Regulation 18 draft Local Plan

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Support

Regulation 18 draft Local Plan

Vision

Representation ID: 7126

Received: 08/01/2024

Respondent: Hereward Homes

Agent: Barmach Ltd

Representation Summary:

Hereward Homes supports the continued, sustainable growth of all villages in Rutland which is essential to meet
housing demand. There is a need for more high-quality housing to provide consumer choice, particularly of
bespoke and custom-built homes in village locations. Such development ensures that there is a balanced housing
offer alongside estate style development in larger settlements.


Our response:

Support noted.

Object

Regulation 18 draft Local Plan

Strategic Objective 2:

Representation ID: 7398

Received: 08/01/2024

Respondent: Hereward Homes

Agent: Barmach Ltd

Representation Summary:

Rutland is a rural area with a network of villages as well as its market towns. Within this context it must be recognised that sustainable transport options can be limited and that the need to ensure the continued growth of villages must be balanced against this. Hereward Homes recommended that paragraph 2 is amended as follows:

‘Supporting an appropriate level of growth which is proportionate in scale and sited in locations that promote
sustainability in local communities, especially those where there are good public transport and active mode
connections, and where people can access: homes which are affordable; jobs; services; health, education, social
and community facilities; open space; and infrastructure. However, to ensure that the Plan’s Vision is achieved
it is also recognised that housing and employment growth in those rural villages less well served by public
transport will be required to ensure their long term sustainability and vibrancy ‘


Our response:

Comments noted. Not deemed required in the Strategic Objective as Chapter 5: Spatial Strategy addresses aspects such as public transport and ensuring the most sustainable location for development.

Object

Regulation 18 draft Local Plan

Policy CC2 - Design Principles for Energy Efficient Buildings

Representation ID: 7399

Received: 08/01/2024

Respondent: Hereward Homes

Agent: Barmach Ltd

Representation Summary:

This Policy in part to duplicates building regulation requirements, particularly criteria 3, 4 and 5. If this is the case Hereward Homes considers that it should it be removed. Would planning development management staff have the technical skills to be able to assess this level of detail or would they involve Building Control at the 2
planning Stage? Have Building Control got the additional resources to do this evaluation at the planning stage? We note criteria 1 and 2 need to be balanced against the need for the design and layout of new development to be informed by an analysis of the site context, particularly in a heritage setting. These matters should be considered through a comprehensive Design Code approach that is subject to extensive stakeholder engagement. Without this there is potentially a significant risk that decision making will be ad-hoc and that the delivery of growth will be significantly delayed. This policy seems to seek to impose an unnecessary and unwarranted burden on new development and applicants for planning permission.


Our response:

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 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 CC3 - Resilient and Flexible Design

Representation ID: 7401

Received: 08/01/2024

Respondent: Hereward Homes

Agent: Barmach Ltd

Representation Summary:

Hereward Homes consider that as with Policy CC2, this policy would appear to go beyond matters that should be considered under the planning system. Criterion 1 is surely a Building Regulations matter. Would planning development management staff have the technical ability to assess matters included under criterion 3 and criterion 4? These matters should be considered through a comprehensive Design Code approach that is subject to extensive stakeholder engagement. Without this there is a significant risk that decision making will be ad-hoc and that the delivery of growth will be significantly delayed. This policy seems to seek to impose an unnecessary and unwarranted burden on new development and applicants for planning permission.


Our response:

Disagree. The PPG advises that when preparing Local Plans, authorities should pay particular attention to mitigation and adaptation. Examples include maximising summer cooling and avoiding solar gain. Requiring applicants to consider how buildings can minimise overheating is therefore justified in seeking to secure high quality design and higher levels of efficiency in new construction. The policy is considered to be justified, effective and consistent with national planning policy. A similar policy approach has been taken with the recently adopted Central Lincs Local Plan (2023).

Object

Regulation 18 draft Local Plan

Policy H1 – Sites proposed for residential development

Representation ID: 7403

Received: 08/01/2024

Respondent: Hereward Homes

Agent: Barmach Ltd

Representation Summary:

The following 2 sites should have been included in Policy H1:

1: Address: Whitwell Road, Land East of Cemetry, Empingham ,OAKHAM ,LE15 8PX
ID: 77

The site was included as an allocation in the abandoned Local Plan and it is unclear why it is not included in this Plan as there are no constraints to development. The previous Site Allocations Assessment in January 2021 concluded that the site was suitable for 5 dwellings.

Whilst Hereward Homes fully supports the proposed reserve site allocation H.1.c to the south of Whitwell Road, development there would extend into the open countryside beyond the existing physical framework of the village. The allocation of land on the north side of Whitwell Road immediately opposite this site allocation would ensure an appropriate rounding off of development alongside that allocation through natural infill.

Hereward Homes support the comments of the Parish Council for this site.

2: Address: Barrowden Rd, Ketton
ID: 15

The site is a disused quarry which also includes an area of hardstanding formerly used as a coal depot and haulage yard immediately adjacent to and immediately opposite existing housing. It can be demonstrated that there are no technical constraints to development of the former coal depot area for up to 10 dwellings and that the long-term future of the adjacent former quarry as an area of enhanced and protected value for wildlife and biodiversity can be secured.


Our response:

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

H1.c Whitwell Road South, Empingham

Representation ID: 7405

Received: 08/01/2024

Respondent: Hereward Homes

Agent: Barmach Ltd

Representation Summary:

Hereward Homes fully supports the allocation of site H.1.c to the south of Whitwell Road for 40 dwellings.
However, it is requested that this site is upgraded to a full rather than a reserve site allocation given that it is within single ownership and can be delivered within the first 5 years of the plan period. Furthermore, it is requested that the allocation is extended to include land to the immediate west as set out in the plan below to provide a site for a GP surgery/medical centre (as a mixed-use allocation). The residential element will enable the land for the GP surgery/medical centre to be secured and this is supported by the Parish Council to provide this much needed community facility.


Our response:

Support noted.

Object

Regulation 18 draft Local Plan

Policy SS2 - Requirements for planning applications

Representation ID: 7406

Received: 08/01/2024

Respondent: Hereward Homes

Agent: Barmach Ltd

Representation Summary:

This Policy is superfluous, replicating other policies in the plan and the national/local validation checklists, and
should be removed.


Our response:

Agree the policy as written does not provide criteria against which a planning application can be assessed and 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

Regulation 18 draft Local Plan

Policy SS3 – Development within Planned Limits of Development

Representation ID: 7407

Received: 08/01/2024

Respondent: Hereward Homes

Agent: Barmach Ltd

Representation Summary:

Hereward Homes consider that this policy should be removed and replaced with criteria-based policies for new
development within and on the edge of settlements. The Policy imposes a greater constraint on development
than in smaller villages and hamlets as set out under Policy SS4 where there are no PLDs. It is unclear why the
Council are treating higher order settlements in a more restrictive way.


Our response:

Noted. Policy SS3 (now SS2) and SS4 (now SS3) to be amended to allow for small scale infill and re-development of appropriate sites on the edge of settlements whether there is a PLD or not. Policy SS4 (now SS3) should be amended to apply to large and small villages and apply a criteria based approach for all small scale proposals on the edge of a settlement.

Object

Regulation 18 draft Local Plan

Policy H9 – First Homes Exception Sites

Representation ID: 7408

Received: 08/01/2024

Respondent: Hereward Homes

Agent: Barmach Ltd

Representation Summary:

Hereward Homes consider that the Policy should be amended to also include provision for First Home Exception
Sites within and adjoining Larger Villages to ensure housing choice, particularly for young people wishing remain
in these sustainable settlements rather than having to relocate to a market town.


Our response:

The Written Ministerial Statement on First Homes of 24 May 2021 states; "As such, the Government has decided that in designated rural areas[4], which includes some of the more constrained and expensive regions of the country such as National Parks and Areas of Outstanding Natural Beauty, rural exception sites will remain as the sole exception site which can come forward." Under Statutory Instrument 2004/418, the whole of Rutland is a 'designated rural area' except for the Parishes of Oakham and Uppingham.

Object

Regulation 18 draft Local Plan

Policy SC3 – Promoting good quality design

Representation ID: 7409

Received: 08/01/2024

Respondent: Hereward Homes

Agent: Barmach Ltd

Representation Summary:

It is recommended that the wording of the Policy be amended as follows:

‘In order to ensure that new development, including the refurbishment of existing buildings to include renewable
energy, is of a high-quality design and locally distinctive, a formal Design and Access Statement should accompany planning applications setting out the design principles to be adopted. The Statement should be proportionate to the scale of development proposed.’


Our response:

Comments noted. Introductory wording to be reviewed.

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