Recommendation 44

HM Government Accepted

45. We are concerned that a lack of clear guidance is leading to unnecessary arguments about food security taking up disproportionate time and resources during examinations. We are concerned that the current guidance on agricultural land classification and land type for solar farms, in paragraphs 2.10.20 to 2.10.26 of EN- 3, is ambiguous, equivocal and seemingly contradictory, particularly in relation to development on BMV agricultural land. There is a compelling need for the National Policy Statements to contain an unequivocal and evidence-based statement of policy in relation to this issue, including the circumstances where BMV agricultural land should or should not be available for development. The NPS already reflects the existing approach in planning policy, which discourages the use of BMV land unless there is an overriding need. It ensures that developers must demonstrate consideration of alternative sites and explain why BMV land is being used, if applicable. The NPS supports planning decisions that consider impacts on food production—while acknowledging that meeting energy security and climate change goals is urgent and of critical importance to the country, and that these goals can be achieved together with maintaining food security for the UK. Government analysis confirms that even in the most ambitious deployment scenarios, the area required for solar projects is very small. The Solar Roadmap sets out how much land we expect to be taken up by solar farms as part of our Clean Power 2030 commitment. Even in ambitious scenarios, we only expect up to 0.4% of total UK land to be occupied. Well-managed solar farms can also coexist with agricultural activity (e.g. grazing and agrivoltaics). Therefore, additional restrictions are not required. Retaining flexibility allows for the balanced delivery of food and energy security. 46. The government should review and amend this guidance to: • The government should reaffirm its commitment to developing solar on developed land, brownfield land, contaminated land and industrial land before agricultural land. The government should also consider innovative ways to develop solar energy without agricultural land. • Clarify more precisely how applicants and decision-makers should assess land type and agricultural land classification, including the use of BMV agricultural land. • Refer explicitly to food security and explain how decision- makers should take this consideration into account. • Clarify when site surveys are necessary to verify agricultural land classification. • Recognise that BMV agricultural land may not all be clustered in one single area but may instead be located in a patchwork of field parcels, mixed with lower-grade land. As set out above, the NPS guidance is clear that wherever possible developers should utilise brownfield, industrial, contaminated, or previously developed land. Where the development of agricultural land is shown to be necessary, lower-quality land should be preferred to higher-quality land. Guidance on the process for assessing agricultural land type is already included in the solar section of EN3 which refers to Defra’s Agricultural Land Classification (ALC) system as the only approved system for grading agricultural quality in England and Wales. The text cross references directly to Natural England’s criteria for assessing land grade. Natural England has also provided more detailed guidance8 on how to use the ALC in planning, including carrying out soil surveys and we have added a reference to this in the NPS to provide greater clarity. 8 https://www.gov.uk/government/publications/agricultural-land-assess-proposals-for- development/guide-to-assessing-development-proposals-on-agricultural-land The Solar Roadmap published in June reaffirms government’s commitment to maintaining planning protections for our best agricultural land. The Roadmap also sets out how alongside ground mount solar, government is planning to drive forward deployment of solar across multifunctional uses of space such as rooftops, car parks and water bodies. 47. The government should review and update