Regulation 18 draft Local Plan

Support

Representation ID: 6859

Received: 08/01/2024

Respondent: Leicestershire & Rutland Wildlife Trust

The Leicestershire & Rutland Wildlife Trust (LRWT) welcomes the inclusion of this policy, however is disappointed to see the lack of
information provided to explain why this policy is needed beyond the listed legislative requirements alone.
Given that the authority has declared an Ecological Emergency, further information should be provided to outline the intrinsic and economic need for spatial strategies for nature’s recovery.
A Local Plan should provide a positive vision for the future of the county whilst addressing serious environmental priorities, therefore great weight should be given to LNRS’s – both for appropriate development site allocation and biodiversity offsetting/enhancement purposes.

Support noted. Additional text to be added under heading ‘Why is this policy needed?’.
The Environment Act 2021 establishes a new mandatory system of spatial strategies ensuring that opportunities to recover nature are joined-up. Local Nature Recovery Strategies (LNRS), part of the Government’s 25-year Environment Plan, are aimed at improving, expanding and connecting habitats to address wildlife decline and provide wider environmental benefits for people. They will map the most valuable existing areas for nature, establish priorities, and map proposals for specific actions to drive nature’s recovery and wider environmental benefits.
A Local Nature Recovery Strategy for Leicestershire, Leicester and Rutland is currently being prepared. Across this area, less than 1% of the area has a high biodiversity score and only approximately 6% is covered by woodland, compared to the national average of 13%. The LNRS is needed because Rutland Council has declared a Climate Crisis and Ecological Emergency and there is a need to work together as communities to deal with the problems and impacts of climate change and the loss of species and habitats. It will help to guide nature-based approaches to carbon removal and storage, and flood prevention. The LNRS will be used to inform the preparation of the Local Plan and will guide policy requirements, such as in relation to Biodiversity Net Gain under Policy EN3, by informing the delivery of biodiversity offsetting. Policy EN2 is also aimed at ensuring that development proposals not subject to the mandatory BNG requirements will still be expected to make a positive contribution towards the LNRS. Statutory guidance on alignment between Local Plans and LNRS is anticipated as part of the Government’s work on planning reform.

Object

Representation ID: 6860

Received: 08/01/2024

Respondent: Leicestershire & Rutland Wildlife Trust

LRWT welcomes this policy along with the comprehensive guidance included.
The requirement to achieve at least 15% net gain is somewhat positive, in that this is beyond the statutory requirement of 10%, however it is disappointing that the authority’s own viability evidence base shows that up to 20% uplift is viable and deliverable on sites within Rutland.

There is serious concern with the environmental sector that a 10% gain figure is insufficient to contribute towards the recovery of nature in a meaning way. Instead, the Wildlife Trusts and other eNGO’s are calling for a minimum of 20% gain, a figure that is evidently shown to
be deliverable and achievable in Rutland.
Both The Wildlife Trusts and the UN have identified the need for 30% of land to be protected for the effective recovery of nature. We strongly believe that the authority has a distinct opportunity to show genuine leadership on this vital agenda by providing bolder, more ambitious targets such as this.

It is strongly recommended that long-term management of off-site BNG be secured in perpetuity (as stated for on-site delivery), rather than for 30 years to support nature’s recovery. (Please note the typo “…biodiversity New Gain…” on the last line of the policy web version)

Support and comments noted. Comments noted. Change from 15% to 10% as a higher percentage than the statutory objective of biodiversity net gain needs to be evidenced. In order for the Local Plan to be deemed sound this uplift above the mandatory level must be robustly evidenced.

Disagree regarding securing off-site BNG in perpetuity as this goes further than the TCP Act which requires any habitat enhancement to be maintained for at least 30 years after the development is completed.
Typo noted on page 178.

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.

Support

Representation ID: 6862

Received: 08/01/2024

Respondent: Leicestershire & Rutland Wildlife Trust

We welcome this policy and would not like to see compromised in any way

Support noted.

Support

Representation ID: 6863

Received: 08/01/2024

Respondent: Leicestershire & Rutland Wildlife Trust

Leicestershire and Rutland Wildlife Trust supports this policy and strongly recommends that long-term management of GBI should be secured in perpetuity rather than for 30 years to support nature’s recovery.

Support noted.

Support

Representation ID: 6864

Received: 08/01/2024

Respondent: Leicestershire & Rutland Wildlife Trust

Leicestershire and Rutland Wildlife Trust supports this policy as it clearly emphasizes the importance of the designated nature conservation features of Rutland Water and the valuable assemblages of species within it.

Support Noted.

Support

Representation ID: 6865

Received: 08/01/2024

Respondent: Leicestershire & Rutland Wildlife Trust

Leicestershire and Rutland Wildlife Trust supports this policy as it clearly emphasizes the importance of the designated nature conservation/geological features of the Eyebrook Reservoir Area.

Support noted.

Object

Representation ID: 6866

Received: 08/01/2024

Respondent: Leicestershire & Rutland Wildlife Trust

Policy is weak and does not correspond with Policy EN1: Protection of Sites, Habitats and Species to ensure that designated sites for nature conservation/irreplaceable habitats are appropriately protected. This should be extended to Priority Habitats as mineral extraction as
significantly contributed to losses historically.
Mineral developments must also align with Policy EN3 – Biodiversity Net Gain, ensuring that BNG can be achieved in principle and in perpetuity.

The protection of the environment from adverse impacts of minerals development is addressed by Policy MIN4; it is not necessary to list all the different types of environmental constraints that need to be considered. Such features will be taken into account on a site-by-site basis in line with the RLP policies (including Policy EN1) and other relevant policies.
Policy MIN9 - Restoration and aftercare, requires that restoration of minerals development provides at least 10% Biodiversity Net Gain (BNG), which is a mandatory requirement under the Environment Act (2021).

Object

Representation ID: 6867

Received: 08/01/2024

Respondent: Leicestershire & Rutland Wildlife Trust

The policy is generally welcomed, however the significance of mineral site restoration for Calcareous Grassland enhancement/creation is lost. It is acknowledged that by definition this could be included
within point b., however much greater emphasis must be placed on this habitat type as a priority for limestone mineral site restoration in order for the scale of restoration needed to be realised (Leicestershire and Rutland BAP, 2016-2026).

Noted. The BAP and priority habitats are recognised through the plan and its policies; however, it is not considered necessary to highlight calcareous grassland over others. Such features will be taken into account on a site-by-site basis in line with the Local Plan policies and other relevant policies.