SPS Position – June 2021

1. Government advice on large scale solar

The Government has set legally binding targets to achieve net zero targets to decarbonise the economy as set out in the Clean Growth Strategy (2017 updated 2018), The Climate Change Order 2019 and the more ambitious targets set out subsequently in April 2021.

The National Planning Statement on Renewable energy is silent on commercial solar, but nevertheless calls for an urgent increase in renewables. The NPPPF supports the increase in renewable energy, subject to balancing any environmental harm against the public benefits. An increase of up to 40GW of new capacity must be added to the electricity system if the Government’s 2050 targets are to benefit.

However, against this urgent imperative for renewables stand the following Government guidance and statements:

Government Planning Practice Guidance for Renewable and Low Carbon Energy 2013 (para 15) states that (our emphasis):

In shaping local criteria for inclusion in Local Plans and considering planning applications in the meantime, it is important to be clear that:

the need for renewable or low carbon energy does not automatically override environmental protections

cumulative impacts require particular attention, especially the increasing impact that wind turbines and large-scale solar farms can have on landscape and local amenity as the number of turbines and solar arrays in an area increases

local topography is an important factor in assessing whether wind turbines and large-scale solar farms could have a damaging effect on landscape and recognise that the impact can be as great in predominately flat landscapes as in hilly or mountainous areas

• great care should be taken to ensure heritage assets are conserved in a manner appropriate to their significance, including the impact of proposals on views important to their setting

• proposals in National Parks and Areas of Outstanding Natural Beauty, and in areas close to them where there could be an adverse impact on the protected area, will need careful consideration

• protecting local amenity is an important consideration which should be given proper weight in planning decisions

The UK Solar PV Strategy, Roadmap to a Brighter Future, 08 October 2013 was based upon four principles. The third principle of the strategy was a requirement that solar PV should ensure proposals are appropriately sited, give proper weight to environmental considerations such as landscape and visual impact, heritage and local amenity, and provide opportunities for local communities to influence decisions that affect them.

The Ministerial Statement from the Secretary of State for Communities and Local Government (25 March 2015) stated:

Meeting our energy goals should not be used to justify the wrong development in the wrong location and this includes the unnecessary use of high-quality agricultural land. Protecting the global environment is not an excuse to trash the local environment. When we published our new planning guidance in support of the Framework, we set out the particular factors relating to large scale ground mounted solar photovoltaic farms that a local council will need to consider. These include making effective use of previously developed land and, where a proposal involves agricultural land, being quite clear this is necessary and that poorer quality land is to be used in preference to land of a higher quality…. We are encouraged by the impact the guidance is having but do appreciate the continuing concerns, not least those raised in this House, about the unjustified use of high-quality agricultural land. In light of these concerns, we want it to be clear that any proposal for a solar farm involving the best and most versatile agricultural land would need to be justified by the most compelling evidence.

2. SPS Position

SPS supports the transition towards a zero-carbon energy system and recognises that this requires an increase in renewable energy generation, including solar.

We support renewable energy schemes which balance the necessary considerations of our natural environment, heritage, landscape and the views of local people and allow local communities to positively shape their energy futures.

Therefore:

  • The re-use of brownfield sites for large scale commercial solar farm should always be the preferred option
  • All new development, except in sensitive settings, should be encouraged to include solar panels on roof tops, both residential, industrial and commercial
  •  ‘Best and most versatile’ agricultural land (Grades 1, 2 and 3a) should be avoided
  • Applications should be supported by a Landscape and Visual Impact assessment in accordance with the guidelines set out by the Landscape Institute. An assessment of any cumulative impact with other existing and planned solar installations must be included.
  • Applications that result in the significant change in character of footpaths or other public rights of way should be resisted and amendments sought to revise the layout and/or appropriate landscape mitigation sought to ameliorate impact upon receptors including walkers, riders, cyclists and motorists
      • A full land management plan should accompany all applications providing detailed information on the way in which the land will be maintained (grass cutting regimes; any use of pesticides/insecticides; animal grazing proposals; etc) and related conditions should be applied to any permissions granted
      • A decommissioning plan which identifies all of the key elements required to return the land to a natural state should be prepared and form a part of any planning application. This should provide details (related to best current practice) of the work required, the opportunities for recycling and an estimate of current cost