Regulation 18 draft Local Plan

Support

Representation ID: 5868

Received: 06/01/2024

Respondent: RCC Expert Panel on Carbon Reduction

2. Conservation Areas

Section c) should emphasise the conservation of traditional features such as kerbstones and limestone walls which should be retained and replaced if necessary, as key features of the Conservation Area.

Section e) should replace “aim to protect trees...” with “protect trees ...”.

Support for policy noted. Traditional features such as limestone walls are included within 'materials' in section 2c. We will retain 'aim to' as policy wording has to be deliverable, and has to be positively worded.

Support

Representation ID: 5869

Received: 06/01/2024

Respondent: RCC Expert Panel on Carbon Reduction

This policy should be cross-referenced with both CC1 and CC5 in terms of the re-use of existing buildings and the management of demolition based on the circular economy.
It also needs to reference the calcareous grassland as this is the largest area of that Priority habitat in Rutland.

RCC should work with the Leicestershire and Rutland Environmental Records Centre to ensure the calcareous grassland is confirmed as a Local Wildlife Site as soon as possible.

Add a clause to ensure that the waste water management prevents increased nutrient enrichment and restricts storm water discharges into the Lyndon Brook.

Support noted. For reasons of clarity, Policy SS5 (now SS4) does not cross-reference to other policies: instead criteria p) sets out that the masterplan will be expected to detail how the scheme meets the other policies in the Local Plan. This means that the policy is clear that it should not be read in isolation. Discussions are ongoing with conservation bodies regarding the status and potential protection of the calcareous grassland on the site.

Support

Representation ID: 5870

Received: 06/01/2024

Respondent: RCC Expert Panel on Carbon Reduction

Section c) should add “include trees and other natural elements such as water, and cross reference to Green Blue Infrastructure and storm water attenuation.”
They should be integrated into shape and character of the development through the use of swales, rain gardens and ponds. The Cambridgeshire Local Plan emphasises the important links between GBI and biodiversity, with many good examples.

Comments noted. Amend text to link in GBI.

Object

Representation ID: 5871

Received: 06/01/2024

Respondent: RCC Expert Panel on Carbon Reduction

This policy should prioritise biodiversity as the main aim of restoration and aftercare.

Sections a) to e) are too general, make no distinction between size of sites, make no mention of Priority habitats, and omit to fully recognise the Leicestershire and Rutland Biodiversity Action Plan, and the Natural Character Areas. The Leicestershire Mineral Plan provides a good local example of a more specific and differentiated plan.

So sections a) to e) should be replaced by detailed suggested policy change provided in full submission based o the following:
“There should be a presumption in favour of restoration for biodiversity and carbon sequestration. Site restoration shall attain a net gain in biodiversity.........

Policy MIN9 does prioritise biodiversity as an after-use, requiring the restoration of temporary minerals and waste development to provide at least 10% Biodiversity Net Gain (BNG), a mandatory requirement under the Environment Act (2021). The Leicestershire and Rutland BAP and priority habitats, Landscape Character Areas and carbon sequestration are recognised through the plan and its policies. Restoration afteruse will be taken into account on a site-by-site basis in line with the RLP policies and other relevant policies; it is not a case of one size fits all. Restoration must be sympathetic to the landscape character of the area and enhance the site. The existing characteristics of the site, ecological linkages, blue and green infrastructure networks, setting within the local and wider landscape and built environment, together with the needs and requirements of the local community, will need to be taken into account when considering the most appropriate restoration after-use(s).

Object

Representation ID: 6951

Received: 06/01/2024

Respondent: RCC Expert Panel on Carbon Reduction

Rutland County Council (RCC), in using phrases like “highest possible”, “where appropriate”, “practically and viably possible” suggests a very defensive, over-cautious response to the required Viability Assessment. Clear, measurable, but challenging targets are the only way that the Local Plan can be a leading example to “address the impacts of climate change and the need to become carbon net zero”.

Comments noted. These relate mostly to the policies in the Climate Change chapter. It is important that the Council puts forward deliverable policies in this plan that enable viable development to take place and further work to update the cost evidence for a number of options for the wording of the Climate Change policies will be undertaken to inform the next stage of the Local plan. This will build on the Whole Plan Viability Assessment (2023). Any changes to the draft policies arising from consultation responses and/or new evidence on climate change will be consulted on through the Reg 19 consultation.

Object

Representation ID: 6960

Received: 06/01/2024

Respondent: RCC Expert Panel on Carbon Reduction

Viability
An average uplift on build costs of about 6%, as indicated in the Viability Assessment, is a small price to pay over the next 20 years. Without this upfront uplift, the build costs for future Local Plans beyond 2040 will be much higher, and RCC will have failed to provide the lead stated in its Vision. Frankly, it is naive to believe that there will be no initial uplift. Despite the Government’s recent instruction to local authorities about not applying local energy efficiency standards (Dec 13, 2023) we believe this is a small price to pay for the future of Rutland and its younger generations to come.
‘Whole Plan Viability Assessments’ for such extended periods, as covered by Local Plans, must, as of necessity, strike balances between innovative vision and apparent viability suggested by projected data. Such data should be largely rooted in averages derived from previous experience and related statistics.

We would therefore draw Rutland County Council’s attention to three key points appearing in their own ‘RCC Draft Local Plan – Whole Plan Viability Report’ which are pertinent to striking that balance.

Comments noted. These relate mostly to the policies in the Climate Change chapter. It is important that the Council puts forward deliverable policies in this plan that enable viable development to take place and further work to update the cost evidence for a number of options for the wording of the Climate Change policies will be undertaken to inform the next stage of the Local plan. This will build on the Whole Plan Viability Assessment (2023). Any changes to the draft policies arising from consultation responses and/or new evidence on climate change will be consulted on through the Reg 19 consultation.

Support

Representation ID: 6963

Received: 06/01/2024

Respondent: RCC Expert Panel on Carbon Reduction

Cooperation with neighbouring local authorities is especially relevant in terms of a small local authority like RCC tackling climate change, which respects no boundaries. For example, landscape and ecological corridors should be enabled to cross the River Welland from Leighfield Forest to Rockingham Forest. In addition to the statutory requirement cooperation would be a cost-effective way of tackling some of the challenging aspects of carbon reduction.

Support noted. Environment Chapter policies encourage the provision and protection of green infrastructure and corridors. Linkages beyond the county boundary may be considered through the Nature Recovery and Biodiversity Action Plans.

Object

Representation ID: 6966

Received: 06/01/2024

Respondent: RCC Expert Panel on Carbon Reduction

Additional comments on the Whole Plan Viability Assessment

The Report states that the Plan contains “no strategic sites”, this seems bizarre given the references made to St. Georges Barracks.

There is little detailed argument about how the + of EUV+ might be impacted in the context of rapidly changed adverse market conditions, the Report relying on historic market averages. Even the most optimistic forecasts do not predict a return to sustained long-term all-time low borrowing rates over the next decade.

Similarly, the calculation of Development returns is estimated at between 15 to 20%, such figures being the product of historic perspectives which reflect a buoyant purchasing housing market.

Policies based on historic approaches to viability and housing land usage will not achieve the necessary changes.

Comments noted. It is important that the Council puts forward deliverable policies in this plan that enable viable development to take place and further work to update the cost evidence for a number of options for the wording of certain policies will be undertaken to inform the next stage of the Local plan. This will build on the Whole Plan Viability Assessment (2023). Any changes to the draft policies arising from consultation responses and/or new evidence on climate change will be consulted on through the Reg 19 consultation.

Object

Representation ID: 6967

Received: 06/01/2024

Respondent: RCC Expert Panel on Carbon Reduction

All temporary minerals and waste development should have, at least, a five year programme of aftercare, including provisions for ongoing management and maintenance where necessary.
There is an opportunity to increase biodiversity through mineral and waste aftercare programes for example:
* creation of woodland cover by planting of new broadleaved woodland
*Floodplain wetland as a good choice of habitat for restoring sites used for sand and gravel extraction, for example in the Welland Valley.
*Limestone operations provide opportunities to create limestone grassland habitat and to expose features of geological interest.
*Restoration to agricultural use should only be for lightly grazed pasture. Light grazing is often desirable in old quarries to prevent species rich grassland reverting to scrub.

Noted. Policy MIN9 - Restoration and aftercare, provides a guide to those types of after-uses that are supported, including: biodiversity and nature conservation, native woodland, forestry and geodiversity. Restoration schemes incorporating types of wetland habitat are discouraged in Rutland as they have the potential to attract large and flocking bird species, increasing the potential threat of bird strike to air traffic.
The length of after-care is dealt with at the planning application stage via planning condition. The National Planning Policy Framework (NPPF) requires a 5-year aftercare period for restored mineral extraction sites (or longer if agreed between applicant and the Mineral Planning Authority).
Restoration to agriculture is supported where it safeguards the long-term potential of best and most versatile agricultural land and conserves soil resources. The type of agricultural land use will be assessed on a site-by-site basis, in line with the Local Plan policies and other relevant policies.