Regulation 19 Rutland Local Plan

Support

Representation ID: 8693

Received: 02/12/2024

Respondent: Defence Infrastructure Organisation (DIO)

Number of people: 2

Agent: Montagu Evans on behalf of Secretary of State for Defence

The DIO are supportive of the overarching vision for the Local Plan and recognise that development is required beyond the market towns to ensure villages and local communities remain vibrant. It also seeks to protect the rural character of the countryside when bringing forward development which can be achieved by building development on the least sensitive sites and by providing a landscape led approach to development. The DIO support the Council’s proposed strategic objectives.
We note that St George’s Barracks remains to be one of, if not the largest, brownfield sites which can deliver high quality residential led development and greater weight should be attributed to its ability to provide early delivery of housing.

Object

Representation ID: 8694

Received: 02/12/2024

Respondent: Defence Infrastructure Organisation (DIO)

Number of people: 2

Agent: Montagu Evans on behalf of Secretary of State for Defence

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The Council have maintained references to matters covered by alternative legislation, such as draft Policy CC2
– Design Principles for Energy Efficient Buildings. The post-text for this policy makes reference to future consultation and changes in these matters, which will result in dated Policies, or potential conflicts with other legislation. Furthermore, the Ministerial Statement made by Lee Rowley on 13 December 2023 made it clear that LPAs could not introduce planning policies that go beyond current or planned Building Regulations.

Object

Representation ID: 8695

Received: 02/12/2024

Respondent: Defence Infrastructure Organisation (DIO)

Number of people: 2

Agent: Montagu Evans on behalf of Secretary of State for Defence

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

we are disappointed to see that our previous comments in respect of draft Policy CC5 – Embodied Carbon, have not been addressed.

Object

Representation ID: 8696

Received: 02/12/2024

Respondent: Defence Infrastructure Organisation (DIO)

Number of people: 2

Agent: Montagu Evans on behalf of Secretary of State for Defence

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Similarly, comments made at Regulation 18 stage in respect of draft Policy CC8 – Renewable Energy, have also not been actioned, and we reiterate our concern regarding the practical implementation of this Policy. Specifically, we note that not all renewable energy technologies would give rise to the issues that the policy is requiring developments to assess, for example solar and battery electrical storage systems (“BESS”) has no impact upon radar. As worded, every part of the policy would require a technical report which would require needless cost and work for developers where such development should be encouraged. Part B of the Emerging Policy should be amended to remove the “and” which would allow matters to be addressed only where the scheme is likely to give rise to such issues. Additionally, at over two pages in length, this policy is also particularly long and, in a development management sense, would be difficult to comply with. It would therefore be useful to have clear sub-sections and/or to create new policies relevant to specific technologies to simplify the plan and ensure it can be appropriately applied moving forward. The approach to identifying “ground mounted solar PV opportunity areas” is unclear and omits important opportunities where this can come forward as part of larger mixed-use sites, such as St Georges Barracks, where commercial or private wire opportunities exist. We also suggest that small-scale turbines may also be appropriate on site and given the areas of search for turbines in the vicinity, both forms of renewable energy could be compatible with the site’s potential ecological designation. As written, we consider this policy to be contrary to paragraph 35 of the Framework because the policy as drafted is neither justified nor effective.

Object

Representation ID: 8697

Received: 02/12/2024

Respondent: Defence Infrastructure Organisation (DIO)

Number of people: 2

Agent: Montagu Evans on behalf of Secretary of State for Defence

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The primary issue we raise in respect of the draft spatial strategy is that it ignores the Government’s well-versed and
acknowledged policy of brownfield first. The draft Rutland plan fails in this regard.

Object

Representation ID: 8698

Received: 02/12/2024

Respondent: Defence Infrastructure Organisation (DIO)

Number of people: 2

Agent: Montagu Evans on behalf of Secretary of State for Defence

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

SS2 which might support planning applications if there is less than 5 years housing land supply, a situation that should be avoided as unsuitable greenfield sites may be brought forward

Object

Representation ID: 8699

Received: 02/12/2024

Respondent: Defence Infrastructure Organisation (DIO)

Number of people: 2

Agent: Montagu Evans on behalf of Secretary of State for Defence

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

the DIO express strong concerns with the decision to delay the delivery of homes on the County’s largest brownfield opportunity by removing the site-specific Policy for St George’s Barracks, and amalgamation with the Woolfox site under an opportunity area policy.

Object

Representation ID: 8700

Received: 02/12/2024

Respondent: Defence Infrastructure Organisation (DIO)

Number of people: 2

Agent: Montagu Evans on behalf of Secretary of State for Defence

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Object to the exclusion of St George’s Barracks, which represents an opportunity larger than any other site contained on the Council’s current brownfield land register. A potential strategic land use plan is provided. Substantial weight should be afforded to brownfield land.

Object

Representation ID: 8701

Received: 02/12/2024

Respondent: Defence Infrastructure Organisation (DIO)

Number of people: 2

Agent: Montagu Evans on behalf of Secretary of State for Defence

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

We support the proposed policy wording in respect of density which sets a minimum of 25 dwellings per hectare but reiterate concern that the Housing Allocations Policy (H1) adopts a standard density of 30 dwellings per hectare for the spatial distribution of homes

Object

Representation ID: 8702

Received: 02/12/2024

Respondent: Defence Infrastructure Organisation (DIO)

Number of people: 2

Agent: Montagu Evans on behalf of Secretary of State for Defence

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Whilst the DIO are supportive of the delivery of accessible
new homes, we do not support the inclusion of the Policy within the Local Plan, as it remains an optional requirement under the current Building Regulations. Where evidence cannot be provided to justify the requirement for all new dwellings to be M4(2) compliant then this policy should be deleted. This approach is not justified and should be removed to ensure that the plan is found sound.