow for such options to be considered.

In the light of the previous proposals for the St George's Barracks site, there presumably remains a significant risk that the MoD will not relinquish the site in the timescales identified. There will also be significant costs in redevelopment, as was established previously. These implications should be spelt out in the current Plan.

Should development of the site go forward, it is not clear whether it will form a new settlement, rather than being
regarded as an extension of Edith Weston; it would, in any case, be outside the existing PLD for the village and would
represent a substantial expansion on its immediate boundary but, again, it should be made clear.

Comments noted. Identifying St George's Barracks as a Future Opportunity Area provides a framework to ensure that any future development is sustainable and holistically planned and address the issues raised. The Woolfox site will also be identified as a Future Opportunity Area in the Regulation 19 Plan.

Object

Representation ID: 7854

Received: 07/01/2024

Respondent: CPRE Rutland

Last sentence should refer to SS7, not SD6.

Agree typo in last sentence of policy. Note SS7 is now SS6.