Guidance Note for the Renewable and Low Carbon Energy Generation in North Somerset Supplementary Planning Document

Document Section Guidance Note Site Selection Site Selection [View all comments on this section]
Comment ID 705793//3
Respondent Deleted User [View all comments by this respondent]
Response Date 14 Jul 2013
Current Status Accepted

3.2 We are pleased that the policy recognises the cumulative impact of solar PV sites.

3.4 We would like to see considerably stronger commitment to keeping BMV land in agricultural use, for reasons of food systems sustainability and food security. We suggest that Grade 1 agricultural land should be more or less off limits for development; grade 2 and 3a should only be developed in very special circumstances. In the case of solar arrays, the function of which is not dependent on the precise site, we suggest that planning permission should only be granted on land of grade 3b or worse and only where any proposal meets the other requirements e.g. in relation to landscape, in this policy.

The language in the draft document is not currently strong enough. The NPPF uses very weak language on this vital issue and we feel that local authorities have a duty to make up for this shortfall.

3.5 – 3.11 CPRE support this section which deals very well with landscape and visual impact issues. We would add that in some cases, additional planting and management of trees could screen a specific view while also added to the value of the natural environment. We would like to see a paragraph added to this effect:

"Where the installation is generally low in visual impact but there are specific narrow view cones into the site, planning may be granted with a condition relating to the planting or management of hedgerow trees to block that particular view".

3.10 This paragraph could be strengthened to prevent removal of existing mature trees from hedgerows, which might be desirable from point of view of allowing the solar array to be installed un-shaded right up to the field boundary, but which would have a detrimental effect on landscape and biodiversity.

3.15 We support this strongly and feel that more could be made of the opportunities to improve biodiversity around solar installations. In a sense, the land beneath a solar array is ‘free’ land, in that the economics of the land ownership are carried by the solar installation. There is therefore great potential to use the land in ways that might not otherwise be economically practical. For example:

  • The restoration of ‘unimproved’, species-rich grassland habitats.
  • Taking advantage of the ‘edge effect’, whereby the borders of particular habitats have greater biodiversity; the intermittent shade of a solar array offers interesting opportunities for marginal, shade-loving and endangered species.
  • The possibility of creating habitats rich in wildflowers with apiculture as part of the permanent management plan, to increase bee numbers to the benefit of surrounding farmlands.

We would like to see:

  • A requirement for a short biodiversity survey of the surrounding areas, to identify the key issues that could be addressed within a biodiversity plan for the site. This need not be expensive; local wildlife trusts might be happy to provide basic local information free of charge.
  • A requirement for a biodiversity plan for each site. This need not be onerous – relatively cheap actions could make a big difference.
  • These requirements should be added into the appendix regarding planning application and EIA submission requirements.

3.19 There is great risk that Solar PV arrays will meet the other requirements of this policy but will still have serious impacts in relation to infrastructure requirements and we are very supportive of 4.1- 4.15 that covers details of these requirements and is essential to proper siting and protecting both the landscape and other impacts for local communities.