Regulation 19 Rutland Local Plan
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Regulation 19 Rutland Local Plan
Policy CC8 - Renewable Energy
Representation ID: 8459
Received: 02/12/2024
Respondent: RWE Renewables UK
Agent: Stantec
RWE supports the basis of the policy, that renewable energy schemes will be supported subject to the direct, indirect, individual, and cumulative impacts.
RWE also supports the use of a spatial designation to indicate areas of in-principle support for solar energy generation, which provides a degree of certainty to the market and roots the provision of renewable energy infrastructure in the spatial plan for the local authority area. Often this type of area-based designation is reserved for other forms of development and this
choice reflects the focus on mitigating the impacts of climate change in the Council’s Vision
and Strategic Objectives.
It is not clear however, what benefit the Opportunity Area designation provides schemes for the following reasons:
▪ The wording ‘more likely to be supported’ in relation to schemes within the identified Opportunity Areas is too subjective to provide additional certainty that schemes should be directed to these locations.
▪ A scheme will not benefit from the Opportunity Area designation if the proposed use of any agricultural land is shown to be necessary.
Some benefits of a scheme, such as the ability for agricultural production to continue during the operation of the energy generation, or whether it can recommence after the end of life of the energy generation equipment without significant impact on the quality of that
agricultural land, would currently result in the proposal not benefitting from the Opportunity Area designation
There is a need to provide a clear justification for the suitability of developments sites for
solar proposals where they are not within the identified Opportunity Areas. T
Support
Regulation 19 Rutland Local Plan
Policy CC9 - Protecting Renewable Energy Infrastructure
Representation ID: 8460
Received: 02/12/2024
Respondent: RWE Renewables UK
Agent: Stantec
RWE is pleased to see the use of a policy to ensure that the continued operation of existing or approved renewable energy infrastructure is unaffected by future development schemes.
Support
Regulation 19 Rutland Local Plan
Policy CC4 - Net zero carbon (operational)
Representation ID: 8461
Received: 02/12/2024
Respondent: RWE Renewables UK
Agent: Stantec
RWE is highly supportive of this policy, which suggests support for the principle of overplanting on development sites for ground mounted solar PV.
Object
Regulation 19 Rutland Local Plan
Policy EN6 - Protecting agricultural land
Representation ID: 8464
Received: 02/12/2024
Respondent: RWE Renewables UK
Agent: Stantec
Legally compliant? Not specified
Sound? Yes
Duty to co-operate? Not specified
the policy wording is not useful because it does not indicate which circumstances Grade 3 land would be permitted for Solar PV development which is required to meet the requirements of CC8.
The phrase “grade 1 and 2 will be ruled out for renewable energy use” is inconsistent with the NPPF, which provides that where significant development of agricultural land is
demonstrated to be necessary, areas of poorer quality land should be preferred to those of a higher quality first.
So long as this approach is demonstrated, Grade 1 and 2 land should not necessarily be ruled out.
Support
Regulation 19 Rutland Local Plan
Whole Plan
Representation ID: 8467
Received: 02/12/2024
Respondent: RWE Renewables UK
Agent: Stantec
RWE is pleased to see that the Council has progressed the Draft Plan within a relatively short timeframe, especially given the fluctuating legislative and policy context of the last few years. RWE is keen to support the Council with achieving its programme, which includes examination in 2025
RWE is generally supportive of the draft policies contained within the Draft Plan. Particularly those which relate to renewable energy generating infrastructure. Nonetheless, specific comments have been provided to ensure that the Draft Plan contains policies that are clearly written and unambiguous, so it is evident how a decision maker should react to development proposals, as is required of plans by NPPF paragraph 16. This would support a plan which is consistent with national policy, which is a necessary test of soundness.
Support
Regulation 19 Rutland Local Plan
Chapter 3 – Vision and Objectives
Representation ID: 8468
Received: 02/12/2024
Respondent: RWE Renewables UK
Agent: Stantec
RWE is strongly supportive of the proposed vision. Particularly the fact that addressing the impacts of climate change and the need to become carbon net zero are central to it.