Support

Representation ID: 4323

Received: 12/08/2025

Respondent: Historic England

5.1.3 We welcome this paragraph which provides a helpful caveat explaining the limitations of Susceptibility Assessment. However, this could be expanded along the lines of the suggested paragraphs under b) on page 2. In addition, the caveats setting the use and limitations of the Study should not just be in Chapter 5 but should be clearly set out at the start of the document.
RECOMMENDATION: Expand the paragraph along the lines of our suggested paragraphs under b) on page 2. Also include scope and caveats at the start of the document in the Introduction.
It is unclear why Section 5 is just limited to Susceptibility and not widened to include value and hence Sensitivity like Section 6. Please can you clarify.

Support

Representation ID: 4337

Received: 20/08/2025

Respondent: Norfolk County Council - LLFA

2.14.
In relation to section 5 considerations, it is worth noting that in flood risk assessment terms under NPPF guidance, solar farms are considered as 'Essential infrastructure' while BESS and AD sites would be considered as 'Highly vulnerable' as this energy infrastructure does not need to be located in a flood risk area for operational reasons. As a BESS is for the storage of electricity and as there is no obvious need for the installations to require a coastal or water-side locations or need for them to be located in other high flood risk areas, then a BESS facility is considered to be in the 'Highly Vulnerable' class of development. As NPPF requires that all sources of flood risk are assessed in the Sequential Test. In the Sequential Test, a 'Highly Vulnerable' development in Flood Zone 2 or equivalent from other sources of flood risk would require the exception test. While a site is Flood Zone 3 or equivalent from other sources of flood risk would not be considered acceptable development for that location. This is likely to direct these developments away from lower lying areas or areas where surface water flow paths are presence.

Object

Representation ID: 4342

Received: 01/09/2025

Respondent: SLR Consulting Ltd

Agent: Mrs Jennifer Gordon

While noting that Table 1 is a summary of the LSS. The table highlights that for all solar farms above 15MW, the susceptibility to development is mostly high with a few medium-high. This seems overly generic and should be considered on a case by case basis. Perhaps this can be reviewed for some ‘farmland areas’ and making it clear this is subjected to individual site assessment.