Regulation 18 draft Local Plan

Object

Representation ID: 7355

Received: 08/01/2024

Respondent: The Society of Merchant Venturers

Agent: Savills

Policy SS8 states what residential will be permitted in the countryside. It is clear that this policy however fails to consider the provisions of Policy SS1 which enables ‘greenfield sites adjoining the Planned Limits of Development of Oakham and Barleythorpe, Uppingham and the Larger Villages… [to] be released in exceptional circumstances"

To ensure consistency across the strategic policies of the Plan, it is therefore recommended that further clarity is set out in Policy SS8 to enable residential greenfield sites adjoining Planned Limits of Development to come forward, either where there is a clear local housing need to maintain a sufficient supply of deliverable housing sites or where sites are allocated through a Neighbourhood Plan.

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 SS8 (now SS7) will be applied.
Additionally, Policy SS8 (now SS7) states within its description that non-essential development within the rural countryside is inappropriate and will be restricted, but it further states that there are certain types of development which are essential, subject to the requirements set out in Policy SS8 (now SS7).

Object

Representation ID: 7356

Received: 08/01/2024

Respondent: The Society of Merchant Venturers

Agent: Savills

Housing Numbers
It is clear that at the anticipated time of adoption the emerging Local Plan will be working within
a 15-year Plan period horizon. Based on the LHN figure (123 dwellings per annum), the Council will be required to deliver a minimum of 2,460 dwellings during the plan period. It is noted that draft Policy H1 provides for a total supply of 1,375 dwellings to be delivered through allocations across the Plan period, in addition to a total of 1,358 existing commitments and completions). As such, there is an anticipated shortfall against the LHN, which is indeed a ‘minimum’ housing figure.

Whilst Policy H1 allows for a buffer and includes some additional reserve sites, it is considered fully allocating more sites that are sustainably located, in single ownership and align with the spatial strategy in focussing growth towards Oakham (such as ‘Land at Uppingham Road’) to ensure greater certainty that the ‘minimum’ LHN can be met and ideally to support the Council in committing to a housing requirement that goes beyond this figure for the reasons set out above.

In addition, the Council should consider whether there is scope to increase residential development densities on sites that are sustainably located and well related to the main town of Oakham (such as ‘Land south of Stamford Road’ and ‘Land at Uppingham Road’), in order to meet local housing needs.

The policy text notes that the site capacity are ‘potential figures’ and based on achieving ‘30 dwellings per hectare’. It will be important for this policy to not be overly prescriptive and instead, enable development densities to be tested through detailed design and the planning application process, to ensure sufficient flexibility in meeting local housing needs.

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

Object

Representation ID: 7357

Received: 08/01/2024

Respondent: The Society of Merchant Venturers

Agent: Savills

The site area has been reduced from 2.7ha to 2.19ha in the north-eastern corner to account for a cordon sanitaire from the Oakham Sewage Treatment Works.

Correspondence received from Anglian Water dated 8 October 2020 confirms that the 350m cordon sanitaire was implemented based on the Environment Agency's H4 guidance issued in 2012. This guidance has however now been superseded by the Institute of Air Quality Management which adjusted the buffers for smaller Sewage Treatment Works. The correspondence with Anglian Water confirms that a 250m cordon sanitaire would suffice for the Oakham Sewage Treatment Works and therefore an updated buffer based on the latest guidance would no longer impact the developable area for ‘Land south of Stamford Road’.

It is requested that Policy H1 and Planned Limits of Development on the Interactive Policy Map is amended to reflect the original site area of 2.7ha and the policy text is adjusted to include the delivery a minimum of 80 dwellings at the site.

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

Object

Representation ID: 7358

Received: 08/01/2024

Respondent: The Society of Merchant Venturers

Agent: Savills

Policy H2 relates to Stamford North, which is a site allocated in the adopted South Kesteven Local Plan
(SVLP - Jan 2020) and includes provision for 1,300 dwellings. It is however unclear how development at
this site is accounted for within the housing figures for Rutland and this must be clearly explained through
appropriate evidence.

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

Support

Representation ID: 7359

Received: 08/01/2024

Respondent: The Society of Merchant Venturers

Agent: Savills

Policy H3 broadly aligns with the NPPF in the requirement to achieve appropriate densities by making ‘efficient use of land’. The policy confirms that ‘Residential densities will vary dependent upon the local area context and character and the sustainability of the location, but generally should be no less than 25 dph (dwellings per hectare).

Indeed, it will be important that residential development densities are established through detailed design
and the planning application process, rather than be prescribed through policy, in order to enable densities
to be considered on a site-by-site basis. The fact that this policy sets out a minimum density figure and does not include a maximum density figure is broadly supported and aligns with the provisions of the NPPF.

Support noted.

Support

Representation ID: 7360

Received: 08/01/2024

Respondent: The Society of Merchant Venturers

Agent: Savills

Policy H4 proposes that ‘Development proposals for sites of 10 or more dwellings should provide a range
of house types, sizes, and tenures. The supporting text for this policy references the HMA and sets out
a suggested housing mix for the County at Table 5 this seems to be appropriately evidenced. It will be important however that the housing mix required across the County is subject to ongoing monitoring to ensure it reflects up to date information.

The suggested housing mix focuses on a range on tenures and the suggested mix is not skewed
towards the smaller or larger house types. It will however be important that this policy is not overly prescriptive in setting mix requirements and instead the policy should act as a guide for any residential planning application. Indeed, this policy should take account of the provisions of Policy SS1 to enable sufficient flexibility in house types and to help facilitate housing delivery beyond the LHN requirements

It is however welcomed that the supporting text for this policy references the role of Neighbourhood Plans
in producing up-to-date evidence to identify local housing need. It should also be supported at the application stage, if Developers choose to produce their own evidence to identify and meet a clear shortfall in house types.

Comment regarding H4 noted. It is not considered necessary to add a link to Policy SS1.

Support

Representation ID: 7361

Received: 08/01/2024

Respondent: The Society of Merchant Venturers

Agent: Savills

The overall requirement for all new dwellings to be adaptable and accessible and to reflect the overall needs
of the community aligns with Building Regulations and the provisions of the NPPF (2023) and is supported.

To ensure the soundness of the Plan, it will be important to ensure that the specific requirement set for
dwellings to meet M4(3) standards is based on an up to date evidence of local housing needs.

Noted. The need for M4(3) dwellings is demonstrated in chapter 6 of the Housing Market Assessment 2023.

Object

Representation ID: 7362

Received: 08/01/2024

Respondent: The Society of Merchant Venturers

Agent: Savills

Whilst there may be uncertainty regarding the current and future number of applicants for custom and self build housing (as people can register on multiple housing registers and therefore the number on the register
is not an accurate representation of custom and self build housing need), it is recommended that further
clarification is provided as to the criteria for where serviced plots should be available for self and custom
build homes.

It is recommended that provision is sought in line with the Council’s latest evidence of local needs, which will need to be subject to ongoing monitoring. This will help to ensure that local needs are accurately addressed over the course of the plan period and that the location and type of self and custom build plots provided is appropriate.

Policy H6 strikes an appropriate balance between requiring Self- and Custom Housebuilding (see Policy H2(b)(iii)) and facilitating it. The supporting text to Policy H6 states: "It is important that the policy approach is flexible and accounts for challenges associated with self-build and custom housebuilding... The Council could allocate sites specifically for Self and Custom Build homes. This is not considered appropriate or necessary at this time." Policy H6 refers to 'larger sites' and the supporting text to 'very large sites'. Self- and custom-build consents and the register are monitored.

Object

Representation ID: 7363

Received: 08/01/2024

Respondent: The Society of Merchant Venturers

Agent: Savills

The overall approach to requiring provision of affordable housing on major housing developments aligns
with the provisions of the NPPF (2023) and will support wider housing needs. Given that affordable housing
needs are likely to change over the course of the Plan period and across the borough, it will be important
that affordable housing is provided to meet local needs at the time of development coming forward and taking into account site-specific circumstances.

It is crucial that the Local Plan supports additional overall housing supply, including affordable housing supply, in order to support local needs and contribute to addressing the local affordability issues.

Proposals of a 30% affordable housing threshold for
developments of 10 or more dwellings would equate to the delivery of only 37 affordable housing units
per annum across the Plan period based on the LHN

Indeed, to deliver the required level of affordable housing provision per annum across the Plan period (78
dwellings), as set out in the Housing Market Assessment , there would need to be the delivery of 260 residential units per annum.

It is clear that even a slight upward adjustment in the affordable housing requirements of Policy H7 would
not meet the shortfall and therefore there is a clear need for more market housing to be delivered across
the Plan period in order to help meet this estimated need and facilitate additional affordable housing
provision (as the majority of affordable housing is delivered as part of the delivery of housing sites led by
market housing).

Affordable housing is not only provided through planning gain, but also through wholly affordable sites such as the 40 dwellings under construction at Brooke Road, Oakham on the former allotment site. Consideration of overall housing numbers is a matter for the spatial strategy. The affordable housing provision is the greatest practicable in the context of the Whole Plan Viability Assessment.

Object

Representation ID: 7364

Received: 08/01/2024

Respondent: The Society of Merchant Venturers

Agent: Savills

This approach is broadly consistent with the requirements for Chapters 15 and 16 of the NPPF as it seeks to protect and enhance valued landscapes and heritage assets.

Policy SC1 also appears to broadly be appropriately evidenced based on the methodology in Rutland’s
Landscape Character Assessment, however, whilst we concur with the overall findings of the Landscape Character Assessment, we note that this is a broad brush
assessment and is not site specific.

Given the high level nature of this assessment, it is not able to identify and adequately address the characteristics and features of the smaller parcels of land around Oakham, some of which are anticipated to accommodate the housing provision allowed for within the plan period (such as ‘Land south of Stamford Road’ (ref. H1.3)). In this regard, we are of the view that the policy should defer, or make reference to the finer grained ‘Rutland Settlement Landscape Sensitivity Study’ (RSLSS) (July 2023).

It is also noted that both the Landscape Character Assessment and the RSLSS were prepared prior to the development at Oakham Pastures. This notably changes the baseline position for the SMV sites, and therefore it is important that these policies and evidence base documents are updated to accurately reflect the landscape position of the sites (specifically in regard to the findings in the RSLSS for ‘Land at Uppingham Road’).

In regard to ‘Land south of Stamford Road’ the RSLSS recorded at “Medium/Low” Sensitivity to housing development.

Overall, we broadly concur with the findings and comments, although query the reference to the role of the site as an ‘important gateway’ and the parcel’s susceptibility to development’. Whilst it is agreed the site occupies a gateway location, we are of the view that the RSLSS should have noted that the site’s visual role and its interrelationship with the wider landscape is very much focused on a small area stretching from the A6003 Burley Park Way and Stamford Road roundabout west along the site’s boundary with Stamford Road. Indeed, this is an unusually focused and limited area of interinfluence. This is a result of the site’s physical and visual containment provided by its urban context with housing along its western and northern edges and additional containment provided by significant planting and trees along its remaining southern and eastern boundaries.

In regard to ‘Land at Uppingham Road’, the RSLSS recorded as being “High” Sensitivity to housing development.

It is clear that the RSLSS was prepared when the Spinney Hill housing development formed the southern edge of the town. This is no longer the case as the Oakham Pastures development has extended the town further south and now forms the arrival edge into the town of Oakham. It is therefore considered that in relation to ‘Land at Uppingham Road’, the landscape policies and evidence base documents are outdated and should be revised to reflect the new landscape character of the southern area of the town.

Comments noted, however the policy criteria do not depend on or derive from the Landscape Character Assessment and therefore it is not considered appropriate to also reference the Landscape Sensitivity Study nor is it considered necessary to update this evidence each time a development takes place.