Regulation 18 Draft Local Plan

Object

Representation ID: 2352

Received: 25/04/2024

Respondent: Rosconn Strategic Land

Agent: Marrons

We object to the description of the role and function of Stamford within the Vision. The Vision states that housing provision at the town will focus on addressing “local housing need.” Stamford is a sustainable market town with a range of services and facilities. It is second only to Grantham in sustainability terms. Restricting the role and function of Stamford to only accommodating “local housing needs” is not commensurate with its position in the settlement hierarchy and this element of the Vision should be reconsidered.

Object

Representation ID: 2353

Received: 25/04/2024

Respondent: Rosconn Strategic Land

Agent: Marrons

In relation to Plan Objective 4, we broadly support this however, we question whether a plan period to 2041, which only extends the current plan period by five years, would provide for a sufficiently long-term basis for planning in the area.

Plan Objective 6, we would question whether it is appropriate for the Plan Objectives to “ensure” that Grantham is supported as the main focus for new housing. This appears to pre-judge the LPR’s spatial strategy. Under the proposed apportionment of housing within the LPR, Grantham will host 49% of growth to 2041 meaning that, other areas will still have a significant role to play in meeting housing need. We recommend that the role and function of other parts of the Plan Area in the spatial strategy are elaborated upon.

Plan Objective 9 – This objection plays down a key element of national planning policy which is to “boost significantly” the supply of housing, not merely achieving an adequate supply. The provision of housing goes beyond offering a choice in the market but rather defining and addressing needs in a manner that addresses the challenges experienced by the Plan Area and delivers the Plan’s ambition.

Object

Representation ID: 2354

Received: 25/04/2024

Respondent: Rosconn Strategic Land

Agent: Marrons

Policy SP1’s housing requirement is flawed, using the minimum Standard Method figure with little substantive consideration as to whether this should be uplifted to account for the factors set out in the NPPF and the PPG. Has the local housing need figure been calculated from the correct base, with the LPR commencing in April 2020 and Policy SP1’s housing requirement has been informed by a fresh calculation in 2023. We recommend that the housing requirement and the duration of the plan period is revisited due to insufficient scope.

We consider the strategic distribution of housing growth proposed to be heavily-weighted in favour of Grantham and this risks stalled delivery and unbalanced growth. The comparatively limited role of Stamford in the spatial strategy as the district’s second largest settlement is difficult to understand.

The Interim Sustainability Report which accompanies this round of consultation has not specifically tested growth or distribution scenarios.

The plan preparation process has missed a step and selected a set of sites to fit a pre-determined spatial strategy rather than considering a range of growth scenarios on a consistent basis to select an appropriate strategy.

Object

Representation ID: 2355

Received: 25/04/2024

Respondent: Rosconn Strategic Land

Agent: Marrons

In general terms, we support the identification of Stamford as a “Market Town” or a second-tier settlement, where it is grouped with the Deepings and Bourne.

However, Policy SP2 does not follow the updated settlement hierarchy for the LPR presented in the Settlement Hierarchy Review Paper (February 2024), which identifies a single tier of market towns comprising Grantham, Stamford, Bourne and The Deepings.

Based upon the wording of Policy SP2 Grantham’s designation as the Sub-Regional Centre and its identification at the top of the settlement hierarchy in Policy SP2 is more related to the general ambition to apportion the majority of growth to this location rather than a reflection of its sustainability credentials relative to other market towns, such as Stamford.

In our view, the settlement hierarchy should be established separately from the strategy for apportioning growth through the District and we support the Settlement Hierarchy Review’s proposal to include Stamford in the same tier of Grantham, given the relative availability of services, facilities and infrastructure within each settlement. Policy SP2 should be updated accordingly.

Object

Representation ID: 2356

Received: 25/04/2024

Respondent: Rosconn Strategic Land

Agent: Marrons

Policy H1 does not propose to allocate RSL’s land interest at Land to the South of Old Great North Road, Stamford. 5.2 Given that the Site is available, deliverable and viable for residential development which can be delivered with no adverse impact arising, we object to the decision not to allocate the Site, as this decision is not justified by the evidence.

Site Assessment SKPR- 66 - As with the Draft Site Assessments, the site-specific assessments within the SA have been undertaken on a straightforward “distance to constraint” basis. This methodology has given a relatively skewed picture of what are, in respect of the SA objectives and constraints more generally, high performing sites such as Site SPKR-66. There are no particular technical matters discussed within the detailed SA appraisal of the Site that have not already been raised above. However, the RAG scoring between the SA assessment of the Site and the Draft Site Assessments is inconsistent, particularly as regards distance to facilities.. The analysis presented in the Draft Site Assessments as regards distances to key services and facilities is more robust and the SA’s assessment should be revised accordingly.