Regulation 18 draft Local Plan

Object

Representation ID: 7784

Received: 08/01/2024

Respondent: Edith Weston Parish Council

Recent policies propose intensive re-development of the St George’s Barracks site and greenfield development in the Edith Weston parish.

Whilst this represents a reduction from previous proposals, these proposals are at odds with the vision, particularly with respect to climate change, rural character and natural environment and infrastructure.

Similarly, they would be contrary to strategic objectives SO1, SO2, SO3, SO4, SO5, SO8, SO9, and SO10.

Comments noted. The Local Plan acknowledges that SGB may be appropriate for meeting some future development needs either during this plan period and/or beyond. The Local Plan must allocate sufficient housing land to meet housing needs during the plan period and the Council took the decision that SGB is identified in the Local Plan as a Future Opportunity Area. The masterplan must detail how the scheme will satisfy the policies of the Local Plan that follow on from the Vision and Strategic Objectives, including infrastructure provision to support the development. In accordance with criteria g) of Policy SS5, the infrastructure required must be delivered in tandem with, or ahead of, the development.

Object

Representation ID: 7785

Received: 08/01/2024

Respondent: Edith Weston Parish Council

We support policies that reduce carbon use, water efficiency and micro energy generation. However, We note that the policy refers to specific building regulations. We would suggest removing these references, as change to the building regulations in question will date the policies. Reference to the relevant building regulations could instead be made in supporting text.

Comments noted. The Optional Technical Standard for housing allows councils to set a more stringent standard of 110 litres per day, as compared to the Building Regulations requirement of 125 litres per day, where there is a clear local need (as is the case in Rutland which is classified as being in a serious water stressed area). The 110 litres per day set out in CC6 is considered justified on this basis and the policy also seeks to go further in terms of water usage by supporting proposals for down to 85 litres per day. The policy already aims, therefore, to go lower than the current Building Regulations requirements. A similarly worded policy is included in the adopted Central Lincs Local Plan (2023).

Support

Representation ID: 7786

Received: 08/01/2024

Respondent: Edith Weston Parish Council

We support policies that reduce carbon use, water efficiency and micro energy generation.

Support noted.

Object

Representation ID: 7787

Received: 08/01/2024

Respondent: Edith Weston Parish Council

Policy CC2 (a) needs to make mention of overheating.

Disagree. Policy CC3 – Resilient and flexible design – considers overheating. The two policies in tandem are seeking to achieve design solutions that manage solar gain whilst preventing overheating – a balance between the two is required. There are significant benefits in solar gain in terms of heating and solar panel efficiency particularly in the winter months but these must be balanced against the harmful risks of overheating. The National Design Guide (2021) has useful advice: ‘Well-designed buildings make the most of passive design strategies to minimise overheating and achieve internal comfort. These include: the layout and aspect of internal spaces; insulation of the external envelope and thermal mass; management of solar gain; and good ventilation to reduce overheating.’

Object

Representation ID: 7788

Received: 08/01/2024

Respondent: Edith Weston Parish Council

For Policy CC7, we suggest the paragraph is re-worded to be compatible with Chapter 16 of the NPPF.

We would like to see a greater emphasis on other forms of energy, rather than solely on electric models of transport, and more linkage with use of public transport.

We would also welcome more clarity on term of how this policy will be delivered and measured.

Comments noted. We consider that Policy CC7 is compatible with Chapter 16 of the NPPF. The accompanying text provides detail of the guidance and best practice for successful retrofitting of energy efficiency measures in existing and historic buildings.

Support

Representation ID: 7789

Received: 08/01/2024

Respondent: Edith Weston Parish Council

We support Policy SS3, and this is reinforced by the emerging Neighbourhood Plan.

Support noted

Object

Representation ID: 7790

Received: 08/01/2024

Respondent: Edith Weston Parish Council

The policy is being prepared without any involvement of Edith Weston Parish Council. The policy could double the number of households in the parish, the total proposed represents the entire requirement for new houses in Rutland which is completely unacceptable.

Development of the site in this way would be extremely unsustainable and contrary to the Local Plan’s own vision and strategic objectives. There is no justification for housing growth of this scale in an isolated rural settlement. There is no apparent evidence for targeting this site for gypsy and traveller accommodation, so we understand this is to be a generic requirement across the board.

E use class development could be beneficial, but we would have concerns over B2 and B8 uses, especially given the limitations on the surrounding highway and public transportation network.

We note the extensive list of requirements in the policy, which reads as a list of reasons for why the site is unsuitable for the development envisaged by the policy.

Apart from the heritage clause, most of the clauses set generic requirements that are already covered in other policies, rather than setting site-specific requirements.

We see no reference to alternative use (solar farm, science park), nor to how inward investment would be achieved.

There are clear tensions between this policy and Policy SS7. We think this policy is not thought through with necessary rigour, nor based on a sufficient level of knowledge and understanding of the site and area.

Comments noted. This is the ‘Preferred Options’ Plan and consultation on this Reg 18 Plan has been undertaken in accordance with the relevant Regulations and the council’s SCI. This follows the Issues and Options consultation in 2022. Policy SS5 does not allocate the SGB for housing/employment but, instead, identifies St George's Barracks as a Future Opportunity Area and provides a framework to ensure that any future development is sustainable and holistically planned and address the issues raised. The Woolfox site will also be identified as a Future Opportunity Area in the Regulation 19 Plan.

The policy would not preclude other uses, such as for a solar farm or science park, subject to such proposals meeting the policies of the Local Plan. Policy SS7 would not apply to any development proposal for SGB as the text accompanying the policy makes clear.

Object

Representation ID: 7791

Received: 08/01/2024

Respondent: Edith Weston Parish Council

Policy SS7 should recognise that in some instances redevelopment could be unsustainable and nature recovery or sustainable energy generation could be more appropriate options. We are very concerned that this policy in its current form could be used to support unsustainable housing development in unsustainable locations.

We are unsure of the relationship between Policies SS9 and SS10 and the previous policies SS5 and SS7.

Comments noted. Policy SS7 (now SS6) is a Strategic Policy in the Local Plan setting out key requirements that need to be considered for any alternative uses of the military base or prison. The text supporting Policy SS7 (now SS6) states that, if the re-use is likely to be significant, then development proposals may need to be through a review of the Local Plan or a separate Development Plan Document which would consider the acceptability of, and need for, new housing proposals there. This would allow for full consultation in accordance with the Local Plan Regulations and in accordance with the Council’s Statement of Community Involvement.

Object

Representation ID: 7792

Received: 08/01/2024

Respondent: Edith Weston Parish Council

H1.4 recognises the St George’s Barracks’ Officers Mess in Edith Weston, which is consistent with the approach taken in the emerging Neighbourhood Plan.

However, the Neighbourhood Plan policy is based on a housing evidence document, prepared by Urban Vision Enterprise, dated July 2023. This identifies the site capacity as 60 dwellings, rather than the indicative 90 cited in the policy.

The figure of 60 recognises environmental constraints and urban design and character considerations having regard to the National Design Guide 2023.

We believe the figure of 90 fails to take account of these considerations and is also incompatible with the Policy SS7(a).

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

Object

Representation ID: 7793

Received: 08/01/2024

Respondent: Edith Weston Parish Council

This site (ED106) is similar in all key respects to site ED109, as identified in the Site Allocations Assessment Appendix C Larger Villages, October 2023. There is clear inconsistency in finding site ED106 (H1.b) as suitable for development.

In addition, Edith Weston is meeting housing needs and part of the wider strategic need already, so there is no need or justification for inclusion of this site.

The Local Plan identifies a proposed target spatial distribution of 514 homes across the 10 Larger Villages. Edith Weston is already more than meeting its share of this figure.

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