Regulation 19 Rutland Local Plan

Object

Representation ID: 8221

Received: 29/11/2024

Respondent: McCarthy Stone (MS) and Churchill Living (CL)

Agent: The Planning Bureau Limited

Legally compliant? No

Sound? No

Duty to co-operate? Yes

The current policy lacks specificity to effectively deliver necessary housing for older people in line with the NPPF. The ageing population in Rutland is projected to increase significantly, necessitating more specialised housing. There are significant economic, social, and environmental advantages of providing housing for older people.

We urge the Council to revise its approach to better meet the identified needs for older persons’ housing. Longer-term projections of need should be used and sites allocated specifically for older people's housing.

Object

Representation ID: 8222

Received: 29/11/2024

Respondent: McCarthy Stone (MS) and Churchill Living (CL)

Agent: The Planning Bureau Limited

Legally compliant? No

Sound? No

Duty to co-operate? Yes

The current assessment does not accurately model the unique characteristics and costs associated with older persons housing, leading to misleading conclusions about its viability. Important variables such as typical scheme size, longer sales periods, higher empty property costs, and increased marketing and professional fees have not been adequately considered. The council's interpretation of the National Planning Policy Guidance (NPPG) is criticised for suggesting that the viability of older persons housing should only be assessed at the development management stage, contrary to the guidance's intent.

Object

Representation ID: 8225

Received: 29/11/2024

Respondent: McCarthy Stone (MS) and Churchill Living (CL)

Agent: The Planning Bureau Limited

Legally compliant? No

Sound? No

Duty to co-operate? Yes

Policy EN2 seeks to direct biodiversity creation and in effect sets a new locational biodiversity hierarchy at points 1 to 5. However, the council should note that paragraph: 006 Reference ID: 74-006-20240214 of the PPG on Biodiversity states that ‘It will also be inappropriate for plans or supplementary planning documents to include policies or guidance which are incompatible with this framework, for instance by applying biodiversity net gain to exempt categories of development or encouraging the use of a different biodiversity metric or biodiversity gain hierarchy’. Therefore policy EN2 is currently contrary to planning policy guidance and points 1 to 5 should be deleted.

Object

Representation ID: 8226

Received: 29/11/2024

Respondent: McCarthy Stone (MS) and Churchill Living (CL)

Agent: The Planning Bureau Limited

Legally compliant? No

Sound? No

Duty to co-operate? Yes

We are concerned that large elements of the proposed policy either repeat national policy or are incompatible with the framework / guidance and therefore the council should reconsider the whole policy.

Object

Representation ID: 8228

Received: 29/11/2024

Respondent: McCarthy Stone (MS) and Churchill Living (CL)

Agent: The Planning Bureau Limited

Legally compliant? No

Sound? No

Duty to co-operate? Yes

In our previous submission we noted that the Rutland County Council Whole Plan Viability Assessment, August 2023 did not appear to include a cost for the embodied carbon policy. We expressed our concern as embodied carbon will have a cost that should be accounted for in any Viability assessment. We are disappointed to see that this policy has again not been tested in the Regulation 19 Viability Note (September 2024).

New development will often be far more sustainable in many circumstances including building fabric by use of modern methods of construction but also extending beyond that, such as sustainability through optimisation of use of a site and more able to meet the council’s zero carbon aspirations. The Council also need to verify that embodied carbon figures are available to developers from suppliers through an Environmental Product Declaration as in our experience this is not yet readily available from the majority of suppliers.

Object

Representation ID: 8229

Received: 29/11/2024

Respondent: McCarthy Stone (MS) and Churchill Living (CL)

Agent: The Planning Bureau Limited

Legally compliant? No

Sound? No

Duty to co-operate? Yes

In our previous submission we noted that the Rutland County Council Whole Plan Viability Assessment, August 2023 did not include a cost for the carbon sequestration policy. Reference to carbon sequestration is also missing from the latest Viability Note (September 2024).

We repeat our concern that embodied carbon will have a cost that should be accounted for in any Viability assessment.