Regulation 18 draft Local Plan

Support

Representation ID: 7014

Received: 08/01/2024

Respondent: House Builders Federation

HBF agree that the Vision for Rutland should include reference to the need to meet the current and future housing needs of the whole community, including for market and affordable housing. We agree that new housing is needed in towns, larger villages and smaller settlements. HBF also agree that it is important for the Local Plan Objectives to recognise the connection between housing and the future aspirations for the local economy.

Support

Representation ID: 7526

Received: 08/01/2024

Respondent: House Builders Federation

HBF support the intention of Strategic Objective 3 to meeting Rutland’s identified current and future diverse housing needs.

Object

Representation ID: 7535

Received: 08/01/2024

Respondent: House Builders Federation

HBF are pleased that the Council have recognised the need for the Plan to cover a period of 15 years from adoption. We would highlight that plan-making can take time and would encourage the Council to consider whether the Plan period should be extended to 2042 or 2043 to ensure that this will still be the case even if there is an unexpected delay during the plan-making and Examination process. It will be
essential that the evidence base covers the full plan period and as such HBF suggest there is merit in considering this issue now.

Object

Representation ID: 7537

Received: 08/01/2024

Respondent: House Builders Federation

HBF supports the Government’s intention to set standards for energy efficiency through the Building Regulations. The key to success is standardisation and the
avoidance of individual Council’s specifying their own policy approach to energy efficiency, which undermines economies of scale for product manufacturers,
suppliers and developers. The Councils do not need to set local energy efficiency standards, or a requirement for zero carbon homes, in a Local Plan policy.

HBF would caution against policies that seek to go further and faster than national policy changes as this would lead to a patchwork of local policies which could undermine the delivery of these wider environmental objectives and create unnecessary delays to much needed new housing.

If a policy were to remain, HBF would question if the requirement for all new development to be net zero carbon in terms of heat supply is realistic in all cases,
and suggest some flexibility is needed within the policy.

Object

Representation ID: 7538

Received: 08/01/2024

Respondent: House Builders Federation

HBF would question what this policy is seeking to achieve and what it adds to Building Regulations. What will the Council do with the information of the ‘as built’ calculations when they receive it? What action could or would be taken once the homes have been completed? HBF note that Plan explains that consideration is being given to the viability of this approach and agree that energy efficiency requirements (and other policies) need to be subject to robust viability testing. However, this policy seems unnecessary and should be deleted.

Object

Representation ID: 7539

Received: 08/01/2024

Respondent: House Builders Federation

HBF are unclear how a developer would show compliance with this policy, and whether the Council has the skills and expertise to undertake or critique embodied carbon assessments, especially as be qualified to make judgements on accepting or rejecting carbon assessments as the baseline and measures therein have not been established. HBF therefore view this policy as unnecessary, and it should be deleted.

Object

Representation ID: 7540

Received: 08/01/2024

Respondent: House Builders Federation

HBF note that the current Part G Building Regulations requires developments to compliance with a limit of 125 litres per day. House builders are frequently delivering
115-110 litres per day which means the house building industry is already improving upon the regulations. HBF would caution against policies that seek to go further and
faster than national policy changes that result in patchwork of differing local standards. Because. There is therefore no need for a policy on this matter in a Local Plan.

Object

Representation ID: 7541

Received: 08/01/2024

Respondent: House Builders Federation

Although HBF does not comment on individual sites or allocations, we believe that the Plan should provide for a wide range of deliverable and developable sites across
the Borough in order to provide competition and choice to ensure that housing needs are met in full. HBF would wish to see the Plan set out a logical settlement hierarchy
which meets all the housing needs and addresses all areas of the housing market, with a range of sites proposed for allocation.

The NPPF requires Local Plans to identify land to accommodate at least 10% of the housing requirement on sites no larger than one hectare, unless there are strong
reasons why this cannot be achieved.

HBF would therefore wish to see the 10% small sites allowance delivered through allocations (and not windfall). Such sites are important for encouraging the growth in
SME housebuilders who will tend to develop these sites but rarely see the benefits that arise from the allocation of sites in a local plan.

Although a policy that sets criteria to enable housing is smaller settlements is welcomed, HBF would support a Local Plan that included sites allocated sites in rural areas. HBF supports this being done through plan-making process in the Local Plan
which provides certainty in meeting rural housing needs.

The Plan needs to set out how and when monitoring will be undertaken, and more is needed on what action(s) will be taken when if monitoring shows under delivery of
housing.

Object

Representation ID: 7544

Received: 08/01/2024

Respondent: House Builders Federation

The standard method LHN should be the minimum starting point for establishing the housing requirement and the Council should then considers if there are issues that result in the need for a higher housing requirement, including the need to provide a range and choice of sites, the need for flexibility, viability considerations and whether higher levels of open-market housing are required in order to secure increased delivery of affordable housing.

HBF suggests that Council should consider if these factors, individually and/or cumulatively result in the need for a higher housing requirement for Rutland, and a subsequent need for additional allocations.

HBF note that the consultation acknowledges that
“some or all of the reserve sites may still need to be allocated in the final version of the plan if the minimum housing need increases or if any of the preferred sites
become unavailable or undeliverable. HBF suggest reserve sites should be allocated so they that can be easily and quickly brought forward to address any under-delivery of housing supply.

HBF believe that the Plan should provide for a wide range of deliverable and developable sites, including a buffer and small site allocations across Rutland in
order to provide competition and choice to ensure that housing needs are met in full.

Object

Representation ID: 7545

Received: 08/01/2024

Respondent: House Builders Federation

HBF have no comments on this policy other than to note that cross-boundary strategic sites can be complex to deliver, which further underlines the need for
flexibility in the plan through additional allocations, and robust monitoring to ensure effective housing delivery is achieved over the Plan period.