Sandford-on-Thames Parish Council The Parish Clerk 93 Church Road Sandford-on-Thames Oxford OX4 4YA Tel: 01865 774178 Email: [email protected] 21.1.2021 Sandford-on-Thames Response to: Planning application P20/S4360/FUL Installation of renewable led energy generating station comprising ground-mounted photovoltaic solar arrays and battery-based electricity storage containers together with substation, inverter/transformer stations, site accesses, internal access tracks, security measures, access gates, other ancillary infrastructure, landscaping and biodiversity enhancements. Location: Land to south west of Cowley Substation, Nuneham Courtenay, OX44 9PA Dear Nicola Smith Sandford on Thames Parish Council OBJECTS to this application. We oppose this greenfield solar farm development within the Green Belt for the following reasons: 1. This application is for a solar farm on 139 hectares and will result in a significant loss of open countryside and unacceptable landscape harm. 2. This application will result in damage to local amenity, in particular the views from existing PRoWs. 3. This application results in the inappropriate use of land which would be better employed for its proper purpose of efficient production of food rather than the production of solar energy. 4. This application represents a serious and unnecessary incursion into the Oxford Green Belt. Summary We believe that this application would be the largest Solar Farm in Oxfordshire and South Oxfordshire. It is contrary to national, & local policies regarding renewable energy. It is an application causing further, major damage to the Oxford Green Belt at a time when the Government has directly intervened with local democracy to amend the Local Plan to promote housing within the Green Belt. The application contravenes the stated objectives of the proposed changes to planning policy outlined by the Secretary of State, Robert Jenrick MP in the recent White Paper on the subject. This application does not take into consideration the impact of the changes to the Local Plan 2035, permitting more than 3000 homes to be built in this part of the Green Belt and the intention to build a ‘Park & Ride’ at Sandford further reducing the Green Belt. Sandford on Thames PC believes the likely benefit of renewable energy production will be small in relation to the aggregate harms in this location and therefore OBJECTS to the application. Sandford on Thames PC are pleased to see that existing PRoWs are maintained and slightly enhanced by the application although the open views currently enjoyed whilst using these PRoWs are severely damaged by the application. The Planning Application We would like to draw attention to some of the comments and answers from the applicant in the Application itself. At Question (8) On the question of creating or altering pedestrian rights of way the applicant answered NO. This incorrect and we are surprised that the SODC officer has accepted this given that one PRoW exists on site and is to be preserved and an additional permissive path is to be granted. Viz The Environment Statement, Chapter 2, Page 2 as provided by the applicant. 2.3.7: The Oxford Green Belt Way and Shakespeare’s Way (both Public Rights of Ways (PRoWs)) follow the southern and eastern boundary of the Site before passing through Field 4, and PRoW 118/14 crosses the Site between Fields 5 and 6 linking the Site to The Baldons. The Environment Statement, Chapter 3, Page 4 as provided by the applicant. 3.4.1: All existing PRoWs within the Site will be retained and will remain open and in their present position for the duration of the construction and operational phases. This includes reinstating the definitive PRoW 118/14 in its formal position which has been moved over time by walkers preferring a route slightly further north within the Site. The informal pathway created by walkers between Fields 5 and 6 would be retained as a permissive footpath in the proposed layout. Here is the CPRE view on the PRoWs. “… a recent list of planning applications in the Western Area we have noticed this one which affects a number of particularly scenic public rights of way just outside Oxford including a substantial section of the Oxford Green Belt Way, a route created to highlight the scenic value of the Oxford Green Belt and the need to protect it from hideous development which the green belt was intended to prevent. We therefore wish to express strong objections to the proposed solar farm on public rights of way grounds as it would totally disfigure the highly attractive hilly landscape with wide views, through which these rights of way pass including notably the Oxford Green Belt Way. While CPRE supports increased use of renewable energy…” …without spoiling some of Central Oxfordshire’s most attractive landscape in the Oxford Green Belt and we therefore trust that your Council will reject this application. At Question (10) And/or: Are there trees or hedges on land adjacent to the proposed development site that could influence the development or might be important as part of the local landscape character? No. We disagree with this response. The trees and hedges on the site are an important part of this section of the Oxford Green Belt. At Question (18) In answer to the question relating to employee numbers the applicant states no change as the result of this application. We are surprised that no change in number of employees on site results, we would question what is to happen to staff who currently farm this considerable piece of farmland? Green Belt The Environment Statement, Chapter 2, Page 2 as provided by the applicant. 2.3.10: The Site is located within the Oxford Green Belt. This application would result in a change of use from Agricultural Land to Solar Farm impacting upon 139 Hectares of the Oxford Green Belt. Robert Jenrick MP and Secretary of State for Communities and Local Government has recently repeated his wish to protect the Green Belt against intrusive and damaging development. In his White Paper ‘Planning for the Future’ August 2020, Page13, 1.8, RJ states that ‘we have continued to protect the Green Belt’ and again on Page 24 at 2.8 states ‘Areas That are Protected – This would include… …Green Belt, AONBs… From the applicants Environment Survey Chapter 4, Page 5, dealing with the NPPF and Green Belt 4.2.27 Paragraph 133 outlines that the Government attaches great importance to Green Belts. The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts are their openness and their permanence. 4.2.28 Paragraph 134 sets out that “Green Belt serves five purposes: a) to check the unrestricted sprawl of large built-up areas; b) to prevent neighbouring towns merging into one another; c) to assist in safeguarding the countryside from encroachment; d) to preserve the setting and special character of historic towns; and e) to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.” 4.2.29 Paragraph 143 of the NPPF states “inappropriate development is, by definition, harmful to the Green Belt and should not be approved except in very special circumstances”. Paragraph 144 states “When considering any planning application, local planning authorities should ensure that substantial weight is given to any harm to the Green Belt. “Very special circumstances” will not exist unless the potential harm to the Green Belt by reason of inappropriateness, and any harm resulting from the proposal, is clearly outweighed by other considerations.” 4.2.30 Paragraph 147 states “When located in the Green Belt, elements of many renewable energy projects will comprise inappropriate development. In such cases developers will need to demonstrate very special circumstances if projects are to proceed... It is clear that this development does not fulfil the requirements for ‘very special circumstances’ and so is both inappropriate and unsustainable against the NPPF requirements. Pedestrian Right of Way and Residents amenity The introduction of such a large solar panel development …. particularly from the elevated PRoWs – the views are long ranging, and the panels despite the planned hedgerows will still be very visible and intrusive in the landscape. We understand that further impacts on the PRoWs have been submitted by the CPRE Oxfordshire Rights of Way convener. The development will change the landscape and the views of the undulating open vale from ground level and from the highest points of the PRoWs. This development is being proposed at the same time that the SODC 2035 local plan has been agreed which gives the go ahead for 3000+ dwellings bordering the Grenoble Road. The residents in those dwellings will be denied the amenity provided by the PRoWs views through the site, a site which will provide the facility to exercise in attractive, open country. Existing Planning practice and this application Planning Practice Guidance Para 013 recognises that “The deployment of large-scale solar farms can have a negative impact on the rural environment, particularly in undulating landscapes.” Local planning authorities will need to consider “encouraging the effective use of land by focussing large-scale solar farms on previously developed and non-agricultural land.” The proposed solar farm is not a community-led initiative, it is not on existing roofs nor a brownfield site, but is a large-scale development in open unspoiled, undulating countryside on high value agricultural land. It is therefore unacceptable in principle and contrary to local & national planning policies. This proposal is contrary to the South Oxfordshire Local Plan 2035 Policy ENV1: Landscape and Countryside. 2. South Oxfordshire’s landscape, countryside and rural areas will be protected against harmful development. Policy DES10: Renewable Energy. 1.