Support

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 noted. Policy CC12 considers land-based carbon sequestration. The importance of embodied carbon in buildings in reducing greenhouse gas emissions is covered by Policy CC5 and the recycling of materials is covered by CC1.

Support

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.

Support noted.

Object

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.

Comments noted. Disagree. The Local Plan must provide for appropriate levels of growth within the county through site allocations and, whilst the Local Plan seeks to ensure the effective use of land through development of previously developed land over greenfield (a carbon sink), it must take a proportionate approach (ie a weight based assessment) to gains/losses of a carbon sequestration process.

Support

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.

Support noted. Policy CC12 considers land-based carbon sequestration. The importance of embodied carbon in buildings in reducing greenhouse gas emissions is covered by Policy CC5 and the recycling of materials is covered by CC1.

Object

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 noted. Nature-based solutions towards carbon sequestration which are controlled through the planning process would also usually be covered by Policies EN1, EN2 and EN3 (biodiversity net gain/local nature recovery strategy) which seek to deliver local net gains for biodiversity. The policy is supported by both Natural England and the Leicestershire and Rutland Wildlife Trust.

Support

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.

Support welcomed.

Object

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.

Comments noted. 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: 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?

Comments noted. Policy CC12 gives material weight where there is significant gain in nature-based carbon sequestration and weight against where there is harm. This is a proportionate approach. 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: 7891

Received: 08/01/2024

Respondent: Ryhall Parish Council

Reference Quarry Farm which is in direct contravention of this policy.

Support noted. Quarry Farm is an allocated site but Policy CC12 would still be applied to the development proposed.