CPRE Wiltshire Position on solar arrays
The Campaign for the Protection of Rural England Wiltshire (CPRE Wiltshire) recognises that solar energy can make a contribution to reducing carbon emissions and increasing energy security. It believes that the most suitable location for solar technologies is on large-scale industrial and other buildings with major roof surfaces. However, it recognises that ground-mounted solar farms have potential benefits if their location and impact meet certain criteria.
"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." UK Solar PV Strategy Part 1: roadmap to a brighter future, para. 6; and letter to planning officers, "Solar Energy", Minister of State for Energy and Climate Change, November 2013
Assessment of solar photo-voltaic (SPV) applications in Wiltshire
CPRE Wiltshire will evaluate applications for SPV farms on a case-by-case basis, and by reference to a series of principles. In particular, applications must conform to the National Planning Policy Framework (NPPF) and to the Wiltshire Local Development Framework (including especially the Core Strategy); and should be consistent with the principles expressed in the Government’s Planning Practice Guidance and the management plans of the Ares of Outstanding natural Beauty and other protected sites in the county.
We have particular regard to Planning Practice Guidance, Renewable and Low-Carbon Energy, para. 007, which says that in considering planning applications:
- the need for renewable or low carbon energy does not automatically override environmental protections;
- cumulative impacts require particular attention, especially the increasing impact…large scale solar farms can have on landscape and local amenity as the number…in an area increases;
- local topography is an important factor in assessing whether…large scale solar farms could have a damaging effect on landscape, and [assessment should] recognise that the impact can be as great in predominately flat landscapes as in hilly or mountainous area;
- great care should be taken to ensure heritage assets are conserved in a manner appropriate to their significance, including the impact of proposals on views important to their setting;
- proposals in National Parks and Areas of Outstanding Natural Beauty, and in areas close to them where there could be an adverse impact on the protected area will need careful consideration;
- protecting local amenity is an important consideration which should be given proper weight in planning decisions.
Our assessment of specific applications will consider:
- Site location, development size, topography, elevation, built context, zone of visual influence.
- Planning principles, designated-area status, heritage assets and historic environment.
- Grade of land, current use, potential damage to agricultural activity and ecological effects.
- Landscape impact & setting: arrangement and elevation; screening; possibilities for alternative siting.
- Intervisibility and cumulative visual impact;
- Access, transport links and grid connectivity.
- Security measures (fencing, CCTV); and appearance – colour, glint and glare.
- Drainage and surface water run-off.
- Local employment impact and community involvement and gain.
- Land management: agricultural and ecological enhancement measures, and long-term reversion plans.
- Plant productivity, potential national and local energy benefits.
- The views of local Parish Councils and other affected community groups.
Local planning guidelines
CPRE Wiltshire believes that the current local planning framework gives inadequate guidance to developers and planners on how they should approach a number of requirements of Core Policies 42 and 51 of the Wiltshire Draft Core Strategy. These inadequacies relate, among other things inter alia, to methods to assess or establish conditions for:
- the spatial distribution of Wiltshireʼs target renewable energy capacity;
- impact on landscape character, and visual amenity effects, especially the effect of local concentration of multiple arrays (accumulation impact);
- light pollution;
- developer indemnification of decommissioning;
- potential long-term leaching of toxic substances into groundwater;
- land-use status on reversion.
With respect to the accumulative landscape and visual impact of multiple arrays, we note that the Planning Practice Guidance emphasises that this does not depend simply on being able to see two arrays at the same time, and that it should not be assumed that a development will not create cumulative impact just because no other sites will be visible from it.
We advocate that planning officersʼ assessments of these matters should refer to the Landscape Instituteʼs Guidelines for Landscape and Visual Impact Assessment, 3rd edition (widely considered among landscape professionals to offer up-to-date best practice). This states (section 7.17) that there are many different types of cumulative and visual effects that may need to be considered in an LVIA. These include:
❖ the ‘filling’ of an area with either the same or different types of development over time, such that it may be judged to have substantially altered the landscape resource and views of visual amenity;
❖ incremental change as a result of successive individual developments such that the combined landscape and/or visual effect is significant even though the individual effects may not be;
❖ temporal effects, referring to the cumulative impacts of simultaneous and/or successive projects that may affect communities and localities over an extended period of time.
CPRE Wiltshire seeks the development of supplementary local guidelines to assist planning assessment of accumulative impact and the other matters listed above. (We note, for example, that several LPAs have produced guidelines to help assess concentration and proximity effects.) We will also seek national review of whether the current classification of agricultural land remains serviceable for renewable energy development decisions.
We believe that better definition on these matters will assist all parties — local communities, renewable energy developers and the planning authority — in managing and accommodating more and better ʻgreenʼ energy.