Representation by Savills (Savills) on behalf of The Church Commissioners for England (The Church Commissioners for England)
- Date submitted
- 11 September 2024
- Submitted by
- Members of the public/businesses
The Church Commissioners for England (CCE) own the land adjacent to the Stonestreet Solar application, located to the north and west of the proposed development site. CCE’s land was promoted for residential development and submitted as part of Ashford Borough Council’s (ABC) Call for Sites process in November 2023. ABC is expected to publish its Regulation 18 draft Local Plan in April 2025. CCE is broadly supportive of the Stonestreet Solar application and advocates for the use of renewable energy. However, having reviewed the submitted application documents, CCE has identified some slight concerns regarding potential noise and visual impact on its land. With respect to noise, CCE notes that several batteries are indicated on the illustrative masterplan as being located within approximately 150m of CCE’s land. CCE would question whether there is any opportunity to relocate these batteries further from CCE’s land and create a more meaningful buffer, in addition to incorporating further planting along the shared boundaries. Whilst being aware that the application proposes the use of acoustic barriers, CCE would like to query whether the acoustic barriers are deemed sufficient to mitigate any adverse noise impact or whether the acoustic barriers can be enhanced further. In relation to visual impact, CCE notes that the illustrative plans propose PV panels up to the very threshold of CCE’s boundary. Although a 2.5 - 3m tall hedge is proposed around the perimeter of the site, CCE notes that the heights of the PV panels are 3.5m and the acoustic fencing is 4m tall. Therefore, it seems adverse visual impacts would be likely. The submitted Landscape and Visual Impact Assessment (LVIA) provides three distant view visualisations of Stonestreet Solar from CCE’s land but no middle-distance views are illustrated. CCE kindly requests additional visualisations are produced from closer proximity to the proposed development to better assess the potential visual impacts on CCE’s land. A number of public rights of ways (PRoW) exist across CCE’s land and would have direct views of the proposed Stonestreet Solar. Only three viewpoints have been provided from PRoWs on CCE’s land (viewpoints 1, 18 and 31) and only one of these has been visualised (viewpoint 31). CCE would appreciate clarification on why additional viewpoints from these PRoWs were not assessed since there could be considerable adverse visual impact from the proposed development. Overall, CCE supports the use of renewable energy but would appreciate further information in regard to suitable mitigation against potential adverse noise and visual impacts on its land and in particular relating to the PRoWs. CCE looks forward to collaborating further throughout the application process.