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

Object

Representation ID: 4365

Received: 29/08/2025

Respondent: Broads Authority

4.10.11 – the description of a typical substation says it includes lighting. Yet this section says lighting is not considered, save for emergency attendance. So, do these schemes have lighting associated with them or not?
Throughout – it is not clear what is meant when it says: No external lighting, save that for emergency attendance
4.10.14 part 4 – a random number 4 in there

Support

Representation ID: 4374

Received: 29/08/2025

Respondent: Broads Authority

General comments
This is the first round of engagement. Will you consult again on this SPD?
Currently no reference to the Local Nature Recovery Strategy, which should be included for things like planning planting to screen sites.
For the cables and pylons – I feel there should be a reference that the s.245 duty (Section 245 of the LUR Act amends the National Parks Act, the Countryside and Rights of Way Act, and the Norfolk and Suffolk Broads Act, relating to protected landscapes) means that when a preferred route is being considered, the need to direct them away from the Broads should be considered – for instance the often floated alternative route for Norwich-Tilbury requires a Norwich – Coast connection that has to go through either the Broads or the Suffolk Coast National Landscape.
You may wish to consider adding something that discusses that it is important to note that just because you can't see a proposal, it doesn't mean there isn't a landscape impact. We include this following text in the emerging Local Plan (see below in italics). There is also this appeal decision that talks about this – the appeal is not about energy infrastructure, but its findings about landscape character seem relevant to all development types: Planning Inspectorate APP/E9505/W/25/3359289: Manor Gates Garden, NR29 5AB. Para 6 says ‘However, even if it were completely unseen from public land, the boat cover would detract from the special qualities of the Ludham CA and the Broads’.
In simple terms Landscape and Visual Impact Assessment is a tool to identify the effects of change resulting from a specific development, and in the case of full LVIAs (EIA development) to assess the significance of the effects. The Guidelines for Landscape and Visual Impact Assessment (GLVIA3), clearly distinguishes between effects on landscape as a resource in its own right, and effects on specific views and general visual amenity experienced by people. There are some common principles set out within chapter 3 of the guidelines that relates to both landscape and visual considerations. However, the guidelines have separate chapters (chapter 5 for Landscape effects, and chapter 6 for visual effects) to deal with the explanation of how these should be dealt with within the assessment. Furthermore, it is common and good practice for an assessment to provide the landscape baseline and visual baseline separately.
Landscape effects concern changes to landscape as a resource, the landscape fabric itself, landscape character, individual components of the landscape and the aesthetic and perceptual qualities.
Visual effects concern how people will be affected by changes in views and or visual amenity.
The Landscape Institute have recently published Technical Guidance Note (LITGN-2024-01) in relation to GLIVA3. One of the issues raised within the TGN provides a good reference point as an example of distinguishing between landscape and visual matters. In this instance in relation to mitigation, the statement item 4(3) of the document reads “Care should be taken to ensure landscape and visual mitigation is not confused. For example, it does not necessarily follow that screening a development from view would reduce its landscape effects, such as those on landscape character.”

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.