Object
Regulation 18 draft Local Plan
Representation ID: 7034
Received: 08/01/2024
Respondent: Natasha Buswell
Whilst I agree that there needs to be a plan for green renewable energy I am concerned about the high number of proposed Solar Farms with our small county.
Comments noted. As national policy is to maximise renewable generation then it would not be appropriate to set a limit on area for ground mounted solar. In terms of targets, para 003 of the PPG states that ‘The National Planning Policy Framework explains that all communities have a responsibility to help increase the use and supply of green energy, but this does not mean that the need for renewable energy automatically overrides environmental protections and the planning concerns of local communities.’ It also states that: ‘The UK has legal commitments to cut greenhouse gases and meet increased energy demand from renewable sources. Whilst local authorities should design their policies to maximise renewable and low carbon energy development, there is no quota which the Local Plan has to deliver.’ Cumulative impacts would be assessed under Policy CC8.
Object
Regulation 18 draft Local Plan
Representation ID: 7038
Received: 08/01/2024
Respondent: Mr Nick Hamilton
The local plan should ensure that we do not just become an easy option for alternative energy companies to develop of our land in order to supply other areas of the country, with no benefit to the inhabitants of Rutland. Consideration of the visual and audible impact on the day to day lives of residents. The impact on the value of the properties in the direct proximity of a development will have a negative impact on creating a sustainable community.
We are all aware of the necessity for alternative energy, but the local plan should not embrace alternative energy at any cost. The siting of any development must, first and foremost, take into account the effect on local, established business that already feeds into the local economy, as well as employing Rutland residents. As with the effect on local residents, this may be visual audible, but must also take into account the effect on flooding, established flora and fauna and wellbeing of employees.
Rutland is small and is a beautifully rural county with its greenness being a major element of the attraction to tourists. Without a buoyant tourism economy the county will implode. Therefore consideration of the siting of any development so that it does not impact the rural feel of the county is imperative.
Comments noted. Policy CC8 accords with national planning policy: ‘To help increase the use and supply of renewable and low carbon energy and heat, plans should: a) provide a positive strategy for energy from these sources, that maximises the potential for suitable development……while ensuring that adverse impacts are addressed appropriately (including cumulative landscape and visual impacts and impacts on residential amenity). Other policies in the Local Plan relating to biodiversity, flooding and tourism would also apply to the assessment of a renewable energy proposal.
RCC has declared a Climate Crisis and has committed to taking positive action to achieve net-zero including by considering renewable energy generation. The Local Plan identifies areas suitable for solar pv development, and provides a positive strategy for energy from these sources in accordance with the requirements of national planning policy (NPPF para 160). The alternative, (ie not identifying any potentially suitable areas), would mean that applications could only be approved if an area was identified in a neighbourhood plan: this could result in no or very limited development, which would not be in line with Rutland’s Strategic Objective to take positive action to achieve net-zero and would be a barrier to the Local Plan making a legally required meaningful contribution to addressing the climate crisis.
Object
Regulation 18 draft Local Plan
Representation ID: 7071
Received: 08/01/2024
Respondent: Linda Gray
Para a) Consideration should include
“the risk of fire and water contamination arising from thermal runaway in Lithium Ion battery storage units”.
Storage units should not be sited near to communities, measures such as retaining ponds should be required to collect contaminated water and the Council should be satisfied that the Fire Authority has sufficient resources to deal with thermal runaway.
Para c. The fire and contamination risk should be added.
In the case of medium to large solar and wind installations, the Council should commit to its own independent assessment in every case.
Replace “may” with “should” in the following sentence, “For the above criteria (a) – (c) the County Council may…..”
First Para. Add the risk of “thermal runaway, water contamination, fire and toxic gases”
Second Para. The areas identified as opportunity areas for solar and wind power far exceed Rutland’s need for renewable energy. There is no assessment in the Plan of the size of this requirement.
The Council should give priority to opportunity areas which have previous industrial use, brownfield sites, redundant military sites.
It is considered 500 m. minimum distance of such an installation from residential properties and communities is insufficient, especially where battery storage is concerned.
Proposers should be required to provide a bond for future reinstatement.
Comments on risks from batteries noted. More applicable to Policy CC10. Agree to add in a paragraph at end of Why is this policy needed? (Policy CC10) on page 47 regarding batteries:
Batteries can help to maximise the efficiency of an installation by allowing energy to be stored. Battery storage should be considered as part of all solar developments. Batteries and inverters should be co-located in existing buildings where possible and should be located away from noise sensitive development. Where planning permission is being sought for development of battery energy storage systems of 1MW or over, in open air environments using lithium-ion batteries government guidance set out in PPG: Renewable and low carbon energy encourages applicants to engage with the relevant local fire and rescue service before submitting a planning application. Where relevant the local fire and rescue service will also be consulted on planning applications. This is to ensure that the fire and rescue service are given the opportunity to provide their views on the application to identify the potential mitigations which could be put in place in the event of an incident, and so these views can be taken into account when determining the application. Further guidance on battery storage and fire safety has been produced by the National Fire Chiefs.
Disagree as decision whether to commission an independent assessment should be kept flexible.
Disagree regarding first para. Developers are encouraged to consult with the fire and rescue service prior to submitting a planning application and any issues raised would be addressed as part of the planning submission.
Policy CC8 follows national guidance (NPPF para 160) by providing a positive strategy for renewable energy generation that maximises the potential for suitable development……while ensuring that adverse impacts are addressed appropriately. CC8 supports proposals where the impact on landscape character is acceptable, or can be made so. If solar pv developments were restricted only to non-agricultural land this would limit such development (after taking into account all of the other constraints that may apply to such land) and would be a barrier to the Local Plan making a legally required meaningful contribution towards addressing the climate change crisis. As national policy is to maximise renewable generation then it would not be appropriate to set a limit on area for ground mounted solar. In terms of targets, para 003 of the PPG states that ‘The National Planning Policy Framework explains that all communities have a responsibility to help increase the use and supply of green energy, but this does not mean that the need for renewable energy automatically overrides environmental protections and the planning concerns of local communities.’ It also states that: ‘The UK has legal commitments to cut greenhouse gases and meet increased energy demand from renewable sources. Whilst local authorities should design their policies to maximise renewable and low carbon energy development, there is no quota which the Local Plan has to deliver.’
Comments noted regarding 500m distance. Advice from the fire and rescue service as part of the planning application process would determine whether the location of batteries within 500m of residential properties would cause a risk to safety. The existing Wind Energy Development Guidelines published in 2006 do not have a prescribed setback distance but do indicate that a 500 m setback distance should be sufficient to prevent any significant noise impact arising from the operations of wind turbines. The 2019 Draft Wind Energy Development Guidelines propose a “visual amenity setback of 4 times the turbine height between a wind turbine and the nearest residential property, subject to a mandatory minimum distance of 500 metres”. For the Rutland Renewable Energy Study, a typical buffer of 500 m between wind turbines and residential dwellings has been implemented to mitigate noise, amenity, and safety issues. This buffer is also reflected in the wording of CC8.
Control of the reinstatement of the land would be covered by planning conditions and/or legal agreement.
Object
Regulation 18 draft Local Plan
Representation ID: 7088
Received: 07/01/2024
Respondent: Bob Chidgey
Plans for large scale solar farm schemes highlight the importance of the enforcement of Policy CC8 of the Local Plan and the need to quantify the energy required.
Comments noted. As national policy is to maximise renewable generation then it would not be appropriate to set a limit on area for ground mounted solar. In terms of targets, para 003 of the PPG states that ‘The National Planning Policy Framework explains that all communities have a responsibility to help increase the use and supply of green energy, but this does not mean that the need for renewable energy automatically overrides environmental protections and the planning concerns of local communities.’ It also states that: ‘The UK has legal commitments to cut greenhouse gases and meet increased energy demand from renewable sources. Whilst local authorities should design their policies to maximise renewable and low carbon energy development, there is no quota which the Local Plan has to deliver.’ (Remainder of objection relates to Staveley solar farm proposals.)
Support
Regulation 18 draft Local Plan
Representation ID: 7117
Received: 08/01/2024
Respondent: Tim Maskell
The requirement defining end of life return to agriculture for solar farms, should be strongly enforced – and not be allowed to be seen as a precursor to housing or non-agricultural commercial development.
The RCC should strongly canvas for a proscribed national formula for calculating community benefit arising from agreed planning of solar farms in our county.
Support noted. In line with the PPG (para 013) solar pv developments are normally temporary structures and planning conditions can be used to ensure that at the end of the life of the development, that the installations are removed and the land restored to its previous state (if greenfield/agricultural) including any biodiversity enhancements if required.
Agree regarding further clarification on community benefits.
Object
Regulation 18 draft Local Plan
Representation ID: 7120
Received: 08/01/2024
Respondent: John Williams
With regard to the development of ground mounted solar farms - the plan does not specify any minimum distance from residential properties. It should perhaps contain a distance such as 500m to reduce impacts on residential amenity.
Comments noted. Government guidance on solar farms does not include a recommended buffer zone between residential properties and the development. The distance adopted would depend partly upon an assessment of the impact on residential amenity although a buffer of 50m from between solar development and residential properties is likely to be applied when the Renewable Energy Study is updated. If solar pv developments were restricted only to non-agricultural land this would limit such development (after taking into account all of the other constraints that may apply to such land) and would be a barrier to the Local Plan making a legally required meaningful contribution towards addressing the climate change crisis. The Rutland Renewable Energy Study that identifies areas of opportunity for potential solar pv and wind turbine generator developments excluded Grades 1 and 2 in the Agricultural Land Classification (ALC). For solar pv developments Policy CC8 includes a criterion that sets a number of additional tests where the proposal is on Best and Most Versatile agricultural land (Grades 1, 2 and 3a in the ALC.). This is in line with para 180 of the NPPF that recognises the economic and other benefits of the best and most versatile agricultural land.
Object
Regulation 18 draft Local Plan
Representation ID: 7123
Received: 08/01/2024
Respondent: Mr Neil Tunstall
The council should be identifying all the brown field areas where it would like developers to apply to put renewable energy projects. It could also identify other areas away from residential housing and tourism based businesses that would be severely impacted by such a development.
I should add almost every resident I have spoken to supports the need for renewable energy but we must protect the Rutland environment by not allowing commercial enterprises to maximize their return at the expense of the character of Rutland and the wellbeing of its residents.
Comments noted. Policy CC8 (with suggested changes) sets out a sequential approach to the siting of solar developments by encouraging the development of previously developed land before greenfield land. Policy CC8 follows national guidance (NPPF para 160) by providing a positive strategy for renewable energy generation that maximises the potential for suitable development……while ensuring that adverse impacts are addressed appropriately. If solar pv developments were restricted only to brownfield sites this would limit such development (after taking into account all of the other constraints that may apply to such land) and would be a barrier to the Local Plan making a legally required meaningful contribution towards addressing the climate change crisis.
Object
Regulation 18 draft Local Plan
Representation ID: 7217
Received: 08/01/2024
Respondent: Tom Gilman Farms Ltd, VB Robinson Deceased Will Trust, WH Robinson Deceased Will Trust, TP and TM Gilman 2008 Discretionary Settlement
Agent: Edmond Harcourt
Representations supporting in general terms draft Policy CC8 (Renewable Energy) but objection to the failure of the Policy and proposals Map to recognise Glaston, Wing and Ketton Sites as a ‘ground mounted solar PV opportunity area’ on the Policies Map. It is considered that the opportunity presented at Glaston, Wing and Ketton Sites for ground mounted solar PV is able to address all matters in criteria (a) – (c) of this Policy, as well as the additional requirements of national planning policy.
Comments noted. Such sites could be considered when further detailed work on updating the Renewable Energy Study is undertaken. The wording of CC8 would not preclude support for ground mounted solar projects that lie outside the opportunity area designation on the Proposals Map. Extra para addressing assessment of sites outside of the opportunity area for ground mounted solar pv development suggested.
Object
Regulation 18 draft Local Plan
Representation ID: 7218
Received: 08/01/2024
Respondent: TP, TM and AL, HJG Gilman and Chilton
Agent: Edmond Harcourt
Representations supporting in general terms draft Policy CC8 (Renewable Energy) but objection to the failure of the Policy and proposals Map to recognise Tixover as a ‘ground mounted solar PV opportunity area’ on the Policies Map. It is considered that the opportunity presented at Tixover for ground mounted solar PV is able to address all matters in criteria (a) – (c) of this Policy, as well as the additional
requirements of national planning policy.
Comments noted. Such a site could be considered when further detailed work on updating the Renewable Energy Study is undertaken. The wording of CC8 would not preclude support for ground mounted solar projects that lie outside the opportunity area designation on the Proposals Map. Extra para addressing assessment of sites outside of the opportunity area for ground mounted solar pv development suggested.
Support
Regulation 18 draft Local Plan
Representation ID: 7226
Received: 07/01/2024
Respondent: Mr Harold Dermott
The opportunities available by requiring maximum solar PV on all buildings given Planning Permission during this Local Plan period should be considered in this policy.
It should also be part of this policy to ensure that at least 500GWh (40%) of the identified 1,231GWh of solar and wind generation facilities identified in the “Renewable Energy Study ” Parts 1 & 2 provided in the “Evidence Base” should be built and operational during the lifetime of this plan and preferably by 2030.
This document makes clear that there are no likely grid connection restrictions to this strategy for installations within the next few years and thus every reason to proceed with these installations this decade. However, that headroom reduces as 2050 is approached and requires “early engagement by RCC with the National Grid” to secure connections before available headroom is allocated” for 2050 and beyond. I trust RCC have ‘contacting National Grid’ to discuss this in their diaries for 2024
Support noted. The policy does set out a presumption in favour of allowing the installation of solar panels on existing buildings. The incorporation of renewable energy into new buildings is set out in Policy CC2. In terms of targets, para 003 of the PPG states that ‘The National Planning Policy Framework explains that all communities have a responsibility to help increase the use and supply of green energy, but this does not mean that the need for renewable energy automatically overrides environmental protections and the planning concerns of local communities.’ It also states that: ‘The UK has legal commitments to cut greenhouse gases and meet increased energy demand from renewable sources. Whilst local authorities should design their policies to maximise renewable and low carbon energy development, there is no quota which the Local Plan has to deliver.’ Policy CC10 supports proposals for upgraded or new electricity facilities such as transmission facilities.
Object
Regulation 18 draft Local Plan
Representation ID: 7234
Received: 07/01/2024
Respondent: Phil Skipper
I have and will again state my objection to both Mallard Pass and Stavely Solar farms on the basis of scale, purpose and environmental impact but also highlight this as a case in point where the plan should prioritise developments that are in themselves sustainable (for instance the installation of solar across Anglian water own sites and industrial buildings) and the use of locally sourced equipment.
The community lives the downsides of these "sustainable projects" for decades - so the plan should prioritise the lifetime value of these projects when considering their worth from a sustainability perspective.
This should be priortised in the plan along with mandating renewable energy production on all industrial and new build properties and not in farmland.
Comments noted. Not able to comment on the Mallard Pass and Staveley proposals. Cumulative impacts would be assessed as part of the planning application process. RCC has declared a Climate Crisis and has committed to taking positive action to achieve net-zero including by considering renewable energy generation. Policy CC8 follows national guidance (NPPF para 160) by providing a positive strategy for renewable energy generation that maximises the potential for suitable development……while ensuring that adverse impacts are addressed appropriately. CC8 supports proposals where the impact on landscape character is acceptable, or can be made so. If solar pv developments were restricted only to non-agricultural sites this would limit such development (after taking into account all of the other constraints that may apply to such land) and would be a barrier to the Local Plan making a legally required meaningful contribution towards addressing the climate change crisis.
In terms of sustainability, requiring details of disposal/recycling of the solar panels would be required under Policy CC8 and CC1. Given the value of solar panels and related material, there is likely to be a strong financial incentive for developers of commercial scale solar farms to sell on materials for reuse and recycling. There is a presumption in favour of granting permission for solar panels on existing buildings set out in Policy CC8 and this is also supported and encouraged in policy documents such as the NPPF and PPG, the National Design Guide (2021), Design Guidelines for Rutland (2021) and also in Local Plan Policy CC7. Policy CC2 seeks to maximise renewable energy generation on new build.
Object
Regulation 18 draft Local Plan
Representation ID: 7252
Received: 08/01/2024
Respondent: Manton Parish Council
There should be recognition that Rutland, as a small county, may find it difficult to gain public acceptance, or find suitable areas for large scale energy proposals. There are practical limits imposed on land usage. Proposals for small to medium wind turbines throughout Rutland don't make sense around Rutland Water. This suggests the scope of the RWA should be enlarged to protect the unique landscape.
Comments noted. RCC has declared a Climate Crisis and has committed to taking positive action to achieve net-zero including by considering renewable energy generation. Policy CC8 follows national guidance (NPPF para 160) by providing a positive strategy for renewable energy generation that maximises the potential for suitable development……while ensuring that adverse impacts are addressed appropriately. The Rutland Landscape Character Assessment (2022) would be used, together with Local Plan Policy SC1, to assess renewable energy applications. CC8 supports proposals where the impact on landscape character is acceptable, or can be made so. An assessment of impacts on landscape character (including cumulative impacts) would be carried out as part of the planning application process for renewable energy schemes. A Landscape and Visual Assessment would accompany a planning application for ground-mounted solar pv or wind turbine development.
Object
Regulation 18 draft Local Plan
Representation ID: 7254
Received: 08/01/2024
Respondent: Ian Mcalpine
Should say planning permission will only be granted for solar developments on agricultural land where no alternative brownfield sites ( e.g. St.George's Barracks ) are available.
Comments noted. Policy CC8 (with suggested changes) sets out a sequential approach to the siting of solar developments by encouraging the development of previously developed land before greenfield land. Policy CC8 follows national guidance (NPPF para 160) by providing a positive strategy for renewable energy generation that maximises the potential for suitable development……while ensuring that adverse impacts are addressed appropriately. If solar pv developments were restricted only to brownfield sites this would limit such development (after taking into account all of the other constraints that may apply to such land) and would be a barrier to the Local Plan making a legally required meaningful contribution towards addressing the climate change crisis. Part of the St Georges Barracks is already identified in the Local Plan as an opportunity area for ground mounted solar pv development. The Barracks are also subject to a number of other constraints/designations shown in the Local Plan that would determine the appropriateness of the site for renewable energy proposals.
Object
Regulation 18 draft Local Plan
Representation ID: 7270
Received: 07/01/2024
Respondent: Mrs Marilyn Clayton
Very large solar farms should not be allowed on large acreages of farmland. Solar panels should
surely be a building requirement for new properties and certainly industrial buildings - and also advised for existing commercial buildings eg Anglia Water works. Open countryside policy below refers.
Comments noted. Large solar farm proposals such as the Mallard Pass scheme is a Nationally Significant Infrastructure Project (as it is greater than 50 megawatts) so would be determined by the Secretary of State for DESNZ in accordance with National Policy Statements rather than the Local Plan. Such schemes (if granted) would, however, be taken into account when assessing planning applications in terms of cumulative impacts.RCC has declared a Climate Crisis and has committed to taking positive action to achieve net-zero including by considering renewable energy generation. Policy CC8 follows national guidance (NPPF para 160) by providing a positive strategy for renewable energy generation that maximises the potential for suitable development……while ensuring that adverse impacts are addressed appropriately. CC8 supports proposals where the impact on landscape character is acceptable, or can be made so. If solar pv developments were restricted only to non-agricultural sites this would limit such development (after taking into account all of the other constraints that may apply to such land) and would be a barrier to the Local Plan making a legally required meaningful contribution towards addressing the climate change crisis. There is a presumption in favour of granting permission for solar panels on existing buildings set out in Policy CC8 and this is also supported and encouraged in policy documents such as the NPPF and PPG, the National Design Guide (2021), Design Guidelines for Rutland (2021) and also in Local Plan Policy CC7. Policy CC2 seeks to maximise renewable energy generation on new build.
Object
Regulation 18 draft Local Plan
Representation ID: 7385
Received: 08/01/2024
Respondent: Morcott Parish Council
Policy lacks targets and a planned approach which will result in piecemeal developments and the county will be subject to the whims of opportunist developers who are not going to adequately consider community involvement .
Too many potential opportunity areas for renewable energy shown on the Policies map which will encourage an excessive percentage of land area to be covered.
There should be a Rutland County-wide upper limit set as part of the Local Plan for the area of land approved for solar farm sites.
Applications for renewable energy sites for Wind or Solar generation should be subject to a planning condition requiring local community involvement in the 1. Design, 2. Appearance, 3. Landscape impact and 4. Community impact of the proposed site(s). All proposal should be subject to an Environmental Impact Assessment and a Noise/Public Nuisance Assessment (Wind) and must be required to calculate and declare the whole life carbon cost of the proposals from source and use of raw materials through to end-of-life restoration and must require sustainable end of life restoration.
The policy must include robust post-installation monitoring of compliance to both standard and special planning conditions together with appropriate enforcement measures
National policy is to maximise renewable generation and there is no requirement for the council to set a target for each renewable energy type. Para 003 of the PPG states that ‘The National Planning Policy Framework explains that all communities have a responsibility to help increase the use and supply of green energy, but this does not mean that the need for renewable energy automatically overrides environmental protections and the planning concerns of local communities.’ It also states that: ‘The UK has legal commitments to cut greenhouse gases and meet increased energy demand from renewable sources. Whilst local authorities should design their policies to maximise renewable and low carbon energy development, there is no quota which the Local Plan has to deliver.’ Thermal solar and air/ground source renewable energy tends to be on small sites or individual buildings so it would not be possible to map opportunity areas for such a scale of development. Such development is, however, supported by Policy CC8.
The identifying of opportunity areas and potentially suitable areas in the Local Plan is consistent with national planning policy. Not all of the areas would necessarily be suitable for renewable energy proposals due to, say, cumulative impacts, land ownership or other constraints.
Conditions would only be applied once a renewable energy application has planning permission. Developers are required to consult with communities for developments of one or more wind turbines, and that such proposals should have community support. The government has produced Good Practice Guidance on Community Engagement and Benefits for Onshore Wind Developments. For solar farm proposals, the council will expect developers to engage with the community prior to submission of an application. The council’s Statement of Community Involvement provides further guidance on appropriate consultation methods and how the results of community consultation should be used.
Not all renewable energy schemes will be EIA development and this is determined by the EIA Regulations. The requirement for a noise assessment submitted as part of the planning application would be set out in the Council’s list of validation requirements. This would consider the construction, operation and decommissioning stages of the development.
Such requirements would go beyond those set out in national planning guidance. Control of the reinstatement of the land would be covered by planning conditions and/or legal agreement. Monitoring and enforcement of the development would be part of the LPA’s responsibilities and does not need to be set out in the policy.
Object
Regulation 18 draft Local Plan
Representation ID: 7455
Received: 08/01/2024
Respondent: Sarah Gresty
Support in General, BUT
With regards to the long process we have endured for the decision on Mallard Pass Solar Farm. I support Solar Panels on Roofs and on Industrial Building but cannot support on food productive and environmental habitat land. The Carbon Footprint over the lifetime of the project is huge and cannot be offset, I have many concerns regarding solar farms with their spurious data and decommissioning anyslis, let alone the mental health of many visitors and residents in this part of Rutland being harmed.
Solar farm proposals such as the Mallard Pass scheme is a Nationally Significant Infrastructure Project (as it is greater than 50 megawatts) so would be determined by the Secretary of State for DESNZ in accordance with National Policy Statements rather than the Local Plan. Such schemes (if granted) would, however, be taken into account when assessing planning applications in terms of cumulative impacts.
RCC has declared a Climate Crisis and has committed to taking positive action to achieve net-zero including by considering renewable energy generation. Policy CC8 follows national guidance (NPPF para 160) by providing a positive strategy for renewable energy generation that maximises the potential for suitable development……while ensuring that adverse impacts are addressed appropriately. CC8 supports proposals where the impact on landscape character is acceptable, or can be made so. If solar pv developments were restricted only to non-agricultural sites this would limit such development (after taking into account all of the other constraints that may apply to such land) and would be a barrier to the Local Plan making a legally required meaningful contribution towards addressing the climate change crisis. There is a presumption in favour of granting permission for solar panels on existing buildings set out in Policy CC8 and this is also supported and encouraged in policy documents such as the NPPF and PPG, the National Design Guide (2021), Design Guidelines for Rutland (2021) and also in Local Plan Policy CC7. Policy CC2 seeks to maximise renewable energy generation on new build.
Support
Regulation 18 draft Local Plan
Representation ID: 7496
Received: 08/01/2024
Respondent: Mrs Marlen Godwin
Am supportive of wind turbines and solar farms for renewable energy.
Support noted.
Object
Regulation 18 draft Local Plan
Representation ID: 7505
Received: 08/01/2024
Respondent: Wing Parish Council
The policies map shows a variety of “suitable” locations for solar and wind initiatives, the methodology behind these sites is not easily accessible. There is no transparency and no consultation with local communities.
It appears that the map has been generated based on geographical features, with no regard for practicality, aesthetics or local sensitivity. It seems that the same methodology has been used to identify potential sites for wind turbines or solar panels, which have very different requirements and implications.
The study should have applied height criteria when considering turbines, and different gradient criteria for turbines and solar. The map is a hostage to fortune that could be used to encourage speculative and wholly inappropriate developments.
We strongly object to the identified locations near Wing, which are not supported at this scale in our NP. In particular, the site north of the village in the Chater valley.
The study was prepared by the same consultant AECOM who also has prepared the FHS. Yet, the FHS dismisses the need for solar panels on houses and relies on decarbonising the grid to make up the necessary carbon reduction. However, the Rutland Renewable Energy Study clearly states the lack of capacity in the grid to realise the potential renewable energy generated.
What weight will be given to sustainable energy in manufacturing when set against the capacity for ‘green’ energy generation? The plan is silent on these important issues.
Comments noted. The Rutland Renewable Energy Study (parts 1 and 2) is one of the supporting pieces of evidence used for the Reg 18 Local Plan and so formed part of the suite of documents consulted on. The study is a high level initial assessment showing options of areas for further investigation. The Neighbourhood Plan, when adopted, would be part of the statutory development plan and, as set out in the supporting text, would be used to assess renewable energy schemes. Issues relating to country of manufacture and modern slavery fall outside national planning guidance and so cannot be considered in the Local Plan. The total available ‘headroom’ on the distribution network is currently 11.26 MW, which gives an annual yield generation of 15.3 GWh. This means that the availability of grid connections will likely not be a barrier to renewable energy installation up to that total capacity. It should be noted that availability of connection capacity is dynamic: it changes as new connections are agreed or grid upgrade are carried out.
Object
Regulation 18 draft Local Plan
Representation ID: 7575
Received: 08/01/2024
Respondent: Historic England
There are significant concerns and objections regarding
the proposed “broad area suitable for Larger Scale Wind
Energy Turbines" as identified on the Policies Map, its
supporting evidence base and corresponding policy.
If a wind map is to be included it should be explicit about what it is a map of and in what sense areas are defined as suitable; specifically what material considerations in respect of future planning applications have not been adequately considered in the mapping but
which would need to give great weight to designated and
equivalent heritage assets, with particular reference to
setting impacts. The approach proposed does not reflect
this.
Consequently, it is considered that the approach of Policy
CC8, the Renewable Energy Study and the
corresponding ‘Wind Map for broad areas suitable for
Larger Scale wind Energy Turbines’ does not comply with
the NPPF:-
The plans showing wind areas cannot support a sound
Local Plan policy in relation to renewable energy, as they
are not based on a robust evidence base or methodology
nor do they adequately address the historic environment
as set out above. As such, the wind map with the areas
shown should not be included in its present form. The evidence base is not robust nor the wind map acceptable as set out above.
Comments noted. Agree further text required explaining which principal constraints have been used in the mapping of the potentially suitable areas in the Rutland Renewable Energy Study and what other site specific constraints would need to be applied in the assessment of a planning application for wind energy development. A similar approach is used in the text accompanying the Central Lincs renewable energy policy.
Object
Regulation 18 draft Local Plan
Representation ID: 7577
Received: 08/01/2024
Respondent: Historic England
The areas which have been identified in the Renewable Energy Study as being suitable for such developments may result in harm to a number of Rutland’s most important designated heritage assets and hence render policy CC8 incompatible with the NPPF’s overarching objectives of sustainable development and specifically paragraph 196.
Consequently, it is considered that the approach of Policy
CC8, the Renewable Energy Study and the corresponding ‘Wind Map for broad areas suitable for Larger Scale wind Energy Turbines’ does not comply with the NPPF.
Whilst criteria a) “heritage assets, their settings and the
historic landscape” is welcomed and a robust assessment
would be required and should be specified within policy
CC8, similar to the requirement for criteria c), as
proposed the policy is not sufficient and the evidence
base is not robust nor the wind map acceptable as set out
above.
Comments noted. Disagree as explanation in policy about compliance with part a) is via applicable policies in the Local Plan (including EN12)/any relevant Neighbourhood Plan and a future SPD.
Object
Regulation 18 draft Local Plan
Representation ID: 7638
Received: 08/01/2024
Respondent: Edward Heckels
Wind or solar farms should only be considered on brown field sites. There are a number of wind farms that have appeared on the Local Plan. Whilst renewable energy is commendable, the potential damage of locating these on unsuitable locations too close to housing or in the areas too close to the flight routes of migrating birds or to protected breeding grounds would rule a considerable number of the new sites suggested on the map.
Comments noted. Policy CC8 (with suggested changes) sets out a sequential approach to the siting of solar developments by encouraging the development of previously developed land before greenfield land. Policy CC8 follows national guidance (NPPF para 160) by providing a positive strategy for renewable energy generation that maximises the potential for suitable development……while ensuring that adverse impacts are addressed appropriately. If solar pv developments were restricted only to brownfield sites this would limit such development (after taking into account all of the other constraints that may apply to such land) and would be a barrier to the Local Plan making a legally required meaningful contribution towards addressing the climate change crisis. The Proposals Map only shows ‘opportunity areas’ for ground-mounted solar and areas ‘potentially suitable’ for wind turbine development in accordance with Government guidance. Being within these locations does not mean that an application for such renewable energy would automatically be approved. Issues relating to impact on residential amenity and biodiversity would be assessed against Policy CC8 and other Local/Neighbourhood Plan policies.
Object
Regulation 18 draft Local Plan
Representation ID: 7642
Received: 08/01/2024
Respondent: Mr Robert Bolton
I object to Regulation 18 and the draft local plan, namely policy CC8 – Renewable Energy – as large scale solar farms should not be allowed on any productive farmland.
Solar should be a mandatory requirement for all new dwellings and industrial buildings, and further encouraged on domestic, industrial and commercial buildings to facilitate green energy and protect our food security and maintain the Rutland countryside for future generations.
This would encourage a huge uptake and rollout of solar, benefitting local businesses with no detrimental implications or negative impacts.
Comments noted. Large solar farm proposals (such as the Mallard Pass scheme) is a Nationally Significant Infrastructure Project (as it is greater than 50 megawatts) so would be determined by the Secretary of State for DESNZ in accordance with National Policy Statements rather than the Local Plan. Such schemes (if granted) would, however, be taken into account when assessing planning applications in terms of cumulative impacts.
Policy CC8 (with suggested changes) sets out a sequential approach to the siting of solar developments by encouraging the development of previously developed land before greenfield land. Policy CC8 follows national guidance (NPPF para 160) by providing a positive strategy for renewable energy generation that maximises the potential for suitable development……while ensuring that adverse impacts are addressed appropriately. If solar pv developments were restricted only to brownfield sites this would limit such development (after taking into account all of the other constraints that may apply to such land) and would be a barrier to the Local Plan making a legally required meaningful contribution towards addressing the climate change crisis. The Proposals Map only shows ‘opportunity areas’ for ground-mounted solar and areas ‘potentially suitable’ for wind turbine development in accordance with Government guidance. Being within these locations does not mean that an application for such renewable energy would automatically be approved. Issues relating to impact on residential amenity and biodiversity would be assessed against Policy CC8 and other Local/relevant Neighbourhood Plan policies.
Object
Regulation 18 draft Local Plan
Representation ID: 7672
Received: 08/01/2024
Respondent: South Luffenham Parish Council
Background documents indicate what energy might be derived from wind turbines or ground solar PV. Has any analysis been undertaken to review existing electrical infrastructure and if Statutory Authorities infrastructure can accommodate any new generation. Open spaces in rural county might be far apart and significant distance/cost for DNO extend their infrastructure to effect connection to renewable energy source. Impact on landscape.
Comments noted. The Rutland Renewable Energy Study considers capacity of the grid and concludes that the total available ‘headroom’ on the distribution network is currently 11.26 MW, which gives an annual yield generation of 15.3 GWh. This means that the availability of grid connections will likely not be a barrier to renewable energy installation up to that total capacity. It should be noted that availability of connection capacity is dynamic: it changes as new connections are agreed or grid upgrade are carried out. The impact of a renewable energy proposal, including any overhead grid connection, would be assessed against Policy CC8 and other relevant policies in the Local/relevant Neighbourhood Plan. Policy CC10 supports proposals for upgraded or new electricity facilities such as transmission facilities.
Object
Regulation 18 draft Local Plan
Representation ID: 7695
Received: 08/01/2024
Respondent: Cllr Abigail West
Our allocation of sites suitable for wind turbines will lead to a rush of applications which we may regret, and will likely leave us with no grounds to reject in places where they may be unpopular. Crowding of sites will be unpopular and regrettable. I appreciate that this is a big step forward for us in relation to the previous local plan where there were very few sites allocated as suitable for turbines.
The policy states that sites within 500-2000m of residential will require additional proofs. On the flip side of my statement above, this is onerous and will need more thought.
Comments noted. The Local Plan identifies areas potentially suitable for wind turbine development, and provides a positive strategy for energy from these sources in accordance with the requirements of national planning policy (NPPF para 160). The alternative, (ie not identifying any potentially suitable areas), would mean that applications could only be approved if an area was identified in a neighbourhood plan: this could result in no or very limited development, which would not be in line with Rutland’s Strategic Objective to take positive action to achieve net-zero and would be a barrier to the Local Plan making a legally required meaningful contribution to addressing the climate change crisis. Cumulative impacts of wind turbine proposals would be assessed as part of the planning application. Guidelines on wind energy development propose a “visual amenity setback of 4 times the turbine height between a wind turbine and the nearest residential property, subject to a mandatory minimum distance of 500 metres”. For the Rutland Renewable Energy Study that forms part of the supporting evidence for the Local Plan, a typical buffer of 500 m between turbines and residential dwellings was used to mitigate noise, amenity, and safety issues. This buffer is also reflected in the wording of CC8.
Object
Regulation 18 draft Local Plan
Representation ID: 7733
Received: 08/01/2024
Respondent: Anglian Water
On policy CC8 Renewable Energy infrastructure we note that the majority of our operational sites are not included on the policy map for ground based solar or wind turbine locations. Anglian Water would welcome the inclusion of all our operational sites and land parcels in close proximity on the map to ensure we can deliver our net zero ambitions either involving the installation of our own arrays or where we are working with a third party and will seek a private wire connection such as at the proposed solar farm near Wing Water Treatment Works. This can also provide resilience to water and wastewater network ensuring that with more extreme weather events being more prevalent they continue to function providing essential services. If the map is not amended or policy support for renewables at vital infrastructure sites included in the new plan, then this will limit where Anglian Water can realistically look to invest and locate new arrays and turbines. We would suggest that to be an effective policy it needs to set out the actual targets for renewables to deliver the Councils overall climate targets and incentivise investment in Rutland’s green energy transition.
Comments noted. Unclear whether such operational sites have been excluded from the solar panel/wind turbine opportunity areas as part of the initial high-level assessment. Such sites could form part of the next stage of the assessment (a review of the Renewable Energy Study) to be used to inform the next stage of the local plan. The wording of CC8 would not preclude support for ground mounted solar projects that lie outside the opportunity area designation on the Proposals Map as would small to medium turbines not be precluded outside the areas potentially suitable for wind turbines.
Object
Regulation 18 draft Local Plan
Representation ID: 7825
Received: 07/01/2024
Respondent: CPRE Rutland
There needs to be much restraint on the use of land for renewable energy installations, in particular solar panels. There are already proposals for solar farms in Rutland which would cover far more than the Government's target for the use of land for this purpose; there must be some practical limit imposed and measures to ensure that Best and Most Versatile land remains available for agricultural purposes.
Reference is made to the installation on existing roofs. Consideration must also be given to requiring solar panels to be fitted on all new buildings, not just residential, unless there is good reason not to.
The introduction includes heat pumps in the list of possible technologies, but there seems to be no mention of these at all in the policy itself. The Council's policy on heat pumps should be made clear.
Under 'Additional matters for wind-based energy proposals', what are 'criteria (i)-(iii)'? Also the charity has concerns about how the phrase “Single small to medium wind turbines will be in principle be supported throughout Rutland” will be interpreted.
A comprehensive SPD to support development control of solar energy installations is required as part of the Local Plan and should be subject to consultation before the Regulation 18 consultation can be considered complete.
Similarly, the Wind Turbines SPD from November 2012 needs to be fully revised and consulted upon in order to ensure effective protection for the landscape of the county with respect to the location of any associated developments.
CPRE Rutland objects to this policy as currently drafted.
As national policy is to maximise renewable generation then it would not be appropriate to set a limit on area for ground mounted solar. In terms of targets, para 003 of the PPG states that ‘The National Planning Policy Framework explains that all communities have a responsibility to help increase the use and supply of green energy, but this does not mean that the need for renewable energy automatically overrides environmental protections and the planning concerns of local communities.’ It also states that: ‘The UK has legal commitments to cut greenhouse gases and meet increased energy demand from renewable sources. Whilst local authorities should design their policies to maximise renewable and low carbon energy development, there is no quota which the Local Plan has to deliver.’ The Rutland Renewable Energy Study that identifies areas of opportunity for potential solar pv and wind turbine generator developments excluded Grades 1 and 2 in the Agricultural Land Classification (ALC). For solar pv developments Policy CC8 includes a criterion that sets a number of additional tests where the proposal is on Best and Most Versatile agricultural land (Grades 1, 2 and 3a in the ALC.). This is in line with para 180 of the NPPF that recognises the economic and other benefits of the best and most versatile agricultural land.
There is a presumption in favour of granting permission for solar panels on all existing buildings set out in Policy CC8 and this is also supported and encouraged in policy documents such as the NPPF and PPG, the National Design Guide (2021), Design Guidelines for Rutland (2021) and also in Local Plan Policy CC7. Policy CC2 seeks to maximise renewable energy generation on new build.
ASHPs are often permitted development (particularly on existing dwellings) but where planning permission is required such proposals would be supported under Policies CC2, CC7 and CC8.
Agree. Criteria (i) – (iii) should read criteria a) – c). The support in principle for single small to medium wind turbines in the policy accords with national planning policy, and the wording of CC8 makes it clear that such proposals would still be assessed against criteria a) – c).
Policy CC8 includes reference to a SPD as part of the assessment under criteria a). This would update the current Wind Turbines SPD that will no longer form part of the Local Plan. Consultation with this revised SPD would be carried out as part of the Local Plan consultation process and in accordance with the Council’s Statement of Community Involvement. It would become a material consideration in determining planning applications for renewable energy developments. `
Object
Regulation 18 draft Local Plan
Representation ID: 7835
Received: 08/01/2024
Respondent: Alicia Kearns
the Local Plan must include clear parameters for solar development to ensure Rutland is not disproportionately affected by the rollout of solar.
In order to strengthen the Plan’s protection of agricultural land from solar development there needs to be a specific proportion of BMV land listed as disqualifying a site included in policy CC8. The Council should select either a proportion or square acreage of BMV land that would disqualify proposed solar plants from gaining approval in Rutland. I would recommend this should be where over 20% of the land is classified as BMV.
Furthermore, the Local Plan should introduce protections for grade 3B land, which although not being classified as BMV is still good quality agricultural land, with a caveat that this restriction can be overruled if the land can be returned to agriculture after the project should also be removed.
The Local Plan has over forty areas highlighted as being potentially suitable for ground mounted solar. Has the land classification for each of these sites been checked?
A preference for wind energy over solar energy for projects on agricultural land should be included in the Local Plan.
The Local Plan could investigate setting out minimum community compensation expectations from developers to ensure that local communities benefit from solar and wind installations near their homes.
As national policy is to maximise renewable generation then it would not be appropriate to set a limit on area for ground mounted solar. In terms of targets, para 003 of the PPG states that ‘The National Planning Policy Framework explains that all communities have a responsibility to help increase the use and supply of green energy, but this does not mean that the need for renewable energy automatically overrides environmental protections and the planning concerns of local communities.’ It also states that: ‘The UK has legal commitments to cut greenhouse gases and meet increased energy demand from renewable sources. Whilst local authorities should design their policies to maximise renewable and low carbon energy development, there is no quota which the Local Plan has to deliver.’ Cumulative impacts would be assessed as part of the planning application process.
The Rutland Renewable Energy Study that identifies areas of opportunity for potential solar pv excluded Grades 1 and 2 in the Agricultural Land Classification (ALC). For solar pv developments Policy CC8 includes a criterion that sets a number of additional tests where the proposal is on Best and Most Versatile agricultural land (Grades 1, 2 and 3a in the ALC.). This is in line with para 180 of the NPPF that recognises the economic and other benefits of the best and most versatile agricultural land.
In line with the PPG (para 013) solar pv developments are normally temporary structures and planning conditions can be used to ensure that at the end of the life of the development, that the installations are removed and the land restored to its previous state (if greenfield/agricultural) including any biodiversity enhancements if required.
Solar pv offers the potential for the greatest generation of renewable energy in Rutland and it would not be appropriate to set a preference for wind energy over solar energy in the local plan. Solar is a key part of the government’s strategy for low-cost decarbonisation of the energy sector. Solar also has an important role in delivering the government’s goals for greater energy independence and the British Energy Security Strategy states that government expects a five-fold increase in solar deployment by 2035 (up to 70GW). The Government is supportive of solar that is co-located with other functions (for example, agriculture, onshore wind generation, or storage) to maximise the efficiency of land use. Solar farms can be built quickly and the generation of renewable electricity and associated reduction in greenhouse gas emissions would make a positive contribution towards achieving the UK Government's legally binding emissions reduction targets as well as contribute to achieving Rutland County Council’s objectives related to the declared Climate Crisis. The policy already has a presumption in favour of permission for solar panels on existing buildings in accordance with national planning policy so cannot be strengthened.
Community benefits are a voluntary package of benefits (usually financial in nature) that renewable energy businesses, including for large scale solar projects, provide to support communities in which they operate. Community funds or investments (e.g., Community Benefits Trust, local share issue, community ownership) do not meet the criteria set out for planning obligations, and as such cannot be considered as part of the decision-making process on planning applications. They would be encouraged but a matter for discussion between the developer and the community. It would not, therefore, to appropriate to include details of community compensation expectations in the Local Plan.
Support
Regulation 18 draft Local Plan
Representation ID: 7879
Received: 08/01/2024
Respondent: Ryhall Parish Council
- Support in General, with exception as below.
We are awaiting a decision re Mallard Pass Solar Farm, which has gone through a lengthy process.
We support Solar Panels on Roofs and on Industrial Building but cannot support on Greenbelt Land. The Carbon Footprint over the lifetime of the project is huge and cannot be offset. Would rather have wind turbines.
Support noted. As there is no greenbelt in Rutland it is assumed that the comments refer to greenfield land. Policy CC8 (with suggested changes) sets out a sequential approach to the siting of solar developments by encouraging the development of previously developed land before greenfield land. Policy CC8 follows national guidance (NPPF para 160) by providing a positive strategy for renewable energy generation that maximises the potential for suitable development……while ensuring that adverse impacts are addressed appropriately. If solar pv developments were restricted only to greenfield land this would limit such development (after taking into account all of the other constraints that may apply to such land) and would be a barrier to the Local Plan making a legally required meaningful contribution towards addressing the climate change crisis. Solar pv offers the potential for the greatest generation of renewable energy in Rutland and it would not be appropriate to set a preference for wind energy over solar energy in the local plan.
Object
Regulation 18 draft Local Plan
Representation ID: 8017
Received: 08/01/2024
Respondent: Mr PJRS Hill and Pikerace Limited
Agent: Silver Fox Developments
We support in general terms draft Policy CC8 (Renewable Energy) but objection to the failure of the Policy and proposals Map to recognise Woolfox as a ‘ground mounted solar PV opportunity area’ on the Policies Map. It is considered that the opportunity presented at Woolfox for ground mounted solar PV is able to address all matters in criteria (a) – (c) of this Policy, as well as the additional requirements of national planning policy.
Comments noted. The renewables opportunity areas have been generated using a variety of constraint layers. One or more of these constraints will have resulted in the exclusion of Woolfox from the mapping. The mapping will be revisited as part of the Regulation 19 Plan.