Regulation 19 Rutland Local Plan
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Regulation 19 Rutland Local Plan
Whole Plan
Representation ID: 8540
Received: 02/12/2024
Respondent: De Merke Estates
Agent: Stantec
Legally compliant? Not specified
Sound? No
Duty to co-operate? No
The present publication/consultation of this Local Plan has been rushed – it is therefore premature and fails to adequately properly provide for the objectives and achievement of long-term sustainable development. We therefore seriously question how the present Local Plan Strategy helps to deliver its vision and objectives, or the Council’s main Corporate Strategy and its 4 No main priorities of:
• tackling the climate emergency
• creating a diverse and sustainable local economy
• supporting the most vulnerable
• providing good public services
Object
Regulation 19 Rutland Local Plan
Chapter 2 – Spatial Portrait
Representation ID: 8541
Received: 02/12/2024
Respondent: De Merke Estates
Agent: Stantec
Legally compliant? Not specified
Sound? No
Duty to co-operate? No
In the light of the presently submitted (and available) information, we question whether RCC has
adequately addressed its statutory obligations in respect of “duty to cooperate”. This goes to the heart
of the “soundness” of the Local Plan – and is our first major objection.
Object
Regulation 19 Rutland Local Plan
Chapter 3 – Vision and Objectives
Representation ID: 8542
Received: 02/12/2024
Respondent: De Merke Estates
Agent: Stantec
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
de Merke Estates whole heartedly supports
the stated Local Plan Vision and Strategic Objectives. However, we do not consider that the present spatial strategy, the accompanying “evidence base” and the draft Local Plan itself – is necessarily best placed to deliver on its own vision and objectives. Having regard to the “tests of soundness”. We object that the stated Vision and Objectives will not be deliverable over the plan
period.
Object
Regulation 19 Rutland Local Plan
Chapter 4 – Climate Change
Representation ID: 8543
Received: 02/12/2024
Respondent: De Merke Estates
Agent: Stantec
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
de Merke Estates supports the aims and objectives of tackling the present climate emergency, and helping to reduce carbon emissions and minimise the impact of climate change on the lives of RCC residents and local businesses.To this end, and to best achieve such aims and objectives, it is clear that the most sustainable location for the majority of planned future growth in the County should be at Oakham. The Council’s own Sustainability Assessment (Settlement Assessment, Jan 2024) concluded that Oakham (with Barleythorpe) scored the highest in the evaluation the relative sustainability merits of each settlement against each SEA theme. In the light of the present Local Plan strategy, we consider it will “not be effective” in achieving the stated Climate Change aims and objectives
Object
Regulation 19 Rutland Local Plan
Chapter 5 – Spatial Strategy
Representation ID: 8544
Received: 02/12/2024
Respondent: De Merke Estates
Agent: Stantec
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
We consider the Spatial Strategy is unsound on a variety of levels – and therefore strongly object to
many aspects of this Chapter of the draft Local Plan.
It is widely anticipated that this anomaly will be amended in the imminent NPPF, with reference to a proportional percentage figure, as opposed to a single (crude) numerical approach.
Object
Regulation 19 Rutland Local Plan
Policy SS1 - Spatial strategy for new development
Representation ID: 8545
Received: 02/12/2024
Respondent: De Merke Estates
Agent: Stantec
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
The Council has acknowledged that it is rushing this present Local Plan in order to “avoid having to meet higher housing targets”. This singularly fails to have any regard to seeking to meet its own “housing needs” – especially those on its own housing register.
It is already failing to accord with the spatial planning objectives and meeting the acknowledged housing needs (inc affordable housing) of its residents with regard to the extant NPPF.
Object
Regulation 19 Rutland Local Plan
Policy SS4 – Future Opportunity Areas
Representation ID: 8546
Received: 02/12/2024
Respondent: De Merke Estates
Agent: Stantec
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
We strongly object to this Policy and the identification of these 2No areas presently: St George’s Barracks and “land at Woolfox”. We do not necessarily object to the future development of either or indeed both of these areas in the long term, but the correct place for such sites to be considered would be in the context of the next Local Plan Review.
Object
Regulation 19 Rutland Local Plan
Policy H1 – Sites proposed for residential development
Representation ID: 8547
Received: 02/12/2024
Respondent: De Merke Estates
Agent: Stantec
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
This plan is "to avoid having to meet higher housing targets", rather than seeking to meet its own housing needs. The need identified in the plan is 110% lower than the new standard method need.
The strategy and sites/allocations will not meet the real aims and objectives of this Local Plan, and the recognised needs of its local residents and local economy, as only a third of the new housing is in Oakham and most of that is unplanned.
Policy H1 (and its accompanying table) also highlights a significant mismatch between the lack of
provision to meet identified housing needs, particularly for affordable housing, as many of the smaller sites the plan relies on do not have an affordable housing requirement, and the plan target for affordable housing (40dpa) is below the identified need (78dpa).
The housing trajectory should delete all references to future opportunity areas, because they are being advanced without consideration of reasonable alternatives.
Object
Regulation 19 Rutland Local Plan
Chapter 7 – Economy
Representation ID: 8548
Received: 02/12/2024
Respondent: De Merke Estates
Agent: Stantec
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
Supports the provision of new employment allocations at Oakham, which will help to strengthen the important role and function of the County Town. Such allocations are welcomed but they should be alongside properly planned housing allocations in order that the social and economic benefits can be realised in pursuit of sustainable development.
Object
Regulation 19 Rutland Local Plan
Policy SC1 – Landscape character
Representation ID: 8549
Received: 02/12/2024
Respondent: De Merke Estates
Agent: Stantec
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
The draft landscape policies (Policies SC1, SC2 and SC3) are all predicated and reliant upon the findings of the “Rutland Landscape Character Assessment 2022” and the “Settlement Landscape Sensitivity Assessment 2023”. We do not concur with the findings of these landscape studies, and consider they have been overly cautious in their assessment/conclusions in certain circumstances – this is particularly the case in respect of the County Town of Oakham. The draft landscape policies (Policies SC1, SC2 and SC3) are all predicated and reliant upon the findings
of the “Rutland Landscape Character Assessment 2022” and the “Settlement Landscape Sensitivity
Assessment 2023”.
We do not concur with the findings of these landscape studies, and consider they have been overly cautious in their assessment/conclusions in certain circumstances – this is particularly the case in respect
of the County Town of Oakham. We therefore object to Policies SC1, SC2 and SC3 as presently drafted.