Regulation 19 Rutland Local Plan

Object

Representation ID: 8453

Received: 02/12/2024

Respondent: House Builders Federation

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy EN2 is unsound, unjustified, ineffective, and not aligned with national policy.

The policy requires development proposals to show a positive contribution to the Local Nature Recovery Strategy (LNRS) and local ecological networks. The Home Builders Federation (HBF) disagrees with this requirement, stating it does not align with LNRS and Biodiversity Net Gain (BNG) policies. LNRS for Rutland is yet to be developed, highlighting the need for ongoing review and public consultation on policy changes to reflect LNRS. HBF finds the environmental policies in the Plan unclear and suggests rearranging the order of issues to prioritize BNG. They emphasize the need for clear guidance on adopting LNRS recommendations and prioritizing BNG solutions for off-site credit compliance. This clarity is vital for developers, communities, and decision-makers to effectively target BNG solutions. The Plan should also specify receptor sites and areas for BNG off-site unit delivery to ensure accurate BNG metric calculation.

Object

Representation ID: 8454

Received: 02/12/2024

Respondent: House Builders Federation

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy EN3 is not considered to be sound as it is not justified, not effective and not consistent with national policy.

The policy mandates a minimum of 10% BNG for qualifying developments, reflecting new legislation effective in 2024. The HBF urges the Council to clarify terms like ‘qualifying developments’ and ensure the policy aligns with national guidance without unnecessary repetition. Guidance specifies that the 10% BNG must be delivered at the end of large, phased developments, not necessarily at each phase. BNG costs should be explicitly included in the viability assessment, as they may impact housing delivery and site density. The policy should be adaptable to the forthcoming LNRS, which is still under development.

Object

Representation ID: 8455

Received: 02/12/2024

Respondent: House Builders Federation

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

89. The HBF believes it should be clearer how this policy relates to the wider BNG and LNRS objectives.

Object

Representation ID: 8456

Received: 02/12/2024

Respondent: House Builders Federation

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The HBF recommends that this policy needs to be clearer about how it links into BNG policies, especially the BNG Metric for watercourses.

Object

Representation ID: 8457

Received: 02/12/2024

Respondent: House Builders Federation

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The HBF argues that the statement regarding viability is misleading, as the assessments indicate challenges for specific areas and site types. The policy mandates that development proposals demonstrate adequate foul water treatment and disposal capabilities, which the HBF contests, stating that this responsibility lies with water service providers, not applicants. The HBF references the Water Industry Act 1991, emphasising that water companies have a legal duty to provide necessary services for new developments. The revised IDP is highlighted as crucial for supporting the Local Plan, necessitating regular updates to ensure its relevance and effectiveness in assessing viability and deliverability.

Object

Representation ID: 8458

Received: 02/12/2024

Respondent: House Builders Federation

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Viability

Viability assessments must support sustainable development and ensure that policy requirements do not hinder the deliverability of the Plan. The 2023 Viability Assessment indicates that while overall values have slightly increased, the introduction of the Future Homes Standard Option 1 will raise build costs, necessitating caution in relying on brownfield sites. The Home Builders Federation (HBF) raises concerns regarding the assumptions in the Viability Assessment, particularly about the costs of mandatory biodiversity net gain (BNG) and the unestablished off-site credit market. Compliance with current and future regulations, such as the new part L and the Building Safety Levy, is projected to significantly increase costs per plot, impacting overall viability. Continuous monitoring of the viability study and policy requirements is essential as the costs of BNG and Future Homes emerge.