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Pre-Submission Local Plan

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Pre-Submission Local Plan Please return to Rutland County Council no later than 4.15pm on Friday 6th November PRE-SUBMISSION LOCAL PLAN REGULATION 19 REPRESENTATION RESPONSE FORM Guidance Note These notes are intended to assist you in making representations to Rutland County Council’s Pre-Submission Local Plan. At this stage of consultation, the Council is seeking views on whether the Local Plan is legally compliant and meets the tests of ‘soundness’, as set out in the National Planning Policy Framework (NPPF), and summarised in the boxes below. Legal Compliance Soundness • The Local Plan should have been prepared • Positively prepared - provides a strategy in accordance with the Council’s latest which, as a minimum, seeks to meet the Local Development Scheme. area’s objectively assessed needs; and is informed by agreements with other • The Local Plan should be accompanied by a Sustainability Appraisal and Habitat authorities, so that unmet need from Regulations Assessment. neighbouring areas is accommodated where it is practical to do so and is consistent with • Consultation on the Local Plan should have achieving sustainable development. been carried out in accordance with the Council’s Statement of Community • Justified - an appropriate strategy, taking Involvement. into account the reasonable alternatives, and based on proportionate evidence. • The Council should have worked • Effective - deliverable over the plan period, collaboratively with neighbouring authorities and based on effective joint working on and prescribed bodies on strategic and cross-boundary strategic matters that have cross boundary matters, known as the Duty to Cooperate. been dealt with rather than deferred, as evidenced by the statement of common • The Local Plan should comply with all ground. relevant laws including the Planning and Compulsory Purchase Act 2004 and the • Consistent with national policy - enabling Town and Country Planning (Local the delivery of sustainable development in accordance with the policies including the Planning) (England) Regulations 2012. National Planning Policy Framework. General Advice This booklet has four parts: • • Part A – Contact Details • Part B – Your Representation • Part C – Future Notifications and Privacy Notice • Part D – Other Monitoring Information • You must provide your contact details within Part A of this booklet. We are unable to accept anonymous representations. The name of respondents and the representations made will be made available on the Councils website. Personal information such as telephone numbers, addresses, and email addresses will not be published. By submitting a representation you confirm your agreement to the publication of your name and consultation response. • Please do not include any personal information within Part B of this booklet. All comments submitted as part of this consultation will be made publically available in reports and online. 3a. Do you consider the Pre-Submission Local Plan to be sound? Yes ☐ No x 3b. If you consider the Pre-Submission Local Plan to not be sound, please select which test(s) of soundness this relates to? (See Guidance on Page 1) ☐ Positively prepared x Justified (inaccuracies in evidence base) ☐ Effective ☐ Consistent with national policy 3c. Please provide an explanation below. Greenlight has two sites in the village of Whissendine at Land off Melton Road (Site Reference: WHI11) and Land off Pickwell Lane (Site Reference: WHI12). The Greenlight land interest was originally proposed to be allocated in the emerging Rutland Local Plan Review Consultation Draft Plan (July 2017) for 60 dwellings under Policy RLP12 (Site Reference WHI/06). However, previous comments from Historic England stated that the wider site would be harmful to the historic agricultural setting of the Grade II* ‘Whissendine Windmill’, as the original site proposed (WHI/06) would infill the remaining section of open fields to the south west of the Windmill. Following detailed discussions between Greenlight, Historic England and the Council’s Conservation Officer during 2018, the WHI/06 site has been split into two to address the heritage setting concerns regarding the th development of all of the WHI/06 site. This is confirmed in Historic England’s letter of 4 July 2018 (included at Appendix A of the accompanying Vision Document – November 2020). However, the Council’s Pre-Submission Local Plan does not follow this agreed approach to splitting the site in two, as it only proposes to allocate the Melton Road site for 12 dwellings under Policy H1.17. The larger, Pickwell Lane site is not proposed for allocation. In terms of Policy H1.17 and the allocation of the Melton Road site, it is Greenlight’s position that, from a landscape and heritage perspective this parcel of land can be acceptably increased from the identified allocation site area of 0.48 hectares to 0.79 hectares; a modest increase of 0.31 hectares. Based on a net developable area of 0.61 hectares and a density of 35 dwellings per hectare, this increased site area could accommodate a housing allocation of 21 dwellings. Greenlight advocates that Policy H1.17 and the allocation of the Melton Road site should be amended to reflect this increased site area and indicative housing capacity. Having reviewed the Pre-Submission Local Plan, Greenlight believes that the emerging Local Plan evidence base should be updated to reflect the fact that both of the Greenlight sites in the village of Whissendine are considered to be suitable, available and achievable, and the allocation of both sites would be consistent with the NPPF and the Local Plan strategy; thus, reflecting the approach for the site agreed at the pre- application stage with both Historic England and Officers of the Council. The accompanying Vision Document (November 2020) demonstrates the suitability, availability and achievability of the sites, and provides a considered landscape / heritage-led development concept for the sites. We suggest the Vision Document provides a good starting point for any further consideration of the sites through the remainder of the Local Plan process. The SHELAA and Site Allocations Assessment In terms of the Council’s assessment of the Pickwell Lane site, we believe there are inconsistencies between the conclusions drawn in the Council’s Site Allocations Assessment and SHELAA (both dated December 2019). It is noted that the Site Allocations Assessment is still only in draft form, so it is possible to rectify these inconsistencies, and for the Council’s evidence base to be made ‘sound’ before progressing the Local Plan any further. The Site Allocations Assessment states an indicative capacity of 82 dwellings for the Pickwell Lane site (WHI12). It is unclear how this has been calculated, but through our detailed design work (informed by the work we have undertaken with both Historic England and Officers of the Council), this Vision Document confirms a notably lower capacity of 47 dwellings, which would influence any balanced consideration of the site’s suitability. Turning to the Site Allocation Assessment RAG Scoring; this is stated as being 24/84 for the site. This appears to have been incorrectly transcribed, as the site actually scores 25 (we refer to site summary section on Page 33 of the Site Allocations Assessment). This is the same score as the South Lodge Farm site, which is proposed as a housing allocation for Whissendine, along with the Melton Road site (which has the highest individual site score of 26). From our reading of the Site Allocation Assessment there appears to be one key issue which has resulted in the Pickwell Lane site being excluded as a housing allocation; this being its unacceptable landscape impact. There is also a lesser issue, in terms of the accessibility of the site to bus stops; both issues are addressed below. Landscape impact – in Greenlights’ opinion the commentary on the potential landscape impact of the Pickwell Lane site leading to the conclusions reached on whether or not it should be allocated in the Local Plan, does not follow a logically reasoned argument; an approach which undermines the Council’s Local Plan evidence base. We explain our position on this below, which goes to the Council’s rationale as to why this site has not been allocated in the Local Plan. The commentary on the landscape impact of the site is relatively consistent in both the SHELAA and Site Allocations Assessment. The commentary within both of these documents, states: “Development in this location would be perceptible but is unlikely to significantly alter the balance of features or elements in the existing view. New housing on the western edge of the village would be on land at a similar height to that existing, and in creating a new western edge mitigation by way of appropriate planting could integrate the village in the countryside more positively than is currently the case in this area.” These documents also helpfully note that: “Potential impact of development could be mitigated so that visual intrusion in the countryside is acceptable.” It is acknowledged that both commentaries state: “Site WHI/12 extends out into open countryside where development would be more isolated from the village than sites WHI/06a and 06b. Consequently, a landscape RAG rating of amber is considered appropriate.” However, following this (comparable) commentary, whilst the SHELAA concludes that the site is developable, the Site Allocations Assessment reaches a different conclusion; stating: “Conclusion: The site is adjacent to the built-up area of Whissendine. This site is promoted for residential development with an indicative capacity of 82 dwellings. Of the 5 sites assessed in Whissendine this site scored 25 out of a possible 84. There is a limited range of scores with there being only 2 points between the least scoring and the top scoring sites. The site is more sensitive than other sites in Whissendine on landscape impact grounds and the relationship to the existing built form is not as strong as other sites promoted in Whissendine with the site protruding into open countryside to the south of existing built form significantly.
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