Other

ID sylw: 106594

Derbyniwyd: 07/03/2025

Ymatebydd: The Umberslade Estate

Asiant : Sworders

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

ID sylw: 106595

Derbyniwyd: 06/03/2025

Ymatebydd: The Umberslade Estate

Asiant : Sworders

Site Ref ID 41
As the HELAA part B scores will be an important consideration in the selection of sites for allocation within the SWLP, it is imperative that the method of assessing these is consistent and robust, so as not to erroneously or unintentionally discount suitable sites. Paragraph 3.13 of the HELAA methodology states in relation to how part B scores influence site selection in decision making that scores are not decisions; they are a tool to inform decision making. Site 41, as part of SG24, should not be considered less favourable as a result of the inconsistencies and errors raised in HELAA part B, which have resulted in a considerably higher score than is warranted and is not representative of the site’s suitability for development.
As a result of the unclear application of the combined weighting factor in the assessment, however, and as detailed in our earlier comments, whilst we have demonstrated that the site’s score should be considerably lower, it is not possible to calculate what the correct overall score should be.
We strongly recommend site 41 is taken forward irrespective of the decision re SG24.

Other

ID sylw: 106597

Derbyniwyd: 06/03/2025

Ymatebydd: The Umberslade Estate

Asiant : Sworders

Site ref ID: 58
We strongly agree with the result for the sites to be Further Assessed, however, we do consider the sites should have been scored lower in the HELAA results, for the reasons set out below.
We would also request clarity as to the application of the harm and mitigation weighting factors, which is not sufficiently provided in the HELAA methodology. Whilst paragraphs 3.9 to 3.11 do provide a brief background, we are unclear whether a consistent approach has been applied to the weighting factor in respect of all criteria.
We disagree with the approach taken in relation to the Spatial Growth Strategy Priority Areas, as set out in paragraph 3.8, whereby the highest weighing factors are reserved for these areas. Whilst we appreciate the importance of these sites, this places all other sites, including new settlements at an unjust advantage in the assessment as it results in a lower score, particularly in consideration of paragraph 3.12 of the methodology, which confirms that scores closest to zero are more favourable.
The approach fails to consider the potential for mitigation in these areas, as set out in Table 3b of the methodology, placing them at a disadvantage in comparison to other sites. This does not represent a consistent approach and does not allow the true comparison of the suitability of sites. It also seems to be a counter-intuitive approach; the Spatial Growth Strategy Priority Areas are deemed to be
fundamental to the success of the SWLP yet they score higher and less favourably than any other site.
We would request full transparency and explanation as to the application of the weighted scores.