Regulation 18 draft Local Plan

Object

Representation ID: 6955

Received: 05/01/2024

Respondent: Cora Homes Limited

Agent: Jeakins Weir

The evidence base is very clear that a higher figure than the LHN should be adopted as the housing requirement, based on data across a range of factors and from a range of sources. In our view, it is perfectly reasonable and possible for the Council to adopt a figure in excess of the Standard Method/LHN on the basis that it has historically delivered materially in excess of it, yet any consideration of an upward adjustment to the LHN is absent from the local plan itself. If this is not rectified then the local plan as adopted will be unsound for want of justification given that its housing requirement is out of step with the evidence base.

The calculation of housing need and the strategic housing requirement for inclusion in the spatial strategy is considered in detail under policy H1

Object

Representation ID: 6956

Received: 05/01/2024

Respondent: Cora Homes Limited

Agent: Jeakins Weir

Policy SS1 is plainly unsound for want of consistency with national planning policy. Sites outside of but adjoining built-up areas do not require anything approaching “exceptional circumstances” for release in circumstances of inadequate five year housing land supply or inadequate housing delivery. In fact, following the approach National Planning Policy Framework (NPPF), a lack of a five year housing land supply or a deficiency of housing delivery to a particular level engages the presumption in favour of sustainable development which, as the term suggests, presumes that the site in question can come forward for development provided the adverse impacts do not significantly and demonstrably outweigh the benefits and the NPPF itself does not indicate that development should be restricted. This limb of Policy SS1 should be reviewed accordingly and should adopt wording that conforms with national policy.

Agree. Remove the last paragraph of Policy SS1b) to remove reference to "exceptional circumstances"

Object

Representation ID: 6958

Received: 05/01/2024

Respondent: Cora Homes Limited

Agent: Jeakins Weir

Draft Policy H1 identifies sites for residential development at Oakham, Uppingham, adjacent to Stamford and within the larger villages including a number as reserve sites. Whilst we agree that the larger villages should play a role in facilitating growth needs, there does not seem to be a discernible approach to the apportionment of growth in each village in that the sustainability credentials of the settlements bear little relation to the level of housing growth planned for. T

The pattern of rural growth envisaged by the emerging local plan will not be sustainable, as it is not being directed to the largest and most sustainable rural settlements as a priority, but rather smaller rural settlements which will generate car dependency. That approach is not in line with the NPPF or the achievement of sustainable development in general.

All site appraisals have been reviewed in the light of comments and further evidence received to determine their suitability for allocation.

Object

Representation ID: 6961

Received: 05/01/2024

Respondent: Cora Homes Limited

Agent: Jeakins Weir

The Site Allocations Assessment records that the site has access and parking concerns, but does not elaborate further. Furthermore, the site is located adjacent and clearly visible from Oakham’s conservation area and it is clear from the assessment that no heritage expertise have informed this site’s selection for a draft allocation. Though no mention is made of it within the Site allocations Assessment, the site is also located adjacent to a Grade II* listed building to the east and a Grade II listed building to the north. There has been no judgement as to whether the heritage constraints will impact upon site capacity or similarly make its development unacceptable. The assessment records the heritage impacts of the site as “Red” indicating a “significantadverse impact” that “cannot be mitigated.” The Environmental Health Officer identifies that contamination is likely and it is unclear from the assessment the extent for this and whether it is capable of being viably remediated. Similarly, no mention is made of the site’s existing use which is for employment purposes and whether the loss of such a use in a sustainable location to housing development is desirable noting the loss of jobs and value added to the local economy. Will the existing use, for example, relocate to premises nearby? In addition, the assessment notes that the site is available “immediately.” It is difficult to see this could be the case given that the site hosts an existing and ongoing commercial enterprise.

All site appraisals have been reviewed in the light of comments and further evidence received to determine their suitability for allocation.

Object

Representation ID: 6962

Received: 05/01/2024

Respondent: Cora Homes Limited

Agent: Jeakins Weir

The Easson’s garage site at Cottesmore (H1.5) is allocated in draft for 8 dwellings. The Site Allocations Assessment, however, states that the site has capacity for only 4 dwellings. There is no highways assessment of the proposed allocation and the conservation area and listed building impacts have been rated as “Red,” indicating significant harm. It is hard to see on these facts how such an allocation is justified.

All site appraisals have been reviewed in the light of comments and further evidence received to determine their suitability for allocation.

Object

Representation ID: 6964

Received: 05/01/2024

Respondent: Cora Homes Limited

Agent: Jeakins Weir

Land East at the Workshops, Exton is draft allocated for 15 dwellings (H.10). The draft allocation within the plan identifies the site as “brownfield” when the Site Allocations Assessment identifies it has “greenfield.” It appears that whilst part of the site is occupied by hardstanding and buildings, these are in fact in agricultural use meaning that the site is not, in fact, brownfield either in whole or in part. The Site Allocations Assessment does not contain any highways comments but it would appear from reviewing the narrow and constrained nature of the access, and its current and presumably future use for what appears to be a fairly intensive agricultural operation, that achieving access for the scale of development anticipated would be challenging.

All site appraisals have been reviewed in the light of comments and further evidence received to determine their suitability for allocation.

Object

Representation ID: 6965

Received: 05/01/2024

Respondent: Cora Homes Limited

Agent: Jeakins Weir

Land North of Mill Lane, Cottesmore has been identified as a reserve site for 90 dwellings. This is in spite of the fact proposed development of this site for around this number was refused planning permission in April 2023 for seven separate reasons. Amongst the concerns raised, was the effect of the proposed development on the landscape and settlement character given the prominence of views of the site on the approach to the village as well as adverse impacts on neighbouring amenity, which according to the Council’s assessment could not be avoided.

Identification of this site as a reserve site for 90 dwellings is therefore not well-founded, given that it is unlikely to be able to support this scale of development without generating a materially adverse impact.

All site appraisals have been reviewed in the light of comments and further evidence received to determine their suitability for allocation.

Object

Representation ID: 6969

Received: 05/01/2024

Respondent: Cora Homes Limited

Agent: Jeakins Weir

Marrons is promoting Land West of Ashwell Road, Whissendine (REF WHI 13) and fundamentally disagree with the statement that the site is poorly related to the settlement. The subject site adjoins a high-density pattern of residential development to the north which is visible in the site’s backdrop along Ashwell Road. It has well developed natural features including mature field boundaries and a wide agricultural access track containing the site to the south, which could be further bolstered through structural landscaping. Whilst the development immediately to the west extending south from The Nook is more sporadic, it contains a number of buildings and a mature tree-belt which contain the subject site to the west. Overall, development of the subject site for housing would be well contained by existing built and natural features and would be clearly read as a logical extension to the settlement. To suggest otherwise, is inaccurate and contradicts the Council’s own assessment of the site found elsewhere in the emerging local plan’s evidence base.

All site appraisals have been reviewed in the light of comments and further evidence received to determine their suitability for allocation.

Object

Representation ID: 6971

Received: 05/01/2024

Respondent: Cora Homes Limited

Agent: Jeakins Weir

The evidence base clearly suggests that the local planning authority should be considering an uplift to the housing requirement in order to bring forward sufficient affordable housing over the plan period to meet needs. Unfortunately, this is not reflected in the emerging local plan or in its housing requirement.
13. An upward adjustment should be made to the housing requirement to maximise opportunities for affordable housing delivery, against the clear backdrop of Rutland’s affordability issues.

Policy SS1 addresses the Spatial Strategy and how development is numerically spread around Rutland. An increase in the amount of housing allowed for in the draft Local Plan is not thought appropriate. The high level of need for affordable housing in Rutland is noted, but an environmentally sustainable approach must be taken.