CPRE Rutland has examined the Local Plan and supporting documents, and has identified a number of shortcomings which may result in the plan being found unsound or even non-compliant at examination; these concerns are summarised below. For further details, please contact the Chair, Malcolm Touchin or the Vice-chair, Ron Simpson.
Residents may wish to use these comments in formulating their own responses to the plan, which must be submitted to Rutland County Council (RCC) by Friday 6th November 2020.
Vision – There is no useful statement of vision for Rutland, against which to judge the merits or otherwise of the plan. Looking to the future, life is certain to change in significant ways as a consequence of the current pandemic experience, in terms of the use of transport, in retail behaviour, through advances in technology and in changes in social care provision. All of these, and more, are likely to have a major impact and should be clearly considered.
Consultation Process – Significant differences between the previous local plan of 2017, consulted upon under Regulation 18, and the current plan mean that much of the current plan has not been subject to consultation at Regulation 18 and so opportunity for public comment on that detail or on the overall spatial strategy has been denied.
Overall Impression – that the whole plan and supporting documents have been developed to justify the St George’s development, rather than the evidence being objectively assessed and the best option to meet the needs determined.
Cross-border Co-operation – While the Duty to Cooperate statement maintains that discussions have been held with neighbouring authorities, the only clear evidence in the plan concerns the proposed development at Quarry Farm/Stamford North, supporting South Kesteven District Council. There are clear implications of developments in other areas, in particular around Leicester and Corby, with concomitant impact on transport requirements; evidence of the draw of retail opportunities, particularly towards Leicester, does not seem to have been taken into account. This may also contravene the NPPF (cf Para 26).
St George’s Barracks Proposals
- There is no apparent consideration of the financial viability of the proposals, in particular with regard to infrastructure.
- The possible impact of such a large housing development on the growth plans for Oakham and Uppingham is not covered, although the Sustainability Appraisal confirms that the option of concentrating growth at Oakham/Uppingham is the best option to maintain their vitality and viability.
- Concentration of most of the affordable housing provision at this one site will clearly prejudice the needs of other communities.
- There is a lack of a sustainability framework for the St George’s Barracks development, including targets, outcomes and monitoring framework.
- There are unresolved issues in the Landscape and Transport Assessments.
There has been no evident consultation on alternative uses for the site.
- Like for like comparison of housing distribution options is not possible, especially regarding the impact on Oakham and Uppingham of development at St George’s, although the Sustainability Appraisal confirms that the option of concentrating growth in those towns is the best to maintain their vitality and viability.
Option assessments are regarded as deficient in many ways.
Reasons for site allocations are not clear, particularly as there seems to be an adequate supply of reserve sites (cf the Strategic Housing and Economic Land Availability Assessment (SHELAA)).
Sustainability Appraisal and Strategic Environmental Assessment – generally felt to be not fit for purpose and to be biased towards St George’s and Woolfox. They fail in many respects to meet relevant directives and regulations. There is no statement defining the baseline that would obtain without the plan update.
Policy Inconsistencies – Many of the policies in the plan seem inconsistent with one another, implying areas of unsoundness, for instance with regard to a number of unduly vague statements. In particular, the first policy, SD1 is too generic, and inconsistent with, amongst others:
- Transport – regarded as unworkable with respect to Tourism (E5) and Sustainable Building (EN4)
- Climate Change – Should address long-term changes – see policies E2, EN4, EN6 and EN8. Also needs to reflect more clearly RCC’s Corporate Plan.
- Land use – what is practical and possible for reuse – open to interpretation – see policies EN7 and EN11.
- Waste management – does not require the developer to include sustainable solutions – cf Policy H1.
- Resource Use and Natural Heritage – out of step with national policy regarding biodiversity
- Character – would allow a developer to ignore a neighbourhood plan – cf policies H1, EN1, EN2, EN3.