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

Object

Representation ID: 4332

Received: 20/08/2025

Respondent: Norfolk County Council - LLFA

2.1.The LLFA notes that while the SPD is focusing on the implications for the local plan, the SPD was meant to consider all energy projects. Yet in section 4.1.2, the different development scales are shown to be under the threshold of the NSIP scales of development. However, the majority of the proposed energy infrastructure development exceeds these thresholds. It would be useful for the LPA to provide some commentary on how the LPA would expect the SPD to interact with the NSIP applications and the applicant's considerations.

Object

Representation ID: 4333

Received: 20/08/2025

Respondent: Norfolk County Council - LLFA

2.2.In relation to section 4.3.4 bullet point 5, there is mention of the need to "Consider the landscape effects of drainage features such as SuDs, which can have a highly engineered form and suburbanising associated paraphernalia. Ensure they have sufficient space to enable shallow sides and opportunities for habitat creation, so as to create meaningful and positive additions to the landscape." The LLFA supports this approach and notes that frequently the applicant's do not consider the compacted platform areas created to facilitate the proposed development as an area that behaves as an impermeable surface. Subsequently, in section 4.7.8, the text states presences a counter-perspective of "Engineered drainage features such as SuDS features and earthworks, including artificial mounds that might be used to screen the development, can have an intrusive effect in the landscape." there is inconsistency in the consideration of the inclusion of SuDS in the proposed design that could undermine their inclusion. While the LLFA appreciates the technical consideration presented in both sections, it is not clear why it is a positive for solar farms and a negative for Battery Energy Storage System (BESS) sites to include SuDS.
2.3.In addition, the temporary construction areas would also need to be considered in terms of surface water management and an appropriate area would need to provided to facilitate the management of the increase in surface water runoff from the construction infrastructure. It is also noted that in a number of applications that have been reviewed to date, the need for frequent maintenance of the proposed temporary energy development such as solar farms and BESS facilities will require construction compound facilities to be built and removed every few years causing regular disturbance to the landscape and local surface water management. The use of surface level SuDS is required for all stages of the development's life cycle, however for SuDS to be effective they require time for the vegetation to mature in order to provide the benefits to the water quality, biodiversity and amenity. Therefore, the LLFA suggests there should be the need to consider the construction facilities that are needed to maintain the proposed development and whether a longer term construction facilities area (access, laydown area, surface water management and utilities connections) should be provided throughout the lifetime of the development to reduce the disturbance to the local area and ensure better management of long term risks such as surface water runoff.
2.4.
2.5.Furthermore, it is worth noting that in the subsequent bullet point 6, the "artificial mounds that might be used to screen the development" are also likely to be formed from compacted material that would likely have an increased runoff rate from the structures. This would likely increase the potential size of the attenuation areas to be constructed to prevent the increase in flood risk from the development.

Support

Representation ID: 4334

Received: 20/08/2025

Respondent: Norfolk County Council - LLFA

2.7.In section 4.5, the LLFA suggests that grid connection infrastructure such as substations are included in the description of the solar farms and BESS as more often we are now seeing this infrastructure included in applications due to a general lack of this type of infrastructure in the area. Therefore, it would be appropriate to acknowledge the grid connection infrastructure into the considerations. In addition, it is noted that frequently solar farms now come forward with BESS facilities incorporated into the solar farms. This should also be mentioned in this section.

2.9.The LLFA has reviewed the renewables mapping browser and notes that there are a number of proposed developments that appear to be not included on the mapping such as the Markshall Solar Farm with BESS facility, the Tasway Energy Park, the proposed extension to the Yelverton solar farm and more.

Support

Representation ID: 4335

Received: 20/08/2025

Respondent: Norfolk County Council - LLFA

2.11.In section 4.7.5, the text indicates that batteries and other components are considered to be a permanent development. However, recent experience has seen a large number of temporary applications come forward for temporary sites of 40 to 60 years in duration. As a battery unit is expected to have 15 to 20 year design life, the replacement of the battery units to facilitate the design life of the development for the long term temporary period. The site would then need to be decommissioned to meet with the planning permission. It is frequently not clear what would be removed. However often it is only the units that would be decommissioned, while the support infrastructure such as grid connections, cabling and access facilities remain, yet the applicant wants all components to be treated as a temporary development rather than acknowledging the permanent nature of the development. This is an issue for the LLFA as it alters the surface water management assessment and design parameters such as climate change allowances and the possible resilience measures. Similar issues occur on the solar farm sites too.

Support

Representation ID: 4336

Received: 20/08/2025

Respondent: Norfolk County Council - LLFA

2.12.In relation to the points made in section 4.8.7, the LLFA notes the lack of comment on the need for a substantial temporary construction area around location of the pylon that has is some applications suggested that some temporary topsoil striping or disturbance is required in addition to the construction compound areas, temporary haul roads and other construction facilities to enable construction activities. This is of interest to the LLFA due to the potential to alter and disrupt surface water flow paths, surface water attenuation and potential impacts associated with soil and subsoil compaction that could result in an increase in flood risk.
2.13.The LLFA notes the support for the consideration of the use of green roofs in the various designs in chapter 4. The LLFA supports this inclusion and suggests that it would be helpful to link it to the SuDS design too.

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.