Regulation 18 draft Local Plan

Object

Representation ID: 5489

Received: 05/01/2024

Respondent: Francis Jackson Homes Ltd

We question why the vision sets out a target/objective of only meeting the County's "minimum" housing need. This is, to our eyes, neither a vision nor inspiring to those of all ages, sectors and demographics who may wish or need to live in Rutland. As a vision statement, saying "we are going to the minimum needed" may be appealing for political reasons, but does not seek to actively grasp or engage with the wider housing need issue of the young, or others not already settled in Rutland. Surely as a "vision" the Council can do better?

Comments noted. The vision reflects government guidance on housing provision using the government’s method of calculating minimum housing need and the plan ensures that it delivers a sufficient supply of homes.

Support

Representation ID: 5491

Received: 05/01/2024

Respondent: Francis Jackson Homes Ltd

We support the element of the vision that confirms development will come forward in the Larger Villages and smaller settlements.

support noted

Support

Representation ID: 5493

Received: 05/01/2024

Respondent: Francis Jackson Homes Ltd

We support growth in sustainable village locations - allowing villages the grow and thrive, and provide housing for all - not just a specific demographic - but the full range that provides housing opportunities for all who wish to live and work in Rutland, including the young and those with families. This should include market housing, as well as affordable housing of various tenures. Villages must be allowed the thrive and grow over time too, not just become fossilised.

Support noted.
The Strategic Objective will support an appropriate level of growth.

Support

Representation ID: 5494

Received: 05/01/2024

Respondent: Francis Jackson Homes Ltd

This strategic objective is better worded than the similar wording in the 'vision' section. The 'vision' seeks only to provide "a range of high-quality housing that meet the County's minimum housing need" - which is not much of a vision. Housing need and the national housing crisis is very real and whilst obviously development must be sustainable and proportionate to existing settlements, the Council should lead the way on this vision and go beyond providing the bare minimum to avoid exacerbating the housing problem. Planning always for the bare minimum is not the answer and solves nothing.

Support noted.
The Strategic Objections explain what is trying to be achieved through the strategy and policies included in the Local Plan to deliver the vision.

Object

Representation ID: 5497

Received: 05/01/2024

Respondent: Francis Jackson Homes Ltd

We have selected Object as whilst we in fact support the thrust and majority of bullet points listed, the provision of high quality, sustainable housing - which we have a track record of delivering in Rutland and elsewhere locally, is rarely "low cost". That element is problematic to deliver when the other, numerous and admirable objectives are factored in - innovative design, low carbon, climate resilient, locally distinctive, safe, green, nature-based are supported, but have viability implications for general housing delivery if the other objective is low cost.

Support and comments noted. The Local Plan acknowledges that a key consideration for many of its policies is the impact they have on the viability of new developments. 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 arising from consultation responses and/or new evidence will be consulted on through the Reg 19 consultation.

Object

Representation ID: 5498

Received: 05/01/2024

Respondent: Francis Jackson Homes Ltd

We have serious concerns over the phrase "Highest possible energy efficiency standards" - as this will have massive impacts on development viability and land coming forward if this is carried forward as drafted. How will this be measured? Will Affordable Housing schemes have to provide the same standard as market housing?

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). 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.

Object

Representation ID: 5500

Received: 05/01/2024

Respondent: Francis Jackson Homes Ltd

This policy, as read in isolation, fails to square with all the other policies about locally distinctive, high-quality design, character, etc. Not all houses can face the "right" way to benefit from solar gain, as they would be lined up like panels in a solar farm. These key objectives, which are supported in principle, need to be balanced with those about making successful places, respecting the character of streets, villages, Conservation Areas, etc. Layouts need to be able to be more nuanced than just providing a development to maximise solar gain! Also, is any heat supply genuinely net zero?

Disagree. Policy CC2, as with other local plan policies, should not be read in isolation and the principles in the policy would only form part of the content of the DAS/Energy Statement. Consideration of other design principles, such as set out in NPPF and PPG, the National Design Guide (2021) and Design Guidelines for Rutland (2021), would form part of the rationale behind the design of a new development. It is possible to achieve a net zero carbon heating supply from renewables, either on-site or from an energy supplier.

Object

Representation ID: 5503

Received: 05/01/2024

Respondent: Francis Jackson Homes Ltd

Draft Policy CC3 and CC2 do not relate well together and should be re-drafted, perhaps as one more coherent policy. Policy CC2 seeks to maximise solar gain - Policy CC3 seeks to minimise overheating. Again, orientation alone cannot be the answer, and there needs to be flexibility here to ensure development produces decent places and houses that people want to live in. Is wind exposure a material planning consideration - where has this criterion come from and what evidence is there to support it?

Comments noted. Disagree. Subject to change to Policy CC2 part a) to read: orientation of buildings such as to manage opportunities for solar gain and to minimize winter cold wind heat loss’, the two policies are seeking to achieve design solutions that manage solar gain whilst preventing overheating – a balance between the two is required. There are significant benefits in solar gain in terms of heating and solar panel efficiency particularly in the winter months but these must be balanced against the harmful risks of overheating. The PPG on climate change 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 National Design Guide (2021) has useful advice: ‘Well-designed buildings make the most of passive design strategies to minimise overheating and achieve internal comfort. These include: the layout and aspect of internal spaces; insulation of the external envelope and thermal mass; management of solar gain; and good ventilation to reduce overheating.’ With the increase in extreme weather events, such as storms with higher wind speeds, as a consequence of climate change, then inclusion of mitigation of risks related to wind exposure is justified.

Object

Representation ID: 5505

Received: 05/01/2024

Respondent: Francis Jackson Homes Ltd

This policy as drafted places a huge burden on applicants for housing. Does this mean every planning application from a single plot to 1,000 houses (say) will have to provide a viability report to set out the level of renewable energy generation is the "maximum" viably possible on site? How else would the Council assess this. Criterion 2. is especially challenging as this level of post-development testing is not a function of national policy, where such matters are generally caught anyway by Building Regs and EPC's. What is the evidence to support the need for this?

Comments noted. Disagree. The NPPF states that, in order to increase the use and supply of renewable and low carbon energy, plans should provide a positive strategy for energy from these sources. As a local plan has a limited influence on retrofitting existing buildings, in order to reach targets for carbon reductions, significant reductions in the energy requirements of new buildings are urgently needed and Policy CC4 seeks this aim. The Plan acknowledges that a key consideration for Policy CC4 is its impact on the viability of new developments. 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 having looked at the feasibility and cost implications of such policies. Any changes to the draft policies, such as setting standards for renewable energy generation or rewording from ‘maximum generation’, 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 energy demand targets for renewables such as that used in other adopted local plans.

Object

Representation ID: 5511

Received: 05/01/2024

Respondent: Francis Jackson Homes Ltd

Reference to "outside hard surfacing" is too vague. Public Highway cannot, from experience, be adopted if it is not impermeable. Does this cover driveways - these can be permeable if the drainage and ground conditions allow, but what about patio areas? Also, drought tolerant plants might not be best for bio-diversity or suitable. Planting in private gardens is not controlled by planning (and can be readily changed by residents) so this wording is not justified or enforceable.

Agree ‘outside hard surfacing’ requires further definition to exclude public highway.
Partly disagree on second bullet point as planting in private gardens, such as hedging or tree planting. is sometimes part of a landscaping scheme that would be controlled through condition for implementation and maintenance. Agree drought resistant plants may not be best for biodiversity. so reword to: ‘with outside soft landscaping, should consider the incorporation of native drought resistant plants in private gardens, communal areas, and any proposed public green spaces whilst recognising the importance of enhancing biodiversity in accordance with Policies EN3 and EN7;’