Senior Landscape Architect’s opinion

Here is the full consultation response sent from Dorset Council’s Senior Landscape Architect to the Case Officer. The Officer notes: “The site is located in a landscape that is highly sensitive to large scale solar PV development, and although the proposals include mitigation measures, I do not consider that these measures would satisfactorily offset the moderate-high adverse magnitude of change which would occur. This would result in a significant change in character of the local landscape and would also potentially adversely affect the setting of the AONB”.

The Officer concludes: “I am not able to support the application as the proposals in their current form do not comply with the requirements of paragraph 154 or paragraph 170 of the NPPF or Policies 3 and 4 of the North Dorset Local Plan. In addition to this, I do not believe that the landscape and visual impacts of the proposal have been fully assessed.

 Application details

Ref: P/FUL/2021/01018Applicant: North Dairy Farm Solar Park LimitedCase Officer: Simon McFarlane
Address:  North Dairy Farm Access To North Dairy Farm Pulham Dorset DT2 7EA
Description: 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
Case Officer comments to Consultee:
Consultee: Helen Lilley, Senior Landscape Architect
Date: 04/06/2021
Has a Pre-application discussion taken place with you?  No
Support 
Support subject to condition(s) 
Unable to supportx
No objection 
Request for further information 
Other 

 Summary

  At 77ha the proposed development would be one of the largest solar PV developments in the southwest. The site is located in a landscape that is highly sensitive to large scale solar PV development, and although the proposals include mitigation measures, I do not consider that these measures would satisfactorily offset the moderate-high adverse magnitude of change which would occur. This would result in a significant change in character of the local landscape and would also potentially adversely affect the setting of the AONB, most particularly given the interrelationship between clay/rolling vale character of the local landscape that the site is located in, and the chalk escarpment landscape of the AONB.   There would also be significant adverse effects on views from Rights of Way to the east of the site, most especially where these extend across the site to Dungeon Hill Scheduled Ancient Monument/the AONB to the west.   For these reasons, I am not able to support the application as the proposals in their current form do not comply with the requirements of paragraph 154 or paragraph 170 of the NPPF or Policies 3 and 4 of the North Dorset Local Plan.     In addition to this, I do not believe that the landscape and visual impacts of the proposal have been fully assessed, and no restoration scheme has been provided, so the proposal does not fully comply with the requirements of Policy 22 of the North Dorset Local Plan.   There may also be potential for the proposals to adversely impact on the setting of various heritage assets, though the Conservation Team will be better placed to advise on these matters.   The adverse effects if the proposal could be reduced if it is significantly reduced in size and contained within the part of the site that is located in the Blackmore Vale LCA only, but the acceptability of this will need to be discussed further with Richard Brown of the AONB Team.   

 Site description/context/significance

  The site is located between the villages of Pulham (to the west), Hazelbury Bryan (to the east) and Mappowder (to the south). The 11 fields within the site are referred to as Fields 4, 6 to 13, 16 and 17 for the purpose of the Application. Fields 1 to 3, 5, 14, 15 and 18 to 27 formed the wider assessment area which were excluded from the site as a result of preliminary environmental assessment and the identified planning constraints. The fields are variously described as Small Irregular Flat Mixed Agricultural Fields, Large Uniformly Sloping Mixed Agricultural Fields and Large Open Undulating Arable Fields.

There are several Rights of Way (RoW) near the site (N49/4; N46/19; N46/21; N46/28) as well as one crossing through the site (N46/20). The Design and Access Statement indicates that no RoW will be stopped up or diverted (temporarily or permanently) and they will remain open to public access throughout the construction, operational and decommissioning phases.
The site is characterised by gentle to moderate gradients, with levels on site ranging from between c. 93m AOD to 77m AOD. The River Lydden is located approximately 90m to the west of the site at its closest point and flows in a north-easterly direction. An unnamed watercourse flows through the centre of the site, and another unamend watercourse flows along part of the north eastern site boundary. Both watercourses converge near the northern site boundary via a pond and join the River Lydden approximately 155m to the north of the site.   The site straddles two landscape character areas. The northern part of the site lies in the Blackmore Vale LCA which is broad, gently undulating flat landscape. Key characteristics:   A broad expansive clay Vale which is tranquil and unified.A unique mosaic of woods, straight hedgerows and grassland fields ‘dotted’ with distinctive mature hedgerow Oaks.Open views across the undulating to flat pastoral landscape to the chalk escarpment backdrop.Dense network of twisting lanes often with grass verges and sharp double 90o bends.Small hump backed bridges with low stone or brick parapetsMany very small villages and hamlets built with locally distinctive materials, such as stone, redbrick, tile and thatch.A network of ditches, streams and brooks which drain into the tributaries of the Stour.Lydlinch Common (an SSSI) and Stock Gaylard Deer Park (an SNCI) are both key locally important features   The southern part of the site lies in the South Blackmore Rolling Vales LCA which is a more undulating/rolling pastoral landscape which represents the transition zone between the landscapes of the Blackmore Vale and the Chalk Escarpment of the Dorset AONB to the south. Key Characteristics:   Undulating and rolling farmland hills forming a transition zone between the Blackmore Vale and the chalk escarpment.The chalk escarpment forms a backdrop and landmark to the area.A more folded landscape at the foot of the escarpment.Irregular shaped fields bounded by thick hedgerows.Mature hedgerows are important features nearer the Blackmore Vale.Twisting hedge lined lanes with narrow verges.Small bridged stream crossings are key features often with low parapets.Settlements are often situated at the foot of the escarpment or on elevated slopes overlooking the Vale.There are numerous scattered farmsteads.Frequent use of locally distinctive building materials, mainly stone and brick, adds to character.A tranquil and unified landscape.The ‘tongue’ of rolling hills at Shillingstone, where the River Stour breaks through the chalk escarpment, is a key feature.Piddles Wood is an important SSSI woodland in the north of the area on the edge of the Stour Valley   There is a strong interrelationship between the landscape character areas of the site and the North Dorset Chalk Escarpment which is in the AONB and is therefore a valued landscape. It forms a prominent backdrop to the site and panoramic views across the Vale form an intrinsic part of its character. Key characteristics:   A dramatic, exposed, steep and narrow escarpment with rounded spurs and deep coombes.A patchwork of small scale pastoral fields on the lower slopes, with scattered farmsteads at the ridge bottom spring line.Areas of unimproved chalk grassland on slopes and ridge tops.Large, straight-sided arable fields on escarpment top.Hanging ancient oak, ash and hazel woodlands on the lower slopes.Dense gorse scrub on the steep ridge sides.Thin calcareous soils with the underlying geology of lower, middle and upper chalk.Panoramic views of the surrounding landscape.Bronze Age barrows and prominent hill top forts.Ancient, sunken winding lanes with an open character towards the top.Ponds on the hill top at Bonsley Common.   The site lies within 1.25km of the Chalk Escarpment landscape of the AONB, and forms an important part of its setting.   This part of the Blackmore Vale is tranquil and undeveloped. Settlements are small and dispersed, and the landscape has a strong rural feel to it. The Vale has been farmed for centuries and is known locally as the Land of Milk and Honey; much of the land being turned over to pasture. There are strong cultural associations, with the Author Thomas Hardy both living locally and using the Vale as the setting in his works. The ‘Hardy Trail’ is a popular long-distance walking route that passes within 850m of the site to the east, from where the site can be seen in views towards Dungeon Hill Scheduled Ancient Monument/the AONB to the west. The Wessex Ridgeway is another popular long-distance footpath which connects many of the heritage assets along the chalk escarpment/ridge, including Rawlsbury Camp Scheduled Ancient Monument from where there are extensive views across the Blackmore Vale. Ancient drove roads are another characteristic feature of the landscape.   The site is in the Blackmore Vale and Vale of Wardour National Character Area. Whilst the proposed development will not negatively impact on the landscape at this NCA scale, it is useful to reference the NCA Profile for background information regarding the strength of character and condition of the landscape planning and management aims. The NCA Profile describes the area as being:

Steeped in a long history of pastoral agricultureCharacterised by hedged fields with an abundance of hedgerow trees, many of them veteranProductive pastureland

Relevant Statements of Environmental Opportunity contained within the Profile:
SEO 1: Protect, manage and enhance the diverse but coherent pastoral landscape character of the clay vales, limestone ridge and Greensand hills, their semi-natural grasslands and woodland and their characteristic wildlife, and manage the simple patterns of land use maintained by the long history of agriculture.
SEO 2: Work with local people to raise their understanding of the way in which the area’s
strong landscape character, sense of place and distinctive wildlife are rooted in the continuity
of agricultural land use, strong historic landscape character and legibility of historic features.
SEO 3: Work with the local farming and land management community to maintain the
distinctive landscape and natural beauty of the area, enhancing ecosystems and ecosystem
services.
Tranquillity is described as being an important part of the character of the landscape (page 23 under Experiential Qualities – Tranquillity):   The 2007 Intrusion Map (CPRE) shows the extent to which rural landscapes are ‘intruded on’ from urban development, noise (primarily traffic noise), and other sources of visual and auditory intrusion. This shows that the most disturbed area is around the settlements of Frome, Warminster, Gillingham and Shaftsbury; apart from here and along transport routes, the whole of the NCA is still undisturbed land.
Threats to character (page 28 under Drivers of Change):   Housing allocations and development of employment sites could have an adverse impact on the character around the NCA’s settlements; increased infrastructure could also have deleterious impacts on character and tranquillity.
The landscape is described as being intact (page 44 under Ecosystem Services – Sense of
Place/Inspiration – State):   The major features of sense of place, the intensely pastoral and rural clay vales and the more mysterious wooded scarps and hills, are at the NCA scale intact and maintain its character.
Much of the area is undeveloped (page 46 under Ecosystem Services – Tranquillity –
Analysis):Tranquillity is still strongly associated with large parts of the NCA. Much of the area is still undeveloped and has changed little for over a century. Levels of intrusion are relative and often do not ‘penetrate’ far beyond the settlement or transport corridor.   The historical and cultural associations, time-depth, tranquillity, strength of character, recreational value and natural beauty of the Blackmore Vale all contribute to the value of the landscape. Whilst in planning terms the undesignated parts of the Vale are not a valued landscape, those areas adjacent to the AONB contribute much to its setting and are considered more than an ordinary landscape.   

 Main issues

  The main issues from a landscape point of view are that there will be significant adverse landscape and visual effects associated with this proposal, and that these effects cannot be satisfactorily mitigated because of the large size and utilitarian appearance of the development. The site is also located close to the Dorset AONB, in a landscape that has a high degree of sensitivity to large scale development of this type.  

 The proposal

  Static solar photovoltaic (PV) panels, ground mounted to a railing sub-structure. Laid out in rows with gaps of approximately 2-6m between each, arranged at an angle of c.22 degrees from east to west. The lower edge of the panels would be approximately 0.8m from the ground and up to approximately 2.6m at their higher edge. String combiner boxes for combining multiple strings of solar panels located underneath or adjacent to the fixed tilt structures. 33 transformer stations distributed evenly across the solar arrays housed within green metal containers. Compacted internal crushed stone tracks (constructed on a sub-layer of geogrid membrane within RPAs) to allow vehicular access between fields. Fencing 2.2m high and gates to enclose the panels within each field and allow sheep to graze securely. These comprise of wooden deer fence poles with galvanised fencing. Mammal Access Points are located along the fence line. Security and monitoring CCTV mounted on fence posts within each field. The poles would be approximately 2.5-3m high spaced at 50m intervals along the fence.Underground cabling to connect the panels to the proposed substation. A security-fenced enclosed substation compound including associated ancillary services which will connect to the existing overhead power line via a new pylon, the maximum height of which would be 15m and maximum width 10m. 5.6m x 4.6m consol room, 12.0m x 5.6m customer switch room, 12.2m x 2.4m spares container and a 6.1m x 2.4m welfare container, all of which will be 3.2m high.A substation access track with a cement based top layer with a geogrid sub-base of compacted stone (a statutory requirement of the DNO, SSE).35 year operational life.Site area 77ha.The total construction period for a site of this size is indicated to be c.5 months, including pre-preparation of the site, fencing, assembly, deliveries and installation of photovoltaic panels and grid connection.A temporary construction compound will be used to store materials and ancillary welfare facilities during the construction period. The temporary compound will likely (but not limited to) include:
• Welfare facilities
• Staff parking
• Offices
• Canteens
• Stores

 Comments on proposal

  Landscape sensitivity   The sensitivity of the landscape character areas that the site is located in is outlined in the Landscape Sensitivity to Wind and Solar Energy Development in North Dorset District SPD (produced by LUC in April 2014). This is a strategic assessment but forms a useful basis against which to consider the sensitivity of the landscape that the site sits within to development of the type that is proposed. The assessment defines landscape sensitivity as ‘the extent to which the character and quality of the landscape is susceptible to change as a result of field-scale solar PV development’.   The southern part of the site falls within the South Blackmore Rolling Vales Landscape Character Area (LCA), which is a subset of the Rolling Vales Landscape Character Type (LCT). The sensitivity assessment (SA) identifies that in the Rolling Vales LCT:   The undulating, irregular, small scale pastoral terrain is typically of high sensitivity to solar PV development.There are some flatter, arable fields which would be less sensitive in terms of landform and land use.The extent of screening from trees and hedgerows to an extent offsets sensitivity, particularly for smaller developments, but there are some strong views into the LCT from adjoining AONB chalk escarpments. At the LCA scale, the SA indicates that sensitivity to larger solar PV developments will be high in this undulating landscape with irregular field boundaries. Smaller developments could potentially be effectively screened but sensitivity could be higher where:   Location is on an exposed or significantly undulating slope, particularly if it is visible in the same context as more distinctive parts of the chalk escarpment, such as near Shillingstone (Hod Hill) and Stoke Wake (White Hill and Bulbarrow Hill).Location detracts from the green, patchwork character of the landscape, as observed from elevated viewpoints (particularly those in AONB settings). Overall, the SA concludes that the South Blackmore Rolling Vales LCA has a high degree of sensitivity large scale (over 30ha) solar development, though as indicated in the LVIA, each development should be assessed on a site by site basis.   As outlined above, areas which consist of flatter arable fields will be less sensitive in terms of landform and land use, and screening from trees and hedgerows will offset sensitivity, but this is only relevant for smaller developments and for those away from the rising ground of the chalk escarpment/elevated viewpoints within the AONB. It is also important to note that views towards the higher ground of the Dorset AONB (including notable cultural and heritage assets) form an intrinsic part of the perceptual character of the southern reaches of the LCA. This aspect is particularly relevant in relation to the proposed development, as the AONB effectively wraps around the landscape that the site sits within, thereby further increasing sensitivity.   The text under Inset Plan 3 of the LVIA indicates that the most sensitive sites (fields in the landholding) were omitted because of their high landscape and visual sensitivity. Figure 6.4 nevertheless shows that all of fields that are to be developed within this LCA have characteristics identified in the SA sensitive: 3 of these fields are large open undulating arable fields, and 1 is a small irregular flat mixed agricultural field. The most significant factor however is that at 77ha, the proposed solar development is extremely large and because of its size alone will detract from the green, patchwork character of the landscape as observed from elevated viewpoints whether in the AONB or not.   Photomontages 2, 3, 6 and 18 produced by Landscape Visual illustrate that the proposed mitigation planting will have little effect in screening the development at year 15. The adverse effects would be less significant if the development was reduced in scale and confined to the larger, flatter arable fields as indicated in the SA. There are however no fields with these characteristics in the part of the LCA where the site is located.   The LVIA concludes that the landscape of the site as a whole has moderate-high sensitivity to solar PV development. However, this part of the LCA forms an intrinsic part of the setting of the Dorset AONB’s North Dorset Escarpment LCA, where there is a strong interrelationship between the valued landscapes of the North Dorset Escarpment and the South Blackmore Rolling Vales. This is highlighted in the descriptions of key characteristics for each LCA that are included in the relevant Landscape Character Assessments:   The North Dorset Escarpment has a ‘bold dominant character’ with a key characteristic being ‘extensive panoramic views of the surrounding countryside, particularly across the Blackmore Vale’ (Dorset AONB Landscape Character Assessment https://www.dorsetaonb.org.uk/resource/north-dorset-escarpment )The South Blackmore Rolling Vales are ‘undulating and rolling farmland hills forming a transition zone between the Blackmore Vale and the chalk escarpment’ – ‘The chalk escarpment forms a backdrop and landmark to the area’ (North Dorset Landscape Character Assessment 2008). Along with the visual and experiential interrelationship, there is clearly an interdependency with regard to character – the Blackmore Rolling Vales represent a transition zone between the chalk escarpment and the Blackmore Vale LCA.   Whilst the validity assessing the susceptibility of the landscape at a site-specific scale by using the criteria in Table 7 (Appendix 6.3) of the SA (as in the LVIA) is understood, the significance of this interdependency is lost and sensitivity therefore understated. I consider that this part of the LCA has a high degree of sensitivity to large scale solar PV development. In reference to Table 4 of the SA this means that ‘key characteristics and qualities of the landscape are highly vulnerable to change from the development type’ and that ‘such development is likely to result in a significant change in character.’  The northern part of the site falls within the Blackmore Vale LCA, which is a subset of the Clay Vale LCT. The SA identifies that flat or gently undulating landform is not inherently sensitive to solar PV development – the even topography means that solar PV development would be unlikely to be perceptible beyond its immediate surrounds. It also notes that ground-level views are limited by the well-treed field boundaries and woodland blocks. However, the assessment goes on the identify that:   The chalk and limestone topography that surrounds and subdivides the Blackmore Vale elevates sensitivity by providing high ground from which there are more open views across the vale.The presence of a distinctive, modern land use which contrasts with the pastoral character of most of the LCA could detract from the sense of rural tranquillity.The homogeneous rural character of the Clay Vale would be sensitive to development that introduced a distinctive, uncharacteristic land use which did not fit into the small scale of the landscape. There are visual sensitivities relating to elevated viewpoints in AONBs however, and sensitivity could be higher where:   Location is prominent within long views either within the LCA (which may be identified in Parish Action Plans, Village Design Statements or other Settlement Appraisals) or into it from prominent AONB viewpoints (e.g. Hambledon Hill); Field shapes are irregular and/or small; Land use in the vicinity is uniformly pastoral; There are no woodland blocks or well treed field boundaries to screen views.’ Overall, the SA concludes that the LCA has a high degree of sensitivity large scale (over 30ha) solar development, though as before, each development should be assessed on a site by site basis.   As outlined above, the text under Inset Plan 3 of the LVIA indicates that the most sensitive sites were omitted because of their high landscape and visual sensitivity. Figure 6.4 however shows that 3 of fields that are to be developed within the Blackmore Vale LCA (small irregular flat mixed agricultural fields) have characteristics identified in the SA as making them more sensitive. The 4 large uniformly sloping mixed agricultural fields may potentially be less sensitive, however the photos in the LVIA show that there are however no woodland blocks/well treed field boundaries to screen views from viewpoints 2, 6 (intermittent), 17 and 20. The Landscape Visual photomontages of the proposals from viewpoints 2 and 6 also show that the proposed mitigation planting will not have a significant screening effect at year 15.   The LVIA concludes that the landscape of the site as a whole has moderate-high sensitivity to solar PV development. However, this part of the LCA also contributes to the setting of the Dorset AONB’s North Dorset Escarpment LCA, where there is an interrelationship between the valued landscapes of the North Dorset Escarpment and the Blackmore Vale. As above, this is highlighted in the descriptions of key characteristics for each LCA that are included in the relevant Landscape Character Assessments:   The North Dorset Escarpment has a ‘bold dominant character’ with a key characteristic being ‘extensive panoramic views of the surrounding countryside, particularly across the Blackmore Vale’ (Dorset AONB Landscape Character Assessment https://www.dorsetaonb.org.uk/resource/north-dorset-escarpment )The Blackmore Vale has characteristically ‘open views across the undulating to flat pastoral landscape to the chalk escarpment backdrop’ (North Dorset Landscape Character Assessment 2008). Along with the visual and experiential interrelationship, there is an interdependency with regard to character which only reduces notably with greater distance.   Again, whilst assessing the susceptibility of the landscape at a site-specific scale by using the criteria in Table 7 (Appendix 6.3) of the SA (as in the LVIA) a valid approach, the significance of this interdependency is lost and sensitivity therefore also understated. As such, I consider that the part of the site that lies in the Blackmore Vale LCA generally has moderate-high sensitivity to solar PV development, but that it has high sensitivity to the scale of development that is proposed. I therefore consider that this part of the LCA also has a high degree of sensitivity to large scale solar PV development. In reference to Table 4 of the SA this means that ‘key characteristics and qualities of the landscape are highly vulnerable to change from the development type’ and that ‘such development is likely to result in a significant change in character.’   Visual effects   Generally, the nature of the topography and strong intact landscape structure found within the Blackmore Vale limits the visual exposure of the site and its interrelationship with the local landscape. The proposals will introduce elements that are uncharacteristic within the surrounding landscape but with limited visual intrusion and the changes being reversable when decommissioned. Therefore, visual receptors overall are likely to experience minor, adverse effects within publicly available locations locally. The LVIA does note however that:   (Para 196) within a very limited geographical area (Hammond Street Farm, Fir Tree Farm, Muston Farm, Wonston and part of PRoW N46/21) where the topography of the landscape provides a vantage point overlooking the Site, the proposals are likely to result in moderate, adverse visual effects as part of the Site will be visible and the PV panels would be apparent and clearly visible within the views. (Para 197) where PRoW N46/20 crosses through the Site the proposals will be clearly evident and dominate the views, however, these are not ‘fine and valued views’ as is the case of views from the AONB for example. It is likely to result in moderately high, adverse effects. In order to reduce the overall impact of the development a number of design strategies have been incorporated within the development layout and include:   Additional boundary screening to mitigate possible glare identified in the Glint and Glare Study that may affect Dairy House Farm (Cluster 10-13), Boywood Farm (Cluster 14-15) and Povert Bridge (Cluster 16-17). A new hedgerow and tree belt to provide screening between the Site and Boywood farm. Tree belt planting to filter views of the sub-station from properties to the east of the Site. A new hedge and hedgerow trees along the north eastern fencing (Fields 6 and 7) to provide robust screening, soften and filter views of the proposals from the PRoW to the north of the Site. Additional hedgerow trees along the north western boundary (Field 17) to filter views from the PRoW running through North Dairy Farm to the north west of the Site. To significantly improve the landscape structure approximately 1646lm of new hedgerows will be planted with only 6-8lm of extant hedge being lost to accommodate a new access point to Field 4. There may be additional short sections of hedge removal to accommodate the laying of underground cables, but these will be replaced with a suitable hedge mix (exact locations and extent to be confirmed). This will see the restoration of field boundary hedges and the removal of post and wire fencing resulting in a long-term enhancement of field patterns. Extant mature hedges will be enhanced through infill planting where there are gaps and improved management. Similarly, all watercourse vegetation will be enhanced through improved management. Further enhancements include new pastures, wildflower rich margins and wild bird cover that will be specifically managed for wildlife benefit. I consider that these measures will be partly effective in reducing the visual impact of the proposals from local visual receptors. However, as illustrated by the photomontages, the impact of the development in views from viewpoints 2, 6, 8 and 17 will be will still be moderate to substantial even after 15 years (NB the AONB and Dungeon Hill Scheduled Ancient Monument form the skyline in the view from viewpoint 2). Also, as indicated in the LVIA (paragraph 222), ‘where RoW N46/20 crosses through the site the proposals will be clearly evident and dominate the views. These are not fine and valued views as is the case of views from AONB, but nonetheless it is likely to result in major-moderate, adverse effects.’ Paragraph 222 goes on to say that ‘additional mitigation measures within the site and flanking the RoW may reduce this effect’ but does not confirm to what degree. I suggest that a strong awareness of the development will remain due to its close proximity, and to the uncharacteristic ‘industrial’ scale and utilitarian form of its component parts.   Improvements to the structure and management of the existing vegetation, and enhancements to support biodiversity will also be achieved, but I am not of the opinion that the resulting improvements will be sufficient to offset the significant residual adverse visual effects that will be observed.   In addition to this, the strong intact nature of the landscape and topography and the proposed mitigation measures will not be as effective from elevated locations where the interior of the site comes into view, such as from the chalk escarpment landscape of the AONB. The LVIA indicates that the proposals have ‘sought to limit the extent of intervisibility between the Site and the AONB’, but I have reservations about the effectiveness of these measures due to the size of the proposed development. I note that Richard Brown has suggested the inclusion of a number of additional viewpoints in the assessment, so will not comment further on this aspect other than to highlight that LVIA makes reference to partial views from Ball Hill, but does not include an assessment of the impact of the development in these views.   Landscape effects   In paragraph 188 the LVIA reports that the proposals will result in the following changes to landscape character:   Site-specific Landscape Character: There will be an inherent moderate-high, adverse magnitude of change to the landscape character of the Site in of itself. Immediate context of Site/ Local Landscape Character: Similarly, there is an inherently moderate-high, adverse magnitude of change to the local landscape character. Wider Landscape/ District Landscape Character Types and Areas: there will be limited changes to the wider landscape character due to the nature of the topography and strong intact landscape structure that is found within the South Blackmore Rolling Vales and Blackmore Vale Landscape Character Areas. At this scale, the magnitude of change to the landscape character is low, adverse. The LVIA goes on to indicate that the proposals include the creation of a significant amount of beneficial landscape structure and elements and that the change is reversable with decommissioning. As I have already indicated, I do not consider that the enhancements satisfactorily offset the introduction of uncharacteristic land use. In addition to this, whilst the development is not permanent and its effects are reversible, the installation will be in place for 35 years, which is a significant amount of time. The proposed mitigation planting/enhancements and the reversibility of the scheme do not in my view therefore limit the interrelationship the site has to the local or wider landscape to the degree suggested in the LVIA. This landscape has a high degree of sensitivity to large scale solar PV development, and as explained in the SA ‘such development is likely to result in a significant change in character.’ Based on this I can agree with the conclusion drawn in paragraph 193 of the LVIA in that within the site and its immediate context, the proposals would result in major-moderate adverse effects during the operational phase. I do not however agree that the proposals would result in limited changes to the wider landscape or that the wider landscape effect would be of a minor, adverse significance. This is because I do not believe that the mitigation measures will satisfactorily maintain or restore losses, and (referring to Table 3 of Appendix 6.2 – Magnitude of change criteria for landscape) this suggests that the magnitude of change would be at the high end of moderate adverse as opposed to low adverse indicated in the LVIA. This is likely to result in the wider landscape effect being of greater significance than reported. It should also be noted that it is not clear from the LVIA or from Appendix 6.2 what criteria have been applied to assess the overall significance of landscape effects, other than that sensitivity and magnitude of change are combined.   I also have concerns about the potential impact of the proposed development on the special qualities of the AONB and on the setting of the following cultural and heritage assets:   Duntish Court (undesignated) heritage asset (see Dorset Gardens Trust report below)Dungeon Hill Iron Age Hillfort Scheduled Ancient MonumentAncient drove roads, including those at the Dorsetshire GapMelcombe Park (former deer park)Rawlsbury Camp Iron Age Hill Fort Scheduled Ancient Monument Both of the Hill forts have a specific relationship with the wider landscape as they were strategically located so as to have long ranging views for surveillance purposes. The eighteenth-century gardens/pleasure ground at Duntish Court also have an important relationship with the wider landscape, with views towards Ibberton Hill being a key aspect of the design. These and other heritage assets indicate the considerable time-depth that is associated with the landscape that the proposed development sits within, and which contributes much to the value of the landscape. This time-depth and the cultural associations of the Blackmore Vale (which is often referred to as Hardy’s Vale because of its association with Thomas Hardy) may not be enough to elevate the value of the landscape outside of the AONB to a level that would constitute a valued landscape, but I consider it to be more than the ‘ordinary landscape’ described in the LVIA.   Richard Brown has been consulted on the application and so will be able to comment further on the impact of the development on the special qualities of the AONB. I see that the Conservation Team has also been consulted and will be able to advise you further on the significance of impact on the setting of heritage assets.

 Policy consideration

  NPPF   Paragraph 154 (renewable and low carbon development) indicates that the application should be approved if its impacts are (or can be made) acceptable.Paragraph 170 (natural and local environment) requires protection and enhancement of valued landscapes. The intrinsic character and beauty of the countryside should also be recognised.   At 77ha the proposed development would be one of the largest solar PV developments in the south west. The site is located in a landscape that is highly sensitive to large scale solar PV development, and although the proposals include mitigation measures, I do not consider that these measures will satisfactorily offset the moderate-high adverse magnitude of change which will occur. This will result in a significant change in character of the local landscape that will also potentially adversely affect the setting of the AONB, most particularly given the interrelationship between clay/rolling vale character of the local landscape that the site is located in and the chalk escarpment. There will also be significant adverse effects on views from Rights of Way to the east of the site, most especially where these views extend across the site to Dungeon Hill Scheduled Ancient Monument and the AONB to the west. For these reasons, I do not think that the proposals in their current form comply with the requirements of paragraph 154 or paragraph 170 of the NPPF. There may be some potential to reduce these adverse effects if the proposal is significantly reduced in size and contained within the part of the site that is located in the Blackmore Vale LCA only, but the acceptability of this will need to be discussed further with Richard Brown of the AONB Team.    North Dorset Local Plan (Jan 2016)   Policy 3 requires renewable and low carbon energy developments to be appropriately sited.Policy 4 requires developments to respect the natural environment including the designated sites, valued landscapes and other features that make it special. Where significant impact is likely to arise as a result of a development proposal, developers will be required to clearly demonstrate that that the impact on the landscape has been mitigated and that important landscape features have been incorporated in to the development scheme. Within the areas designated as AONB and their setting, development will be managed in a way that conserves and enhances the natural beauty of the area.Policy 22 requires all adverse impacts arising from the proposal to have been satisfactorily assessed. The potential to mitigate any adverse impacts identified must be maximized. The proposal must incorporate an agreed restoration scheme.   As identified above, the site is located in a landscape that is highly sensitive to large scale solar PV development, and although the proposals include mitigation measures, these measures will not satisfactorily offset the moderate-high adverse magnitude of change which will occur. For this reason, and given the adverse impact on views from the east of the site, I do not consider that it is appropriately sited or that it respects the character of the setting. The proposals in their current form do not therefore comply with the requirements of Policies 3 and 4. There may be some potential to reduce the adverse effects if the site is significantly reduced in size and contained within the part of the site that is located in the Blackmore Vale LCA only, but again, the acceptability of this will need to be discussed further with Richard Brown of the AONB Team.   As far as I am aware, the viewpoints included within the LVIA were not agreed with the Local Planning Authority. I am also aware that the AONB Team requires the inclusion of further viewpoints to enable full consideration of the visual effects of the proposal. In addition to this, the submitted documents indicate that the installation will be removed from the site at the end of its 35 year operational life, but no restoration scheme has been provided. For these reasons, I do not consider that the proposal complies with the requirements of Policy 22.

Officer: Helen Lilley

Job Title: Senior Landscape Architect

Date: 04/06/2021

APPENDIX:

 Application details

Ref: P/FUL/2021/01018Applicant: North Dairy Farm Solar Park LimitedCase Officer: Simon McFarlane
Address:  North Dairy Farm Access To North Dairy Farm Pulham Dorset DT2 7EA
Description: 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
Case Officer comments to Consultee:
Consultee: Helen Lilley, Senior Landscape Architect
Date: 04/06/2021
Has a Pre-application discussion taken place with you?  No
Support 
Support subject to condition(s) 
Unable to supportx
No objection 
Request for further information 
Other 

 Summary

  At 77ha the proposed development would be one of the largest solar PV developments in the southwest. The site is located in a landscape that is highly sensitive to large scale solar PV development, and although the proposals include mitigation measures, I do not consider that these measures would satisfactorily offset the moderate-high adverse magnitude of change which would occur. This would result in a significant change in character of the local landscape and would also potentially adversely affect the setting of the AONB, most particularly given the interrelationship between clay/rolling vale character of the local landscape that the site is located in, and the chalk escarpment landscape of the AONB.   There would also be significant adverse effects on views from Rights of Way to the east of the site, most especially where these extend across the site to Dungeon Hill Scheduled Ancient Monument/the AONB to the west.   For these reasons, I am not able to support the application as the proposals in their current form do not comply with the requirements of paragraph 154 or paragraph 170 of the NPPF or Policies 3 and 4 of the North Dorset Local Plan.     In addition to this, I do not believe that the landscape and visual impacts of the proposal have been fully assessed, and no restoration scheme has been provided, so the proposal does not fully comply with the requirements of Policy 22 of the North Dorset Local Plan.   There may also be potential for the proposals to adversely impact on the setting of various heritage assets, though the Conservation Team will be better placed to advise on these matters.   The adverse effects if the proposal could be reduced if it is significantly reduced in size and contained within the part of the site that is located in the Blackmore Vale LCA only, but the acceptability of this will need to be discussed further with Richard Brown of the AONB Team.   

 Site description/context/significance

  The site is located between the villages of Pulham (to the west), Hazelbury Bryan (to the east) and Mappowder (to the south). The 11 fields within the site are referred to as Fields 4, 6 to 13, 16 and 17 for the purpose of the Application. Fields 1 to 3, 5, 14, 15 and 18 to 27 formed the wider assessment area which were excluded from the site as a result of preliminary environmental assessment and the identified planning constraints. The fields are variously described as Small Irregular Flat Mixed Agricultural Fields, Large Uniformly Sloping Mixed Agricultural Fields and Large Open Undulating Arable Fields.

There are several Rights of Way (RoW) near the site (N49/4; N46/19; N46/21; N46/28) as well as one crossing through the site (N46/20). The Design and Access Statement indicates that no RoW will be stopped up or diverted (temporarily or permanently) and they will remain open to public access throughout the construction, operational and decommissioning phases.
The site is characterised by gentle to moderate gradients, with levels on site ranging from between c. 93m AOD to 77m AOD. The River Lydden is located approximately 90m to the west of the site at its closest point and flows in a north-easterly direction. An unnamed watercourse flows through the centre of the site, and another unamend watercourse flows along part of the north eastern site boundary. Both watercourses converge near the northern site boundary via a pond and join the River Lydden approximately 155m to the north of the site.   The site straddles two landscape character areas. The northern part of the site lies in the Blackmore Vale LCA which is broad, gently undulating flat landscape. Key characteristics:   A broad expansive clay Vale which is tranquil and unified.A unique mosaic of woods, straight hedgerows and grassland fields ‘dotted’ with distinctive mature hedgerow Oaks.Open views across the undulating to flat pastoral landscape to the chalk escarpment backdrop.Dense network of twisting lanes often with grass verges and sharp double 90o bends.Small hump backed bridges with low stone or brick parapetsMany very small villages and hamlets built with locally distinctive materials, such as stone, redbrick, tile and thatch.A network of ditches, streams and brooks which drain into the tributaries of the Stour.Lydlinch Common (an SSSI) and Stock Gaylard Deer Park (an SNCI) are both key locally important features   The southern part of the site lies in the South Blackmore Rolling Vales LCA which is a more undulating/rolling pastoral landscape which represents the transition zone between the landscapes of the Blackmore Vale and the Chalk Escarpment of the Dorset AONB to the south. Key Characteristics:   Undulating and rolling farmland hills forming a transition zone between the Blackmore Vale and the chalk escarpment.The chalk escarpment forms a backdrop and landmark to the area.A more folded landscape at the foot of the escarpment.Irregular shaped fields bounded by thick hedgerows.Mature hedgerows are important features nearer the Blackmore Vale.Twisting hedge lined lanes with narrow verges.Small bridged stream crossings are key features often with low parapets.Settlements are often situated at the foot of the escarpment or on elevated slopes overlooking the Vale.There are numerous scattered farmsteads.Frequent use of locally distinctive building materials, mainly stone and brick, adds to character.A tranquil and unified landscape.The ‘tongue’ of rolling hills at Shillingstone, where the River Stour breaks through the chalk escarpment, is a key feature.Piddles Wood is an important SSSI woodland in the north of the area on the edge of the Stour Valley   There is a strong interrelationship between the landscape character areas of the site and the North Dorset Chalk Escarpment which is in the AONB and is therefore a valued landscape. It forms a prominent backdrop to the site and panoramic views across the Vale form an intrinsic part of its character. Key characteristics:   A dramatic, exposed, steep and narrow escarpment with rounded spurs and deep coombes.A patchwork of small scale pastoral fields on the lower slopes, with scattered farmsteads at the ridge bottom spring line.Areas of unimproved chalk grassland on slopes and ridge tops.Large, straight-sided arable fields on escarpment top.Hanging ancient oak, ash and hazel woodlands on the lower slopes.Dense gorse scrub on the steep ridge sides.Thin calcareous soils with the underlying geology of lower, middle and upper chalk.Panoramic views of the surrounding landscape.Bronze Age barrows and prominent hill top forts.Ancient, sunken winding lanes with an open character towards the top.Ponds on the hill top at Bonsley Common.   The site lies within 1.25km of the Chalk Escarpment landscape of the AONB, and forms an important part of its setting.   This part of the Blackmore Vale is tranquil and undeveloped. Settlements are small and dispersed, and the landscape has a strong rural feel to it. The Vale has been farmed for centuries and is known locally as the Land of Milk and Honey; much of the land being turned over to pasture. There are strong cultural associations, with the Author Thomas Hardy both living locally and using the Vale as the setting in his works. The ‘Hardy Trail’ is a popular long-distance walking route that passes within 850m of the site to the east, from where the site can be seen in views towards Dungeon Hill Scheduled Ancient Monument/the AONB to the west. The Wessex Ridgeway is another popular long-distance footpath which connects many of the heritage assets along the chalk escarpment/ridge, including Rawlsbury Camp Scheduled Ancient Monument from where there are extensive views across the Blackmore Vale. Ancient drove roads are another characteristic feature of the landscape.   The site is in the Blackmore Vale and Vale of Wardour National Character Area. Whilst the proposed development will not negatively impact on the landscape at this NCA scale, it is useful to reference the NCA Profile for background information regarding the strength of character and condition of the landscape planning and management aims. The NCA Profile describes the area as being:

Steeped in a long history of pastoral agricultureCharacterised by hedged fields with an abundance of hedgerow trees, many of them veteranProductive pastureland

Relevant Statements of Environmental Opportunity contained within the Profile:
SEO 1: Protect, manage and enhance the diverse but coherent pastoral landscape character of the clay vales, limestone ridge and Greensand hills, their semi-natural grasslands and woodland and their characteristic wildlife, and manage the simple patterns of land use maintained by the long history of agriculture.
SEO 2: Work with local people to raise their understanding of the way in which the area’s
strong landscape character, sense of place and distinctive wildlife are rooted in the continuity
of agricultural land use, strong historic landscape character and legibility of historic features.
SEO 3: Work with the local farming and land management community to maintain the
distinctive landscape and natural beauty of the area, enhancing ecosystems and ecosystem
services.
Tranquillity is described as being an important part of the character of the landscape (page 23 under Experiential Qualities – Tranquillity):   The 2007 Intrusion Map (CPRE) shows the extent to which rural landscapes are ‘intruded on’ from urban development, noise (primarily traffic noise), and other sources of visual and auditory intrusion. This shows that the most disturbed area is around the settlements of Frome, Warminster, Gillingham and Shaftsbury; apart from here and along transport routes, the whole of the NCA is still undisturbed land.
Threats to character (page 28 under Drivers of Change):   Housing allocations and development of employment sites could have an adverse impact on the character around the NCA’s settlements; increased infrastructure could also have deleterious impacts on character and tranquillity.
The landscape is described as being intact (page 44 under Ecosystem Services – Sense of
Place/Inspiration – State):   The major features of sense of place, the intensely pastoral and rural clay vales and the more mysterious wooded scarps and hills, are at the NCA scale intact and maintain its character.
Much of the area is undeveloped (page 46 under Ecosystem Services – Tranquillity –
Analysis):Tranquillity is still strongly associated with large parts of the NCA. Much of the area is still undeveloped and has changed little for over a century. Levels of intrusion are relative and often do not ‘penetrate’ far beyond the settlement or transport corridor.   The historical and cultural associations, time-depth, tranquillity, strength of character, recreational value and natural beauty of the Blackmore Vale all contribute to the value of the landscape. Whilst in planning terms the undesignated parts of the Vale are not a valued landscape, those areas adjacent to the AONB contribute much to its setting and are considered more than an ordinary landscape.   

 Main issues

  The main issues from a landscape point of view are that there will be significant adverse landscape and visual effects associated with this proposal, and that these effects cannot be satisfactorily mitigated because of the large size and utilitarian appearance of the development. The site is also located close to the Dorset AONB, in a landscape that has a high degree of sensitivity to large scale development of this type.  

 The proposal

  Static solar photovoltaic (PV) panels, ground mounted to a railing sub-structure. Laid out in rows with gaps of approximately 2-6m between each, arranged at an angle of c.22 degrees from east to west. The lower edge of the panels would be approximately 0.8m from the ground and up to approximately 2.6m at their higher edge. String combiner boxes for combining multiple strings of solar panels located underneath or adjacent to the fixed tilt structures. 33 transformer stations distributed evenly across the solar arrays housed within green metal containers. Compacted internal crushed stone tracks (constructed on a sub-layer of geogrid membrane within RPAs) to allow vehicular access between fields. Fencing 2.2m high and gates to enclose the panels within each field and allow sheep to graze securely. These comprise of wooden deer fence poles with galvanised fencing. Mammal Access Points are located along the fence line. Security and monitoring CCTV mounted on fence posts within each field. The poles would be approximately 2.5-3m high spaced at 50m intervals along the fence.Underground cabling to connect the panels to the proposed substation. A security-fenced enclosed substation compound including associated ancillary services which will connect to the existing overhead power line via a new pylon, the maximum height of which would be 15m and maximum width 10m. 5.6m x 4.6m consol room, 12.0m x 5.6m customer switch room, 12.2m x 2.4m spares container and a 6.1m x 2.4m welfare container, all of which will be 3.2m high.A substation access track with a cement based top layer with a geogrid sub-base of compacted stone (a statutory requirement of the DNO, SSE).35 year operational life.Site area 77ha.The total construction period for a site of this size is indicated to be c.5 months, including pre-preparation of the site, fencing, assembly, deliveries and installation of photovoltaic panels and grid connection.A temporary construction compound will be used to store materials and ancillary welfare facilities during the construction period. The temporary compound will likely (but not limited to) include:
• Welfare facilities
• Staff parking
• Offices
• Canteens
• Stores

 Comments on proposal

  Landscape sensitivity   The sensitivity of the landscape character areas that the site is located in is outlined in the Landscape Sensitivity to Wind and Solar Energy Development in North Dorset District SPD (produced by LUC in April 2014). This is a strategic assessment but forms a useful basis against which to consider the sensitivity of the landscape that the site sits within to development of the type that is proposed. The assessment defines landscape sensitivity as ‘the extent to which the character and quality of the landscape is susceptible to change as a result of field-scale solar PV development’.   The southern part of the site falls within the South Blackmore Rolling Vales Landscape Character Area (LCA), which is a subset of the Rolling Vales Landscape Character Type (LCT). The sensitivity assessment (SA) identifies that in the Rolling Vales LCT:   The undulating, irregular, small scale pastoral terrain is typically of high sensitivity to solar PV development.There are some flatter, arable fields which would be less sensitive in terms of landform and land use.The extent of screening from trees and hedgerows to an extent offsets sensitivity, particularly for smaller developments, but there are some strong views into the LCT from adjoining AONB chalk escarpments. At the LCA scale, the SA indicates that sensitivity to larger solar PV developments will be high in this undulating landscape with irregular field boundaries. Smaller developments could potentially be effectively screened but sensitivity could be higher where:   Location is on an exposed or significantly undulating slope, particularly if it is visible in the same context as more distinctive parts of the chalk escarpment, such as near Shillingstone (Hod Hill) and Stoke Wake (White Hill and Bulbarrow Hill).Location detracts from the green, patchwork character of the landscape, as observed from elevated viewpoints (particularly those in AONB settings). Overall, the SA concludes that the South Blackmore Rolling Vales LCA has a high degree of sensitivity large scale (over 30ha) solar development, though as indicated in the LVIA, each development should be assessed on a site by site basis.   As outlined above, areas which consist of flatter arable fields will be less sensitive in terms of landform and land use, and screening from trees and hedgerows will offset sensitivity, but this is only relevant for smaller developments and for those away from the rising ground of the chalk escarpment/elevated viewpoints within the AONB. It is also important to note that views towards the higher ground of the Dorset AONB (including notable cultural and heritage assets) form an intrinsic part of the perceptual character of the southern reaches of the LCA. This aspect is particularly relevant in relation to the proposed development, as the AONB effectively wraps around the landscape that the site sits within, thereby further increasing sensitivity.   The text under Inset Plan 3 of the LVIA indicates that the most sensitive sites (fields in the landholding) were omitted because of their high landscape and visual sensitivity. Figure 6.4 nevertheless shows that all of fields that are to be developed within this LCA have characteristics identified in the SA sensitive: 3 of these fields are large open undulating arable fields, and 1 is a small irregular flat mixed agricultural field. The most significant factor however is that at 77ha, the proposed solar development is extremely large and because of its size alone will detract from the green, patchwork character of the landscape as observed from elevated viewpoints whether in the AONB or not.   Photomontages 2, 3, 6 and 18 produced by Landscape Visual illustrate that the proposed mitigation planting will have little effect in screening the development at year 15. The adverse effects would be less significant if the development was reduced in scale and confined to the larger, flatter arable fields as indicated in the SA. There are however no fields with these characteristics in the part of the LCA where the site is located.   The LVIA concludes that the landscape of the site as a whole has moderate-high sensitivity to solar PV development. However, this part of the LCA forms an intrinsic part of the setting of the Dorset AONB’s North Dorset Escarpment LCA, where there is a strong interrelationship between the valued landscapes of the North Dorset Escarpment and the South Blackmore Rolling Vales. This is highlighted in the descriptions of key characteristics for each LCA that are included in the relevant Landscape Character Assessments:   The North Dorset Escarpment has a ‘bold dominant character’ with a key characteristic being ‘extensive panoramic views of the surrounding countryside, particularly across the Blackmore Vale’ (Dorset AONB Landscape Character Assessment https://www.dorsetaonb.org.uk/resource/north-dorset-escarpment )The South Blackmore Rolling Vales are ‘undulating and rolling farmland hills forming a transition zone between the Blackmore Vale and the chalk escarpment’ – ‘The chalk escarpment forms a backdrop and landmark to the area’ (North Dorset Landscape Character Assessment 2008). Along with the visual and experiential interrelationship, there is clearly an interdependency with regard to character – the Blackmore Rolling Vales represent a transition zone between the chalk escarpment and the Blackmore Vale LCA.   Whilst the validity assessing the susceptibility of the landscape at a site-specific scale by using the criteria in Table 7 (Appendix 6.3) of the SA (as in the LVIA) is understood, the significance of this interdependency is lost and sensitivity therefore understated. I consider that this part of the LCA has a high degree of sensitivity to large scale solar PV development. In reference to Table 4 of the SA this means that ‘key characteristics and qualities of the landscape are highly vulnerable to change from the development type’ and that ‘such development is likely to result in a significant change in character.’  The northern part of the site falls within the Blackmore Vale LCA, which is a subset of the Clay Vale LCT. The SA identifies that flat or gently undulating landform is not inherently sensitive to solar PV development – the even topography means that solar PV development would be unlikely to be perceptible beyond its immediate surrounds. It also notes that ground-level views are limited by the well-treed field boundaries and woodland blocks. However, the assessment goes on the identify that:   The chalk and limestone topography that surrounds and subdivides the Blackmore Vale elevates sensitivity by providing high ground from which there are more open views across the vale.The presence of a distinctive, modern land use which contrasts with the pastoral character of most of the LCA could detract from the sense of rural tranquillity.The homogeneous rural character of the Clay Vale would be sensitive to development that introduced a distinctive, uncharacteristic land use which did not fit into the small scale of the landscape. There are visual sensitivities relating to elevated viewpoints in AONBs however, and sensitivity could be higher where:   Location is prominent within long views either within the LCA (which may be identified in Parish Action Plans, Village Design Statements or other Settlement Appraisals) or into it from prominent AONB viewpoints (e.g. Hambledon Hill); Field shapes are irregular and/or small; Land use in the vicinity is uniformly pastoral; There are no woodland blocks or well treed field boundaries to screen views.’ Overall, the SA concludes that the LCA has a high degree of sensitivity large scale (over 30ha) solar development, though as before, each development should be assessed on a site by site basis.   As outlined above, the text under Inset Plan 3 of the LVIA indicates that the most sensitive sites were omitted because of their high landscape and visual sensitivity. Figure 6.4 however shows that 3 of fields that are to be developed within the Blackmore Vale LCA (small irregular flat mixed agricultural fields) have characteristics identified in the SA as making them more sensitive. The 4 large uniformly sloping mixed agricultural fields may potentially be less sensitive, however the photos in the LVIA show that there are however no woodland blocks/well treed field boundaries to screen views from viewpoints 2, 6 (intermittent), 17 and 20. The Landscape Visual photomontages of the proposals from viewpoints 2 and 6 also show that the proposed mitigation planting will not have a significant screening effect at year 15.   The LVIA concludes that the landscape of the site as a whole has moderate-high sensitivity to solar PV development. However, this part of the LCA also contributes to the setting of the Dorset AONB’s North Dorset Escarpment LCA, where there is an interrelationship between the valued landscapes of the North Dorset Escarpment and the Blackmore Vale. As above, this is highlighted in the descriptions of key characteristics for each LCA that are included in the relevant Landscape Character Assessments:   The North Dorset Escarpment has a ‘bold dominant character’ with a key characteristic being ‘extensive panoramic views of the surrounding countryside, particularly across the Blackmore Vale’ (Dorset AONB Landscape Character Assessment https://www.dorsetaonb.org.uk/resource/north-dorset-escarpment )The Blackmore Vale has characteristically ‘open views across the undulating to flat pastoral landscape to the chalk escarpment backdrop’ (North Dorset Landscape Character Assessment 2008). Along with the visual and experiential interrelationship, there is an interdependency with regard to character which only reduces notably with greater distance.   Again, whilst assessing the susceptibility of the landscape at a site-specific scale by using the criteria in Table 7 (Appendix 6.3) of the SA (as in the LVIA) a valid approach, the significance of this interdependency is lost and sensitivity therefore also understated. As such, I consider that the part of the site that lies in the Blackmore Vale LCA generally has moderate-high sensitivity to solar PV development, but that it has high sensitivity to the scale of development that is proposed. I therefore consider that this part of the LCA also has a high degree of sensitivity to large scale solar PV development. In reference to Table 4 of the SA this means that ‘key characteristics and qualities of the landscape are highly vulnerable to change from the development type’ and that ‘such development is likely to result in a significant change in character.’   Visual effects   Generally, the nature of the topography and strong intact landscape structure found within the Blackmore Vale limits the visual exposure of the site and its interrelationship with the local landscape. The proposals will introduce elements that are uncharacteristic within the surrounding landscape but with limited visual intrusion and the changes being reversable when decommissioned. Therefore, visual receptors overall are likely to experience minor, adverse effects within publicly available locations locally. The LVIA does note however that:   (Para 196) within a very limited geographical area (Hammond Street Farm, Fir Tree Farm, Muston Farm, Wonston and part of PRoW N46/21) where the topography of the landscape provides a vantage point overlooking the Site, the proposals are likely to result in moderate, adverse visual effects as part of the Site will be visible and the PV panels would be apparent and clearly visible within the views. (Para 197) where PRoW N46/20 crosses through the Site the proposals will be clearly evident and dominate the views, however, these are not ‘fine and valued views’ as is the case of views from the AONB for example. It is likely to result in moderately high, adverse effects. In order to reduce the overall impact of the development a number of design strategies have been incorporated within the development layout and include:   Additional boundary screening to mitigate possible glare identified in the Glint and Glare Study that may affect Dairy House Farm (Cluster 10-13), Boywood Farm (Cluster 14-15) and Povert Bridge (Cluster 16-17). A new hedgerow and tree belt to provide screening between the Site and Boywood farm. Tree belt planting to filter views of the sub-station from properties to the east of the Site. A new hedge and hedgerow trees along the north eastern fencing (Fields 6 and 7) to provide robust screening, soften and filter views of the proposals from the PRoW to the north of the Site. Additional hedgerow trees along the north western boundary (Field 17) to filter views from the PRoW running through North Dairy Farm to the north west of the Site. To significantly improve the landscape structure approximately 1646lm of new hedgerows will be planted with only 6-8lm of extant hedge being lost to accommodate a new access point to Field 4. There may be additional short sections of hedge removal to accommodate the laying of underground cables, but these will be replaced with a suitable hedge mix (exact locations and extent to be confirmed). This will see the restoration of field boundary hedges and the removal of post and wire fencing resulting in a long-term enhancement of field patterns. Extant mature hedges will be enhanced through infill planting where there are gaps and improved management. Similarly, all watercourse vegetation will be enhanced through improved management. Further enhancements include new pastures, wildflower rich margins and wild bird cover that will be specifically managed for wildlife benefit. I consider that these measures will be partly effective in reducing the visual impact of the proposals from local visual receptors. However, as illustrated by the photomontages, the impact of the development in views from viewpoints 2, 6, 8 and 17 will be will still be moderate to substantial even after 15 years (NB the AONB and Dungeon Hill Scheduled Ancient Monument form the skyline in the view from viewpoint 2). Also, as indicated in the LVIA (paragraph 222), ‘where RoW N46/20 crosses through the site the proposals will be clearly evident and dominate the views. These are not fine and valued views as is the case of views from AONB, but nonetheless it is likely to result in major-moderate, adverse effects.’ Paragraph 222 goes on to say that ‘additional mitigation measures within the site and flanking the RoW may reduce this effect’ but does not confirm to what degree. I suggest that a strong awareness of the development will remain due to its close proximity, and to the uncharacteristic ‘industrial’ scale and utilitarian form of its component parts.   Improvements to the structure and management of the existing vegetation, and enhancements to support biodiversity will also be achieved, but I am not of the opinion that the resulting improvements will be sufficient to offset the significant residual adverse visual effects that will be observed.   In addition to this, the strong intact nature of the landscape and topography and the proposed mitigation measures will not be as effective from elevated locations where the interior of the site comes into view, such as from the chalk escarpment landscape of the AONB. The LVIA indicates that the proposals have ‘sought to limit the extent of intervisibility between the Site and the AONB’, but I have reservations about the effectiveness of these measures due to the size of the proposed development. I note that Richard Brown has suggested the inclusion of a number of additional viewpoints in the assessment, so will not comment further on this aspect other than to highlight that LVIA makes reference to partial views from Ball Hill, but does not include an assessment of the impact of the development in these views.   Landscape effects   In paragraph 188 the LVIA reports that the proposals will result in the following changes to landscape character:   Site-specific Landscape Character: There will be an inherent moderate-high, adverse magnitude of change to the landscape character of the Site in of itself. Immediate context of Site/ Local Landscape Character: Similarly, there is an inherently moderate-high, adverse magnitude of change to the local landscape character. Wider Landscape/ District Landscape Character Types and Areas: there will be limited changes to the wider landscape character due to the nature of the topography and strong intact landscape structure that is found within the South Blackmore Rolling Vales and Blackmore Vale Landscape Character Areas. At this scale, the magnitude of change to the landscape character is low, adverse. The LVIA goes on to indicate that the proposals include the creation of a significant amount of beneficial landscape structure and elements and that the change is reversable with decommissioning. As I have already indicated, I do not consider that the enhancements satisfactorily offset the introduction of uncharacteristic land use. In addition to this, whilst the development is not permanent and its effects are reversible, the installation will be in place for 35 years, which is a significant amount of time. The proposed mitigation planting/enhancements and the reversibility of the scheme do not in my view therefore limit the interrelationship the site has to the local or wider landscape to the degree suggested in the LVIA. This landscape has a high degree of sensitivity to large scale solar PV development, and as explained in the SA ‘such development is likely to result in a significant change in character.’ Based on this I can agree with the conclusion drawn in paragraph 193 of the LVIA in that within the site and its immediate context, the proposals would result in major-moderate adverse effects during the operational phase. I do not however agree that the proposals would result in limited changes to the wider landscape or that the wider landscape effect would be of a minor, adverse significance. This is because I do not believe that the mitigation measures will satisfactorily maintain or restore losses, and (referring to Table 3 of Appendix 6.2 – Magnitude of change criteria for landscape) this suggests that the magnitude of change would be at the high end of moderate adverse as opposed to low adverse indicated in the LVIA. This is likely to result in the wider landscape effect being of greater significance than reported. It should also be noted that it is not clear from the LVIA or from Appendix 6.2 what criteria have been applied to assess the overall significance of landscape effects, other than that sensitivity and magnitude of change are combined.   I also have concerns about the potential impact of the proposed development on the special qualities of the AONB and on the setting of the following cultural and heritage assets:   Duntish Court (undesignated) heritage asset (see Dorset Gardens Trust report below)Dungeon Hill Iron Age Hillfort Scheduled Ancient MonumentAncient drove roads, including those at the Dorsetshire GapMelcombe Park (former deer park)Rawlsbury Camp Iron Age Hill Fort Scheduled Ancient Monument Both of the Hill forts have a specific relationship with the wider landscape as they were strategically located so as to have long ranging views for surveillance purposes. The eighteenth-century gardens/pleasure ground at Duntish Court also have an important relationship with the wider landscape, with views towards Ibberton Hill being a key aspect of the design. These and other heritage assets indicate the considerable time-depth that is associated with the landscape that the proposed development sits within, and which contributes much to the value of the landscape. This time-depth and the cultural associations of the Blackmore Vale (which is often referred to as Hardy’s Vale because of its association with Thomas Hardy) may not be enough to elevate the value of the landscape outside of the AONB to a level that would constitute a valued landscape, but I consider it to be more than the ‘ordinary landscape’ described in the LVIA.   Richard Brown has been consulted on the application and so will be able to comment further on the impact of the development on the special qualities of the AONB. I see that the Conservation Team has also been consulted and will be able to advise you further on the significance of impact on the setting of heritage assets.

 Policy consideration

  NPPF   Paragraph 154 (renewable and low carbon development) indicates that the application should be approved if its impacts are (or can be made) acceptable.Paragraph 170 (natural and local environment) requires protection and enhancement of valued landscapes. The intrinsic character and beauty of the countryside should also be recognised.   At 77ha the proposed development would be one of the largest solar PV developments in the south west. The site is located in a landscape that is highly sensitive to large scale solar PV development, and although the proposals include mitigation measures, I do not consider that these measures will satisfactorily offset the moderate-high adverse magnitude of change which will occur. This will result in a significant change in character of the local landscape that will also potentially adversely affect the setting of the AONB, most particularly given the interrelationship between clay/rolling vale character of the local landscape that the site is located in and the chalk escarpment. There will also be significant adverse effects on views from Rights of Way to the east of the site, most especially where these views extend across the site to Dungeon Hill Scheduled Ancient Monument and the AONB to the west. For these reasons, I do not think that the proposals in their current form comply with the requirements of paragraph 154 or paragraph 170 of the NPPF. There may be some potential to reduce these adverse effects if the proposal is significantly reduced in size and contained within the part of the site that is located in the Blackmore Vale LCA only, but the acceptability of this will need to be discussed further with Richard Brown of the AONB Team.    North Dorset Local Plan (Jan 2016)   Policy 3 requires renewable and low carbon energy developments to be appropriately sited.Policy 4 requires developments to respect the natural environment including the designated sites, valued landscapes and other features that make it special. Where significant impact is likely to arise as a result of a development proposal, developers will be required to clearly demonstrate that that the impact on the landscape has been mitigated and that important landscape features have been incorporated in to the development scheme. Within the areas designated as AONB and their setting, development will be managed in a way that conserves and enhances the natural beauty of the area.Policy 22 requires all adverse impacts arising from the proposal to have been satisfactorily assessed. The potential to mitigate any adverse impacts identified must be maximized. The proposal must incorporate an agreed restoration scheme.   As identified above, the site is located in a landscape that is highly sensitive to large scale solar PV development, and although the proposals include mitigation measures, these measures will not satisfactorily offset the moderate-high adverse magnitude of change which will occur. For this reason, and given the adverse impact on views from the east of the site, I do not consider that it is appropriately sited or that it respects the character of the setting. The proposals in their current form do not therefore comply with the requirements of Policies 3 and 4. There may be some potential to reduce the adverse effects if the site is significantly reduced in size and contained within the part of the site that is located in the Blackmore Vale LCA only, but again, the acceptability of this will need to be discussed further with Richard Brown of the AONB Team.   As far as I am aware, the viewpoints included within the LVIA were not agreed with the Local Planning Authority. I am also aware that the AONB Team requires the inclusion of further viewpoints to enable full consideration of the visual effects of the proposal. In addition to this, the submitted documents indicate that the installation will be removed from the site at the end of its 35 year operational life, but no restoration scheme has been provided. For these reasons, I do not consider that the proposal complies with the requirements of Policy 22.

Officer: Helen Lilley

Job Title: Senior Landscape Architect

Date: 04/06/2021

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