Regulation 18 draft Local Plan

Support

Representation ID: 6588

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.

The Council have used the emerging Local Plan to highlight the importance of identifying sufficient land to deliver housing and for that land to be capable of delivery without delay following the grant of permission. The DIO supports this statement and advocates the need to plan positively for the delivery of housing within Rutland that provides opportunities for all residents and levels of affordability.

Support noted.

Object

Representation ID: 6592

Received: 08/01/2024

Respondent: Defence Infrastructure Organisation (DIO)

Agent: Montagu Evans LLP

Policy H1 includes a list of reserve sites which are all on greenfield land. The DIO does not support this approach and believe the Council should consider the available supply of brownfield sites in the area including St George's Barracks. This is particularly relevant considering Reserve Site H1.b – Land North of Pennine Drive, Edith Weston, which has been identified for 84 dwellings. This site is located to the immediate north of the St George’s Barracks main site. The DIO believe development of this land would be contrary to national policy and the strategic objectives of the draft Local Plan.

All site appraisals have been reviewed in the light of comments and further evidence received to determine their suitability for allocation.

Object

Representation ID: 6593

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.
The DIO wish to highlight that there is currently a difference between the minimum density specified in draft Policy H3 of 25 dwellings per hectare, and the density used for the site capacity exercise at emerging Policy H1 – which uses 30 dwellings per hectare. The Council should ensure that there is a robust and consistent approach within the Local Plan.

Comments noted. NPPF recommends the use of minimum density standards in policies and suggests that a range of densities may be appropriate to reflect different local circumstances.
the Core Strategy sets a minimum of 30 for the villages and 40 for the towns. Monitoring suggests that this has not always been achieved and therefore the policy has been written to allow flexibility to reflect local circumstances and existing development patterns whilst ensuring that a minimum density is established.
The indicative capacity of allocated sites is based upon 30 dph as these sites have been assessed as being suitable for development and free from constraints which may reduce the capacity.

Object

Representation ID: 6595

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.
The DIO supports Policy H7 which identifies the requirement for 30% affordable housing, with a mix of unit sizes and affordable tenures, subject to appropriate assessment of viability. The DIO note that not all development proposals will be viable due to a number of factors such as abnormal costs related to demolition and site remediation. The Council should amend the wording of the Policy to reflect this.

Noted. Viability is already taken account of through the Whole Plan Viability Assessment and the provision in Policy H7 for site-specific viability assessments in exceptional circumstances and for consideration of Vacant Building Credit. Further provision for viability is unnecessary until a site-specific DPD is prepared further to Policy SS5.

Object

Representation ID: 6597

Received: 08/01/2024

Respondent: Defence Infrastructure Organisation (DIO)

Agent: Montagu Evans LLP

There is currently inconsistency in the wording used within the Plan, as emerging Policy H10 refers to an Action Plan, which is inconsistent with other draft policies in the Plan. For completeness, the DIO believe that the reference to an Action Plan Development Plan document should be removed from this policy. The DIO request that a consistent approach is adopted by the Council to future development at St George’s Barracks.

The reference to a DPD Action Plan for St George's Barracks highlights the importance of providing traveller sites and is appropriate.

Support

Representation ID: 6599

Received: 08/01/2024

Respondent: Defence Infrastructure Organisation (DIO)

Agent: Montagu Evans LLP

DIO are supportive of the Council’s objectives to create sustainable communities and well-designed places. The Local Plan should protect community facilities in sustainable locations and the provision of new local community services and facilities where there is an identified need alongside new development. The DIO are supportive of open space requirements to meet the needs of occupiers and will work with Rutland Council and the local community to ensure the St George's Barracks site is developed to a high standard to create an inclusive and sustainable new community.

Support noted

Object

Representation ID: 6601

Received: 08/01/2024

Respondent: Defence Infrastructure Organisation (DIO)

Agent: Montagu Evans LLP

Policy SC3 is supported, but comments are made in relation to Part 2 of the policy on the approach to designing streets and spaces within developments. The thrust of policy is supported as the design matters outlined are intended to lead to the creation of high-quality spaces, however, it is important to consider these within a practical context and the ability for such an approach to be supported by the local highway authority without leading to significant financial payments to support the adoption of streets and spaces.

Support noted. Practical aspects such as site constraints are addressed under part 3 c) of this policy.

Object

Representation ID: 6603

Received: 08/01/2024

Respondent: Defence Infrastructure Organisation (DIO)

Agent: Montagu Evans LLP

Policy SC6 is supported in principle however here are concerns relating to the application of Part (i) of the policy which relates to the need for applications for new facilities in larger schemes to be accompanied by a robust business plan and governance arrangements.

This will not be possible for all developments, especially those of a strategic nature where the end developer, operator and user of the facility will not be known or in a position to provide such information. This level of information goes beyond what would normally constitute a material planning consideration and should be removed from policy.

Noted and agreed. Clarification added to criterion i) that this would apply to a Full or Reserved Matters application as it is considered that this level of detail would be available at this stage.

Object

Representation ID: 6606

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 SC7 is supported in principle, however the level of information sought within the Policy is very detailed and would normally be expected to be approved via suitably worded conditions (e.g., Part (g) materials, equipment RoSPA accredited inspections, etc for play equipment) or s106 Obligations (e.g., funding strategies for future maintenance). These are not Policy related matters and should be removed from the policy if it is to be found sound.

Comments noted. This level of detail is important for the consideration of planning applications which involve the loss or provision of new open space and sports facilities, but the policy can be amended to be clearer on when this detail should be expected.

Support

Representation ID: 6608

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.

The DIO are supportive of the Council’s vision and objectives and encourage the protection and enhancement of the existing natural environment. New planning policies should accord with national planning policy and legislative requirements and avoid duplication where possible.

Support noted.