Regulation 18 draft Local Plan
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Regulation 18 draft Local Plan
Policy H1 – Sites proposed for residential development
Representation ID: 7661
Received: 08/01/2024
Respondent: South Luffenham Parish Council
Site Allocation Assessment: Appendix C -larger Villages SHLAA SOU 02 Site ID 50 Development Agricultural Land Grade 3 -North of A6121 Stamford Road. States Indicative Capacity 44 based on Standard Calculation in SH LAA methodology. In the Conclusion however 152 dwellings are indicated in the report, is this a typo as based on 152 dwellings this number would be disproportionate to the present number of dwellings in South Luffenham and present significant unrealistic pressures on current infrastructure and access to the current road system.
All site appraisals have been reviewed in the light of comments and further evidence received to determine their suitability for allocation.
Object
Regulation 18 draft Local Plan
Strategic Objective 1:
Representation ID: 7662
Received: 08/01/2024
Respondent: South Luffenham Parish Council
Plan appears to concentrate on National guidelines, the plan only addresses new build developments and not existing dwellings which rely heavily on carbon generated fuels.
It is beyond the remit of the Local Plan to impose requirements on existing buildings. However, proposals for new development related to existing buildings will be expected to demonstrate increased energy efficiency. In addition, retrofitting of energy efficiency measures and micro-renewables are supported under Policy CC7 (Chapter 4 - Climate Change).
Object
Regulation 18 draft Local Plan
Strategic Objective 2:
Representation ID: 7663
Received: 08/01/2024
Respondent: South Luffenham Parish Council
Strategic objective 2- Sustainable Development Population increases – but while indicating current primary/secondary education facilities does not address how population increases and housing developments will impact on existing amenities. In addition, current healthcare facilities currently struggle to meet patient demands.
Support noted.
Alongside the Local Plan, an Infrastructure Delivery Plan is being established which brings together a range of data from infrastructure providers to help ensure that the right infrastructure is prioritised. Additionally, at the planning application stage the relevant bodies would be consulted on and additional provisions would be secured through CIL and S106 agreements if required. Policy INF4 includes the allocation of a new Medical Centre in Empingham.
Object
Regulation 18 draft Local Plan
Strategic Objective 10:
Representation ID: 7664
Received: 08/01/2024
Respondent: South Luffenham Parish Council
The plan while indicating the most viable centres i.e. Oakham, Uppingham and Stamford for housing development is does not address the impact on neighbouring villages for increased traffic if Rutland is a net exporter of a labour to areas outside the county.
Comments noted. The impact on the road network of major housing schemes (as set out in a Transport Assessment) would be assessed as part of the planning application process.
Object
Regulation 18 draft Local Plan
Policy CC1 - Supporting a Circular Economy
Representation ID: 7665
Received: 08/01/2024
Respondent: South Luffenham Parish Council
Plan concentrates on new build developments and reducing waste. As new development will only realise 10% growth of new homes over a 20-year period, more survey work should be undertaken on the existing household recycling and how that service could be improved. How will this be managed, resources required to audit, the Council are already stretched in terms of Highways inspectors for example. More Building control inspectors would be required to monitor the new developments.
Policy CC1 aims to complement policies in Chapter 10: Minerals and Waste where the management of household waste, including recycling, across the County is dealt with. The principles of the Circular Economy are referenced in Chapter 10. It is not the role of the Local Plan to consider staffing implications of policies.
Object
Regulation 18 draft Local Plan
Policy CC2 - Design Principles for Energy Efficient Buildings
Representation ID: 7666
Received: 08/01/2024
Respondent: South Luffenham Parish Council
Plan concentrates on new build developments and building to almost “Passivhaus” standards. Consideration should be given to existing building stock in reducing heat losses and energy usage of primary fuels i.e. gas/oil/electric
Noted. One of the objectives in the Council’s Corporate Strategy is to reduce carbon emissions but the Local Plan has no influence over domestic retrofitting, or the financing, of insulation/changes from primary fuels where such alterations do not require planning permission.
Object
Regulation 18 draft Local Plan
Policy CC3 - Resilient and Flexible Design
Representation ID: 7667
Received: 08/01/2024
Respondent: South Luffenham Parish Council
The plan looks at designs to reduce overheating and negate the use of air conditioning. The use of ASHP’s to reduce carbonisation by 2030 within new developments would by its nature provide cooling via underfloor heating or buildings will have to be designed to reduce heat gains via orientation or use thermal mass, which might be at variance with the plan for affordability housing. Where large sites are proposed consideration should be given to ground source heat pumps system serving multiple dwellings.
Comments noted. Maximising the generation of energy from ASHPs and ground source heat pumps would be encompassed in part f) of CC2 and both are included in the list of renewable energy technologies in the introductory text to Policy CC8.
Object
Regulation 18 draft Local Plan
Policy CC4 - Net zero carbon (operational)
Representation ID: 7668
Received: 08/01/2024
Respondent: South Luffenham Parish Council
Roof mounted PV is mentioned for any new development, what consideration or derogation was considered where development falls within conservation areas. Building Control/management can this be undertaken with existing resources?
Comments noted. Agree that weight must be given, in terms of design, to the character of the location of the development and to other Local Plan policies such as EN12 and EN13, and other guidance such as the National Design Guide (2021) and Design Guidelines for Rutland SPD (2021). It is suggested that RCC may wish to consider guidance notes and templates to assist in the drawing up and assessment of Energy Statements to help with the interpretation of the policy by developers and planning staff.
Object
Regulation 18 draft Local Plan
Policy CC5 - Embodied Carbon
Representation ID: 7669
Received: 08/01/2024
Respondent: South Luffenham Parish Council
More prevalent to a barn conversion, where the existing structure is retained.
Comment noted. The policy, as well as seeking to reduce wastage of embodied carbon as a result of demolition, also seeks to decarbonise the construction of new buildings by reducing the carbon content of the construction materials that are used.
Object
Regulation 18 draft Local Plan
Policy CC6 - Water Efficiency and Sustainable Water Management
Representation ID: 7670
Received: 08/01/2024
Respondent: South Luffenham Parish Council
Plan concentrates on efficiencies and management but does not address the failings of a Victorian water infrastructure that gives rise to leaks and wastage and reduced water pressure. South Luffenham has only recently (summer 2023) been upgraded to MDPE to replace the life expired asbestos pipework. As the water authority is a private body there appears little joined up approach to overhauling the water infrastructure.
Comments noted. Policy CC6 establishes a series of principles for sustainable water management. Requirements for infrastructure relating to waste water disposal and treatment is considered under Policy INF1 and addressing leaks is the responsibility of the Water Companies rather than through a policy in the Local Plan.