Landscape Susceptibility in relation to Energy Generation, Storage and Transmission - SPD

2.1.1 The following paragraphs provide a high-level summary of planning policy as it relates to the design and location of energy-related developments.

2.2.1 The National Planning Policy Framework^[3] [NPPF] sets out the Government's planning polices for England and how these should be applied. It promotes a plan-led planning system and requires that development plans include strategic policies to address each local planning authority's priorities for development and use of land, including [§20] a strategy for:

… infrastructure for transport, telecommunications, security, waste management, water supply, wastewater, flood risk and coastal change management, and the provision of minerals and energy (including heat) …

2.2.2 Chapter 14: Meeting the challenge of climate change, flooding and coastal change, notes:

The planning system should support the transition to net zero by 2050 and take full account of all climate impacts including overheating, water scarcity, storm and flood risks and coastal change. The planning system should support the transition to a low carbon future in a changing climate, taking full account of flood risk and coastal change. It should help to: shape places in ways that contribute to radical reductions in greenhouse gas emissions, minimise vulnerability and improve resilience; encourage the reuse of existing resources, including the conversion of existing buildings; and support renewable and low carbon energy and associated infrastructure. [§161]

2.2.3 To help increase the use and supply of renewable and low carbon energy and heat, §165 requires that plans should (amongst other things): "provide a positive strategy for energy from these sources, that maximises the potential for suitable development, … while ensuring that adverse impacts are addressed appropriately (including cumulative landscape and visual impacts)", and "consider identifying suitable areas for renewable and low carbon energy sources, and supporting infrastructure, where this would help secure their development".

2.2.4 With regard to landscape as a consideration in the location of energy-related projects, planning policies and decisions should (amongst other things) "contribute to and enhance the natural and local environment by", amongst other things "protecting and enhancing valued landscapes ..." and "recognising the intrinsic character and beauty of the countryside, and the wider benefits from natural capital and ecosystem services…" [§187].

2.3.1 The adopted South Norfolk Local Plan is made up of various documents. These include the Greater Norwich Local Plan (GNLP), which was jointly prepared by South Norfolk and Broadland District councils, Norwich City Council and Norfolk County Council, which was adopted on 25^th March 2024. The plan covers the period up to 2038 and includes strategic policies to guide future development and plans to protect the environment, seeking to ensure that delivery of development is achieved in a way which promotes sustainability.

2.3.2 Section 2 describes the Greater Norwich spatial profile. Regarding renewable energy, §109 notes:

Renewable Energy 109. Recent years have seen an increase in renewable energy generation locally, chiefly from solar power (both small and large-scale), with some wind and biomass developments. Our plan should support further development of decentralised, renewable and low carbon sources of energy in appropriate locations

2.3.3 Regarding landscape, §§122 to 124 note:

The varied landscape character areas identified by Natural England in and adjacent to Greater Norwich area consist of: the fens and marshes of the Broads to the east of Greater Norwich [NCA 80]; a more intimate landscape of small fields and hedgerows adjacent to the Broads, also in the east NCA 79; rolling landscapes of varied geology including woodland, heath and former parkland estates in the west and north [NCA 84 and 78] and an extensive open clay plateau in the south [NCA 83].

These nationally identified landscape character areas inform local landscape character studies. Locally significant landscapes include strategic gaps between settlements, river valleys (including the Wensum, Waveney, Bure, Tiffey, Tas and Chet), undeveloped approaches to Norwich and the setting of the Broads.

Greater Norwich does not have a nationally designated Green Belt. National policy is clear that new Green Belts should very rarely be established. Therefore this plan will need to carry forward policies for protecting our valued landscapes.

2.3.4 Energy and the environment are at core of The Vision for Greater Norwich in 2038:

By promoting this Greater Norwich Local Plan our aim is that it will support growth of a diverse low carbon economy which will compete globally through its world class knowledge-intensive jobs in the Cambridge Norwich Tech Corridor.

As a result, by 2038 Greater Norwich will have vibrant, healthy, inclusive and growing communities supported by the delivery of new homes, infrastructure and an enhanced environment. Growth will make the best of Greater Norwich's distinct built, natural and historic environments, whilst protecting and enhancing them.

To achieve this, growth will be clean and resource efficient, with significantly reduced emissions to ensure that Greater Norwich plays a full part in meeting national commitments on tackling climate change and is moving towards a post-carbon economy. The focus on three high growth sectors: clean energy, agri-food and ICT/digital, along with the high environmental standards and significant further improvements to our extensive green infrastructure network promoted through this plan, will support Norfolk and Suffolk as the United Kingdom's clean growth region.

2.3.5 It continues: "Greater efficiency in water and energy usage will minimise the need for new infrastructure, and further reductions in carbon emissions will be delivered through the increased use of sustainable local energy sources", "The distinctive characteristics of our landscapes will also be protected and enhanced. This will be achieved by shaping high-quality, well designed and beautiful new development …" and "Critically, our plan will have helped to achieve reductions in our greenhouse gas emissions to contribute to the national target to reduce all greenhouse gas emissions by 68% by 2030 and by 78% by 2035 compared to 1990 levels and the zero-emission target by 2050."

2.3.6 Policy 2: Sustainable Communities requires that development proposals should, were relevant, address the following matters (amongst others) in order to contribute to the achievement of sustainable communities:

• Make efficient use of land with development densities taking account of accessibility and local character consideration. …
• Create beautiful, well-designed places and buildings which respect the character of the local area and seek to enhance it through appropriate design, having regard to any local design guidance (including design codes).
• Take account of landform, layout, building orientation, massing and landscaping to minimise energy consumption and the risk of overheating.
• Provide for the use of sustainable energy, local energy networks and battery storage where appropriate.

2.3.7 Policy 3: Environmental Protection and Enhancement. Sub section The Natural Environment requires that development proposals should enhance the natural environment through, amongst things:

• Being designed to respect, conserve and enhance natural assets, taking account of local design and other guidance such as landscape character assessment.
• Avoiding harm to designated and non-designated assets of the natural environment, having regard to their level of significance (local, national, and international) in accordance with the requirements of the NPPF and relevant policies in other Development Plan Documents and Neighbourhood Plans.
• Following a hierarchy of seeking firstly to avoid impacts, mitigate for impacts so as to make them insignificant for biodiversity, or as a last resort compensate for losses that cannot be avoided or mitigated for. Adherence to the hierarchy should be demonstrated.
• Undertaking a relevant assessment (such as a landscape or ecological assessment) if impacts to a natural asset might arise.
• Provision of new, or conservation or enhancement of existing, green infrastructure to contribute (directly or indirectly) to the strategic green infrastructure network having regard to local green infrastructure strategies (identified indicatively in Maps 8A and 8B).
• Respecting landscape character and retaining important views and features, having regard to landscape character assessments and sensitive areas such as landscape settings, strategic gaps and green spaces identified in Local or Neighbourhood Plans, and to the importance of the nationally designated Broads Authority area and its setting.

2.3.8 In applying the above, regard will be given to the level of importance of the natural asset.

2.3.9 The South Norfolk Local Plan Development Management Policies Document, Adoption Version, October 2015 includes a policy on renewable energy.

2.3.10 Policy DM 4.1: Renewable Energy notes:

Proposals for renewable energy generating development requiring planning permission other than for proposals for wind energy development will be supported and considered (taking account of the impact of relevant ancillary equipment) in the context of sustainable development and climate change on the wider environmental, social and economic benefits of maximising use of renewable energy. The Council will encourage the use on-site communal-scale energy generation measures.

2.3.11 It notes that consideration will be given to the effect of the proposal on number of factors, including the "character and appearance of the landscape", and that "Permission will be granted where there are no significant adverse effects or where any adverse effects are outweighed by the benefits." It also notes that where appropriate, planning conditions will be imposed requiring the decommissioning and removal/dismantling of all plant and ancillary equipment and, if necessary, the restoration of land, on the cessation of use.

2.3.12 The document also contains several policies that relate directly to landscape character and the location and design of development within the landscape.

2.3.13 Policy DM 4.5: Landscape Character Areas and River Valleys, requires that:

All development should respect, conserve and where possible, enhance the landscape character of its immediate and wider environment. Development proposals that would cause significant adverse impact on the distinctive landscape characteristics of an area will be refused.

All development proposals will be expected to demonstrate how they have taken the following elements (from the 2001 South Norfolk Landscape Assessment as updated by the 2012 review) into account:

• The key characteristics, assets, sensitivities and vulnerabilities;
• The landscape strategy; and
• Development considerations.

Particular regard will be had to protecting the distinctive characteristics, special qualities and geographical extents of the identified Rural River Valleys and Valley Urban Fringe landscape character types.

2.3.14 Policy DM 4.6: Landscape Setting of Norwich is considered in more detail at Section 7.

2.3.15 Policy DM 4.7: Strategic gaps between settlements within the Norwich Policy Area states:

Gaps between settlements within the Norwich Policy Area Development will be permitted in the Strategic Gaps identified on the Policies Map, between the development boundaries of the Settlements listed below, where it would not erode or otherwise undermine the openness of the Strategic Gap, and complies with other Development Plan policies.

• Cringleford – Hethersett
• Hethersett - Wymondham

2.3.16 Policy DM 4.8: Protection of Trees and Hedgerows states:

The Council will promote the retention and conservation of significant trees, woodlands and traditional orchards and will serve Tree Preservation Orders where necessary. 119 The Council will presume in favour of the retention of 'important' hedgerows as defined by the Hedgerows Regulations 1997.

The Council will safeguard and promote the appropriate management of protected and other significant trees and hedgerows, unless the need for, and benefits of, a development clearly outweigh their loss.

2.3.17 Policy DM 4.9: Incorporating landscape into design emphasises the importance of good quality design:

Where appropriate, detailed development proposals must demonstrate a high quality of landscape design, implementation and management as an integral part of the new development.

The provision for new planted features (such as tree belts, hedgerows, wild flowers and specimen trees) is expected to form part of development proposals from their outset and should provide an appropriate landscape setting for the scheme.

'Hard' landscape features (such as paving, kerb stones, street furniture, boundary treatments etc) will reflect and where possible enhance locally distinctive character and styles where relevant; or innovative contemporary solutions reflecting local context and reinforcing or creating local distinctiveness and the setting of the development.

Landscape schemes will be required to respect the character and distinctiveness of the local landscape and should ensure that any land remodelling respects the local topographic character in terms of height, slope, angle and character. Landscape schemes should be clearly and properly specified.

2.4.1 Overarching National Policy Statement for Energy, dated 2024, sets out the government's policy for the delivery of major energy infrastructure.

2.4.2 In England, the National Policy Statements (NPS) may be a material consideration in decision making. Whether the policies in a NPS are material and to what extent will be judged on a case-by-case basis and will depend upon the extent to which the matters are already covered by applicable planning policy. For the purposes of Nationally Significant Infrastructure Projects (NSIPs), the NPSs represent the primary policy for decision making.

2.4.3 The government sees a need for significant amounts of new large-scale energy infrastructure to meet its energy objectives. However, "it will not be possible to develop the necessary amounts of such infrastructure without some significant residual adverse impacts. These effects will be minimised by the application of policy set out in Parts 4 and 5 of this NPS."

Electricity storage

2.4.4 Electricity storage is considered to have "a key role to play in achieving net zero and providing flexibility to the energy system" ]§3.3.25]. There is currently around 4GW of electricity storage operational in Great Britain, around 3GW of which is pumped hydro storage and around 1GW battery storage.

2.4.5 Electricity Storage facilities are not generally considered to be NSIPs except for pumped hydro storage facilities above 50MW.

New electricity infrastructure

2.4.6 The NPS states that substantial reinforcement of the transmission network is required in East Anglia to handle increased power flows from offshore wind generation [§3.3.68], which may also require additional offshore connections coming to land in England.

The historical approach to connecting offshore wind resulted in individual radial connections developed project-by-project… For regions with multiple windfarms or offshore transmission projects it is expected that a more coordinated approach will be delivered. For these areas, this approach is likely to reduce the network infrastructure costs as well as the cumulative environmental impacts and impacts on coastal communities by installing a smaller number of larger connections, each taking power from multiple windfarms instead of individual point-to-point connections for each windfarm. [§3.3.71]

2.4.7 The final Phase 1 report for National Grid ESO's Offshore Coordination Project (published December 2020) found that the number of new electricity infrastructure assets, including cables and onshore landing points could be reduced by up to 50 per cent, significantly reducing environmental impacts and impacts on coastal communities.

Heat networks

2.4.8 Heat networks are systems of insulated pipes that take heat from a central source and supply it, as hot water, to residential, commercial and public sector buildings to provide hot water and heating. There are over 14,000 heat networks in the UK with nearly 492,000 connections in total including 446,500 domestic customers.

Assessment principles

2.4.9 In considering any proposed development the Secretary of State should take into account:

• its potential benefits, and
• its potential adverse impacts, including on the environment, including any long-term and cumulative adverse impacts, as well as any measures to avoid, reduce, mitigate or compensate for adverse impacts. [§4.1.5]

2.4.10 It is stated that:

The overarching need case for each type of energy infrastructure, and the substantial weight which should be given to this need … is the starting point for all assessments of energy infrastructure applications. [§4.2.6]

Applicants must apply the mitigation hierarchy, and demonstrate that it has been applied. … Applicants should demonstrate that all residual impacts are those that cannot be avoided, reduced or mitigated. [§4.2.11]

Applicants should set out how residual impacts will be compensated for as far as possible. ... The cumulative impacts of multiple developments with residual impacts should also be considered. [§4.2.12]

2.4.11 All proposals for projects that are subject to the Environmental Impact Assessment Regulations must be accompanied by an Environmental Statement describing the aspects of the environment likely to be significantly affected by the project.

Criteria for good design for energy infrastructure

2.4.12 The NPS notes that:

Whilst the applicant may not have any or very limited choice in the physical appearance of some energy infrastructure, there may be opportunities for the applicant to demonstrate good design in terms of siting relative to existing landscape character, land form and vegetation. Furthermore, the design and sensitive use of materials in any associated development such as electricity substations will assist in ensuring that such development contributes to the quality of the area.

The Secretary of State should be satisfied that the applicant has considered both functionality (including fitness for purpose and sustainability) and aesthetics (including its contribution to the quality of the area in which it would be located, any potential amenity benefits, and visual impacts on the landscape or seascape) as far as possible.

Climate change adaption and resilience

2.4.13 Regarding climate change:

Applicants should demonstrate that proposals have a high level of climate resilience built-in from the outset. [§4.10.11]

Ancient Woodland and veteran trees

2.4.14 Regarding Ancient Woodland and veteran trees:

Applicants should include measures to mitigate fully the direct and indirect effects of development on ancient woodland, ancient and veteran trees or other irreplaceable habitats during both construction and operational phases. [§5.4.32]

Landscape and visual

2.4.15 Landscape and visual impacts are considered in Section 5.10 of the NPS.

The landscape and visual effects of energy projects will vary on a case by case basis according to the type of development, its location and the landscape setting of the proposed development. [§5.10.1]

Landscape effects arise not only from the sensitivity of the landscape but also the nature and magnitude of change proposed by the development, whose specific siting and design make the assessment a case-by-case judgement. [§5.10.4]

Virtually all nationally significant energy infrastructure projects will have adverse effects on the landscape, but there may also be beneficial landscape character impacts arising from mitigation. [§5.10.5]

Projects need to be designed carefully, taking account of the potential impact on the landscape. Having regard to siting, operational and other relevant constraints the aim should be to minimise harm to the landscape, providing reasonable mitigation where possible and appropriate. [§5.10.6]

The applicant should consider landscape and visual matters in the early stages of siting and design, where site choices and design principles are being established. [§5.10.19]

2.4.16 The assessment should include the effects on landscape components and character as well as the impact on views and visual amenity. The assessment should also address the landscape and visual impacts of noise and light pollution.

Applicants should consider how landscapes can be enhanced using landscape management plans, as this will help to enhance environmental assets where they contribute to landscape and townscape quality. [§5.10.24]

Adverse landscape and visual effects may be minimised through appropriate siting of infrastructure within its development site and wider setting. The careful consideration of colours and materials will support the delivery of a well-designed scheme, as will sympathetic landscaping and management of its immediate surroundings. [§5.10.27]

Depending on the topography of the surrounding terrain and areas of population it may be appropriate to undertake landscaping off site. For example, filling in gaps in existing tree and hedge lines may mitigate the impact when viewed from a more distant vista. [§5.10.28]

The scale of energy projects means that they will often be visible across a very wide area. The Secretary of State should judge whether any adverse impact on the landscape would be so damaging that it is not offset by the benefits (including need) of the project. [§5.10.35]

Other NPSs

2.4.17 A further five technology-specific NPSs provide further detail and for the energy sector cover:

• EN-2: natural gas electricity generation
• EN-3: renewable electricity generation (both onshore and offshore)
• EN-4: gas supply infrastructure and gas and oil pipelines
• EN-5: the electricity transmission and distribution network
• EN-6 nuclear electricity generation

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^[3] National Planning Policy Framework, Ministry of Housing, Communities & Local Government (December 2024)