Regulation 18 draft Local Plan

Object

Representation ID: 7341

Received: 08/01/2024

Respondent: The Society of Merchant Venturers

Agent: Savills

Whilst the title of this policy relates to the circular economy, the wording of the policy focuses on waste
management and construction waste. The supporting text briefly addresses the principles of the circular
economy, however, these are not addressed within the policy itself. If this policy is seeking to address the
circular economy design principles, the policy should relate more to the design of the buildings and how to
ensure they are reused and adapted with appropriate evidence to support the policy wording and providing
certainty as to how the policy should be implemented.

Object

Representation ID: 7342

Received: 08/01/2024

Respondent: The Society of Merchant Venturers

Agent: Savills

The policy must ensure it is aligned with the Written Ministerial Statement entitled, ‘Planning – Local
Energy Efficiency Standards Update’. This sets out that, ‘The Government does not expect plan-makers
to set local energy efficiency standards for buildings that go beyond current or planned buildings
regulations…. Any planning policies that propose local energy efficiency standards for buildings that go
beyond current or planned buildings regulation should be rejected at examination if they do not have a well reasoned and robustly costed rationale that ensures:
• That development remains viable, and the impact on housing supply and affordability is considered in accordance with the National Planning Policy Framework.
• The additional requirement is expressed as a percentage uplift of a dwelling’s Target Emissions
Rate (TER) calculated using a specified version of the Standard Assessment Procedure (SAP).

This relates in particular to criteria e) around heat supply and connect to the gas network.

Point f) should clearly ensure that energy consumption is reduced initially and only any remaining energy
requirements are from renewable energy sources. Energy generation on ‘or near’ the site should also be prioritised to ensure there is flexibility to accommodate site specific circumstances.

It is also considered that these measures could be better addressed through a dedicated Energy/Sustainability Statement, rather than the Design & Access Statement, with clear examples and supporting text clearly explaining the requirements to ensure there is certainty over the implementation requirements associated with this policy

Support

Representation ID: 7343

Received: 08/01/2024

Respondent: The Society of Merchant Venturers

Agent: Savills

The broad principles of this policy are all supported and align with the NPPF. However, any duplication with other policies should be avoided. For example, there appears some crossover with the requirements in policy CC14 and CC1 within policy CC3, particularly points b) and d), which could be incorporated within policy CC1. This should be addressed to ensure the policies are compliant with the NPPF.

Object

Representation ID: 7344

Received: 08/01/2024

Respondent: The Society of Merchant Venturers

Agent: Savills

Whilst the principle of on-site generation is broadly accepted, the policy must incorporate flexibility to
address site specific circumstances where there are opportunities for renewable generation adjacent/ very
close to a site. The Council must ensure there are full resources to enable site specific circumstances around energy provision to be properly assessed to pragmatically enable the most appropriate option to be considered and progressed.

The policy also sets out what ‘proposals supported by an Energy Statement should cover: Whilst the overall aspirations of the policy are understood and broadly accepted, the detail within the policy is not clear. There is currently no industry accepted definition of ‘net zero carbon’. This should therefore be explicitly set out within the policy or elsewhere within the emerging Local Plan, with details on methodology and expectations also clearly set out to ensure there is certainty around implementation.
Additionally, further clarification is needed on what is meant by ‘independently verified calculations’.

Furthermore the policy must ensure it is aligned with the Written Ministerial Statement made on 13
December 2023 entitled, ‘Planning – Local Energy Efficiency Standards Update’.

Object

Representation ID: 7345

Received: 08/01/2024

Respondent: The Society of Merchant Venturers

Agent: Savills

This policy is not clear how ‘favouring’ a building would be assessed or what this might mean in practice. Additionally, the policy does not acknowledge that repairing, refurbishing, re-using and re-purposing a building will not always result in less carbon use. It would be helpful if the policy could explain a methodology to assess the total embodied carbon consumption to consider whether this approach would actually use less carbon.

Support

Representation ID: 7346

Received: 08/01/2024

Respondent: The Society of Merchant Venturers

Agent: Savills

The approach to reducing water consumption is broadly supported and the policy appears to align with
Building Regulations.

Support

Representation ID: 7347

Received: 08/01/2024

Respondent: The Society of Merchant Venturers

Agent: Savills

This wording reflects Paragraph 173 of the NPPF (December 2023).

For both ‘Land south of Stamford Road’ (ref. H1.3) and ‘Land at Uppingham Road’, it is noted that a watercourse runs on the redline boundary between these two sites (i.e. on the southern boundary of ‘Land south of Stamford Road’ (ref. H1.3) and on the northern boundary of ‘Land at Uppingham Road’) and is situated within Flood Zones 2 and 3. The sites are however not located within a Flood Alert Area and the majority of the sites sit within Flood Zone 1 (which has a low probability of flood risk).

It is therefore considered that both sites can be sensitively designed for housing development, with appropriate sustainable drainage systems and green infrastructure located to adjacent the existing watercourse, to optimise development on the rest of the site.

Object

Representation ID: 7348

Received: 08/01/2024

Respondent: The Society of Merchant Venturers

Agent: Savills

The proposed housing requirement is based on the standard method of LHN. The draft Local Plan is clear that this is a ‘minimum figure’ and it should be considered ‘if it is reasonable and possible to exceed the Standard Method’. Indeed the NPPF is clear the standard method should determine the ‘minimum’ number of homes needed.

The Housing Market Assessment established ‘household growth of around 124-167 per annum’, therefore concludes that ‘the Standard Method housing need should be considered by the Council as very much a minimum figure with a range of different projections typically pointing to a higher figure’.

Figure 3 of the HMA highlights that there is a net estimated need for 78 affordable housing units per annum across the Plan period.

Policy H7 of the draft Local Plan proposes a 30% affordable housing threshold for developments of 10 or more dwellings. This would equate to the delivery of only 37 affordable housing units per annum across the Plan period based on the LHN. To deliver the required level of affordable housing provision per annum across the Plan period there would need to be the delivery of 260 residential units per annum.

Location of growth

As per our representation response to Q13 of the Issues and Options consultation, this approach to growth is broadly supported as it seeks to assign the majority
of growth to the market towns of Oakham and Uppingham.

Ensuring an adequate supply of housing sites in and around Oakham and Uppingham, including medium
sites (particularly in single ownership such as ‘Land south of Stamford Road’ (ref. H1.3) and ‘Land at
Uppingham Road’ that can be delivered quickly), will be important to meet and respond to local housing
needs.

Object

Representation ID: 7352

Received: 08/01/2024

Respondent: The Society of Merchant Venturers

Agent: Savills

Given the need for housing above the LHN, a flexible approach should be taken to the Planned Limits of Development in order to ensure that sufficient
housing can be accommodated during the Plan period.

The requirements for Policy SS1 set out above, enable ‘greenfield sites adjoining the Planned Limits of Development of Oakham and Barleythorpe, Uppingham and the Larger Villages… [to] be released in exceptional circumstances where it is demonstrated that they are needed to maintain a sufficient supply of deliverable and developable land’, it is considered that in these instances larger scale adjustments to the Planned Limits of Development may be required to achieve the necessary level of housing growth.

Indeed, it is reasonable to ensure that growth should firstly be focussed around the most sustainable settlements, such as Oakham, to ensure that any greenfield development would meet the other objectives of the Plan. However, it is recommended that the supporting text for Policy SS3 is therefore amended to ensure consistency across the strategic policies of the Plan and any Neighbourhood Plan.

Object

Representation ID: 7353

Received: 08/01/2024

Respondent: The Society of Merchant Venturers

Agent: Savills

It is clear that the existing evidence doesn’t support an allocation on this site coming forward, with the supporting text for this policy confirming ‘Development proposals for the re-development of the site remains uncertain at the point of preparing the Local Plan, therefore no specific proposal is included for the site’.

Indeed, the Council notes that ‘Allocating a development of the scale and nature proposed for Woolfox
would compromise the delivery of the proposed spatial strategy set out in this plan and potentially the plans
of neighbouring areas’. In terms of housing numbers therefore, the site should not be considered to
contribute towards the Local Plan housing requirements.