BASE HEADER

Do you agree with the approach laid out in Draft Policy D: Large Scale Renewable Energy Generation and Storage?

Yn dangos sylwadau a ffurflenni 121 i 147 o 147

No

Preferred Options 2025

ID sylw: 103967

Derbyniwyd: 07/03/2025

Ymatebydd: Mr Martin Potter

Crynodeb o'r Gynrychiolaeth:

Renewables could be better and cheaper if supplied on buildings and built up areas leaving Land for food production or future housing.
This should be a matter for central Government such as Nuclear and off shore.

Yes

Preferred Options 2025

ID sylw: 104041

Derbyniwyd: 07/03/2025

Ymatebydd: Mr Stephen Norrie

Crynodeb o'r Gynrychiolaeth:

This policy declares the Councils supports renewable developments in principle, except under certain conditions. I broadly support this. However, condition (f), applied to wind developments, is too strong, to the extent of making them impossible. It seems that the Councils are not in fact supportive of wind ‘in principle’, but rather the opposite.

The policy might also refer to a standard of reasonableness, and provide estimates of the limits of generation limits of rooftop solar as some people think it could replace rural solar farms.

No

Preferred Options 2025

ID sylw: 104048

Derbyniwyd: 07/03/2025

Ymatebydd: Ms Donna Green

Crynodeb o'r Gynrychiolaeth:

The policy should be to encourage (or insist) the fixing of solar panels on new buildings (homes and commercial) rather than creating solar panel farms on agricultural land. If solar panel farms are created there must be an obligation to use those solar panels that move with the migration of the sun - thereby generating more energy on a smaller footprint than fixed solar panels.

The ability of the country to feed itself must be taken into account. Each solar panel farm on agricultural land reduces that ability.

Yes

Preferred Options 2025

ID sylw: 104399

Derbyniwyd: 07/03/2025

Ymatebydd: South Warwickshire Foundation trust

Crynodeb o'r Gynrychiolaeth:

Yes, broadly agree and the approach seems sound and well thought out. However, it should be noted the biodiversity aspect is crucial, especially as it can directly affect community health and environmental resilience. More emphasis on ensuring green spaces and biodiversity is not affected and how, as well as the inclusion of green infrastructure, such as tree planting or wildlife corridors, alongside renewable energy schemes would provide a more holistic approach to addressing biodiversity.

Yes

Preferred Options 2025

ID sylw: 104402

Derbyniwyd: 07/03/2025

Ymatebydd: Mr Neal Appleton

Crynodeb o'r Gynrychiolaeth:

Agree, but such large-scale generation schemes should not have to provide for a community benefit as described.

Other

Preferred Options 2025

ID sylw: 104649

Derbyniwyd: 07/03/2025

Ymatebydd: John Stott

Crynodeb o'r Gynrychiolaeth:

Ground mounted solar is compatible with agriculture but some loss of agricultural productivity is inevitable. Item C could be interpreted as meaning no reduction in agricultural productivity and could exclude ALC 1,2 & 3a. Item C needs softening to allow some reduction in agricultural productivity. Suggested wording :-

C. Higher agricultural land (Grades 1, 2, and 3a) if the development does not prevent the land not occupied by solar infrastructure being used for agriculture and the solar infrastructure design provides a balanced optimisation of both agricultural and solar yield.
A similar point applies to Wind Energy.

No

Preferred Options 2025

ID sylw: 104658

Derbyniwyd: 07/03/2025

Ymatebydd: Miss Ann Colley

Crynodeb o'r Gynrychiolaeth:

Solar is not the most ideal form of power production on farmland. All houses that are built should have their own solar panels, therefore, the developers house designs whatever size should accomodate the required panels to power the property. The use of tidal power should be invesgiated and utilised. Farm bio-gas units should be encouraged.

No

Preferred Options 2025

ID sylw: 104728

Derbyniwyd: 07/03/2025

Ymatebydd: Mrs Sarah Whalley-Hoggins

Crynodeb o'r Gynrychiolaeth:

Using any sort of agricultural land for solar panels is reckless in terms of destruction to the open Countryside and this country's food security. The criteria for development need to be far more robust or some areas of South Warwickshire will loose their rural identity.

Yes

Preferred Options 2025

ID sylw: 104742

Derbyniwyd: 07/03/2025

Ymatebydd: Mr Ian Dunning

Crynodeb o'r Gynrychiolaeth:

Build it all everywhere.

Other

Preferred Options 2025

ID sylw: 104802

Derbyniwyd: 07/03/2025

Ymatebydd: Dr Susan Hood

Crynodeb o'r Gynrychiolaeth:

Emphasis should be on building/industrial solar rather than large scale ground mounted - a) this is where the energy will be utilised and b) large available space without impacting land use.

Yes

Preferred Options 2025

ID sylw: 104896

Derbyniwyd: 07/03/2025

Ymatebydd: Ms Susan Ingleby

Crynodeb o'r Gynrychiolaeth:

Yes. Very much so. But I'm concerned that recent approvals of solar farms in the Fosse corridor do not meet criteria a) to d)

Yes

Preferred Options 2025

ID sylw: 105257

Derbyniwyd: 26/02/2025

Ymatebydd: Stratford upon Avon District Council

Crynodeb o'r Gynrychiolaeth:

Renewable Energy Generation
Support the principle of renewable generation and storage but the development of solar farms must be spread across the whole of South Warwickshire and not concentrated in specific areas creating a cumulative factor and must not result in significant adverse impacts on the local environment, including landscape character and flooding issues.
Support the proposals for increased community benefits in terms of either profit sharing or proportion of community ownership or deliver local, social and community benefits.
Support the principle of wind energy and energy storage. although this part of Warwickshire is not that windy!

Yes

Preferred Options 2025

ID sylw: 105629

Derbyniwyd: 06/03/2025

Ymatebydd: Cllr Eileen Edwards

Crynodeb o'r Gynrychiolaeth:

Renewable Energy Generation

Support the principle of renewable generation and storage but the development of solar farms must be spread across the whole of South Warwickshire and not concentrated in specific areas creating a cumulative factor and must not result in significant adverse impacts on the local environment, including landscape character and flooding issues.

Support the proposals for increased community benefits in terms of either profit sharing or proportion of community ownership or deliver local, social and community benefits.

Support the principle of wind energy and energy storage. although this part of Warwickshire is not that windy!

All new housing must have solar pv panels on their roofs – this must be a condition of planning for every new dwelling.

Other

Preferred Options 2025

ID sylw: 106284

Derbyniwyd: 04/03/2025

Ymatebydd: Mr Paul Darnell

Crynodeb o'r Gynrychiolaeth:

Renewable Energy Generation
Support the principle of renewable generation and storage but the development of solar farms must be spread across the whole of South Warwickshire and not concentrated in specific areas creating a cumulative factor and must not result in significant adverse impacts on the local environment, including landscape character and flooding issues.
I recommend all new domestic and commercial properties fitted with solar pv panels on their roofs as a condition of planning.

No

Preferred Options 2025

ID sylw: 106435

Derbyniwyd: 05/03/2025

Ymatebydd: Porterbrook Mid Leasing Company

Asiant : Planning Prospects

Crynodeb o'r Gynrychiolaeth:

Porterbrook supports the draft policy in principle but the policy must include flexibility so that its criterion are only applicable to relevant types of large scale renewable energy generation and storage and where necessary for certain development sites. This is because some proposals for large scale renewable energy generation will be contained within previously developed sites and will not impact upon open countryside or result in adverse impacts on the local environment, landscape character, local amenity or local communities, and as such should not be required to provide wider community benefits by way of mitigation. Similarly, it would not be appropriate in all instances for all land around every renewable energy facility that is currently not used for agriculture to deliver carbon sequestration benefits and to protect local ecosystems, habitat or enhance biodiversity over and above the statutory requirements that would already be applied to relevant development in any event. Generally speaking, parts A. And B. Of the draft policy are supported and should be encouraged in accordance with sustainable development principles which underpin planning policy in any event. Part C. However will not apply to all proposals for large scale renewable energy generation and storage as in some instances the energy generated will be needed by those proposing the energy generation and storage in the first instance. In such circumstances, there should be no requirement for profit sharing or community ownership etc. As this will not be possible and would represent a planning policy burden that is unnecessary to make the development acceptable in planning terms, not directy related to the development proposed and would not be fairly and reasonably related in scale and kind to the development proposed. For similar reasons, the wording after ‘cessation’ should be removed from part D. Of the draft policy as in some instances any large scale renewable energy generation and storage proposals would comprise an ancillary use to a wider principal use at a site and therefore there would not always be a requirement to restore the site to an original or alternative use.

Other

Preferred Options 2025

ID sylw: 106574

Derbyniwyd: 06/03/2025

Ymatebydd: Mr Edward Muntz

Asiant : Sworders

Crynodeb o'r Gynrychiolaeth:

The policy states that “where development other than solar farm development is proposed on sites identified on Figure 16 as land suitable for Ground Mounted Solar PV (score >0.9), development in those areas will be expected to install solar PV, this could be either rooftop or ground mounted”. As set out in our comments to the HELAA part B, we are sceptical as to the reliance that can be placed on the conclusions of the Renewables and Decentralised Energy Opportunities report (May 2024). This fails to
have regard to any of the main factors which determine whether a site is suitable for ground mounted solar schemes. Fundamentally, the costs involved in doing so, the grid capacity and the land availability for such use. The report itself notes these limitations, stating that:
“Please note that a more detailed feasibility and techno-economic assessment, as well as consideration of grid connections and landscape impact, will be needed for any specific sites selected for renewable energy.”
Notwithstanding our concerns with the report, Figure 10 of the report relates to ground mounter solar, yet Draft Policy D seeks to extend this roof mounted solar and reach the assumption that these can only be provided in areas deemed suitable for ground mounted solar. This is not what the report says, and there is no other evidence that supports this approach. This policy as drafted would financially disadvantage sites within these areas, and represents an inconsistent and unevidenced approach.

Other

Preferred Options 2025

ID sylw: 106594

Derbyniwyd: 07/03/2025

Ymatebydd: The Umberslade Estate

Asiant : Sworders

Crynodeb o'r Gynrychiolaeth:

The policy states that “where development other than solar farm development is proposed on sites identified on Figure 16 as land suitable for Ground Mounted Solar PV (score >0.9), development in those areas will be expected to install solar PV, this could be either rooftop or ground mounted”. As set out in our comments to the HELAA part B, we are sceptical as to the reliance that can be placed on the conclusions of the Renewables and Decentralised Energy Opportunities report (May 2024). This fails to have regard to any of the main factors which determine whether a site is suitable for ground mounted solar schemes. Fundamentally, the costs involved in doing so, the grid capacity and the land availability for such use. The report itself notes these limitations, stating that:
“Please note that a more detailed feasibility and techno-economic assessment, as well as consideration of grid connections and landscape impact, will be needed for any specific sites selected for renewable energy.”
Notwithstanding our concerns with the report, Figure 10 of the report relates to ground mounter solar, yet Draft Policy D seeks to extend this roof mounted solar and reach the assumption that these can only be provided in areas deemed suitable for ground mounted solar. This is not what the report says, and there is no other evidence that supports this approach. This policy as drafted would financially disadvantage sites within these areas, and represents an inconsistent and unevidenced approach.

Other

Preferred Options 2025

ID sylw: 106896

Derbyniwyd: 06/03/2025

Ymatebydd: Historic England

Crynodeb o'r Gynrychiolaeth:

Historic England welcomes inclusion of heritage and landscape character impacts as criteria against which schemes for large-scale energy generation and storage will be considered. However, we suggest the word ‘local’ is removed from the phrase ‘local heritage’ and the policy should instead refer to both designated and non-designated heritage assets.

We note Figure 16 for ground mounted solar PV and the intention to undertake further work to inform site allocations for solar and wind energy. To ensure that the historic environment is fully considered in such work, we advise undertaking the process of ‘Site Selection Methodology’ set out in Historic England’s Advice Note 3 The Historic Environment and Site Allocations in Local Plans, 2015 (HEAN3), to ensure the plan is positively prepared.

We also direct you to our guidance on commercial renewable energy: Historic England Advice Note 15 (February 2021) ‘Commercial Renewable Energy
Development and the Historic Environment’:

https://historicengland.org.uk/images-books/publications/commercial-renewableenergy-development-historic-environment-advice-note-15/heag302-ommercialrenewable-energy-development-historic-environment/

No

Preferred Options 2025

ID sylw: 107263

Derbyniwyd: 07/03/2025

Ymatebydd: Cotswolds National Landscape Board

Crynodeb o'r Gynrychiolaeth:

development in the setting of the CNL is not adequately addressed.

No, the Cotswolds National Landscape (CNL) Board does not agree with the approach laid out in Draft Policy D.
The over-arching principles set out in Draft Policy D are generally sound. However, we have a number of concerns about some of the detail of the Policy. These concerns include:
i.A lack of explicit reference to the CNL - and to how development within the CNL should be addressed - within Draft Policy D
ii.A lack of explicit reference to how development in the setting of the CNL should be dealt with.
iii.The fact that the identification of suitable areas for wind and solar energy does not factor in landscape sensitivity (other than by excluding the CNL).
Cotswolds National Landscape

Firstly, we are concerned that the Policy makes no explicit mention of the CNL. This is surprising given that the Renewables and Decentralised Energy Opportunities report, which is referred to in the Policy, rules out large-scale wind and solar energy development in the CNL.31 We support this approach, which is consistent with the Board’s Renewable Energy Position Statement32 and with the statutory duty to seek to further the purpose of conserving and enhancing the natural beauty of the CNL33. Large-scale wind and solar energy would constitute major development, in the context of paragraph 190 of the National Planning Policy Framework, which sets a presumption against such development.

Setting of the Cotswolds National Landscape
Secondly, we are concerned that neither Draft Policy D (or the Renewables and Decentralised Energy Opportunities report) address how development in the setting of the CNL should be addressed. Nor do they differentiate between development in the setting of the CNL and development that is not in the setting. This is an important consideration because development in the setting of the CNL has the potential to adversely affect the natural beauty of the CNL. Paragraph 189 of the NPPF states that great weight that should be given to conserving the landscape and scenic beauty of National Landscapes.35 Case law has clarified that this great weight applies in relation to the impact of development outside a National Landscape on views from the National Landscape.

Because of this lack of differentiation, several of the locations that have been identified as being suitable for large scale solar energy are located in very close proximity to the CNL boundary.
Map showing the areas that have been identified as being suitable for large scale solar energy in the vicinity of the Cotswolds National Landscape
Key:
•Green shading = areas identified as being suitable for large-scale solar energy development.
•Black hatching = Cotswolds National Landscape (CNL).
•Grey shading = CNL 3km buffer.

Many of the identified locations would be overlooked from elevated viewpoints on public rights of way (PROW) within the CNL. These elevated viewpoints are in landscape character types (LCTs) where the views that are experienced in (and from) these LCTs are one of the LCTs’ key features / characteristics. In some cases, the identified locations would be overlooked from viewpoints on the Cotswold escarpment (LCT 2) (for example, the locations near Oxhill and Avon Dassett). This is particularly significant as views from (and to) the escarpment are one of the ‘special qualities’ of the CNL.
Depending on the scale and proximity of potential solar energy schemes in these locations, and the elevation of the viewpoints from which they would be overlooked, such schemes could potentially have a significant adverse effect on these views from the CNL.
One option to address this issue would be to exclude large scape solar energy proposals on sites that are within, say, 1km of the CNL boundary or within 3km of LCTs that have ‘views’ as one of their key features / characteristics. An alternative approach would be to use a landscape sensitivity assessment to help direct the location of large-scale schemes (see below).
Similar principles apply in relation to large-scale wind energy development in the setting of the CNL, which, arguably would have a bigger adverse impact on the natural beauty of the CNL than large-scale solar energy development.

Landscape Sensitivity
Our third concern is that the Councils have not factored in landscape sensitivity into the identification of suitable sites or into Draft Policy C.
In the Board’s Renewable Energy Position Statement, we state that the identification of ‘suitable areas’ for wind and solar energy should be underpinned by a landscape sensitivity assessment (LSA) and by consideration of constraints that relate to the natural beauty of the CNL, including nature conservation and historic environment designations (in addition to infrastructure constraints and other technical considerations).38 The Position Statement recommends that:
•suitable area mapping should exclude areas of high landscape sensitivity (at least within the CNL) and key constraints;
•renewable energy schemes should be targeted towards areas of relatively low landscape sensitivity.
The extent to which locations would be overlooked from elevated views within the CNL should be taken into consideration in the LSA.
This is the approach that has been taken by Bath & North East Somerset Council, for example, who commissioned a landscape sensitivity assessment,39 which now underpins the renewable energy policies in their local plan (at least in relation to wind energy)40.
Not surprisingly, LSAs tend to identify that landscape character types within the CNL have a relatively high landscape sensitivity to large-scale wind and solar energy development. However, LSAs can be particularly useful in identifying areas of relatively low landscape sensitivity, particularly within the setting of the CNL.
Recommendations
The Board recommends that Draft Policy C should:
•explicitly state that large-scale wind and solar energy development in the CNL will not be supported;
•recognise that sites within the setting of the CNL are likely to have a higher sensitivity to large-scale wind and solar energy development than sites further afield;
•be underpinned by a landscape sensitivity assessment, with large scale wind and solar energy being steered towards areas of relatively low landscape sensitivity.

No

Preferred Options 2025

ID sylw: 107315

Derbyniwyd: 09/03/2025

Ymatebydd: Campaign to Protect Rural England - Warwickshire

Crynodeb o'r Gynrychiolaeth:

The draft Policy is incompatible with protecting the landscape of South Warwickshire, views from higher ground and viable agriculture. It places support for renewable energy (solar farms, wind farms) and battery storage over protection of the landscape and its character. Wind turbines, solar arrays in fields and BESS are industrial impositions. Solar arrays on industrial and commercial roofs should be supported instead; these are not mentioned in the Policy. Only by preventing solar on farm and open land will it be placed on roofspace. The Policy should be rewritten to give priority to roof solar and resist solar on farmland.

Other

Preferred Options 2025

ID sylw: 107358

Derbyniwyd: 06/03/2025

Ymatebydd: National Trust

Crynodeb o'r Gynrychiolaeth:

Energy related policies – The National Trust are taking a proactive approach towards future proofing the places that we care for in terms of energy use, carbon emissions and climate resilience and adaptation. This has incorporated the installation and operation of biomass boilers and ground source heat pumps elsewhere in the Midlands.
The National Trust are supportive of renewable energy generation, given the benefits that this could deliver in respect of reducing carbon emissions and addressing climate change through the removal of the use of fossil fuels. We recognise the scale and complexity of the challenge to the nation of transitioning to renewable energy and acknowledge that any impacts upon the
Cont/d
5
setting and significance of special places across the country will need to be considered in light of the pressing need to deliver clean energy, alongside a balance of the public benefits. Nevertheless, we believe delivering renewable energy projects sensitively with respect for the setting and significance of places is possible and all such proposals should aim to do so. We would therefore recommend that any proposal for renewable energy is assessed in the context of the special places that the National Trust care for and seek appropriate mitigation where necessary.

Yes

Preferred Options 2025

ID sylw: 107451

Derbyniwyd: 16/02/2025

Ymatebydd: Moreton Morrell Parish Council

Crynodeb o'r Gynrychiolaeth:

Support the principle of renewable generation and storage but the development of solar farms must be spread across the whole of South Warwickshire and not concentrated in specific areas creating a cumulative factor and must not result in significant adverse impacts on the local environment, including landscape character and flooding issues.
Support the proposals for increased community benefits in terms of either profit sharing or proportion of community ownership or deliver local, social and community benefits.
Support the principle of wind energy and energy storage. although this part of Warwickshire is not that windy!
All new housing must have solar pv panels on their roofs – this must be a condition of planning for every new dwelling.

Other

Preferred Options 2025

ID sylw: 107536

Derbyniwyd: 07/03/2025

Ymatebydd: Warwickshire Wildlife Trust

Crynodeb o'r Gynrychiolaeth:

WWT propose the Councils need more emphasis on roof top solar which should be the default. Need more emphasis on and encouragement for biodiversity and BNG on-site.

Other

Preferred Options 2025

ID sylw: 107608

Derbyniwyd: 07/03/2025

Ymatebydd: National Highways

Crynodeb o'r Gynrychiolaeth:

National Highways agrees with the approach for renewable energy generation and
storage in principle. However any site which comes forward in close proximity to the
SRN would be subject to a full review and consultation with National Highways.

Yes

Preferred Options 2025

ID sylw: 107632

Derbyniwyd: 06/03/2025

Ymatebydd: Napton Parish Council

Crynodeb o'r Gynrychiolaeth:

We broadly agree with the approach. Whilst there is Draft Policy D for Large Scale Renewables, the context against smaller scale systems and energy conservation should have more emphasis. The wind profile for Central England is not particularly promising - the National Wind Database suggests average wind speeds of 6.2m/s 45m above ground level. The equivalent figure in a western coastal area might be about 7.2m/s. Power is proportional to the cube of the wind speed, so the same installation would be about 56% more effective at the coast for these sample speeds.

Whilst it is relative, within the Districts the Arup study unsurprisingly prioritises areas of ‘hilly landscapes’ for wind generation by dint of higher windspeeds. The policy should seek to balance visual harm against energy generation rather than agricultural land classification. In this respect, single farm scale turbine masts are likely to have better balance in terms of impact rather than large scale wind farms.

Other

Preferred Options 2025

ID sylw: 108327

Derbyniwyd: 07/03/2025

Ymatebydd: George Martin

Crynodeb o'r Gynrychiolaeth:

Local schemes have a significant role. They are often faster to deliver, less impactful on the local environment, and support and create jobs in local communities by keeping energy bills lower. (Therefore, LAs have a really important role to play!)

I’m not sure the authors have seen beyond major wind farms and solar parks etc – there’s actually a lot they can do to support local district energy schemes, onsite generation in factories and business parks etc. The main problem can be planners who think this is the same class of planning problem as a nuclear power station or offshore wind farm, and approach the case with that mentality!

Agree mandating solar panels would reduce the need for large-scale renewable energy developments (though not negate it). This is especially true in Warwickshire, which has relatively poor renewable resources. Note that farms can also do a lot with Anaerobic digestion and small/mid scale (<1MW) wind turbines; industrial parks should all have their own (shared) energy centres etc.

Consider adding a requirement that applicants for large-scale schemes can demonstrate they have considered smaller-scale local options and included consultation on these as alternatives with local communities.

Energy storage can be used by industrial sites to hedge against volatile and typically very expensive UK electricity prices - not entirely clear this is covered by the 3 criteria, although maybe k cover this case (contributes to meeting renewable energy supply), but could be more explicit and linked to economic benefits for the customer.

Good to see criteria k - I would suggest some demonstrated consultation with the electricity network operator would be a good idea somewhere.

The Policy should define a 'wind farm' to highlight that these are different from rooftop wind turbines.

The statement that 'further technical work will be undertaken to establish the area's overall energy requirements and the specific sites for allocation for solar and wind energy" is very vague.

Yes

Preferred Options 2025

ID sylw: 108391

Derbyniwyd: 07/03/2025

Ymatebydd: Alscot Estate

Asiant : Jonathan Thompson Land & Consultancy Limited

Crynodeb o'r Gynrychiolaeth:

The Estate as a principle, support methods to assist the Councils to achieve a net zero future and therefore have no in principle objections to the purpose of this policy.