Proposal:
Application number P24/S1336/FUL. Construction and operation of a solar farm with all associated works, equipment, necessary infrastructure and biodiversity net gains- known as 'Nuneham Solar Farm'.(Hard copies of the Environmental Statement can be found at South Oxfordshire District Council, Abbey House, Abbey Close, Abingdon OX14 3JE). (Additional Information received 30 August 2024, updated highway plans received 2 October 2024 and additional and amended information received 25 October 2024)
Land north-west of Nuneham Courteney situated to the west of the A4074 north of Upper Farm and south of Lower Farm
Our Response:
The attitude which is displayed within the Heritage Addendum demonstrates a failure to understand the significance of the application site within the green setting of Oxford, and the settings of a number of significant designated heritage assets. The applicant has appeared to completely ignore the strong objections from a number of expert and highly qualified heritage authorities (including: Historic England, Oxfordshire Architectural and Historical Society, The Gardens Trust, The Georgian Group, South Oxfordshire District Council’s own Heritage Officer, Oxford County Council Archaeologist, CPRE Oxfordshire and the Oxford Preservation Trust) failing to understand the gross inappropriateness of the scheme within the historic setting, and the degree of potential harm.
OPT maintain that the proposed scheme would cause the high test of substantial harm to the settings of the village of Nuneham Courtney and its exceptional number of listed buildings, and the Grade I listed Nuneham Registered Park and Gardens as per the Trust’s comment submitted on the 19th June 2024. Similar concerns were also put forward by the Gardens Trust, the Oxford Architectural and Historical Society, and the Campaign to Protect Rural England. All these respective experts reached the same conclusion as to the extent of harm posed by the scheme, and OPT would challenge the claim made in the Heritage Addendum that all of these assessments are inaccurate, given the applicants assertion of less than substantial harm.
The overarching issues remains to be largely unaddressed by the applicant, These are that the proposed scheme poses substantial harm to a number of designated heritage assets, firstly a Grade I listed registered park and garden, but also a scheduled monument, and a Grade II listed building.. According to paragraph 206 of the National Planning Policy Framework (2023) harm to these assets should be ‘wholly exceptional’, requiring clear and convincing justification. It is the view of OPT that the applicant has failed to provide ‘wholly exceptional’ clear and convincing justification of the harms posed by this scheme.
The South Oxfordshire District Council adopted Local Plan policy ENV10 reiterates this national policy, stating that:
“Any harm to or loss of significance of any heritage asset requires clear and convincing justification. Substantial harm to or loss of these assets should be wholly exceptional in the case of Registered Historic Battlefields and Grade I and Grade II* Registered Historic Parks and Gardens and exceptional in the case of Grade II Registered Historic Parks and Gardens.”
It is the view of the Oxford Preservation Trust that wholly exceptional circumstances have not been sufficiently evidenced to justify the proposed development, and the substantial harm which it threatens.
Within the adopted local plan, policy ENV7 states that development proposals affecting the significance of a designated heritage asset’s setting will be refused unless harm or loss is necessary to achieve substantial public benefits. Though solar farms play a key role in Net Zero strategies, contributing to wider public benefit, the historic significance of the application site outweighs the potential for public benefit, especially when viewed in the context of planning application P20/S4360/FUL. This scheme for a solar farm was granted in January 2022, and is situated immediately opposite the current application site, to the north east of the A4074. Any public benefit which a solar farm would bring to the local area is being fulfilled by this prior application.
This most recent application for an additional solar farm is excessive, with the potential for public benefit being largely unbalanced by the potential for significant harm to neighbouring designated heritage asset, breaking further from policy ENV6, stating new development should not cause harm to the historic environment.
OPT strongly urge Officers to reject the above planning application, on the grounds that the substantial harm posed by the scheme is not justified, and would like to reiterate our more detailed comments which are attached below.