CONTEXT 176 : JUNE 2023 39 feedback to the DAC and receipt of formal DAC advice, which had first been applied for – with all the commensurate and wide-ranging consultations to statutory bodies – in March 2022. Caroe comments: ‘It was a source of real concern that the regulation processes (both secular and ecclesiastical) did not operate to respond in a timely manner.’ The planning application was submitted in August 2022, and widely publicised. The planning and heritage statement noted Church of England, university and city council climate change ambitions, and pre-application dialogue with Historic England and SPAB. There was consensus that installation of the panels would not harm the fabric of the listed building. ‘The key consideration in terms of impact on the building is whether or not the PV panels would draw the eye to such an extent that they would interfere with one’s ability to understand and enjoy the architectural and historic interest of the building… The chosen panels will not be reflective’ (para 7.7). Nine different viewpoints were agreed with the council. ‘In none of these views would PVs on the roof of the chapel cause any harm to the character and appearance of the conservation area (para 7.33). The statement referenced NPPF and Cambridge Local Plan policies. Significant viewpoints were omitted. The interested public was not told about the trial panels. For the entire time the planning application was ‘live’, the public could not see the trial panels because the chapel roofs were effectively concealed from view, which was not what the college or design team had wanted. There was no method statement for replacing panels (but Oliver Caroe has confirmed that it will be possible to renew panels without needing scaffolding). The statement did not mention the key international standard, BS EN 16883: 2017 ‘Conservation of cultural heritage – Guidelines for improving the energy efficiency of historic buildings’. This includes cultural, as well as environmental, economic and social among the sustainability aspects to be balanced, ‘understanding that they are complementary and mutually dependent, rather than isolated aspects’. The standard provides ‘a systematic procedure to facilitate the best decision in each individual case.’ Historic England (citing NPPF paras 155 and 158) and SPAB challenged the justification for the panels, and the claim that the ‘chosen panels will not be reflective’. Historic England concluded that the proposal would harm the significance of the chapel, and recommended ‘that the application for planning permission should be refused unless the council concluded that the harm the proposed installation would cause would be outweighed by the public benefit that renewable power generation would provide.’ The college’s agents Turley responded: ‘In reality the “harm” to the chapel is imperceptible to all but the most keen or concerned specialist; but the material and public benefit is incalculable… and, in our view, clearly outweighs any harm.’ In SPAB’s view, ‘the level of harm would be less than substantial, and may therefore be acceptable if a clear and convincing justification can be provided’, but ‘we can see no evidence in the application or elsewhere that the college has an adopted and funded sustainability strategy.’ SPAB saw this as a key point as ‘in order to provide the clear and convincing justification of carbon reduction required, a proposal of this type must form part of a building/estate approach.’ The officer report referenced one letter supporting the proposal, and the sustainability officer’s comment: ‘Support… only if… deemed that the renewable energy/sustainability benefits of the scheme outweighed the possible negative impacts on the heritage asset and historic environment.’ Officers concluded ‘that the proposals give rise to less than substantial harm of moderate significance’, that ‘the proposal is therefore contrary to policies 29, 61 and 63 of the Cambridge Local Plan 2018 and the NPPF, paragraphs 199–200 and 202’, and that ‘the magnitude of the public benefit derived from the solar panels in this case does not outweigh the less than substantial harm identified to the heritage interests of the Grade I listed chapel.’ They recommended refusal. The committee amendment sheet included PV panels will cover both north and south-facing slopes. The proposed PV arrays are indicated in blue. 11 12 10 9 8 7 6 5 4 3 2 1 11 12 10 9 8 7 6 5 4 3 2 1 NP I H G F E D C B A SP R Q P O N M L K J G G Scope of Work Roof Plan, 1:200 @A1 3 3 3 3 1 1 2
RkJQdWJsaXNoZXIy MjgyMjA=