Regulation 18 draft Local Plan
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Regulation 18 draft Local Plan
General comments
Representation ID: 7309
Received: 08/01/2024
Respondent: Ketton and Tinwell Joint Neighbourhood Plan Steering Group
The availability of documentation.
It is slightly disconcerting that information that appears to have been in documents at the beginning of the consultation period is no longer available. In the case of Ketton, a map that was available for the employment sites under policy EN 1 which was on the website at the start of the consultation process was not there on 8th January.
Another example of this is that originally the list of made neighbourhood plans on page 6 failed to include Ketton and Tinwell. It now does. Whilst we are grateful that this error has been rectified, overall these instances do not engender confidence in the permanence of the text of the Local Plan consultation.
The relationship between the Local Plan and Neighbourhood Plans
We are pleased to see that in respect of a number of important policies e.g. EN8 and EN 9, and CC 8, there is specific reference to additional requirements within neighbourhood plans that need to be taken into account. We feel that it would be appropriate for all policies as necessary to make this kind of reference (e.g. EN 7 on blue and green infrastructure) as well as having an overall clear explanation within the opening text of the plan about how the specific local requirements of neighbourhood plans will be addressed (as opposed to the current generalities about the existence of neighbourhood plans).
Comments noted. Once uploaded for the start of the Regulation 18 consultation period, the Plan was not amended in any way. It may be that the issues experienced may have been a temporary technical issue. The text under the heading ‘How do Neighbourhood Plans fit in?’ outlines how, once adopted, NPs form part of the statutory development plan and their role in determining planning applications. It is not considered necessary or appropriate to reference them in all the policies in the Local Plan.
Comments on sustainability in relation to Ketton to be considered under Policy SS1.
Comments on infrastructure covered under Policy INF1.
Comments on flood risk considered under Policy CC14.
Support
Regulation 18 draft Local Plan
Policy SS1 - Spatial strategy for new development
Representation ID: 8043
Received: 08/01/2024
Respondent: Ketton and Tinwell Joint Neighbourhood Plan Steering Group
When so much development has been crammed into the larger villages over recent years, with Ketton being a particular example of this, it is encouraging that there is wording in the Spatial Strategy section that is far more reflective of the fact that larger villages are not necessarily more sustainable for development; they just have a few more than amenities than the very small villages. In particular, the existence of one very sporadic bus service has frequently has in the past been deemed, quite unrealistically in our view, to make a larger village an inherently sustainable location.
We welcome that the emphasis is that such development that comes forward in the larger villages in future will be small-scale. We hope this will truly be the case in future, as it has clearly not been so up until this point, with very large developments being forced into Ketton during recent years.
It would be helpful to for the Local Plan to be worded more strongly in this respect. This would help guard against unrealistic statements within developers’ proposals which imply that all that larger villages are, by definition, sustainable locations for more development.
Support noted
Object
Regulation 18 draft Local Plan
Policy INF1 - Infrastructure and connectivity
Representation ID: 8044
Received: 08/01/2024
Respondent: Ketton and Tinwell Joint Neighbourhood Plan Steering Group
We would also like to note, context of INF 1, that whilst provisions within this policy in themselves appear acceptable, this does not address the chronic under-provision of basic infrastructure in many villages for services such as water and sewerage. Whilst developers may be required to provide drainage/sewerage in the context of their own sites, we feel insufficient attention is still being paid to how that interacts with the overall water/sewerage infrastructure, and how the effect is exacerbated by the significant increase in development over recent years. We would welcome a clearer indication from the Local Authority that these issues and impacts, both cumulative as well as individual, will be addressed.
Comment Noted. The need for upgrades to critical infrastructure in many villages, such as water and sewerage, is recognised and the ability of existing utility networks to service new development is key to Policy INF 1. The cumulative impact of the levels of growth planned in the new Local Plan on utilities has been considered in preparation of the Infrastructure Delivery Plan which forms part of the new Local Plan evidence base and where necessary critical projects identified.
Object
Regulation 18 draft Local Plan
Policy CC14 - Flood Risk
Representation ID: 8045
Received: 08/01/2024
Respondent: Ketton and Tinwell Joint Neighbourhood Plan Steering Group
While the risk of flooding is referenced in a number of policies, the Strategic Flood Risk Assessment (SFRA) appears to us to be out of date for the areas to the South East of the county along the Welland Valley. The draft 2023 assessment available on the RCC web site is based on a 2009 SFRA with updates carried out using a desktop assessment process.
Given the increase in flooding over recent years from the Chater, Welland, Surface Water and Underground Springs we do not believe that the Local Plan is robust enough in this respect to ensure additional flood problems with new developments over the period covered by the new Local Plan will be addressed.
The draft SFRA also includes a list of reported flooding events over the period Jan 2018 to June 2023. While there are a number of entries from Ketton, these do not cover the full impact of the flood events over the period. The RCC website does not include a reporting mechanism for flooding.
The overall objective of the SFRA is to identify any constraints on housing and employment growth planned for Rutland up to 2041 that may be imposed by flood risk and how these can be resolved i.e. by ensuring that flood risk taken into consideration. The updated SFRA 2023 uses the latest flood risk maps from the Environment Agency data source March 2023. It also includes an assessment of the implications of climate change on flood risk.