Regulation 18 draft Local Plan

Object

Representation ID: 7063

Received: 08/01/2024

Respondent: Wing Parish Council

The Viability Report, concerned primarily with the production of ‘Housing’ in the context of the present
situation in Rutland, is wide-ranging and comprehensive. However, we have a number of seriously critical comments, as follows

1. At clause 1.17, there is a vital and substantial caveat on interpreting the Report – part of which states “No part of this Report constitutes a valuation and should not be relied upon in that regard.” Much of the viability calculation relates to relative valuations in determining yield, the Report thereby cannot be relied on and effectively falls at the first hurdle.

3.2. Similarly, the Report clearly states that the Consultant does not warrant the estimates and projections made, which again are key to comprehending the range and levels of risk inherent to the Assessment. The second hurdle is failed because the caveat is absolute.

3.3. These opening clauses also make clear, and it is repeated at certain junctures throughout the paper, that much of the data and information used to underpin the
Assessment has been provided by the Local Authority (RCC), or its “contractors” (unspecified), for which HDH carries no responsibility. This caveat potentially invalidates the notion of ‘third party opinion being independent and based on objective technical and professional review’ in the Assessment. A third fundamental hurdle is failed.

3.4. The Report states that the Plan contains “no Strategic Sites”. Does this mean that RCC have ruled out of their consideration all potential Strategic Sites in determining
the Plan and its viability, if so, clearly closing the door on such option for a considerable period? St. Georges Barracks is mentioned and even the reduced number of houses cited, as a percentage of RCC’s total housing estimates would clearly have strategic impact on all other RCC Policies. This appears contradictory.

3.5. Whilst the EUV+ is a recognised and accepted approach to forecasting development costs, there is little detailed argument about how the + element might be impacted in the context of rapidly changing adverse market conditions, the Report relying instead on historic averages.

3.6. Similarly, the calculation of Development Returns is estimated at between 15 to 20%, such range of figures being associated with a buoyant purchasing housing
market and taking no account of either the changes referred to at (5) or the additional statutory demands made by Government environmental commitments that are yet fully to feed into Development Costs.

3.7. Rutland already has ‘outlier’ status in terms of the number of ‘four bedroom plus’ houses, and in terms of under-occupancy, it has high average house prices in
total all partly as a product of the above planning/market distortions. However there is no indication of attempting to correct these figures related to expressed housing needs. This will be compounded by the estimates being suggestive of those existing market outlier size distortions being the most capable of meeting the expressed demands related to enhanced environmental and energy measures, which could reinforce those market distinctions/distortions, creating an even greater scarcity of affordable housing to both rent and buy within Rutland.

Object

Representation ID: 7500

Received: 08/01/2024

Respondent: Wing Parish Council

We are pleased to see the prominence given to this critical issue, but feel strongly that the Council could and should be more ambitious. Several policies have been considerably watered down from the carbon reduction targets we had hoped RCC would follow. Central Lincs and Cambridge have set the necessary targets and their plans are adopted, while RCC appear to have backed down because of their flawed Viability Assessment. The situation has been made more difficult with the Minister putting out a directive that all LP’s must follow Building Regulations while the Future Homes Standard (FHS) intended to upgrade these is currently out for consultation. Astonishingly, the FHS does not even list solar panels as a developer requirement

Object

Representation ID: 7501

Received: 08/01/2024

Respondent: Wing Parish Council

This is very much “motherhood and apple pie”, lacking specifics and with no indication of how it will be enforced. What does “highest possible energy efficiency standards” mean? Where is an ambitious target? There are local concerns about how to improve energy efficiency of homes in Wing especially older/listed houses but the planning constraints imposed by RCC on altering existing housing are significant. The adoption of Future Homes Standard will provide little energy efficiency gain so not offsetting Rutland’s older housing stock.

Object

Representation ID: 7502

Received: 08/01/2024

Respondent: Wing Parish Council

Again the policy is weak, in requiring only that developers should “consider” various elements in their designs.

Object

Representation ID: 7503

Received: 08/01/2024

Respondent: Wing Parish Council

This should be worded more strongly to require that all new
developments must provide all their own energy needs and achieve the net zero carbon targets. The policy is simply not ambitious enough to address the objectives outlined at the start of the Plan.

Object

Representation ID: 7504

Received: 08/01/2024

Respondent: Wing Parish Council

We support the principle of reducing energy consumption in existing buildings but we know from the experience of residents of Wing (which has many older and listed buildings) that this is often far from easy. There can be severe technical difficulties in retrofitting old buildings to use new energy sources, apart from planning issues which require clear policies to balance conservation and energy efficiency.

Object

Representation ID: 7505

Received: 08/01/2024

Respondent: Wing Parish Council

The policies map shows a variety of “suitable” locations for solar and wind initiatives, the methodology behind these sites is not easily accessible. There is no transparency and no consultation with local communities.

It appears that the map has been generated based on geographical features, with no regard for practicality, aesthetics or local sensitivity. It seems that the same methodology has been used to identify potential sites for wind turbines or solar panels, which have very different requirements and implications.

The study should have applied height criteria when considering turbines, and different gradient criteria for turbines and solar. The map is a hostage to fortune that could be used to encourage speculative and wholly inappropriate developments.

We strongly object to the identified locations near Wing, which are not supported at this scale in our NP. In particular, the site north of the village in the Chater valley.

The study was prepared by the same consultant AECOM who also has prepared the FHS. Yet, the FHS dismisses the need for solar panels on houses and relies on decarbonising the grid to make up the necessary carbon reduction. However, the Rutland Renewable Energy Study clearly states the lack of capacity in the grid to realise the potential renewable energy generated.

What weight will be given to sustainable energy in manufacturing when set against the capacity for ‘green’ energy generation? The plan is silent on these important issues.

Object

Representation ID: 7506

Received: 08/01/2024

Respondent: Wing Parish Council

It is disappointing that the policy on sustainable travel deals only with provision for electric vehicles and charging points and fails to consider other forms of public or private transport, including buses and cycling

Object

Representation ID: 7507

Received: 08/01/2024

Respondent: Wing Parish Council

Much of this chapter appears contradictory (and confusing) especially on planned limits of development and the assessed need for housing.

Support

Representation ID: 7508

Received: 08/01/2024

Respondent: Wing Parish Council

We are pleased to note that Wing is identified as a larger village, appropriately reflecting the range of facilities and character of the village.