Regulation 18 draft Local Plan
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Regulation 18 draft Local Plan
Chapter 1 – Introduction
Representation ID: 6749
Received: 05/01/2024
Respondent: Barrowden Parish Council
BPC recognises the need to review their Barrowden and Wakerley Neighbourhood Plan 5 years after adoption, i.e. commencing in 2024.
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
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.
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
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.
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
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.
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
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.
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
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.
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
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?
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
SS2
We question whether this statement is redundant as the requirement for Design & Access Statements is specified within the NPPF
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
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
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
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.
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.