Representation by Philip Andrew Britton
- Date submitted
- 16 February 2023
- Submitted by
- Members of the public/businesses
Comments upon the proposed development of Mallard Pass Solar Farm. I wish to record my objections to the planning proposal to develop Mallard Pass Solar Farm for the following reasons. 1. Best Most Versatile Farmland. A significant proportion of the proposed solar farm is to be developed on agricultural land that has been classified by your own survey work as best and most versatile (BMV) farm land. Government guidance is that BMV land should not be developed, it should be protected from development and used for food production. BMV land is critical to our country’s food security and as agriculture inevitably moves towards less intensive and lower yielding production systems such as regenerative farming we will need more BMV land to compensate for yields dropping under less intensive production systems. BMV agricultural land can be used to grow most agricultural crops. As a qualified professional agronomist with over 30 years experience in agriculture I would suggest that the soil types in and around this development are quite capable of growing crops beyond the current combineable crops. This land could grow seed potatoes, and with irrigation vegetable and fruit crops. Most crops need to be rotated around farms to prevent a build up of weeds, pests and diseases, taking BMV out of production places more pressure upon the rotations of BMV land elsewhere, which in turn drives up costs and drives down productivity. At a time of global food insecurity through war and climate change it is frankly madness to sacrifice BMV land for generations to come in pursuit of a ‘quick buck’. BMV land is the life blood of our county and of our country. BMV agricultural land should not be wasted on energy production when previously developed land in the locality could be used for this purpose. The BMV agricultural land is only being proposed for use for a solar farm as it is close to a sub-station with spare capacity, it is quite possible to develop other large brownfield sites within the locality and cable the power to the sub-station at Ryhall but this has option has been dismissed out of hand as it would be more costly to develop, this should not be an argument in a planning decision. 2. Flooding. I am very concerned about the potential for the proposed solar farm to increase the speed and severity of flooding in the village of Greatford. The information about flooding that was made available to us in the PEIR during the consultation does not give adequate consideration to the downstream effects that the potential runoff from solar panels, tracks, hard standing and buildings will have upon the speed and severity of flooding in Greatford. The construction of the solar farm will reduce the soil area available to receive rainfall as a circa 50% of the soil in the proposed panel area will be covered by panels, around 232 Ha undercover. The ability of the uncovered land to absorb around double the amount of water running off the panels will be severely compromised as it will inevitably be compacted by construction traffic during the construction of the panel arrays, especially in the winter when the soil will be at field capacity (ie full of water) and any trafficking of the soil in this condition will inevitably cause severe compaction which will significantly will reduce the ability of the soil to absorb water and hold water in the future. Reducing the infiltration rate and water holding capacity of the soil will lead inevitable lead to increased runoff from the site. The runoff will enter the West Glen river which is at present unable to cope with peak flows which causes Greatford to flood at times of prolonged heavy rain. Runoff will also enter drainage channels to the north of Greatford which flow directly to the village, and when over capacity due to prolonged heavy rain overflow into the village causing flooding. In my opinion construction of the panel arrays should not be permitted when the soil is too wet to traffic without causing compaction, according to the PEIR this will be the case for at least 110 days of the year in late autumn, winter and early spring. 3. Traffic. I strongly object to the assertion in the PEIR that the area of the proposed development is a semi-industrial landscape as it has a line of pylons, a railway and small industrial estate present in one of the villages. The proposed site for the solar farm is in a rural landscape that is made up of open fields, hedges, woodland and single trees. As a rural landscape it is served by rural roads which are narrow, winding and in some areas dangerous. Each of the proposed access routes to the proposed development are inadequate for the HGV traffic required to build, service and dismantle the proposed development. An increase in traffic and particularly HGV traffic will cause more accidents than is currently the case I have looked at the publicly available data on the Crashmap website for the village of Essendine which could be at the epicentre of the proposed development and I found that there has been 1 fatal accident, 3 serious accidents and 1 minor accident in the last 5 years. From what I have been able to glean from the PEIR this information was not included when it should have been. I have some experience of the problems that HGV traffic (specifically tipper trucks servicing local quarries) cause for the residents of the area. Most of the local quarries have section 106 routing agreements that require their lorries to use prescribed routes along the A roads of the locality. This is the same approach Mallard Pass will adopt in delivering materials to their site. These agreements simply do not work, HGV drivers follow their satellite navigation devices despite the routing agreements and the drivers are often not aware of routing agreements. 4. Cumulative development. The locality has several other large scale projects that have already been granted development permission. As well as existing quarries there is a new 55Ha quarry to be developed to the east of Greatford, a new water pipeline that will run north to south along the eastern side of the proposed solar farm, and a large housing development between Stamford and Ryhall. These developments will lead to a rise in the HGV traffic and another large development coming on top of those listed will in my view take the local roads beyond their ability to cope with the associated traffic. 4. Community benefits. This proposed development would change for ever the character of our cherished rural landscape, and the amenity that this provides to residents. Local country walks with far reaching views will be changed and the only compensation offered is 2.9 miles of permissive footpath through the low lying and flood susceptible part of the proposed development, and a picnic bench. This represents a derisory offer to compensate the local communities for the loss of the character of the countryside in which we choose to live, and for all of the disruption this development will bring both during its construction, and operation. At the very least I think that Mallard Pass should be offering a large scale, permanent gift for the benefit of the local communities, for example this might be the construction and improvement of a network of local cycle paths to link the affected villages and local towns. 5. Archaeology. I am concerned that if Mallard pass eventually decide to use ground penetrating structures for the solar arrays and other equipment they will disturb or destroy significant archaeology that may be present throughout the proposed site. Significant archaeology has already been found throughout the local area (eg Roman Coffins, Roman Mosaic Floors etc…) and other developments are subject to strict conditions which prohibit ground works until the development area has been properly surveyed and trial trenches dug. It is my opinion that this has not yet been adequately done and I am very concerned that as yet undiscovered artefacts and structures will be destroyed by this development unless more detailed archaeology survey work is done prior to, and during the development. Local and national heritage should be properly preserved and protected as it is with other NSIP developments such as HS2. 6. Wildlife The development site is home to healthy populations of large mammals including deer (Roe, Fallow & Muntjac), foxes, hares and badgers, all of which have territories that currently enable them to roam freely throughout the proposed development site. Fencing off large swathes of these territories for the security of the site will inevitably lead to the loss of these animals from our locality which would further alter the character of the landscape. Populations of other birds, small mammal, invertebrate and plant species will no doubt change as a result of this development, and will no doubt be part of the claimed 10% biodiversity gain, however the large mammals mentioned above will largely be lost and this will be a tragedy for the area. In summary I am opposed to the development of Mallard Pass Solar Farm as it will reduce the nation’s food production capacity, increase the risk of flooding where I live, increase quantity of HGV traffic and associated problems in the area, provide no benefit to the community, damage our archaeological heritage and drive local wildlife away from the area.