Representation by James Williams
- Date submitted
- 18 February 2023
- Submitted by
- Members of the public/businesses
Mallard Pass Solar Farm – objection I write to register opposition to, and concern about, the Mallard Pass Solar Farm proposal. I am an affected resident, and wish to be kept informed as an interested party. Professionally I am an ecologist with over 30 years experience working at the national and international level in the nature conservation sector. I therefore appreciate the balance to be struck between strategic projects and local concerns. However, based on information currently available, my judgement is that this is not the right project in the right place at the right time. I have a number of concerns and questions, detailed below, which can be summarised under the following headings: 1. Public safety, 2. Flooding, 3. Appropriate use of agricultural land, 4. Scale and efficiency, 5. Biodiversity protection, 6. Appropriate mitigation, 7. Lifecycle impacts. I raised many questions in my response to the consultations run by Mallard Pass. Many of these have not been answered by the impact report, so I reiterate them here. In many cases, when I attended the public meeting in Greatford, concerns by myself or others were answered glibly along the lines of: there will be a plan for that. I have concerns about the adequacy and enforcement of the plans submitted. For example, it isn’t clear how any elements of the plan(s) will be enforced – will there be penalties for contractors – either at a company level or for individuals as a result failure to follow the measures in those plans? Without such enforcement and penalties any plans are meaningless words on paper. 1. Public safety Given the open nature and topography of the land to be covered with solar panels, it is likely that there will be implications for public safety with respect to reflections from panels causing dangers for those driving on local roads. This could potentially occur both during the day and at night with reflections from the sun, or from vehicle headlights. It is not clear how shielding might be used, or how the location of panels might mitigate this danger. The shielding which appear to be proposed is in the form of hedges – these will take time to grow, and unless they are maintained much higher than many hedges in the area currently are, will not shield panels in the middle of a field from view. 2. Flooding The area to be developed, and surrounding areas, are low-lying. There have been significant floods to local rivers in the area in recent years. There are properties outside the project area that may be affected by drainage from the project area. There appear to be significant risks from compaction of land as a result of construction leading to increased run-off, and therefore increased risk of flooding. This is not adequately addressed in the impact report. 3. Appropriate use of agricultural land A significant proportion of the land which is proposed to be developed is grade 3a and above agricultural land. Development of this land is directly contrary to the Government’s agricultural and food security policies. Given the UK’s reliance on imports of food to feed our population, and recently published statistics about the UK’s impacts on the rest of the world (see https://jncc.gov.uk/our-work/ukbi-a4-global-biodiversity-impact/ including the associated technical report), and the WWF report titled “Riskier Business” [Redacted] it is clear that the UK needs all the agricultural land it has to produce food, regardless of agricultural grade. There is therefore a key strategic issue about how energy production and food production are optimised, without negatively impacting on each other. Taking a large area of agricultural land out of production to produce energy is not an appropriate decision. It is not acceptable that the project continues to propose development of best and most versatile agricultural land. I consider the project should cease on these grounds, let alone the other concerns expressed here. 4. Scale and efficiency The scale of the proposal is the largest in the UK to date. That begs questions around how the project will work in practice, and whether implementation of such a proposal by a firm with no operational experience is realistic. The proposed solar farm claims to produce enough energy sufficient for around 92,000 homes. But, given the scale of the project, that energy appears to be being produced at a low efficiency. In addition, the location of the project is be predicated on the location of the substation at Ryhall. This seems to be an artificial reason for location; if the proponents are serious about solar energy production in the public good they would identify the best location, taking account of a multiplicity of factors, and then if necessary install a substation of their own. Furthermore, it is becoming clearer that the proponents may not actually undertake the development themselves. This begs many questions about how the conditions that may be attached to any permission will be passed to any other contractor, and whether/how the proposal may be amended post-permission by another developer. This is very high risk for residents, who may find they have a completely different proposal unfolding in front of them that that which is initially proposed and consented. If the proponents aren’t prepared to implement their proposal they should cease and desist forthwith. 5. Biodiversity protection The UK has experienced considerable losses of biodiversity including for Priority Species, Birds, Butterflies, Plants and Pollinators as recorded in the Governments own Official Statistics (see the UK Biodiversity indicators https://jncc.gov.uk/our-work/uk-biodiversity-indicators-2022/ and England biodiversity indicators https://www.gov.uk/government/statistics/england-biodiversity-indicators). The most recent State of Nature report [Redacted] similarly records adverse changes to the UK’s environment. The world, UK included, is facing twin biodiversity and climate change crises. Given these past changes, it is important that local projects do not lead to further biodiversity loss, nor while addressing one part of the twin crisis, cause issues elsewhere. Within the project area a number of European and nationally protected species are extremely likely to occur. These include, but are not limited to: great crested newts (I see these annually in my garden pond in Braceborough, together with smooth newts, so they will be in the landscape), harvest mice red kites, hares, bats, badgers, deer, and a variety of flora (also recorded in Braceborough),. The impact report relies heavily on local environmental record data, but it is well known that such records, particularly for commoner species, are often out-of-date or inadequate. Based on my knowledge of wildlife in the area, and after reviewing the impact report, I consider that insufficient survey work has been undertaken, and that it has not been appropriately focussed. l observe that there has been a lack of survey for bats, plus insufficient survey for newts, reptiles and harvest mice. Based on the results provided in the impact assessment, decisions about the proposal are therefore could be made based on inadequate or insufficient information. This is especially the case for bats; the report notes possible trees for bats, but has not actually surveyed for them. If it is necessary to fell some trees or hedgerows for project access how will the project determine if it will disturb a bat roost or bird nest, and therefore that it is legal to undertake such felling? 6. Appropriate mitigation The diagram for the project area notes areas for mitigation and proposals for biodiversity net gain. However, it is not clear what sorts of mitigation will be proposed, how long these will last, or how net gain might be achieved. Given the time needed to develop mature grassland, or woodland, it is important that mitigation is considered on ecological rather than project timescales. At the project meeting in Greatford I was informed that any mitigation would only be for the life-cycle of the project. This is inadequate – there may (depending on how mitigation is implemented) be a biodiversity gain for part of the project lifecycle, but unless habitat creation / restoration is to continue for a timespan which is ecologically meaningful, any mitigation is transitory and will not address the biodiversity losses noted in section 5 above. For woodlands and hedgerows it is essential that consideration is given not just to their establishment but also to their maintenance. A diverse mix of native species is likely to provide the best opportunities for biodiversity, and wide, thick hedges and treelines are important – in effect the creation of a thicket is a better option than a linear feature, and will also provide better screening. For meadows there is no information available on the seed mixes that might be used and whether these will have appropriate genetic diversity – using local source material rather than that brought in from afar. See the Flora Locale project [Redacted] for the sorts of issues that lack of consideration of genetic diversity raises. There are potentially animal welfare issues in putting up a long fence around the project – in that it will interfere with the movement of animals across what is currently an open landscape. Six foot high fencing will not exclude roe deer. The location of gates / gaps for badgers and other animals needs to be carefully planned to fit with existing routes (current project details do not show how these issues will be addressed). The fragmentation of the landscape caused by the project is likely to require different mitigation for different species – such as otters, deer, badgers and hares. Given the timescale for the project it is extremely unlikely that all species will be excluded from the project area, or be kept out for the 40 years of the project. It is therefore imperative that issues of movement of animals through the project area are addressed. 7. Lifecycle impacts The project in envisaged to have a 40 year timespan. That implies that there will be impacts on local communities throughout the project lifecycle, including through establishment, running the project, and decommissioning. It is not clear how traffic will be managed in each of these stages – the impact report states there will be a plan. But it does not provide details; it is therefore impossible to assess if the plan is adequate, nor how it will be enforced. The local wildlife sites which are roadside verges are extremely vulnerable to traffic, e.g. lorries pulling off the road to allow other traffic to pass. It is therefore essential that the plans and their implementation stop construction, operational or decommissioning traffic from damaging the verges.