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ID sylw: 107282

Derbyniwyd: 07/03/2025

Ymatebydd: Cotswolds National Landscape Board

In principle, the Cotswolds National Landscape (CNL) Board agrees with the approach outlined in Draft Policy Direction 49.
However, we have some concerns regarding the statement that ‘the large-scale renewable energy development will be prioritised on the poor-quality agricultural land (Grades 3b, 4 and 5)’. This statement should be framed in a more qualified / less absolute way to ensure that large-scale energy development isn’t inadvertently directed towards assets of particular importance, such as the CNL.
The National Planning Policy Framework (NPPF) gives great weight to conserving and enhancing the landscape and scenic beauty of National Landscapes.97 In contrast, it just says that areas of poorer quality land should be preferred to those of a higher quality.98 In other words, the weighting given to conserving and enhancing the landscape and scenic beauty of National Landscapes is stronger than the weighting given to using poorer quality land.
It is also important to note that the NPPF frames the preference for using poorer quality land in the context of ‘where consistent with other policies in this Framework’.99 We recommend that Draft Policy Direction 49 should explicitly reflect this wording.
Large-scale renewable energy schemes would constitute major development in the context of paragraph 190 of the NPPF. Such development should only be permitted in exceptional circumstances and where it can be demonstrated that the development would be in the public interest.100 A key consideration, in this regard, is whether the scheme would meet a need that could not be addressed elsewhere (i.e. outside the CNL) or in some other way.101 There is no equivalent ‘exceptional circumstance’ in relation to BMV land.
Furthermore, relevant authorities have a statutory duty to seek to further the purpose of conserving and enhancing the natural beauty of National Landscapes. There is no equivalent legislative requirement in relation to BMV land.
All other things being equal, if there was a choice between allocating or permitting a large-scale renewable energy scheme on (i) poorer quality land in the CNL (or in the setting of the CNL, where views from the CNL would be adversely affected) or (ii) higher quality (BMV) land outside the CNL, preference should, in principle, be given to (ii).
It is also important to note that the phrase ‘poor-quality’ land can also be misleading. Land that is not classed as ‘best and most versatile’ (BMV) can be just as productive as BMV land. The main difference is that BMV land is more versatile.