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Representation by Cambridgeshire and Peterborough Combined Authority (Cambridgeshire and Peterborough Combined Authority)

Date submitted
17 March 2022
Submitted by
Local authorities
  1. Agricultural Land Value is incorrectly considered The Combined Authority’s Economic Strategy recognises the value that its agricultural sector provides to the national economy and food security. The proposed development would take a significant area of land in Cambridgeshire out of agricultural production for a minimum of 40 years. • The applicant has concluded that the majority of land is not within the Agricultural Land Classification (ALC) of Grades 1 to 3a, and has attached little material weight to national and local planning policies to protect the Best and Most Versatile Land. • The applicant’s supporting evidence shows their ALC assessment has downgraded the land due to the need for irrigation. This downgrade relies on an email dated 2019 from Natural England that references the now superseded Planning Policy Guidance Note PPG7. • Current government guidance to planning authorities and developers on undertaking new ALC surveys refers to the 1988 Agricultural Land Classification of England and Wales Revised Criteria for grading the quality of agricultural land • Natural England’s currently available technical document, Agricultural Land Classification: protecting the best and most versatile agricultural land - TIN049 also cites the 1988 methodology as the appropriate methodology. • The 1988 methodology clearly states: “Irrigation can significantly enhance the potential of agricultural land, especially in drier areas, and should therefore be taken into account in ALC grading where it is current or recent practice”. • The applicant’s assessment states: “All of the farm businesses can be described as predominantly arable dry land units that include high margin irrigated crops (e.g. potato, sugar beet, onion) among rotations of cereals.” It is evidenced that irrigation is a current practice. • The ALC assessment is therefore not consistent with the 1988 methodology. The potential loss of Best and Most Versatile Land has not been correctly considered in the application. The development would have a significant adverse loss of Best and Most Versatile Land. 2. Battery Electric Storage System is disproportionate • The BESS takes additional agricultural land out of production. It is included as associated development that is described as having a direct relationship with the solar farm. The application does not provide certainty that the BESS is appropriately sized to support the storage of electricity from the solar panels for use at different times, or is sized to operate at a large scale as a recipient of other electricity. If the latter then this additional capacity as an energy trading operation would be unconnected to the need of the solar farm itself and is providing unnecessary loss of agricultural land. 3. Public consultation inadequate • Residents in the area have raised significant concerns over the appropriateness of the public consultation. Local authorities have, at best, indicated that the consultation only met the minimum required standard. This is clearly inappropriate for such a significant scheme covering a large rural area and impacting on multiple communities. The Combined Authority called for the scheme to be “exemplary in avoiding detrimental impacts”. Without proper information on the scheme (with several aspects still left to subsequent obligations) this is not the case.