APPENDIX 1
SUMMARY REPORT
AVIATION EVALUATION
PROPOSED SOLAR FARM
FORMER RAF COLTISHALL
SCOTTOW MOOR SOLAR
DECEMBER 2014
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1.1
1.0
INTRODUCTION
2.0
PROPOSED AVIATION USE
3.0
OPERATIONAL REQUIREMENTS FOR A C-130
HERCULES
4.0
SAFEGUARDING THE RUNWAY
5.0
FINANCIAL IMPLICATIONS
6.0
CONCLUSION
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1.0
INTRODUCTION
1.1
Scottow Moor Solar Limited has submitted a planning application to North Norfolk
District Council and Broadland District Council for the development of a solar farm
on the grass areas either side of the runway at former RAF Coltishall. During the
pre-application consultation and at the Planning Committee meeting of Broadland
District Council on 18 November 2014, the issue of the compatibility of the solar
farm with possible future use of the runway was discussed. The question was
asked as to whether the solar farm could be designed to enable potential use of
the runway by Hercules aircraft that might be used by an occupier of the Scottow
Enterprise Park for humanitarian missions.
1.2
In response to this question, Scottow Moor Solar Limited commissioned a report
from Falcon Consultancy Limited, aviation experts on:
(i)
What the Civil Aviation Authority’s (CAA) requirements would be
should the runway be utilised for aerodrome purposes;
(ii)
What supporting infrastructure would be required;
(iii)
What criteria would the solar farm have to meet to enable the two uses
to co-exist.
2.0
PROPOSED AVIATION USE
2.1
Aviation activity is controlled by the CAA who license facilities to ensure their
suitability for the safe operation of aircraft.
The requirements for licensing an
aerodrome are set out in CAP 168. In addition, CAP 793, Safe Operating Practises
at Unlicensed Aerodromes, Chapter 4, paragraph 2 states that:
“while the licensing criteria may not be necessary for safe operation of every type
of aircraft” they can be used as a guidance on which the layout of an unlicensed
aerodrome may be based”.
It is therefore recommended by the Falcon Consultancy report that considering the
size and performance of the target aircraft (Lockheed Martin C-130J) and the
proposed frequency of operation (occasional humanitarian missions), the
requirements of CAP168 should be followed in full.
2.2
The specific regulatory requirements for the resumption of aircraft use at former
RAF Coltishall is therefore set out in the Aerodrome Reference Code in CAP 168.
This defines the operational requirements of an aerodrome based on the
parameters of the target aircraft – the field length required for take-off and landing
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December 2014
and the wingspan. Rescue and fire fighting requirements are determined by
fuselage length.
2.3
A C-130 Hercules has a take-off distance requirement of 1,783 metres. The
wingspan is 40.38 metres. Its classification is therefore Code 3(D).
3.0
OPERATIONAL REQUIREMENTS FOR A C-130 HERCULES
3.1
The runway at former RAF Coltishall is 2,286 metres in length, 45 metres in width
and it has three turning pads. An inspection of the runway would be required to
determine whether it is still in a safe condition as if there is any deterioration it
would need to be repaired by the application of a seal treatment. Ongoing
maintenance works would include regular weed-killing spray treatment and the
repair of minor defects. Any significant resurfacing works would be at considerable
cost, possibly several million pounds.
Related works to return the runway to operational use would include new paint
markings, the restoration of other areas between the turning pads and
reconfiguration to allow unimpeded access to the taxiways.
3.2
The taxiways at former RAF Coltishall are adequate for a C-130 Hercules.
Taxiways are also required to be of a similar width, strength and surface condition
to the runway. An inspection of the taxiways would also be required to determine
whether they too are in a safe condition.
3.3
Aprons are the areas of an aerodrome where aircraft can be safely parked whilst
loading/unloading operations take place including the safe movement of
associated ground servicing equipment. The aprons at former RAF Coltishall can
accommodate a C-130 Hercules. However, consideration would need to be given
to their condition and the operational requirements should aircraft use the runway.
These requirements are a function of the proposed frequency of use of the runway.
3.4
Former RAF Coltishall is within the Norwich Control Zone (CTR) and operations at
former RAF Coltishall and Norwich Airport are inter-dependent. Even if there was
only an irregular operation of C-130 Hercules aircraft, air traffic control would need
to be provided for arriving and departing aircraft. This could be undertaken by
Norwich Air Traffic Control (ATC) and would require the development of
operational procedures, staff training at Norwich ATC and approval by the CAA.
If ATC were provided on-site, the existing control tower would require
refurbishment and retrofit. Alternatively a mobile ATC could be utilised.
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3.5
Aircraft operations have to be covered by rescue and fire fighting services. The
scale of services required is determined by the size of aircraft. The provision of
permanent rescue and fire fighting services at former RAF Coltishall for sporadic
use by a C-130 Hercules would be prohibitive. It may be possible to make an
arrangement with the local fire fighting service to provide cover only during aircraft
operations.
3.6
Other requirements associated with the use of the runway are aircraft fuel
provision; aircraft ground lighting, ground communication system, navigational
equipment to enable aircraft to navigate at night and in poor weather conditions
and accommodation for personnel.
4.0
SAFEGUARDING THE RUNWAY
4.1
The solar panels of the proposed solar farm are sited at 10 metres distance from
the edge of the runway and reach a height of 2.56 metres. This gives a total lateral
separation of 18.2 metres as measured from the outer edge of the runway strip.
If the runway were to be safeguarded for potential future use by aircraft a 75 metre
strip would be required both sides of the runway centre line extending 60 metres
beyond the runway threshold at the northern and southern ends. (This would also
have implications for Norfolk County Council’s proposals in these areas). In
addition, an 18.2 metre wide safeguarding zone would be required extending along
the runway strip perimeter.
4.2
Whilst solar panels have low reflectivity, they might cause glare and dazzle
resulting in pilots confusing them with aeronautical lights. Whilst permission is not
required from the CAA to shine or reflect a light or lights into the sky, should
aviation use be re-introduced at former RAF Coltishall, compliance with Air
Navigation Order 2009 would need to be demonstrated with respect to safety on
aircraft and lights, in particular glint and glare which could occur from the solar
panels during low level circumnavigation, passage over the airfield and during
approach and take-off operations.
The alignment of the solar panels for the proposed solar farm at former RAF
Coltishall is directly south with an inclination and lateral separation to prevent
shading. Due to this alignment, it is not considered that the solar panels would give
rise to glint or glare which would critically obstruct or compromise the navigation of
aircraft. However, in order to meet the requirements of Air Navigation Order 2009,a
detailed risk assessment would need to be undertaken to ensure that the risk of
glint or glare is not significant.
4.3
The solar farm does not emanate any electromagnetic radiation and the gird
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December 2014
connection is via underground cables. There will therefore be no risk of
interference with communication systems for aviation.
4.4
The structural resilience of the solar panels when a C-130 Hercules is
manoeuvring from a stationary position in the apron area, operational areas and at
the point of entry onto the runway and prior to take off, could be considerable. The
likely zone of impact during these manoeuvres would need to be mapped and the
structural resilience of the solar farm validated against these parameters. Within
the zone of impact any potential obstruction would need to be collapsible. This is
not practical for solar panels.
4.5
In their report Falcon Consultancy have provided an initial assessment of the
implications for the layout of the solar farm should it be designed to allow future
operation of the runway. This takes into account a safeguarding zone and blast
protection. The current proposal is for a solar farm on 88.6 hectares of the airfield.
Safeguarding the runway and a blast protection zone would limit the solar farm to
an area of approximately 60 hectares.
5.0
FINANCIAL IMPLICATIONS
5.1
Whilst the landowner would not incur any costs by safeguarding the runway and
leaving it unused, returning the airfield to operational use, even sporadic use,
would require capital investment to repair the runway, taxiways and aprons. In
addition, provision would need to be made for the purchase of other ancillary
equipment required for safe operations. For example, ATC, communication
systems and lighting.
Ongoing operational and maintenance costs would also be incurred by the
landowner or operator in order to maintain the runway and ancillary areas in a
condition that would allow the landing and take-off of aircraft and maintain CAA
licensing status.
6.0
CONCLUSION
6.1
Safeguarding of the runway and ancillary areas would have significant implications
for the design and financial viability of the proposed solar farm. In addition,
safeguarding of the runway is not considered to be viable in the absence of a firm
commitment to utilise it in the near future given the commitment this would require
with respect to capital costs and ongoing revenue requirements
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1.6
2
PV ZONE - A AREA
89,122.21 sq.m.
22
AIRFIELD SITE AREA
51,989.47 sq.m.
PV ZONE - B AREA
178,124.98 sq.m.
1.7
PV ZONE - C AREA
259,479.24 sq.m.
AIRFIELD SITE AREA
2,414,270.89 sq.m.
PV ZONE - D AREA
39,112.41 sq.m.
04
PV ZONE - E AREA
13,769.73 sq.m.
04
SUPPLEMENTARY STATEMENT
PROPOSED SOLAR FARM
FORMER RAF COLTISHALL
SCOTTOW MOOR SOLAR LTD
DECEMBER 2014
1.8
1.0
INTRODUCTION
2.0
SITE SELECTION
3.0
ECONOMIC DEVELOPMENT
4.0
DEVELOPMENT SIZE
5.0
PUBLIC BENEFIT
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SECTION 1.0
INTRODUCTION
1.1
This Supplementary Statement has been prepared for North Norfolk District
Council and Broadlands District in order to further support the application and to
provide clarity on a number of issues raised during the consultation process.
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SECTION 2.0
SITE SELECTION
2.1
Recent Government guidance on solar farm developments favours brownfield sites
and commercial roof tops over greenfield sites for the development of solar energy
projects. Within Norfolk, most solar farms have been developed on agricultural
land because of a lack of suitable brownfield sites. This proposal on brownfield
land will relieve the pressure for further solar farm projects to be developed on
greenfield sites.
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SECTION 3.0
ECONOMIC CONTRIBUTION
3.1
In addition to the public benefit associated with the need for low-carbon clean,
renewable energy (see Planning Statement), the proposal also can bring
significant benefits to former RAF Coltishall. This is because the income generated
by the project will make a significant financial contribution to support the
management and operation of the site and its regeneration as an enterprise park.
In so doing, it will bring positive public benefit to the local and wider community in
Norfolk.
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SECTION 4.0
DEVELOPMENT SIZE
4.1
Scottow Moor Solar Limited is seeking to deliver a ground mounted solar farm that
would deliver up to 49.9 MW of local low carbon energy. This is the energy
generation level required for commercially viability. The project’s use of RAF
Coltishall will financially benefit Norfolk County Council via rental income, and
Broadland and North Norfolk through business rates.
4.2
A key factor in determining the commercial viability of any solar energy project (as
well as other types of energy project) this the cost of the grid connection. If the grid
connection costs are deemed to be too high, then projects, including this one, are
uneconomic and will not meet the relevant investment criteria.
4.3
Over the last five years, the UK has experienced considerable growth in the
connection of distributed generation to the national grid. As a result there is now a
very real shortage of grid capacity in many regions of the UK making it difficult for
distributed generators to connect to the grid and export their generation.
4.4
Therefore, two key issues have to be considered in tandem when assessing
whether a project is commercially viable:
4.5
(i)
Can I connect to the grid;
(ii)
What is the cost of connecting to the grid.
UK Power Networks (UKPN), the distribution network operator for Norfolk,
considers that its Norfolk distribution area has very real connectivity issues as a
result of caps on investment in the distribution network as well as capacity being
taken up by large renewable energy projects such as Sheringham Shoal, the major
offshore wind project.
As a result, securing export capacity in Norfolk has been significantly restricted
and many solar farm developers are abandoning project proposals in the UKPN
Eastern area.
4.6
UKPN have been seeking to address this and have participated in a pilot
programme with OFGEM, the electricity regulator, to assess whether “flexible”
connections could provide a solution to this problem. Flexible connections allow a
generator to connect to the network but at times they may have their export
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December 2014
curtailed to less than their “nameplate export” capacity to prevent the grid from
becoming overloaded.
4.7
In November 2014 UKPN made “flexible plug and play” connections available to
generators in the UKPN Eastern region.
4.8
Scottow’s has been offered a “flexible plug and play” connection offer by UKPN.
Because this is likely to require curtailment during peak periods, the solar farm is
sized to achieve maximum generation when permitted in order to offset any
periods when the export is curtailed. Due to these curtailment requirements, any
scaling back or phased development of the solar farm will have an impact on its
commercial viability and therefore its realisation.
4.9
The proposed solar farm at the former RAF Coltishall is ideally located for
connection to the UKPN grid as its Scottow primary substation is located within
450 metres of the solar farm site. However, an additional connection to Worstead
sub station, will also be required due to restrictions on the grid at Scottow. Given
Worstead sub station’s distance from the solar farm site, there will significantly
higher connection costs than at Scottow that must be borne by the project.
4.10
Utilising only the grid connection capacity at Scottow is technically possible but the
project would not be commercially viable. The Worstead connection is therefore
required in to ensure commercial viability.
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SECTION 5.0
PUBLIC BENEFIT
5.1
The proposed scheme would make a significant contribution to UK renewable
energy provision. The proposed solar farm would generate sufficient electricity to
provide the annual power needs to 15,000 households and would save in the
region of 25,500 tonnes of carbon dioxide per annum that would otherwise be
generated through the burning of traditional fossil fuels. Renewable energy is a
public interest matter and this is a proper planning consideration when considering
the impact of the development in the context of the NPPF and its presumption in
favour of sustainable development.
5.2
Specifically the NPPF aims to encourage a positive approach to renewable energy
from local planning authorities. It requires them to:
•
have a strategy promoting energy from renewable and low carbon
sources;
•
actively identify suitable areas and supporting infrastructure;
•
to maximize development of alternative energy.
The substantial local low carbon energy generation provided by the proposed solar
farm is therefore a significant “public interest” benefit.
5.3
In undertaking pre-application consultation on the proposed solar farm at former
RAF Coltishall, the feedback from local residents was supportive with many
welcoming the proposal as a benign renewable energy development. In many
cases, local residents considered the proposal to be a good use of the airfield and
preferable to other previously considered development options.
82 people visited the pre-application exhibition and the majority were in favour of
the proposed solar farm.
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1.15
EAST OF ENGLAND OFFICE
Mr G Lyon
North Norfolk District Council
Planning Service, Council Offices
Holt Road
Cromer
Norfolk
NR27 9EN
Direct Dial: 01223 582751
Direct Fax: 01223 582700
Our ref: P00437601
29 November 2014
Dear Mr Lyon
Notifications under Circular 01/2001, Circular 08/2009 &
T&CP (Development Management Procedure) Order 2010
FORMER RAF COLTISHALL, LAMAS ROAD, SCOTTOW, NORFOLK NR10 5LR
Application No PF/14/1334
Thank you for your letter of 28 October 2014 notifying English Heritage of the above
application.
Summary
The proposed development comprises the construction of an 86.64 ha solar farm
within former airfield at RAF Coltiishall, including landscaping, transformers,
substations, security fencing and associated works. The development would be
situated within RAF Coltishall Conservation Area, which includes the historic airfield,
two scheduled monuments, and a number of locally listed buildings.
Following our letter of the 19th November (Our Ref: P00437601) we have now received
additional visitations from the applicant for this scheme. We appreciate the effort the
applicant has undertaken to produce these visualisations and have been very
impressed with the high quality and usability of this data.
Having considered all available information, we consider that the proposals would
have a direct impact upon the historic airfield and conservation area and impact the
setting of nearby designated heritage assets; resulting in a high level of harm to
significance. It is our view that amendments to the design scheme should be employed
to reduce the scale of the solar farm and lessen the level of adverse impact. We would
recommend that the application is withdrawn or the decision deferred to enable
consideration of design scheme changes to reduce impact and harm and ensure the
economic benefit to the site is secured.
24 BROOKLANDS AVENUE, CAMBRIDGE, CB2 8BU
Telephone 01223 582 700 Facsimile 01223 582 701
www.english-heritage.org.uk
English Heritage is subject to the Freedom of Information Act. 2000 (FOIA) and Environmental Information Regulations 2004 (EIR).
All information held by the organisation will be accessible in response to an information request, unless one of the exemptions in
the FOIA or EIR applies.
1.16
EAST OF ENGLAND OFFICE
English Heritage Advice
Significance of the Historic Environment
RAF Coltishall was a prominent Cold War era airfield, originating in the Second World
War. The initial construction began in February 1939 and the airbase served as a
fighter base during World War Two (WWII). Originally the airbase had an open grass
airfield replaced in the post war by the laying of an asphalt runway, later extended
beyond the original perimeter track in 1957. The Airbase saw great change during this
second half of the 20th century where it played an important role during the Cold War,
serving as a base for sequential generations of fighter jets and being designated as a
"V-Bomber dispersal airfield’. It later played a role in subsequent operations and
conflicts, including providing fighter jets during the first Gulf War. RAF Coltishall closed
in February 2006 and the airbase is now within a variety of uses.
RAF Coltishall comprises a number of designated and non-designated heritage
assets, which together form an important historic landscape. The entirety of the
airbase, including the airfield, is a Conservation Area and it includes a number of
locally important buildings, including the control tower and former hangers. The airfield
includes two scheduled monuments, designated together as World War II fighter pen,
Cold War blast walls and associated remains at the airfield formerly known as RAF
Coltishall (List Entry No. 1021425). There are also a large number of non-designated
heritage assets, including runways, control buildings, radar structures, bomb-stores,
runway surfaces, a second WWII fighter dispersal pen, three Picket-Hamilton forts and
various other features. These assets include another set of Cold War blast walls which
are not statutorily protected, but would be considered of equivalent value and
significance as their designated counterparts.
There is significance in each of the individual heritage assets, as well as from their
typological and chronological group value, and the wider historic landscape
significance from the airbase as a whole. The evidential, historical and communal
values which contribute to significance derive from the physical attributes of the assets
as well as their setting. The contribution of setting to significance is not limited to the
visual context, but includes how the assets are experienced together both spatially and
functionally, as well as their relationship to one another within the wider evolution and
historic development of the RAF site.
The 2010 Conservation Area Appraisal (CAA) identified a number of key
characteristics within the Area. This includes the evidential value of the airbase; the
range, age, grouping, visual and spatial relationship and socio-comic value of the
surviving historic buildings and features; the high quality landscape design and mix of
hard and soft grain; as well as the important panoramas and views throughout and
across the base. The CAA identified a number of ‘striking vistas, glimpses and
24 BROOKLANDS AVENUE, CAMBRIDGE, CB2 8BU
Telephone 01223 582 700 Facsimile 01223 582 701
www.english-heritage.org.uk
English Heritage is subject to the Freedom of Information Act. 2000 (FOIA) and Environmental Information Regulations 2004 (EIR).
All information held by the organisation will be accessible in response to an information request, unless one of the exemptions in
the FOIA or EIR applies.
1.17
EAST OF ENGLAND OFFICE
panoramas across the airfield’ which make a significant contribution to the base's
special character. These included the panoramas of the whole site from either end of
the runway, from the southern boundary and from the hangars across the runway and
the prominent, key focal point of the Control Tower.
The two scheduled monuments are important elements within the wider airfield which
together form an excellent example of the changing nature and design of fighter pen
blast walls and dispersal systems. Their positioning and spatial relationships within the
airfield contribute to their significance. This significance is further enhanced by their
good physical survival, excellent evidential value and aesthetic value in terms of their
visual prominence within the airfield. The nature of an airbase means there are
features and non-designated assets which provide context to and contributes to the
significance of the designated heritage, and vice versa. In the case of the Cold War
blast walls, this includes the association with the associated areas of hardstanding,
perimeter tracks, runway and readiness platforms, which link the blast walls with
associated buildings, such as the bomb stores to the west or the hangers to the east,
and other structures of a contemporary date - such as the radar buildings or
emergency control tower, for example. There is also added importance in an
understanding and appreciation of these 32 blast walls as a distinct group, laid out
together in association with one another, rather than individual structures. The Eshaped WWII fighter dispersal pen also has an important relationship with the former
flying field, which would have incorporated the standard ‘A’ arrangement of grass
runways during the Second World War. In 1944 parts of the grass runways were metal
reinforced, including installation of prefabricated pierced metal planking in some area.
The majority of this metal work has been removed during the latter iterations of the
airfield, although parts of the metal planking - aligned northeast to southeast towards
the fighter pen - still survives below ground to the east of the asphalt runway. There
are few Second World War assets remaining upon Coltishall’s airfield, emphasising
the importance of any relationship between the fighter pen and those that remain, such
as the three rare Pickett-Hamilton forts, the second fighter pen in the southeast,
sleeping shelters and air-raid shelters.
Two notable features associated with the designated Cold War blast walls and WWII
fighter pen are the two non-designated examples of these structures which also
survive within the airbase. The second WWII fighter pen is a W-shaped pen designed
for twin-engine aircraft. It is located in the southeast of the airbase. The condition of
this fighter pen is poorer than the scheduled example, less complete having been
impacted by later development and less discernible to the casual observer. It would
not be considered to be as important as the designated example in the northwest;
however it still retains significance through its type, design and setting - including the
spatial positioning around the second field and relationship to the other WWII pens.
Spatial relationship is also an important element in the significance of the two groups
24 BROOKLANDS AVENUE, CAMBRIDGE, CB2 8BU
Telephone 01223 582 700 Facsimile 01223 582 701
www.english-heritage.org.uk
English Heritage is subject to the Freedom of Information Act. 2000 (FOIA) and Environmental Information Regulations 2004 (EIR).
All information held by the organisation will be accessible in response to an information request, unless one of the exemptions in
the FOIA or EIR applies.
1.18
EAST OF ENGLAND OFFICE
Cold War blast walls. The second blast wall group, situated in the southwest of the
airfield, are almost identical to the first in their nature and extent; however they contain
added interest in the range of additional features - such as the Jaguar engine testing
facility. The visual link between the two group of blast walls adds to the significance of
both assets. Although the second group of blast walls are non-designated, they are of
equivalent value to the designated examples and would be consider of a similar
National Importance.
Summary of Proposed Development
The proposed 49.9MW solar farm would be located within six blocks spread across the
grassed sections of the airfield, separated by the existing hardstanding runway and
perimeter tracks. The solar panels would be installed on fixed frames aligned to face
south, measuring a height of approximately 3.0m at the back, 0.6m at the front with a
tilt angle of 25°. The panels would be placed in parallel rows 4 - 6m apart, with the
majority of the frames secured by piles driven between 0.6 and 1.0m below ground
level. The Planning Statement states that where a potential for buried archaeological
remains, airfield structures or surfaces exists, concrete shoes could be used to anchor
the arrays. The solar farm would include a number of green prefabricated cabins to
house inverter and switch gear and a brick built structure to house the network
connection and metering. The six blocks of arrays would each be encircled by 2.1m
high security fencing, set back between 8m and 10m from the solar panels, and
include 6m high pole mounted security cameras and 3m high weather data stations.
The Planning Statement indicates that the fencing is likely to be deer fencing rather
than mesh fencing, due to this being less intrusive.
The application has been accompanied by a comprehensive heritage assessment,
including detailed visualisations, and has included a justification for the proposed
works - including securing the optimal viable use of the site in order to support the long
term conservation of the heritage assets. The application has highlighted the
reversibility and 25 year lifespans of the proposal and the minimal total loss of heritage
assets. It has also indicated that the ‘immediate setting’ of the scheduled monuments
would be preserved and that the retention of the perimeter track, runway and
readiness platforms would mean that the important the ‘functional relationship’ of these
assets would not be adversely impacted.
Assessment of Impact
English Heritage have undertaken a number of site visits and given careful
consideration to the information provided. It is our view that the proposed solar farm
would physically impact on the RAF Coltishall Conservation Area. It would impose a
notable modern element across almost the entirety of the flying field, fundamentally
impacting the ability to appreciate this part of the airbase as an airfield. It would
impose upon and obstruct the shared views of the runways, perimeter tracks, aprons
24 BROOKLANDS AVENUE, CAMBRIDGE, CB2 8BU
Telephone 01223 582 700 Facsimile 01223 582 701
www.english-heritage.org.uk
English Heritage is subject to the Freedom of Information Act. 2000 (FOIA) and Environmental Information Regulations 2004 (EIR).
All information held by the organisation will be accessible in response to an information request, unless one of the exemptions in
the FOIA or EIR applies.
1.19
EAST OF ENGLAND OFFICE
and surrounding structures, and physically block several of the key panoramas
identified in the CAA. Although the runway and the perimeter tracks would still be
accessible, the extent and spread of the solar farm and height of the panels (and
associated infrastructure) would act as a separating feature, almost subdividing the
eastern half of the airbase from the rest. The internal separation of the solar farm with
2m high security fencing would further add to the sense of subdivision within the
airbase - crucially within an area which should be appreciated as a single, wide open
space. Aside from the runway, perimeter tracks, and redlines platforms; the layout of
the solar farm bears little respect to the conservation area’s historic features which
survive within the airfield. Upstanding structures (e.g. radar buildings, emergency air
traffic control building, antenna buildings) are surrounded and divorced from their
context and there is no indication in the application of any firm plans to re-use these,
although it is referenced in the heritage statement (prefabricated cabins and a new
brick metering building have been proposed instead). The use of concrete shoes
would prevent physical damage to below ground features, such as the PickettHamilton Forts or the surviving metal runway; however the proposed layout obscures
any visible evidence of these and in no way alludes to their presence. The proposed
solar farm would also impact the setting of a number of heritage assets within the
conservation area, including the control tower and the hangers, which are locally
listed. The impact upon the setting of the scheduled monuments (and the nondesignated asset of equivalent value) would be particularly notable.
The solar arrays would erode our understanding of the positioning and spatial
relationship of the designated features, and, to some extent, the evidence of their
evolutionary sequence. The height of the panels and extent of the array would intrude
upon nearly all views of these heritage assets. It would physically block the view when
looking from between the two sets of blast walls, the two sets of fighter pens and the
fighter pens and blast walls. They would also impact an appreciation of each of these
assets, individually and together, within the wider afield site. For example, the panels
obscure both sets of blast walls in views from the south end of the runway and intrude
upon all views of the airfield when observed from the top of the control tower. The east
- west spread of the solar farm further emphasis this impact, particularly in views
looking through and amongst the designated blast walls and when looking out of the
designated fighter pen onto to the flying field (which only has a 20m buffer to the solar
panels). Although the solar farm includes 20m and 40m buffers to separate the panels
from these sensitive assets, the fencing encroaches closer than this; - often less than
2m from the edge of the perimeter track and runway. This adds to the sense of
intrusion. The fencing also creates a disturbing sense of subdivision which is
distracting in a number of viewpoints around the airfield; such as from the northern tip
of the designated blast walls.
24 BROOKLANDS AVENUE, CAMBRIDGE, CB2 8BU
Telephone 01223 582 700 Facsimile 01223 582 701
www.english-heritage.org.uk
English Heritage is subject to the Freedom of Information Act. 2000 (FOIA) and Environmental Information Regulations 2004 (EIR).
All information held by the organisation will be accessible in response to an information request, unless one of the exemptions in
the FOIA or EIR applies.
1.20
EAST OF ENGLAND OFFICE
Legislative and Policy Context
The Planning (listed buildings and conservation areas) Act 1990 states that special
attention should be paid to preserving or enhancing the character or appearance of a
Conservation Area (Sections 72). The National Planning Policy Framework (NPPF)
builds upon this and identifies the concepts of significance, setting and harm. NPPF
Paragraph 132 states that significance of heritage assets can be harmed or lost
through development within its setting and that any harm should require clear and
convincing justification. Paragraph 134 goes on to state that where a development
proposal would lead to less than substantial harm to significance, this harm should be
weighed against the public benefits of the proposal, including securing its optimum
viable use. Paragraph 137 highlights that opportunities should be sought for new
development within conservation areas and within the setting of heritage assets to
enhance or better reveal significance, whilst Paragraph 131 notes that local planning
authorities should take account of the desirability of sustaining and enhancing the
significance of heritage assets and putting them to viable uses consistent with their
conservation. Paragraph 139 states that non-designated heritage assets of
archaeological interest that are demonstrably of equivalent significance to scheduled
monuments, should be considered subject to the policies for designated heritage
assets.
English Heritage recognises that renewable solar development could form part of a
viable economic redevelopment plan in the context of an evolving airbase such as
RAF Coltishall. However, we must be certain that the type, design and scale of
development does not result in unjustified harm to the significance of the designated
heritage assets. Any such development, where accepted in principle, would also need
to take advantage of all opportunities to minimise impact, reducing the level of harm,
and any viable opportunities to benefit or enhance significance.
The application has suggested that the proposal would result in harm to the
significance of the designated heritage; but this would not be substantial.
It is our view that the current scale, extant and height of the proposed solar farm would
neither preserve nor enhance the character or appearance of the Conservation Area,
as set out in Section 72 of the Planning (Listed Buildings and Conservation Areas) Act
1990. It would result in a very high level harm to the significance of RAF Coltishall
Conservation Area in-line with Paragraph 132 of the NPPF. English Heritage would
concur that the application would not amount to substantial harm to the significance of
the scheduled monuments; however the adverse impact upon their setting would be
considerable and result the level of harm to the significance would be high. The impact
and harm would be similar for the non-designated blast walls in the southwest, which
we would consider to be demonstrably of equivalent significance to scheduled
monuments, in line with Paragraph 139.
24 BROOKLANDS AVENUE, CAMBRIDGE, CB2 8BU
Telephone 01223 582 700 Facsimile 01223 582 701
www.english-heritage.org.uk
English Heritage is subject to the Freedom of Information Act. 2000 (FOIA) and Environmental Information Regulations 2004 (EIR).
All information held by the organisation will be accessible in response to an information request, unless one of the exemptions in
the FOIA or EIR applies.
1.21
EAST OF ENGLAND OFFICE
We recognise that there is a need to make the former RAF base economically viable in
order to provide it, and its heritage assets, with a sustainable future and accept that
solar renewable energy could form part of this approach. It is, however, important that
the economic driver does not create a development that would cause serious harm to
the significance of the heritage assets. We remain unconvinced by the justification for
the current design, layout and scale of the proposed solar farm, in particular that the
public benefit could not be delivered through a smaller, less impactful scheme.
Next Steps
Having considered the range of application information, including the detailed
visualisations, it is our view that design scheme changes would need to be employed
to reduce the scale of the solar farm and lessen the level of adverse impact. English
Heritage would be please to discuss the details of how this could be achieved with you
and the applicant. We would recommend the following options, as set out below,
should be considered.
Reducing the height of the solar panels and scaling back the extent of the solar arrays
would dramatically reduce the level of impact to the setting of the designated heritage
assets. The panels are currently approximately 3m tall and the there is significant
scope to reduce the height - even if it negates grazing opportunities beneath the
panels. Removing arrays from within the space between the designated blast wall on
the east and removing arrays in the southwest would open up views across, through
and towards the blast walls. Increasing the distance of the arrays from the fighter pens
to allow more of the former flying field to be appreciated would also reduce the
adverse impact upon setting. We would be happy to discuss other opportunities to
relocate or reduce the solar panels as appropriate.
We continue to remain unconvinced on the need for fencing and would recommend its
removal and placement of the solar farm within the wider security fence that already
circles the airbase; which itself is gated and has a manned security post.
There could also be opportunities to use existing structures and features to discreetly
house security camera equipment. If the solar farm is genuinely proposing to present
opportunities for enhancement of the heritage assets, we would reiterate our previous
recommendations for the retention and re-use of the non-designated buildings which
lie within the area of the solar panels (e.g. use the radar building and emergency
control tower to house transformer or substation equipment). Similarly, adjustments of
the layout of the solar panels could better acknowledge the surviving features within
the airfield - such as creating buffers around the Pickett-Hamilton Forts to highlight
their locations.
24 BROOKLANDS AVENUE, CAMBRIDGE, CB2 8BU
Telephone 01223 582 700 Facsimile 01223 582 701
www.english-heritage.org.uk
English Heritage is subject to the Freedom of Information Act. 2000 (FOIA) and Environmental Information Regulations 2004 (EIR).
All information held by the organisation will be accessible in response to an information request, unless one of the exemptions in
the FOIA or EIR applies.
1.22
EAST OF ENGLAND OFFICE
We note the application’s explanation of the 25 year life span of the proposed solar
array. The presence and level of harm is not dependent upon the lifespan of an
impact, and any harm would endure for as long as it exists. The fact that this might be
for a limited period is a material consideration and something that the Council should
take into account when you weigh against the wider public benefits of a scheme. 25
years is, however, still a notable period of time and a sizeable part of a human life
time. If the Council is minded to approve the application, we would seek opportunities
to secure by Condition the removal of the panels at the end of this 25 year period or
the end of the solar arrays use (whichever occurs sooner).
Finally, a key element of the solar farms justification is securing the optimal viable use
of the site in order to support the long term conservation of the heritage assets. We
recognise the benefit that revenue from this use could bring to the continued
preservation, repair and consolidation of the heritage assets within the site. This would
be an important consideration for the Council in determining if the public benefit of this
proposal outweighs the high level of harm; although what this would consist of and
how it would be achieved has not been clearly set out in the application documents.
English Heritage would be keen for any such economic benefit to be secured through
Condition or a clearly defined legal agreement, through Section 106, for heritage
enhancement.
Recommendation
English Heritage recognises that renewable solar development could form part of a
viable economic redevelopment plan, in the context of an evolving airbase such as
RAF Coltishall, provided that that development does not result in unjustified harm. We
also recognise that there is a need to make the former RAF base economically viable
in order provide it, and its heritage assets, with a sustainable future.
However, it is our view that the current scale and extent of the solar farm, including the
height and layout of the panels, would result in a high level of harm to the significance
of the designated heritage assets. We remain unconvinced for the justification for
some elements of the proposal. We would therefore recommend that it the application
is withdrawn or the decision is deferred pending further consideration of design
scheme changes to reduce the scale of the solar farm and lessen the level of adverse
impact and harm.
If, notwithstanding our advice above, the Council proposes to determine the scheme in
its present form, you would need to be satisfied that application shows clear and
convincing justification for any harm, and for this harm to be out-weighed by the public
benefits of the proposal. This should include arguments that the benefit could not be
delivered through a less impactful scale and design scheme. Any consented scheme
24 BROOKLANDS AVENUE, CAMBRIDGE, CB2 8BU
Telephone 01223 582 700 Facsimile 01223 582 701
www.english-heritage.org.uk
English Heritage is subject to the Freedom of Information Act. 2000 (FOIA) and Environmental Information Regulations 2004 (EIR).
All information held by the organisation will be accessible in response to an information request, unless one of the exemptions in
the FOIA or EIR applies.
1.23
EAST OF ENGLAND OFFICE
should also require the removal of the solar array at the end of its lifespan, secured
through condition. In addition we would recommend a legal agreement should be put
in place which would ensure the economic benefits from any solar development are
directed into the preservation, repair and consolidation of RAF Coltishall and its
heritage assets.
Should any additional information or amendments be submitted, we would welcome
the opportunity of advising further. Should the Council proposes to approve the
scheme in its present form; please advise us of the date of the committee and send us
a copy of your report at the earliest opportunity.
Yours sincerely
Nick Carter
Assistant Inspector of Ancient Monuments
E-mail: nicholas.carter@english-heritage.org.uk
24 BROOKLANDS AVENUE, CAMBRIDGE, CB2 8BU
Telephone 01223 582 700 Facsimile 01223 582 701
www.english-heritage.org.uk
English Heritage is subject to the Freedom of Information Act. 2000 (FOIA) and Environmental Information Regulations 2004 (EIR).
All information held by the organisation will be accessible in response to an information request, unless one of the exemptions in
the FOIA or EIR applies.
1.24
1.25
1.26
EAST OF ENGLAND OFFICE
Mr G Lyon
North Norfolk District Council
Holt Road
Cromer
Norfolk
NR27 9EN
Direct Dial: 01223 582751
Direct Fax: 01223 582700
Our ref: P00437601
5 December 2014
Dear Mr Lyon
FORMER RAF COLTISHALL, LAMAS ROAD, SCOTTOW, NORFOLK NR10 5LR
Summary
Further to our letter dated 28th November (Our Ref: P00437601) we have received
additional clarification from the applicant regarding the extent a scale of the proposed
solar farm at RAF Coltishall. The applicant has also provided a response to our letter,
dated 3rd December 2014, a copy of which is appended to this response. Having
considered this additional information and would offer the following advice. This letter
should be read in conjunction with our earlier advice.
English Heritage Response
We acknowledge that only two of three (non-designated) Picket-Hamilton Forts at RAF
Coltishall have been discovered and neither are situated within the footprint of the
solar panels. The third fort has not currently been located, but is thought to be sited
beneath the Cold War concrete aprons in front of the hangars; also outside the extent
of the solar panels. Our previous advice on highlighting and buffering these features
would not, therefore, be applicable. We would reiterate our advice on the use of an
appropriate and non-intrusive design to minimise the impact upon the other nondesignated assets, such as any surviving parts of the metal runway (should this be
identified through further survey).
We also acknowledge that the height of the solar panels have been reduced from that
stated in the Planning and Heritage Statements (height of 3m at the back, 0.6m at
front and tilt of 25°) and is now proposed to comprise a height of 2.56m, 0.8m at the
front with a tilt angle of 20° and a clearance of approximately 7.06m between rows.
The applicant has provided clarification on the distance of the proposed panels and
security fencing from the heritage assets. We understand the designated WWII fighter
pen would be approximately 32m away from the fence and at least c. 40m from the
panels; and the both the designated and non-designated blast walls would be
approximately 32m away from the fence and at least c. 40m from the panels. The
panels would be c. 8m from the fence, with 2m between them and all runways,
taxiways and aprons.
24 BROOKLANDS AVENUE, CAMBRIDGE, CB2 8BU
Telephone 01223 582 700 Facsimile 01223 582 701
www.english-heritage.org.uk
English Heritage is subject to the Freedom of Information Act. 2000 (FOIA) and Environmental Information Regulations 2004 (EIR).
All information held by the organisation will be accessible in response to an information request, unless one of the exemptions in
the FOIA or EIR applies.
1.27
EAST OF ENGLAND OFFICE
We appreciate the clarification on the scale of the solar farm provided by the applicant
and we accept that some incorrect data on the distances and heights were included in
our original text. However, our initial assessment was informed by the visualisations,
as well as the planning information, and having considered these and the distances
again; conclusions remain unchanged. We continue to feel that the scale and extent of
the solar farm would be harmful to the significance of the designated heritage assets
and the conservation area. Increasing the distance between the WWII fighter pen and
solar panels would reduce the level of impact and allow its association with the airfield
to be better understood. As stated in our previous advice, it is our view that removing
the solar panels from the space between the blast walls on the east and from in front
of the blast walls in the southwest would notably reduce the adverse impact from the
solar farm; opening up the views across, through and towards these assets. We still do
not recognise a clear and convincing justification for the fencing and would continue to
recommend a reduction in the height of the panels in order to minimise the level of
impact upon the setting of these assets.
The applicant has raised a question over our terminology used in assessing the harm
from the proposed development. Our previous advice stated that ‘English Heritage
would concur that the application would not amount to substantial harm to the
significance of the scheduled monuments; however the adverse impact upon their
setting would be considerable and [the resulting] level of harm to the significance
would be high’. Harm, in the National Planning Policy Framework (NPPF), is
subdivided in to ‘harm’ and ‘substantial harm’. As discussed in the NPPF Practice
Guides; ‘substantial harm’, in general terms, is a high test and does not arise in a
many cases. The level of impact which could result in less than substantial harm is
more varied. It is important, in our view, to highlight where the degree of harm may be
higher or lower (whilst still not ‘substantial’) so that the full breadth of a proposal’s
effect upon and asset’s significance can be understood. In the case of RAF Coltishall,
the use of the terminology indicated our view that the degree of harm from the
proposal are at the higher end of the scale.
With regards to the conservation area, we disagree with the applicant’s statement that
the appreciation of the airfield would not be lost. Whilst we would recognise that the
solar farm would not result in a total loss of appreciation and the runway itself would
still be recognisable from either end and, partially, at height; the proposal would
significantly impair one’s ability to read and understand the airfield. It would impose
upon and obstruct the shared views of the runways, perimeter tracks, aprons and
surrounding structures, and physically block several of the key panoramas identified in
the Conservation Area Appraisal as contributing to the significance of the
Conservation Area
24 BROOKLANDS AVENUE, CAMBRIDGE, CB2 8BU
Telephone 01223 582 700 Facsimile 01223 582 701
www.english-heritage.org.uk
English Heritage is subject to the Freedom of Information Act. 2000 (FOIA) and Environmental Information Regulations 2004 (EIR).
All information held by the organisation will be accessible in response to an information request, unless one of the exemptions in
the FOIA or EIR applies.
1.28
EAST OF ENGLAND OFFICE
It is for the two Local Planning Authorities to consider the wider economic and
environmental benefits of the proposal including renewable energy generation and
brown field use. We recognise the potential role that a solar energy proposal could
have in securing the medium term future of the RAF Coltishall through raising funds for
its conservation. However, we have yet to see any concrete proposals in the
application which explicitly show how this would be achieved. The suggested use of
the redundant non-designated assets as storage building is welcome; however we
note that there are no details of what this would require, how this would ensure their
repair, consolidation and preservation or even that there is a certainty that this would
be undertaken. Clarification of this, and inclusion in a Condition or Section 106
Agreement (should the proposal be approved), may therefore be necessary.
Recommendations
Having considered the additional information, English Heritage would reiterate our
previous advice. It is our view that the current scale and extent of the solar farm would
result in harm to the significance of the designated heritage assets and we remain
unconvinced on the justification for some elements of the proposal, such as the
fencing and the extent of the panels.
We would recommend that it the application is withdrawn or the decision is deferred
pending design scheme changes to reduce the scale of the solar farm and lessen the
level of adverse impact and harm. If, notwithstanding our advice above, the Council
proposes to determine the scheme in its present form, we would refer you to our
earlier letter and recommendations pertaining to harm and public benefits, and
suggested conditions and legal agreements.
Should any additional information or amendments be submitted, we would welcome
the opportunity of advising further. Should the Council proposes to approve the
scheme in its present form; please advise us of the date of the committee and send us
a copy of your report at the earliest opportunity.
Yours sincerely
Nick Carter
Assistant Inspector of Ancient Monuments
E-mail: nicholas.carter@english-heritage.org.uk
cc. Mr Nigel Harriss, Broadland District Council, Thorpe Lodge, 1 Yarmouth Road,
Norwich, Norfolk, NR7 0DU
24 BROOKLANDS AVENUE, CAMBRIDGE, CB2 8BU
Telephone 01223 582 700 Facsimile 01223 582 701
www.english-heritage.org.uk
English Heritage is subject to the Freedom of Information Act. 2000 (FOIA) and Environmental Information Regulations 2004 (EIR).
All information held by the organisation will be accessible in response to an information request, unless one of the exemptions in
the FOIA or EIR applies.
1.29