National Planning Policy is now strongly supportive of renewable energy but, together with Local Plans, that policy attempts to ensure that solar farms, wind turbines or battery storage systems are located in ‘the right places’. But the subject raises legitimate concerns, and this brief note explains in outline the factors that go into a planning decision. These factors are called ‘material’; other issues are ‘non-material’; I touch on some of these wider issues, too.
Renewable Energy in the Moorlands
In recent years the Moorlands has seen a significant number of renewable applications. The (non-definitive) map above was created by Moorlands Climate Action to help keep track. The map shows how closely projects follow the main 400kV power line from the Trent Valley (where the old coal-fired power stations were) to Macclesfield and beyond. Renewable energy typically needs a close connection to the National Grid.
Solar projects in the Moorlands are clustered in the south of the district (near the power line but not in the Green Belt). Battery storage sites are typically near the main Cellarhead sub-station (in the Green Belt). More and more individual farms have wind turbines, but the few larger ones are on the Morridge Ridge east of Leek. Here are some of the main planning issues surrounding placement of renewables sites…
Renewables and the Green Belt
The Stoke Green Belt covers a lot of the Moorlands north of Forsbrook; the National Grid line and the Cellarhead sub-station are bang in the middle of it. Renewable energy projects (like most others) need to demonstrate Very Exceptional Circumstances to be located in the Green Belt. This is a contentious and ever-evolving area – and does depend upon an application’s circumstances – but increasingly, Planning Committees (and Inspectors on appeal) are now accepting that renewables meet these criteria.
It is important to note that the Green Belt is a designation that has nothing to do with Nature as such. It is designed chiefly to limit urban sprawl. Ecological considerations are largely dealt with under….
Biodiversity Net Gain (BNG)
Introduced under the Environment Act 2021, BNG aims to go beyond existing protective laws by requiring all new developments to achieve a 10% uplift in biodiversity. This is measured using a national matrix and Staffordshire Wildlife Trust vets this procedure. In practice, it is usually relatively easy for renewables developers to go beyond this 10% minimum because, in the Moorlands at least, the baseline is low since sites have typically been subject to modern farming practices and can be species- and habitat-poor.
This uplift is usually achieved by a mixture of new tree, hedge and wildflower planting. A (non-definitive) example of a Landscape and Ecological Mitigation Plan for a solar development in the Moorlands is shown below.
While all this is ‘good’ in theory – and it is good – BNG is a new and evolving regime, whose true effectiveness will only be tested over time. While BNG involves a 30-year management contract, in the end it will depend on the Local Planning Authority to monitor compliance and enforcement to ensure the promised results for nature.
Renewables and Food Security
Most renewables projects are situated on farmland and its often argued that taking this land ‘out of production’ damages UK food security. The land use change undeniably reduces the amount available for farming (as do housing, golf courses or recreational paddocks for horses.) But planning policy strongly directs renewables away from the ‘best and most versatile’ land.
Further south and east in England there is some pressure on productive land and there have been real tensions caused where this has involved tenant farmers on sought-after land. But in the Moorlands, the overwhelming amount of renewables is sited on land graded 3b or 4 (poor) and so the ‘trade-off’ seems far less acute.
For some farmers, leasing land for renewables has been a vital part of diversification strategies, offering them a stable income stream allowing them to continue farming on other parcels they own or lease. Supporters of renewables argue that certain types of farming can be continued on the same site as, say, solar and there are already many examples of this in the UK and abroad. But the success or otherwise of these schemes can only be tested over time and, as with all sales brochures, those depicting happy sheep grazing alongside solar panels might best be treated with caution.
But what is a very significant point in planning law is that renewables are treated as ‘temporary’ and that they can be returned to agriculture in 40 years’ time (the length of the planning permission). But 40 years is long part of anyone’s life and as renewables are relatively new, we just don’t know how successful restoration to agriculture would be in practice. And while those projects are running, they will still have…
Visual and Landscape Impact
This is one of the hardest aspects of planning decisions. Despite experts and established parameters – number of viewpoints, terrain, lines of sight etc – there still remains an element of subjectivity. This gets harder still when ‘cumulative impact’ is judged – the overall effect of a number of similar developments over a large area. In the Moorlands, as said, we have two large clusters of renewable projects – in the south along the A50, and around the Cellarhead sub-station. Near Cellarhead a large solar farm application was recently turned down and its visual impact was a key part of that decision.
On the other hand, a decision to turn down a solar farm application that crossed the boundary into East Staffordshire was overturned by the Inspector on appeal. The reasoning included his view that the visual impacts cited as part of the original ‘no’ decision were vague and subjective and did not stand up against the much more tightly argued landscape case of the project sponsors. It may be relevant to note here that the SMDC planning officers had recommended refusal of the Cellarhead site but approval for the other one.
All renewables projects now include an element of screening – earthworks, tree and hedge planting. It is arguable that over time this might create a more richly textured landscape of woodland and hedges more akin to that before the advent of intensive farming practices. Equally, it is undeniable that even the best planting schemes take time to mature, and a development does usually involve the insertion of more industrial-type elements into the landscape.
Battery Storage Safety
This is often raised by objectors and is a legitimate issue; there have been fires at battery storage sites and once started (in a process known as thermal runaway) they can take some time to deal with. There have been calls to make the Fire Service a statutory consultee on applications – and any standardisation of safety regulations could certainly help damp concerns. But the Staffordshire Fire Service has issued up-to-date guidelines and all recent applications before the Planning Committee have adhered to these, including, crucially, early engagement with the Service on scheme design.
Why Can’t Renewables be Sited Elsewhere?
Brownfield sites and rooftops are often cited as alternatives to putting solar or storage on green fields – and indeed it make sense to encourage this as far as is feasible. The government’s new Future Homes Standard seeks to achieve this for new housing. The planning process requires applicants on renewable projects to demonstrate that they have first examined other sites (including brownfield) before seeking to build, particularly in the Green Belt.
This process typically lays bare the paucity of alternatives. There are far fewer suitable brownfield sites than is commonly thought: renewables need to be near main National Grid lines and most brownfield is anyway far more valuable for housing. On a national scale and given the pressing need for decarbonising the Grid there seems no way short of urgent central government diktats on millions of existing householders and commercial property owners to connect enough renewable generation and storage to the Grid in the timescales needed.
Wind Power
Onshore wind turbines had been effectively ruled out since 2015 and the only sizeable installations in the Moorlands are the three older ones on Morridge. But this effective ban has on new turbines has now been removed and there is already an application in for a site near Ipstones. Because of their wider visual impact, deciding on wind power applications will likely involve quite technical considerations on lines of sight and how distantly does ‘impact’ matter.
One particular issue will be the proximity of the National Park (which is its own Planning Committee). Though the park has recently become a little more accommodating to renewables, they will have a say of some kind in any Staffs Moorlands decisions on any turbines potentially visible in their area.
Community Benefit
Some renewables applications include an element of community benefits – a grant scheme for local parishes or community groups. While this is good practice and certainly helps the local community warm to a proposal, it is important to note that these are not a ‘material consideration’ in planning decisions. To weigh these in the balance would give the appearance of ‘buying permission’.
Article originally written for the Moorlands Green Network*
*This note seeks to outline the main issues in planning and are general in nature. Any comments should not be taken as supporting or opposing any particular application.