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

Support

Representation ID: 4311

Received: 12/08/2025

Respondent: Historic England

1.1.4 We welcome the reference to protecting and enhancing local character.
1.1.5 We welcome the reference to locally distinctive characteristics.

Support

Representation ID: 4312

Received: 12/08/2025

Respondent: Historic England

2.3.7 Policy 3 of GNLP. This is only a partial quotation of policy 3 of the GNLP. The first part of the policy relates to the Built and Historic Environment.
RECOMMENDATION: We advise that this should also be included in the SPD since impacts on the historic environment are also important.
2.3.10 This is a partial quote of the policy and misses the references to heritage.
RECOMMENDATION: We advise that the full policy should also be included in the SPD since impacts on the historic environment are also important.
2.3.11 We welcome the reference to character and appearance of the landscape

Support

Representation ID: 4313

Received: 12/08/2025

Respondent: Historic England

2.4 Whilst we welcome the reference to the National Policy Statement EN-1 the review in section 2.4 is very selective and does not mention the historic environment section of the Policy Statement.
RECOMMENDATION: We advise that reference to the historic environment section of the NPS should also be included in this section of the SPD.

Object

Representation ID: 4314

Received: 12/08/2025

Respondent: Historic England

3.4.2 Please can you confirm if scheduled monuments and listed buildings as well as non-designated heritage assets have also been included?
Insufficient consideration of historic environment in methodology and assessment More generally, in relation to the methodology, we are concerned that the methodology for the study falls short and is very much focussed on landscape with minimal consideration of the historic environment.
We appreciate that the Assessment is not completely devoid of consideration for historic environment issues. For example, in Appendix 3 The Landscape Susceptibility Analysis mentions heritage assets including some conservation areas and some registered parks and gardens.
However, heritage does not appear to have not been considered in the identification of areas of sensitivity and therefore it is our view that the Landscape Sensitivity Assessment does not give sufficient consideration to heritage assets and their settings.
Further, more detailed heritage specific assessment is needed now which should give greater consideration to heritage assets and their setting, as described in Historic England Advice Note 15. Paragraphs 23-27 set out advice regarding how to assess areas for renewable energy development and the importance of considering heritage assets.
We would emphasise that a receptor buffering approach is neither appropriate nor sufficient to assess impact upon the significance of heritage assets since it fails to engage with their historic landscape, designed landscape, topographic or archaeological context.

Support

Representation ID: 4315

Received: 12/08/2025

Respondent: Historic England

Paragraph 3.7.1 This is an important section of the SPD, setting out the limitations of the LSS. Bullet point 4 is particularly pertinent and helpfully clarifies that the study only really considers landscape.
RECOMMENDATION: We advise including the words ‘or heritage assets’ after ‘ecological habitats’ at the end of the third sentence of the fourth bullet point.

Object

Representation ID: 4316

Received: 12/08/2025

Respondent: Historic England

4.3.2 We note that the SPD states that the design development guidelines only relate to landscape susceptibility and not to other areas of potential environmental impact. Indeed, the guidelines set out at paragraph 4.3.4 are mainly landscape focussed. However, the historic environment is an important aspect of the landscape and should therefore be included in any development guidelines.
RECOMMENDATION: We advise that a more holistic approach is needed which captures historic environment considerations for design as well.

Support

Representation ID: 4317

Received: 12/08/2025

Respondent: Historic England

4.5.3 The threshold is due to change in December 2025.
RECOMMENDATION: We advise that the change in threshold should be noted here.
4.5.11 We note the reference to conservation areas and listed buildings and park in bullet point 3 and 5. Bullet point 3 should also refer to scheduled monuments and registered parks and gardens
RECOMMENDATION: Amend bullet point 3 to make it clear that this also includes scheduled monuments and registered parks and gardens. Also amend wording as currently implies just the settings of those designated heritage assets that should be avoided but it should also include the assets themselves.

Support

Representation ID: 4318

Received: 12/08/2025

Respondent: Historic England

4.6.8 We note reference to greater time depth at bullet point 9 and viewpoints from Conservation Areas at bullet point 14. We also welcome reference to local vernacular at bullet pint 16 and historic assets at bullet point 19. However, there is currently insufficient reference to the historic environment including designated and non-designated heritage assets and their settings.
RECOMMENDATION: Add a new bullet point to read: Ensure that designated heritage assets including Listed Buildings, Conservation Areas Scheduled Monuments and Registered Parks and Gardens as well as non-designated heritage assets and their settings are conserved and enhanced through careful siting and design of AD plants as well as appropriate landscape mitigation.
Amend bullet point 19 from historic assets to heritage assets in line with the NPPF terminology.

Support

Representation ID: 4319

Received: 12/08/2025

Respondent: Historic England

4.8.18 We welcome the reference to sub note to Rule 2 of the Holford Rules relating to overhead lines and designated heritage assets.

Support

Representation ID: 4320

Received: 12/08/2025

Respondent: Historic England

4.7.11 We note that there is reference to greater time depth at bullet point 8 and areas with historical significance e.g. parklands at bullet point 9. We note reference to viewpoints from conservation areas at bullet point13, local vernacular at bullet point 15 and historic assets at bullet point 18. However, there is currently insufficient reference to the historic environment including designated and non-designated heritage assets and their settings.
RECOMMENDATION: Add a new bullet point to read: Ensure that designated heritage assets including Listed Buildings, Conservation Areas Scheduled Monuments and Registered Parks and Gardens as well as non-designated heritage assets and their settings are conserved and enhanced through careful siting and design of battery storage developments as well as appropriate landscape mitigation.
Amend bullet point 18 from historic assets to heritage assets in line with the NPPF terminology