Policy CC12 - Carbon Sequestration
Support
Regulation 18 draft Local Plan
Representation ID: 5075
Received: 02/01/2024
Respondent: Mary Cade
Buildings can be carbon sinks if they use locally sourced stone, timber, lime mortar, crop residues and sheep wool.
Support
Regulation 18 draft Local Plan
Representation ID: 5095
Received: 03/01/2024
Respondent: Natural England
Natural England welcomes this policy which will ensure that a nature-based solution is sought within a development proposal. We are also pleased to note that the policies reference net gain and the provision of wider benefits for biodiversity and health and wellbeing.
Object
Regulation 18 draft Local Plan
Representation ID: 5153
Received: 03/01/2024
Respondent: Mr Frank Brett
Surely any development that harms carbon sequestration must not be permitted. Not just ‘weight’ or a presumption in favour / against.
Support
Regulation 18 draft Local Plan
Representation ID: 5849
Received: 06/01/2024
Respondent: RCC Expert Panel on Carbon Reduction
It should also be recognised here that buildings can be carbon sinks in their bio-based construction materials such as wood and agricultural crop residues. Carbon can also be stored in materials such as lime mortar.
Object
Regulation 18 draft Local Plan
Representation ID: 6300
Received: 08/01/2024
Respondent: Mr Chris Read
I support the principle - but not the open-nature of the objective. I think that words such as "local", "parish" and "Rutland" should be included in the statement. I don't think someone planting a tree in Borneo is sufficient recompense for a tree killed in Rutland. That's not selfish, it's just sensible, accountable and fits with other objectives such as biodiversity.
Support
Regulation 18 draft Local Plan
Representation ID: 6854
Received: 08/01/2024
Respondent: Leicestershire & Rutland Wildlife Trust
Polices welcomed and offer a level of protection for existing valuable carbon sinks, along with supporting nature-based solutions within new development proposals.
Object
Regulation 18 draft Local Plan
Representation ID: 7774
Received: 08/01/2024
Respondent: McCarthy Stone
Agent: The Planning Bureau Limited
Policy CC12 requires ‘The demonstration of meaningful carbon sequestration through nature-based solutions within a proposal will be a material consideration in the decision making process. Material weight in favour of a proposal will be given where the net outcome is demonstrated to be a significant gain in nature-based carbon sequestration as a consequence of the proposal. Where a proposal will cause harm to an existing nature-based carbon sequestration process, weight against such a proposal will be given as a consequence of the harm, with the degree of weight dependent on the scale of net loss.’
Again, we would like to remind the Council of the increased emphasis on Local Plan viability testing in Paragraph 58 of the NPPF and that the PPG states that “The role for viability assessment is primarily at the plan making stage. Viability assessment should not compromise sustainable development but should be used to ensure that policies are realistic, and that the total cumulative cost of all relevant policies will not undermine deliverability of the plan” (Paragraph: 002 Reference ID: 10-002-20190509). The policy requirement must not be so inflexible that it deems sites unviable, and any future policy needs to ensure this to make sure it is consistent with NPPF/PPG and can be justified by the Council. We note that the Rutland County Council Whole Plan Viability Assessment, August 2023, HDH (Viability Assessment) does not include a cost for carbon sequestration and indeed confirms at para 8.6 that ‘As well as the above, the Council has indicated that it is considering policies that cover matters such as protecting renewable energy infrastructure, the wider energy and service infrastructure, carbon sinks and sequestration and sustainable travel.’ This is concerning as such a requirement will have a cost that should be accounted for within any Viability Assessment.
Recommendation:
Ensure the policy is properly assessed within the Viability Assessment and that the requirement is realistic.
Object
Regulation 18 draft Local Plan
Representation ID: 7827
Received: 07/01/2024
Respondent: CPRE Rutland
Is there a requirement for some form of Carbon Sink Net Gain approach? Otherwise, how can we actually know whether a development will result in adding or removing carbon?
Object
Regulation 18 draft Local Plan
Representation ID: 7891
Received: 08/01/2024
Respondent: Ryhall Parish Council
Reference Quarry Farm which is in direct contravention of this policy.