Object

Representation ID: 4947

Received: 31/12/2023

Respondent: Mr Neal Ince

Clause a) should be removed. How can you protect carbon sinks and the wider environment if allocating a site for development is a reason/excuse to ignore them.
This should also mandate the use of brownfield sites before greenfield sites.

Comments noted. The Local Plan must provide for appropriate levels of growth within the county through site allocations and so criteria a) must be included in the policy. The site appraisal process, however, included appraisal against the Sustainability Objectives from the Sustainability Appraisal and each site is considered against a set of criteria which cover environmental, social and economic factors. Environmental factors include whether the site is greenfield or whether it would lead to the loss of green infrastructure, both important carbon sinks. Encouraging the effective use of land by reusing land that has been previously developed (brownfield land) provided that it is not of high quality for biodiversity or environmental value is a key principle identified within the NPPF and this principle underpins the approach taken throughout the Local Plan, including the allocation of sites.

Support

Representation ID: 4959

Received: 31/12/2023

Respondent: Mrs Jayne Williams

Grazing land is already a valuable carbon sink. Recent research has shown that solar farms reduce the amount of carbon sequestration in the soil due to the shading of the panels. This is why panels should go on roofs, over car parks and on walls, like the system installed at the M&S distribution centre at Castle Donnington.
We should not consider covering agricultural land with solar panels until all other possibilities have been utilised.

Support noted. Whilst the amount of carbon sequestration may be reduced by the solar panels causing shade on agricultural land, this would be outweighed by the benefits of the amount of renewable energy generation by the panels. Solar pv offers the potential for the greatest generation of renewable energy in Rutland and is a key part of the government’s strategy for low-cost decarbonisation of the energy sector.
The Rutland Renewable Energy Study has calculated the amount of potential energy that could be generated by solar pv on carports to be 2.1 MWp (Megawatt peak). This is a fraction compared to the potential from ground-mounted solar panels of 649 MWp. The Local Plan already seeks to maximise the amount of renewable energy generated by supporting the installation of solar panels on buildings (new build and existing) through Policies CC2, CC7 and CC8.

Support

Representation ID: 5074

Received: 02/01/2024

Respondent: Mary Cade

a) should be removed as no carbon sink should be an allocated site.
Are there any peat soils in Rutland?
Should there be a semi colon between 'scrub' and 'open habitat' ? all the areas quoted from 'open habitat' are also carbon sinks since they are where photosynthesis occurs.
What should be included in the evaluation, recording and interpretation?

Support noted. The Local Plan must provide for appropriate levels of growth within the county through site allocations. Criteria a) must be included in the policy because, whilst the Local Plan seeks to ensure the effective use of land through development of previously developed land over greenfield, there are still some greenfield allocated sites.
Agree due to there being no peat soils in Rutland delete references to peat in 2nd para on page 48 and delete ‘peat soils or other’. Also delete ‘and’ (twice) in second sentence of Policy CC11. Delete ‘peat soils or other form of’ in last para of CC11.
Details on the requirements for evaluating, recording and interpreting the carbon sink would be set out in a future SPD.

Support

Representation ID: 5094

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.

Support noted.

Object

Representation ID: 5152

Received: 03/01/2024

Respondent: Mr Frank Brett

Surely any development that harms carbon sinks needs to replace those sinks elsewhere. Not just ‘weight’ or a presumption in favour / against.

Comments noted. Disagree. Policy CC11 is positively worded, seeking to minimise the loss of carbon sinks and Policy CC12 gives weight in favour of proposals that would result in gain in nature-based sequestration. Local Plan Policy EN3 on Biodiversity Net Gain would also require nature-based solutions for loss of carbon sinks for certain developments.

Object

Representation ID: 5414

Received: 04/01/2024

Respondent: North Luffenham Parish Council

Does the preservation of farmland as a "Carbon Sink" overule Renewables development ?

Comment noted. The Local Plan recognises the importance of renewable energy generation in tackling the Climate Crisis and policies are supportive of such renewable schemes in accordance with national guidance. This means that the inclusion of farmland in Policy CC11 as a carbon sink would not prevent renewable energy development but, in accordance with the policy, developers would need to demonstrate that harm to the carbon sink as been reduced to the minimum possible, and that there was not a less harmful viable option for the development of that site. Other policies such as EN3 on Biodiversity Net Gain would also apply to such proposals.

Support

Representation ID: 5475

Received: 05/01/2024

Respondent: Ms Janet Taylor

Support as long as it recognised that grazing land is an important carbon sink, and should never be covered with PV panels.

Support noted. Policy CC8 (with suggested changes) sets out a sequential approach to the siting of solar developments by encouraging the development of previously developed land before greenfield land. If solar pv developments were restricted only to non-agricultural land this would limit such development (after taking into account all of the other constraints that may apply to such land) and would be a barrier to the Local Plan making a legally required meaningful contribution towards addressing the climate change crisis. Whilst the amount of carbon sequestration may be reduced by the solar panels causing shade on agricultural land, this would be outweighed by the benefits of the amount of renewable energy generation by the panels. Solar pv offers the potential for the greatest generation of renewable energy in Rutland and is a key part of the government’s strategy for low-cost decarbonisation of the energy sector.

Support

Representation ID: 5796

Received: 06/01/2024

Respondent: Mrs Sue Scarrott

I am very much in support of the principles but think that insufficient care will be taken about sites for development . Sadly, commercial interests will win e.g in Uppingham, a wonderful natural woodland habitat on Seaton Rd has been earmarked as a gypsy and traveller site.
RCC should insist on more brownfield sites being used.

Comments noted. The Local Plan must provide for appropriate levels of growth within the county through site allocations and so criteria a) is included in the policy. This includes the allocation of gypsy, traveller and travelling showpeople sites. The allocation of sites depends upon not only environmental factors but also on social and economic factors. Encouraging the effective use of land by reusing land that has been previously developed (brownfield land) provided that it is not of high quality for biodiversity or environmental value is a key principle identified within the NPPF and this principle underpins the approach taken throughout the Local Plan.

Support

Representation ID: 5847

Received: 06/01/2024

Respondent: RCC Expert Panel on Carbon Reduction

Add sentence “There should be a presumption in favour of preserving carbon sinks in situ, especially for wetlands and woodland habitats. On land wetlands store the largest amount of carbon per unit area, followed by woodlands.”

There are very few, if any, peat soils in Rutland - only in garden centres! Replace with “Grassland, scrub, arable land and especially wetlands and woodlands, sequester and store carbon. Development on these habitats is a major source of global greenhouse gas emissions.”

Add examples of methodologies for evaluation such as life cycle assessment or material flow analysis.

Support noted. Agree but more appropriate in accompanying text. Add in extra sentence in first para after sentence ending in …’under water.’ ‘On land wetlands store the largest amount of carbon per unit areas, followed by wetlands.’
Add in to 2nd para after 2nd sentence: ‘Grassland, scrub, arable land and especially wetlands and woodlands, sequester and store carbon. Development on these habitats is a major source of global greenhouse gas emissions.’
Further details of methodologies for evaluation of the carbon sink would be included in a future SPD.

Support

Representation ID: 5949

Received: 07/01/2024

Respondent: Jane Ellis

Grassland is a natural carbon sink and greenfield site development for housing and use of agricultural land for solar farms should be discouraged. Brownfield sites are available for both uses

There are no peat soils in Rutland and this reference should be removed, as it appears to be consultant "cut and paste"

Comment noted. Policy CC8 (with suggested changes) sets out a sequential approach to the siting of solar developments by encouraging the development of previously developed land before greenfield land. If solar pv developments were restricted only to brownfield land this would limit such development (after taking into account all of the other constraints that may apply to such land) and would be a barrier to the Local Plan making a legally required meaningful contribution towards addressing the climate change crisis. Encouraging the effective use of land by reusing land that has been previously developed (brownfield land) provided that it is not of high quality for biodiversity or environmental value is a key principle identified within the NPPF and this principle underpins the approach taken throughout the Local Plan, including housing site allocations.
Agree due to there being no peat soils in Rutland.

Support

Representation ID: 6101

Received: 07/01/2024

Respondent: Mr David Lewis

I support the overall policy aim, but condition (a) should be deleted. A site should not be allocated for development if it is a carbon sink (unless condition (b) is fulfilled).

Comments noted. The Local Plan must provide for appropriate levels of growth within the county through site allocations and so criteria a) must be included in the policy. The site appraisal process, however, included appraisal against the Sustainability Objectives from the Sustainability Appraisal and each site is considered against a set of criteria which cover environmental, social and economic factors. Environmental factors include whether the site is greenfield or whether it would lead to the loss of green infrastructure, both important carbon sinks. Encouraging the effective use of land by reusing land that has been previously developed (brownfield land) provided that it is not of high quality for biodiversity or environmental value is a key principle identified within the NPPF and this principle underpins the approach taken throughout the Local Plan, including the allocation of sites.

Support

Representation ID: 6299

Received: 08/01/2024

Respondent: Mr Chris Read

Agree absolutely.

Support noted.

Object

Representation ID: 6480

Received: 08/01/2024

Respondent: Mr Roderick Morgan

This is far too weak and will allow carbon sinks to be destroyed as part of development, with some minimal efforts at off-setting damage. Carbon sinks should be fully valued and sacrosanct when considering development. It's not clear how a site can be identified as suitable for development if it contains an effective carbon sink or other natural asset.

Comments noted. Disagree. The Local Plan must provide for appropriate levels of growth within the county through site allocations and these do include greenfield sites. The site appraisal process, however, included appraisal against the Sustainability Objectives from the Sustainability Appraisal and each site is considered against a set of criteria which cover environmental, social and economic factors. Environmental factors include whether the site is greenfield or whether it would lead to the loss of green infrastructure, both important carbon sinks. Encouraging the effective use of land by reusing land that has been previously developed (brownfield land) provided that it is not of high quality for biodiversity or environmental value is a key principle identified within the NPPF and this principle underpins the approach taken throughout the Local Plan, including the allocation of sites.

Support

Representation ID: 6853

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.

Support noted.

Object

Representation ID: 7175

Received: 08/01/2024

Respondent: Persimmon Homes East Midlands

Persimmon Homes support the protection of Carbon Sinks. It was unclear from this policy and the evidence base which underpins how much of the land within the County (and its location), is classified as a ‘carbon sink’. It would be expected that a plan identifying the location of existing carbon sinks be incorporated within this Plan.

It was also unclear what the impacts of this policy would have on the viability of schemes as this has not been referred to or considered in the ‘Whole Plan Viability Report’ undertaken by HDH Planning and development Limited.

Comments noted. Disagree that a plan is required as the policy describes the type of habitats that act as carbon sinks. The document ‘Carbon Storage and Sequestration by Habitat 2021 (NERR094) (Natural England)’ gives further information, identifying 'reliable', 'long term' and 'important' carbon sinks. Reference to be made to this document in the text accompanying Policy CC11.
It is likely that further work to update the cost evidence for a number of options for the wording of the Climate Change policies will be undertaken to inform the next stage of the local plan. This will build on the Whole Plan Viability Assessment (2023). Any changes to the draft policies arising from consultation responses and/or new evidence on climate change will be consulted on through the Reg 19 consultation.

Object

Representation ID: 7696

Received: 08/01/2024

Respondent: Vistry Group c/o Pegasus Group

Agent: Pegasus group

We strongly object to this policy as drafted. This policy needs to be reconsidered, it is too onerous and will impact on almost all major developments. There is no mention of the need to consider the scale of loss as there is in the Carbon Sequestration draft policy.
As currently drafted the loss of a single hedge, tree or shrub and all developments on agricultural land will be caught by this policy. In this context, the presumption in favour of preservation of carbon sinks in-situ is in direct conflict with the presumption in favour of sustainable development.

Comments noted. Disagree. Policy wording similar to that in the adopted Central Lincs Local Plan (2023). The policy includes the requirement for a ‘proportionate’ evaluation and ‘appropriate’ management plan of the loss so it does incorporate flexibility in terms of scale of loss. The policy recognises that the natural environment plays a vital role in tackling the climate crisis as healthy ecosystems take up and store a significant amount of carbon in soils, sediments and vegetation. Alongside many other negative impacts, the destruction and degradation of natural habitats has resulted in the direct loss of carbon stored within them. National guidance (para 157 NPPF) stresses the importance of the planning system helping to shape places in ways that contribute to radical reductions in greenhouse gas emissions.
It is likely that further work to update the cost evidence for a number of options for the wording of the Climate Change policies will be undertaken to inform the next stage of the local plan. This will build on the Whole Plan Viability Assessment (2023). Any changes to the draft policies arising from consultation responses and/or new evidence on climate change will be consulted on through the Reg 19 consultation.

Support

Representation ID: 7735

Received: 08/01/2024

Respondent: Anglian Water

Anglian Water supports policies CC11 Carbon Sinks including no dig construction methods, CC12 Carbon Sequestration including nature-based solutions for water quality.

Support noted.

Object

Representation ID: 7826

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?

Comments noted. Policy CC11 requires a proportionate evaluation of the impact of the development on the carbon sink and seeks to reduce harm of carbon sink loss to a minimum, supporting proposals that strengthen carbon sinks. It would not be appropriate or proportional to always require a carbon sink net gain and this would also need to be part of the viability assessment of the policy (which may form part of the updated viability assessment to inform the Reg 19 Plan.)

Object

Representation ID: 7888

Received: 08/01/2024

Respondent: Ryhall Parish Council

The land at Quarry Farm is a Natural Carbon Sink in direct contravention of this policy

Support noted. Quarry Farm is an allocated site so meets exception criteria a) of Policy CC11.