A lesson in writing to the planners

Ramblers who don’t ramble on!

For anyone unsure about how to construct an effective letter objecting to a planning application, Jan Wardell, Footpath Secretary; Ramblers – North Dorset Group and Dr Janet Davis, Countryside Secretary, have presented us all with a mini masterclass! Cogent, to the point, based on pertinent material planning matters and referenced to current national and local planning policy – and all in plain English.

Mr Simon McFarlane
Planning Officer
Dorset Council
South Walks House
South Walks Road
Dorchester
DT1 1UZ
19 May 2021

Dear Mr McFarlane,
Planning Application: P/FUL/2021/01018

Location: North Dairy Farm Access to North Dairy Farm Pulham Dorset DT2 7EA
Proposal: Install ground-mounted solar panel photovoltaic solar arrays, substation, inverter stations, transformer stations, security fencing, gates and CCTV; form vehicular access, internal access track, landscaping and other ancillary infrastructure

We are writing on behalf of the North Dorset Group of the Ramblers and the Ramblers Dorset Area, in response to the above.

The Ramblers work to help everyone enjoy the pleasures and benefits of walking, and to enhance and protect the places where people walk. As walkers and users of the countryside, we understand the importance of our environment for the health and wellbeing of all. We are committed to encouraging and supporting walking, protecting and expanding public rights of way and access land, and protecting the beauty of the countryside and other areas.

We recognise the threat posed to our countryside by climate change, which could severely alter many of our cherished landscapes. We support measures to mitigate this by switching to renewable sources of energy including the use of solar photovoltaic (PV) technology. However, PV arrays should be installed as close to the point of use as possible, with particular use made of roofs on homes and large public or commercial buildings, and not be detrimental to that same countryside.

When there is a need for large-scale solar PV arrays (solar farms) these should be sensitively situated so that they do not damage valued landscapes, and should be achieved in a way that is harmonious with those landscapes – landscapes which are highly valued for their aesthetic qualities, and which are ‘naturally’ attractive.

Whilst we support the concept of renewable energy, we object to this application on the following grounds:

This would be a large-scale industrial development (77 hectares; 9.5km of perimeter internal security fence, 120 6m-high camera posts, 33 inverter containers and an electricity substation) in previously undeveloped countryside. Critically, this application site is within the setting of the Dorset AONB (at its closest point only 1.3 km from the AONB boundary). Thus, it would be visible from the AONB. In response to a similar proposal in 2013 (2/2013/1336/PLNG), the then NDDC Planning Officer observed “The small undulations in the landscape would give rise to localised
views of the development from public rights of way and nearby villages which need to be considered.

The development would also be highly visible in panoramic views from the Dorset AONB located to the south and south east of the site. The development is likely to result in a marked change to a significant area of the Blackmore Vale landscape when viewed from high viewpoints in the AONB.

The visual impact is likely to be significant given the scale of development.” The present application also is within the Blackmore Vale, which is depicted in the writings of Thomas Hardy, and thus has international significance. Dorset Council recognises that its “greatest economic asset” is the countryside because of its interest to visitors from around the world.

Present planning policy, guidance and future plans, at both national and local level indicate that this planning application should not be approved. National policy
Paragraph 152 of the NPPF (2019 revision) says that “Local planning authorities should support community-led initiatives for renewable and low carbon energy.” This is not a community-led initiative, indeed there is much opposition within the local community for the present proposal.

In October 2020, in setting out the government’s proposals to Build Back Greener, the Prime Minister set out a number of commitments to ensure that the UK will be at the forefront of the green industrial revolution. These included “Confirming that offshore wind will produce more than enough electricity to power every home in the country by 2030, based on current electricity usage, boosting the government’s previous 30GW target to 40GW1.

A scheme of the scale proposed in this application is inappropriate in the context of the government’s plans. North Dorset Local Plan Paragraph 4.8 of the North Dorset Local Plan supports the production of energy from renewable and low carbon sources at both the large scale, for example through the incorporation of solar panels on roofs of large commercial and agricultural buildings, and the micro-scale, such as the use of ground source heat pumps. The present application does not propose using existing buildings but a large area of undeveloped countryside. Paragraph 4.21 says that “Whilst encouraging schemes, adverse impacts including cumulative landscape and visual impacts will need to be addressed.”

There is advice from national government on how such impacts should be assessed. In respect of the particular planning considerations that relate to large scale ground-mounted solar.

Photovoltaic farms, there is reference to cumulative landscape and visual impacts which apply to both wind farms and photovoltaic schemes: “sequential effects on visibility occur when an observer moves through a landscape and sees two or more schemes. Common routes through a landscape (e.g., major roads; long distance paths or cycle routes) can be identified as ‘journey scenarios’ and the proposals impact on them can be assessed.” In this instance, although there is only one scheme, it would be visible from many of the viewpoints on the north of the Dorset AONB, over which the Wessex Ridgeway long distance path runs, in particular, the Ibberton Bulbarrow ridge, as well as from the rights of way on the western side of Hazlebury Bryan, including the Hardy Way, all of which overlook the site. A walker exploring this area will find it to be a quiet rural farming area.

Apart from the scattered farm buildings and houses, the only sign of modern life visible from the footpath running through the site (N46/20) are the overhead power lines. We are in no doubt that the development would have an adverse impact on the experience of users of public rights of way, both visitors and locals.
Indeed, the developer’s LEMP admits that “The proposals will not alter the right of access but may alter the visual amenity.”

Public rights of way

Specifically, in respect of public rights of way across the site, we note the comments of the Senior Ranger, Graham Stanley, that the proposed works directly affect Footpath N46/20 and Bridleway N49/7, and indirectly N46/19 – 21 & 28. Mr Stanley observes that footpath N46/20 as currently shown on the application and in the definitive map is not as walked on the ground (we are of the view that there would be a loss of the very open feeling and views from that path). In the event
that planning permission for this development is granted then the situation must be regularised:

either by legal diversion onto the walked line, with accommodations made for it within the plan or the definitive route should be opened up correctly. Also, if this development does go ahead, we ask for mitigation in the form of gates to replace stiles at the eastern end of footpath 20, and also that the access route along Cannings Court Lane, (which is used to reach footpath N49/9) then along bridleway N49/7, before reaching the private access track, is not obstructed at any time, and any damage made good.

However, in view of our comments about the overall impact of the scheme, we urge Dorset Council to refuse planning permission for this development.

Yours sincerely
Jan Wardell
Mrs Jan Wardell
Footpath Secretary; Ramblers – North Dorset Group

Janet Davis
Dr Janet Davis
Countryside Secretary; Ramblers – Dorset AThis Ramblers group is a part of Dorset Area.

Telephone:01963 370009

1 New plans to make UK world leader in green energy – GOV.UK (www.gov.uk)
2 Renewable and low carbon energy – GOV.UK (www.gov.uk)