Other

ID sylw: 107182

Derbyniwyd: 05/03/2025

Ymatebydd: Sandwell Metropolitan Borough Council

DPDs 39, Draft Policy Direction 40 and Draft Policy Direction 41 - Carbon Sinks and Sequestration all reference the same issue – it needs to be made clear what the relationship between the policies is in terms of how they use / measure carbon sequestration. Assuming DPD 39 represents a strategic policy approach to how and where sequestration would occur, the other two policy directions would need to translate that strategy into requirements on site and ensure any targets for the sub-area were reflected in site-specific outcomes. This seems unnecessarily repetitive in theory. Subsequent policies will need to be very clear which aspects of the issue they cover and ensure there is no overlap between them.

As the justification states, the role of planning in carbon sequestration is limited and the process itself is effectively addressed through those policies that seek to protect open spaces and ecologically important sites. On that basis it is not clear why a separate policy on sequestration is required when existing policies could be drafted to include reference to the role of open spaces, the LNRS etc. in delivering it.

No

ID sylw: 107760

Derbyniwyd: 07/03/2025

Ymatebydd: Bellway Strategic Land

Asiant : Savills

The policy seeks to protect and enhance carbon sinks. Reference is made to a supporting plan but these plans are unclear. More detail needs to be provided to demonstrate how much of the district is considered to be a ‘carbon sink’ and the Council’s justification for this identification.

Other

ID sylw: 107863

Derbyniwyd: 05/03/2025

Ymatebydd: Catesby Estates Ltd

Asiant : Pegasus Group

This policy direction seeks to protect and enhance carbon sinks that are sequestering carbon above a certain threshold. The Councils are also considering requiring a net gain in carbon sequestration as part of developments. It is acknowledged that the Assessment of Carbon Sequestration and Habitat Baseline and Opportunities (March 2024) does suggest that the South Warwickshire authorities should consider setting a threshold, and that to maximise climate change resilience, environmental features that make contributions towards carbon sequestration should be protected.

However, this is likely to have a negative impact by potentially placing a constraint on development, particularly if the threshold is too low, as stated in the report (page 48), and the Councils should have regard to this. Moreover, it must be emphasised that the conclusions in the Assessment of Carbon Sequestration and Habitat Baseline and Opportunities (March 2024) do not recommend a policy requiring a net gain in carbon sequestration. At present, there is insufficient evidence to justify this policy, as suggested by the Councils in the policy direction itself, which does not propose a threshold due to the lack of green infrastructure evidence which exists to inform this.

Yes

ID sylw: 107889

Derbyniwyd: 07/03/2025

Ymatebydd: Taylor Wimpey Strategic Land

Asiant : Turley

We broadly agree that consideration should be given to the carbon sequestration potential of land. This is often a requirement set by Natural England in response to EIA Scoping for large scale development. Certain land types such as peatland can have a significant carbon sequestration and storage benefit and avoiding development on this type of land or ensuring adequate mitigation is important.
It is noted that further work is required to determine the threshold for protecting and enhancing carbon sinks. We would recommend this is considered carefully as this will have impacts on the land available for development and viability of development. It is possible there may be unintended consequences from setting the threshold too high, effectively sterilising areas of land from development, despite these potentially being more sustainable locations for development than others.

Other

ID sylw: 107983

Derbyniwyd: 07/03/2025

Ymatebydd: Rainier Developments Ltd

Asiant : Pegasus Group

This policy direction seeks to protect and enhance carbon sinks that are sequestering carbon above a certain threshold. The Councils are also considering requiring a net gain in carbon sequestration as part of developments. It is acknowledged that the Assessment of Carbon Sequestration and Habitat Baseline and Opportunities (March 2024) does suggest that the South Warwickshire authorities should consider setting a threshold, and that to maximise climate change resilience, environmental features that make contributions towards carbon sequestration should be protected.

However, this is likely to have a negative impact by potentially placing a constraint on development, particularly if the threshold is too low, as stated in the report (page 48), and the Councils should have regard to this. Moreover, it must be emphasised that the conclusions in the Assessment of Carbon Sequestration and Habitat Baseline and Opportunities (March 2024) do not recommend a policy requiring a net gain in carbon sequestration. At present, there is insufficient evidence to justify this policy, as suggested by the Councils in the policy direction itself, which does not propose a threshold due to the lack of green infrastructure evidence which exists to inform this.

No

ID sylw: 108094

Derbyniwyd: 07/03/2025

Ymatebydd: Seven Homes

Asiant : Pegasus Group

This policy direction seeks to protect and enhance carbon sinks that are sequestering carbon above a certain threshold. The Councils are also considering requiring a net gain in carbon sequestration as part of developments. It is acknowledged that the Assessment of Carbon Sequestration and Habitat Baseline and Opportunities (March 2024) does suggest that the South Warwickshire authorities should consider setting a threshold, and that to maximise climate change resilience, environmental features that make contributions towards carbon sequestration should be protected.

However, this is likely to have a negative impact by potentially placing a constraint on development, particularly if the threshold is too low, as stated in the report (page 48), and the Councils should have regard to this. Moreover, it must be emphasised that the conclusions in the Assessment of Carbon Sequestration and Habitat Baseline and Opportunities (March 2024) do not recommend a policy requiring a net gain in carbon sequestration. At present, there is insufficient evidence to justify this policy, as suggested by the Councils in the policy direction itself, which does not propose a threshold due to the lack of green infrastructure evidence which exists to inform this.

No

ID sylw: 108237

Derbyniwyd: 07/03/2025

Ymatebydd: Persimmon Homes (South Midlands)

Asiant : Pegasus Group

This policy direction seeks to protect and enhance carbon sinks that are sequestering carbon above a certain threshold. The Councils are also considering requiring a net gain in carbon sequestration as part of developments. It is acknowledged that the Assessment of Carbon Sequestration and Habitat Baseline and Opportunities (March 2024) does suggest that the South Warwickshire authorities should consider setting a threshold, and that to maximise climate change resilience, environmental features that make contributions towards carbon sequestration should be protected.

However, this is likely to have a negative impact by potentially placing a constraint on development, particularly if the threshold is too low, as stated in the report (page 48), and the Councils should have regard to this. Moreover, it must be emphasised that the conclusions in the Assessment of Carbon Sequestration and Habitat Baseline and Opportunities (March 2024) do not recommend a policy requiring a net gain in carbon sequestration. At present, there is insufficient evidence to justify this policy, as suggested by the Councils in the policy direction itself, which does not propose a threshold due to the lack of green infrastructure evidence which exists to inform this.

No

ID sylw: 108477

Derbyniwyd: 06/03/2025

Ymatebydd: The Bird Group

Asiant : Framptons

Whilst we acknowledge that integrating carbon sinks and sequestration into planning policy can be beneficial for mitigating climate change, it also presents several challenges. For example, accurately measuring and verifying the amount of carbon sequestered can be complex and resource-intensive, which can lead to uncertainties and inconsistencies in reporting. Furthermore, ensuring that carbon sinks, such as forests and wetlands, are maintained and managed effectively over the long term can also be challenging, especially when climate change can affect their ability to sequester carbon. We therefore consider that this policy requirement should not, at this time be taken forward in the SWLP.
If, however, the Councils do decide to pursue Draft Policy Direction 41, before any requirement is introduced that requires a net gain in carbon sequestration, the viability of doing so should be undertaken taking into account and factored into the Viability Assessment produced with the Pre-Submission SWLP.

No

ID sylw: 108596

Derbyniwyd: 07/03/2025

Ymatebydd: Corbally Group (Harbury) Ltd

Asiant : Pegasus Group

This policy direction seeks to protect and enhance carbon sinks that are sequestering carbon above a certain threshold. The Councils are also considering requiring a net gain in carbon sequestration as part of developments. It is acknowledged that the Assessment of Carbon Sequestration and Habitat Baseline and Opportunities (March 2024) does suggest that the South Warwickshire authorities should consider setting a threshold, and that to maximise climate change resilience, environmental features that make contributions towards carbon sequestration should be protected.

However, this is likely to have a negative impact by potentially placing a constraint on development, particularly if the threshold is too low, as stated in the report (page 48), and the Councils should have regard to this. Moreover, it must be emphasised that the conclusions in the Assessment of Carbon Sequestration and Habitat Baseline and Opportunities (March 2024) do not recommend a policy requiring a net gain in carbon sequestration. At present, there is insufficient evidence to justify this policy, as suggested by the Councils in the policy direction itself, which does not propose a threshold due to the lack of green infrastructure evidence which exists to inform this.

Other

ID sylw: 108643

Derbyniwyd: 07/03/2025

Ymatebydd: Kiely Bros Holdings Ltd

Asiant : Pegasus Group

Policy Direction 41 – Carbon Sinks and Sequestration
10.10.
This policy direction seeks to protect and enhance carbon sinks that are sequestering carbon above a certain threshold. The Councils are also considering requiring a net gain in carbon sequestration as part of developments. It is acknowledged that the Assessment of Carbon Sequestration and Habitat Baseline and Opportunities (March 2024) does suggest that the South Warwickshire authorities should consider setting a threshold, and that to maximise climate change resilience, environmental features that make contributions towards carbon sequestration should be protected.
10.11.
However, this is likely to have a negative impact by potentially placing a constraint on development, particularly if the threshold is too low, as stated in the report (page 48), and the Councils should have regard to this. Moreover, it must be emphasised that the conclusions in the Assessment of Carbon Sequestration and Habitat Baseline and Opportunities
(March 2024) do not recommend a policy requiring a net gain in carbon sequestration. At present, there is insufficient evidence to justify this policy, as suggested by the Councils in the policy direction itself, which does not propose a threshold due to the lack of green infrastructure evidence which exists to inform this.