Q-B9: Should the plan include a policy requiring the safeguarding of sites of national importance, sites of local importance, and other non-designated sites known to make a positive contribution to biodiversity or geodiversity; unless the benefits of the
No answer given
Yes in order to meet national requirements and targets set out in the 25 year Environment Plan, COP15 biodiversity framework targets, and the Governments commitment to have 30% more land In nature recovery by 2030, and Councils NERC duties there clearly needs to be a specific policy protecting biodiversity and importantly other non-designated sites such as Potential Local Wildlife Sites, Nature Reserves and Ecosites. It is also very important to include a policy on enhancing these sites, the words ‘unless clearly outweighs..’ should be removed as this waters down the requirement, and will greatly affect the Councils ability to achieve the Government and COP targets.
Q-B3: Please select the option which is most appropriate for South Warwickshire Option B3c: Discard Special Landscape Areas and bolster general landscape policy 7.1. Special Landscape Areas currently only exist within Stratford-on-Avon District and were introduced in the currently adopted Core Strategy (2016), as a result of information provided in the Special Landscape Area Study (2012). 7.2. Such designation has no basis in national guidance or policy and are not included in Natural England's approach. Rather, paragraph 174 of the NPPF and others seek to conserve and enhance the local environment, ensure that policies take into account landscape implications arising from development, consider landscape and visual impacts, and protect 'valued landscapes'. 7.3. Any landscape policy should reflect the content of national guidance, rather than continuing with or introducing additional policies and designations that have no policy basis, as they are not necessary, are not consistent with national policy and are not justified. Q-B4: Please select the option which is most appropriate for South Warwickshire 7.4. Paragraph 176 of the NPPF requires 'great weight' to be given to conserving and enhancing 'landscape and scenic beauty' in, inter alia, Areas of Outstanding Natural Beauty (AONB). It also requires "…development within their setting should be sensitively located and designed to avoid or minimise adverse impacts on the designated areas.” 7.5. The requirement for development within the 'setting' of AONBs to be sensitively located and designed renders the provision of a policy on this matter unnecessary. National policy guidance seeks to protect AONBs and their setting, and a policy on this matter would be repetitive and is unnecessary. Q-B8.1: Do you agree that the plan should include a policy avoiding development on the best and most versatile agricultural land, unless it can be demonstrated that the harm to agricultural land is clearly outweighed by the benefit of development? 7.6. Para 174 b) of the NPPF states that "planning policies and decisions should contribute to and enhance the natural and local environment by … recognising the intrinsic character and beauty of the countryside … including the economic and other benefits of the best and most versatile agricultural land.” In addition, PPG paragraph 001 Ref ID 8-001-20190721 states that the quality of farmland should be utilised to inform choices about its future use within the planning system. 7.7. Any policy should avoid taking a blanket approach as there will be circumstances where development on best and most versatile land is appropriate. This may also apply to some allocations. The policy should be sufficiently flexible and allow for cases when the planning balance favours approval.
The Stratford-on-Avon Core Strategy includes a number of Special Landscape Area (SLA) designations. The Ironstone Hills Fringe SLA is consistent with and contiguous to similar SLA designations in West Northamptonshire which have been confirmed in the relatively recently adopted Part 2 Local Plans for Daventry and South Northamptonshire. Landscape evidence commissioned for the new Local Plan for West Northamptonshire has confirmed the appropriateness of these designations. The continuation and potential extension of SLA designations to cover Warwick District would be supported by West Northamptonshire Council. Discussions have taken place over recent years between Stratford on Avon District Council and our predecessor councils regarding the potential designation of an Area of Outstanding Natural Beauty for the Northamptonshire Ironstone Uplands. This culminated in an expression of interest being submitted to Natural England and whilst this is not currently being taken forward the potential remains for this to be considered further in the future.
Q-B3: Please select the option which is most appropriate for South Warwickshire 2.57 Ellis Machinery considers that Option B3c is considered to be the most appropriate for South Warwickshire. The Landscape Appraisal (LA) that supported the Call for Sites Submission concluded that the Land at Old Town, Gaydon has the capacity to accommodate residential development. The LA sets outs series of parameters to ensure that development of the Site would not cause any significant harm to the landscape. These include, the incorporation of landscape buffer to the south eastern and south western boundaries; retention and reinforcement of hedgerows; building height not to exceed 2 storeys; and, the use of a sympathetic palette of materials.
Issue B1: Areas of Restraint: The current greenbelt designation concerns openness, inappropriate development, and traffic generation, but the new plan should also include biodiversity enhancement. Any development in the greenbelt / area of restraint should only be permitted if there is a measurable increase in biodiversity, in addition to the other conditions. Planners must develop unambiguous and consistent policies to protect special landscapes and enhance biodiversity. Issue B5: Environmental Net Gain: The concept of Environmental Net Gain should be preferred to Biodiversity Net Gain as it includes air quality and water quality as well as biodiversity. Carbon offsetting must go beyond tree planting, for example, committing to retrofitting existing houses to make them more energy efficient. Definitions of offsetting need to be absolutely clear to prevent greenwashing.
Issue B1: Areas of Restraint: The current greenbelt designation concerns openness, inappropriate development, and traffic generation, but the new plan should also include biodiversity enhancement. Any development in the greenbelt / area of restraint should only be permitted if there is a measurable increase in biodiversity, in addition to the other conditions. Planners must develop unambiguous and consistent policies to protect special landscapes and enhance biodiversity. Issue B5: Environmental Net Gain: The concept of Environmental Net Gain should be preferred to Biodiversity Net Gain as it includes air quality and water quality as well as biodiversity. Carbon offsetting must go beyond tree planting, for example, committing to retrofitting existing houses to make them more energy efficient. Definitions of offsetting need to be absolutely clear to prevent greenwashing.
Q-B3: Please select the option which is most appropriate for South Warwickshire 7.1. Special Landscape Areas currently only exist within Stratford-on-Avon District and were introduced in the currently adopted Core Strategy (2016), as a result of information provided in the Special Landscape Area Study (2012). 7.2. Such designation has no basis in national guidance or policy and are not included in Natural England's approach. Rather, paragraph 174 of the NPPF and others seek to conserve and enhance the local environment, ensure that policies take into account landscape implications arising from development, consider landscape and visual impacts, and protect 'valued landscapes'. 7.3. Any landscape policy should reflect the content of national guidance, rather than continuing with or introducing additional policies and designations that have no policy basis, as they are not necessary, are not consistent with national policy and are not justified. Q-B4: Please select the option which is most appropriate for South Warwickshire 7.4. Paragraph 176 of the NPPF requires 'great weight' to be given to conserving and enhancing 'landscape and scenic beauty' in, inter alia, Areas of Outstanding Natural Beauty (AONB). It also requires "…development within their setting should be sensitively located and designed to avoid or minimise adverse impacts on the designated areas.” 7.5. The requirement for development within the 'setting' of AONBs to be sensitively located and designed renders the provision of a policy on this matter unnecessary. National policy guidance seeks to protect AONBs and their setting, and a policy on this matter would be repetitive and is unnecessary. Q-B8.1: Do you agree that the plan should include a policy avoiding development on the best and most versatile agricultural land, unless it can be demonstrated that the harm to agricultural land is clearly outweighed by the benefit of development? 7.6. Para 174 b) of the NPPF states that "planning policies and decisions should contribute to and enhance the natural and local environment by … recognising the intrinsic character and beauty of the countryside … including the economic and other benefits of the best and most versatile agricultural land.” In addition, PPG paragraph 001 Ref ID 8-001-20190721 states that the quality of farmland should be utilised to inform choices about its future use within the planning system. 7.7. Any policy should avoid taking a blanket approach as there will be circumstances where development on best and most versatile land is appropriate. This may also apply to some allocations. The policy should be sufficiently flexible and allow for cases when the planning balance favours approval.
Development is still one of the major causes of habitat decline. Make the most of brownfield land in order to limit the adverse effect on wildlife and habitats loss. • A 20% biodiversity net gain must be sufficiently demonstrated in all new development. • Audit council-owned land to facilitate projects to promote and enhance biodiversity, tree planting, educational opportunities and community allotments. • Encourage Parish Councils to adopt local biodiversity plans • Support and invest in biodiversity projects all around the district by working together with town and parish councils.
Issue B1: Areas of Restraint: The current greenbelt designation concerns openness, inappropriate development, and traffic generation, but the new plan should also include biodiversity enhancement. Any development in the greenbelt / area of restraint should only be permitted if there is a measurable increase in biodiversity, in addition to the other conditions. Planners must develop unambiguous and consistent policies to protect special landscapes and enhance biodiversity. Issue B5: Environmental Net Gain: The concept of Environmental Net Gain should be preferred to Biodiversity Net Gain as it includes air quality and water quality as well as biodiversity. Carbon offsetting must go beyond tree planting, for example, committing to retrofitting existing houses to make them more energy efficient. Definitions of offsetting need to be absolutely clear to prevent greenwashing.
Q-B3: Please select the option which is most appropriate for South Warwickshire The Consultation Document sets out the approach taken in the Stratford-on-Avon Core Strategy to Special Landscape Areas. These are local landscape designations which are based on a 2012 evidence base which is now out of date, and which were intended to put in place a layer of protection for high quality landscapes that also contained historic or cultural features. As noted in the Consultation Document, local landscape designations are not supported by national policy. Nevertheless, some local authorities still use them. Many other local authorities, however, use a more nuanced policy approach which enables a judgement to be made on individual proposals based upon landscape character assessments and Landscape Value Impact Assessments (LVIA). This is the approach taken in the Warwick Local Plan, and is an approach we have seen used very effectively across England. Policy CS.12 of the Stratford-on-Avon Core Strategy simply sets out where the SLAs are designated and gives broad guidance on how to assess development in these areas. It does not set out the detail of the considerations that are to be applied, and therefore a planning application in the SLAs would still need to produce a LVIA with no policy guidance about what particular unique factors should be assessed. We would therefore suggest that the SLA policy is not carried forward into the SWLP, and instead a stronger policy framework for assessing landscape considerations across the plan area is introduced. In this way, it would be easier to draw out the factors most applicable to any given landscape, and the approach would be strengthened for the whole plan area, as landscape considerations would apply to any location, with or without a formal designation.
QB1 Please select the option which is most appropriate for South Warwickshire Claverdon endorses option B1a and proposals to protect and enhance the historic and environmental quality of the village and the steps to be taken by the partnership to achieve that. This level of proposal, however, appears to Claverdon to be far too detailed and is an example of excessive scope/detail in this consultation. These are all issues that are being delegated to NPs and there needs to be some reference in the document to encouraging Neighbourhood Plans to undertake this activity and guidance as to appropriate approaches QB2 Should the Policy on the Vale of Evesham Control Zone be removed, if neighbouring authorities decide not to carry the designation. This is a matter for local councils and people. QB4.Please select the option which is most appropriate for South Warwickshire Claverdon believes that in general our environmental quality needs to be protected and maintained and although the ideas are sound this might have a negative impact on areas to the North depending on the scale of the buffer. However, these are issues to be debated with local communities and the relevant statutory agencies involved and the Local Plan part 1 does not seem to be the correct place to have this debate. QB5 Please select the option which is most appropriate for South Warwickshire Claverdon supports option B5a. The core idea is sound, but we have concerns that this might push more development further to the North.
Shouldn’t we bring the 2 policies in line with each other?
2.29 Special Landscape Areas (B3) 2.29.1 Three options are presented in relation to Special Landscape Areas (SLAs) (B3a – maintain SLAs in Stratford on Avon district and introduce SLAs into Warwick District, B3b – maintain SLAs in Stratford on Avon but don’t introduce them into Warwick and B3c, discard SLAs and bolster landscape policy. Given the intention to create a Joint Local Plan it would make sense for option B3c to be adopted. 2.30 Environmental net gain (B5) and Wildbelt designations (B6) 2.30.1 Options relating to net gain are discussed, the first B5a is an ‘integrated approach’ with a policy covering air quality, water quality and carbon capture – biodiversity net gain would still be required. Option B5b is to have separate policies relating to biodiversity, air quality etc. It is suggested that option B5b is preferable – keeping the requirement for biodiversity net gain separate from other requirements will help provide clarity. 2.30.2 Wildbelts are discussed under B6 as a new approach to aiding nature recovery. From the information provided it appears that these could also act as wildlife corridors and stepping stones, which the NPPF (paragraph 179) already encourages, alongside areas identified by national and local partnerships for habitat management, enhancement, restoration and creation – it therefore appears that the NPPF provides a policy hook for local policies aimed at achieving these objectives. 2.31 Links to the Minerals Plan (B7) 2.31.1 It is agreed that it is appropriate to highlight links to the Minerals Plan, avoiding the unnecessary duplication of policy within the SWLP. 2.32 Agricultural Land (B8.1) 2.32.1 Question B8.1 asks: “do you agree that the plan should include a policy avoiding development on the best and most versatile agricultural land, unless it can be demonstrated that the harm to agricultural land is clearly outweighed by the benefit of development?”. It is noted that the Government intends to produce a new suite of national development policies, and this may well be covered in there. The NPPF provides policy at paragraph 174b and a specific Local Plan policy that repeats national policy is not considered to be warranted. 2.33 Protecting biodiversity and geodiversity (B8.2 and B9) 2.33.1 Question B8.2 is: “should the plan include a policy requiring the safeguarding of sites of national importance, sites of local importance, and other non-designated sites known to make a positive contribution to biodiversity or geodiversity; unless the benefits of the proposal clearly outweigh the need to protect the site. Where possible conserve and enhance these sites.” 2.33.2 From the explanatory text in the I&O part of the driver for the question appears to be that the two existing local plans have similar policies with different wording. It makes sense to have one policy covering the different designations that are in the area, the degree of protection given to such sites would need to be consistent with paragraph 175 of the NPPF. This principle would also apply to any policy referenced under Question B9.
Q-B3 58. As a matter of principle, there should be no Special Landscape Areas within South Warwickshire because normal countryside and landscape impact policies are sufficient to protect all landscapes. Q-B4 59. National policy should be relied upon for the AONB because there is no specific need for local policies. There is no national basis for a buffer policy for the AONB. The setting of the AONB is a landscape judgement to be made on an individual basis not through a generic policy
Q-B3: Please select the option which is most appropriate for South Warwickshire Special Landscape Areas currently only exist within Stratford-on-Avon District and were introduced in the currently adopted Core Strategy (2016), as a result of information provided in the Special Landscape Area Study (2012). 7.2. Such designation has no basis in national guidance or policy and are not included in Natural England's approach. Rather, paragraph 174 of the NPPF and others seek to conserve and enhance the local environment, ensure that policies take into account landscape implications arising from development, consider landscape and visual impacts, and protect 'valued landscapes'. 7.3. Any landscape policy should reflect the content of national guidance, rather than continuing with or introducing additional policies and designations that have no policy basis, as they are not necessary, are not consistent with national policy and are not justified. Q-B4: Please select the option which is most appropriate for South Warwickshire Option B4a: Maintain the current policy approach, without the use of a buffer 7.4. Paragraph 176 of the NPPF requires 'great weight' to be given to conserving and enhancing 'landscape and scenic beauty' in, inter alia, Areas of Outstanding Natural Beauty (AONB). It also requires "…development within their setting should be sensitively located and designed to avoid or minimise adverse impacts on the designated areas." 7.5. The requirement for development within the 'setting' of AONBs to be sensitively located and designed renders the provision of a policy on this matter unnecessary. National policy guidance seeks to protect AONBs and their setting, and a policy on this matter would be repetitive and is unnecessary. Q-B8.1: Do you agree that the plan should include a policy avoiding development on the best and most versatile agricultural land, unless it can be demonstrated that the harm to agricultural land is clearly outweighed by the benefit of development? Yes | No | Don’t Know 7.6. Para 174 b) of the NPPF states that "planning policies and decisions should contribute to and enhance the natural and local environment by … recognising the intrinsic character and beauty of the countryside … including the economic and other benefits of the best and most versatile agricultural land…" 7.7. In addition, PPG paragraph 001 Ref ID 8-001-20190721 states that the quality of farmland should be utilised to inform choices about its future use within the planning system. If a specific policy is to be proposed for the emerging Local Plan then it should be fully evidenced by information to demonstrate that it is justified and does not unduly prevent sustainable development from coming forward in accordance with relevant considerations regarding the NPPF and Development Plan.
Q-B3 60. As a matter of principle, there should be no Special Landscape Areas within South Warwickshire because normal countryside and landscape impact policies are sufficient to protect all landscapes. Q-B4 61. National policy should be relied upon for the AONB because there is no specific need for local policies. There is no national basis for a buffer policy for the AONB. The setting of the AONB is a landscape judgement to be made on an individual basis not through a generic policy. .
Q-B3 60. As a matter of principle, there should be no Special Landscape Areas within South Warwickshire because normal countryside and landscape impact policies are sufficient to protect all landscapes. Q-B4 61. National policy should be relied upon for the AONB because there is no specific need for local policies. There is no national basis for a buffer policy for the AONB. The setting of the AONB is a landscape judgement to be made on an individual basis not through a generic policy. An example of a potential incorrect application of a generic buffer policy is the unreasonable discounting of Kineton as a location for growth when there are opportunities for growth which have no adverse impact on the setting of the AONB, including the reserve housing site identified in the Neighbourhood Plan.
Q-B3 57. As a matter of principle, there should be no Special Landscape Areas within South Warwickshire because normal countryside and landscape impact policies are sufficient to protect all landscapes. Q-B4 58. National policy should be relied upon for the AONB because there is no specific need for local policies. There is no national basis for a buffer policy for the AONB. The setting of the AONB is a landscape judgement to be made on an individual basis not through a generic policy.
Q-B3 58. As a matter of principle, there should be no Special Landscape Areas within South Warwickshire because normal countryside and landscape impact policies are sufficient to protect all landscapes. Q-B4 59. National policy should be relied upon for the AONB because there is no specific need for local policies. There is no national basis for a buffer policy for the AONB. The setting of the AONB is a landscape judgement to be made on an individual basis not through a generic policy.
Q-B1: The JPC strongly endorses option B1a and proposals to protect and enhance the historic and environmental quality of the town and the steps to be taken by the partnership to achieve that. This level of proposal, however, appears to JPC to be far too detailed and is an example of excessive scope/detail in this consultation. These are all issues that are being delegated to NPs and there needs to be some reference in the document to encouraging Neighbourhood Plans to undertake this activity and guidance as to appropriate approaches. Q-B2: This is a matter for the local councils and their residents Q-B4: The JPC believes that in general our environmental quality needs to be protected and maintained and although the ideas are sound this might have a negative impact on areas to the North depending on the scale of the buffer. However, these are issues to be debated with local communities and the relevant statutory agencies involved and the Local Plan part 1 does not seem to be the correct place to have this debate. Q-B5: The JPC supports option 5a. The core idea is sound, but we have concerns that this might push more development further to the North. Q-B9: The JPC supports the proposal, but it still seems doubtful that the duplication is essential at this stage.
Coventry City Council welcomes the protection and enhancement of biodiverse and geodiverse sites. Through on-going sub-regional joint working at officer level as well as work on Local Nature Recovery Strategies, Habitat audits and an updated Green Infrastructure Strategy, the council considers that key ecology assets can have long term protection through policies which provide for enhanced connectivity via green and blue infrastructure and are protected from inappropriate development.
Option S1a: Identify Strategic Green and Blue Corridors in advance of the Local Nature Recovery Strategy being producedSouth Warwickshire Councils need a clear policy to protect important environmental assets, designated and non designated sites including potential local wildlife sites. As well as a policy to enhance and restore wildlife sites. Without watering down the policy with wording such as ‘where appropriate’ and in line with the priorities of the Biodiversity Action Plan. The Councils need to plan in line with the legal requirements set out in the National Planning Policy Framework (NPPF), 25 year Environment Plan, the Governments commitment to 30% land in nature recovery by 2030, COP 27 and COP 15 and the Councils declared climate change emergencies. National Planning Policy Framework Paragraph 20d) requires ‘conservation and enhancement of the natural...environment, including landscapes and green infrastructure, and planning measures to address climate change mitigation and adaptation’ Paragraph 175. Requires Councils ‘take a strategic approach to maintaining and enhancing networks of habitats and green infrastructure; and plan for the enhancement of natural capital at a catchment or landscape scale across local authority boundaries’. Option B5a: Explore and pursue an integrated Environmental Net Gain Policy. I am disappointed to see such a low minimum target for proposed biodiversity net gain. Other councils such as Greater Cambridgeshire have been more ambitious requiring 20% Biodiversity net gain. This would be more in keeping with mitigating our environmental state of emergency. Q B.6 Should the South Warwickshire Local Plan introduce Wildbelt designations? - Yes, absolutely but this should not push development to the North of South Warwickshire, instead all areas have wild belt designations. QB9 - Yes. In order to meet national requirements and targets set out in the 25 year Environment Plan, COP15 biodiversity framework targets, and the Governments commitment to have 30% more land In nature recovery by 2030, and Councils NERC duties there clearly needs to be a specific policy protecting biodiversity and importantly other non-designated sites such as Potential Local Wildlife Sites, Nature Reserves and Ecosites. It is also very important to include a policy on enhancing these sites, the words ‘unless clearly outweighs..’ should be removed as this waters down the requirement, and will greatly affect the Councils ability to achieve the Government and COP targets. BQ10 - The biodiversity and environmental assessments for Henley presented in the current consultation documents are inadequate and have not identified a number of considerable environmental areas of conservation and protected species, along with a lack of understanding about the geology of the Henley area which leaves it open to flood related issues which are unlikely to be fully addressed by developers. In Henley the infrastructure in general including the sewer provision is not able to meet the needs of large scale development in the area.
Issue B5: Environmental Net Gain MAOL supports the principle of environmental net gain. There is not yet any clarity on how the approach might work. As such, our client does not provide further comments at this stage save to say that any policy should be justified and ensure flexibility for consideration on a site-by-site basis.
In introducing new initiatives related to design, the Chamber would emphasise that costs impacts of new measures need to be understood and properly evaluated. The Chamber would also not support prescriptive policies in relation to density of development .As set out above some commercial development and land use types require low density layouts-for example the biomedical and scientific sectors as well as many logistic and distribution schemes. Setting blanket density policies could cut across the proper provision for some commercial land uses. Storage land and space represents another commercial land use type where pressures from brownfield land policy and density increase could seriously impact the overall provision of the use.
Minerals WCC note that minerals policy for the South Warwickshire area is contained within the Warwickshire Minerals Local Plan 2018-2032, adopted in July 2022. Question B7 asks “Do you agree that it is appropriate to highlight links to the Minerals Plan, avoiding the unnecessary duplication of policy within the SWLP?”. Whilst WCC recognises that unnecessary duplication of policies should be avoided, we support the SWLP giving appropriate prominence to the need for mineral safeguarding. Site allocations should be informed by mineral safeguarding, and site-specific policies within the SWLP should highlight the need for any further mineral safeguarding that may eb required at planning application stage.
The concept of Environmental Net Gain should be preferred to Biodiversity Net Gain as it includes air quality and water quality as well as biodiversity. Carbon offsetting must go beyond tree planting, for example, committing to retrofitting existing houses to make them more energy efficient. Definitions of offsetting need to be absolutely clear to prevent greenwashing.
Q- B.5 Please select the option which is most appropriate for South Warwickshire. Option B5a: Explore and pursue an integrated Environmental Net Gain Policy. I am disappointed to see such a low minimum target for proposed biodiversity net gain. Other councils such as Greater Cambridgeshire have been more ambitious requiring 20% Biodiversity net gain. This would be more in keeping with mitigating our environmental state of emergency Q B.6 Should the South Warwickshire Local Plan introduce Wildbelt designations? Yes, absolutely but this should not push development to the North of South Warwickshire, instead all areas have wild belt designations. Q B 9 Yes. In order to meet national requirements and targets set out in the 25 year Environment Plan, COP15 biodiversity framework targets, and the Governments commitment to have 30% more land In nature recovery by 2030, and Councils NERC duties there clearly needs to be a specific policy protecting biodiversity and importantly other non-designated sites such as Potential Local Wildlife Sites, Nature Reserves and Ecosites. It is also very important to include a policy on enhancing these sites, the words ‘unless clearly outweighs..’ should be removed as this waters down the requirement, and will greatly affect the Councils ability to achieve the Government and COP targets. BQ. 10. The biodiversity and environmental assessments for Henley presented in the current consultation documents are inadequate and have not identified a number of considerable environmental areas of conservation and protected species, along with a lack of understanding about the geology of the Henley area which leaves it open to flood related issues which are unlikely to be fully addressed by developers. In Henley the infrastructure in general including the sewer provision is not able to meet the needs of large scale development in the area.
The concept of Environmental Net Gain should be preferred to Biodiversity Net Gain as it includes air quality and water quality as well as biodiversity. Carbon offsetting must go beyond tree planting, for example, committing to retrofitting existing houses to make them more energy efficient. Definitions of offsetting need to be absolutely clear to prevent greenwashing.