Regulation 19 Rutland Local Plan

Object

Representation ID: 8285

Received: 02/12/2024

Respondent: Define (on behalf of William Davis Homes)

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The general scope of Policy CC2, which expects new developments to meet “the highest possible energy efficiency standards” is appropriate.

However, to ensure that the policy is “clearly written and unambiguous” as required by paragraph 16d of the National Planning Policy Framework (NPPF), it should clarify that developments are expected to meet the highest standards, subject to feasibility and viability; so decision-makers will clearly understand the factors that define what is “the highest possible” standard.

Object

Representation ID: 8287

Received: 02/12/2024

Respondent: Define (on behalf of William Davis Homes)

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The requirement of Policy CC4 for new developments to “provide the maximum generation of renewable electricity as practically and viably possible on-site (and preferably on-plot)” is appropriate in that it is sufficiently flexible in taking account of the feasibility and viability of renewable energy solutions.

However, the policy name is “net zero carbon (operational)” which is not actually a requirement of Policy CC4. It is suggested, therefore, that the policy name changes to ensure that the policy as a whole is “clearly written and unambiguous” as required by NPPF paragraph 16d, and that the policy is applied consistently.

Object

Representation ID: 8290

Received: 02/12/2024

Respondent: Define (on behalf of William Davis Homes)

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Modifications are required to ensure that the spatial strategy is effective and sustainable; most notably by identifying additional allocation sites in settlements such as Cottesmore. Given the Government’s position regarding the level of modifications that should be made to Local Plans during their examination (with a preference to plans being withdrawn and local authorities re-considering their approach), RCC should take a step backwards to re-consider the RLP’s housing requirements, and identify additional sites.

In that regard, WDH’s response to Policy H1 highlights the merits of their site at ‘Land North of Mill Lane, Cottesmore’ as a proposed allocation site.

Object

Representation ID: 8292

Received: 02/12/2024

Respondent: Define (on behalf of William Davis Homes)

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Policy SS2 seeks to limit growth in Rutland’s settlements only to the proposed allocation sites and specific forms of development within the Planned Limits to Development (PLDs); which are very tightly drawn. That approach is clearly unduly inflexible in light of the clear issues of unsoundness, and WDH’s responses to Policies SS1 and H1 highlight how the spatial strategy should be revisited to identify additional housing allocation sites. In that regard, Policy SS2 and the identified PLDs must be amended accordingly to reflect any changes to the plan.

Object

Representation ID: 8293

Received: 02/12/2024

Respondent: Define (on behalf of William Davis Homes)

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Whilst WDH recognises that an MoU has been agreed between RCC and SKDC, the proposed SUE will clearly operate functionally/geographically as an extension to Stamford.

Therefore, Stamford SUE should continue to be treated in the same way as in the withdrawn plan, as an allocation to meet the needs of neighbouring SKDC. Whilst WDH recognises that the RLP must make reference to the delivery of the SUE given that the site is within RCC’s jurisdiction, it should not be considered as an allocation to meet RCC’s needs, and should be removed from the housing supply in the RLP.

Object

Representation ID: 8294

Received: 02/12/2024

Respondent: Define (on behalf of William Davis Homes)

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

WDH are concerned that the policy could be mis-construed as suggesting that the starting point for residential densities should be 25 dwellings per hectare (dph). To ensurethe policy is “clearly written and unambiguous”, it should be modified as follows:

“New residential development is required to make the most efficient use of land whilst responding to local character, context, and distinctiveness. 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), and ordinarily should be between 30 and 35 dph.”

Object

Representation ID: 8295

Received: 02/12/2024

Respondent: Define (on behalf of William Davis Homes)

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The scope of Policy H4 is generally sound in requiring housing mixes to respond to evidence of need, but the policy should also make reference to how they should also respond to “evidence of demand, site and settlement-specific factors / constraints, feasibility, and site viability.”

Object

Representation ID: 8296

Received: 02/12/2024

Respondent: Define (on behalf of William Davis Homes)

Legally compliant? No

Sound? Yes

Duty to co-operate? No

WDH objects to the implementation of a blanket requirement seeking the provision of Self- and Custom-Build (SCB) units within market housing schemes on the basis that (i) the need / demand for SCB is disputed, often relating to a demand in a specific location, rather than in market housing developments, and (ii) delivering SCB housing within market housing schemes can be practically challenging.

Therefore, the requirement for market housing developments to deliver SCB housing is unjustified and unsound. It should, therefore, be removed from Policy H6.

Object

Representation ID: 8297

Received: 02/12/2024

Respondent: Define (on behalf of William Davis Homes)

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The policy refers to the use of calculators such as CAVAT for offsetting tree loss. Their use is not a national requirement, and therefore is not consistent with national policy, and there is no evidence to justify such an alternative approach.

Furthermore, such calculators attribute significant costs to trees that have not been taken into account in the viability assessment (as they will vary on a site-by-site basis). In that regard, the policy requirement is not deliverable.

Reference to the use of tree loss calculators should, therefore, be removed.

Object

Representation ID: 8298

Received: 02/12/2024

Respondent: Define (on behalf of William Davis Homes)

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The NPPF does not provide a blanket protection of Best and Most Versatile Agricultural Land, instead stating that “the economic and other benefits” of such land should be “recognised” in plan-making and decision-taking. The proposed policy tests are inconsistent with national policy and should be deleted.