Regulation 19 Rutland Local Plan

Support

Representation ID: 8433

Received: 02/12/2024

Respondent: House Builders Federation

Recent consultations on the NPPF and housing need will impact the Rutland Local Plan. The Written Ministerial Statement (WMS) from Angela Raynor stresses the necessity for local authorities to have development plans, particularly for those nearing the examination stage. The HBF encourages the Rutland Council to prepare a sound Local Plan that is ready for adoption. Inclusion of clause and paragraph numbers in policies is recommended for better referencing by stakeholders. The proposed plan period of 2021 to 2041 should ensure compliance with NPPF guidelines, necessitating adoption by 2026 for a full 15-year coverage.

Support

Representation ID: 8434

Received: 02/12/2024

Respondent: House Builders Federation

The HBF considers that as per the vision it is important that the Plan supports the delivery of a range of high-quality housing that meets that County’s minimum housing need and which meets the needs of all sections of the community.

Object

Representation ID: 8435

Received: 02/12/2024

Respondent: House Builders Federation

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The HBF emphasises that local standards should not diverge from national government approaches to low carbon and energy solutions. Current regulations (Part L 2013 and Part L 2021) provide benchmarks for carbon reduction, with significant improvements expected in Part L 2025. The HBF advocates for amendments to Policy CC2 to reflect national standards better.

Object

Representation ID: 8436

Received: 02/12/2024

Respondent: House Builders Federation

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy CC4 is not considered to be sound as it is not justified, not effective and not consistent with national policy for the following reasons:

The policy outlines the maximum generation of renewable electricity on-site for development proposals, with proposals supported by an energy statement requiring updated calculations of energy performance. However, the HBF is concerned that this focus may not be the most sustainable option for all developments. The Council should apply this policy flexibly to achieve the most appropriate outcomes, rather than following requirements. The HBF also questions the unnecessary duplication of energy statement calculations with building regulations.

Object

Representation ID: 8437

Received: 02/12/2024

Respondent: House Builders Federation

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

There is ambiguity regarding how developers can demonstrate compliance with the policy, particularly concerning embodied carbon assessments. Questions arise about the Council's capability to evaluate carbon assessments and whether qualified personnel have been identified for this task. The HBF highlights a lack of accurate data on embodied carbon across building materials, questioning the robustness of any assessments made under this policy. The policy may disproportionately affect small to medium-sized enterprise (SME) developers and could hinder the overall deliverability of housing developments.

Object

Representation ID: 8438

Received: 02/12/2024

Respondent: House Builders Federation

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The HBF questions the necessity and evidence supporting the inclusion of green roofs and rainwater harvesting systems, suggesting these may not always be the most sustainable options. The potential costs associated with implementing green roofs have not been adequately assessed, raising concerns about the policy's viability. The HBF argues that there is no need for a specific policy on water efficiency that exceeds national standards, warning against a fragmented approach to local regulations.

Object

Representation ID: 8439

Received: 02/12/2024

Respondent: House Builders Federation

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The definition of infill development is limited and therefore HBF suggest a more flexible approach. In addition, HBF emphasises allocations over windfalls to support SME developers. HBF advocates for the inclusion of rural site allocations and calls for effective monitoring and action plans.

Object

Representation ID: 8440

Received: 02/12/2024

Respondent: House Builders Federation

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

This policy states that provision is made in the Local Plan for the delivery of at least 123dpa with an additional 10% allowance for flexibility. The Plan therefore makes provision for 2705 new dwellings.

33. The HBF does not comment on individual sites or allocations. The HBF generally supports the need for a contingency buffer to provide for a range of market choice. However, the standard method LHN should be the minimum starting point for establishing the housing requirement and the Council should then considers if there are issues that result in the need for a higher housing requirement, including the need to provide a range and choice of sites, the need for flexibility, viability considerations and whether higher levels of open-market housing are required in order to secure increased delivery of affordable housing. The HBF suggests that Council should consider if these factors, individually and/or cumulatively result in the need for a higher housing requirement for Rutland, and a subsequent need for additional allocations.

34. The HBF would also encourage the Council to ensure the Local Plan fully considers the new Biodiversity Net Gain (BNG) requirements in relation to site allocations. This is likely to require undertaking an assessment of the baseline to support the allocation to enable an understanding the BNG requirements for a site to be allocated and the impact this may have on viability and other policy requirements and considerations. It will be important to understand the BNG costs of mandatory BNG as this is non-negotiable and as such may impact on the viability of the site and its ability to deliver against other policy requirements such as affordable housing or other s106 asks. BNG will also impacts on the density of housing schemes that can be provided, as land used for on-site BNG is not available for housing. This may require larger and/or additional housing sites to be allocated.

35. It is important that housing delivery is effectively monitored so that if housing monitoring shows delays to housing delivery across Rutland action is taken to address this as soon as possible. The HBF believes that the Plan should provide for a wide range of deliverable and developable sites, including a buffer and small site allocations across Rutland in order to provide competition and choice to ensure that housing needs are met in full. As mentioned above we would also recommend the Council consider whether an extension to the plan period is needed.

Support

Representation ID: 8441

Received: 02/12/2024

Respondent: House Builders Federation

HBF have no comments on this policy other than to note that cross-boundary strategic sites can be complex to deliver, which further underlines the need for flexibility in the plan through additional allocations, and robust monitoring to ensure effective housing delivery is achieved over the Plan period.

Object

Representation ID: 8442

Received: 02/12/2024

Respondent: House Builders Federation

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy H3 is not considered to be sound as it is not justified and not consistent with national policy for the following reasons:

This policy states that new residential development is required to make the most efficient use of land whilst responding to local character, context and distinctiveness. It suggests that generally density should be no less than 25 dwellings per hectare (dph).

38. The HBF generally supports the need to optimise the use of land to meet local housing needs, and the flexibility recognised within this policy to give consideration to site specific circumstances. However, the HBF notes that the NPPF looks for policies to include minimum density standards for town centres, and other locations that are well served by public transport and suggests that this will be robustly tested at examination. The HBF would therefore expect the Council to have evidence that the 25dph is appropriate in these areas as well.