Regulation 18 draft Local Plan

Support

Representation ID: 6531

Received: 08/01/2024

Respondent: Defence Infrastructure Organisation (DIO)

Agent: Montagu Evans LLP

The DIO support the Council’s proposed strategic objectives and encourage the draft policies which respond to climate change, the delivery of sustainable, prosperous and well-designed communities, with appropriate housing and employment opportunities. The DIO believe that the delivery of residential-led development on a brownfield site at St George’s Barracks and the Officers Mess supports the Council’s objectives. Development on previously developed land and opportunities for the re-use of existing buildings aligns with a circular economy and carbon reduction. Redevelopment of these sites will provide an appropriate level of growth proportionate in scale to the local area and County.

Support noted.

Support

Representation ID: 6547

Received: 08/01/2024

Respondent: Defence Infrastructure Organisation (DIO)

Agent: Montagu Evans LLP

Comments made on behalf of the Defence Infrastructure Organisation (DIO) as part of a full written response to Rutland Council. Representations should be read in context and not in isolation.

The DIO are supportive of the Council’s objective to tackle the climate crisis and ensure that development takes a proactive approach to carbon reduction, in line with national policy.

There are points of detail within the policies of this section, that need to be reviewed to ensure there is no duplication with other legislation (including Building Regulations and Future Homes Standards) or other policies within the emerging plan.

Support noted in relation to overall strategy on climate change. Responses on specific policies set out under individual policies.

Object

Representation ID: 6550

Received: 08/01/2024

Respondent: Defence Infrastructure Organisation (DIO)

Agent: Montagu Evans LLP

Comments made on behalf of the Defence Infrastructure Organisation (DIO) as part of a full written response to Rutland Council. Representations should be read in context and not in isolation.

The DIO are of the opinion that there are points of detail within the Policy which should be reviewed to avoid duplication. For example Policy CC2 makes reference to there being no mains-gas connection in new development, which is already prohibited from 2025 under the Future Homes Standard.

Support noted. RCC has declared a Climate Crisis and the Corporate Strategy recognises the urgency of reducing the county’s carbon footprint. A regulatory framework is also required, including through the planning and building regulations systems, and progress is being made with the proposed climate change policies in the local plan and the Future Homes and Buildings Standards currently being drawn up.

Object

Representation ID: 6557

Received: 08/01/2024

Respondent: Defence Infrastructure Organisation (DIO)

Agent: Montagu Evans LLP

Comments made on behalf of the Defence Infrastructure Organisation (DIO) as part of a full written response to Rutland Council. Representations should be read in context and not in isolation.

Emerging Policy CC5 currently requires proposals to provide a “full justification for the demolition” of a building but does not provide guidance on what the Council expects applicants to submit. It would be useful for the Council to outline the minimum level of information expected in this Policy and/or indicate whether an SPD would be prepared on this issue and adopted in line with the Plan to support this matter.

Comments noted. RCC may wish to consider guidance notes and templates to assist in the drawing up and assessment of Justification Statements to help with the interpretation of the policy, similar to that available to support the policies in the adopted Central Lincolnshire Local Plan.

Object

Representation ID: 6564

Received: 08/01/2024

Respondent: Defence Infrastructure Organisation (DIO)

Agent: Montagu Evans LLP

Policy CC8 is supported in principle, including the need to engage with relevant stakeholders in relation to the potential impact upon aviation and defence navigation system/communications. However, not all renewable energy technologies would give rise to the issues that the policy is requiring developments to assess, for example solar and battery electrical storage systems (“BESS”) has no impact upon radar. Part B of the Emerging Policy should be amended to remove the “and” which would allow matters to be addressed only where the scheme is likely to give rise to such issues. The Policy should be reduced in length.

Comments noted. Disagree regarding part b) as the policy goes on to state that: ‘Compliance with part (b) above will require, for relevant proposals, the submission…….
Agree that the policy is somewhat long but it benefits from covering all types of renewable energy proposals. If broken up the separate policies would contain a lot of repetition and there would need to be several policies for each of the energy types.

Object

Representation ID: 6566

Received: 08/01/2024

Respondent: Defence Infrastructure Organisation (DIO)

Agent: Montagu Evans LLP

It is important for the Council to recognise all of the available brownfield development opportunities that are available, achievable and deliverable for housing within emerging Policy SS1 and to include the St George’s Barracks Growth Area. Not doing so, means that Policy SS1 is inconsistent with the other policies of the plan as well as the NPPF’s emphasis of taking a brownfield first approach to delivering development that boosts significantly the supply of housing.

This amendment is a necessity if the next version of the plan is to be considered Sound.

Comments noted. Include reference to St Georges Barracks and Woolfox Opportunity Areas within the Spatial Strategy (Policy SS1d)

Object

Representation ID: 6569

Received: 08/01/2024

Respondent: Defence Infrastructure Organisation (DIO)

Agent: Montagu Evans LLP

Comments made on behalf of the DIO as part of a full written response to Rutland Council. Representations should be read in context and not in isolation.
Policy SS2 is not needed as it is covered by both the national and local level validation requirements and does not set anything by which development can be assessed as compliance is simply met by having a valid application. Should the Council wish to include such guidance then it should be in the form of supplementary guidance or as supporting text within the Local Plan. The Policy should be removed.

Agree the policy as written does not provide criteria against which a planning application can be assessed and largely reflects national guidance.
However it is useful for the local plan to clearly set out what is expected for the submission of planning applications and it is therefore suggested that the policy becomes supporting text within the plan

Object

Representation ID: 6573

Received: 08/01/2024

Respondent: Defence Infrastructure Organisation (DIO)

Agent: Montagu Evans LLP

Through Policy SS3, the proposals map for the draft Local Plan should include a new PLD boundary specifically for the brownfield (previously developed) land at St George’s Barracks. The main barracks site is a large development area which will become vacant from 2026. As such, a meaningful future use of the site will be required to avoid it remaining vacant.

A PLD boundary for the brownfield land at St George’s Barracks would help to guide future policy, planning guidance or development proposals brought forward on the Site and help to deliver homes that do not encroach towards Edith Weston.

St George's Barracks is not allocated for development in the plan although it is identified as a Future Opportunity Area. This is because there are a number of uncertainties about the scale and nature of development on the site. It would not be appropriate to draw a PLD around the Barracks before the developable area has been defined.
The PLD around Edith Weston is considered the most appropriate and up-to-date delineation between the built framework of the village and surrounding military infrastructure and open countryside, drawn in accordance with methodology established by the PLD Review Study 2023. At criterion In.F the methodology for this study specifically

Support

Representation ID: 6576

Received: 08/01/2024

Respondent: Defence Infrastructure Organisation (DIO)

Agent: Montagu Evans LLP

The DIO are supportive of the thrust of emerging Policy SS6 and the support the Council are giving for these sites. To assist with the implementation of this policy and potential changes in Government agendas, it is suggested that the wording of the policy is amended to make reference to “the use of military bases and other secure residential establishments for operational or other purposes.” Clarification is required to confirm the works that need planning permission, or those which can be undertaken through Crown Permitted Development Rights.

Support noted. Agree to rename policy to: ‘Use of military bases and other secure residential establishments for operational or other purposes’.
Agree clarification on PD rights would be appropriate. Add in: The MOD, as a Crown body, also has permitted development rights on Crown Land whereby planning permission would not be required for certain types of development and so Policy SS6 would not be applicable.

Support

Representation ID: 6583

Received: 08/01/2024

Respondent: Defence Infrastructure Organisation (DIO)

Agent: Montagu Evans LLP

DIO support the policy given the strategic nature of these sites. The DIO are not opposed to the requirement for a masterplan or development brief and endorses the need for the Council to have a role in bringing forward development on sites of a strategic nature. The DIO support the suggestion of the use of Supplementary Planning Documents for sites which are yet to be identified and considered for major development.

Support noted.