Regulation 18 draft Local Plan

Object

Representation ID: 5522

Received: 05/01/2024

Respondent: Mr C Udale and Grafton Spaces Ltd

The sixth bullet point under the heading “The Local Plan will have supported the delivery of:” should be re-worded as follows:

Protection and preservation of heritage assets, including enhancement and securing new uses for the future, and natural environment

Comments noted. Agreed to add in to 6th bullet point: "and their setting, including the enhancement and recovery of biodiversity contributing to the nature recovery network". Policy EN1e addresses the protection of heritage assets in detail.

Object

Representation ID: 5523

Received: 05/01/2024

Respondent: Mr C Udale and Grafton Spaces Ltd

This strategic objective fails to recognise that locating development in smaller settlements can be vital to provide the necessary sustainable community and economic activity to support the amenity in those places. The proposal put forward at the Call for Sites stage for the Dovecote site on the land east of Exton Road, Empingham included proposals for the heritage asset to be made available as a community asset, which could fulfil a range of social and community functions in addition to the amenities already available in the village.

Comments noted. Infill/windfall sites within villages would be assessed against the policies in the Local Plan as a whole. Sites put forward at the Call for Sites stage have been through the rigorous site appraisal process.

Object

Representation ID: 5524

Received: 05/01/2024

Respondent: Mr C Udale and Grafton Spaces Ltd

Reference to the diverse and thriving network of villages and communities that serve local needs should also reflect the need for carefully targeted growth to support the local amenities and heritage assets in these places as a particular priority.

Comments noted. Growth to support local communities is part of Strategic Objective 2: Delivering sustainable development. The protection and enhancement of heritage assets is covered by Strategic Objective 8. It would not be appropriate to rank the Strategic Objectives in terms of priority.

Object

Representation ID: 5525

Received: 05/01/2024

Respondent: Mr C Udale and Grafton Spaces Ltd

The policy could go further in proving specific and positive guidance in respect of the way that under-utilised, or unused heritage assets could be re-purposed. This is especially important, as these buildings have both a heritage importance, but also themselves embody significant carbon in their structures.

Comments noted. National guidance/Local Plan policy covers this. Para 124 of the NPPF states that planning policies should…promote and support the development of under-utilised land and buildings. Strategic Objective 9 and Policy EN12 of the Local Plan seek to encourage the re-use and refurbishment of existing buildings (including heritage assets) in accordance with the national planning policy guidance.

Object

Representation ID: 5526

Received: 05/01/2024

Respondent: Mr C Udale and Grafton Spaces Ltd

There is a concern that the Local Plan as proposed reflects the available pockets of land that have been put forward in each of the larger villages, rather than the level of amenity, and hence sustainability, that can be achieved. For example, Empingham is exceptionally well provided for in terms of amenity, having a suite of facilities that is not available, in total, in other larger villages. The allocation of sites should, therefore, reflect the relative sustainability of each village and not simply respond to land that may be conveniently apportioned for development.

The availability and deliverability of development sites is a key part of ensuring that the local plan is deliverable. It is not beneficial to the Local Plan to allocate sites which are not available or where a landowner is unwilling to develop their land.
A part of the site assessment process has been to consider the sustainability of settlements and to try to direct development of these locations. This will be refined in a review of the site assessment process.

Object

Representation ID: 5527

Received: 05/01/2024

Respondent: Mr C Udale and Grafton Spaces Ltd

The Dovecote site, on land to the east of Exton Road, Empingham should be included as an allocation, with the PLD adjusted accordingly to include it. The site has a potential capacity of 12 - 14 homes, and with a specific provision that the development constitutes enabling development to secure the future of the heritage monument (the Dovecote) on the site.

Noted. The Dovecote site does not meet any of the criteria for inclusion within the PLD under the methodology established in the PLD Review study 2023. It lies outside the recognised built framework of Empingham, within the countryside beyond the village.

Object

Representation ID: 5528

Received: 05/01/2024

Respondent: Mr C Udale and Grafton Spaces Ltd

We consider that the PLD defined for Empingham village should therefore be amended, to include the Dovecote site, on land east of Exton Road.

The Dovecote is not considered to fall within a residential or commercial curtilage, notwithstanding ownership of specific parcels or buildings. The freestanding building is located within a small agricultural pasture not directly functional to the residential unit at the farmstead. Therefore, would not justify inclusion within PLD under criteria In.F of the Planned limits to development review study, 2023.

Inclusion of land within a Conservation Area does not automatically confer inclusion within PLD.

The proposed PLD around Empingham is considered the most appropriate and up-to-date delineation between the built framework of the village and surrounding open countryside, drawn in accordance with methodology established by the PLD Review Study 2023.

Object

Representation ID: 5529

Received: 05/01/2024

Respondent: Mr C Udale and Grafton Spaces Ltd

The Dovecote site is a particular case where policy should make a way for proposals that can secure the asset with a long-term purpose through enabling development. We would suggest that Policy SS8 would benefit from an additional bullet point provision, as follows:

New-build open market housing will only be permitted in the open countryside where the proposal is for the following uses and which specifically meet the requirements of NPPF and subject to the relevant policies of this plan:
• As enabling development to the extent that they secure the future re-use of heritage assets that are otherwise disused

Noted.
Change not required as Heritage Assets are addressed in Policy EN13.

Object

Representation ID: 5530

Received: 05/01/2024

Respondent: Mr C Udale and Grafton Spaces Ltd

It is unclear how the allocation of housing to the larger villages has been achieved, it appears disproportionate to the amenities and accessibility of the locations. Of the 184 dwellings to be allocated to the larger villages, only 6 are to be located in Empingham. This seems perverse, as Empingham is the only larger, better connected villages in the County.

The distribution of development allocations could reflect the disposition of amenities, recognising that these are better in some locations rather than others. The Dovecote site, east of Exton Road, Empingham should be included in the sites proposed for residential development.

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

Support

Representation ID: 5532

Received: 05/01/2024

Respondent: Mr C Udale and Grafton Spaces Ltd

The proposed policy appears both proportionate and appropriate, setting out clear guidance for the provision of affordable housing, but also the scope that exists for departures from policy to be considered where these are robustly justified.

Noted.