Regulation 18 draft Local Plan
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Regulation 18 draft Local Plan
Policy H1 – Sites proposed for residential development
Representation ID: 6525
Received: 08/01/2024
Respondent: Allison Homes
AH support the draft policy and have no suggested changes to the proposed wording.
The policy confirms the logic of the spatial strategy and ongoing cooperation/alignment with the SKDC Local Plan, both adopted and emerging.
Support noted.
Object
Regulation 18 draft Local Plan
Policy SS1 - Spatial strategy for new development
Representation ID: 6528
Received: 08/01/2024
Respondent: Allison Homes
Draft Policy SS1 advises that:
The majority of new development will be focussed within.... .and on land adjacent to Stamford (which lies within South Kesteven District adjoining the County boundary).
The land adjacent to Stamford which forms Monarch Park is within the RCC boundary, there is of course the adjacent land within SKDC boundary but that does not count towards RCC housing delivery.
We would suggest that the sentence in brackets is not required and is also confusing.
Comments no9ted. Amend SS1a.
Object
Regulation 18 draft Local Plan
Policy H2 – Cross-boundary development opportunity – Stamford North
Representation ID: 6529
Received: 08/01/2024
Respondent: Allison Homes
The parties agree that the site is a sustainable location for development and that the site can in principle be developed to deliver 650 dwellings, a road connecting the eastern and western boundaries of the site and a country/community park which will also act as mitigation and a translocation area.
Ultimately the development proposal represents an opportunity to deliver significant benefits to the locality whilst underpinning the Councils housing delivery strategy. It is a viable, available and deliverable proposal that will be completed in the next 5-10 years.
(We have provided a formal response regarding the policy to RCC)
All site appraisals have been reviewed in the light of comments and further evidence received to determine their suitability for allocation.
Support
Regulation 18 draft Local Plan
Car Park 3 Rutland Showground, Oakham
Representation ID: 6611
Received: 08/01/2024
Respondent: Allison Homes
We support the allocation of this site for employment purposes and given its sustainable location we would encourage the Council to considered a wider a range of potential uses that could be accommodated on this land parcel, including Class E uses.
We can confirm that the site is available, deliverable and viable for employment use including E classes and there has been market interest for employment purposes to be located on the site.
We would welcome further discussions with the Council on defining the appropriate use classes.
Support noted.
Object
Regulation 18 draft Local Plan
Policy SS1 - Spatial strategy for new development
Representation ID: 7190
Received: 08/01/2024
Respondent: Allison Homes
The annual housing requirement of 123 dwellings, would result in a level of housing delivery which is lower than the current 160 dwellings per annum. There is considered to be an existing and pressing local need for housing in many areas of Rutland. It is therefore suggested that the proposed housing delivery of 123 dwellings per annum should be expressed as a minimum requirement.
It’s also considered that the PLDs should be amended to accurately reflect the sites proposed for allocation in ongoing Neighbourhood Plan Reviews i.e. Uppingham.
Comments regarding the housing requirement are considered separately under policy H1
Any necessary changes to PLDs arising from the Uppingham Neighbourhood Plan (and other Neighbourhood Plans currently going through the statutory process ) will be changed once those plans have been "made"
Object
Regulation 18 draft Local Plan
Policy H1 – Sites proposed for residential development
Representation ID: 7191
Received: 08/01/2024
Respondent: Allison Homes
Policy H1 states that 316 dwellings are to be allocated through the Uppingham Neighbourhood Plan. AH supports the overall allocation of dwellings to Uppingham, however believes the Local Plan should also identify these supported allocations rather than relying on the adoption of the neighbourhood plan review.
AH control land off Ayston Road, Uppingham. This benefits from a draft allocation in the Uppingham Neighbourhood Plan Review (ref. U-HA2) for the development of up to 40 dwellings plus a commercial / food store (equating to 13 dph). AH believe circa 70 no. new dwellings plus a commercial / food store is deliverable on the site – resulting in a more efficient use of land in accordance with the NPPF.
Currently, Policy U-HA2 and Policy H1 are contradictory, with the proposed allocation suggesting a considerably lower density than the target stated in adopted and emerging Policy H1 (25 dph).
Furthermore, AH believe the overall requirement of 316 dwellings delegated to Uppingham should be increased given the uncertainty surrounding the two proposed “longer-term” Neighbourhood Plan allocations. Sites U-HA4 and U-HA5 are reliant on primary vehicular access over third party land and are potentially undeliverable in the plan period due to delivery and ransom constraints.
As such, the proposed indicative housing supply for Uppingham should be either increased or specified as a minimum figure.
All site appraisals have been reviewed in the light of comments and further evidence received to determine their suitability for allocation.
Object
Regulation 18 draft Local Plan
Policy CC2 - Design Principles for Energy Efficient Buildings
Representation ID: 7192
Received: 08/01/2024
Respondent: Allison Homes
AH suggests that Policies CC2 and CC4 are removed, and that the Plan takes a more flexible approach to requiring developments to meet national sustainability standards being developed and enforced through the Building Regulations which in turn would future proof the policy.
The Council may wish to reconsider this policy in the context of the consultation version of the FHS
Disagree regarding CC2. It is acknowledged that the Government is committed to improving the energy efficiency of new homes through the Building Regulations system under the Future Homes and Buildings Standards which are due to take effect in 2025. The FHBS is still being debated, however, and there is no legal guarantee of that date being met. Recognising that buildings are the UK’s second-highest emitting sector, and that it is significantly cheaper and easier to install energy efficiency and low carbon heating measures when building from scratch rather than retrofitting them afterwards, Policy CC2 sets out a series of design principles for energy efficient buildings. The Plan acknowledges, however, that a key consideration for Policy CC2 is its impact on the viability of new developments (that would include affordable housing). It is intended that further work to update the cost evidence will be undertaken to inform the next stage of the local plan. This will build on the Whole Plan Viability Assessment (2023) and will inform the policies at the next stage of the local plan. Any changes to the draft policies, such as setting standards for energy efficiency, arising from consultation responses and/or new evidence on viability in relation to the climate change policies will be consulted on through the Reg 19 consultation. Following this work there may be sufficient, robust evidence to set an energy use limit such as that used in other adopted local plans.
Object
Regulation 18 draft Local Plan
Policy CC6 - Water Efficiency and Sustainable Water Management
Representation ID: 7193
Received: 08/01/2024
Respondent: Allison Homes
AH suggests more flexibility is added to the water management requirements to have regard to site specific technical constraints, viability and local context.
Comment noted. Partly agree. Para 158 of the NPPF states that ‘Plans should take a proactive approach to mitigating and adapting to climate change, taking into account the long-term implications for flood risk,…..water supply….' The Water Management criteria in CC6 are largely justified as they meet these requirements set out in the NPPF with flexibility built into the wording of first bullet point ‘(unless there are technical or unavoidable reasons for not doing so in certain areas)’ and is in the interests of sustainable water management. Agree the second bullet point on drought resistant planting schemes is perhaps too prescriptive and may conflict with policies in the Local Plan that seek to ensure enhancements for biodiversity through landscaping (eg Policies EN3 and EN7). Agree third bullet point is too prescriptive and should be more flexible. Disagree fourth bullet point too prescriptive as even such small measures can reduce demands on water supply, and thereby carbon emissions, in new residential development.
Object
Regulation 18 draft Local Plan
Policy SS3 – Development within Planned Limits of Development
Representation ID: 7194
Received: 08/01/2024
Respondent: Allison Homes
The spatial strategy should be refined. The wording of this policy should be updated to ensure the PLDs / policies map reflects any forthcoming Neighbourhood Plan allocations.
Noted
Object
Regulation 18 draft Local Plan
Policy H4 - Meeting all housing needs
Representation ID: 7195
Received: 08/01/2024
Respondent: Allison Homes
AH recognises the importance of the latest HMA, but believe more flexibility should be added to the wording of this policy to take account of alternative forms of evidence of market demand, site specific considerations (i.e. Design) and viability.
Policy H4 already allows for market 'demand' to be taken account of in criterion (b). However, the section on the HMA points to other up-to-date sources of 'need', which is different from 'demand'. Policy H4 sets an appropriate balance between the two. Viability is taken account of through the Whole Plan Viability Assessment. Policy H3 addresses density and Policy SC3 addresses design.