Representation by Suffolk Wildlife Trust (Suffolk Wildlife Trust)
- Date submitted
- 16 March 2022
- Submitted by
- Non-statutory organisations
Suffolk Wildlife Trust is the only organisation dedicated entirely to the conservation of wildlife and restoration of the natural environment in Suffolk. Our interest in the Sunnica energy farm proposals is in relation to its ecological and wildlife impacts, both in terms of existing wildlife and ecological features and the potential for future ecological restoration and biodiversity recovery, for instance through the establishment of a Nature Recovery Network. Suffolk Wildlife Trust is a member of The Wildlife Trusts, and we share the concerns of our colleagues in the Wildlife Trust for Bedfordshire, Cambridgeshire and Northamptonshire about potential impacts of the scheme across the border in Cambridgeshire. We also work closely with the RSPB across Suffolk and have consulted with their conservation team about the potential impacts on stone curlew, for which a significant area of the Brecks is designated as a Special Protection Area. We have concerns at this stage that within Chapter 8 of the Environmental Statement (ES) several ecological features have been determined as having no potential to experience significant effects as a result of the proposals, without there being sufficient evidence to support this conclusion or sufficient detail or certainty regarding the long-term management of the mitigation and compensation habitat or decommissioning of the site. Additionally, we are concerned that there has been a lack of consideration of cumulative impacts from the proposal with other plans and projects, including local smaller solar farm developments. Large solar farm developments of the scale of the Sunnica scheme are relatively new in England and there is a notable lack of strategic policy to guide the spatial planning for large scale ground-mounted solar arrays – both at the national and local level. There is also a paucity of data from long term scientific studies monitoring the ecological impacts and outcomes of such schemes. Sunnica has the potential to contribute to the body of scientific evidence for the ecological impacts of large-scale solar energy schemes, as well as how their design and ecological management can be improved to maximise environmental gains, including biodiversity gain and improved ecological connectivity. Our areas of interest in relation to the scheme’s impacts include: • Impacts to Chippenham Fen and Snailwell Poor’s Fen SSSI and the Fenland SAC, as well as Snailwell Meadows SSSI. • Impacts to County Wildlife Sites and Local Nature Reserves. • Impacts to stone curlew and land functionally linked to the Breckland SPA. • Impacts to invertebrates which lay their eggs in water, including several nationally rare species. • Impacts to arable flora and the unique Brecks plant communities. • Impacts to wintering birds. • Impacts to breeding birds. • Impacts to bats. • Impacts to badgers. • Impacts to other protected species. • Impacts on ecological connectivity in the wider landscape within which the scheme would be located. • Impacts on chalk streams and other freshwater ecosystems. Mitigation, compensation and enhancement The applicant’s assessment of the likelihood of significant effects from the scheme is highly dependent on the success of the habitat creation within the mitigation and compensation areas, as well as the successful creation of species rich grassland and field margins for arable flora within the solar arrays. Uncertainty surrounding the decommissioning of the site and the retention of the created habitats in perpetuity, also creates doubts about the long-term retention of any benefits resulting from the scheme’s proposed enhancements for wildlife and biodiversity. Our main areas of interest in relation to the mitigation, compensation and decommissioning of the scheme at this stage include: • The compatibility and implications for ecological outcomes of combining archaeological mitigation areas with areas proposed for stone curlew plots, such as ECO1. • Footpath placement in relation to stone curlew mitigation areas and risk of disturbance. • The adequacy of proposed mitigation for stone curlew (considering the possible disturbance effect of the close proximity of the solar panels, on-site buildings, roads and on-site operations), including number and location of nesting plots. • The suitability of proposed seed mixes for the soil types across the scheme area and the Brecks’ unique plant communities and stone-curlew habitat. • The design and management of arable plant areas within the scheme to benefit rare arable plants and characteristic Brecks plant communities. • The deliverability and outcomes of proposals to establish species-rich grassland under solar panels due to issues with shading and management difficulties. • The relationship between proposed mitigation and compensation, and habitat creation for Biodiversity Net Gain (BNG) within the BNG calculations, and additionality of BNG. • Impacts of cabling route through the compensation area ECO4. • Insufficient detail contained in the CEMP. • Uncertainty as to the long-term management of the site (including mitigation areas) after decommissioning. • In light of uncertainty about the successful outcomes of proposed mitigation and compensation, the absence of proposal to adopt an adaptive plan for the implementation and management of these measures. • Uncertainty regarding whether mitigation habitat will be in suitable condition for stone-curlews prior to the start of construction • Uncertainty regarding the avoidance of disturbance to stone-curlews in the mitigation areas during the construction phase • Lack of detail within the OLEMP -The full OEMP should be produced early in order to inform the inspectors decision Monitoring and evaluation For there to be greater certainty as to the effectiveness of mitigation, compensation and enhancement measures it will be necessary for more detailed monitoring of ecological impacts to take place than is currently proposed, to include: • Monitoring of all stone curlew habitat for the duration of the operational phase of the solar farm, to ensure that mitigation and compensation habitats are effective and to enable management works to be planned in order to avoid disturbing active nests during the breeding season. • Monitoring of impacts to invertebrate species in areas adjacent to the Fenland SAC, in order to contribute to the limited evidence base for the potential impacts solar panels have on insects which lay their eggs in water. • Monitoring of breeding and wintering birds for the duration of the operational phase of the solar farm, in order to obtain a more detailed understanding of how breeding and wintering birds use operational solar farms. Proposal for an ecology stakeholder group Considering the significant complexities involved in ensuring the mitigation and compensation habitats created for this proposal meet the required outcomes, we propose that an ecological stakeholder group is set up for the proposal, to advise on the scheme’s design and ongoing management of ecological areas and be reactive to monitoring data and difficulties in habitat establishment on site.