National Resources Wales’ draft guidance on Landscape Sensitivity and Capacity Assessment (LSCA) for wind and solar developments is stymied by the flawed context set by the Welsh Government
CPRW welcomes NRW’s guidance on LSCA because the landscapes of Wales are its prime concern and form a key ingredient in the Wellbeing of Future Generations Act 2015. The Welsh Government’s Planning Policy Wales Edition 10 (PPW10) of December 2018 contains an explicit approach to ‘Distinctive and Natural Placemaking and Well-being’ and stresses the value of ‘all the landscapes of Wales’.
However, these aspirations are crucially dependent on reforming the mis-mash of existing mechanisms and confused policy with which the process needs to work. CPRW is alarmed by PPW10 para 5.9.17 on impact assessment of renewable and low carbon energy generation proposals, added after the public consultation last year, and which states:
In circumstances where protected landscape, biodiversity and historical designations and buildings are considered in the decision making process, only the direct irreversible impacts on statutorily protected sites and buildings and their settings (where appropriate) should be considered.
This text fundamentally changes how the planning system defines material effects for individual proposals – and side-lines the LSCA process, rendering it impotent. It is contrary to the published Guidelines for Landscape and Visual Assessment and to the Environmental Impact Assessment Regulations, which both require all direct and indirect effects to be taken into account. It implies that impacts on undesignated sites may not be considered, and that because wind turbines and solar panels can be dismantled, their impacts are not to be taken into consideration because they are reversible.
Even if this clearly misconceived text were to be removed, there are further obstacles to the effective use of the proposed LSCA system. PPW 10 stresses the key role of the primary LANDMAP assessment system, but this ground-breaking and valuable tool is now showing its age and contains inconsistencies. It should be revised and updated to partner the LSCA.
The LSCA guidance is also intended ‘to support the Welsh Government’s Renewable Energy Toolkit for Planners’. Unfortunately, that has been found to be flawed, illogical and technically inadequate at important public planning events. An overhaul by new consultants is needed to raise it to a standard compatible with that now envisaged for the LSCA.
TAN (Technical Advice Note) 8 remains as it was originally written in 2005. Since then, its Strategic Search Area (SSA) concept for large-scale wind has been supplemented in some areas by the Local Search Area (LSA) approach for locating solar and wind below 25MW capacity, which has proved to be idiosyncratic, volatile, and unstable.
Given the confused and outmoded processes that are supposed to provided a framework for wind and solar development, the LSCA process should operate entirely separately from these allocations, and should apply to the whole of Wales prior to the final formation of local authority Renewable Energy Assessments.
CPRW doubts the ability, willingness and availability of local authority officers to commission and oversee such a consistent product and would argue that an all-Wales approach is led by NRW with LPAs acting as consultees.
CPRW has expressed reservations about some technical aspects of the proposed system in its detailed response to NRW, but believes that it is capable of developing into a consistent LSCA exercise that informs policies for the deployment of wind and solar technologies throughout Wales. This is, however, crucially dependent on reforming the mis-mash of existing mechanisms with which it needs to work.
Notes for Editors
CPRW was founded in 1928, last year celebrated its 90th anniversary, and is Wales’ only organisation whose primary concern is the country’s rural landscape and the land uses that support it. It is a membership charity (number 239899) with its head office at 31 High Street Welshpool Powys and 13 Branches throughout the country. Further details - including the full text of its response to the LSCA consultation - are to be found on its website https://cprw.org.uk/cms-data/resources/CPRW%20NRW%20%20LSCA%20consultation%20response.pdf
The NRW consultation text is available online at:
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