R (on the application of Wye Valley Action Association Ltd) v Herefordshire Council [2009] EWHC 3428 (Admin), [2010] All ER (D) 44 (Jan)
In the context of environmental impact assessment development, “natural” meant untouched by man. “Semi-natural land” was land where there had been some interference with the landscape, but the natural qualities which preceded or continued alongside man’s activities were still clearly and obviously evident in the natural environmental capital of the area.
Man’s intervention in such “semi-natural” areas might well be evident, but it would not have been spoilt, and might even have complemented, the natural qualities which gave the area its environment value. Those matters could be gauged by the statutory and other designations to which the land might have been made subject.
