BASE HEADER

No

ID sylw: 107263

Derbyniwyd: 07/03/2025

Ymatebydd: Cotswolds National Landscape Board

development in the setting of the CNL is not adequately addressed.

No, the Cotswolds National Landscape (CNL) Board does not agree with the approach laid out in Draft Policy D.
The over-arching principles set out in Draft Policy D are generally sound. However, we have a number of concerns about some of the detail of the Policy. These concerns include:
i.A lack of explicit reference to the CNL - and to how development within the CNL should be addressed - within Draft Policy D
ii.A lack of explicit reference to how development in the setting of the CNL should be dealt with.
iii.The fact that the identification of suitable areas for wind and solar energy does not factor in landscape sensitivity (other than by excluding the CNL).
Cotswolds National Landscape

Firstly, we are concerned that the Policy makes no explicit mention of the CNL. This is surprising given that the Renewables and Decentralised Energy Opportunities report, which is referred to in the Policy, rules out large-scale wind and solar energy development in the CNL.31 We support this approach, which is consistent with the Board’s Renewable Energy Position Statement32 and with the statutory duty to seek to further the purpose of conserving and enhancing the natural beauty of the CNL33. Large-scale wind and solar energy would constitute major development, in the context of paragraph 190 of the National Planning Policy Framework, which sets a presumption against such development.

Setting of the Cotswolds National Landscape
Secondly, we are concerned that neither Draft Policy D (or the Renewables and Decentralised Energy Opportunities report) address how development in the setting of the CNL should be addressed. Nor do they differentiate between development in the setting of the CNL and development that is not in the setting. This is an important consideration because development in the setting of the CNL has the potential to adversely affect the natural beauty of the CNL. Paragraph 189 of the NPPF states that great weight that should be given to conserving the landscape and scenic beauty of National Landscapes.35 Case law has clarified that this great weight applies in relation to the impact of development outside a National Landscape on views from the National Landscape.

Because of this lack of differentiation, several of the locations that have been identified as being suitable for large scale solar energy are located in very close proximity to the CNL boundary.
Map showing the areas that have been identified as being suitable for large scale solar energy in the vicinity of the Cotswolds National Landscape
Key:
•Green shading = areas identified as being suitable for large-scale solar energy development.
•Black hatching = Cotswolds National Landscape (CNL).
•Grey shading = CNL 3km buffer.

Many of the identified locations would be overlooked from elevated viewpoints on public rights of way (PROW) within the CNL. These elevated viewpoints are in landscape character types (LCTs) where the views that are experienced in (and from) these LCTs are one of the LCTs’ key features / characteristics. In some cases, the identified locations would be overlooked from viewpoints on the Cotswold escarpment (LCT 2) (for example, the locations near Oxhill and Avon Dassett). This is particularly significant as views from (and to) the escarpment are one of the ‘special qualities’ of the CNL.
Depending on the scale and proximity of potential solar energy schemes in these locations, and the elevation of the viewpoints from which they would be overlooked, such schemes could potentially have a significant adverse effect on these views from the CNL.
One option to address this issue would be to exclude large scape solar energy proposals on sites that are within, say, 1km of the CNL boundary or within 3km of LCTs that have ‘views’ as one of their key features / characteristics. An alternative approach would be to use a landscape sensitivity assessment to help direct the location of large-scale schemes (see below).
Similar principles apply in relation to large-scale wind energy development in the setting of the CNL, which, arguably would have a bigger adverse impact on the natural beauty of the CNL than large-scale solar energy development.

Landscape Sensitivity
Our third concern is that the Councils have not factored in landscape sensitivity into the identification of suitable sites or into Draft Policy C.
In the Board’s Renewable Energy Position Statement, we state that the identification of ‘suitable areas’ for wind and solar energy should be underpinned by a landscape sensitivity assessment (LSA) and by consideration of constraints that relate to the natural beauty of the CNL, including nature conservation and historic environment designations (in addition to infrastructure constraints and other technical considerations).38 The Position Statement recommends that:
•suitable area mapping should exclude areas of high landscape sensitivity (at least within the CNL) and key constraints;
•renewable energy schemes should be targeted towards areas of relatively low landscape sensitivity.
The extent to which locations would be overlooked from elevated views within the CNL should be taken into consideration in the LSA.
This is the approach that has been taken by Bath & North East Somerset Council, for example, who commissioned a landscape sensitivity assessment,39 which now underpins the renewable energy policies in their local plan (at least in relation to wind energy)40.
Not surprisingly, LSAs tend to identify that landscape character types within the CNL have a relatively high landscape sensitivity to large-scale wind and solar energy development. However, LSAs can be particularly useful in identifying areas of relatively low landscape sensitivity, particularly within the setting of the CNL.
Recommendations
The Board recommends that Draft Policy C should:
•explicitly state that large-scale wind and solar energy development in the CNL will not be supported;
•recognise that sites within the setting of the CNL are likely to have a higher sensitivity to large-scale wind and solar energy development than sites further afield;
•be underpinned by a landscape sensitivity assessment, with large scale wind and solar energy being steered towards areas of relatively low landscape sensitivity.