Local Plan Issues and Options (Regulation 18)

Comment

Representation ID: 13637

Received: 28/07/2025

Respondent: Qair UK

I&O_14156
The evidence base proposed does not include a new renewable energy sensitivity study. Given the change in Green Belt policy and the incorporation of Grey Belt in the NPPF this would be expected to inform any renewable energy policy. Furthermore, the previous study is almost a decade old, in which time both the technology and policy context have significantly changed. For example, the renewable energy study does not recognise the declaration of the climate change emergency by Cheshire West and Chester in 2019. Furthermore, technology has significantly progressed along with the need for renewable energy developments. A 25-hectare solar farm is not considered to be ‘very large’ in modern day solar development. Given the significant need for renewables, the declaration of a climate change emergency, the updated Green Belt policy context, it would be expected that ‘suitable’ areas for renewable energy development are identified as part of the emerging Local Plan.

Comment

Representation ID: 13705

Received: 28/07/2025

Respondent: Qair UK

I&O_14225
The Evidence Base includes the ‘Tyndall Centre Climate Emergency Report (2019)’ within which it states: CO2 emissions in the carbon budget related to electricity use from the National Grid in Cheshire West and Chester are largely dependent upon national government policy and changes to power generation across the country. It is recommended however that Cheshire West and Chester promote the deployment of low carbon electricity generation within the region and where possible influence national policy on this issue. This acts as another reason why the LPA needs to designate suitable areas for renewable energy development taking into account the location of grid connections and should feed into an updated report on sensitivity to renewable energy development.

Comment

Representation ID: 13706

Received: 28/07/2025

Respondent: Qair UK

I&O_14226
The current Local Plan (Part One) policy STRAT 9 may need to be updated if required to set out approach to grey belt and to reflect Green Belt review evidence (to be prepared). Do you agree with the suggested policy approach towards Green Belt and countryside, as set out in GB 1 ‘Green Belt and countryside’ above? If not please suggest how it could be amended. Any Green Belt Assessment should consider the contribution of all areas of the Green Belt not just areas relating to settlements. The new Green Belt evidence base should incorporate a Grey Belt Assessment covering all parcels not just those considered relevant for residential or commercial development. This will assist in determining suitable areas for renewable energy assets as set out in paragraph 165 of the Framework.

Comment

Representation ID: 13707

Received: 28/07/2025

Respondent: Qair UK

I&O_14227
Paragraph 28.3 refers to the threshold for energy developments to be considered under the Planning Act 2008. The threshold stated is 50MW however, as of 31st December 2025 this will be increased to 100MW and should be noted. The Evidence Base regarding landscape sensitivity and Renewable Energy Study will be over a decade old upon preparation of the Draft Plan. The evidence documents refer to out of date policy requirements and do not look appropriate in the preparation of new planning policies for example, the document refers to the ‘draft NPPF’ and there is no inclusion of detailed guidance contained within the National Policy Statements (EN-1 and EN-3). The Energy Opportunity Map for the LPA does not show the suitability of solar, it only includes hydropower and wind sites. This should be updated to better accord with paragraph 165 of the Framework. Paragraph 5.3 of the Landscape Sensitivity Study sets out the thresholds for the size of solar schemes, notable ‘very large solar farms’ are considered to be anything over 25 hectares in size. This is no longer the case, 25 hectares nowadays would be considered small to medium. Very large sites would likely be over 100 hectares as these sites could still be in the TCPA regime. Taken in turn, the following comments are made regarding the outlined criterion: 1. There is no mention of the role of an available grid connection which is the main driver behind the location of renewable energy development. If the LPA wants to prioritise PDL and industrial areas, a guide as to available sites and their distance from the nearest point of connection would be highly recommended. Otherwise, it is a restrictive criterion with a very low likelihood of compliance for new projects. 2. This conflicts with criterion 1 which looks to prioritise industrial areas which are those most likely to retain employment designations. This reinforces the need for an evidence document identifying available PDL parcels and their proximity to a point of connection. If they are designated for alternative uses then they should not be considered ‘available or deliverable’. 3. See points 1 and 2. 4. This is not consistent with national policy. Paragraph 187 of the Framework only requires the ‘economic and other benefits of BMV land to be recognised’ this is not a blanket requirement to avoid all BMV land. Furthermore, there should be recognition that agricultural land practices can still continue on the land for some renewable energy development.  

Comment

Representation ID: 13710

Received: 28/07/2025

Respondent: Qair UK

I&O_14230
All recent research shows that the biggest threat to food production, viability, food security etc. is climate change. Research from the Energy and Climate Intelligence Unit (ECIU) suggests the wet winter of 2023-24 has reduced the UK’s ability to feed itself by nearly a tenth. This is the biggest challenge of a generation and there are demanding targets to hit for solar installation (45 – 47 GW of solar by 2030 and approx. 70GW by 2035). It is widely known and reported of the difficulties delivering this quantum of solar on rooftops given technical/ suitability issues, ownership issues, fire and insurance risk etc. To achieve the targets set, there requires a mix of both ground mounted and rooftop solar. In delivering these targets it is considered that less than 1% of all UK farmland would be temporarily required. Solar farms are only temporary development which often allow for continued agricultural use, their impact on food production is negligible as outlined in the Food Security Strategy issued by the UK Government. Food production can be best protected by responding to climate change and allow for diversification of farms to allow a dual income to stabilise their finances. Previous years have seen the most dramatic seasonal weather with severe droughts and flooding attributed to the impacts of climate change. Allowing farmers to diversify their income is the best way to ensure viability of farm holdings. Solar farms offer the potential for long-term, stable revenue, allowing farmers to lease parts of their land for renewable energy production without compromising their ability to farm. There is no requirement in planning terms for farmers to farm the land for food production as represented by multiple appeal decisions. The weight to be afforded to this issue is therefore minimal. It would be more productive for the authority to promote diversification of farms and agrivoltaics, promoting the use of renewable energy and food production within the same farm holding. To reinforce this point NFU have backed the solar sector and condemned “sensationalist” claims about food security referencing that it is a small amount of land being taken out of production. Furthermore, this question does not recognise the significant environmental benefits by taking land out of intensive agriculture which has previously led to a substantial decline in biodiversity. The benefits of solar farms on biodiversity are now widely reported and understood and therefore this needs to also be a part of the discussion when assessing the impacts of solar farms on available farmland. It should be recognised in Local Plan policy. Ground mounted solar developers are led entirely by the grid when determining the location of development. This should be recognised when considering the impact on BMV land. In most instances there are simply no alternatives then to use an element of BMV land. Indeed, when approaches are made to farmers they often guide the most appropriate locations for solar development so they can retain the best agricultural land parcels for food production.

Comment

Representation ID: 13713

Received: 28/07/2025

Respondent: Qair UK

I&O_14233
Taking the criterion in turn: 1. Agree that a landscape sensitivity assessment should be a consideration for a planning application. However, this assessment should be updated to better represent updated policy considerations along with increased technical efficiencies of the technology. Whilst the landscape may not have significantly changed, the policies relating to it have. The inclusion of Grey Belt within the framework and the increase in size of solar developments are a consideration which needs to be incorporated into any sensitivity study. Appendix B of the landscape sensitive study refers to the Low Carbon and Energy Study (2012), this should also be updated taking into account the now, better understood, constraints associated with new energy development such as proximity to point of connection etc. 3. Agree with this policy and should replicated or represented in policy EN 1. Potential for agrivoltaics to be given materially beneficial weight in the determination of a planning application to further encourage it.