Rother is one of the most wooded areas within England and therefore has a large
resource of biomass that could be exploited for wood-burners and small scale biomass boilers and Combined Heat and Power (CHP) plants. We would support any policies that encourage the use of this sustainable resource. Bringing back large areas of woodland into active management has the potential to be very positive to biodiversity as evidenced by the work of the Wildlife Trusts, Natural England, The Forestry Commission and the Butterfly Conservation Trust, all of which are actively working with landowners to this effect.

Planning policies should be put in place that not only encourage the householder e.g.
chimneys/flues on all new properties for wood burners; but also to make it easier for
landowners to set up wood fuel businesses e.g. buildings, storage facilities etc.

The current system of asking for all new developments over a certain size to explore the use of biomass / CHP does not seem to be working as developers tend to show that they are not viable. Often it is the public sector that has to lead the way and therefore it is suggested that all new public buildings of a minimum size should have a system installed. This would kick start a local market for fuel. Consideration should also be given to retro-fitting existing public assets. Swimming pools would be a prime target as they have a year round need for heat.

The policy wording for larger developments to 'consider' biomass is not strong enough. There is a need for a proper viability analysis to be undertaken and for RDC to employ their own consultants to review rather than accepting the results.

In conclusion, there is a need to strengthen use of biomass as suitable for smaller
developments and public buildings so that this form of energy is given more serious
consideration.

It should also be borne in mind that adequate insulation saves more energy than can be generated by householders. It is essential therefore that the highest standards are sought.



6.20 Comments on solar paragraph as no question for response

There needs to be a DRM2- to encourage where appropriate wind and solar, and to
make solar mandatory on all commercial and industrial buildings; and any application to alter/extend industrial building needs to carry an obligation to fit rooftop solar.

Encourage:
* Solar thermal panels for "family" properties.
* Community solar schemes.

The National Grid needs updating so that the above average generation rates achieved within Rother can be utilised fully. In the meantime, where there are grid problems, smart meters should allow neighbours to share.

Could RDC council monies be used to improve the grid?

The document from Maidstone BC which in turn was borrowed from Cornwall CC and
Ashford BC gives detailed guidance and it would be helpful for RDC to provide similar
guidance:

Reference; Maidstone Borough Council: Planning Policy Advice Note:
Domestic and Medium scale solar PV arrays (up to 50kw) and solar thermals
Jan 2014

Items 6.21 & 6.22 of the DaSA are deeply flawed. The 'unduly onerous' (para 6.22) is dubious to whom? Any developer will always say such is 'unduly onerous'. CS SRM(i) does not contain a target for energy reduction proposals. Without, such it is not effective. Target should be to cut predicted C02 emissions by the equivalent of 20% over and above what current building regulations require.

The validation checklist referred to in paragraph 2.21 of the Renewable Energy
background paper is inadequate and in urgent need of updating. Other local authorities, such as Maidstone Borough Council, include the following condition for ALL new build houses (threshold 1 dwelling): 'Prior to any development above damp proof course level, details of proposed renewable energy sources shall be submitted to and approved in writing by the local planning authority. The approved details shall be implemented prior to the first occupation of any dwelling.' This clearly demonstrates that RDC can, if it so chooses, impose much tighter and binding rules, for ALL new build development. The difficulty in applying the current policy is due to a lack of will by RDC. As it is, rather than relaxing Core Strategy Policy SRM1, it should be tightened.

Reference: RDC Development and Site Allocation Local Plan, Renewable and Low
Carbon Energy - Background Paper. November 2016
Examples of criteria RDC should be setting:

* Are as many as possible of the sloping roofs oriented as much as possible to the
South and West in order to be fitted with solar panels?

* Are locations for solar panels included in the design of the roofs - even if not
fitted?
* Where solar panels can be fitted have you considered providing space in the
dwelling for batteries?
* Are heat pumps being considered?
* If so have you included in the design suitable locations for them?
* Have you considered installing under floor heating?
* Are electric charging points being included for electric vehicles?
* All new commercial and industrial roofs over (100) sq. m. must install solar panels
on south or south west facing roofs.
* All new developments should consider specific on-site positioning to maximise the
possibility of installing solar roof panels and for increasing passive solar gain.

6.23 Praise to RDC for this clause as this applies to every development/dwelling.