Support

Representation ID: 4375

Received: 29/08/2025

Respondent: Broads Authority

Proposed new section
SPD needs to generally reflect amendments to the Broads Act. The Levelling Up and Regeneration Act, which received Royal Assent on 26 October 2023, amended Section 17A of the Norfolk and Suffolk Broads Act 1988. Section 17A creates a general duty of public bodies and this was amended to replace ‘shall have regard to’ with ‘must seek to further’ the purpose of conserving and enhancing the natural beauty, wildlife and cultural heritage of the Broads, promoting opportunities for the understanding and enjoyment of the special qualities of the Broads by the public; and protecting the interests of navigation.
I would suggest there needs to be a section in the SPD that talks about this – how the impact on the Broads and its setting will be addressed through this SPD, similar to the section on the setting of Norwich. In particular, given that section 3.7.1 says ‘When assessing the susceptibility of a landscape to change, consideration must be given to the effects of the development as perceived in neighbouring LCAs (and potentially further afield), not just the LCA in which the development is proposed’.
Please see a proposed section below. We have made the section look like the section on Norwich. The second part (Considerations for the LSS) may or may not be needed or you may wish to amend it. We are happy to discuss this with you.

Landscape setting of the Broads

The Broads is an internationally important wetland and designated protected landscape of the highest order, with a status equivalent to that of a National Park and one of Europe’s finest and most important wetlands for nature conservation.
Part of the Broads lies within South Norfolk district area. The Levelling Up and Regeneration Act, which received Royal Assent on 26 October 2023, amended Section 17A of the Norfolk and Suffolk Broads Act 1988. Section 17A creates a general duty of public bodies and this was amended to replace ‘shall have regard to’ with ‘must seek to further’ the purpose of conserving and enhancing the natural beauty, wildlife and cultural heritage of the Broads, promoting opportunities for the understanding and enjoyment of the special qualities of the Broads by the public; and protecting the interests of navigation.
Paragraph 189 of the 2024 NPPF says: ‘Great weight should be given to conserving and enhancing landscape and scenic beauty in National Parks, the Broads and National Landscapes which have the highest status of protection in relation to these issues. The conservation and enhancement of wildlife and cultural heritage are also important considerations in these areas and should be given great weight in National Parks and the Broads66. The scale and extent of development within all these designated areas should be limited, while development within their setting should be sensitively located and designed to avoid or minimise adverse impacts on the designated areas’. Footnote 66 says ‘English National Parks and the Broads: UK Government Vision and Circular 2010 provides further guidance and information about their statutory purposes, management and other matters’
South Norfolk District Council is not the Local Planning Authority for the Broads, and this SPD does not apply to the Broads. But there could be potential for some renewable energy schemes of the type discussed in this SPD within the South Norfolk administrative area to have an impact on the Broads and its setting.

When considering schemes that are near to or next to the Broads Authority Executive Area, the impact on the setting of the Broads and on the Broads will be a key consideration. South Norfolk District Council will consult and engage with the Broads Authority at an early stage in the consideration of such proposals.

The special landscape qualities of the Broads are set out in the Broads Authority’s Landscape Character Assessment and the Broads’ Landscape Sensitivity Study assesses the impact of renewable infrastructure on the Broads and these documents will also be used when assessing relevant planning applications.

Schemes near to the Broads will also be assessed against the special qualities of the Broads. These are listed in the Broads Plan, which is the Management Plan for the Broads. The current version can be found here: Introduction.
Considerations for the LSS
The following paragraphs provide commentary on how the various development scenarios identified at Section 4 would accord with the purposes of the Broads Authority.
Solar PV

Although Solar PV preserves the existing soils and vegetation cover beneath the panels it nonetheless represents a form of development and could result in the loss of land for other purposes more appropriate in this area(e.g. grazing)Whilst it might be possible to screen Solar PV to mitigate harm on the setting of the Broads, it is likely that there would still be some detrimental impact
AD plants

AD plants include large structures and clamps, and these could have a substantial negative effect on the setting of the Broads. Whilst it may be possible to screen battery storage with planting, it is likely to still appear incongruous in the landscape
Battery Storage

Battery Storage represents a utilitarian form of development which could have a substantial negative effect on the setting of the Broads. Whilst it may be possible to screen battery storage with planting, it is likely to still appear incongruous in the landscape.
Overhead power lines

Overhead powerlines increase the sense of human influence and are a form of development. The scale of the structures and the topography of the Broads means that they are likely to have an adverse impact on the setting of the Broads.
Underground cable routes

Underground cable routes would have no perceived effect on the Broads.
Substations

A substation could have a substantial negative effect on the setting of the Broads. Whilst it may be possible to screen a substation with planting, it is likely to still appear incongruous in the landscape.