Regulation 18 draft Local Plan

Object

Representation ID: 7181

Received: 08/01/2024

Respondent: Persimmon Homes East Midlands

Persimmon Homes are in support of this policy, however, this interlinks with criteria a) of policy H4. Furthermore, the policy should set out if the policy requires M4(3)b or M4(3)b standards – these different standards have very different cost implications and these need to be reflected in the Council’s Viability Report.

Policy H4(a) and H5 are complementary and not duplicates. The Whole Plan Viability Assessment assesses the viability of M4(3)(a) properties. M4(3)(b) properties can only be required where the Council has nomination rights for the property.

Object

Representation ID: 7182

Received: 08/01/2024

Respondent: Persimmon Homes East Midlands

No objections in principle to the requirements of this condition, its wording seemed unduly complicated and could be set out in a much clearer manner.

Criteria d) sets out developments need to ‘achieve a minimum of 25 % of all affordable homes secured through developer contributions as First Homes’.

Persimmon Homes are of the view the words ‘through developer contributions’ should be removed from this wording.

Noted. The words 'through developer contributions' should remain so that it does not apply to wholly affordable sites. See national PPG Reference ID: 70-001-20210524.

Object

Representation ID: 7183

Received: 08/01/2024

Respondent: Persimmon Homes East Midlands

Persimmon Homes support this policy, however, would suggest the trigger for submission for Health Impact Assessments (HIA) for residential developments be increased to 100 dwellings.
Developments of 100 plus dwellings will be of a sufficient size to provide more open space and infrastructure on site. Criteria points a) to d) of this policy will ensure that health and safety will be at the forefront of the design of a development.
Criteria b) of the HIA part of this policy states that HIA’s should be carried out using the Council’s Agreed template for HIA. Having searched the Council’s website this document could not be found. To enable full comments to be provided on this policy a copy of this template needs to be publicly available.

Policy threshold should be amended to 10 or more dwellings to align with the definition of major development. As evidenced and required by the Health Impact Assessment of the Local Plan

Object

Representation ID: 7184

Received: 08/01/2024

Respondent: Persimmon Homes East Midlands

The open space standards proposed are significantly higher than those in place in the current local plan with the amount almost doubling.

Reviewing the figures this is from an increase in the provision of parks/ gardens/ amenity space provision and a requirement for 1.8ha of natural/ semi natural open space of 1.8ha per 1,000 population, previously this was not a requirement.

With respect to Parks and Gardens, the current Site Allocations and Policies Development Plan Document sets out a standard of 0.4ha per population the Open Space Assessment, states at paragraph 6.37 that the existing quantity standard is 0.75ha, this appears to be incorrect (this information is also shown in Table 33 of this document ‘Proposed Quantity Standards in Rutland’

Persimmon Homes are of the view there is an insufficient evidence space to justify the use of this national benchmark figure for new developments, particularly given the Assessment states at paragraph 6.38 that there is a current and future surplus at a County wide level.

Whilst Persimmon Homes recognise the importance of incorporating Natural and Semi Natural Greenspace on site and incorporating standards within the local plan, particularly given the links to achieving required biodiversity gain levels, we would question the need for the levels proposed.

Persimmon Homes welcome the inclusion of criteria e) of this policy and consider it is imperative the biodiversity function of open space is recognised within this policy.

Comments noted. The table at Appendix 3 has been prepared using the Open Space Assessment 2023 which provides and detailed assessment of quantity and quality of open space in the County.
Whilst the figure for Parks and gardens has increased this is a reflection of a paucity across the county of this form of open space. It should be noted that the figures for Children and Young People and for outdoor sports facilities have decreased.

Object

Representation ID: 7185

Received: 08/01/2024

Respondent: Persimmon Homes East Midlands

No evidence has been provided to demonstrate the county is in need of enhanced biodiversity gains above the 10% Environment Act requirements.

The Council’s evidence base for introducing higher bng standards is the ‘Rutland County Biodiversity Assessment Non Technical Biodiversity Report’. There is no evidence set out in this report, or any comment, that the existing ecological position is any worse than the national situation.

Persimmon Homes are also of the view that the impact of increasing the bng requirement to 15% on viability has not been fully considered by the Council.

Net gain is site specific and there is a lack of evidence to demonstrate that applying 15% across all sites is achievable. Additional viability evidence and testing needs to be prepared on a range of sites, including allocated sites, to enable a full understanding of the impacts of this policy and if it is achievable.

Furthermore, in terms of sites allocated in the local plan, there is no evidence to demonstrate the requirement for 15% bng has been taken into account in the Housing Site Assessment Report.

The wording of Criteria d) of this policy requires ‘any off-site habitats created or enhanced are well located to maximise opportunities for local nature recovery.’ This policy also needs to recognise for some sites the use of national credits may be required.

Comments noted. Change from 15% to 10% as a higher percentage than the statutory objective of biodiversity net gain needs to be evidenced. In order for the Local Plan to be deemed sound this uplift above the mandatory level must be robustly evidenced.

Biodiversity credits are set out in the second paragraph on page 179 (Now 181 in the Reg 19 Plan). Add in extra criteria to policy EN3:
e) (Now f) in the Reg 19 Plan) Where developers are unable to use on-site or off-site units to deliver Biodiversity Net Gain, then they must buy statutory biodiversity credits. This must be a last resort and developers must include evidence in their Biodiversity Gain Plan that they have considered on-site BNG and the reasons why this is not possible, and evidence that insufficient off-site options are available.
Add in at beginning of para:

‘If developers cannot achieve on-site or off-site biodiversity net gain, they must buy statutory biodiversity credits. This must be a last resort. Buying statutory credits means that as well as, or instead of, creating and enhancing biodiversity on or off a development site, developers can make a financial contribution which counts towards their BNG. This contribution will be used to fund biodiversity enhancements across England. Buying statutory credits is a last resort option for developers who are unable to use on-site or off-site units to deliver BNG.’

Object

Representation ID: 7186

Received: 08/01/2024

Respondent: Persimmon Homes East Midlands

Under the Mitigation for Loss of Trees and Woodland section it talks about 3 replacement trees be planted for every trees lost and these should be of a similar size and species to that which is being lost.

The policy needs to recognise that the replacement trees will not be of the same size as the trees they will be replacing on day one, instead Persimmon Homes would recommend the wording ‘similar size’ be removed from the wording.

Comments noted. Agree regarding wording for replacement trees.

Object

Representation ID: 7187

Received: 08/01/2024

Respondent: Persimmon Homes East Midlands

Persimmon Homes do however consider there should be some flexibility in the wording of this policy for example, there are times that the size of a parcel of agricultural land is too small to accommodate the increased size of agricultural vehicles and as such function well as agricultural land.

Comments noted. The functionability of land for remaining in agricultural use if restricted by its size would be taken into account during the site allocation process.

Object

Representation ID: 7188

Received: 08/01/2024

Respondent: Persimmon Homes East Midlands

The fifth paragraph of this policy state: ‘Proposals for major development should be accompanied by an audit of the existing GBI within and around the site and a statement demonstrating how this will be retained and enhanced through the development process.’ Persimmon Homes are of the view that the policy should clarify what is expected from ‘within and around the site.’

Noted. Policy to be amended for clarity.

Object

Representation ID: 7189

Received: 08/01/2024

Respondent: Persimmon Homes East Midlands

Criteria point h) of this policy requires that developments provide levels of car parking in line with Council’s published car parking standards at Appendix 5.

However the shared / communal parking spaces appear excessive, for example of a dwelling with 3 habitable rooms will require total 3 ½ parking spaces. The provision of such a high number of car parking spaces will result in a car dominated development which can potentially be unsafe for non-car users.
A balanced approach to parking provision, when used as part of a package of measures, can promote sustainable transport choices and provide attractive and safe environments whilst ensuring that sufficient parking is provided to meet local needs.

Paragraph 111 of the National Planning Policy framework sets out that local parking standards policies need to take into account of a) the accessibility of the development b) the type, mix and use of development c) the availability of and opportunities for public transport d) local car ownership levels and e) the need to ensure an adequate provision of spaces for charging plug-in and other ultra-low emission vehicles. There appears to be no evidence base put forward by the Council to show how these different criteria have been considered in the development of this policy.

Comment Noted. The Parking Standards set out in Appendix 5 of the Local Plan should be read in conjunction with the Design Guidelines for South Kesteven and Rutland (2021) Section 5Q specifically relating to parking design, on plot, on street and communal. Insufficient and poorly designed parking can have negative impacts on how streets function, can create cluttered and chaotic environments and can create unnecessary neighbour and community conflicts and divisions. Rear parking courtyards and car parks for flats rear parking courts should be a last resort, only used once other options have been exhausted or if there are clear placemaking benefits like creating strong frontages to overlook a key space