Planning Policies

South Worcestershire Development Plan (SWDP) 2016

Renewable and Low Carbon Energy Supplementary Planning Document

Section 5.9

“To avoid the systems becoming a dominant feature within the local landscape and having an adverse visual impact, they should be sited on relatively level ground to reduce their visual profile. Where possible, sites should be screened from view, either by the existing landscape or by planted hedges”

• The land is clearly undulating
• It is not possible to screen the site from view from from local property and viewpoints due to this undulation
• This industrial scale development will be visible from the Malvern Hills

Section 5.10

“There are also sites in South Worcestershire that make a significant contribution to the natural diversity of the area and a number of buildings, monuments, sites, areas or landscapes that have heritage significance… Such assests include… Areas of Outstanding National Beauty [AONB]… Listed Buildings”

“If a solar power scheme is proposed within, or affects the setting of, one of the above types of heritage asset (both designated and non-designated), an assessment of its impact on the asset must be undertaken and submitted with the planning application along with details of how any identified negative impacts have been mitigated”

• The development is within the setting of the Malvern Hills National Landscape, an AONB.
• We can see no evidence of any attempt to mitigate the effect of the development on views from the Malvern Hills and indeed can think of no way in which this could be achieved
• We think it beggars belief that RWE has even considered submitting this planning application – it is almost as if they are a German company and that even their UK representatives have never visited this part of the world
• The development is within the setting of the former Powick Hospital, for which the Administration Building is a listed. Restrictive covenants apply to adjacent properties in order to protect this setting and the views to and from the Old Hills
• This setting will be affected negatively by the proposed development – it would seem perverse to have set these restrictions if the setting was then to be destroyed by an industrial scale development

Section 5.14 Glint and Glare

“Consultation with the MoD is strongly encouraged and evidence of the consultation should be submitted with the planning application along with details of how any concerns have been mitigated”

• The RAF frequently operates helicopter and aeroplane flights at very low altitude  over the site of the proposed development
• We show a photo of the effect that low sun has on glare from the RWE’s solar farm at Doverdale
• Given that this development is not operational yet, and is presumably therefore using the latest panels, it is misleading to state that the sun does not reflect from solar panels
• We can see no evidence of consultation with the MOD in relation to any concerns that they may have in relation to such glare.
• Many properties have outlooks from the Hospital Lane housing estate looking west towards the sun setting over the Malvern Hills. They will similarly be affected by this glare, something that RWE’s glint and glare assessment conveniently overlooks.
• A viewpoint from the Hospital Lane estate will similarly be impacted.

South Worcestershire Development Plan Revision

SWDP 2016 is due to be replaced by the SWDP Revision which is currently in consultation and is therefore yet to be adopted. Our research suggests that most of the policies referenced above for SWDP2016 are very similar in wording and we have not repeated them here.

However, there is a report commissioned by South Worcestershire councils as part of the SWDP Revision evidence gathering that is pertinent:

Malvern Hills AONB Environs Landscape and Visual Sensitivity study

The land parcels that comprise the proposed site and referenced in RWE’s proposal were assessed for their visual sensitivity in this study as follows:

Parcel A: “openness”and being overlooked by the Malvern Hills as a “clear separation between developed corridors and separating Malvern from Worcester.”

• clearly the industrial nature of this development would remove both the openness and separation

Parcels B1 and B2: these were assessed as having no capacity for development

• clearly this development would contravene this assessment

Parcel B3: its visual sensitivity is also described as resulting from its openness and being overlooked by the
Malvern Hills

This environs study has not been referenced at all in RWE’s planning application and they have not carried out a Landscape Sensitivity and Capacity Assessment as recommended by Malvern Hills National Landscape.

To us it appears that they have tried to set the scope of their own Landscape Visual Impact assessment to exclude the Malvern Hills

Other planning policies relating to the Malvern Hills National Landscape

The implications of the policies summarised here are detailed more fully in Malvern Hills National Landscape’s objection to this planning application which can be viewed by clicking here

National Planning Policy Framework 2024 (NPPF)

Paragraph 189

“scale and extent of development within all these designated areas should be limited, while development within their setting should be sensitively located and designed to avoid or minimise adverse impacts on the designated areas.”

• At 271 acres, we believe that the Monksfield Solar Farm is of industrial scale

Countryside Right of Way Act 2000 (CRoW)

Section 85

“a relevant authority must seek to further the purpose of conserving and enhancing the natural beauty of the area of outstanding natural beauty.”

• It is our understanding that a local planning authority (LPA) has to explicitly address the above duty within the decision making including an explanation of how the LPA considers the duty has been discharged

Malvern Hills AONB Management Plan 2019-24

Policy BDP2

“development in the AONB and its setting should be in accordance with good practice guidance including
that produced by the AONB Partnership”

• We understand that the Malvern Hills AONB Management Plan is a material planning consideration in decision-making on planning applications

Policy BDP8

“Appropriate scale renewable energy schemes should be encouraged where these support the management of core elements of the AONB landscape and/or where they do not
negatively affect the distinctive attributes or special qualities of the AONB.”

• MHNL’s position statement says: ““in relation to large-scale schemes, the MHNL Partnership would not be supportive of solar energy schemes within the MHNL or its setting larger than five hectares in size”.
• Monksfield Solar Farm would be more than 20 times the 5-hectare limit set and on an industrial scale

Policy BDP4

“development proposals that may affect
land in the AONB, including those in its setting, should protect and/or enhance key views and landscape
character. AONB guidance relating to views and development in views should be used where relevant.”

• RWE’s Landscape Visual Impact Assessment 3.5KM study does not encompass the majority of the Malvern Hills National Landscape
• As such, it ignores the views that would be compromised should the developmen proceed
• Clearly viewpoints from the Malvern Hills are from an eleveated position – it would be impossible to mitigate this (except by covering the solar panels which would somewhat take away their point!)
• Further detail is provided in MHNL’s objection to the planning application

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