Planning for Renewable Energy Development in Cumbria
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Planning Cumbria Cumbria and Lake District Joint Structure Plan 2001 – 2016 Technical Paper 6 Planning for Renewable Energy Development in Cumbria CONTENTS 1. Introduction i 2. Commentary by Cumbria County Council i 3. AXIS Report iii ‘ Renewable Energy Development – Identifying the Potential’ Cumbria & Lake District Joint Structure Plan 2001 – 2016 Technical Paper No 6 Planning for Renewable Energy Development 1 Introduction 1.1 This statement provides commentary on the report ‘Renewable Energy Development in Cumbria - Identifying the Potential’, January 2003, prepared by AXIS Planning Consultants for Cumbria County Council and Sustainability North West. The full report (referred to here as the AXIS Report) is included in this technical paper. 1.2 The AXIS Report was commissioned by Cumbria County Council and Sustainability North West in July 2002. Its purpose was to inform development of the Structure Plan policies by identifying the potential for grid connected renewable energy developments in Cumbria, to assess the ability of the County to meet renewable energy targets and to identify areas of search with potential for different types of renewable energy developments which merit further detailed investigation. 1.3 The study process that led to the AXIS Report included 3 main stages. First, broad policy and viability constraints criteria were mapped to leave Broad Areas of Search. The criteria applied here were considered to be consistent with current sustainable development policy and technical best practice. Secondly, following discussion with local planning authorities, additional criteria were applied to the Broad Areas of Search that resulted in the identification of Refined Areas of Search. The second stage criteria took account of local environmental factors, including an assessment of the impact on defined landscape character* (*further details can be found in the Structure Plan Technical Paper No 5 ‘Landscape Character’). This was followed by further consultations with the local electricity network provider to ascertain the potential energy contribution from each of the Refined Areas of Search. The final stage of the study gave an indication of the potential contribution from each of the renewable energy technologies considered and quantified them by District. Comparison was also made with the regional energy study ‘From Power to Prosperity’ dating from March 2001. Further details of the study process and the methodologies applied can be found in the AXIS Report. 1.4 The AXIS Report has informed preparation of the Structure Plan. However, the methodology, analysis and views contained in the AXIS Report are those of its authors and do not constitute Structure Plan policy. 2 Commentary by Cumbria County Council 2.1 It is considered that the AXIS Report has given a comprehensive assessment of renewable energy potential in the County and offered an objective basis to inform Structure Plan policies. The Report establishes some appropriate criteria for the Deposit Structure Plan policies as well as inclusion of technically viable Areas of Search. However, specific elements of the AXIS Report have not been taken forward in the Deposit Structure Plan. These elements are outlined below together with further commentary. 2.2 Areas of Search: Whilst the study process adopted by AXIS incorporates a stage to refine broad areas of search, it is not considered appropriate for the Structure Plan to include maps that have been derived from the application of local environmental constraints criteria. It is considered that the application of local environmental criteria should occur at the Local Plan stage. The issues considered in the refinement stage of the AXIS Report will require further assessment by local planning authorities before they can be acted upon through the identification of discrete areas within Local Plans and in the determination of individual planning applications. Issues such as landscape/visual impact will need to be assessed on a case by case basis. A new Planning Policy Statement (PPS 22) ‘Renewable Energy’ will be published by the Government after the Structure Plan goes on Deposit, which hopefully will give further guidance. It is considered, however, that the strategic landscape assessment and clear representation of the refinement process included in the AXIS Report offers a significant insight Cumbria & Lake District Joint Structure Plan 2001 – 2016 Technical Paper No 6 Planning for Renewable Energy Development i into the local issues that need to be considered by planning authorities. It is also considered that the facilitative approach promoted in the AXIS Report is consistent with the emphasis given in the Energy White Paper published by the Government in February 2003. Taking this approach forward, the County Council will require that refined Areas of Search are represented in Local Plans, to ensure there is further clarity for developers, and only include policy reference to the Area of Search maps identified following the application of Stage 1 (broad) criteria in the Structure Plan. 2.3 Definition of On Shore Wind Technologies: During the study process AXIS amended the definitions given for On Shore Wind technologies. The County Council consider that the original definitions of onshore wind turbine technologies (i.e. ‘3MW or less’ and ‘greater than 3MW’) are preferable to the definitions cited in the final report i.e. ‘Onshore Wind Farms/Clusters Outside Statutory Landscape Designations and Hadrian’s Wall Buffer Zone’ and ‘Onshore Wind Clusters and Single Turbine Development (Commercial Scale, but nominally 3 MW or less of installed capacity) within Statutory Landscape Designations and Hadrian’s Wall Buffer Zone’. The former definitions did not incorporate a landscape reference, which is considered to be a constraint criteria that should be used in the sieve mapping exercise rather than being part of the technology description. The technology description should not be influenced by matters of policy such as landscape designation. Schedule 3 of the Deposit Structure Plan gives a list of all the renewable energy technologies referred to in the Structure Plan together with the constraints criteria that have been used to determine Areas of Search. 2.4 Areas of Search for On Shore Wind Turbines: The criteria and maps taken forward into the deposit Structure Plan do not exactly mirror those presented in Stage 1 of the AXIS Report. This is because a difference now occurs between the constraints criteria applied in the Structure Plan for the technology ‘Grid Connected On Shore Wind Clusters of 3MW or less’ and those applied in Stage 1 of the AXIS Report for ‘Onshore Wind Clusters and Single Turbine Development (Commercial Scale, but nominally 3 MW or less of installed capacity) within Statutory Landscape Designations and Hadrian’s Wall Buffer Zone’. An additional criterion has been applied in the Structure Plan to that in the AXIS Report. The Structure Plan criteria exclude development of windclusters (3MW or less) within national landscape designations. The reason being that grid connected wind turbine development is not considered acceptable in nationally designated landscapes given the likelihood of a damaging effect on the character of the area from such a scale of development. In most circumstances commercial wind energy developments will constitute ‘major development’ and therefore in accordance with national planning guidance should not take place in nationally designated landscape areas save in exceptional circumstances. Consequently, it would be inappropriate to include them in areas of search. The AXIS Report has shown that significant opportunity exists outside designated areas for grid connected wind energy schemes to be developed without the risk of permanent damage to important conservation interests. Hadrian’s Wall Buffer Zone has been left within the ‘broad’ search area shown in the Structure Plan given the purpose of its designation is not on landscape grounds but rather to recognise the presence (and setting) of a internationally important archaeological feature. The large area covered by the Buffer Zone designation and the varying topography within it could potentially accommodate a small-scale grid connected wind turbine development without necessarily damaging the characteristics and setting of Hadrian’s Wall. However, it should be recognised that the Structure Plan will continue to apply strong tests to any development within the designated area. Development proposals would also require individual assessment and compliance with Local Plan Policy. 2.5 Technical Criteria Validity: The AXIS Report was prepared with a view to the potential for development over the life of the Structure Plan (up to 2016). When taking forward the outputs of the AXIS Report into Structure Plan policy the County Council recognised that the technical constraints criteria used to define Areas of Search reflect the current position on economic viability. This could change over the life of the Plan. For example, wind turbines located where Cumbria & Lake District Joint Structure Plan 2001 – 2016 Technical Paper No 6 Planning for Renewable Energy Development ii wind speed is on average 6.5 m/s are considered to be on the margins of viability at the present time due to the specifications of current technology. However, the industry is continually improving the efficiency ratings of wind turbines. This ultimately could result in turbines being able to be operated economically in areas where wind speed is less