Through the looking-glass: Planning permission granted on appeal for BESS at Culham, Oxford
On 22 July 2025 the Planning Inspectorate (“PINS”) allowed an appeal against the refusal of South Oxfordshire District Council (the “Council”) to grant planning permission for a 40-year, 500 MW, Battery Energy Storage System (“BESS”), adjacent to Culham Science Centre, Oxford (“CSC”). The decision underscores the weight now accorded to large-scale energy storage in achieving the United Kingdom’s net-zero objectives, while also illustrating how further material planning considerations, such as heritage and Green Belt, are balanced.
Background
The application, submitted in May 2024, was refused by the Council on 8 August 2024 on the following grounds:
- the development constituted inappropriate development in the Green Belt;
- the development would result in significant adverse effects on neighbouring landscape;
- the development would encroach into the Nuneham Courtaney Grade 1 Registered Park and Garden (the “RPG”) and would result in significant adverse impacts to the designated heritage asset, and the setting of the RPG; and
- there would be an unjustifiable loss of Best and Most Versatile (“BMV”) land for the lifetime of the proposed development.
Culham Energy Storage Ltd lodged an appeal in December 2024, leading to a public inquiry in June 2025.
Demand for renewable energy
Central to the decision of the Inspector was the “urgent need” for electrical storage to support the growth of renewable energy generation to meet the Government’s 2050 net zero target. Both parties agreed on the critical role of BESS in enabling the transition to a low-carbon energy system. The Inspector cited that the Overarching National Policy Statement for Energy (EN-1), which recognises that storage is essential to achieving net zero and providing flexibility to the energy system.
The Inspector was unequivocal: “The world is in crisis; a climate crisis caused by carbon emissions.” In this context, the BESS was found to be a critical element in addressing both climate change and energy security.
Additionally, the site’s proximity to the CSC, a leading international science hub and home to the United Kingdom Atomic Energy Authority, was also noted. While the Inspector gave only minor weight to the benefits for the skilled workforce at the CSC, the location was considered appropriate, particularly as the CSC itself has been removed from the Green Belt in recognition of its strategic importance.
Heritage
The most contentious issue was the impact of the RPG, Grade I listed landscape of international significance, with historical associations to Lancelot “Capability” Brown and Lewis Carroll (purportedly serving as the inspiration behind Lewis Carroll’s ’Alice in Wonderland’ novels).
The Inspector accepted that the BESS would cause "less than substantial harm" to the setting and significance of the RPG, but found this harm to be at the low end of the scale. The southern part of the RPG where the BESS development would be sited, has already suffered from post-war decline, conversion to arable land, and the intrusion of power lines and industrial features.
Importantly, the Inspector found that the scheme’s landscaping proposals - particularly the partial reversion of arable land to parkland and the restoration of tree belts - would deliver permanent heritage benefits. While not a fully authentic restoration, these measures were seen as a positive enhancement to the RPG’s character, in line with aspirations set out in the Nuneham Estate Parkland Management Plan. The Inspector concluded that the temporary harm to the RPG was outweighed by these permanent improvements.
Green Belt and Landscape Impact
The Inspector undertook a detailed analysis of Green Belt policy, concluding that the site constituted “Grey Belt” land i.e. land within the Green Belt that does not strongly contribute to its purposes and is not subject to overriding heritage constraints. The BESS was found not to fundamentally undermine the purposes of the Green Belt, particularly given its adjacency to the CSC and the scale of other planned developments in the area.
In terms of landscape character, the Inspector acknowledged that the BESS would have a moderate adverse effect initially, diminishing to minor once screening vegetation is established. The landscape in this location is already compromised by industrial elements, and the Inspector did not consider it to be a “valued landscape” for the purposes of the National Planning Policy Framework (“NPPF”).
Best and Most Versatile (“BMV”) Land
Whilst the development would remove up to five hectares of BMV land for forty years, the Inspector concluded that the moderate/minor harm was far outweighed by the urgent need for the BESS and the wider public benefits associated with renewable energy infrastructure. The Inspector also noted that the land could be restored to its former condition following decommissioning.
Planning Balance and Conclusion
The decision emphasises the increasing weight being given to renewable energy and climate change objectives in planning decisions. Paragraph 161 of the NPPF requires the planning system to support the transition to net zero by 2050, and that significant weight must be given to the benefits of renewable and low carbon energy generation. The Inspector concluded that the benefits of the BESS – its contributions to net zero, energy security, and heritage enhancement – far outweighed the limited and temporary harms to matters such as heritage, landscape and agricultural land.
Wider Implications
The case has wider significance, demonstrating the nuanced approach required to reconcile heritage and conservation with the pressing need for a clean energy future. It also reinforces the importance of robust evidence and mitigation in addressing heritage and landscape concerns. Developers can take confidence that, where the need for renewable energy infrastructure is clear and harm is limited or can be mitigated, planning policy is, and planning decisions are, increasingly supportive. Where robust justification exists, the benefits of renewable energy projects - especially those critical to national policy objectives - will be given substantial weight, even in sensitive locations. However, the decision also makes clear that heritage impacts must be properly assessed and mitigated, and that respect for the historic environment remains a core part of the planning process.
This article was co-authored by Sophie Lee, Solicitor Apprentice at CMS.
