Yes

ID sylw: 92273

Derbyniwyd: 28/02/2025

Ymatebydd: SolStar Power Limited

Asiant : Enzygo

SolStar Power consider the new Local Plan Strategic Objectives have been strengthened from the adopted plan, to include the commitment to become a net zero carbon area. Further comments are provided in the attached letter (SHF.3100.001).

Yes

ID sylw: 92274

Derbyniwyd: 28/02/2025

Ymatebydd: SolStar Power Limited

Asiant : Enzygo

Whilst SolStar Power agree with the approach laid out in this Draft Policy Direction, it is considered that the policy could be strengthened. Further comments are provided in the accompanying letter (SHF.3100.001).

Yes

ID sylw: 92276

Derbyniwyd: 28/02/2025

Ymatebydd: SolStar Power Limited

Asiant : Enzygo

SolStar Power support Draft Policy Direction 18, but consider that the draft policy could be further expanded.

Yes

ID sylw: 92277

Derbyniwyd: 28/02/2025

Ymatebydd: SolStar Power Limited

Asiant : Enzygo

SolStar Power agree with Draft Policy D, it’s a step forward in achieving the UK’s climate goals and securing its energy security and the proposed scheme will assist in the Government’s ambition to achieve net zero emissions by 2050.
SolStar Power consider that identifying suitable locations for renewable / low carbon energy technologies and associated infrastructure would significantly constrain these types of developments unnecessarily and would not support renewable energy developments. Renewable energy is subject to various site specific constraints and therefore to only allocate certain areas of Stratford-on-Avon and Warwick would be too restrictive and may prevent developments coming forward.
Grid constraints is also a significant factor for renewable energy developments, with development only being viable when they are in close proximity to an available local grid connections. However, it is felt that the policy focuses on agricultural land, as discussed below in Draft Policy Direction 49. Location is determined by a number of factors including grid connection, environmental considerations and landowners’ willingness. We consider that unless the Council has up to date information on grid capacity (which is always changing) then identifying areas/locations should not take place unless a specific site is submitted through the call for sites process with an evidenced agreed point of connection which should then be allocated in the subsequent SWLP. This is exactly the situation with Claverdon PC, and the site submitted into the Call for Sites. We consider the SWLP should contain positively worded policies for renewable energy rather than areas.
Whilst SolStar Power agrees with Draft Policy D, we recommend clarity over the Draft Policy D title referring to ‘Large Scale Renewable Energy Generation and Storage’, as no definition is provided on what is classed as large scale within the policy. In addition, large scale is not referred to throughout the policy, only renewable energy generation and storage and specific types of generation, for example ground mounted solar and wind energy development. Furthermore, if there is a ‘Large Scale Renewable Energy Generation and Storage’ category, it is required that an additional policy referring to ‘Small Scale Renewable Energy Generation and Storage’ should be included and the scale again clarified, and this should be clearly reflected in the title to Draft Policy D.
SolStar Power does agree with the constraints outline in Table 7: Filter used to identify sites for ground -mounted solar PV. It is key to consider the environmental impacts as part of any development, and SolStar Power agree with the fixed constraints. South Warwickshire has areas of Green Belt across both Stratford on-Avon and Warwick, with Green Belt sites having to be released (if a suitable Point of Connection is available) for a temporary period for renewable energy generation to reach the net zero 2050 target.
Accordingly, it is agreed that Green Belt is not considered a constraint within Table 7. SolStar Power strongly agrees with part c. of the general section of Draft Policy D, in relation to providing a community benefit such as community ownership. SolStar Power have partnered with Claverdon Parish Council to deliver a community led solar farm with a generating capacity of approximately 7MW. The Parish Council, on behalf of the local residents are seeking to provide a renewable energy project, which the adopted Neighbourhood Plan includes a positively worded policy (Policy NE3). The community led solar farm will be delivered through an agreement between the Parish Council and a SPV, the owners of which will deliver and manage the operational activity of the site. A newly formed Community Interest
Company (CIC) will the eventual recipient of the pay away providing the financial power to create a sustainable green community with locally run projects that will help households convert to renewable energy so enabling the reduction of the parish council's carbon footprint, give a positive contribution to energy security and the climate emergency, particularly considering the number of households in
Claverdon Parish whose energy is provided from oil which is expensive and has a high carbon footprint. As discussed in Draft Policy Direction 49, renewable energy generation and energy storage projects are a temporary use and are recognised to improve agricultural land when it’s taken out of cultivation for a period of time, as well as the biodiversity enhancements that are provided alongside renewable energy generation projects.
SolStar Power supports a strategic policy setting out key climate change principles that development should seek to achieve. However, it is considered that such a strategic policy should include a certain degree of flexibility whereby site factors are considered and where it can be justified using evidence that certain climate change principles would impact viability of the development then the requirements of the policy should be reduced, and alternative mitigation sought. SolStar Power welcome the new Local Plan emphasising and promoting renewable energy generation and energy storage development, in light of
Stratford-on-Avon’s declaration of Climate Emergency in July 2019, with their targets aligning national targets to become net-zero by 2050.

Other

ID sylw: 92278

Derbyniwyd: 28/02/2025

Ymatebydd: SolStar Power Limited

Asiant : Enzygo

No further comments to what is provided under Draft Policy D.

Also, no comments for Draft Policy E-K and Draft Policy Direction 22-24.

Yes

ID sylw: 92279

Derbyniwyd: 28/02/2025

Ymatebydd: SolStar Power Limited

Asiant : Enzygo

SolStar agrees with the general policy approach to safeguarding the best and most versatile agricultural
land as it is keeping with national policy, as expressed in paragraph 188 footnote 65 of the NPPF,.
SolStar Power agrees with the Draft Policy recognition to renewable energy generation and energy storage development on agricultural land.
It is recognised that renewable energy generation projects, such as solar farms, are a temporary use and during that time provide environmental benefits to the land.
SolStar consider that inclusion of the phrase ‘Developments should be assessed on a case by case basis
considering the merits and benefits of the scheme against any concluded impacts’ should be included within the policy or the justification of the policy, and the justification should clearly set out renewable energy development as being a suitable form of development that requires the use of agricultural land.

Other

ID sylw: 92280

Derbyniwyd: 28/02/2025

Ymatebydd: SolStar Power Limited

Asiant : Enzygo

No further comments to what is provided under Draft Policy Direction 49.

Also have no comments for Draft Policy Direction 36-48.