Freshford Ce Primary School, High Street, Freshford

We acknowledge and support the movements and policies driving proposals for green energy generation, including the UK and B&NES declaration of Climate Emergency, Net Zero by 2050, the NPPF and B&NES Core Strategy Policies D1 and CP1. Bath Preservation Trust actively wishes to respond positively to these policies while continuing to emphasise the need and value for the protection of the historic environment and areas of special interest.

The special interest of Freshford Village is characterised by its many traditional unlisted and listed buildings, traditional building materials encapsulated in its designation as a Conservation Area, and its landscape setting within the Cotswold AONB and greenbelt.

We recognise Freshford School is a traditional building of local interest and features in the photographs of ‘unlisted buildings of merit’ in the village conservation area appraisal; although not listed it can be considered as a non-designated heritage asset. Therefore the assessment of this planning application needs to take account of the extent of harm, if any, to the significance of this heritage asset.

We agree with the approach of Historic England and others to encourage a ‘Whole Building’ approach to energy efficiency, and would welcome applications for energy generation being supported by a whole building energy strategy with a description of other measures which have been or are being considered to cut energy consumption and reduce energy loss.

We recognise that efforts have been made to improve the design and appearance of solar PV since the last application. The matt black framing and mounting system and non- reflective material and the arrangement of the panels is welcomed as a more sensitive approach. Better symmetry and alignment of the panels helps to minimise the visual impact of the panels. It is important that retrofitted solar PV is in harmony with the building on which it is located and maintains the character of our historic landscapes.
The effect of solar PV on the prominent rear roof slope would result in a degree of change to the character and appearance of the conservation area, and the traditional village roofscape, especially in the view from the Tyning junction with High Street.

While there is no permanent impact on the fabric of the roof covering the solar PV would introduce a new material and structure that would have an impact on appearance of a large area of traditional slate roof, and affect its harmonious relationship with the prevailing palette of traditional materials.
Whether or not this change amounts to harm is a matter of judgement and debate. The panels are sited on the roof slope facing the rural surroundings and would be visible in rural views of the village from the AONB and greenbelt, and particularly prominent in closer views. Given the siting on the roofscape within a village scene we do not consider that the solar PV will not have more than a minor adverse impact on the landscape character, scenic beauty and visual appearance of the AONB.

Our committee after much consideration has concluded in their assessment that if there is harm, the degree of harm is less than substantial.

In accordance with NPPF solar panels on a roof are not considered to be inappropriate development in the greenbelt that would harm openness or conflict with the purposes of the greenbelt, they fall into paragraph 145 c “the extension or alteration of a building provided that it does not result in disproportionate additions over and above the size of the original building”. Paragraph 147, though seemingly aimed at inappropriate development such as solar farms or wind turbines, states; “When located in the Green Belt, elements of many renewable energy projects will comprise inappropriate development. In such cases developers will need to demonstrate very special circumstances if projects are to proceed. Such very special circumstances may include the wider environmental benefits associated with increased production of energy from renewable sources.”

The potential benefits of the scheme would make a small contribution towards renewable energy generation and assist in tackling climate change. They also present an opportunity to engage with future generations about climate and energy efficiency. In the context of Climate Emergency we recognise the environmental gains as wider public benefits, the local benefits brought about by providing green energy for the school, a public building, and furthermore the opportunity for continued environmental education on site all mitigate the less than substantial harm to both heritage assets and landscape character.