Regulation 18 draft Local Plan

Object

Representation ID: 7142

Received: 08/01/2024

Respondent: Taylor Wimpey Straetgic Land

Agent: Bidwells

Policy SS1 would benefit from a cross reference to policy H1 which sets out which sites are proposed for residential development. Whilst not repeating the list, it would be helpful for the reader to understand where they can find further detail of the sites that will form part of the Spatial Strategy.

The housing requirement generated by the Standard method will need to be kept under review prior to the publication of the next iteration of the Local Plan and progress will need to be made in a timely manner to ensure the Local Plan will have a 15-year life span from adoption.

Comments noted. Agree to include a cross reference to policy H1 and to policy E1 in policy SS1 part a) and b).
Agree housing requirement will need to reflect publication of changes to the requirement using the standard methodology.

Support

Representation ID: 7237

Received: 08/01/2024

Respondent: Taylor Wimpey Straetgic Land

Agent: Bidwells

The approach to the St Georges Barracks site is supported. Any change to make the Barracks sites are more integral part of the Spatial Strategy should be resisted, particularly if it is at the expensive of development in Oakham. This would lead to a Local Plan which has uncertain deliverability and a less sustainable pattern of development.

Support noted.

Object

Representation ID: 7238

Received: 08/01/2024

Respondent: Taylor Wimpey Straetgic Land

Agent: Bidwells

The capacity of site H1.2 is c.180 dwellings. Including the appropriate capacity in policy H1 will add to the flexibility and contingency in land supply.

Site H1.2 is one of the most suitable sites for development in Rutland. Being on the edge of Oakham, the location of the Site is fundamentally sustainable, with good access to services, facilities and public transport, including main line railways services, offered by the main settlement in the area.

The Council’s assessment of land south of Brooke Road is generally supported, albeit there are a couple of points around TPOs, ALC and ecology where changes to the attributed scores should be considered.

All site appraisals have been reviewed in the light of comments and further evidence received to determine their suitability for allocation.

Object

Representation ID: 7239

Received: 08/01/2024

Respondent: Taylor Wimpey Straetgic Land

Agent: Bidwells

Policy H1 would benefit form clarity as to how the total housing requirement will be delivered, linking to Table 4.

The overall distribution of development is generally supported, but any future amendments should not reduce the quantum of development directed to Oakham as this would undermine the sustainability of the Local Plan.

We note that the 650 dwellings at Quarry Farm, on the edge of Stamford, were originally identified in the South Kesteven Local Plan as delivering part of the need of South Kesteven (South Kesteven Local Plan, Paragraph 2.16). We therefore have some concern that there is an element of double counting in the land supply positions that the Council will need to cover off in moving the Local Plan forward to examination.

All site appraisals have been reviewed in the light of comments and further evidence received to determine their suitability for allocation.

Object

Representation ID: 7240

Received: 08/01/2024

Respondent: Taylor Wimpey Straetgic Land

Agent: Bidwells

Draft policy H3 indicates a minimum density of 25 dph on all sites, recognising the need to consider local character and distinctiveness.

Whilst Taylor Wimpey have no fundamental issue with setting a minimum density, we suggest it may be beneficial to link the policy back to the indicative site capacities set out in policy H1 to avoid the perception by some readers that 25 dwellings per hectare would be an appropriate density for all sites.

Comments noted. NPPF recommends the use of minimum density standards in policies and suggests that a range of densities may be appropriate to reflect different local circumstances.
the Core Strategy sets a minimum of 30 for the villages and 40 for the towns. Monitoring suggests that this has not always been achieved and therefore the policy has been written to allow flexibility to reflect local circumstances and existing development patterns whilst ensuring that a minimum density is established.
The indicative capacity of allocated sites is based upon 30 dph as these sites have been assessed as being suitable for development and free from constraints which may reduce the capacity.

Object

Representation ID: 7241

Received: 08/01/2024

Respondent: Taylor Wimpey Straetgic Land

Agent: Bidwells

Within the policy there is currently no recognition that different types of development site, in different locations, will be more appropriate for some types of development than others. We suggest it would be appropriate to note in the policy that the mix of housing proposed on any development site should be appropriate to its context.

The policy also needs to be flexible and adaptable to allow departure from the latest evidence, where appropriate and justified. This will ensure that sites remain deliverable and can adapt to changes in the economy – both locally and nationally.

Policies H3 and SC3 allow flexibility regarding different types of site. It is not necessary to amend Policy H4 in this regard. Policy H4 is evidence-based. The Whole Plan Viability Assessment has been carried out. In addition, Policy H7 makes provision for site-specific viability assessments in exceptional circumstances.

Object

Representation ID: 7242

Received: 08/01/2024

Respondent: Taylor Wimpey Straetgic Land

Agent: Bidwells

We note that there is a need to clarify the position with regard to the application of the M4(3) standard, which 1% of dwellings on sites over 100 units will be expected to meet. There are two elements to M4(3) – M4(3)a and M4(3)b, with the former being readily adaptable rather than fully wheelchair accessible. The policy current doesn’t distinguish between the two standards.

From Taylor Wimpey’s perspective, it would be appropriate to require 1% of dwellings to be readily adaptable to wheelchair accessibility rather than requiring dwellings to be fully complaint as this would add an element of flexibility to ensure dwellings didn’t remain unsold should a suitable buyer not be found for a fully wheelchair accessible home.

The Whole Plan Viability Assessment is modelled on the M4(3)(a) standard. Under national guidance, M4(3)(b) properties can only be required where the Council has tenancy nomination rights.

Support

Representation ID: 7243

Received: 08/01/2024

Respondent: Taylor Wimpey Straetgic Land

Agent: Bidwells

Taylor Wimpey support the reference in policy H6 to large development sites being ‘encouraged’ to deliver self-build plots, rather than requiring them to be provided. Self and custom build housing is supposed to broaden the choice in housing provision across an area. To require selfbuild plots to be provided on large development sites does not allow this diversification and, indeed, has the opposite effect in slowing down delivery on allocated sites.

Taylor Wimpey would therefore resist any change to the policy which ‘required’ self-build plots to
be provided on major sites.

Noted.

Object

Representation ID: 7244

Received: 08/01/2024

Respondent: Taylor Wimpey Straetgic Land

Agent: Bidwells

Taylor Wimpey have a concern with the policies on climate change in the draft plan as they go beyond what national guidance suggests should be included in local policies.

Whilst the updated NPPF is less clear on this point, the Government is consulting on the Future Homes Standard (FHS) and Future Buildings Standard, which will set new requirements for energy efficiency and heating for new homes and non-domestic buildings.

Draft policies CC2 and CC4 set out Rutland County Council’s own local policy requirements in relation to the energy efficiency of new development and net zero carbon. Whilst TW are fully supportive of the Council’s strategic climate objectives, on the basis it is the Government’s intention to publish the FHS in 2024, TW would urge the Council to review their strategy in relation to Draft Policies CC2 and CC4 and consider whether it is necessary to include criteria that may duplicate the requirements of FHS.

LPAs have the power under the Planning and Energy Act 2008 to adopt planning policies that set higher targets for energy performance standards for development in their area than the national baseline providing that they are reasonable, comply with the usual plan-making requirements and do not affect the viability of new development to an unreasonable extent. A number of development plan documents have passed examination which have successfully included energy efficiency and/or other emissions reduction requirements beyond those of the Building Regulations. Such policies allow LPAs to meet the obligation on them to ensure development plan documents include policies designed to secure that development of land in the local authority’s area ‘contribute to the mitigation of, and adaption to, climate change’. The Future Homes and Buildings Standards (which aims to improve the energy efficiency and carbon emissions of new homes and non-residential buildings through the Building Regulations system) should take effect in 2025. With such regulations still being debated and no legal guarantee that they will come into effect in 2025, and recognising that buildings are the UK’s second-highest emitting sector, the Local Plan sets out a positive strategy through the Climate Change policies for carbon reduction and to mitigate against the impact of climate change. The Plan acknowledges that a key consideration for Policy CC2: Design Principles for Energy Efficient Buildings is its impact on the viability of new developments. It is intended that further work to update the cost evidence for a number of options for the wording of CC2 will be undertaken to inform the next stage of the local plan. This will build on the Whole Plan Viability Assessment (2023).