Please return to 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 ’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 • Justified - an appropriate strategy, taking Council’s Statement of Community 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) () 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. Therefore, on this basis, this site is not considered suitable for allocation.”

As noted earlier, as a result of our detailed analysis, Greenlight do not believe the site has the capacity for 82 dwellings, and as such are promoting it for a notably lower capacity of 47 dwellings. This would clearly have a strong influence on the landscape judgements and assessment of the site’s credentials/suitability.

The conclusion reached does not reflect the landscape commentary for the site found within both the SHELAA and Site Allocations Assessment. Within both commentaries, the site is concluded as having an ‘amber’ RAG rating. As confirmed at Paragraph 3.41 on Page 12 of the SHELAA Methodology (December 2019) an amber rating is not a constraint to development; it states: “Where it is considered that mitigation maybe possible this will be identified and an amber RAG rating will be given to reflect that it is considered that the constraints could be overcome. Where there are constraints that are considered to be so significant that they could not be mitigated a red RAG rating will be given.”

Given this, it is clear the council recognise mitigation is possible. Greenlight recognised the need to craft a sympathetic new village to countryside interface from the outset and the development strategy put forward is landscape-led, being provided by Greenlight’s landscape architects, The Richards Partnership. The Vision Document notes that the development of the Pickwell Lane site brings forward the opportunity to potentially improve the village’s interface with the countryside to the south. This point was acknowledged by the Council’s Conservation Officer, Ian Wright, at our site meeting on the 16th May 2018, who considered the current housing on Mill Close was not sympathetic with the setting of the village or the Windmill and that new houses that are of a higher standard would be more in keeping with the local vernacular and had the potential to improve the village edge and interface.

Given Greenlights discussions with the council and Historic England’s Heritage Officers, the development strategy was further refined, with the housing heights staggered to provide single storey bungalows on the western side of the scheme, rising to one and half and then two storey as one moves east and northwards across the site.

As mentioned above, there is also a lesser issue, in terms of the accessibility of the site to bus stops, which is discussed below.

Distance to bus stops - Greenlight questions a ‘red’ rating for the distance from the site to a bus stop. A distance of 400-500 metres is stated. On this matter, Manual for Streets states at Paragraph 4.4.1 on Page 45 that, “Walkable neighbourhoods are typically characterised by having a range of facilities within 10 minutes’ (up to 800 m) walking distance of residential areas which residents may access comfortably on foot.” Clearly, the site (at 400-500 metres to a bus stop) falls well within this threshold and should therefore be deemed to be within an acceptable walking distance for bus stops.

Furthermore, this Vision Document shows the Pickwell Lane site being delivered in-conjunction with the Melton Road site, with a new permissive pedestrian path proposed between the two sites, (measuring circa 250 metres) providing a pedestrian connection between Pickwell Lane and Melton Road (and the adjoining Melton Road Sports Ground) . This footpath would assist in enhancing the accessibility credentials of the Pickwell Lane site via the Melton Road site; in particular gaining access to the two bus stops on Melton Road, which would now be within circa 400 metres of the Pickwell Lane site (as they are within 50 metres of the Melton Road site).

On the point of ‘comfortably’ accessing on foot, the Highways comments on Page 374 of the Site Allocations Assessment assist in dealing with this; they state: “…however there is poor pedestrian access into the village centre and a new footpath would resolve this issue.” Page 24 of the accompanying Vision Document (November 2020) shows the proposed highways solution for the site (details of which are included in Appendix B of the Vision Document). The Highway Authority (Rutland Council) has provided correspondence to confirm the feasibility of the proposed access options to both Melton Road and Road (north of Pickwell Lane) – this is included at Appendix C of the Vision Document.

Based on the above, we do not believe that the Pickwell Lane site should have a RAG rating of ‘red’ for access to bus stops. At the least we believe it should be ‘amber’, as it could be said it is somewhat reliant on mitigation (in the form of a pedestrian permissive path and a new footway in Pickwell Lane) in order to improve the site’s accessibility credentials.

Summary

The accompanying Vision Document (November 2020) confirms Greenlights’ ambitions for development of both sites in the village of Whissendine, and for the Pickwell Lane site to be allocated alongside a modestly enlarged Melton Road site in the Local Plan.

In terms of the Council’s assessment of the Pickwell Lane site, there are clear inconsistencies between the conclusions drawn in the Council’s Site Allocations Assessment and SHELAA. In addition, having considered both the Pickwell Lane and the Melton Road site’s interrelationship with the Whissendine Windmill and the surrounding countryside, the project landscape architect and heritage consultant have crafted a development strategy that provides for 47 dwelling, as opposed to the Council’s assessment which considers an 82 dwelling scheme. Greenlight is very much of the opinion that if the commentary on the landscape impact of the Pickwell Lane site is accurately carried forward into the conclusions on whether the site should be allocated or not in the Site Allocations Assessment, then a different conclusion would have been reached; this being a conclusion that the site is suitable for allocation within the Local Plan (in- conjunction with Greenlights’ Melton Road site, which as discussed above, should be increased in size).

4. Please set out the modification(s) you consider necessary to make the Pre-Submission Local Plan legally compliant and/or sound, including any revised wording.

Contained in the above response (3c).

5. If your representation is seeking a modification, do you consider it necessary to participate at the oral part of the examination?

☐ No, I do not wish to participate at the oral examination x Yes, I wish to participate at the oral examination

6. If you wish to participate at the oral part of the examination, please outline why you consider this to be necessary:

Representations go to the soundness of the evidence base that informs key decisions on which sites to allocate for housing in Whissendine.

Please note: It is the Inspector that will determine the most appropriate way to hear those who have indicated that they wish to participate at the oral examination.

Part C– Future Notifications and Privacy Notice

Future Notifications Please let us know if you would like us to use your details to notify you of any future stages of the Local Plan by ticking the relevant box(es):

x Submission of the Local Plan to the Secretary of State for independent examination under Section 20 of the Planning and Compulsory Purchase Act 2004 x Publication of the recommendations of the Planning Inspector appointed by the Secretary of State to carry out the independent examination x Adoption of the Local Plan by the Council x Future revisions to the Local Plan, new planning policies and guidance

How we will use your information We will use your details to contact you regarding your comments on the Local Plan consultation. In submitting comments to this consultation we are also required, under The Town and Country Planning (Local Planning) (England) Regulations 2012, to notify you of when the independent examination will take place. We will use the contact details you have provided to do this. Please note: At the end of the consultation period, all comments will be made public and will be submitted to the Secretary of State, who will pass them to a Planning Inspector, along with the Local Plan and other relevant supporting documents. Your comments and name will be published, but other personal information will remain confidential. Your comments will be reviewed by the independent Planning Inspector appointed by the Secretary of State to carry out the independent examination for the Local Plan. You may be invited to discuss your comments at the oral examination if you have expressed a wish to do so. If you chose not to provide your data for this purpose, or ask us to erase your data, you will be unable to participate in the Local Plan process. If you would like to find out more about how the Local Plan Team at Rutland County Council use your personal data please go to https://www.rutland.gov.uk/my- council/data-protection/privacy-notices/planning-policy/local-plan.

Please return this form to Rutland County Council no later than 4.30pm on 6th November 2020: By Email: [email protected] By Post: Local Plan Team, Rutland County Council, Catmose House, Catmose Street, Oakham, LE15 6HP

Land off Melton Road and Pickwell Lane, Whissendine, Rutland

A Vision Document

Greenlight Developments’ Representations to Rutland Local Plan - Pre-Submission Local Plan - Regulation 19 Consultation

November 2020 Land off Melton Road and Pickwell Lane, Whissendine: Vision Document Document Ref: 17-71-CR03 Revisions Revision Date Description Prepared Approved 0 02/11/2020 Document created JBG PJR Contents

Section 1 Introduction and Planning Policy Context

Section 2 Understanding the Sites and their Wider Context

Section 3 Design Vision

Section 4 Summary

Appendix A: Historic England letter to Duncan Coe of Cotswold Archaeology, dated 4th July 2018

Appendix B: BWB Consulting Proposed Access Drawings

Appendix C: Rutland County Council Correspondence Section 1 Introduction and Planning Policy Context

Introduction

Purpose of the Document Introduction to Greenlight Developments Introduction to the Sites

This Vision Document has been prepared on behalf of Greenlight Greenlight is a niche land promotion business. The Greenlight proposed allocation site is made up of two parcels of land Developments Limited (“Greenlight”) to promote the Land off Melton (refl ecting Site References: WHI11 and WHI12), as shown on the satellite Road and Pickwell Lane, Whissendine, for residential development as The business is privately owned and is led by its four Directors: Philip image overleaf. These parcels are within two fi elds which appear from part of the Rutland Local Plan – Pre-Submission Local Plan – Regulation Rawle, Matt Gallagher, Simon McNally and Simon Cooper. The Directors the ridge and furrow to have been in pastoral use for many years. The 19 Consultation. It has been prepared by The Richards Partnership, are ‘hands-on’ and run all aspects of the business. This approach means fi rst parcel adjoins Melton Road and sits between existing residential with contributions from the wider consultant team, and builds upon the Greenlight’s attention to detail and their liaison with their consultant team properties and the Whissendine Sports Club (Site Reference: WHI11). previous Vision Document prepared for these sites in September 2018. and landowners is second to none. The second parcel adjoins Pickwell Lane and residential properties along Mill Grove (Site Reference: WHI12). The Council’s Pre-Submission Local Plan proposes to allocate the Melton The experience, knowledge and approachability of the Greenlight team Road site for 12 dwellings under Policy H1.17. The larger Pickwell Lane enables them to fully engage in the planning process, in turn providing the The existing fi eld boundaries are formed by relatively low clipped, well site is not proposed for allocation. best development solutions for all key stakeholders. managed hedgerows. A small number of mature trees are present along the rear gardens of the houses along Melton Road and Mill Grove. There The Vision Document provides an overview of the Greenlight consultant Greenlight is very selective in choosing sites; selecting only those sites are no public rights of way across the sites. team’s detailed considerations of the sites and their environs, and in they believe can be acceptable for future development. particular the setting of Whissendine Windmill, a Grade II* Listed building. In light of the heritage and landscape work considering the setting of Since its formation in early 2014, Greenlight has secured planning the Windmill, and a meeting with Historic England and Rutland County permission for over 500 houses and two 64-bedroom care homes across Vision for the Sites Council in May 2018, the consultant team proposed a variation to the eight sites through Development Plan allocations, planning applications previously proposed housing allocation in the Rutland Local Plan Review and appeals; resulting in a 100% track record in land promotion. The development on land off Melton Road and Pickwell Lane would (2016-2036) Consultation Draft (July 2017). The proposal and supporting provide a range of attractive, good quality homes. As will be shown within rationale for these changes was outlined in the Vision Document Greenlight has interests in a further eight land holdings that have the this Vision Document, the development would be sensitively designed (September 2018). This variation to the originally proposed housing site potential to deliver over 1,600 houses; including this site in Whissendine, with regard to its interrelationship with the Windmill, the adjoining village, refl ects the two housing sites proposed as part of the previous ‘Additional which has the capacity for approximately 68 houses. and the village’s and the Windmill’s interrelationship with the countryside Sites 2018’ Consultation – Site References: WHI11 (Land off Melton to the south. Road) and WHI12 (Land off Pickwell Lane), and this approach has been To help with the delivery of the Land off Melton Road and Pickwell Lane, continued forward in this latest Vision Document (November 2020). Whissendine, Greenlight has assembled an experienced consultant team, The two proposed sites would provide approximately 68 dwellings in a comprising: range of forms from single-storey bungalows to one-half storey houses to two-storey houses. The two housing sites can be delivered with access points within Greenlight’s control. Planning - PDR Planning Urban Design and Landscape - The Richards Partnership Heritage & Archaeology - Cotswold Archaeology Flood Risk and Drainage - BWB Consulting Highways - BWB Consulting Ecology - Ecology Solutions

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Local Plan Review - Consultation Draft Policies Map (July 2017)

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.

Project: Land off Melton Road and Pickwell Lane, Whissendine, Rutland Date: November 2020 8 Client: Greenlight Developments Limited 9 Emerging Local Plan - Allocation Proposed Housing Flood Zone 3 Important Open Space

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7

1 35

48 39 H1.17 Local Plan Pre-Submission Consultation Policies Map - Inset 61 Whissendine 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 The SHELAA and Site Allocations Assessment Landscape impact – in Greenlights’ opinion the commentary on the this parcel of land can be acceptably increased from the identifi ed potential landscape impact of the Pickwell Lane site leading to the allocation site area of 0.48 hectares to 0.79 hectares; a modest increase In terms of the Council’s assessment of the Pickwell Lane site, we believe conclusions reached on whether or not it should be allocated in the Local of 0.31 hectares. Based on a net developable area of 0.61 hectares there are inconsistencies between the conclusions drawn in the Council’s Plan, does not follow a logically reasoned argument; an approach which and a density of 35 dwellings per hectare, this increased site area could Site Allocations Assessment and SHELAA (both dated December 2019). undermines the Council’s Local Plan evidence base. We explain our accommodate a housing allocation of 21 dwellings. Greenlight advocates position on this below, which goes to the Council’s rationale as to why this that Policy H1.17 and the allocation of the Melton Road site should It is noted that the Site Allocations Assessment is still only in draft form, site has not been allocated in the Local Plan. be amended to refl ect this increased site area and indicative housing so it is possible to rectify these inconsistencies, and for the Council’s capacity. evidence base to be made ‘sound’ before progressing the Local Plan any The commentary on the landscape impact of the site is relatively further. consistent in both the SHELAA and Site Allocations Assessment. The Having reviewed the Pre-Submission Local Plan, Greenlight believes commentary within both of these documents, states: that the emerging Local Plan evidence base should be updated to refl ect The Site Allocations Assessment states an indicative capacity of 82 the fact that both of the Greenlight sites in the village of Whissendine are dwellings for the Pickwell Lane site (WHI12). It is unclear how this has “Development in this location would be perceptible but is unlikely to considered to be suitable, available and achievable, and the allocation of been calculated, but through our detailed design work (informed by the signifi cantly alter the balance of features or elements in the existing both sites would be consistent with the NPPF and the Local Plan strategy; work we have undertaken with both Historic England and Offi cers of the view. New housing on the western edge of the village would be on land thus, refl ecting the approach for the site agreed at the pre-application Council), this Vision Document confi rms a notably lower capacity of 47 at a similar height to that existing, and in creating a new western edge stage with both Historic England and Offi cers of the Council. dwellings, which would infl uence any balanced consideration of the site’s mitigation by way of appropriate planting could integrate the village in the suitability. countryside more positively than is currently the case in this area.” This Vision Document demonstrates the suitability, availability and achievability of the sites, and provides a considered landscape/heritage Turning to the Site Allocation Assessment RAG Scoring; this is stated These documents also helpfully note that: -led development concept for the sites. We suggest this Vision Document as being 24/84 for the site. This appears to have been incorrectly provides a good starting point for any further consideration of the sites transcribed, as the site actually scores 25 (we refer to site summary “Potential impact of development could be mitigated so that visual through the remainder of the Local Plan process. section on Page 33 of the Site Allocations Assessment). This is the same intrusion in the countryside is acceptable.” score as the South Lodge Farm site, which is proposed as a housing allocation for Whissendine, along with the Melton Road site (which has It is acknowledged that both commentaries state: the highest individual site score of 26). “Site WHI/12 extends out into open countryside where development From our reading of the Site Allocation Assessment there appears to be would be more isolated from the village than sites WHI/06a and one key issue which has resulted in the Pickwell Lane site being excluded 06b. Consequently, a landscape RAG rating of amber is considered as a housing allocation; this being its unacceptable landscape impact. appropriate.” There is also a lesser issue, in terms of the accessibility of the site to bus stops; both issues are addressed below. 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 signifi cantly. Therefore, on this basis, this site is not considered suitable for allocation.”

Project: Land off Melton Road and Pickwell Lane, Whissendine, Rutland Date: November 2020 10 Client: Greenlight Developments Limited As noted earlier, as a result of our detailed analysis, Greenlight do distance from the site to a bus stop. A distance of 400-500 metres is not believe the site has the capacity for 82 dwellings, and as such are stated. On this matter, Manual for Streets states at Paragraph 4.4.1 This Vision Document confi rms Greenlights’ ambitions for development promoting it for a notably lower capacity of 47 dwellings. This would on Page 45 that, “Walkable neighbourhoods are typically characterised of both sites in the village of Whissendine, and for the Pickwell Lane site clearly have a strong infl uence on the landscape judgements and by having a range of facilities within 10 minutes’ (up to 800 m) walking to be allocated alongside an modestly enlarged Melton Road site in the assessment of the site’s credentials/suitability. distance of residential areas which residents may access comfortably on Local Plan. foot.” Clearly, the site (at 400-500 metres to a bus stop) falls well within The conclusion reached does not refl ect the landscape commentary for this threshold and should therefore be deemed to be within an acceptable In terms of the Council’s assessment of the Pickwell Lane site, there are the site found within both the SHELAA and Site Allocations Assessment. walking distance for bus stops. clear inconsistencies between the conclusions drawn in the Council’s Site Within both commentaries, the site is concluded as having an ‘amber’ Allocations Assessment and SHELAA. In addition, having considered RAG rating. As confi rmed at Paragraph 3.41 on Page 12 of the SHELAA Furthermore, this Vision Document shows the Pickwell Lane site being both the Pickwell Lane and the Melton Road site’s interrelationship with Methodology (December 2019) an amber rating is not a constraint to delivered in-conjunction with the Melton Road site, with a new permissive the Whissendine Windmill and the surrounding countryside, the project development; it states: “Where it is considered that mitigation maybe pedestrian path proposed between the two sites, (measuring circa 250 landscape architect and heritage consultant have crafted a development possible this will be identifi ed and an amber RAG rating will be given metres) providing a pedestrian connection between Pickwell Lane and strategy that provides for 47 dwelling, as opposed to the Council’s to refl ect that it is considered that the constraints could be overcome. Melton Road (and the adjoining Melton Road Sports Ground). This assessment which considers an 82 dwelling scheme. Greenlight is very Where there are constraints that are considered to be so signifi cant that footpath would assist in enhancing the accessibility credentials of the much of the opinion that if the commentary on the landscape impact of they could not be mitigated a red RAG rating will be given.” Pickwell Lane site via the Melton Road site; in particular gaining access the Pickwell Lane site is accurately carried forward into the conclusions to the two bus stops on Melton Road, which would now be within circa on whether the site should be allocated or not in the Site Allocations Given this, it is clear the Council recognise mitigation is possible. 400 metres of the Pickwell Lane site (as they are within 50 metres of the Assessment, then a different conclusion would have been reached; Greenlight recognised the need to craft a sympathetic new village to Melton Road site). this being a conclusion that the site is suitable for allocation within the countryside interface from the outset and the development strategy put Local Plan (in-conjunction with Greenlights’ Melton Road site, which as forward is landscape-led, being provided by Greenlight’s landscape On the point of ‘comfortably’ accessing on foot, the Highways comments discussed above, should be increased in size). architects, The Richards Partnership. The Vision Document notes that on Page 374 of the Site Allocations Assessment assist in dealing with the development of the Pickwell Lane site brings forward the opportunity this; they state: “…however there is poor pedestrian access into the to potentially improve the village’s interface with the countryside to the village centre and a new footpath would resolve this issue.” Page 24 of south. This point was acknowledged by the Council’s Conservation this Vision Document shows the proposed highways solution for the site Offi cer, Ian Wright, at our site meeting on the 16th May 2018, who (details of which are included in Appendix B). The Highway Authority considered the current housing on Mill Close was not sympathetic with (Rutland Council) has provided correspondence to confi rm the feasibility the setting of the village or the Windmill and that new houses that are of of the proposed access options to both Melton Road and Oakham Road a higher standard would be more in keeping with the local vernacular and (north of Pickwell Lane) – this is included at Appendix C. had the potential to improve the village edge and interface. Based on the above, we do not believe that the Pickwell Lane site should Given Greenlight’s discussions with the Council and Historic England’s have a RAG rating of ‘red’ for access to bus stops. At the least we Heritage Offi cers, the development strategy was further refi ned, with the believe it should be ‘amber’, as it could be said, it is somewhat reliant on housing heights staggered to provide single storey bungalows on the mitigation (in the form of a pedestrian permissive path and a new footway western side of the scheme, rising to one and half and then two storey as in Pickwell Lane) in order to improve the site’s accessibility credentials. one moves east and northwards across the site.

As mentioned above, there is also a lesser issue, in terms of the Summary accessibility of the site to bus stops, which is discussed below.

Distance to bus stops - Greenlight questions a ‘red’ rating for the

11 Section 2 Understanding the Site and its Wider Context

Understanding the Sites and their Wider Context

Introduction

This section focuses on the sites and the surrounding area, and contains a summary of the technical work undertaken by the project’s consultant team. The specialist advice that has fed into this Vision Document includes input on: heritage and archaeology, urban design, landscape, highways, fl ood risk and drainage and ecology.

Whissendine is a large village situated approximately 20km north east of Leicester. It lies within the north-west part of the County of Rutland. Prominent village landmarks include the Grade I listed St Andrew’s Church, which sits on high ground at the eastern end of the village and the Grade II* listed Whissendine Windmill, built in 1809, which occupies high ground to the western end of the village.

Whissendine older buildings There are approximately 550 homes in Whissendine ranging from thatch and cob cottages to 21st century conversions and new developments. Whissendine has a popular primary school, pub, village shop, village hall and sports club.

Whissendine more modern housing Historic view of Whissendine Windmill. Source:Historic England Archive

Windmill Church of St Andrew

View towards Whissendine from the south east - Whissendine Windmill is discernible at the western end of the village and the Church of St Andrew is clear to the east of the village

Land off Melton Road and Pickwell Lane, Whissendine, Rutland Date: November 2020 14 Client: Greenlight Developments Limited Site Context

15 Understanding the Sites and their Wider Context

Settlement Evolution

Whissendine has a long history; the ‘whissendine.net’ web page describes IInformationnformation unavailableunavailable the village as having at least 1000 years of history, as it is mentioned in the Domesday Records, however, the current settlement probably dates back to the late Saxon period, 900-1066AD, although evidence for earlier prehistoric and Roman period activity has been found.

As the settlement evolution study drawings shows the settlement has always had a linear, or ribbon like form with housing focused along the Melton Road and Main Street. More modern development such as the housing on Mill Grove and the small housing schemes to the west of Stapleford Road and west off Melton Road have grown out from this linear form. The village has grown only modestly over the last few centuries.

The village is linear in form along a single main street with little Church of St Andrew Village sign development in depth, and is quite straight.

1766 1902

Whissendine Village Hall

1981 2018 The White Lion public house

Land off Melton Road and Pickwell Lane, Whissendine, Rutland Date: November 2020 16 Client: Greenlight Developments Limited Legend Site

1766

1902

1981

2018

windmill

Settlement Evolution

The historic Windmill visible in between more modern buildings off Mill Grove

17 Understanding the Sites and their Wider Context

Topographical Study and Landscape Features

The sites are located on gently sloping ground on the south-western side of Whissendine. The land falls gently to the south-east, towards Pickwell Lane and Whissendine Brook.

The sites lie within the ‘High Rutland’ Landscape Character Type and within the ‘Ridges and Valleys’ Landscape Character Sub-area as defi ned in the Rutland Landscape Character Assessment (2003). This describes this Sub-area as having “a much more open, regular, geometric fi eld pattern (exacerbated by some boundary removal) with fewer, low-cut or gappy hedges, fewer hedgerow trees and less enclosure. The ridges and valleys are evident but not as pronounced as to the west. There are fewer woodlands and those that occur tend to be enclosure or post- enclosure, straight-edged plantations. In parts there are a number of small plantations and some of the valley streams have linear strips of woodland or narrow, linear wetland habitats. Mixed or arable farming prevails with a variety of crops and intensively managed, improved grasslands grazed by cattle and sheep.”

It also notes that: “The northern-most part of the sub-area, around Whissendine, differs from the rest of the sub-area in that it is more obviously a transition from the characteristic High Leicestershire / High Rutland landscapes to the west and the Vale of Catmose to the east. Notably, the ridges and valleys tend to run generally north - south rather than east west and the ridges are more rounded and lower, and the valleys shallower, than in the rest of the sub-area.”

Initial analysis suggests sensitively designed dwellings could be introduced off Melton Road and Pickwell Lane without compromising the setting of the Windmill, whilst also bringing forward the opportunity to potentially improve the village’s interface with the countryside to the south. Legend

Study Sites 120-125m AOD 145 -150m AOD Landscape Context < 105m AOD 125-130m AOD >150m AOD

Ponds and 105-110m AOD 130-135m AOD water courses

Public Rights 110-115m AOD 135-140m AOD of Way

115-120m AOD 140 -145m AOD

Project: Land off Melton Road and Pickwell Lane, Whissendine, Rutland Date: November 2020 18 Client: Greenlight Developments Limited View into the site from Pickwell Lane

Aerial view looking north east towards Whissendine, with the site outlined in red. The large open fi eld pattern is clear in this view

19 Understanding the Sites and their Wider Context

Character and Land Uses

Whissendine is an attractive historic village. The village is serviced with a local shop & post offi ce, public house, primary school, village hall, sports club, and a church (see page 21). All the local facilities within the village are conveniently located within a 10 minutes walking distance from the sites. The sports club, adjacent to the Melton Road site, includes a football pitch, cricket fi eld, tennis court, bowls green and clubhouse. Whissendine Primary School is located approximately 5 minutes walking distance from the sites.

Motorists approaching the village from the west along Melton Road fi rst see this site when they are alongside the sports club. At this western entrance to the village the houses are mid 20th century along the southern side of Melton Road and more modern late 20th century on the northern side of the road. It is the mid 20th century houses and their gardens which back onto the proposed Melton Road development area.

The proposed larger development parcel is situated to the south alongside the late 20th century Mill Grove. Access to this parcel would be via Pickwell Lane, a quiet country road which connects to the A606 approximately 2kms to the south.

As seen in the drawing overleaf and the Pickwell Lane photograph on page 19, the absence of any signifi cant landscape structure around the Mill Grove and Melton Road southern edge of the village results in a the western side of the village having a rather unsympathetic and abrupt interrelationship with the countryside to the south.

Primary school

Local post offi ce Village green Whissendines Windmill

Project: Land off Melton Road and Pickwell Lane, Whissendine, Rutland Date: November 2020 20 Client: Greenlight Developments Limited Legend

Whissendine Windmill

Church of St Andrew

Local Bus Stop

Local Shop and Post Office

Public House

Primary School

Village Hall

Village Green

Greendale Farm Caravan and Camping

Land Use

School Playing Field Land Uses

School

Sports Ground

Residential Area

Rutland Recycling Centre

21 Understanding the Sites and their Wider Context

The Site

The sites are both greenfi eld and comprise pastoral fi elds located at the western end of Whissendine Village. The fi rst parcel adjoins Melton Road and sits between existing residential properties off Melton Road and the Whissendine Sports Club. This parcel measures 0.79 hectares (1.95 acres). The second parcel adjoins Pickwell Lane and residential properties along Mill Grove. This parcel measures 2.86 hectares (7.07 acres).

Ecology

A review of ecological matters in relation to the sites has been undertaken to inform its potential development. Consideration has been given to the potential ecological value of the sites and the impacts that may arise from the proposed scheme as well as options to deliver a net gain in terms of biodiversity as part of the proposals.

A desk-based study of the sites has identifi ed habitats on site are limited to grazed fi elds with boundary hedgerows. In light of the information reviewed it is considered likely that these habitats are of limited intrinsic ecological value.

The emerging development strategy has been assessed in terms of its potential effects on ecology and nature conservation. It is noted from the emerging strategy that sections of boundary hedgerows would be Legend lost to facilitate site access as well as the loss of an internal hedgerow Study area / to the proposed development area within the Pickwell Lane parcel. prprop posed sitess Areas of grazed fi eld would also be developed. None of these losses Winndmdmilll Grade II** LisL ted BuBuildill ing are considered to be of ecological signifi cance. To further inform the proposals the sites will be subject to a full Phase 1 habitat survey and Abruptpt uru ban too countrysidee intin erfrfrfacacec any other species-specifi c surveys considered necessary. The results of Filtered views these surveys, a detailed assessment of the impacts of the development and a suite of ecological mitigation and enhancement measures will be Arable fieldldl s presented within an Ecological Assessment. Historic riddge and furrow Although the emerging development strategy shows losses to existing habitats, it is also clear that substantial areas of new planting are Existing treees proposed to be delivered. Replacement planting would consist of species Existing Ovev rheadd Site Analysis Power Linnes (poole rich native hedgerow of greater value than those habitats lost. As well mounteteed)d as this area of new planting other mitigation measures will be developed SpoS rts club fieldss as informed by the results of the detailed surveys planned. This would 50m 100m ensure a net benefi t to biodiversity is delivered as part of the proposals, in Listedd BuB idingn accordance with national policy (NPPF paragraph 170).

Project: Land off Melton Road and Pickwell Lane, Whissendine, Rutland Date: November 2020 22 Client: Greenlight Developments Limited their letter to the Council, dated 20th September 2017) they entered into In respect of Historic Englands’ response of 4th July 2018, Greenlight Heritage and Archaeology a dialogue with both Historic England and the Conservation Advisor to has prepared a revised Framework Plan (included on Page 31 of this Rutland Council. A site meeting was held on 16th May 2018 and following Vision Document), which responds to Historic England’s comments in Greenlight identifi ed the potential issues relating to the presence of this, details of potential layouts and development form were supplied a positive way, by reducing the proposed development area in-line with the Grade II* listed Whissendine Windmill at an early stage in their to Historic England. Historic England’s formal response to these early the area marked ‘B’ on the plan below (extract of an early Development site appraisal work, prior to the response from Historic England on the discussions was received on 4th July 2018 (see Appendix A). Strategy drawing 17-71-SK03 submitted on 22nd May 2018). Greenlight proposed allocation site being made public. can also confi rm that the concern about the development heights within Historic England have concluded that for the parcel off Melton Road: this proposed development area can be accommodated within this It is acknowledged that the land to the south west of Whissendine “…..we do not believe that new development that is in keeping with the development parcel. The detail of which can be adequately documented Windmill is a part of its setting that contributes to its signifi cance. Both the prevailing scale and pattern of existing built form would be likely to have in any subsequent detailed planning application (following the allocation well-preserved ridge and furrow earthworks and the Windmill are surviving signifi cantly negative effects upon the setting of the windmill. We would of the site in the Local Plan) to demonstrate that there would be no visible reminders of the different periods of the historic agricultural not therefore object to this part of the proposal.” unacceptable impact on the signifi cance of the Windmill, through an economy of Whissendine; and there is a functional association between alteration to its setting. the land to the south-west and the Windmill, since it was across the tract For the parcel off Pickwell Lane Historic England have concluded that if: of open pasture that the prevailing south-westerly winds would have “….the site was to be reduced in area so that development was instead blown before turning the sails of the Windmill. It is in views from the concentrated more in the portion marked as ‘B’ on the plan closer to the south-west that the original positioning of the Windmill at the interface of lane, along with a signifi cant reduction in the heights of the dwellings to the historic settlement and its agricultural hinterland can still be discerned. no more than 1 ½ storeys, we believe that this would lessen the impact upon the windmill and its setting to a level that we would be likely to fi nd It was quickly established that an alternative plan would be required more acceptable, subject to the effect be adequately demonstrated.” and through careful assessment it was concluded that two land parcels may be acceptable for development, one off Melton Road and one off Pickwell Lane. In order to ensure that Greenlight had a proposal that would meet the concerns expressed by Historic England (as set out in

View discussed with Historic England and Rutland Conservation Offi cers on site Extract of early Development Strategy drawing 17-71-SK03 (submitted on 22nd May 2018)

23 Understanding the Sites and their Wider Context

In addition to these footways, a footpath is also proposed to provide a Highways 2.4m x 43m visibility splays pedestrian connection between the two sites of residential development, forming a link between Melton Road and Pickwell Lane/Oakham Road. Melton Road is approximately 5.5m wide with a speed limit of 30mph along the site frontage, which changes to 60mph approximately 150m to the west of the western extent of the site.

Pickwell Lane is approximately 4.2m wide and is subject to a speed limit of 30mph where the road forms the minor arm of a priority controlled T-junction with Oakham Road. Pickwell Lane narrows to circa 3.0m wide, with the speed limit also changing to 60mph at a point approximately 25m to the south of the junction.

There is a footway approximately 1.8m wide provided adjacent to the southern side of Melton Road which extends towards the centre of Proposed 2m footway to connect with existin g Whissendine. Whilst no footways are present along the eastern perimeter Proposed 2m footway to connect with of the site adjacent to Pickwell Lane, there are footways approximately existing 2.0m wide on both sides of Oakham Road which extend to the Oakham Proposed access point to the site off Melton Road Road/Pickwell Lane junction. 5.5m wide access Vehicle Access The access road is proposed to be 5.5m wide with a 6.0m corner radii Given that Rutland County Council (RCC) do not have a local highways to the north and a 9.0m corner radii to the south. A 2.0m footway is design guide, discussions were held with the Council to determine also proposed adjacent to the northern side of the access road that is appropriate dimensions for the accesses to the proposed development. to connect to the existing pedestrian infrastructure adjacent to Oakham RCC suggested that the 6C’s Design Guidance which is used by the Road. neighbouring local authorities, would be a reasonable guide for the Proposed access point to the site off Pickwell Lane preliminary access designs. RCC also confi rmed that the access Pickwell Lane is proposed to form the minor arm of a junction with the proposals should be submitted to the highways department as part of the access road in the form of a priority controlled T-Junction which is to be scoping discussions to confi rm that the standards used are acceptable. 5.5m wide with 6.0m corner radii’s. The required visibility splays based on the MfS Guidance are achievable from both the proposed Oakham Road/ The proposed access arrangements to the sites from Melton Road and Site Access and Pickwell Lane/Site Access Junctions as shown in drawing Pickwell Lane are shown in the Drawings contained in Appendix B - these MRW-BWB-GEN-00-DR-TR-104-S2-P5 (see Appendix B). The Highway being MRW-BWB-GEN-00-DR-TR-103-S2-P2 (Melton Road Access Authority (RCC) has provided correspondence to confi rm the feasibility Arrangement) and MRW-BWB-GEN-00-DR-TR-104-S2-P5 (Oakham of the proposed access options to both Melton Road and Oakham Road Road Access Arrangement) & MRW-BWB-GEN-00-DR-TR-110-S2-P2 (north of Pickwell Lane), see Appendix C. (Oakham Road/Pickwell Lane Vehicle Tracking Assessment). The drawings included in Appendix B show that the proposed works to the The proposed access arrangements from the sites adjacent to Melton highway can be accommodate either within the site or within the adopted Road and Pickwell Lane were agreed in principle with RCC. Access from highway boundary. The signpost of the speed limit change from 30/60mph Melton Road is proposed in the form of a priority controlled T-Junction along Pickwell Lane will also be relocated further south, given the extent with a 5.5m wide access road, 6.0m corner radii and 2.0m adjacent of the highway works are proposed. footways that connect with the existing pedestrian infrastructure. 2.4m x 43.0m visibility splays based on the Manual for Streets (MfS) Guidance Pedestrian Access are achievable from the proposed access as shown in drawing MRW- Footways 2.0m wide are proposed each side of the vehicular access BWB-GEN-00-DR-TR-103-S2-P2 (see Appendix B). from Melton Road which are to connect with the existing footway on the southern side of Melton Road. A 2.0m wide footway is also proposed Access to the parcel of the site adjacent to Pickwell Lane is to be served adjacent to the northern side of the Pickwell Lane access which is to directly from Oakham Road in the form of a priority controlled T-Junction extend and connect with the footway located adjacent to the western side in order for a refuse vehicle to be able to access and egress the site. of Oakham Road to the north of the site. Tracking diagram of refuse vehicle exiting the site

Project: Land off Melton Road and Pickwell Lane, Whissendine, Rutland Date: November 2020 24 Client: Greenlight Developments Limited Flood Risk and Drainage

Flood Risk A preliminary fl ood risk and drainage plan has been prepared for the sites (see page 27). The key fi ndings of this investigations to date are summarised as follows. The sites are not shown to be at signifi cant risk of fl ooding from any source. The site lies within Flood Zone 1 and the small isolated areas of surface water fl ood risk shown on the site appear associated with localised topographic depressions (see BWB Consulting’s Preliminary Flood Risk and Drainage Strategy).

There are, however, fl ooding sensitivities in the village. The Whissendine Brook fl ows from south to north through the village. Photos 1 and 2 below, provided by RCC, show examples of historic fl ooding in the village. Further investigation into these historic fl ooding incidences will be undertaken to ensure that these are refl ected and referenced in the Flood Risk Assessment for the sites. Focus on the potential ‘benefi ts’ of formal drainage of the sites and reduction in peak runoff rates should also be drawn out from the Sustainable Drainage Strategy for the sites, albeit it is not considered that development of the sites could signifi cantly reduce (or increase) downstream fl ood risk.

Photo 1 - Rutland County Council Photos showing the Photo 2 - Rutland County Council Photos showing Cow Junction of Main Street and Cow Lane Lane

25 Understanding the Sites and their Wider Context

Proposed Drainage Strategy

The splitting of the original site into two sites will provide the need to either consider the separation of the drainage strategies associated with each land parcel or to deliver shared drainage infrastructure serving both parcels.

The underlying geology and prevailing soil types suggest that infi ltration will not be viable, as such preliminary investigations have concentrated on the potential to achieve an off-site connection.

Levels across and between the sites are such that it is possible to drain the north-west corner of the site either to the north or to drain to and through the larger development parcel to the east.

The proposed drainage option shown in BWB Consulting’s Preliminary Flood Risk & Drainage Strategy (adjacent) shows both parcels of land draining to the east. This option does provide the opportunity for a single attenuation basin serving both parcels; maximising the potential site frontage along Melton Road.

The majority of the site will drain to the public surface water sewer in Oakham Road near the junction with Pickwell Lane, which in turn outfalls to the Whissendine Brook to the east of that site.

Given the levels, the most effi cient form of attenuation is to deliver a basin immediately south of the proposed new highway access to Pickwell Lane. Some localised earthworks (raising of land) may be required in the south- eastern most site extent to achieve a discharge via the north-east corner of the site.

It is considered likely that a gravity solution will be available for the site, given that much of the existing village is at a lower level than the site, albeit this will need to be confi rmed via a Pre-Development Enquiry to Severn Trent Water Ltd.

Project: Land off Melton Road and Pickwell Lane, Whissendine, Rutland Date: November 2020 26 Client: Greenlight Developments Limited BWB Consulting’s Preliminary Flood Risk & Drainage Strategy

27 Section 3 Design Vision

Vision & Design Evolution

1 3

The initial development strategy was led by With the benefi t of a site meeting with the Council’s discussions with the project consultant teams’ Conservation Offi cer and Historic England’s Heritage Heritage and Archaeology consultant (Duncan Offi cer the development strategy was further Coe from Cotswold Archaeology). The site refi ned. In consideration of views from Pickwell Lane studies revealed the Grade II* listed Windmill (provided on page 19) the extent of development was a prominent feature in the western side of was pulled back behind the Pickwell Lane to Windmill the village. In walking the fi elds to the south of sightline with an area of open space (informal open the Windmill (the draft allocation site - shown space and possibly a natural play area) to act as with red line) it was evident the Windmill has a an interface with the adjoining fi eld. A permissive strong landscape and visual interrelationship footpath would be introduced between Pickwell Lane, with the ridge and furrow fi elds to the south across the fi elds over to the Whissendine Sports Club west of the Windmill. In consideration of and the parcel of housing proposed off Melton Road. this early analysis and evaluation work the This footpath would provide walkers excellent views development strategy suggested splitting the of the Windmill. proposed housing areas into two parcels; a relativity small one off Melton Road and  two storey In addition, the development strategy included refi ned larger second parcel off Pickwell Lane. input from the Flood Risk and Drainage consultants  (BWB Consulting) who had identifi ed the optimum location for the SuDS strategy. single storey (bungalows)

2 4 two storey dwellings Further dialogue concerning views to the In response to Historic England’s comments in their Windmill led to the refi nement of the initial letter (dated, 4th July 2018) to Greenlight’s heritage development strategy with single and one and consultant (Duncan Coe of Cotswold Archaeology) a half storey development proposed along the  dwellings have been eased back from the southern Pickwell Lane parcels’ western and southern edge/corner of the Pickwell Lane site and in addition edges, shown as area A on the adjacent plan. dwellings have been removed from the north west corner of the Pickwell Lane site. Single storey development along the Pickwell Lane site’s western boundary rising to one and half and then two storey as one moves eastwards away from the Pickwell Lane Windmill sightline.

one & a half storey dwellings

Project: Land off Melton Road and Pickwell Lane, Whissendine, Rutland Date: November 2020 30 Client: Greenlight Developments Limited Framework and Land Budget Legend The Framework Plan shown is an evolution of those provided on page 30 oppostie. This Framework Plan is in response to Historic England’s letter dated 4th July 2018. In consideration of the feedback contained within Site Boundary this correspondence, the Framework Plan shows no dwellings west of the sightline identifi ed along Pickwell Lane and has noted all development Two Storey Dwellings alongside and the east of this sightline would be single storey, rising to one and a half and then two storey as one moves eastwards away from the Windmill sightline. In addition, it has responded to detail studies One and a Half Storey provided by consultant team members contributing on access, fl ood risk Dwellings and drainage aspects of the development strategy. The Framework Plan One Storey Dwellings identifi es the development areas (or cells), the vehicular and pedestrian circulation and links, existing features retained and proposed landscape features, such as open space, tree and hedgerow planting and surface Proposed Pedestrian water attenuation ponds. Permissive Paths

Proposed Structure The layout has been infl uenced by the existing features and access Planting location. The Framework Plan has been analysed in terms of areas and densities and this analysis is presented in the Land Budget table below. Proposed SuDS Existing pond It is envisaged the sites would provide circa. 21 dwellings on the Melton Attenuation Ponds Road site and circa 47 dwellings on the Pickwell Lane site, a total of circa 68. Proposed Tree Planting

Proposed Hedge Land Budget Site Area 3.65 Ha (0.79 + 2.86 Ha) Public Open Space Total Dwellings Circa 68 (both sites) Net Development Area Approx 2.03 Ha (56%) Whissendine Windmill Melton Road: approx 0.61 Ha (77%) Grade II* Listed Building Pickwell Lane: approx 1.42 Ha Existing Overhead Power (49.6%) Lines (pole mounted) Net Green Infrastructure/POS Approx 1.62 Ha (44%)

Sports Field Melton Road: approx 0.18 Ha (23%) Framework Plan Pickwell Lane: approx 1.44 Ha (50.4%)

0m50m 100m

31 Section 4 Summary

Summary

This Vision Document has been prepared to promote the sites known as The Greenlight proposed allocation sites are made up of two parcels of The purpose of the planning system is to contribute to the achievement of Land off Melton Road and Pickwell Lane, Whissendine, for residential land (refl ecting Site References: WHI11 and WHI12). These parcels are sustainable development, part of this includes ensuring suffi cient number development as part of the Rutland Local Plan – Pre-Submission Local within two fi elds which appear from the ridge and furrow to have been in and range of homes can be provided to meet development needs (NPPF Plan – Regulation 19 Consultation. . pastoral use for many years. The fi rst parcel adjoins Melton Road and sits paragraph 8). Planning policies should identify a suffi cient supply and mix between existing residential properties and the Whissendine Sports Club of sites, taking into account their availability, suitability and likely economic The Vision Document has been developed with the benefi t of technical (Site Reference WHI11). The second parcel adjoins Pickwell Lane and viability (paragraph 67 of the NPPF). and design input from the project’s consultant team: residential properties along Mill Grove (Site Reference WHI12). Greenlight’s site presents an opportunity to provide circa 68 new It is proposed that vehicle access will be taken from Melton Road in homes in Whissendine to assist in sustaining and growing the village Planning - PDR Planning the centre of the site frontage for the Melton Road site and for access (acknowledged as an important Local Service Centre by RCC) and assist Urban Design & Landscape - The Richards Partnership onto Pickwell Lane, from the other site, it is proposed that the existing RCC in meeting its strategic housing needs. The proposed scheme Heritage & Archaeology - Cotswold Archaeology carriageway is widened to 6.75m to allow two-way traffi c between the new capitalises on the sites’ inherently sustainable location on the edge of Flood Risk & Drainage - BWB Consulting access and the Oakham Road/Pickwell Lane junction. Whissendine and seeks to provide sensitively assessed and designed, Highways - BWB Consulting high quality housing developments. Ecology - Ecology Solutions The Melton Road site is partially identifi ed as a proposed housing site in the Local Plan Pre-Submission Rutland Local Plan under Policy H1.17. The sites as can be brought forward for development quickly and, in this The site proposed in this Vision Document is a slight alteration to the respect, they support the Local Authority’s objectives for managing and site identifi ed, and the inclusion of the whole of the Pickwell Lane site, delivering growth over the course of the Plan period. The sites at Melton which allows for an improved setting of the historic Whissendine Windmill; Road and Pickwell Lane are suitable, available and achievable and the refl ecting the two parcels of land that were previoulsy consulted upon in sites should be allocated in the Local Plan for residential development. the ‘Additional Sites 2018’ Consultation - Sites References: WHI11 and WHI12.

Project: Land off Melton Road and Pickwell Lane, Whissendine, Rutland Date: November 2020 34 Client: Greenlight Developments Limited 35 Appendix A: Historic England Letter, 4th July 2018

Project: Land off Melton Road and Pickwell Lane, Whissendine, Rutland Date: November 2020 36 Client: Greenlight Developments Limited 37 Appendix B: Proposed Highway Drawings

Appendix C: Rutland County Council Correspondence

Draft Local Plan Policy: 2018-2036.

Submitted by an individual being Responses to formatted Questions Paul Browne B 1. This response indicates at each point that section of the Pre-Submission Local Plan “PSLP” to which it relates B 2. I do not consider that the PSLP to be lawfully compliant as it is unsound on the grounds of failing the test of Justification B 4. I submit modifications to the SDLP as stated in the final paragraph hereof B 5. I consider it necessary to participate in the oral part of further examination of the Plan either personally or if appropriately by Counsel B 6. To ensure by representation that my proposals are further substantially examined Tel: Part C. Please utilise my details to keep me advised of all further stages of the LP

Email address:

Please not that:

References herein to “cl…..”, refers to that clause number as is contained in the draft plan.

It is noted that the Plan has to exhibit Soundness- i.e has to be positively prepared to meet reasonable objectively assessed need

Soundness has three tests:

1. Justified -Defined at cl.1.10 as “ an appropriate strategy taking into account reasonable alternatives and based on proportional evidence”.

2. Effectrive

3. Consistency with the National Policy document (NPPF)

This representation is an Objection based on the consideration of the factors identified in the methodology for the site assessment and criteria used as contained in the Rutland Local Plan (hereafter referred to as “the Plan”) Sustainability Appraisal Technical Annex. It is understood that these factors are generally understood to normally include two steps in respect of each considered site. Firstly, “constraints” and secondly “opportunities”(or possible mitigation). It is argued that it would have been more helpful is commentary on each point, explanation of balancing conflicts in the RAG rating, intended outcome and details of method of presenting mitigation for each site This has resulted, in this submission, of a

(i) a failure consider the alternatives available for the whole site allocation criteria for the two towns in the Plan, and

(ii) The allocation of site H1.2 (OAK/)5) is neither justified in its own right, nor following detailed objective review of two other candidate sites, namely OAK/02 and OAK/08a as identified in the document entitled Rutland Local Plan Review- Call for sites of February 2016

I would submit that to respond in the on-line format as stated to be required by the Council is neither a fair nor reasonable requirement of the Council, because

(a) The on-line forms are formatted to require specific responses to specific single objections. The Plan itself states at cl.1.28 “, when using the Plan it must be read as a whole as a number of different policies may apply to a site” The Council therefore is stipulating a format that its own policy states is if not unfeasible, is, inadvisable.

(b) in my particular case the on-line format has declined to accept responses to such questions as to whether I wish to object to raise any particular point, allowing only answers in the affirmative, whereas I wish to answer in the negative. Therefore the response mechanism itself is in operable so far as I am concerned. I am a vulnerable person, in respect of the Covid19 recommendations, therefore am unable to obtain further external help, in further specialist help or advice to progress my responses, in a method that is initially requested.

I am therefore delivering this communication both physically to RCC offices and electronically. I would request confirmation that the contents, have been reviewed together with other notified objection, are accepted on the basis that it has been validly submitted for consideration Details of Objections to the Plan

Part 4: Spatial Strategy & Location Development

Cl.4.10 states it is “Whist the new settlement will increasingly form a large part of the County’s development it is important to allow some modest growth of Oakham & Uppingham and the LSC’s. this Plan therefore allocates a range of small and medium sized sites in these localities”.

An Alternative, which does not appear to have been considered would be to allocate one specific area for development being adjacent to each town. This alternative policy would protect and support the existing character, reduces the impact of perceive extension of urban sprawl, and is less detrimental to the features and spaces surrounding those two settlements. Other historic towns have adopted this approach to maintain their character, i.e Salisbury and Chester. In the proposed site allocations at H1.3 [formerly OAK13(a) & OAK13(c)] the Plan accepts and provides the precedent for development beyond the erstwhile boundary of the eastern ring road, yet precludes OAK9 (256 units) and OAK/14 ( 432units), which surrounds them. Those four areas taken as a whole would form a centralised common area, that would still identify itself as part of Oakham as it is immediately adjacent to the existing town, and being one which would amply accommodate any required units for some considerable time. That consolidated area as a whole would more adequately comply with clauses (a), (b) & (c) of Policy stated SD3, and cls.7.61, 7.64 ,7.65 and 7.66 (Policy EN12), whereas the hotch potch of allocated developments as proposed, would contravene each of those criteria, in particular, the visual perception of nature of entering Oakham from the South.

Parts 4 & 5: Spatial Strategy & Locational Development

Should points above relating solely to Part, be deemed inappropriate

Then in respect of Part 4 as to identifying specific areas (Policy SD2) and following Part 5 in section 5.

Point (i).

Cl. 5.15 Provides at, the specifically proposed allocation areas and residential units at Table 2

Namely:

Site Completed 2018/19 Commitments Capacity Indentified Total - Comments as at 04/2019 St. Georges - - 1,000 1,000 See point (i)

Windfalls - - 300 300 See point (ii)

Oakham 99 409 382 890 See point (iii)

Uppingham 34 85 200 319 See point (iv)

Local Service Centres 66 53 249 368 Other villages 12 53 0 65

2,942 (inc. RCC’s 25% buffer above Gov. stipulated units)

Point (i). Total permission outlined is for 2,215 units on this site. The above tabled allocation assumes a rate of delivery at 100 units pa over 2025/26 and ongoing. There is no explanation of the basis for attributing that annual proportionality? Infrastructure costs, even with Government help (HIF), will be heavy for any developer. Further, declared planning criteria for constructing community structures would also fall on any developer and will be heavy for the initial years of the development. It is therefore unreasonable to arbitrarily consider, that any commercial developer would soft pedal this development to those numbers as stated, as that rate of delivery as estimated, would alleviate an acceptable fiscal return for any commercial developer, for some considerable number of years. It is likely that this number would be accelerated.

Point (ii) References to “Windfall” is defined in NPPF (see cl.4.6) as “sites not specifically identified in the Development Plan”. The Plan appears to have excluded the following:

(a) The “Woolfox Garden Town” this is a proposed large and comprehensive development lying within the boundaries of RCC, adjacent to the A1. It is the site of a war time airport. It has been put forward for incorporation into the Local Plan by the family owners. Their proposals are for an initial 2,700 units by 2036, with a further 5,000 units thereafter.

This has been actively promoted, including a public exhibition of comprehensive plans and detailed infrastructural development held in Oakham’s Victoria Hall. Further, this proposal was actively discussed in a report prepared by the Director of Planning to at the Local Plan Report on Strategy Committee on 30th October 2018. Yet there is no mention of it in the Plan. This may well be because under the title “Windfall Study” in the Plan , it states that those calculations of “Windfalls” are up to 2020, in respect of small sites (up to 10 units) and the Full Study (it is understood a reference to include over 10 units) only upto 2017. Should the lack of referral to it in the Plan be for the reason that its potentiality arose after 2017, then that would, in my submission, be an unjustified and unlawful representation of the current and known position.

It is understood that RCC are aware that the promoters of the whole site will continue to promote this site, regardless of its being not included in the Plan.

(b) By virtue of Policy H4 (relating to Cross Boundary Development) and cl.4.12, the likely effect on Rutland of the 650 units being erected within RCC boundaries, which have been allocated, to South Kesteven DC, is ignored. The inhabitants of Rutland villages immediately adjacent to this development of Great Casterton and Little Casterton do not regard their settlements to being adjuncts of Stamford. It is also unreasonable to arbitrarily decide that the whole of that development would be taken up entirely by residents outside of Rutland. I practiced as a conveyancing lawyer in Rutland for over 25 years, and there has always been a steady, but substantial number of residents leaving RCC to reside in Stamford and its environs throughout that period, but particularly in latter years. It was repeatedly stated by clients that Stamford’s qualities of life have steadily increased over those years, whilst those of Oakham (particularly), have steadily abated. It is entirely probable that a significant minority of those properties will be purchased by present occupiers of the two towns in Rutland, this should be reflected in those figures. It is accepted that this would be difficult to quantify the same, but such difficulties have not prevented arbitrary figures being included elsewhere in this Table i.e. the figure for Uppingham.

Point (iv) It is both disappointing and surprising that Uppingham criteria is arbitrarily “guessed” at 200 units, and indeed the figures provide are only until 2026 (cl.5.14), which is not the time span required by NPPF. Sufficient time to create a detailed assessment for everywhere in the County has been given. This vague projection is important, given its impact of the assessed figures for the whole of RCC . There is no stated reason for RCC’s methodology in arriving at that figure of 200. The analysis of the 9 acceptable sites, put forward for development, as detailed in the Plan, gives a total of 555 potential units. I submit that it is unrealistic to believe that only sites representing 36% of those units, will be promoted by eager land owners. It is noted that no further estimates for the following 10 years ending 2036 have been put forward.

Point (iii): the availability of Oakham’s medical facilities are generally acknowledged as currently in a parlous states. The ratio of doctors to patients is already at an acknowledged unacceptable level. The Plan makes reference to the fact that within the time frame the existing levels of elderly will increase by 50% (cl. 2.36). The development of units undertaken and identified from 2018 upto and including the committed development includes a total of approaching additional 150 aged related retirement dwellings and care facilities. There is then an additional total of 382 further units proposed for Oakham. The current increases, have not resulted in any existing expansion of medical practitioners within the only medical practice in Oakham dispensing Primary Medical Care. In fact, the number of practitioners has fallen. The Plan whilst piously reciting the need for adequate medical facilities (Strategic Objective Policy 6), provides no reference to the need for enhanced primary care capability of coping for these increased units. I submit that should any consent for development sites in Oakham be thought appropriate, then such consents should be subject to conditions precedent as to rights of occupancy being dependant on the provision of such additional primary care facilities. This can be achieved without or without the co-operation of the existing practice, by dynamic action the Council itself, funded through the general levy, reserves and by increased CIL. In the absence of any other methodology of promoting Policy 6, the imposition of such a planning condition would address this crucial problem, it is also probably the only avenue of approach that can reasonably be expected to consolidate the resolve by all relevant parties to the problem.

Given the objective likelihood of the enhanced numbers of residential units that will arise by virtue of points made above, will be well above those required by the relevant Government directive , and the problem of lack of related health facilities, I would submit that the need for further extensive development around the perimeters of Oakham (in particular) and Uppingham are both unnecessary and inappropriate.

Alternatively, if the above submission is considered inappropriate, then I would object to the Plan specifically:

(a) In general , on the grounds that :

(i) recommended development should strive to preserve the identity of these two towns as small market towns in their context as being in of the most agricultural county/district in the . The current proposals could be objectively held to be in breach of the policy statements at SD1 (particularly cl, “m”), SD.2 and S.D.3.

(iii) in the “Rutland Local Plan Review- Call for Sites” of February 2016, various other sites that were considered, which have failed to reach this stage, despite their comparative attractiveness given the assessed criteria in the Sustainability Appraisal and Technical annex

(ii) I would submit that the cumulative effect of the currently proposed sites in conjunction with their adjacent existing suburban development, will unnecessarily worsen what is left of the identity of the two towns, for both those persons approaching the same and for those living in the towns. In particular H1.2 site exemplifies this fact. The plan’s policy states at 10.9 that “ the Southern approach to Oakham, should reflect the existing character of the approach to the town.” This proposed site creates an incongruous and intrusive figure of development into the former surrounding countryside and is contrary to that policy.

(b) That the stated policies are inconsistent with the recommendation for the proposed site H1.2 (formerly referred to in the 2016 plan as OAK/05) ( being 4.13h for 73 proposed units). This objection is based on the factors of assessment identified in the methodology for site assessment and criteria to be adopted as outlined in the Rutland Local Plan Sustainability Appraisal and Technical Annexe. It is submitted that it would have been more helpful on all sites to have included commentaries based initially on “Constraints” and then “Opportunities”, then referring to the balancing of conflicts in the RAG ratings, then commentary on the intended outcome and the opportunity for mitigation.

On that criteria as is presently submitted, the allocation of H1.2 is not justified in its own right, nor following further consideration of two other proposed sites, specifically OAK/02 (beneficially owned by the same commercial developer as the adjacent “Spinney Hill” development)and site OAK/08a. In particular it is submitted that in respect of H1.2 insufficient weight has been given to:

(i) Agricultural Land classification:

- The Policy at cl.7.61, states that the benefit of best and most versatile agricultural land is important and where significant development is considered then areas of poorer quality land in preference to higher quality, should be looked to. Much of the land surrounding the town is Grades 1 & 2, including H1.2. There is no clarification why this site amongst others of the same grade can be justified in terms of agricultural practice. It is heresay that the site owner, who has always held out that land as being grade 1 agricultural land, for all other past purposes has now arranged for the quality of the land to be re-assessed and re-classified to a lesser grade, which has enabled the land now to be credited with a RAG rating of 26. Should this be the case, then is it Council practice to accept such a recent report without further objective scrutiny.

- it is noted that OAK/08a is Grade 3 and should therefore be preferred to H1.2. Further OAK/02 is now the same as H1.2

(ii) Landscaping sensitivity:

- The Landscape characterisation as stated appears to be based on old studies. The classification of H1.2 is recorded as overlapping with medium landscaped sensitivity does not bear comparison with adjacent sites rated as overlapping with high landscape sensitivity. Again, no recognition has been given to the appeal decision in 2010/0954 in which clear assessment of the benefits of the landscape character of the Southern boundary of Oakham was outlined. - In comparison to H1.2, OAK/02 would not exhibit any further significant intrusion - OAK/02 is 7.17ha, which is substantially more than H1.2 (4.13ha) development of the same could readily incorporate and provide protection for the existing mature specimen trees and woodlands, which are identified in the RAG rating for BAP priority habit. Whilst OAK/02 falls within Oakham Conservation Area and OAK/08A adjoins that Conservation Area, there is however no published Conservation Area Appraisal. Accordingly, there is no method of assessing the special items of interest of that Conservation Site in respect of OAK/02 and OAK/08A. Both are otherwise open agricultural land. Should the designation of the Conservation Area be precautionary in the event of an application for future development, then this needs to specify what is protected. There is no evidence in justification of this - There is no evidence in the Plan to suggest there are overriding access or utilities constraints with either OAK/02 or OAK/O8a - It is therefore submitted that it should be concluded that OAK/02 and OAK/08a are capable of development whilst not prejudicing constraints that have been identified in the Sustainability Appraisal and Technical Index RAG ratings. Indeed, it would appear that they should be positively preferred to H1.2. Given the size of their areas it could be that neither site needs to be allocated to its full extent.

Should the above submissions not be considered appropriate, then In respect of site H1.2 -- the Plan should be modified for the reason:

1. The Site Specific Policy, at cl.10 of the Plan advises at (a) that in respect of this site, that any planning should “respond sensitively to the development on the Northern boundary, ensuring that the outlook from the existing development is preserved”. The only way that can effectively be achieved, as the two co-extensive pieces of land are effectively flat, is by the provision of a buffer zone of at least 30 metres, which could and should incorporate appropriate landscaping provisions, from the boundary of that existing development, to the boundary of any unit erected on H1.2 This would also facilitate the preservation of the existing established and substantial field hedge and the mature trees within the same, which presently is a marked exemplary feature for anybody approaching Oakham from the South feature. 2. to undertake such modifications to the Plan to incorporate such modifications as proposed above, both as to Chapters 4 & 5 as to site allocations. Eventually resolved site specific policies should be prepared and included in Chapter 10. Boundaries of the finally settled allocations be incorporated in the Policies map (inset 38). The planned limit of development to be amended to incorporate such eventually resolved sites

Paul Browne 02.11. 2020

Presubmission Consultation

Reference # 11707057

Status Complete

Title Ms

First Name Rachel

Last Name Burkitt

Are you? Responding as an individual

Please tick which part of the Pre-submission Chapter 3. The Vision and Strategic Local Plan that this representation relates to Objectives here:

Please select which paragraph, vision or Strategic Objective 2: Deliver a new garden strategic objective in Chapter 3 that this community representation relates to:

Do you consider the Pre-submission Local No Plan to be legally compliant?

Please provide an explanation below: The question asked were too complicated and a simple yes or no answer on future growth in Rutland based on over 2,000 houses, quarry and employment development should have sufficed, The Pre-submission used leading question and were therefore not valid.

Do you consider the Pre-submission Local No Plan to be sound?

As you consider that the Pre-submission Local • Positively prepared Plan is not sound please select which test(s) • Effective of soundness this relates to: • Justified • Consistent with national policy Please provide an explanation for your answer As a former Rutland county councillor (I lost below: my seat at the last election) I am concerned that due process wasn't followed for the pre- submission for the local plan. Firstly, it took about a year before councillors were informed of an MOU between RCC and the MOD sighed by Rutland Council's CEO Helen Briggs. There was no consultation with county councillors or the Cabinet although I understand that the council leader at the time, Tony Mathias was aware of the situation and supported it. This seemed to set the tone of the whole submission and consultation that fostered a lack of trust in the general public and county councillors as to the transparency of any decision to build at St George's - almost as if the Council had made up its mind and everything that followed was merely a box ticking exercise.

Regarding community support and the consultation undertaken by RCC following the inclusion of RCC in the Local Plan. The Summary of Consultation Responses simply does not address the scale of local opposition and from my position as a county councillor RCC seemed to be deaf and blind to it, dismissing any genuine concerns as nimbyism with a fixed mindset that the plan would go ahead. I also reject RCC's statement that the vision for Rutland was developed by the Council together with partners and stakeholders'. There is no evidence of this . A peer review of RCC's approach in November 2019 found that a major weakness of the council is that they communicate but do not listen. Both issues are contrary to to NPPF Section 3 Pan-Making paragraphs 16-37

RCC has also also missed its target date of March 2020 to provide a major strategic priority to consult Rutlanders on a 50-year vision for the county.

Paragraph 127 of the NPPF requires any development sin Rutland to be sympathetic to the area. The scale of St George's is totally our of keeping for Rutland that is an area of outstanding beauty. The plan includes a new town that would cause congestion on the roads and destroy the uniqueness of the area. The claim by RCC's that people living on the site would take advantage of the employment opportunities there is fanciful It is more likely that people would commute in or out from Peterborough or from further afield. This is not a sustainable proposition and would lead to an increase in traffic and pollution and put pressure on nearby villages and towns including Uppingham which will see 14,000 houses built close to its borders with Corby putting massive pressure on the A6003 which RCC councillors have discussed widening to cope with the increase in traffic.

The policy is also not consistent with the NPPF Section 2. Achieving Sustainable Development paragraph 7-10, and flies in the face on the Government's climate change targets. The town will become a commuter belt for Peterborough and further afield and will inevitably lead to more road widening, destroying verges and wildlife. The cost of providing viable public transport to enable people to go to work is unsustainable. It is to isolated for people to cycle and will lead to a total dependency on cars which will help to frustrate the Government's vision on reducing carbon emissions.

Rutland's stable community has evolved over many hundreds of years with a low crime rate and an appreciation of the rural and quiet nature of scattered villages, a willingness to forego a lack of amenities to preserve the unique beauty of the towns and villages. The rapid expansion of Oakahm with new housing developments demonstrates the downside of overdevelopment with pressure for fast food outlets and other amenities that threated the uniqueness of Rutland. A county of beautiful towns and village and wonderful countryside and wildlife that is now under threat and could be lost forever.

Please set out the modification(s) you consider The questions laid out were too complicated necessary to make the Pre-submission Local for lay people to understand. they should have Plan legally compliant and/ or sound, including been provided with two simple alternatives. any revised wording: The questions were loaded and as such not legal. RCC should be directed to revert to the Spatial Strategy approved in the July 2017 Local Plan Review Consultation.

If your representation is seeking a No, I do not wish to participate at the oral modification, do you consider it necessary to examination participate at the oral part of the examination?

Last Update 2020-11-05 20:14:46

Start Time 2020-11-05 19:49:57

Finish Time 2020-11-05 20:14:46 Presubmission Consultation

Reference # 11696349

Status Complete

Title Mrs

First Name Catherine

Last Name Gwilliam

Organisation Select

Are you? Responding as an individual

Please tick which part of the Pre-submission Chapter 7. Sustaining our Environment Local Plan that this representation relates to here:

Please select which paragraph or policy in Policy EN11 - Protecting Agricultural Land Chapter 7 that this representation relates to:

Do you consider the Pre-submission Local No Plan to be legally compliant? Please provide an explanation below: Chapter 7, Policy EN11 Protecting agricultural land. EN11 Planning permission for development which would lead to the loss of Grade 1, 2 and 3a agricultural land will only be permitted where: b) It has been clearly demonstrated that there are no other more suitable and sustainably located sites available and that the needs for development are sufficient to override the need to protect Best and Most Versatile agricultural land.

It has NOT been clearly demonstrated that there are no other sites in the area that are more sustainable.

The needs for development are NOT sufficient to override the need to protect Best and Most Versatile agricultural land.

It is NOT in line with national policy regarding biodiversity

Do you consider the Pre-submission Local No Plan to be sound?

As you consider that the Pre-submission Local • Positively prepared Plan is not sound please select which test(s) • Effective of soundness this relates to: • Justified • Consistent with national policy Please provide an explanation for your answer Policy EN11: Protecting agricultural land below: Planning permission for development which would lead to the loss of Grade 1, 2 and 3a agricultural land will only be permitted where: a) The land is allocated for development in the Local Plan; or b) It has been clearly demonstrated that there are no other more suitable and sustainably located sites available and that the needs for development are sufficient to override the need to protect Best and Most Versatile agricultural land.

Also relevant to the protection of agricultural land is Policy No. H1: Development sites that are clearly more sustainable and suitable have been ignored or housing numbers granted to other authorities. For example Woolfox and Quarry farm. Windfall sites have also be woefully underestimated. In 2017 RCC own study predicted 34 houses per annum could be generated by windfall sites yet now that figure has dropped to only 20 houses per year. To date the actual number of houses generated by windfall sites have been approx 50 per year.

The need to develop "Best and Most Versatile agricultural land" and not just protect what we already have, HAS NOT BEEN CONSIDERED. For example the need to provide versatile and affordable small scale starter farming opportunities to enable young people wishing to start farming businesses has not been considered. Please see modification suggestions for more detail in a positive way forward.

As this is a predominantly farming community there has been no effort to positively prepare any proposals for the encouragement and development of farming traditions within the community. Please set out the modification(s) you consider I would like to see the creation of small scale necessary to make the Pre-submission Local farming starter small holding units. Plan legally compliant and/ or sound, including any revised wording: This is a predominantly rural farming area however land is often inherited, making it impossible for young people (many of whom have been born and raised into our farming community), to start up there own farming businesses. This can result in young people and families having no choice but to leave the area altogether. This is a national problem, not just a local one.

I think the availability of a space like the airfield at St Georges Barracks would be perfect to develop a Utilised agricultural area (UAA) – land used for agriculture purposes, including arable land, permanent grassland and crops, as well as kitchen gardens. This would give young farmers/families the opportunity to start up their own farming businesses where aspirations, skills and experience can be grown, as well as produce. These units can then be used as a springboard for people to go on to further there businesses in other parts of the community.

Small holdings on this scale are also idea places to further the development of alternative farming methods that promote the sustainable management of land to promote wildlife habitat and community wellbeing.

They also contain opportunity to develop facilities for the promotion of rural skills such as hedge laying, Pottery, Farriery/ironmongery, basket making, spinning and weaving. Some of these are on the Heritage Arts Association Endangered and Critically endangered crafts lists.

Last but by no means least these developments can also enrich communities by enhancing well being in providing various outdoor and wildlife based community projects.

If your representation is seeking a No, I do not wish to participate at the oral modification, do you consider it necessary to examination participate at the oral part of the examination?

Last Update 2020-11-05 13:46:59

Start Time 2020-11-05 13:46:02

Finish Time 2020-11-05 13:46:59 Presubmission Consultation

Reference # 11698517

Status Complete

Title Mr

First Name Paul

Last Name Gwilliam

Organisation Select

Are you? Responding as an individual

Please tick which part of the Pre-submission Chapter 8. Sustainable Communities Local Plan that this representation relates to here:

Please select which paragraph or policy in Paragraph 8.5 Chapter 8 that this representation relates to:

Do you consider the Pre-submission Local Yes Plan to be legally compliant?

Do you consider the Pre-submission Local No Plan to be sound?

As you consider that the Pre-submission Local • Positively prepared Plan is not sound please select which test(s) • Effective of soundness this relates to: • Justified Please provide an explanation for your answer Para.8.7 says the aim to reduce the use of below: cars throughout the plan time frame. It highlights the importance of ensuring new development is located in the most accessible places. It also explains in paragraphs 8.12 and 8.13, the importance of supporting public transport, of working with Network Rail, the Department of Transport to improve passenger and rail provision. This this is in accordance with Policy SC2.

I can also see very little commitment to improving current transport infrastructure. For example, in some places the current road capacity is already stretched, and I can see no effort has gone into improving the local road networks to take any extra capacity generated by placing housing and employment away from main roads or existing housing, business and employment areas. A case in hand would be the Transport Assessment that forms part of the Master Plan for the St Georges Barracks proposal. Some effort has been made to suggest improvements to some junctions, but no effort has been made to assess the likely use of small single-track lanes such as Normanton Lane, Empingham Road or Ketton Road in the vicinity of the developments main eastern site access onto Wytchley Warren Lane or plans to mitigate their use as short cuts (rat runs) to avoid difficult junctions at Normanton Park Road/Wytchley Warren Lane and the junction of Normanton Park Road/Ketton Road/Bunkers Hill (an already dangerous crossroads). Traffic counts used in the Transport Assessment were also undertaken in October 2017 which, in my mind is out of date and did not take into account the increased amount of seasonal holiday traffic generated by the Rutland Water tourist attraction.

There are missed opportunities and the plan could and should go further much further. The soundness of the Plan has to be challenged because the ability to deliver sustainable transport is made completely unrealistic by locating such a large amount of Rutland’s new development, over 2000, in places that are not sustainable and make it almost impossible to achieve the goals set out in the policy.

I can see no commitment to integrating various forms of public transport. For example, the bus services that link the villages to Oakham do not go near to the railway station, clearly an important opportunity missed.

Please set out the modification(s) you consider The inconsistencies caused by putting much of necessary to make the Pre-submission Local Rutland’s future development in places that Plan legally compliant and/ or sound, including challenge the the development of more any revised wording: sustainable transport must be addressed.

Plans to mitigate the use of dangerous, narrow lanes with few passing places other than residents driveways must be included. The development of a link road from the south of the St Georges Barracks site to the A47 diverting traffic from the villages of Manton, Edith Weston, North Luffenham, South Luffenham, Empingham, and Ketton already stretched beyond sensible capacity and mitigating the use of narrow county lanes.

Plans for a more integrated and efficient public transport system must be set out.

If your representation is seeking a No, I do not wish to participate at the oral modification, do you consider it necessary to examination participate at the oral part of the examination?

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