Regulation 18 draft Local Plan

Object

Representation ID: 6809

Received: 08/01/2024

Respondent: Leicestershire & Rutland Wildlife Trust

The bullet point “protection and preservation of heritage assets and natural environment” is weak and insufficient for tackling the joint Climate Crisis and Ecological Emergency that we are facing and has been declared by the authority.
In order for the vision to align with the aims of the Environment Act, 2021 - much greater emphasis must be placed on the need for biodiversity enhancement and nature restoration at scale, through the development of a robust Nature Recovery Network.
The role of high quality and accessible natural habitats in providing a wide range of health and wellbeing benefits to local communities must also be included as a key visionary element.

Comments noted. Add in to 6th bullet point: "and their setting, including the enhancement and recovery of biodiversity contributing to the nature recovery network". Climate Change is addressed in Chapter 4.

Support

Representation ID: 6848

Received: 08/01/2024

Respondent: Leicestershire & Rutland Wildlife Trust

The role of nature-based solutions is clearly identified and supported, along with the need to increase biodiversity and put nature into recovery in order to mitigate/adapt to climate change.

Support noted.

Object

Representation ID: 6850

Received: 08/01/2024

Respondent: Leicestershire & Rutland Wildlife Trust

Wording is weak in relation to avoiding and mitigating for potential adverse impacts on the natural environment. “…taking account of impacts…” should be amended to “avoiding and minimising impactions on…”.

Suggested amendment to wording is reflective of Policy MIN4 and will be incorporated as an amendment to the Plan.

Object

Representation ID: 6852

Received: 08/01/2024

Respondent: Leicestershire & Rutland Wildlife Trust

Provisions for biodiversity, geodiversity and nature recovery/Local Nature Recovery Strategies within this policy are welcomed. However, adequate protection for protected species, namely for bats and migratory birds should also be included in relation to wind-based
energy proposals. This is a particularly significant issue given the proximity of any proposed sites within the vicinity of Rutland Water SSSI/Ramsar Site, which is designated for its nationally/internationally important bird assemblages.

Support noted. Reference to be made to priority habitats or species in the policy and further defined in the text accompanying Policy CC8.

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.

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: 6855

Received: 08/01/2024

Respondent: Leicestershire & Rutland Wildlife Trust

Point f. refers to “…ensuring a minimum 10% biodiversity net gain…”
within the site masterplan. This is inconsistent with the proposed
Policy EN3 – Biodiversity Net Gain which states that a net gain of at least 15% would be required for all qualifying developments.
Note that a large area of the former airfield on the St George’s Barracks site has been identified as a potential Local Wildlife Site due to the extent of Calcareous Grassland, a local and national Biodiversity Action Plan Habitat and Habitat of Principle Importance under the NERC Act, 2006. Any development in and around this area should therefore be firstly avoided in accordance with the mitigation hierarchy.

Comments noted. Policy is to be amended. Policy EN3 is also to be amended to specify a BNG of at least 10%. Details of the extent of the development area would be set out in the masterplan, taking into account the presence and importance of the calcareous grassland habitat.

Object

Representation ID: 6856

Received: 08/01/2024

Respondent: Leicestershire & Rutland Wildlife Trust

Point c. refers to a “country park incorporating the appropriate mitigation of potential harm to biodiversity and wildlife assets, including the appropriate translocation of notable species”. There are concerns over the potential viability of habitats capable of supporting translocated notable species within this context. The point should be
amended to focus on the need for a clear spatial mitigation strategy for habitat losses, in-line with both the Mitigation Hierarchy and new Biodiversity Net Gain Hierarchy, with an assessment of the viability of species translocations alongside this. The strategy should favour on site provision over off-site provision to mitigate any losses.

All site appraisals have been reviewed in the light of comments and further evidence received to determine their suitability for allocation.

Support

Representation ID: 6857

Received: 08/01/2024

Respondent: Leicestershire & Rutland Wildlife Trust

Policy supported, specifically point e., which relates to maximising ecological benefits/networks and delivering Biodiversity Net Gains.

Support noted

Object

Representation ID: 6858

Received: 08/01/2024

Respondent: Leicestershire & Rutland Wildlife Trust

The policy is generally supported; however no mention is made to spatial mitigation – i.e. the need to mitigate for habitat/species losses in close to proximity to where they occur, or within existing nearby ecological networks within emerging Local Nature Recovery Strategies.
The inclusion of priority grasslands is welcomed but would be stronger by detailing the specific habitat types within the county, namely Calcareous Grassland and Neutral Grassland.
Reference to the Leicestershire and Rutland BAP is absent from the policy wordings and should be included in order to maximise opportunities for the restoration, enhancement and connection of priority habitats and species.
The undertaking and publication of the supporting evidence documents - Biodiversity Assessment (May 2023) and Rutland GBI Strategy is welcomed and are considered to be an important resource for planning nature’s recovery.

Comments and support noted. Agreed. Add in after ‘habitats’ in part 3c) ‘including those in the Leicestershire and Rutland Biodiversity Action Plan’. Add in after ‘priority’ in part 4) ‘Calcareous and neutral grasslands.’ Add in after ‘harm’ in part 5b) ‘in close proximity to where the losses occur, or within nearby existing ecological networks within Local Nature Recovery Strategies.’