Main Modifications Consultation

Object

Representation ID: 9165

Received: 07/09/2026

Respondent: Defence Infrastructure Organisation (DIO)

DIO object to this modification as it is not effective in line with the soundness test of NPPF paragraph 35. The
text now notes that the Council is “expected” to begin work on a new plan under the new plan making system.
However, the text does not note the stricter requirements of the new local plan making system transitional
arrangements which specifically note Rutland as an authority which was required to publish notice of intention
to commence plan making by 30th June 20261. The inclusion of the word “expected” conflicts with The Town
and Country Planning (Local Planning) (England) Regulations 2026 transitional provisions schedule which is
clear that there is a requirement for RCC to begin plan-making, not merely an expectation.

Object

Representation ID: 9166

Received: 07/09/2026

Respondent: Defence Infrastructure Organisation (DIO)

DIO object to this policy as written as it is not effective in line with the soundness test of NPPF paragraph 35.
It is considered that the clarification that the highest possible thermal efficiency is in the context of the Future
Homes Standard is not clear enough and results in a policy requirement which is not defined in the policy. The
modification makes reference to the Future Homes Standard however this can change and the requirement is
not specific enough to be deemed effective.
In order for the policy to be considered effective, a footnote should be inserted after “Standard” to clarify that
the policy refers to the Future Homes Standard 2026. This will ensure clarity in the future, should the standard
be updated.

Object

Representation ID: 9167

Received: 07/09/2026

Respondent: Defence Infrastructure Organisation (DIO)

DIO object to this modification as it is not justified in line with the soundness test of NPPF paragraph 35. The
modification proposes to add a requirement for development proposals to submit design stage estimates of carbon dioxide emissions, going beyond the previous requirement in Policy CC4 for the submission of estimates
and calculations of energy performance. The reason stated for this modification is to “clarify the intended scope
of the policy”.
It is considered that this reason attempts to understate the effect of this modification. This is not simply a
clarification but introduces an entirely new requirement for carbon dioxide emission calculations and modelling
at such an early stage in the planning process (for example where an application is submitted by a
landowner/promoter). The introduction of an additional requirement must be supported by proportionate
evidence demonstrating why it is necessary that these calculations be provided. However, no further evidence
base documents have been submitted by RCC which would justify this requirement.
It is considered that in the absence of any further evidence base documents, in order for the Local Plan to be considered sound, this modification should be deleted.

Support

Representation ID: 9168

Received: 07/09/2026

Respondent: Defence Infrastructure Organisation (DIO)

DIO support this modification as it provides the necessary clarification to ensure that Policy CC4 is effective in
line with the soundness test of NPPF paragraph 35. The explanation that the level of detail expected will be
proportionate to the size of the scheme and that Energy Statements will not be required at outline application
stage are both welcomed and necessary to make the policy effective.

Object

Representation ID: 9169

Received: 07/09/2026

Respondent: Defence Infrastructure Organisation (DIO)

DIO object to the proposed modification to remove part (d) on the basis that it seeks to remove reference in the
policy to the delivery of development on one of the largest brownfield sites available in the county (see footnote).

The suitability of St George’s Barracks for development is confirmed in the examination document RCC51:
Housing and Employment Site Assessment Report. Appendix B sets out the site assessment conclusion
reviewing all technical assessments and concluding that the development of the site would be acceptable
subject to appropriate mitigation measures. It goes on to say that the site has been “found suitable for
allocation”.

The spatial strategy should therefore reflect the ability for this large brownfield site on the edge of the Planned
Limits of Development to come forward within the plan period.

footnote: St George’s Barracks is included on the Rutland Brownfield Land Register – see: https://www.rutland.gov.uk/planningbuilding-
control/planning/brownfield-land-register

Support

Representation ID: 9170

Received: 07/09/2026

Respondent: Defence Infrastructure Organisation (DIO)

DIO support the inclusion of the wording “2) the redevelopment of previously developed land which is
physically well related to the existing built form.” in policy SS2. This is important recognition of the ability
for brownfield sites, which are sustainably located within walking distance of key shops and services of existing
settlements, are recognised for their ability to contribute to the housing supply

Support

Representation ID: 9171

Received: 07/09/2026

Respondent: Defence Infrastructure Organisation (DIO)

DIO support the inclusion of wording which acknowledge the ability for St George’s Barracks to come forward
for development and therefore contribute to Rutland’s housing land supply.
The principle of the acceptability of development on the Site is established by the amended policy SS2 –
Development Within Planned Limits of Development. There is therefore no reason why the site cannot come
forward for development, pending consideration of detailed technical considerations through the development
management process.

Object

Representation ID: 9172

Received: 07/09/2026

Respondent: Defence Infrastructure Organisation (DIO)

DIO disagree with the inclusion of the following text in policy SS6 – Re-use of redundant Military Bases and
Prisons. The modification states:
“Where such sites are large-scale or operational at the time of plan adoption, and proposals would
result in significant redevelopment or a change of use, this is likely to require consideration through a
Local Plan review, depending on the nature and scale of the proposal.”
DIO objects to this wording on the basis of it not being necessary to ensure that the plan can be made sound,
as required by paragraph 35 of the NPPF.

Object

Representation ID: 9173

Received: 07/09/2026

Respondent: Defence Infrastructure Organisation (DIO)

MM29 proposes the inclusion of Table 5: “Sources of Housing Supply for the Plan Period 2021 – 2041”. This
includes 325 dwellings of windfall allowance over the plan period. We note that the windfall allowance proposed
broadly aligns with historic delivery. Rather than relying on windfall, there is an opportunity for RCC to rely on
development of a brownfield site, which has been assessed as “suitable for allocation” (see footnote)

St George’s Barracks is included on the Brownfield Land Register4, and has been assessed by RCC through
the examination document “The suitability of St George’s Barracks for development is confirmed in the
examination document RCC51: Housing and Employment Site Assessment Report. Appendix B sets out the
site assessment conclusion reviewing all technical assessments and concluding that the development of the
site would be acceptable subject to appropriate mitigation measures. It goes on to say that the site has been
“found suitable for allocation”.

This should be considered when planning for windfall, that a suitable site already exists to be allocated to meet
this need.

footnote: See examination document RCC51: Housing and Employment Site Assessment Report

Object

Representation ID: 9174

Received: 07/09/2026

Respondent: Defence Infrastructure Organisation (DIO)

DIO object to this modification on the basis that it seeks to render the purchasing of statutory credits impossible
which is not in accordance with the Biodiversity Gain Regulations 2024. The burden for it to be demonstrated
that offsite gain could not be achieved “Elsewhere in England” is in effect impossible for a developer to prove.
This is therefore in conflict with The Biodiversity Gain Regulations 2024 37A(a) (iv) which explicitly allows the
purchase of biodiversity credits.

It is considered that in order for the policy to be made compliant with the Regulations, that the purchase of
statutory credits be added as part 5 of the proposed hierarchy, making it clear that this is within the hierarchy rather than introducing an impossible burden for developers to prove, effectively removing this from the
hierarchy.