The Clinton Estate had secured planning permission for a large battery storage area within a former quarry on the registered Woodbury Common. The former quarry was used for commercial purposes and, although registered as common land, it did not fulfil any of the usual functions of a common. The Estate proposed deregistration of the former quarry, to allow the development to proceed, and offered a larger area of land contiguous with the wider Common as a replacement. The Estate, through pre-application engagement, secured the support of the Open Spaces Society and no objection from Natural England. The Estate offered by way of a s.106 planning obligation, to provide public access to the replacement land from the date the order was made, so as to avoid the delay to formalising access until access plans were updated. The Estate also secured consent for works on the common to deliver underground cabling to the battery storage compound and for a bat hibernaculum.

Douglas Edwards KC was instructed for the Clinton Estate by Jade Luys of Clarke Willmott.