Regulation 18 draft Local Plan

Object

Representation ID: 7000

Received: 08/01/2024

Respondent: Vistry Group c/o Pegasus Group

Agent: Pegasus group

It is important that the policies included in the final draft Local Plan do not duplicate or overlap with matters that are more appropriately dealt with by the national building regulations. Building standards should not be dealt with through local plan policies.
The Plan proposes a large number of new climate change policies and from a practical perspective it would be helpful if these climate change policies could be combined into a smaller number of more focused policies to reduce the complexity of the emerging policy framework for officers and applicants. It is suggested that at most three policies are needed on the requirements for new development, changes to existing buildings and renewable energy.
Once all the matters covered by building regulations, the National Planning Policy Framework and the General Permitted Development Order are removed, many of the individual policies could be distilled into one or two bullet points within an over arching climate change policy. This is the approach taken by many authorities in local plans to avoid conflict between policies and unnecessary duplication.

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).

In recognising the need for urgent action to address climate change, the Local Plan seeks to achieve this by a range of policies that reduce carbon dioxide emissions and encourage renewable energy generation. They consider all areas where greenhouse gas emissions can be reduced, including wider resource efficiency and its link to carbon emissions. Climate change mitigation is addressed including sustainable travel, net zero buildings, design, energy and water efficiency, renewable energy, supporting the circular economy and green infrastructure (for example through the protection of carbon sinks and carbon sequestration).

Object

Representation ID: 7696

Received: 08/01/2024

Respondent: Vistry Group c/o Pegasus Group

Agent: Pegasus group

We strongly object to this policy as drafted. This policy needs to be reconsidered, it is too onerous and will impact on almost all major developments. There is no mention of the need to consider the scale of loss as there is in the Carbon Sequestration draft policy.
As currently drafted the loss of a single hedge, tree or shrub and all developments on agricultural land will be caught by this policy. In this context, the presumption in favour of preservation of carbon sinks in-situ is in direct conflict with the presumption in favour of sustainable development.

Comments noted. Disagree. Policy wording similar to that in the adopted Central Lincs Local Plan (2023). The policy includes the requirement for a ‘proportionate’ evaluation and ‘appropriate’ management plan of the loss so it does incorporate flexibility in terms of scale of loss. The policy recognises that the natural environment plays a vital role in tackling the climate crisis as healthy ecosystems take up and store a significant amount of carbon in soils, sediments and vegetation. Alongside many other negative impacts, the destruction and degradation of natural habitats has resulted in the direct loss of carbon stored within them. National guidance (para 157 NPPF) stresses the importance of the planning system helping to shape places in ways that contribute to radical reductions in greenhouse gas emissions.
It is likely that further work to update the cost evidence for a number of options for the wording of the Climate Change policies will be undertaken to inform the next stage of the local plan. This will build on the Whole Plan Viability Assessment (2023). Any changes to the draft policies arising from consultation responses and/or new evidence on climate change will be consulted on through the Reg 19 consultation.

Object

Representation ID: 7697

Received: 08/01/2024

Respondent: Vistry Group c/o Pegasus Group

Agent: Pegasus group

It will be important to review the local housing need figure in March 2024 when the affordability ratios are updated again, to ensure the local plan reflects the most up to date position. The potential for further changes should be factored into the final preparations of the plan before submission.
An updated Strategic Housing Market Assessment (SHMA) was published in August 2023, and this acknowledges the need to test the standard method and consider whether there are exceptional circumstances which justify a higher housing requirement figure in the Local Plan.
The assessment is very clear that the housing requirement for the County should exceed the standard methodology if it is reasonable and possible to do so, in order to meet the local housing needs which, the assessment finds is underestimated by the standard methodology.
There is no evidence, however, that this has been taken into account or considered in preparing the Preferred Options consultation document. This is a fundamental flaw in the process which needs to be addressed before the plan is finalised for submission. The updated SHMA is not mentioned as supporting evidence to either SS1 or H1

The calculation of housing need and the strategic housing requirement for inclusion in the spatial strategy is considered in detail under policy H1

Object

Representation ID: 7698

Received: 08/01/2024

Respondent: Vistry Group c/o Pegasus Group

Agent: Pegasus group

The proposed housing distribution to Stamford north, Oakham and Uppingham and larger villages combined with the proposed housing requirement and buffer (both of which are challenged elsewhere in this representation), means it is proposed to distribute a total of 514 homes in the plan period to the Larger Villages including Ketton. This is a modest scale of development given there are 21 villages identified as sustainable Larger Villages capable of supporting growth, it is the equivalent of 25 homes each.
4.6. It is noted that, taking account of commitments and completions, the minimum indicative target housing supply to deliver the housing requirement for Larger Villages is 153 homes over the 20 year plan period. This is the equivalent of 7 homes if this figure was split equally between the Larger Villages.
The Council should be planning to exceed the standard method local housing need figure, it is important the capacity of the Larger Villages to support growth is not underestimated.
There are nine proposed allocations in the Larger Villages, and eight of these sites are between 6 and 20 dwellings, three are less than 10 dwellings i.e. not defined as major sites and not meeting the threshold for on-site affordable housing, mix or open space policy. This is a missed opportunity to plan and direct development in a way that delivers more for communities i.e. new open spaces, new affordable homes and a good mix of homes.

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

Support

Representation ID: 7699

Received: 08/01/2024

Respondent: Vistry Group c/o Pegasus Group

Agent: Pegasus group

The draft policy sets out the settlement hierarchy and identifies Ketton as a defined Larger Villages were development of allocated sites and windfall sites within the Planned Limits of Development will be permitted. The identification of Ketton as a defined Larger Village is supported. The village of Ketton has a range of services and facilities which makes it a sustainable location for growth.
The proposed policy helpfully sets out the circumstances in which a proposal for housing development on greenfield sites adjoining the Planned Limits of Development of the Larger Villages will be considered, namely when they are needed to maintain a sufficient supply of deliverable and developable land. This clarity is welcomed and supported.

Support noted

Object

Representation ID: 7700

Received: 08/01/2024

Respondent: Vistry Group c/o Pegasus Group

Agent: Pegasus group

Policy SS8 sets out very restrictive circumstances when new-build open market housing will be permitted in the open countryside and this is not consistent with the wording of Policy SS1.

It is important that the policy wording of SS8 is reconsidered to allow for the important flexibility set out in Policy SS1 or that Policy SS8 is cross referenced with Policy SS1 to explain the circumstances when SS8 would not apply.

Objection noted.
Policy SS1 establishes the level of housing needed for the plan period and sets out where this development should be.
SS1 (a) states that the majority of development will be focused mainly within PLDs and allocated sites.
SS1 further states that sites outside the PLDs will only be released in expectational circumstances where the need to maintain a sufficient supply of deliverable and developable land is demonstrated.
Policy SS1 clearly explains when Policy SS7/8 will be applied.

Object

Representation ID: 7701

Received: 08/01/2024

Respondent: Vistry Group c/o Pegasus Group

Agent: Pegasus group

Policy H1 includes sufficient sites to provide a contingency buffer of 10% to aid delivery of the minimum housing requirement.
The Local Plans Expert Group report, 2016, set out recommendations for a 20% allowance of developable reserve sites to provide extra flexibility to respond to change. Harborough District Council, includes a 15% contingency in their Local Plan, over and above their minimum housing requirement which the Local Plan Inspector specifically commented was to provide resilience.
It is suggested that a 20% buffer is used in the case of Rutland given the relatively low housing requirement and the potential for unforeseen circumstances to mean sites are not brought forward and the significant impact this could quickly have on the Council’s ability to deliver sufficient housing.

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

Object

Representation ID: 7702

Received: 08/01/2024

Respondent: Vistry Group c/o Pegasus Group

Agent: Pegasus group

Policy H1 spreads development over a larger number of smaller sites and this is not supported. This approach, removes the benefits of a local plan for the Larger Villages, as it fails to create a critical mass that would support communities in the way intended and instead supports incremental growth of communities which brings minimal benefits.
A total of 150 homes proposed on brownfield sites, many within the planned limits to development of the Larger Villages. The deliverability of all the sites proposed needs to be demonstrated, but this is particularly important for brownfield sites. The principle of development is already acceptable on those brownfield sites within the planned limits to development, so it is questionable whether allocating these sites will overcome the reason they haven’t already been brought forward.
As proposed, Policy H1 has an overreliance on brownfield sites within the Larger Villages, without sufficient evidence presented on the deliverability of these sites or the impact the number of brownfield sites will have the delivery of affordable housing, open spaces and developer contributions through CIL payments, which are reduced on brownfield sites.
It is also noted that the only substantial sized allocation made at St George's Barracks Officers Mess in Edith Weston overestimates the scale of development that is achievable.

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

Object

Representation ID: 7703

Received: 08/01/2024

Respondent: Vistry Group c/o Pegasus Group

Agent: Pegasus group

reserve sites
The potential for deliverability issues appears to be acknowledged by the unusual inclusion of eight greenfield reserve sites, all but one of which are located in the Larger Villages.
There are however also questions about the deliverability of the reserve sites which need to be considered further, in particular where planning permission has recently been refused on such sites

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

Object

Representation ID: 7704

Received: 08/01/2024

Respondent: Vistry Group c/o Pegasus Group

Agent: Pegasus group

Additional site at Land North of Luffenham Road, Ketton shuld be allocated. The site is approx. 7 ha and is currently in use for agricultural purposes and is capable of delivering 130 dwellings (including 39 affordable homes). (Appendix 1 site plan) in a sustainable village, the site is well located in relation to a number of local facilities in the surrounding area which would be available for use by future residents of the site. The site is 10 minutes walk from Ketton C of E Primary School. It is also within walking distance of the village Post Office and General Store, sport facilities, Public House, Community Hall and Library. The village also benefits from a regular bus service, the number 12, which runs between Stamford and Uppingham.
The Site Allocation Assessment Appendix C concludes that the scale of the proposed development is not suitable for allocation.
It is unclear how a site, identified as having capacity for 126 homes in the assessment, can be of a scale that excludes it from further consideration when the proposed housing requirement, even just within the Larger Villages is greater than this amount.

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