Regulation 18 draft Local Plan

Object

Representation ID: 7292

Received: 08/01/2024

Respondent: Ketton and Tinwell Joint Neighbourhood Plan Steering Group

The statement in the Vision on the need to for ‘protection and preservation… of natural environment’ is wholly weak and out of keeping with many of the detailed policies in the draft Plan. At the very least, the Vision should include the ‘protection, preservation and enhancement of the county's natural environment’, together with an emphasis on biodiversity increase and nature recovery.

Moreover the emphasis in the narrative in this section describing "internationally recognised" environmental features tends to imply that only the Rutland Water area is important. There is a great deal of biodiversity/geological characteristics within the county which make its natural environment important on both the local and national level. We would suggest this section of the Plan needs stronger drafting.

Comments noted. Agree to add in to 6th bullet point: "and their setting, including the enhancement and recovery of biodiversity contributing to the nature recovery network"

Object

Representation ID: 7293

Received: 08/01/2024

Respondent: Ketton and Tinwell Joint Neighbourhood Plan Steering Group

Whilst we recognise that this policy follows patterns elsewhere in the UK, and that there is some detail given as to the conditions to be applied, we feel that removing planned limits for smaller settlements could lead to difficulty in arguing against development creep out from these settlement areas. We are not convinced that the wording in the policy would be sufficient to prevent this.

Incidentally, regarding the debate over ‘flexibility’, it is surely true that planned limits are either there, or they are not – there is no point in having a set of limits which are flexible, as that means that the inherent control within the idea of planned limits disappears. We wonder, somewhat cynically, whether the 65% of respondees on this topic who favoured flexibility were made up of county residents, or if they were corporate bodies?

Comments noted. No change to the general approach to remove PLDs from small villages, however policy SS4 (now SS3) is to be amended to provide greater clarity to be added to the policy criteria.

Object

Representation ID: 7294

Received: 08/01/2024

Respondent: Ketton and Tinwell Joint Neighbourhood Plan Steering Group

We are pleased that there have been no further sites allocated within our Neighbourhood Plan area. Our Neighbourhood Plan policies (KT 11 and KT 12) relating to development made it very clear that the Plan area had seen more than its fair share in recent years.

However we are disappointed to see that all the reserve sites mentioned are greenfield. Should the unfortunate situation come to pass that more housing delivery was required to be identified, this would represent an unacceptable sprawl out of the larger villages. We would argue that an increased focus on urban brownfield sites and the concept of building ‘up’ rather than ‘out’ (i.e. blocks rather than individual dwellings in an urban context) would help avoid what would otherwise be a constant erosion of the rural character of the county.

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

Object

Representation ID: 7295

Received: 08/01/2024

Respondent: Ketton and Tinwell Joint Neighbourhood Plan Steering Group

We would query what happens to this housing delivery for Rutland should the overall Stamford development not proceed, and what are Rutland County Council’s fallback options? This is a significant amount of development to commit to, on a partnership basis. It would be helpful for the Plan to explain what the safeguards are in this situation.

We would also note in the context of this policy that the proposals for the creation of a Country Park do not suitably compensate for the loss of biodiversity on the Quarry Farm site in question. In addition, the proposals for translocations of specific species may look fine on paper but are extremely difficult to achieve in practice, and due weight should be given to this concern. In this, we echo the concerns of the Leicestershire and Rutland Wildlife Trust in their response to you.

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

Object

Representation ID: 7297

Received: 08/01/2024

Respondent: Ketton and Tinwell Joint Neighbourhood Plan Steering Group

We welcome the emphasis in this policy on the protection of non-designated heritage assets, for example ridge and furrow. However, EN13 is another policy where the relationship between the Local Plan and local specifications with relevant Neighbourhood Plans could be helpfully reinforced.

Neighbourhood Plan policies relate to the Neighbourhood Plan area and as such are not always relevant to the wider county. Policies relating to protecting heritage assets within Neighbourhood Plans will be material considerations for decision-making alongside EN13.

Object

Representation ID: 7298

Received: 08/01/2024

Respondent: Ketton and Tinwell Joint Neighbourhood Plan Steering Group

Whilst the Ketton and Tinwell Neighbourhood Plan identified that the Pit Lane area of Ketton would be a suitable place for any further business development (as opposed to any possible alternative sites within the Plan Area) we have some concerns about the size of the area to be considered as employment land.

In the first instance, this whole area is very much a mix between wildlife-rich nature reserve, recreation areas, local wildlife sites and small business. The saturation of that area by a sprawl of new businesses would be detrimental to wildlife corridors that currently exist and could result in the significant loss of valuable habitat. We note that the sites were identified as potential development areas in the 2023 biodiversity survey (of which see more below) but we do not feel that these parcels of land have been adequately studied to be able to support their zoning for development. Our concerns are particularly in the context of bat foraging areas.

The second point of concern is whether there is an overall strategy that the Local Authority sees for how these areas would be populated by small businesses. There are already not only a large number of businesses in the Pit Lane area, but also operating from private homes within Ketton. In that context we feel that it would be advisable to have a clearer proposal from the Local Authority as to the structure of the business opportunities, rather than the somewhat random approach as now.

Noted.

The site assessment process has considered all constraints in relation to all those sites considered. Sites will allocated to meet the required need as identified in this evidence and will ensure that these are the most suitable set of sites in order to do. Where required development principles will be provided in the Plan to minimise and mitigate the impact of any development. This is whilst ensuring the right uses and allocated in the most suitable locations.

Object

Representation ID: 7299

Received: 08/01/2024

Respondent: Ketton and Tinwell Joint Neighbourhood Plan Steering Group

We fully support the response on environmental matters – which are touched on throughout the Local Plan proposals and also looked at in depth in section EN - which has been submitted by the Leicester and Rutland Wildlife Trust.

In particular, we would note the need to strengthen the emphasis on avoiding negative impacts on local biodiversity, and in extending the time periods for biodiversity net gain. We also agree with their view that that currently the Plan does not look as fully as it might at the various important ecological characteristics of the county.

Comments noted that echo the representations from the L and R Wildlife Trust. Responses to the Trust's comments will be set out under each policy in the Environment Chapter.

Object

Representation ID: 7300

Received: 08/01/2024

Respondent: Ketton and Tinwell Joint Neighbourhood Plan Steering Group

We feel this policy should have more emphasis on restoration of mineral extraction areas for nature recovery within the county.

In particular, MIN 4 is very selective about the areas where it says damage should be avoided. It does not for instance mention Ketton Quarry Nature Reserve, which given its proximity to the new extraction areas still needs consideration. In addition, rather than purely looking at protection of, for instance, SSSIs, there should be adequate protection for general field and woodland biodiversity, particularly given the destructive nature of the mineral extraction process.

The restoration of mineral extraction sites is addressed in Policy MIN9 - Restoration and aftercare. It states that restoration should provide a net-gain in biodiversity and integrate where possible, into the forthcoming Nature Recovery Networks. Policy MIN4 requires proposals for mineral extraction to be environmentally acceptable and avoid and/or minimise potentially adverse impacts (including cumulative impacts) to acceptable levels. This includes consideration of all elements of the natural environment such as environmental designations and local landscape features. It is not necessary to list all the environmental constraints as such features will be taken into account on a site-by-site basis in line with the RLP policies and other relevant policies.

Object

Representation ID: 7301

Received: 08/01/2024

Respondent: Ketton and Tinwell Joint Neighbourhood Plan Steering Group

We were disappointed to see this survey had been carried out at what is in fact a very high level, without adequate attention to detail. Moreover, its purpose seems to have primarily been to identify possible new development sites, rather than in looking at how nature recovery might be taken forward in the county, in reflection of the need to tackle the twin crises in biodiversity and climate change.

Comments noted. Disagree regarding securing off-site BNG for a longer time period as this goes further than the TCP Act which requires any habitat enhancement to be maintained for at least 30 years after the development is completed. Work is currently ongoing to prepare a LNRS which will map and target actions in locations where they are most needed in order to reverse the decline of biodiversity. The LNRS, together with other supporting documents, will then be used to inform the preparation of the Local Plan and will guide policy requirements, such as in relation to Biodiversity Net Gain under Policy EN3.

Object

Representation ID: 7306

Received: 08/01/2024

Respondent: Ketton and Tinwell Joint Neighbourhood Plan Steering Group

The map for Ketton identifies KET 11 and KET 12 as being in Aldgate Court. These areas are not in Aldgate Court; they are in Aldgate, a completely different part of the village.

Either these sites have been incorrectly labelled, or they are supposed to be in Aldgate Court and are on the wrong part of the map.

We would like you to correct this.

KET11 and KET12 are shown within the supporting evidence base document (PLD Review Study 2023) as lying to the east of Aldgate, at the eastern end of a cul-de-sac labelled on Google Earth mapping as Aldgate Court (we appreciate there is another Aldgate Court in Ketton, off Station Road). We acknowledge that this is incorrect; KET11 and KET12 should be labelled as lying in Aldgate in the supporting evidence base document (PLD Review Study 2023).