8. Planning for renewable energy

Background

8.1 The council has pledged to provide the leadership to enable South Gloucestershire to become carbon neutral by 2030. The decarbonisation and decentralisation of the energy system in the UK is essential to mitigating climate change. We know there is a need to significantly increase renewable and low-carbon energy generation in South Gloucestershire.

8.2 In addition to its contribution to mitigating the effects of a changing climate, increasing the generation of renewable and low carbon energy can also bring wider environmental and economic benefits and improve the security of our energy supply.

8.3 The term ‘renewable energy’ covers those energy flows that occur naturally and repeatedly in the environment – from the wind, the fall of water, the movement of the oceans, from the sun and also from biomass and deep geothermal heat (National Planning Policy Framework). It produces little or no net carbon dioxide, which is one of the main greenhouse gas emissions that causes anthropogenic climate change.

Local Plan 2020: Phase 1 – Issues and Approaches consultation document (Nov 2020 to March 2021)

8.4 Through the Phase 1 consultation document, we shared a new draft policy in relation to renewable and low carbon energy systems and asked some key questions in relation to our proposed approach. Much of the feedback received related more to policy areas that were being developed for future stages of Local Plan preparation, including in relation to energy management in new development.

8.5 The feedback received highlighted that:

  • it is appropriate for the council to show leadership and where possible, support communities to bring forward renewable energy generation
  • renewable energy generation is important and will bring environmental and economic benefits
  • subject to further consideration and development of detailed policy criteria, there was broad consensus that the proposed approach, which included identifying suitable areas for renewable energy and safeguarding land, was appropriate
  • further detail is needed on the process by which land or sites would be safeguarded through the Local Plan

Local Plan 2020: Phase 2 – Urban, Rural and Key issues (February 2022 to April 2022)

8.6 Through the Phase 2 consultation document, we shared our thinking about how we can develop a positive strategy for renewable energy generation in South Gloucestershire. We highlighted that an important part of doing this would involve directing development of standalone wind and solar renewable energy installations to specific areas and in some cases safeguard land to facilitate delivery.

8.7 The feedback received highlighted that:

  • support for general principles proposed for developing a strategy for renewable energy through the Local Plan
  • there are concerns in relation to the potential impacts of solar and wind technologies in specific areas within South Gloucestershire, particular concern regarding large turbines in sensitive areas
  • the identification of specific sites for future energy generation will need to be approached sensitively
  • there is a need for the right checks and balances to be put in place through policy to protect amenity and the area’s valued and distinctive natural and historic environments
  • it is important that future development of renewable energy generation is not at the expense of opportunities for farming/ local food production
  • opportunities to re-power/ upgrade existing renewable energy generating development should be encouraged
  • broad support for facilitating community-led renewable and low carbon energy generation
  • there are a growing number of local groups interested in community-led renewable energy projects

8.8 Much of the feedback received related more to policy areas that were being developed for Phase 3 of Local Plan preparation, including in relation to requiring the use of domestic scale renewables through our approach to energy management in new development.

Planning for renewable energy generation

8.9 Through its new Local Plan, the council will provide a planning framework to significantly increase onshore renewable energy generation, including geothermal, at all scales, from domestic to large-scale commercial development in South Gloucestershire*
(*The generation of renewable energy offshore is outside of the council’s remit. Instead, proposals for energy generation in these areas are considered by the Marine Management Organisation unless they would generate more than 100 megawatts (MW) in which case they require a development consent order granted by the Secretary of State.)

8.10 Through our proposed approach to energy management in new development, we will, through setting an energy hierarchy, require applicants to maximise on-site renewable energy generation to achieve an annual net zero energy balance. Read our proposed policy on energy management in new development.

8.11 In addition to this, the council recognises the direct additional benefits of supporting communities to develop their own community renewable projects, similar to those seen in Bristol. With this in mind, we have proposed a policy aimed at encouraging community schemes, recognising those additional benefits and ensuring they are given weight within the decision-making process. These schemes can be fully owned/ controlled by the community or through a partnership with commercial or public sector parties. Community energy projects can include community-owned renewable electricity installations such as solar PV panels, wind turbines or hydroelectric generation. Read our proposed policy on community-led renewable energy schemes.

8.12 The focus of this part of the Local Plan is to facilitate the delivery of large or commercial-scale renewable energy schemes. Large-scale renewable energy generation is defined as those installations which are freestanding or standalone, are not building-mounted or wired through a building to support the onsite energy balance.

8.13 As at 2022, 263GWh of renewable energy was generated in South Gloucestershire – which is the equivalent to 4% of South Gloucestershire’s average annual energy consumption from heat, electricity and transport. This clearly demonstrates the scale of the challenge we face and underlines the need for a step change in the way we approach planning for renewable energy in South Gloucestershire.

8.14 As set out in the Phase 2 consultation document, our focus is primarily on wind and solar renewable energy because:

  • these resources provide the most opportunities in South Gloucestershire, compared to other resources such as hydropower
  • they are ‘mature’ technologies in that they are technically well developed, widely used globally and cost effective, and can be deployed rapidly
  • they have the most significant spatial implications of all types of renewable energy generating development;
  • this is consistent with national policy and the Government’s Net Zero Strategy, and
  • the council, as the local planning authority, can play an important role in their delivery

8.15 Through Phase 2, we also set out some key principles that underpin our emerging approach, including that: a mix of onshore wind and solar technology is necessary; opportunities to deliver ‘big’ wind energy generation (1MW and 2.5MW turbines) are finite, and therefore they should be safeguarded to maximise opportunity; and opportunities for co-location of new renewable energy generation with other complimentary land uses should be explored. With the above we have developed a permissive, positively worded criteria-based policy aimed at facilitating the delivery of renewable energy in South Gloucestershire.

What we are seeking your views on now

8.16 At this stage we want to test our emerging policy approach to planning for renewables seeking your views on:

  • the general approach to proposals for renewable energy generation
  • safeguarded areas for wind
  • other areas potentially suitable for wind energy development

General approach to proposals for renewable energy generation

8.17 The starting point of our emerging policy approach is that we need a step change in the way we consider proposals for renewable energy development if we are to significantly increase generation in South Gloucestershire. With this in mind, we consider that proposals for the generation of renewable energy should be generally supported. To be clear, this does not however mean that we will support renewable energy development at all costs, as there are other important issues that should be taken into account in assessing the suitability of proposals put forward.

8.18 Clearly there is a need for the potential harm caused by such development to be considered, and this should be weighed against the benefits that individual proposals may bring, including any wider environmental benefits.

8.19 In considering development proposals, a number of factors will need to be taken into account including the: contribution it would make to our objectives; potential impacts on residential amenity, potential impact, including cumulative impacts on the natural and historic environment among other things; contribution to objectives around Green Infrastructure and sustained increase in biodiversity, and; potential to promote continued agricultural use alongside energy generation. These considerations will apply to proposals for all renewable and low carbon energy development.

8.20 Allied to the need to provide policy support for proposals for renewable and low carbon energy generating development, it is considered that fossil fuel-based energy installations are not compatible with our objectives. On this basis, we consider they will only be acceptable where it can be demonstrated that no other alternative is available.

Approach to solar energy generation

8.21 Through our Phase 2 consultation document, we explained that even after areas covered by planning constraints are removed from further consideration, large areas of South Gloucestershire are potentially suitable for solar development.

8.22 Following further consideration, as the ground mounted solar resource is widespread across South Gloucestershire, we are not proposing to safeguard specific areas of land through the new Local Plan.

8.23 We also noted that, whilst we removed areas of high-quality agricultural land (Grades 1 and 2) from consideration, there was a need to give further though to how we could reduce the impact on ‘best and most versatile’ agricultural land, which comprises Grades 1, 2 and 3a. With this in mind, we consider it appropriate to provide general policy support for ground mounted solar development, where it can be demonstrated that they are not sited on the best and most versatile agricultural land unless significant benefits can be shown to outweigh the temporary loss of the land to use for renewable energy generation. This provision is considered to strike an appropriate balance in that the potential solar resource is widespread and the amount of best and most versatile agricultural land is limited and therefore should be avoided unless robust and compelling justification can be provided.

8.24 We have prepared a draft policy which sets out key criteria against which proposals for solar development should be considered, in addition to general criteria that relate to all proposals for renewable and low carbon energy development. Find out more and submit your comments.

General approach to wind energy generation

8.25 In Phase 2, we set out the findings of the Renewable Energy Resource Assessment Study (RERAS) and noted that there is a stark contrast between the widespread nature of the areas potentially suitable for solar development and the finite areas potentially suitable for wind development.

8.26 National planning policy makes clear that LPAs should only grant planning permission for wind development in suitable areas that are identified in the Local Plan. So, with this in mind, we proposed different policy responses for these two technologies, which includes safeguarding areas of land for wind development, in line with the approach recommended through the RERAS.

8.27 To be clear, the safeguarding of areas for wind does not mean that the principle of wind development in these locations is agreed, or that planning permission will be granted in these areas. Safeguarding is a material planning consideration that seeks to protect potential future infrastructure projects from conflicting development but does not in itself rule out alternative types of development within these areas.

8.28 The areas proposed for safeguarding were identified through a high-level technical exercise, which focussed on areas where wind speeds sufficient to support wind development exist. Owing to its scale, this process did not consider important issues, such as potential impacts on the historic environment, including specific heritage assets, or landscape or ecology, as these issues are more appropriately considered through individual proposals as they come forward. Therefore, proposals for wind development within safeguarded areas will still stand to be considered on a case-by-case basis through the planning application process and against the relevant policies in the Local Plan and other material planning considerations as relevant.

8.29 Furthermore, in line with national planning policy, proposals for all wind development should have community support with the planning concerns of the community dealt with. To this end, it is very important for those promoting commercial schemes to engage with local communities at an early stage in developing proposals.

8.30 We have prepared a draft policy which sets out key general criteria against which proposals for wind development should be considered, in addition to general criteria that relate to all proposals for renewable and low carbon energy development. Find out more and submit your comments.

Safeguarded areas for wind

8.31 Through Phase 2 we published the areas we are proposing to safeguard for ‘big’ wind development, including a standard buffer in order to prevent sterilisation of the resource opportunity by other land uses, including residential development.

8.32 Since Phase 2, we have reconsidered our position slightly and are now proposing that those areas should be safeguarded for wind development. This alteration of our approach reflects that some of those areas proposed for safeguarding are in close proximity to important heritage assets and landscape features where the potential for ‘big’ wind development may be more limited, but there may be potential for smaller scale to come forward. This updated approach, we consider, provides a degree a flexibility, consistent with our overall desire to increase renewable energy generation across South Gloucestershire to bring forward wind development, balanced against the need to protect high value environmental assets.

8.33 You can submit your comments on the areas proposed for safeguarding through our interactive map.

8.34 As part of this approach, within those defined areas proposed for safeguarding, we think that development not associated with wind should only be permitted in specific, limited circumstances, with the aim of avoiding their sterilisation for potential future wind development and maximising potential, in line with our evidence base.

8.35 While the general factors to be considered for all renewable energy (outlined above) remain relevant to proposals for wind within safeguarded areas, with the need to affect a step change in mind, there may also be other material considerations that are capable of attracting weight to counter any harm identified. For example, the need to significantly increase generation and the scarcity of potential opportunity are also material considerations that may attract weight in the overall planning balance, as part of the decision-making process.

8.36 We have prepared a draft policy which sets out key criteria against which proposals for wind energy development within the proposed safeguarding areas should be considered, in addition to general criteria that relate to all proposals for wind energy and renewable and low carbon energy development. Find out more and submit your comments.

Other areas potentially suitable for wind energy development

8.37 In addition to the proposed safeguarding areas specifically for wind energy, in the context of our need to significantly increase renewable energy generation, we consider that strategic development sites being delivered through the Local Plan process and safeguarded employment sites may be suitable in principle for wind development, subject to the consideration of relevant issues, such as for example (but not restricted to):

  • in the case of safeguarded employment sites, proposals for wind energy development should not impact upon the operation of existing, viable businesses.
  • in the case of strategic sites being promoted for residential-led development, safety considerations will need to be taken into account, in addition to all other relevant policy considerations

8.38 Also, as trailed in Phase 2, we consider that if communities or developers wish to bring forward proposals for wind energy through the Local Plan process, we could consider the potential to safeguard or even allocate specific areas of land to facilitate their delivery.

Community energy proposals

8.39 As set out above, we are keen to encourage the development of community energy proposals, for the direct and wider benefits they can bring. To this end, we have developed a new draft policy which sets out our emerging approach to proposals to develop community-led energy schemes or schemes that will demonstrably benefit a community. Find out more and submit your comments.

8.40 In order to facilitate such proposals, we propose that the entirety of South Gloucestershire is effectively designated as area of search for community wind energy. It is however important to note that this area is only potentially suitable, and any proposals that come forward will stand to be assessed against the detailed policy criteria set out the proposed policy on Renewable and Low Carbon Energy Systems, all other relevant policies in this Local Plan, as well as policies in any relevant neighbourhood plan.

Mine-water heat

8.41 South Gloucestershire has an extensive network of former mine workings. These were worked for the extraction of coal over a period of 150 years up to the 1920s. Mine workings flood when no-longer used and this floodwater is warmed by natural geological processes. This provides a potential heat resource, that in combination with heat pumps, can supply heat networks delivering space heating and hot water. Mine water can also be used to provide cooling in new and existing buildings. If exploited this resource could significantly contribute to carbon dioxide targets within the district.

8.42 With this in mind, we are proposing policy criteria to support proposals for the supply of renewable heat and cooling, subject to consideration of impacts on the water regime and water quality and minimising visual impacts. Find out more and submit your comments.

Energy balancing including storage and generation

8.43 Energy storage has a vital role to play in enabling a zero-carbon electricity system. Energy storage is required to reduce the impact from intermittency of electricity output which varies according to weather conditions and to address grid capacity constraints. Renewable energy storage provides reserves for use when demand is high, when supply is low, or at times of system stress.

8.44 With this in mind, we consider that proposals for new energy generation or storage installations/ proposals should be supported where they meet the criteria as set out in this and other policies within the plan. Find out more and submit your comments.

Question

Do you have any comments on the areas proposed for wind safeguarding?

Please submit your comments through our interactive map.

Read the next section – Planning for minerals.

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