Representation by Boston Borough Council (Boston Borough Council)
- Date submitted
- 5 May 2023
- Submitted by
- Members of the public/businesses
Summary comments. The solar park is located within North Kesteven District and the eastern boundary of the site runs along the Borough / District boundary. The Borough has residents that are about 800m from the site boundary. One dwelling that fronts the A17 will be about 450m from the solar park and will have the cable route pass to its north and east. The impact of the solar park on Boston Borough residents is reduced by distance, any intervening natural and built landscape features and the proposed boundary hedge to the solar park. The direct impact of the solar park on the Borough relates to the cable route to the National Grid substation at Bicker Fen. However, this impact is temporary whilst the route is excavated, the cables installed and the trench re filled, with the agricultural land being restored to agriculture. The Borough has experience of Triton Knoll off shore wind farm and Viking Link Interconnector installing cables across our landscape to connect to the Bicker Fen Substation. We have also had an Anglian Water pipeline installed to link the town of Boston to a point of supply to the north that also crossed our neighbour, East Lindsey District Council. From this experience once the cable work is complete the visual impact of the disturbed route is minimal, relating to marker posts to warn of buried cables and any repaired hedgerow planting whilst it establishes. We have undertaken a high-level review of the submitted documents focussing on topics that directly or indirectly impact the Borough’s residents. We make the following Relevant Representation, which can be summarised as follows: • Boston Borough Council is broadly supportive of the proposals for a variety of reasons including but not limited to: o It contributes to the nation’s transition from hydrocarbons. • Boston Borough Council does however believe there are a series of issues which require further detail, clarification, analysis or discussion, these include but are not limited to: o Fumes from fire – emergency response plan IN DCO; o Trial trenching of grid connection route for archaeology; o Cable route landscaping and BNG; o The height of the boundary hedge of the Solar Park as different documents have different heights. • We have also provided initial comments on the draft DCO, and its schedules, and have suggested some initial changes. We appreciate that the DCO may need to evolve throughout the DCO process as the Applicant seeks to respond to any issues raised. • Cumulative impacts in relation to the cable connection route should be adequately assessed, due to the number of proposed renewable energy proposals seeking to route cable connections to Bicker. Detailed comments. The Borough Council supports the principle of the Heckington Fen Solar Park because: • The Borough is protected by flood defence schemes. Flood risk is increased by sea level rise that is caused by increased temperature melting ice. Increased temperature also thaws permafrost, which releases methane into the atmosphere and causes further warming. This solar park will have less whole life cycle GHG intensity than hydrocarbon fuels (Chapter 13 inset 13.2) and although its individual impact on sea level rise is close to zero it, along with other non-hydrocarbon fuels, represents an appropriate direction of travel. The Borough Council comment below on relevant topic areas: Air Quality. The Environmental Statement in Chapter 15 considers air quality, including dust and emissions from machinery during construction and decommissioning. Air quality during operation of the solar park was scoped out of the ES. It is worth noting that residents of the Borough will not be affected by dust generated when crops are planted or harvested whilst the Solar Park exists on site as the ground will not be disturbed and will be vegetated. The report indicates that dust generated during construction and decommissioning will be controlled by a Construction Environment Management Plan, document 7.7 and a Construction Traffic Management Plan, document 7.10. Emissions at decommissioning are considered in the Decommissioning and Restoration Plan, document 7.9. It is also worth noting that emissions from plant, machinery and vehicles could be very different during decommissioning owing to changes in motive power over the lifetime of the solar park as current Government policy seeks a move away from hydrocarbons. This is alluded to on page 41 of document 7.9. Chapter 18 considers emissions from fire, amongst other issues. The risk is considered to be low and managed by an Energy Storage Management Plan, document 7.11. This is to inform an emergency response plan that is required by the DCO. The wind roses in figures 8 and 9 in Appendix C show that the normal wind direction is from the south west. The report says the direction of the plume depends on wind direction and as a result there is the potential for emissions from a fire to spread across the Borough. As a result the Borough would like more detail on what measures are to be employed in the event of a fire to protect residents from fumes. Chapter 13 Climate change shows that air quality was scoped out of the ES for ‘In Combination Effects’ and explains that the relationship between the two is complicated. Archaeology / Heritage. The Environmental Statement in Chapter 10 says heritage setting assessments, archaeological desk-based assessment and geophysical survey of the Cable Route Corridor for the grid connection has been undertaken. However, unlike the Energy Park site no trial trenching has been undertaken prior to submission. A written Scheme of Investigation for trial trench evaluation of the cable route is provided as document 7.13 and shows 240 trenches over the cable route. The Borough Council would like to know when this work is to be undertaken. Biodiversity. The Environmental Statement in Chapter 8 explains the evidence work that has been undertaken on the solar park and the cable route. The majority of the land is considered to be of low conservation value. Biodiversity net gain is to be achieved on the Energy Park. What can be achieved along the cable route to link the new habitat on the solar park with landscaping around the Bicker Fen National Grid, Triton Knoll and Viking Link substations plus mitigation of impacts on the South Forty Foot Drain Local Wildlife Site? Flood Risk. The Environmental Statement in Chapter 9 says the main source of Tidal/Fluvial flood risk to the Energy Park is the Head Dike and Skerth Drain. The cable route and the Bicker Fen Substation risk is from the South Forty Foot Drain. Surface water flood risk is mostly very low for the Energy Park, the cable route and the substation with only localized areas at high, medium and low risk. Reservoir flooding is limited in normal circumstances and rises with flooding from rivers. The site does not contain an aquifer. Climate change will alter the distribution of water received over time with drier summers, wetter winters and an increase in intense rainfall. Wind speeds are likely to increase overtime as will the frequency of winter storms. The impact will be felt by ground and surface water drainage but the sensitivity is classified as no worse than medium in half of the assets, the others being low and negligible. It is concluded that potential effects arising from construction of the Proposed Development are likely to be localized, temporary and controlled by embedded mitigation measures, i.e. the Construction Environmental Management Plan, Document 7.7. With the implementation of embedded mitigation measures, the residual effects associated with operation of the Energy Park are Negligible and Not Significant. The electrical connection to the National Grid Bicker Fen Substation comprises an underground cable that would not give rise to impacts upon hydrology, hydrogeology, flood risk and drainage during the operational phase. As such the proposal does not increase flood risk to residents of the Borough. Highways. The Environmental Statement in chapter 14 provides information on HGV, abnormal loads and construction staff. It also indicates mini buses could be used to reduce the amount of vehicle movements from construction staff. It concludes the construction phase traffic would add 89 vehicle, including 29 HGV, two way traffic. This is less than 1% of the baseline figures and as a consequence is considered to be of negligible significance. It will be managed by a Construction Traffic Management Plan, document 7.10. This includes a left in and left out policy, which has been used for the Triton Knoll and Viking Link projects. As such the proposal has minimal traffic impact on residents of the Borough Residential amenity. The Environmental Statement in chapter 6, chapter 7, chapter 12 and chapter 17 consider landscape and residential visual amenity, noise and vibration plus glint and glare. In Chapter 6 landscape and visual impact is considered. This is concerned more with landscape character and less on residential amenity. Changes to landscape character are mitigated by the scale of the landscape and consequential impact on residential amenity by the distance between the Solar Park and the residential properties in the Borough. As a result the outlook from these properties and the consequent impact on residential amenity is mitigated by the expansive nature of the location, distance between the Solar Park and the dwelling and any intervening landscape features. In figure 6.5a viewpoints 7, 8, 9, 10, 11, 12, 13, 14, 15, 22 and 23 are within the Borough. Viewpoints 7, 9 -13 were not taken for detailed assessment and have no significant effects. For viewpoint 8 the energy (solar) park had no significant effect. For viewpoint 14 and 15 the grid connection has a major significant short term and temporary effect. For viewpoints 22 and 23 the energy (solar) park has no significant effect. Therefore, the two viewpoints that will experience a significant effect will do so for a temporary period as the cable is installed. The locality has experienced similar impacts when the Triton Knoll and Viking Link underground cables were installed. In Chapter 7 paragraph 7.4.3 contains a list of properties that are judged to be visually effected by the proposed development to a major adverse (significant) extent. None are within Boston Borough. The chapter lists mitigation that will reduce the impact on the dwellings in North Kesteven. These are design changes that increase physical separation between dwellings and elements of the solar park infrastructure, reducing the height of the panels and also the location of the substation works at Bicker Fen is well landscaped. The design changes to the solar park can also help Boston Borough Residents. In chapter 12 Noise and Vibration are considered. Sources of noise and vibration arise from the construction of the solar park supporting frames, access road construction, horizontal direct drilling and operational plant noise. The impact of these sources of disturbance can be reduced by distance between the source and the receptor dwelling and the type of construction method used. As such there are quieter alternatives to horizontal direct drilling as well as screening techniques and avoiding overnight work. Overnight working is sometimes unavoidable owing to the nature of the process. Plant noise can be reduced by designing the solar park such that the plant is located away from dwellings, aided by the choice of equipment that have lower noise outputs. A number of dwellings are quoted in the report and the supporting Appendix 12.2: Noise Modelling. Some are within Boston Borough but overall the reports conclude the effects are negligible to minor and not significant. The impacts can be managed through the Construction Environment Management Plan, document 7.7 and a Construction Traffic Management Plan, document 7.10. In chapter 17 the impact of glint or glare on residents of the Borough relates to Boston Aerodrome, users of the A1121, part of the A17 and living near to the solar park. The highways have the potential for Significant effect prior to mitigation. This becomes Not Significant after mitigation. For residential impact there are a number of observation points that have been used to assess impact. Those in Boston Borough are OP24 to OP34. The impact on OP24 to OP28 are Not Significant. The impact on OP29 to OP34 is Significant prior to mitigation and Not Significant after mitigation. Mitigation includes fixed panels, i.e. they do not track the sun, and so properties to the north are protected owing to the panels facing south. Another mitigation feature is the planting of a boundary hedge that according to Fig 2.1 will be maintained at 3m wide and 4m high. Finally the height, orientation and angle of the panels has been adjusted to mitigate glint or glare. To conclude the impact of the solar park on residents is unlikely to be significant, or will not be significant once various mitigation measures are in place. The height of the hedge is quoted differently in different documents. 4m on Fig 2.1 and 3m – 3.5m with sections at 5m in para 7.5.2 of Chapter 7. This needs clarifying. Cumulative Impacts There are a number of solar parks proposed in proximity to the site, including Springwell Solar Park in North Kesteven, Bicker Solar Farm, Roman Bank Solar Park in South Holland DC, Beacon Fen and Temple Oaks. Cumulative impacts in terms of landscape, agricultural land, visual impact, archaeology and flood risk should be taken into account. In addition, this proposal seeks to connect to the National Grid via Bicker substation. There are a number of other schemes that also seek to connect to this point and cumulative impacts on residents, landscape, biodiversity and flood risk should be taken into account. Existing projects proposing to connect to Bicker include Temple Oaks at RAF Folkingham (SKDC) and Beacon Fen also at Heckington. Socio-Economic impacts: Chapter 11 considers the impact on employment, economic contribution, accommodation demand and business rates during construction, operation and decommissioning. In respect of the construction phase, the assessment indicates that the Proposed Development will have the following temporary effects: • 400 peak on-site construction jobs, with an average of 150 on-site construction jobs, over the 30-month construction programme. • £175million of gross value added over the 30-month construction programme. • Increase (up to 200 construction) in demand on Serviced and Non-Serviced Accommodation in North Kesteven. In respect of the operational phase, the assessment indicates that the Proposed Development will have the following effects: • 5 direct additional jobs in the North Kesteven economy. • £627,000 of gross value added per annum or £13.9million over 40-year lifespan of the project (present value). • Business rates £1.3million per annum and £29.3million over the 40-year project lifespan (present value). In respect of the decommissioning phase, the assessment indicates that the Proposed Development will have the following temporary effects: • 200 peak on-site construction jobs over the 18-month decommissioning programme. • £52.5million of gross value added over the 18-month decommissioning programme. • Increase (up to 100 construction) in demand on Serviced and Non-Serviced Accommodation in North Kesteven. Overall, there are beneficial effects in terms of employment, economic contribution, and business rates in all relevant phases of development. Notably, beneficial economic contribution effects are considered to be significant in the construction and decommissioning phases, and beneficial business rates effects are considered to be significant in the operational phase. Effects relating to accommodation demands in the construction and decommissioning phases are adverse but not significant. DCO: On the DCO the Borough Council raises the following comments. These include changes to action our comments. Schedules 4 and 7 Lincolnshire County Council is Highway Authority. We consider they should be listed rather than Boston Borough Council. END