Regulation 18 draft Local Plan

Object

Representation ID: 7329

Received: 08/01/2024

Respondent: Jeakins Weir

Agent: Jeakins Weir

There is no indication within the emerging local plan or its evidence base as to when this would need to come forward to support ongoing needs, but it is worthy of note the latest Annual Position Statement (APS) adopted by neighbouring South Kesteven District Council and subject to examination by the Planning Inspectorate contains a number of useful comments on the deliverability of Quarry Farm, which should be taken into account as part of any assessment of the plan-led supply.
The Inspector noted that due to the scale of and the infrastructure requirements associated with Stamford North, it is a complex site, and referred to the need for further transport modelling. Nonetheless, the Inspector endorsed the build trajectory provided by Allison Homes (the promoter of Quarry Farm) which anticipated the start of completions from 2025/2026. However, submissions from Allison Homes indicated that completions beyond 300 units at Quarry Farm will not occur before the completion of a new Distributor Road which clearly presents a risk from a timing perspective, given that Stamford North plays such a significant role in the emerging Rutland Local Plan’s spatial strategy.

Object

Representation ID: 7330

Received: 08/01/2024

Respondent: Jeakins Weir

Agent: Jeakins Weir

The Site Allocations Assessment records that the site has access and parking concerns, but does not elaborate further. Furthermore, the site is located adjacent and clearly visible from Oakham’s conservation area and it is clear from the assessment that no heritage expertise have informed this site’s selection for a draft allocation.
Though no mention is made of it within the Site allocations Assessment, the site is also located adjacent to a Grade II* listed building to the east and a Grade II listed building to the north. There has been no judgement as to whether the heritage constraints will impact upon site capacity or similarly make its development unacceptable. The assessment nonetheless records the heritage impacts of developing the site site as “Red” indicating a “significant adverse impact” that “cannot be mitigated.”
The Environmental Health Officer identifies that contamination is likely and it is unclear from the assessment the extent for this and whether it is capable of being viably remediated.

Object

Representation ID: 7331

Received: 08/01/2024

Respondent: Jeakins Weir

Agent: Jeakins Weir

The Easson’s garage site at Cottesmore (H1.5) is allocated in draft for 8 dwellings. The Site Allocations Assessment, however, states that the site has capacity for only 4 dwellings. There is no highways assessment of the proposed allocation and the conservation area and listed building impacts have been rated as “Red,” indicating significant harm. It is hard to see on these facts how such an allocation available or achievable. It is plainly not justified.

Object

Representation ID: 7332

Received: 08/01/2024

Respondent: Jeakins Weir

Agent: Jeakins Weir

Land East at the Workshops, Exton is draft allocated for 15 dwellings (H.10). The draft allocation within the plan identifies the site as “brownfield” when the Site Allocations Assessment identifies it has “greenfield.” It appears that whilst part of the site is occupied by hardstanding and buildings, these are in fact in agricultural use meaning that the site is not, in fact, brownfield either in whole or in part.
The Site Allocations Assessment does not contain any highways comments but it would appear from reviewing the narrow and constrained nature of the access, and its current and presumably future use for what appears to be a fairly intensive agricultural operation, that achieving access for the scale of development anticipated would be challenging.

Object

Representation ID: 7333

Received: 08/01/2024

Respondent: Jeakins Weir

Agent: Jeakins Weir

Proposed development of this site for 93 dwellings was refused planning permission in April 2023 for seven separate reasons including the effect of the proposed development on the landscape and settlement character given the prominence of views of the site on the approach to the village as well as adverse impacts on neighbouring amenity, which according to the Council’s assessment could not be avoided. Identification of this site as a reserve site for 90 dwellings is therefore not well-founded, given that it is unlikely to be able to support this scale of development without generating a materially adverse impact.
This proposed Reserve Site is inappropriate both in terms of scale for the settlement of Cottesmore and for the reasons given by the Council less than a year ago for refusing the grant planning permission why a planning application.

Object

Representation ID: 7334

Received: 08/01/2024

Respondent: Jeakins Weir

Agent: Jeakins Weir

Marrons is promoting Land at Seaton Road, Glaston on behalf of Jeakins Weir for residential development. This site is available now and deliverable with no fundamental technical constraints. Given that it is within the PLD for Glaston and due to its previously developed nature, delivery of the site for residential development is supported by the provisions of the adopted development plan.
Retention of the PLD for Glaston or else the articulation of a clear policy framework for land within and well-related to the smaller villages as suggested above, would support the delivery of this sustainable site for development to in order to meet housing needs.
We note from the December 2019 Strategic Housing and Economic Land Availability Assessment (SHELAA) that the site was not carried forward for further assessment given it was not located adjacent or within the towns or the local service centres. We note, also however, that many allocations and reserve sites have been identified in Draft Policy H1 at locations that were not previously classified as towns or local service centres. There is no clear explanation for this apparent lack of consistency.

Object

Representation ID: 7335

Received: 08/01/2024

Respondent: Jeakins Weir

Agent: Jeakins Weir

The analysis presented in the Small Sites Windfall Study demonstrates that the provision of small windfalls has been heavily led by rural settlements and the positive policy framework provided by the PLDs is likely to have had a significant influence on that. Through deletion of the PLDs at many rural settlements, it is unlikely that these will continue to sustain the level of windfall seen historically and that as such, the assumed windfall allowance of 25 dpa is likely to be over-optimistic in light of the emerging local plan’s more restrictive approach.

Object

Representation ID: 7336

Received: 08/01/2024

Respondent: Jeakins Weir

Agent: Jeakins Weir

We are concerned regarding the inconsistent and contradictory assessment provided of our client’s site at East of Uppingham Road, Oakham (REF OAK02) within the Site Allocations Assessment and ask that this element of the evidence base is revisited.
Taken cumulatively the approach of Draft Policy SS1 in respect of the smaller rural settlements is overly restrictive and will discourage suitable windfall sites from coming forward within the county’s smaller rural settlements. This is contrary to the advice of paragraph 69 of the National Planning Policy Framework which requires local planning authorities to, amongst other things, support the development of windfall sites through their policies and decisions, giving great weight to the benefits of using sites within existing settlements for homes. The Planning Practice Guidance (PPG) similarly states:
“A wide range of settlements can play a role in delivering sustainable development in rural areas, so blanket policies restricting housing development in some types of settlement will need to be supported by robust evidence of their appropriateness.”
Supply-side contingency should not be identified as a way to address concerns about the robustness of the housing requirement. Similarly, contingency should not be identified as a way to address uncertainties over the deliverability of the supply. Rather, deliverable sites should be selected from the outset and contingency added to these to ensure flexibility to respond to changing circumstances.

Object

Representation ID: 7337

Received: 08/01/2024

Respondent: Jeakins Weir

Agent: Jeakins Weir

The more recent 2023 SHMA suggests a need for 78 affordable homes per annum. Even if 78 dpa was an over-estimation of affordable needs within Rutland, it is more than twice the level of gross average annual affordable housing delivery over the last 10 years and almost twice the target of the adopted 2011 Core Strategy of 40 affordable homes per annum. Adopting a housing requirement analogous to the LHN (123 dpa) which is significantly less than historic average delivery will likely not meet even the Core Strategy’s modest and now very dated affordable housing target. The evidence base clearly suggests that the local planning authority should be considering an uplift to the housing requirement in order to bring forward sufficient affordable housing over the plan period to meet needs. Unfortunately, this is not reflected in the emerging local plan or in its housing requirement.

Object

Representation ID: 7338

Received: 08/01/2024

Respondent: Jeakins Weir

Agent: Jeakins Weir

This matter of economic growth and its relationship to housing growth is discussed within the August 2023 SHMA. Though its recommendations in this regard are quite equivocal, the conclusion of the August 2023 SHMA is that ultimately the baseline job forecast within the ELR suggests a level of housing requirement in excess of the minimum amount, though it does not say by how much and suggests that determining this is an exercise for the plan-maker. But it is clear from Policy SS1, which adopts only the minimum LHN figure as the housing requirement, this recommendation has not been taken on board by the local planning authority.