Regulation 18 draft Local Plan

Object

Representation ID: 6939

Received: 08/01/2024

Respondent: Morcott Parish Council

1. policy needs to be both strengthened and adapted so that emerging technologies are included - eg hydrogen and small nuclear. Paragraphs d. e. and f. should be subject to these revisions.
2. inserting provisions that ensure that there is an obligation to install the latest climate change friendly technology as this becomes available.
3. including provisions within d. e. and f. which recognises that technology will change over the life of the Plan.
4. Para d. should include heat recovery from ground sources including ground water.
5. Para e. should include a reference to hydrogen or other forms of climate friendly gases being permitted in future to be supplied by a gas distribution main. Hydrogen forms a key part of the UK Government long term energy infrastructure plans.
6. Para f. should specifically mention solar pv, wind, air source and ground source technology.

Disagree. Part d) already references the ‘most efficient available technologies’ which would take into account new technologies. Parts e) and f) would also apply to new technologies. Part f) encompasses all on-site renewables: solar pv, wind, air source and ground source technology.

Object

Representation ID: 7385

Received: 08/01/2024

Respondent: Morcott Parish Council

Policy lacks targets and a planned approach which will result in piecemeal developments and the county will be subject to the whims of opportunist developers who are not going to adequately consider community involvement .
Too many potential opportunity areas for renewable energy shown on the Policies map which will encourage an excessive percentage of land area to be covered.
There should be a Rutland County-wide upper limit set as part of the Local Plan for the area of land approved for solar farm sites.
Applications for renewable energy sites for Wind or Solar generation should be subject to a planning condition requiring local community involvement in the 1. Design, 2. Appearance, 3. Landscape impact and 4. Community impact of the proposed site(s). All proposal should be subject to an Environmental Impact Assessment and a Noise/Public Nuisance Assessment (Wind) and must be required to calculate and declare the whole life carbon cost of the proposals from source and use of raw materials through to end-of-life restoration and must require sustainable end of life restoration.
The policy must include robust post-installation monitoring of compliance to both standard and special planning conditions together with appropriate enforcement measures

National policy is to maximise renewable generation and there is no requirement for the council to set a target for each renewable energy type. Para 003 of the PPG states that ‘The National Planning Policy Framework explains that all communities have a responsibility to help increase the use and supply of green energy, but this does not mean that the need for renewable energy automatically overrides environmental protections and the planning concerns of local communities.’ It also states that: ‘The UK has legal commitments to cut greenhouse gases and meet increased energy demand from renewable sources. Whilst local authorities should design their policies to maximise renewable and low carbon energy development, there is no quota which the Local Plan has to deliver.’ Thermal solar and air/ground source renewable energy tends to be on small sites or individual buildings so it would not be possible to map opportunity areas for such a scale of development. Such development is, however, supported by Policy CC8.
The identifying of opportunity areas and potentially suitable areas in the Local Plan is consistent with national planning policy. Not all of the areas would necessarily be suitable for renewable energy proposals due to, say, cumulative impacts, land ownership or other constraints.
Conditions would only be applied once a renewable energy application has planning permission. Developers are required to consult with communities for developments of one or more wind turbines, and that such proposals should have community support. The government has produced Good Practice Guidance on Community Engagement and Benefits for Onshore Wind Developments. For solar farm proposals, the council will expect developers to engage with the community prior to submission of an application. The council’s Statement of Community Involvement provides further guidance on appropriate consultation methods and how the results of community consultation should be used.
Not all renewable energy schemes will be EIA development and this is determined by the EIA Regulations. The requirement for a noise assessment submitted as part of the planning application would be set out in the Council’s list of validation requirements. This would consider the construction, operation and decommissioning stages of the development.
Such requirements would go beyond those set out in national planning guidance. Control of the reinstatement of the land would be covered by planning conditions and/or legal agreement. Monitoring and enforcement of the development would be part of the LPA’s responsibilities and does not need to be set out in the policy.

Object

Representation ID: 7386

Received: 08/01/2024

Respondent: Morcott Parish Council

Only if developers are targeted will they respond with adequate biodiversity schemes. Each development proposal should be required to achieve a biodiversity net gain which makes a meaningful contribution to the overall target. A Biodiversity gain of 15% from a very low level is meaningless without having an overall target level for the County to reach over the life of the Plan. An overall planned target level of biodiversity for Rutland is required. This would ensure the achievement of an overall healthy local ecosystem rather than unconnected spot improvements from an unknown base.

Comments noted. There is a mandatory requirement for new (qualifying) developments to provide at least a 10% BNG and the process for this is set out in legislation. Developers are legally bound to comply with the legislation on BNG. Work is currently ongoing to prepare a Local Nature Recovery Strategy (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: 7387

Received: 08/01/2024

Respondent: Morcott Parish Council

Need to plan for infrastructure which would support and control agricultural transport. As agricultural vehicles become larger and more efficient they become more intrusive and dangerous if used on the road network. Policy should refer to a plan for safe agricultural transport. Operators of agricultural vehicles should be required to operate in a safe manner whilst on public roads. Restrictions should be placed on the maximum size of vehicles allowed to be used on narrow roads and through villages. Preferred routes for large agricultural vehicles and adequate notice of vehicle movements could be established in conjunction with communities.

Comment Noted. This falls outside the scope of the Local Plan however, Farmers planning to move oversized machinery on the rural road need to complete Agricultural Vehicle Dispensation Scheme documentation. In normal circumstances, police must be notified at least 24 hours before vehicles more than 3m wide and/or with a speed limit of 40mph or less are taken on the road, or when they are travelling distances greater than five miles. However, applying for annual dispensation is a way to manage the uncertainty of short term dispensations, but it must be done prior to travel and the document should be kept in the vehicle at all times. Once granted, machinery up to 4.3m (14ft) wide can be moved without the need to notify police. This typically includes the majority of medium and large wheeled combines, as well as the bigger tracked tractors. The scheme allows farmers to chaperon their own machines, within a 25-mile radius of their base, using a suitable escort vehicle running ahead to warn oncoming traffic – tractors and telehandlers towing the header can’t be used to escort the combine.

Object

Representation ID: 7388

Received: 08/01/2024

Respondent: Morcott Parish Council

We strongly object to the re-classification of the spatial strategy utilising just two categories, i.e. Large Village and Small Village, which we think inadequately reflects the real-life grouping of Rutland’s villages and contains unanticipated consequences for those villages such as Morcott which are of “Medium” size rather than “Smaller” or “Larger”. We request that more thought is put into the spatial strategy so that it actively aids preservation of the character of Rutland.
The inappropriate wording in Policy SS4 strengthens the need for a “Medium” size of village in the spatial strategy so that the implications and consequences of Policy SS4 can be thought through and defined with more clarity and better reflecting the range of different sizes of Village currently found within Rutland.

The proposed approach is considered to be an appropriate for the scale of villages in Rutland. Under the current adopted plan there is little difference in policy terms between what is acceptable development in Local Service Centres and Smaller Service Centres, other than where sites are allocated. Combining the two categories in policy SS1 reflects the existing similarities in terms of policy. Therefore although the classification of Morcott has changed from a Small Service Centre to a Larger Village the policy for development within the PLD has not changed.

The removal of PLDs from smaller villages actually provides them with greater protection from development as they become classed as countryside. Clarification of this

Policy SS4 will be considered separately

Object

Representation ID: 7389

Received: 08/01/2024

Respondent: Morcott Parish Council

Morcott falls into the Larger Village category even though it falls below the housing number threshold defined and has no public facilities other than a village hall (privately owned & run by a trust, not by the Parish Council). The convenience facilities are provided by two petrol filling stations situated on the A47, both of which are inaccessible on foot for many of the village (e.g. including young people, the elderly & the disabled) by virtue of distance or the necessity of crossing the A47. Should the current Spatial Strategy definition of Larger and Smaller Village be retained we suggest that Morcott is redefined as a “Smaller Village”.

The evidence contained within the Spatial Strategy Background Paper shows that Morcott has more than 150 homes and a population of more than 300 people.
The categorisation of villages uses this data rather than the presence of local shops and public houses which can change during the lifetime of the plan.

Object

Representation ID: 7390

Received: 08/01/2024

Respondent: Morcott Parish Council

Removal of Permitted Limits of Development (PLD) from the Smaller Village category is an error as it has unexpected consequences. The distinction that everything outside the PLD is in open countryside does not offer the necessary level of protection from unwanted and unwarranted development. The potential for uncontrolled growth of Small Villages rather than organic growth through infill should be avoided by the restoration of the existing PLD. The policy does not adequately reflect the nature of Rutland’s Smaller Villages: In many Smaller Villages 5 dwellings would be considered to be an unacceptably large development which would be considered disruptive and inappropriate.
The meaning and importance of the PLD should be emphasised and the concept applied without exception. Rather than viewing the PLD as a concept which can be avoided in certain circumstances it should be very clear that any development beyond a PLD is not acceptable.

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: 7391

Received: 08/01/2024

Respondent: Morcott Parish Council

. Far too many planning applications are submitted without consultation with neighbours which leads to rancour and an excessive number of objections. In addition to the provisions of this policy we believe that SS2 should make it clear that all applicants are required to certify that they have properly consulted with their immediate neighbours prior to their application being submitted. Each neighbour consulted with should be listed in the application. We believe that this would result in far less time wasted by Planning Officers and staff in dealing with objections and would reduce the load on the Planning Committee so that it was able to devote sufficient time to major or disputed developments.

Noted. Please note, the policy as written largely reflects national guidance.
However it is useful for the local plan to clearly set out what is expected for the submission of planning applications and it is therefore suggested that the policy becomes supporting text within the plan.

Object

Representation ID: 7392

Received: 08/01/2024

Respondent: Morcott Parish Council

This policy does not include sufficient safeguards to prevent the over-ambitious & ill thought through development and other mistakes around the issue of the St George’s site previously proposed.
The policy should include a more tightly defined framework plan and include tighter assumptions as to the number of dwellings permitted, the amount of land to be devoted to economic activity (and the types of employment preferred), the land reserved for mineral extraction and a vision of restorative measures post extraction. It should define RCC s being responsible for the Masterplan that would become the Development Plan Document if local accountability is to be affirmed.
A total number of dwellings and the density per hectare should be defined very closely and loose phrases such as “will be expected to” or “not expected to” should be replaced by more prescriptive phrasing such as “will” or “will not”.
The development pathway and milestones for the St. George’s site over the next 20 years+ must have clarity and definition. Transport and Infrastructure improvements must pre-date development and funding pathways determined before any development for housing or employment takes place.

Comments noted. However, the purpose of Policy SS5 (now SS4) is to guide future proposals for the redevelopment of SGB. Identifying St George's Barracks as a Future Opportunity Area 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.

Object

Representation ID: 7393

Received: 08/01/2024

Respondent: Morcott Parish Council

Policy SS6 should include a requirement for a Transport Assessment (as in Policy SS7) if any proposal for development is beyond a certain size eg 25 dwellings. The Transport Assessment needs to include the wider impact on County roads and villages linked by the road network on the formulation of plans for any military or prison site including St George’s.

Comments noted. St George’s is not covered by Policies SS6 (now SS5) and SS7 (now SS6). Criteria c) and e) of SS6 (now SS5) require consideration of the highway impacts of development proposals, including impact of traffic on local communities. There are no definitive thresholds set out in national planning guidance that dictate when a Transport Assessment is required, as local factors will determine whether the Council considers a development will have a 'significant impact' on transport or not. They are usually required, however, in relation to major development which are more likely to be applicable under Policy SS7 (now SS6).