Object

Representation ID: 4555

Received: 27/11/2023

Respondent: The Woodland Trust

Rutland’s tree canopy cover is just nine per cent, which contrasts to around 13 per cent for the UK and an average of 38 per cent across the EU. Therefore, we believe that woodland creation should be a major priority for the LP.

Principally, it is key to select the right tree for the right place and, while we recognise the role non-native trees will play in meeting near-term targets, as well as the ability of some to confront specific concerns like air pollution on busy streets, they should be minimised both to prevent the introduction of pests and diseases through tree importation (viz. biosecurity risk) and to offer the greatest ability for already-existing flora and fauna to benefit.
The maximum possible proportion of new trees should be native, and UK and Ireland Sourced and Grown (UKISG). Not only are some pests hazardous to human health, but supporting local nurseries and tree growers confers an economic benefit.

The overall ambition should be for a canopy cover of 30 per cent in new developments.

Comments noted.

Regarding non native trees, trees have many benefits with many exotic (non-native) trees excelling in some. To limit the selection to just 33 native trees is more a detriment than a benefit however amend policy text to ensure non native are only used if appropriate.

Support

Representation ID: 4565

Received: 01/12/2023

Respondent: Mr Kevin Corby

Any development requiring excessive tree felling should not be considered, unless of significant importance.

Noted

Support

Representation ID: 4606

Received: 04/12/2023

Respondent: Mr Nigel Roberts

Agree

Support noted.

Support

Representation ID: 4623

Received: 04/12/2023

Respondent: Forestry Commision

We have reviewed the documents online and fully support its aims and ethos as an exemplar example regarding trees and woodland, especially the protection of ancient woodland and increasing tree cover in the county.

Support noted.

Support

Representation ID: 4747

Received: 12/12/2023

Respondent: Miss Serena Solanki

I support this but the Policy is in direct conflict with the planned housing developments- especially Quarry farm. It seems pointless to have these policies if they are going to be ignored for housing development plans. 8.7% of Quarry farm is woodland and the development would adversely impact this woodland

Support and comments noted. The Local Plan allocates Quarry Farm (as part of the Stamford North development) for housing and forms a fundamental part of the Spatial Strategy for the delivery of housing. The availability and deliverability of development sites is a key part of ensuring that housing needs are met through the Local Plan. The Local Plan must make provision to meet the county’s housing needs and all allocated housing sites in Policy H1 have been through a rigorous site appraisal process that cover environmental, social and economic factors. The Quarry Farm proposals will include mitigation to ensure biodiversity net gain secured through a habitat creation and management plan.

Support

Representation ID: 4872

Received: 22/12/2023

Respondent: Burley Parish Meeting

yes please plant more trees - We helped the guides plant lots of tree last year at Whissendine sports ground. But we should do more. But also we need to look after the trees we have - too often they are neglected and left covered with Ivy or damaged/diseased. RCC should plan with land owners to remove diseased trees more quickly and incentivise farmers, to care for some of the trees that are hundreds of years old.

Support noted.

Support

Representation ID: 5111

Received: 03/01/2024

Respondent: Natural England

Natural England welcomes this policy. The Plan may want to refer to the Urban Tree Canopy Cover Standard set out within the Green Infrastructure Framework

Support noted. The benefits of increase in tree canopy are referenced in the supporting text of Policy EN5.

Support

Representation ID: 5211

Received: 03/01/2024

Respondent: Mr Frank Brett

Supported in general. However, in the paragraph on 'Mitigating for loss of Trees and Woodland', I would suggest that submitted plans must detail the location where the new trees are to be planted to ensure this has been planned from the outset.

Support noted.

Object

Representation ID: 5434

Received: 04/01/2024

Respondent: North Luffenham Parish Council

"Planning permission will only be granted if the proposal provides evidence that it has been subject to adequate consideration of the impact of the development on any existing trees and woodland found on-site and on any trees off site which are visible from the site"
How is "Visible from the site" defined, many developments can see whole areas of woodland from their location

Comments noted. Text amended.

Support

Representation ID: 5455

Received: 04/01/2024

Respondent: Mary Cade

But the use of non-native trees, and 'street' varieties of trees that produce sterile flowers (no pollen) and no fruit should be minimised to prevent the introduction of pests and diseases through tree importation. Locally grown native trees are best for biodiversity and the more that are grown and planted the more that natural selection will result in adaptations for climate change. It will also benefit the local economy by supporting local growers.
Since Rutland is impoverished with respect to trees, new developments should aim for 30% tree cover. Traditional orchards need to be included for protection here too.

Support noted.

Regarding non native trees, trees have many benefits with many exotic (non-native) trees excelling in some. To limit the selection to just 33 native trees is more a detriment than a benefit however amend policy text to ensure non native are only used if required.

Targets regarding the amount of tree cover across the County would form part of the Local Nature Recovery Strategy, and once this is published, it would be used to inform the Local Plan. Agree regarding traditional orchards which are identified as priority habitats in the UK Biodiversity Action Plan.

Object

Representation ID: 5588

Received: 05/01/2024

Respondent: Francis Jackson Homes Ltd

The wording of this policy is not positively prepared. Surely the presumption is always planning permission will be granted unless there is a negative impact, not "will only be permitted if...."

Where does the evidence for the 3-for-1 replacement of trees come from? Surely these matters would be covered by the BNG calculations in the Metric anyway and are not really for policy to prescribe at this juncture?

The hedgerow requirements are very prescriptive and leave little/no scope for flexibility or practical alternatives to be considered or site specific circumstances to be taken account of.

Comments noted. Regarding replacement trees amend policy text to "In such cases the council will require new trees to replace the value of the trees that were removed. In most cases, this will be a higher number of new trees as trees significantly increase in value as their grow and mature. A value of the trees lost should be obtained by using appropriate formats, (e.g. CAVAT, Helliwell or iTree). Replacement trees should be of a similar species and capable of attaining a similar size to that which are being lost and will be required to be planted on-site."

Disagree that replacement trees should be left to the BNG calculations as s197 TCPA sets out a statutory duty for LPAs to ensure, where appropriate, for the planting of trees.
Disagree regarding hedgerows. This part of the policy states that development ‘will not be supported…unless’ and is similar in wording to other adopted Local Plan policies.

Support

Representation ID: 5630

Received: 05/01/2024

Respondent: Mrs laura alcock

I support, but strongly believe this policy is weak and not enough. Rutland should be seeking to work with land owners and encourage a much larger goal of tree planting. Exiting hedges should be protected, and the annual management and cutting of hedges should be controlled to reduce the damage currently being caused, which has a devastating effect on wildlife and biodiversity.

Support and comments noted. Working with landowners over tree planting (where not connected with development proposals or works that require consent on protected trees) falls outside the remit of the Local Plan. Likewise, the management of hedges (where not connected with development) falls outside the remit of the Local Plan.

Support

Representation ID: 5712

Received: 06/01/2024

Respondent: Braunston-in-Rutland Parish Council

Tree replacement should be strictly enforced, it takes many years for replacement trees to mature and gain the amenity value of the lost tree

Support noted. Criterion A) of Policy EN4 states: Planting schemes should:
a) include provision to replace any plant failures within five years post development .

Support

Representation ID: 5762

Received: 06/01/2024

Respondent: Ms Rachel Butler

Policy welcomed but improving tree cover also needs making clear, it is the right kind of tree. Growing any tree is not a magic bullet to mitigate the Climate Emergency.

Support noted. Amend Criteria e) of Policy EN4.

Support

Representation ID: 5856

Received: 06/01/2024

Respondent: Braunston-in-Rutland Parish Council

We should encourage all tree planting, many existing trees are in poor condition, we have lost many trees in the recent winds, sadly trees are not being encouraged in hedgerows as it makes hedge trimming with modern machinery more difficult, we need more trees to help with climate change and air quality and they have remarkable eco systems so vital to life .

Support noted. Local Plan Policies seek to protect and enhance biodiversity, including tree planting, but the remit of the Local Plan cannot extend to control the management of existing trees and hedges where these are not affected by development proposals, or where they are not subject to protection under the planning system.

Support

Representation ID: 5863

Received: 06/01/2024

Respondent: RCC Expert Panel on Carbon Reduction

It is important for biodiversity to emphasise the value of planting native trees.

Add a small section on traditional orchards. Natural England includes them as Priority Habitats unlike hedgerows. They have been mapped in Rutland by the Peoples Trust for Endangered Species and DEFRA, even though they are not included in the Biodiversity Action Plan Spaces for Wildlife 2016-2026.

For example, Ketton and Normanton parish have large traditional orchards. Many Local Plans include the protection of traditional orchards, especially as they often have veteran trees in abandoned orchards. These are very valuable for biodiversity.
See https://data.jncc.gov.uk/data/2829ce47-1ca5-41e7-bc1a-871c1cc0b3ae/UKBAP-BAPHabitats-56-TraditionalOrchards.pdf

Support noted.

Regarding non native trees, trees have many benefits with many exotic (non-native) trees excelling in some. To limit the selection to just 33 native trees is more a detriment than a benefit however amend policy text to ensure non native are only used if appropriate.

Agree regarding traditional orchards which are identified as priority habitats in the UK Biodiversity Action Plan.

Object

Representation ID: 5880

Received: 07/01/2024

Respondent: NGO East Mercia Rivers Trust

The policy is welcomed though point 'e' a little ambiguous & could be interpreted as both native and non-native tree species should be used in all new planting schemes. Clarity is needed to ensure in most instances planting of native trees is the priority, therefore planting of non-native should be limited (EMRT recognises that sometimes for climate adaptation non-native species are beneficial).

Comments noted.

Regarding non native trees, trees have many benefits with many exotic (non-native) trees excelling in some. To limit the selection to just 33 native trees is more a detriment than a benefit however amend policy text to ensure non native are only used if appropriate.

Support

Representation ID: 5922

Received: 07/01/2024

Respondent: Mr Rob Cooke

It is important that areas of mature scrub are included in the definition of tree cover; scrub can have considerable wildlife value and may for part of the natural succession to mature woodland which, in itself is likely to be more resilient than planted woodland.

Support noted. Agree.

Support

Representation ID: 5989

Received: 07/01/2024

Respondent: Jane Ellis

Polices must be adhered to, as developers ignore planning conditions and there appears to be no enforcement regarding hedge and tree removal post planning approval

Noted

Support

Representation ID: 6318

Received: 08/01/2024

Respondent: Mr Chris Read

Support

Support noted.

Support

Representation ID: 6439

Received: 08/01/2024

Respondent: Mrs Hilary Smith

planting trees at St George’s Barracks should be considered a priority to provide another attraction to the Rutland water area

Noted.

Object

Representation ID: 6562

Received: 08/01/2024

Respondent: Mr Roderick Morgan

I support the intent of this policy, but the statement is wholly inadequate. There should be concrete targets for tree cover growth over a specific timeframe, connectivity between woodland, and absolute preservation of established and ancient woodland, without exception or exemption. Rutland's tree cover is critically sparse, and is therefore not contributing to flood resilience and other objectives.

Support and comments noted. Targets regarding the amount of tree cover across the County would form part of the Local Nature Recovery Strategy, and once this is published, it would be used to inform the Local Plan. Ancient woodland is protected under Policy EN5, the wording of which accords with government guidance set out in the NPPF para 186: ‘development resulting in the loss or deterioration of irreplaceable habitats (such as ancient woodland and ancient or veteran trees) should be refused, unless there are wholly exceptional reasons and a suitable compensation strategy exists’.

Object

Representation ID: 6861

Received: 08/01/2024

Respondent: Leicestershire & Rutland Wildlife Trust

Whilst the policy is generally very welcomed, we are concerned about point e. which infers that both native and non-native tree species should be used in all new planting schemes. The Trust recognises the role that non-native trees can play in e.g. climate adaptation, however
to say that they should be used in all new schemes is a mistake and over-generalisation. It is widely accepted that for the purposes of nature conservation, the right kind of trees should be selected for the right place/conditions and that the use of non-native trees should be limited to prevent e.g. the spread of new pests and diseases.
It is therefore recommended that the wording be changed to “… primarily using native tree species and, only non-native tree specieswhere appropriate…”.

It is encouraging to see a proactive policy around improving tree cover within development proposals, however there is some concern that other equally valuable and locally scarce habitat types appear to be
excluded, namely species-rich Calcareous and Neutral Grassland (both local/national BAP/Priority Habitats) and accounting for only 1.03% and 0.79% of the land cover of the county respectively (Rutland County Biodiversity Assessment, 2023). Other proactive measures and
policies aligned with the Leicestershire & Rutland BAP 2016-2026 should therefore be included in the Local Plan in order to directly contribute towards nature’s recovery.

Comments noted. The protection of other valuable habitat types, including priority habitats, are covered under Policy EN1 (which it is suggested is amended to include reference to calcareous and neutral grasslands).

Regarding non native trees, trees have many benefits with many exotic (non-native) trees excelling in some. To limit the selection to just 33 native trees is more a detriment than a benefit however amend policy text to ensure non native are only used if appropriate.

Object

Representation ID: 6916

Received: 08/01/2024

Respondent: Hanbury Farms Partnership

Agent: Savills

A paragraph from Policy EN4 states: “Planning permission will only be granted if the proposal provides evidence
that it has been subject to adequate consideration of the impact of the development on any existing trees and
woodland found on-site and on any trees off-site which are visible from the site”.

The Estate OBJECTS to the phrase “… visible from the site …”, which is considered unduly onerous and that
BS5837 only requires trees which are located beyond the site boundary within a distance of up to 12 times their
estimated stem diameter to be included in the tree survey. This increases to 15 times stem diameter for veteran
and ancient trees.

It is therefore recommended that the Council that the Council removes the phrasing “… visible from the site …”
and instead references British Standards guidelines.
Furthermore, the policy continues to state “… replacement trees should be of a similar size and species to that
which are being lost”. The Estate OBJECTS to this, and advises that the amended wording of “… similar species
and capable of attaining a similar size …” should be added to policy EN4.

Comments noted. Agree this is ambiguous.
Agree regarding wording for replacement trees.

Object

Representation ID: 7186

Received: 08/01/2024

Respondent: Persimmon Homes East Midlands

Under the Mitigation for Loss of Trees and Woodland section it talks about 3 replacement trees be planted for every trees lost and these should be of a similar size and species to that which is being lost.

The policy needs to recognise that the replacement trees will not be of the same size as the trees they will be replacing on day one, instead Persimmon Homes would recommend the wording ‘similar size’ be removed from the wording.

Comments noted. Agree regarding wording for replacement trees.

Object

Representation ID: 7325

Received: 08/01/2024

Respondent: Manor Oak Homes

Agent: Mr Andy Moffat

The Policy should allow for planning permission to be granted where the public benefits of a development outweigh harm to trees, woodland, and hedgerows rather than stating that “Planning permission will only be permitted where the proposal does not adversely affect important trees, woodlands, and hedgerows…”.

Comments noted. Agree that the policy is not positively worded.

Object

Representation ID: 7373

Received: 08/01/2024

Respondent: The Society of Merchant Venturers

Agent: Savills

The overall approach of Policy EN4 broadly reflects paragraphs 136 and 180 of the NPPF (2023) which
acknowledges the contribution and benefits of trees and woodland. However, whilst the need to provide
replacement planting is acknowledged, it is not clear or justified why there is a specific need to provide at
least 3 replacement trees for each tree lost. Accordingly, it is therefore recommended that this specific
requirement is removed and that a flexible approach is taken to replacement planting to take into account
site-specific circumstances and individual affected trees.

Comments noted. Amend policy text.

Object

Representation ID: 7566

Received: 08/01/2024

Respondent: Mr Roderick Morgan

I support the intent of this policy, but the statement is wholly inadequate.

There should be concrete targets for tree cover growth over a specific timeframe, connectivity between woodland, and absolute preservation of established and ancient woodland, without exception or exemption. Rutland's tree cover is critically sparse, and is therefore not contributing to flood resilience and other objectives.

Delete as repeat of representation 6562.

Object

Representation ID: 7568

Received: 08/01/2024

Respondent: House Builders Federation

This could be clearer are unclear how this relates to the wider BNG and LNRS objectives.

The policy also seeks to require three replacement trees for each tree lost. How and why is there the requirement for three replacement trees for every one lost and what assumptions have been relation to the size
and standard of trees? A three for one replacement policy could impact on the land uptake for any development and may have implications for the density of developments, which in turn has the potential to have an impact on the
viability of developments.

Comments noted. Policy already refers to BNG in relation to mitigating for loss of trees and woodland. Add in reference to ‘LNRS’ after ‘Biodiversity Net Gain’. Targets regarding the amount of tree cover across the County form part of the Local Nature Recovery Strategy.

For replacement trees; Amend policy text to "In such cases the council will require new trees to replace the value of the trees that were removed. In most cases, this will be a higher number of new trees as trees significantly increase in value as their grow and mature. A value of the trees lost should be obtained by using appropriate formats, (e.g. CAVAT, Helliwell or iTree). Replacement trees should be of a similar species and capable of attaining a similar size to that which are being lost and will be required to be planted on-site."

Object

Representation ID: 7749

Received: 08/01/2024

Respondent: Anglian Water

On EN4 and replacement trees (3 for 1), whilst we support the aim, on an operational site this may not be possible due to the site constraints, buried assets and operational processes.

Policies EN4 and EN5 (and EN7) recognises the link between fluvial and terrestrial habitats and the role for example of tree cover in also reducing flood risks.

Comments noted. Text to be amended.