Regulation 18 draft Local Plan

Object

Representation ID: 6947

Received: 07/01/2024

Respondent: Cottesmore Parish Council

we have also understood that the plan is still a work in progress and that other supporting documents are being published for consultation after the commencement of this Reg.18 process. For example, to develop climate change and environment policies (see comments on Chapter 4 below) and the further work to be done on the infrastructure requirements. This is clearly totally unsatisfactory and flies in the face of other commitments from the new Leadership that have consistently said that this Reg. 18 document is the only significant opportunity for consultation, in that the next draft (Reg. 19) will be more limited consultation priorities around soundness and viability. Whilst hoping the Reg. 19 will be different, to reflect representations made during this consultation process, it is surely unacceptable to issue a document at this stage, which is not even a finalised Reg.18 document, more a work in progress!

Comments noted. Further detailed evidence relating to renewable energy and climate change policies and to further develop the Infrastructure delivery plan have been produced following the consultation on the Reg 18 Plan. All evidence used to prepare the Local Plan will be published as part of the Regulation 19 consultation.

Object

Representation ID: 7426

Received: 07/01/2024

Respondent: Cottesmore Parish Council

December 2023 NPPF has flagged up a number of potential changes to the planning system. These relate, for example, to the treatment of the 5 year land supply; bolstering protection from speculative development; greater reflection on local character; and respecting the ‘democratic voice of local communities’. It would seem inevitable that this may well necessitate yet more changes to the current draft, which are likely to require further community consultation.

Comments noted. It is not unusual for changes to be made to Government guidance during the Local Plan process. Consultation will take place again once the Reg 19 Plan is produced. This will incorporate the updates to the NPPF made in December 2023.
Please note that changes to the NPPF are currently being consulted upon and these may impact upon the Local Plan as it progresses through Examination.

Object

Representation ID: 7427

Received: 07/01/2024

Respondent: Cottesmore Parish Council

The Parish Council Objects to the lack of Community engagement during the preparation of the Local Plan; considers the consultation process has been made very difficult and cumbersome for residents to engage with; and the Interactive Map is far too complicated and we think many people will give up trying to understand it. Given the bulk of the documents and the complexity of the content, the lack of reasonable access to hard copy paper plans is not acceptable; neither is the total reluctance seemingly to even entertain the very reasonable suggestion, promoted by many parts of the community, that the consultation period should be extended to the end of January 2024.

Comments noted. Under the Town and Country Planning (Local Planning (England) Regulations 2012, the statutory consultation period for Regulation 18 is six weeks. The Council chose to extend this by two weeks to a total of eight weeks to allow for the festive period. The consultation followed the requirements set out in the Council's Statement of Community Involvement (SCI). The experience of the Issues and Options consultation and the Call for Sites exercise has been that local councils and the general public have generally responded well to the online platforms without the need for paper hard copies. A short video guide on use of the online consultation was also created to assist users navigate the system. Nonetheless, in recognition that not all members of the community may be able to access these resources, paper copies were made available at the Council offices and all public libraries. A paper copy was available on request at cost price. The Local Plan chapters were available to read or download from the Council website without needing to access the consultation portal. We also accepted representations by email and post for those who were unable to access or navigate the online consultation system.

Object

Representation ID: 7428

Received: 07/01/2024

Respondent: Cottesmore Parish Council

The whole way that the site allocation has been done in preparation for the Reg.18 Plan is thrown into stark relief by the relationship to parishes in the allocation of sites for development. It is quite correct when RCC states that Neighbourhood Plans ‘cannot propose less development than that allocated in the Local Plan with which it has to conform’. However, what seems to be conveniently forgotten is the right for local communities to influence the location of new development through the mechanisms of the Neighbourhood Plan. By identifying sites without any direct engagement with local communities, it is in effect short-circuiting an important element of the whole underlying rational behind establishing Neighbourhood Plans in the first place.

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

Object

Representation ID: 7429

Received: 07/01/2024

Respondent: Cottesmore Parish Council

the Vision Statements together with the Spatial Portrait does give the impression of a less than optimistic Vision of Rutland. There is too much emphasis on the need for change and significant improvements, rather than championing what is good about Rutland, as a place ‘to live, work, shop and play’! The Local Plan should start from a much more positive view of the County.
We would also like more clarity and explanation about how the inevitable conflicts around delivering these elements of the Vision will be resolved and justified, including the weight to be given. For example, will protecting the countryside and particularly protecting views and agricultural land be given precedent over unnecessary build development or will the needs for housing and employment prevail. The relationship between the Local Plan and other local strategies for Health, Education and particularly transport and other infrastructure need to be much more clearly set out.

Comments noted. In accordance with the NPPF, the Local Plan provides a positive vision for the future and acknowledges that Rutland generally has a high quality of life. The Local Plan must make provision for change in terms of sustainable growth by allocating sites for housing and employment development. In terms of weight, planning decisions must be made in accordance with the Development Plan (which would include any relevant made neighbourhood plan) unless there are material planning considerations that would indicate otherwise. The role of other strategies, such as for health and education, are set out in other parts of the Local Plan, including in Chapter 11: Infrastructure.

Object

Representation ID: 7430

Received: 07/01/2024

Respondent: Cottesmore Parish Council

The population projections for Rutland for the duration of the Plan have increased considerably since the 2020 Plan. Overall a 6% increase in the 2020 plan has increased to an 11% increase in the current plan. There is no robust explanation of how this scale of change has been arrived at and the degree to which the Local Plan can influence this projection. This discrepancy between population projections and dwelling numbers has potential implications across many policy areas, and it needs to be properly explained.

There appears to be an inconsistency in the projections between these population figures and the housing projections set out in chapter 6, suggesting either the population figures are an under projection or there are more dwellings projected than are needed to meet both Rutland’s current and projected need. This discrepancy is likely to be increased as windfalls are likely to be higher with the changes proposed through to SS4.

Comments noted. The Spatial Portrait chapter is largely factual setting out the main characteristics of Rutland. The 11% increase figure is taken from latest Office of National Statistics (ONS) published data as detailed in the footnotes. The Local Plan must make provision, based on robust evidence, for housing and employment development to meet the needs of the county to 2041: it cannot merely make provision for small, incremental changes as suggested. The Local Plan cannot influence population rises but must, instead, make proper provision to plan for the projected increase. Regarding including NPPF paragraph numbers, the NPPF is frequently reviewed and so paragraph numbers would become quickly out of date and this could lead to confusion. Remaining comments regarding housing figures are covered by the representation under Policy H1.

Object

Representation ID: 7431

Received: 07/01/2024

Respondent: Cottesmore Parish Council

We welcome the increased priority given to Climate Change in this Reg18.Local Plan and introducing a suite of policies to ensure development has to meet many more up to date environment, design and energy efficient policies.
we are concerned that climate aspirations set out in this chapter have not consistently been reflected in the other chapters of the Plan, despite this being, promoted as a clear, almost overriding aspiration.
We understand that additional work is being undertaken on climate change policies - what will the status of this be – will they, for example, be subject to a separate consultation sometime later in 2024? They really cannot be introduced by RCC in this way, as they are either part of the Local Plan in which case they need to have been part of the Reg.18 consultation or they are not.

Response: Support for the increased priority given to Climate Change in the Local Plan noted. Climate Change policies are the first ones set out in the Local Plan and climate change was one of the assessment criteria used in the Sustainability Appraisal, a key piece of supporting evidence for the drawing up of the whole plan. 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: 7432

Received: 07/01/2024

Respondent: Cottesmore Parish Council

This chapter would greatly benefit from an introduction that clearly sets out what the Spatial Strategy of Rutland is.
This should include how it looks in reality and how the component parts work together. It should paint a clearer picture, a Vision of Rutland, over the next 15 years or so within which the key policies should be set and importantly against which they can be measured and tested.

Comments noted - It is felt that the Vision and objectives chapter does this however some additional text can be added to the introduction of this section setting out linking to the Vision and Objectives and the spatial strategy set out in policy SS1

Object

Representation ID: 7433

Received: 07/01/2024

Respondent: Cottesmore Parish Council

We note the changes to the Spatial Strategy, particularly the ‘simplification’ of the hierarchy of the villages and hamlets into just two groupings and the changes to the Planned Limits of Development. Cottesmore, as we would expect, is classed as a larger village in which it would be expected to have some development during the Plan period and that services would be located here, we have no issue with this in principle. Our primary concerns have been and continue to relate to the location, scale and type of development proposed.

Support noted

Support

Representation ID: 7434

Received: 07/01/2024

Respondent: Cottesmore Parish Council

The Final Report of the Planned Limits of Development Review (October 2023)
includes several relatively minor changes for Cottesmore which the PC has no concerns with, although the wording on Cott. 3 (where the Allotments are located) are ambivalent in that it could be interpreted and has been locally as a ‘de-designation of the Important Open Space’. We are assuming the designation solely relates to the area being removed from the PLD, in which case the CPC supports this proposal.
the Review does not show is any ‘room’ within the PLD boundary for development, seemingly something beyond the scope of this Review. Had it done so, it may have come to different conclusions about the development sites to be included or not included in the Local Plan itself.

Support for Cottesmore PLD noted