Regulation 19 Rutland Local Plan

Object

Representation ID: 8316

Received: 02/12/2024

Respondent: Bowbridge Land Ltd

Agent: Pegasus group

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

These representations are submitted by Pegasus Group on behalf of Bowbridge Land Ltd in response to Regulation 19 consultation the Rutland Local Plan, and are in relation to our client’s interests at Main Street, Barleythorpe, Rutland. The site location is included at Appendix 1. Our client has previously submitted representations concerning this site to the Regulation 18 consultation on the Rutland Local Plan in January 2024

Object

Representation ID: 8322

Received: 02/12/2024

Respondent: Bowbridge Land Ltd

Agent: Pegasus group

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

It is noted that the spatial portrait states that:
“[Rutland] is one of the least affordable areas in the region with median house price to median workplace earnings ratio of 9.53 in 2023 compared with 7.59 across the East Midlands”.
For the reasons set out later in this representation, we consider that the spatial strategy for housing does not respond adequately to this acknowledged issue of affordability as it fails to provide sufficient housing land.

Object

Representation ID: 8327

Received: 02/12/2024

Respondent: Bowbridge Land Ltd

Agent: Pegasus group

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

It is noted that Strategic Objective 3 Meeting housing needs is:
“Meeting Rutland’s identified current and future diverse housing needs, including the affordability and adaptability of housing, through the provision of well-designed, energy efficient and low/zero carbon new homes”.
For the reasons set out later in this representation, we consider that the spatial strategy provides insufficient housing land and so this spatial objective will not be achieved

Object

Representation ID: 8333

Received: 02/12/2024

Respondent: Bowbridge Land Ltd

Agent: Pegasus group

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Policy CC1 is ambiguous, and it is not clear how a decision maker should react to development proposals; the Policy is also unreasonable as promoters and landowners will submit planning applications, but not necessarily know how waste management will be dealt with during the construction stage.
The Policy should be deleted.

Object

Representation ID: 8338

Received: 02/12/2024

Respondent: Bowbridge Land Ltd

Agent: Pegasus group

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Policy CC2 is not effective because it is unclear what is meant by “highest possible standards”, it is unclear how a decision maker should react to development proposals. Furthermore, evidence Regulation 19 Viability Note (September 2024) indicates the policy’s intention is to duplicate Building Regulations and so Policy CC2 is unnecessary and unjustified.
Accordingly, the policy should be deleted.

Object

Representation ID: 8343

Received: 02/12/2024

Respondent: Bowbridge Land Ltd

Agent: Pegasus group

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Policy CC3 is not effective because criterion d is unclear and is unclear what is meant by ‘commensurate with the scale and type of development proposed’. Policy CC3 duplicates Building Regulations and but also includes requirements untested in Viability evidence so is unnecessary and it is unjustified.

Object

Representation ID: 8346

Received: 02/12/2024

Respondent: Bowbridge Land Ltd

Agent: Pegasus group

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The Regulation 19 Viability Note (September 2024) confirms that the Council are not mandating Zero Carbon standards, the viability of which should not be deferred to the planning application stage and could delay the delivery of development. Policy CC4 is not justified and should be deleted.

Object

Representation ID: 8351

Received: 02/12/2024

Respondent: Bowbridge Land Ltd

Agent: Pegasus group

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Policy SS1 should be modified:
• to include sufficient housing land in appropriate locations to provide 264 dwellings per annum, sufficient for 15 years from the anticipated adoption of the Local Plan and, additionally, includes 20% buffer.
• set out the main urban areas as a specific tier in the settlement hierarchy and include Barleythorpe within main urban areas alongside Oakham.
• To include wording from Regulation 18 Draft of the Local Plan relating to the release of greenfield site (see proposed modifications below)

Object

Representation ID: 8354

Received: 02/12/2024

Respondent: Bowbridge Land Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Policy SS7 sets out very restrictive circumstances when new-build open market housing will be permitted in the open countryside.

It is considered that Policy SS8 when read alongside Policy SS1 does not provide the necessary policy framework to consider housing proposals where the authority cannot demonstrate a 5-year supply of deliverable housing sites.

Object

Representation ID: 8356

Received: 02/12/2024

Respondent: Bowbridge Land Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The policy should consider factors which affect the most appropriate housing mix including, housing market evidence, economic conditions, viability and site-specific circumstances like character.
The requirement for all new housing sites to make provision for specialist housing across all tenures including extra care and other forms of supported housing is not viable.
It is also not clear whether the implications criteria a-d within this policy have been tested by the viability appraisal supporting the Local Plan.