Salhouse Parish Council, 11 th November 2013 Response to Planning Application 20131408 Summary Salhouse Parish Council (SPC) has received via Broadland District Council a Planning Application for a 5MWp solar farm on land to north of Stonehouse Road, Salhouse. A previous Planning Application (PA 20130702) was for a Screening Opinion to decide whether an Environmental Impact Assessment (EIA) would be required for the proposed development. SPC argued strongly that an EIA would be required, but this was refused by BDC. Salhouse Parish Council Response to Planning Application 20131408 The site is adjacent to the crossroads of Stonehouse Road/Vicarage Road with B1140 Hills and Holes and immediately opposite The Lodge public house, hotel and campsite. It lies just outside the Salhouse Village Conservation Area and an area of Designated Landscape Value, within clear view of All Saints Parish Church, and is in an extremely visible and exposed location where it will make a high visual impact from a significant distance. Salhouse Parish Council OBJECTS to this application Summary of Objections It is the Parish Council s view that: Contrary to statements in the submission, due to its exposed and highly visible location, the solar farm will yield significant adverse impacts on the surrounding landscape character and visual quality. It is extremely unlikely that the proposed development will be absorbed into the existing landscape context as the submission tries to suggest. The proposed development will be visible from at least 500 metres in a southerly quadrant, and will be clearly visible from (and beyond) the Grade-I listed All Saints Church, Salhouse, which is within the Salhouse Village Conservation Area. The location of the installation will have a considerably more significant impact on the southerly view of the church than the developers claim (see photos). The proposed development lies adjacent to the boundary of both the Conservation Area and an area of Landscape Value (ENV8) and will be clearly visible from and will have a negative visual effect on both. The site has significant complex gradients, sloping gently downward from the west, and dipping more steeply down from the southern boundary to the north into a depression adjacent to road, before ascending again towards the northern boundary. This topography, which is matched by the profile of the adjacent road, will make the development more visible and will serve to emphasise the negative visual impact.
The site is stated by the applicant (EIA Screening Request, section 2.4) that the land is Agricultural Grade 2/3. This is a sufficiently high grade to represent a significant loss to local agricultural production. Drainage is across the site from west to east towards Wroxham Broad a short distance away to the north-east via a probable glacial palaeochannel. Drainage is normally sub-surface but surficial run-off is observed at times of high rainfall and when de-cropped. When runoff is highest, this causes soil erosion on the site and flooding of the B1140. The inevitable loss of vegetation and increased runoff created by a solar farm will exacerbate this problem. The Norfolk Heritage website records a rectangular enclosure, visible as a cropmark on aerial photographs, located northeast of Oldfield (now Milestones) on the Stonehouse Road (NHER 18128) which is thought to be of Roman date, together with evidence of a field system of Iron Age to Roman age (NHER 50726). These features lies exactly on the proposed site. The visual impact of the proposed development will have a negative effect on the area s tourism value, as the B1140 is one of two main tourist routes from the south into Wroxham, and the environment of the adjacent Salhouse Lodge Hotel and campsite will also be degraded. The site is just off the B1140 close to a junction on a deceptive bend with a very high accident rate. The proposal to possibly access the site from this stretch of road is totally unacceptable on safety grounds (although this is now the developer s second choice access). The installation of security cameras and fencing and other hard infrastructure will be entirely out of keeping with the rural character of the area. The proposed development fails to meet the NPPF requirement to recognize the intrinsic character and beauty of the countryside.. The proposed development fails to meet the criteria set by various National Government and Local Authority policies and guidelines. The view of SPC is that the installation of solar panels is not appropriate for open countryside, nor should land be taken out of agriculture for this purpose, but that the policy for solar panels should be that they are installed on the roofs of existing buildings, eg. barns, warehouses, office developments. Justification Public Consultation at Parish Level SPC held a public display of plans relating to PA20131408 on 2 nd November 2013 which was attended by approximately 130 residents. Respondents at the event objected to the Solar Farm proposal by a majority of 7 to 1. The main objections were focused on the following aspects of the development: The high visibility and visual impact of the development at this particular site.
Damage to the landscape, both in general and with particular reference to the high landscape value of this site, given its location next to a busy road in an area of such scenic and tourism value. The industrialisation of the countryside and the loss of agricultural land (and consequent loss of food production). Alternative proposals that solar panels should be placed on the roofs of industrial buildings, particularly at the nearby Rackheath industrial estate. Broadland District Council Policies The proposed development fails to satisfy policy ENV5: Management of Natural Features and Provision of Compensating Features for Those Lost Through Development. Policy ENV5 of the Local Plan seeks to protect natural or semi-natural features where appropriate. The proposed development fails to satisfy policy ENV8: Areas of Landscape Value. Such areas are described as areas of special scenic quality or importance in the landscape. Development will only be permitted in these areas where it is not detrimental to the character, scenic quality or visual benefit of the area. The whole of the site falls within this local designation. The proposed development fails to satisfy policy ENV16: Conservation Areas. This policy seeks to protect the character and appearance of Conservations Areas within the District. The site adjoins the Conservation Area and will be clearly visible from within it. The site is readily visible on the approach to Wroxham from the south along the B1140 Salhouse Road/Bell Lane.and features in many of the recognised views associated with this area (see photos below, which show the view from the South, ie. facing the panels). PV Farm Site PV Farm Site Photos: Two views from the south, close to All Saints Parish Church within the Conservation Area Broads Authority Landscape Character Assessment (LCA) The site lies adjacent to but just outside the Broads Authority s area. Nevertheless, the BA s document Landscape Sensitivity Assessment for Solar PV Development refers to this landscape category (E4) and describes it as follows:
Rackheath and Salhouse Wooded Estatelands: Characteristic northerly views over descending wooded slopes to the Broads, and associated wooded horizon. Fieldwork has confirmed that sensitivity ratings for this area would be the same at the upper end of the typology as those set out for the Broads areas above, although aspects of the landscape may be less sensitive to smaller scale roof mounted solar PV where there is a degree of visual containment. This however would be subject to siting, topography and level of intervisibility. The ridges in these adjacent character areas are visually prominent, as described above and are therefore highly sensitive. It would appear from the above that this application does not fulfill the Broads Authority s Landscape Character Assessment criteria. National Government Guidelines The recent (1 st November 2013) letter from Greg Barker MP, Secretary of State at the Department of Energy and Climate Change to Local Authorities has emphasised the Government s ambitions and priorities in relation to solar energy. Mr. Barker s letter makes it clear that he is very keen to utilize commercial and domestic roof space for solar PV installations, and that he is determined to crack down on inappropriately located large scale solar PV farms. He makes particular reference to the recently published (8 th October 2013) Solar PV Roadmap, which comprises four guiding principles. One of these refers to environmental and landscape considerations, as follows: Support for solar PV should ensure proposals are appropriately sited, give proper weight to environmental considerations such as landscape and visual impact, heritage and local amenity, and provide opportunities for local communities to influence decisions that affect them. Mr. Barker also refers to the Planning Practice Guidance published in July 2013 by the Department for Communities and Local Government (DCLG) in relation to planning issues associated with renewable energy including solar PV, quoting that: From the contents of Mr.Barker s letter it would appear that the subject application fails to meet any of the recently published guideline criteria of two separate Government departments (DECC and DCLG).
National Solar Centre Guidelines National Solar Centre planning guidance for the development of large scale ground-mounted solar PV systems states that ideally, ground mounted large scale PV arrays should utilise previously developed land, brownfield land, contaminated land, industrial land or agricultural land preferably of classification 3b, 4 or 5. Whilst there is no ban prohibiting ground mounted large scale PV arrays on sites classified agricultural 1, 2 and 3a or designated for their natural beauty or acknowledged/recognised ecological/archaeological importance/interest it is unlikely that planning permission will be granted where there is significant impact on these designations. The guidelines also state that, for land of quality Grade 3a and above, the developer should provide an explanation of why the development needs to be located on the site and not on land of a lesser agricultural classification within the area and provide information on the impact of the proposed development on the local area s supply of farming land within the same classification. The application does not meet these guidelines. National Government Policies The National Planning Policy Framework (NPPF) of 2012 states (para 17) that planning principles require planning to recognize the intrinsic character and beauty of the countryside... The NPPF (para 112) states that Where significant development of agricultural land is demonstrated to be necessary, local planning authorities should seek to use areas of poorer quality land in preference to that of a higher quality. The Loss of Grade 3a quality land is therefore contrary to the NPPF policy. The NPPF (para 111) also states that: Planning policies and decisions should encourage the effective use of land by re-using land that has been previously developed (brownfield land). It would appear from the above that this application does not fulfill the NPPF criteria. Conclusions 1. A local public consultation showed significant opposition to this proposal, the main concerns being issues connected with loss of landscape value and loss of agricultural land. 2. The Parish Council is opposed to this proposal, primarily on the grounds of loss of landscape value and visual amenity, impact on the Conservation Area, loss of agricultural land, drainage issues and road safety, and has provided adequate justification to support this view. 3. The proposed development at this site fails to comply with the policies of the Broads Authority, Broadland District Council and the National Planning Policy Framework in relation to Solar PV developments.
4. The proposed development at this site fails to meet the guidelines proposed by National Government and the National Solar Centre. 5. The recent letter from the Secretary of State Greg Barker makes it clear that he does not support Solar PV development on sites of this type.