A scheme for a solar farm on high quality agricultural land in Devon (DCS Number 200-003-894) failed the sequential test, the inspector not being satisfied that brownfield opportunities including rooftop schemes had been properly looked at. She recognised that the NPPF and PPG on solar farms did not expressly refer to the need to undertake a sequential test but reasoned that it was self-evident that in requiring an assessment as to whether land of lower quality was available a review of the quality of the land which was available needed to be undertaken. Given the ministerial statement of March 2015 which set out a need for developers to provide a compelling justification for schemes involving high quality land she decided that she had no alternative but to dismiss the appeal.
The second case concerned the orientation of roof-mounted solar panels on 20 houses in Nottinghamshire (DCS Number 400-008-261). The Carbon Trust advises that ideally solar panels should be orientated so that they face within 45˚ of south. The council was concerned that whilst five of the houses would adhere to this advice the remaining 15 would be orientated east-west. The inspector pointed out that if all the houses were orientated within 45˚ of south it would not be possible to get so many houses on the site. Anyway, the panels on west-facing roof slopes would generate electricity in the late afternoon and early evening, when most needed. He decided that the layout and orientation of the houses would provide very good levels of renewable energy generation whilst optimising the development potential of the site.
The first case does seem to set the bar very high. Pity the developer who must ask anyone with a roof in the area if there is any chance of putting solar panels on it.
DCP section 26.536 refers.