Representation by Andrew Whitaker
- Date submitted
- 16 March 2022
- Submitted by
- Members of the public/businesses
I would like to object to the present application due to concerns over the following aspects that I request the Examination evaluate. 1. The scheme would use mainly greenfield agricultural land which is needed to meet the UK’s increasing deficit in home produced food – a strategic UK need at least as pressing as decarbonisation. This is in a region which leads the UK’s development of more efficient and productive agriculture and horticulture practice. So, would the scheme be a net contributor to the UK’s strategic significant infrastructure? (I refer also to the revised Planning Practice Guidance for Low Carbon Energy which says that large scale solar farms should be focussed on previously developed and non-agricultural land, and “best and most versatile land” should not be considered for large scale solar farms - the agricultural land in the proposed scheme is definitely most versatile.) 2. Has the net carbon footprint of the scheme been modelled fully to take account of emissions due to food production overseas and its transportation costs necessary to replace the lost UK food production, (including the potential for high value horticulture crops rather than just the production of low-cost feedstock grain from current practice)? 3. It is not necessary to build large BESS plants on greenfield sites within UK whilst there are brown field sites near any grid substation. It is not clear if the BESS aspect of Sunnica’s proposed scheme is required mainly for storage of temporary excess of the scheme’s own solar generated output , or if the BESS capacity has been enlarged to support an essentially separate non-solar business in the potentially lucrative grid peak demand market which would have no place on greenfield land? Is the large BESS capacity essential to the viability of the scheme? 4. The scheme very correctly takes account of the costs and emissions of decommissioning at the forecast end-of-life. However, the widespread distribution of the solar panel infrastructure over the landscape makes such decommissioning an essential requirement to avoid a possible widespread blight at any time. So, in order to provide the necessary environmental protection, has Solaer SL (Spain), the beneficial owner of Sunnica Ltd and assumed actual developer, agreed to place in escro sufficient up front funds for full decommissioning (or equivalent insurance thereof), and guaranteed this should the scheme be sold on in future – and has this cost been taken into account for scheme viability? Thank you