Regulation 18 draft Local Plan
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Regulation 18 draft Local Plan
Policy CC2 - Design Principles for Energy Efficient Buildings
Representation ID: 6574
Received: 08/01/2024
Respondent: Distinctive Developments Group Ltd
The solar gain measures proposed in this policy are not consistent with current BRegs provisions.
Surely there is no need to repeat the BRegs provisions within planning policy?
Imposing all these measures will have an impact on viability and could result in fewer homes, particularly affordable homes, being delivered.
Object
Regulation 18 draft Local Plan
Policy CC3 - Resilient and Flexible Design
Representation ID: 6589
Received: 08/01/2024
Respondent: Distinctive Developments Group Ltd
This policy seems to be at odds with policy CC2 which encourages solar gain. The measures suggested should again be addressed via the BRegs process and do not need to be repeated or enlarged upon within planning policy. It is not stated how some of the criteria can be met/measured, which leaves it open to interpretation. The planning system needs less ambiguity and more certainty in order to support successful and timely housing delivery.
Object
Regulation 18 draft Local Plan
Policy CC4 - Net zero carbon (operational)
Representation ID: 6591
Received: 08/01/2024
Respondent: Distinctive Developments Group Ltd
This policy, as drafted, is placing an extra burden and cost on housebuilders and developers to prove the energy efficiency of new homes, which is unnecessary when this is already covered by BRegs.
Object
Regulation 18 draft Local Plan
Policy SS1 - Spatial strategy for new development
Representation ID: 6612
Received: 08/01/2024
Respondent: Distinctive Developments Group Ltd
Proposed housing delivery over the Plan period is less than the current Development Plan provides for, and yet we have a growing population. Why is Rutland relying on South Kesteven to deliver a significant element of its housing requirement? Although the policy will permit windfall development in the villages, this is unluikely to make a significant contribution to housing delivery because few sites for development remain within the PLDs. The Plan should acknowldge that people wish to live in villages; in turn this creates more sustainable communities, enhancing the vitality and helping their services, facilities and shops etc to thrive.
Object
Regulation 18 draft Local Plan
Policy H4 - Meeting all housing needs
Representation ID: 6635
Received: 08/01/2024
Respondent: Distinctive Developments Group Ltd
BRegs provide for accessibility standards; is it necessary to repeat here in planning policy?
Where a local authority or planning policy requires certain house types, sizes and tenures, it is accepted that this should be provided as long as genuine need in that particluar location can be evidenced, and viability allows the delivery of siuch homes in that location. It is unclear what constitutes up to date evidence of local housing need and how this should be approached at a local level.
Object
Regulation 18 draft Local Plan
Policy H6 – Self-build and custom housebuilding
Representation ID: 6647
Received: 08/01/2024
Respondent: Distinctive Developments Group Ltd
We support the introduction of a policy on self and custom housebuilding (SCB). However, the Local Plan does not offer up much opportunity for SCB plots since there are few plots of land available within the PLDs and development adjoing PLDs is not supported. Where will these people build their homes? The data shows that they do not wish to build a home on land which is attached to a major development scheme but would prefer an individual plot in a village location.
Object
Regulation 18 draft Local Plan
Policy H7 - Affordable housing
Representation ID: 6650
Received: 08/01/2024
Respondent: Distinctive Developments Group Ltd
The use of VBCs is set down in national planning policy and it gives developers certainty when buying previously developed land where viability is often an issue. This part of the policy should be deleted as it is covered by national policy.
What will proposals be measured against to determine whether they “meet the proven local and affordability housing need”?
Object
Regulation 18 draft Local Plan
Policy SC4– Pollution control
Representation ID: 6653
Received: 08/01/2024
Respondent: Distinctive Developments Group Ltd
This policy, as drafted, could mean that valuable brownfield sites may not be brought forward for housing development since viability may be an issue on contaminated sites. Why not just condition any planning consent in relation to contamination, as is currently the case? This policy places an unncessary upfront cost on developers at the planning application stage which again can threaten viability and ultimately housing delivery
Object
Regulation 18 draft Local Plan
Policy EN3 - Biodiversity Net Gain
Representation ID: 7148
Received: 08/01/2024
Respondent: Distinctive Developments Group Ltd
We object to this not only because it is inconsistent with the Environment Act and national policy requirements of 10%, but also because of the impacts on viability and housing delivery. The on-site provision of 15% BNG is likely to result in a reduced site density, and therefore impact viability and could be argued to be at odds with the policy on density which encourages making best use of land. Off-site provision, whilst perhaps not limiting density on the subject site, will also impact on scheme viability through the associated costs of purchasing credits. The purchase price is varied and uncertain (and not insignificant) so this in turn creates uncertainty for developers when purchasing sites. In both cases, housing delivery and affordability will suffer since the increased costs will render many schemes much less viable.
Object
Regulation 18 draft Local Plan
Policy EN13: Protecting heritage assets
Representation ID: 7149
Received: 08/01/2024
Respondent: Distinctive Developments Group Ltd
We object to this policy as it seems unnecessarily restrictive. If we are to protect and maintain historic buildings which become unsuitable for their current use or which have been disused for some time, the property owner should have the freedom to bring that building back into whatever use most suits their requirements. An owner may not wish to start a tourism or recreation business or rent the space out to another business and a residential use may be the most suitable use of their building whilst serving a housing need and freeing up an existing home for another occupier. Eg some property owners such as the elderly may need a more suitable home to meet their changing needs which they can’t find elsewhere in the village and they may not wish to leave the village if they still enjoy living there. This policy as drafted is not in the spirit of other policies in the Plan which encourage re-use of existing buildings as it could result in existing buildings not being used and create greater demand for new buildings.