Regulation 18 draft Local Plan

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Support

Regulation 18 draft Local Plan

Chapter 1 – Introduction

Representation ID: 6749

Received: 05/01/2024

Respondent: Barrowden Parish Council

Representation Summary:

BPC recognises the need to review their Barrowden and Wakerley Neighbourhood Plan 5 years after adoption, i.e. commencing in 2024.


Our response:

Support noted. A review would also take into account changes to national and local planning policy that have taken place since the NP was ‘made’.

Support

Regulation 18 draft Local Plan

Policy CC1 - Supporting a Circular Economy

Representation ID: 6751

Received: 05/01/2024

Respondent: Barrowden Parish Council

Representation Summary:

But are concerned that regardless of size, householder applications for extensions and alterations should be exempt from Design and Access Statements.

We would ask that in Conservation Areas where an extensions or alterations involves construction for two storeys or more, a D & A Statement, should be provided.
This is in line with the existing requirement for all new builds in Conservation Areas.

The reason for seeking such a requirement is to ensure that larger extensions and alterations properly consider layout in relations to surrounding buildings, the scale of the development, landscaping, appearance, context in relation to the neighbourhood plan, consultation with local community, proposed use and access and parking requirements.


Our response:

Support for Policy CC1 noted. Design and Access Statements are legally required to accompany planning applications for certain types of development but (unless a listed building) are not required for householder applications. It would not, therefore, be appropriate to include their requirement under this policy.

Object

Regulation 18 draft Local Plan

Policy CC2 - Design Principles for Energy Efficient Buildings

Representation ID: 6752

Received: 05/01/2024

Respondent: Barrowden Parish Council

Representation Summary:

CC2
There appears to be a contradiction between these two policies in that CC2 seeks “.. to optimise opportunities for solar gain..”, whereas Page 81 CC3 should “.. prevent overheating..”

We would ask that these policies are clarified and examples of how developer can optimise solar gain while preventing overheating.


Our response:

Agree some contradiction. The two policies are seeking to achieve design solutions that manage solar gain whilst preventing overheating – a balance between the two is required. There are significant benefits in solar gain in terms of heating and solar panel efficiency particularly in the winter months but these must be balanced against the harmful risks of overheating. The National Design Guide (2021) has useful advice: ‘Well-designed buildings make the most of passive design strategies to minimise overheating and achieve internal comfort. These include: the layout and aspect of internal spaces; insulation of the external envelope and thermal mass; management of solar gain; and good ventilation to reduce overheating.’

Object

Regulation 18 draft Local Plan

Policy CC3 - Resilient and Flexible Design

Representation ID: 6753

Received: 05/01/2024

Respondent: Barrowden Parish Council

Representation Summary:

There appears to be a contradiction between these two policies in that CC2 seeks “.. to optimise opportunities for solar gain..”, whereas Page 81 CC3 should “.. prevent overheating..”

We would ask that these policies are clarified and examples of how developer can optimise solar gain while preventing overheating.


Our response:

Disagree. Subject to change to Policy CC2 part a) to read: orientation of buildings such as to manage opportunities for solar gain and to minimize winter cold wind heat loss’, the two policies are seeking to achieve design solutions that manage solar gain whilst preventing overheating – a balance between the two is required. There are significant benefits in solar gain in terms of heating and solar panel efficiency particularly in the winter months but these must be balanced against the harmful risks of overheating. The PPG on climate change advises that when preparing Local Plans, authorities should pay particular attention to mitigation and adaptation. Examples include maximising summer cooling and avoiding solar gain. Requiring applicants to consider how buildings can minimise overheating is therefore justified in seeking to secure high quality design and higher levels of efficiency in new construction. The National Design Guide (2021) has useful advice: ‘Well-designed buildings make the most of passive design strategies to minimise overheating and achieve internal comfort. These include: the layout and aspect of internal spaces; insulation of the external envelope and thermal mass; management of solar gain; and good ventilation to reduce overheating.’

Support

Regulation 18 draft Local Plan

Policy CC7 - Reducing Energy Consumption in Existing Buildings

Representation ID: 6754

Received: 05/01/2024

Respondent: Barrowden Parish Council

Representation Summary:

We fully support the retrofitting of energy efficient measures in listed buildings and buildings in Conservation Areas but would ask that there should be a presumption in favour of such improvements with the appropriate caveats to safeguard the historical aspects of listed buildings.

There is a typo in the Policy, second last line, the “in” is not required.


Our response:

Support and typo noted. The part of the policy on retrofitting is positively worded (‘will be expected’) but flexibility in the policy is required meaning that a presumption in favour would not be appropriate given that where heritage assets are concerned, improvements in efficiency should be consistent with the asset’s significance and consistent with relevant national planning policy and with other Local Plan policies on the built environment.

Object

Regulation 18 draft Local Plan

Policy CC14 - Flood Risk

Representation ID: 6755

Received: 05/01/2024

Respondent: Barrowden Parish Council

Representation Summary:

This Policy is ambiguous and needs to be made clearer. It can be read that the policy only applies to major developments which should not be the case.

The use of “where appropriate “ is far too loose and needs to have further clarity either in terms of size of development or size in relation to the plot or total hard surfaced area in relation to the plot size. The B & W Neighbourhood Plans in Policy BW7 has a simple statement which should be used in the Local Plan.


Our response:

Comments noted. Agree to remove ‘major’ from first sentence in the policy. Disagree regarding use of ‘where appropriate’ as not all development proposals will be required to show that the list of criteria have been addressed. Detailed guidance on the requirements in relation to flood risk to accompany a planning application is set out in the NPPF/PPG. The wording of NP Policy BW7 follows that of the longer Local Plan Policy CC14 and the two policies would be used in the assessment of applicable planning applications.

Object

Regulation 18 draft Local Plan

Policy SS1 - Spatial strategy for new development

Representation ID: 6759

Received: 05/01/2024

Respondent: Barrowden Parish Council

Representation Summary:

We note the inclusion of Barrowden within the Larger Village Group. Is the condition for the release of land sufficiently strong in relation to the work being undertaken “normally” through the Local Plan review?

Is the only other occasion when such development would be approved would be due to lack of supply in the County?


Our response:

Comments noted, these are addressed in policies SS2 and SS3.

Object

Regulation 18 draft Local Plan

Policy SS2 - Requirements for planning applications

Representation ID: 6760

Received: 05/01/2024

Respondent: Barrowden Parish Council

Representation Summary:

SS2
We question whether this statement is redundant as the requirement for Design & Access Statements is specified within the NPPF


Our response:

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

Support

Regulation 18 draft Local Plan

Policy SS3 – Development within Planned Limits of Development

Representation ID: 6761

Received: 05/01/2024

Respondent: Barrowden Parish Council

Representation Summary:

We support the proposed modifications to the Planned Limits of Development.

However we are concerned about the lack of a Policy statement regarding Backland Developments, We ask that a statement similar to that used in the Barrowden and Wakerley Neighbourhood Plan Policy BW8 be incorporated in the Local Plan


Our response:

Support noted. Any backland development proposed with be subject to Policy SC2 and SC3

Object

Regulation 18 draft Local Plan

Policy SS5 – St. George's Barracks Opportunity Area

Representation ID: 6762

Received: 05/01/2024

Respondent: Barrowden Parish Council

Representation Summary:

We support the development of St George’s Barracks on a more extensive basis than up to 500 homes.

It has the opportunity if properly developed to provide all the housing and employment required in Rutland over a 20 year period as a properly designed new self sufficient new town and with facilities which could be used by other residents in Rutland such as medical and sports facilities, etc.


Our response:

Support noted. The approach taken in the Local Plan for the location of new housing is for a wider spread of development across the communities rather than for a large scale site whilst acknowledging that SGB and similarly Woolfox, may be appropriate for meeting some future development needs either during this plan period and/or beyond. 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.

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