Representation by Keith Johnson
- Date submitted
- 24 February 2023
- Submitted by
- Members of the public/businesses
I am against the construction of Mallard Pass Solar Farm. Generation Potential. The Company states that Mallard Pass is expected to generate in the region of 350 megawatts (MW) of renewable energy. They do not state if this is 350MW generated per hour or per day. This figure might well be the case during optimum weather conditions, (350MWh ‘peak’ being the absolute maximum generation capacity of the system at any point in time), however, based on the location of the site relative to the sun, fluctuating daylight availability across the year and cloud cover and other meteorological factors restricting solar penetration to the panels, the system will not consistently be at its generating peak throughput the day. To ‘reliably’ provide 350MW power that the company has promised, they would need a system far in excess of the 350MW Peak to allow for climatic conditions. I own a modest solar array and, from lived experience, during the winter months especially, I cannot achieve anywhere near the 3.7kWh ‘Peak’ the system is capable of generating in optimum conditions. During the winter, I’m lucky if generate a total of between 0.5 - 3 kW total for the entire day during hours of daylight; moreover, rarely does the system provide 3.7kWh peak in winter. Whilst I accept that the Company will be generating on a much larger scale that I am able, it can be argued that the same number of daylight hours and cloud-cover that prevent my system realizing its full potential, will impede the Company’s system in equal measure. In the Mallard Pass Company literature, the company has declared that the expected annual production can be calculated as follows: • 350,000 kW (installed capacity (350 MW x 1,000)) x 8,760 (number of hours in a year) x 0.114 (solar load factor estimated based on East Midlands history plus uplift for newer, more efficient solar panels) = 349,524,000 kWh. Whilst a headline of 350MWh looks impressive on paper, the location of the proposed site in the East Midlands, provides a total of 349,524,000 kW per year, (349.5GW). • This 349.5GW total generation per year, equates to an average of 957.6MW total generation per day, [total annual yield divided by 365], averaging seasonal peaks & troughs of sunlight availability. • Meaning that, whilst the solar farm is advertised as capable of 350MWh Peak, the total daily generation, averaged out (using the Company’s own published calculations of 350,000kW x 0.114 [load factor]) is, only 39.9MW per hour. Thus, I assert that the company’s 350MWh argument is misleading as they will (by their own calculations) only actually provide [an average] 11.4% (39.9MW per hour) of the designed 350MW system per day, over the generating year. I accept that there will be peaks and troughs during the generating year, in the summer, in the summer months, they might well generate a peak output of 350MWh as designed but in the winter, the yield will be woefully below that level. We already know this as, the [East Midlands] solar load factor estimate, averaged out the generation figures to only 11.4% of the 350MWh potential yield to only 39.9MWh, across the generating year. In other words, the company’s proposal is to destroy circa 2100 acres of prime agricultural [food] farmland for [an average] 11.4% benefit to the grid. Not an efficient way to utilize green-field areas. Generation Capacity vs Demand. The Company has stated that ‘the 350 MW figure indicating the potential power output from the site, [they] relate it to potential homes powered. The average UK household consumes approximately 3.76 MWh per year. Therefore, Mallard Pass has the ability to generate the same amount of power each year as would be consumed by approximately 92,000 ‘average’ UK households, in a full 12-month period’. That’s all very well but, when the Solar Farm is fulfilling its peak potential, (during the day, in the summer months), consumer demand is far less than it would be in the winter. The Company have stated their annual generation estimate (349,524,000 kW per year). We know that the site has a design maximum of 350MWh Peak and, in the summer, generation figures will be impressive. However, in the shorter days of the winter, consumers put the lights on for longer, ironically, at the very time that the Solar Array is not generating. In essence, when the Solar Farm is at its peak generating power, consumer demand is less and, when we really need power, the Panels are unable to generate and the system must rely on storage reserves. I recognize that the that connection to the sub-station is at the main North-South mainline thus, once the [yet to be declared] energy storage method, the company will be able to feed surplus power to the Rail Network. Stated Benefit to the Local Community. I find it crass that the company are ‘bigging up’ what they believe to be benefits to the local community. Their stated intent to create: • 112 hectares of new tussocky grassland with wildflowers; • 43 hectares of wildflower grassland with calcareous species; • 13.9 kilometres of new hedgerow planting; • 3.7 hectares of wet woodland planting; • 7.5 kilometres of new treebelt planting; and • 8.1 kilometres of new permissive paths. This sounds impressive but, what the Company has cleverly avoided is the facts and figures surrounding exactly how much grassland, woodland, wild flowed and wildlife habitat they will destroy in the making of the Solar farm in the firs place. Ironic it might be but, the local community currently enjoys over 2100 acres of beautiful unspoilt landscape without any help from Mallard Pass Solar Farm. The Company are, in effect stating that, if they are allowed to destroy prime farming land in the building of the site, they will create open spaces for the local community to enjoy. Paradoxically, if the project does not go ahead, the local community will continue to benefit from the 2100 acres of unpolluted, prime green-belt land they currently enjoy. Country of Hardware Manufacturing. Where will the hardware, (solar panels, inverters and batteries etc), be manufactured? (In the UK or overseas)? If overseas, what systems are in place to ensure the ethical manufacture of the system hardware? We already know that Mallard pass is ‘fronted’ by Windel Energy, (UK), who are partnered with Canadian Solar. There are documented reports of Canadian Solar having shipments of panels from China seized by US Customs, suggesting that there are links between Canadian Solar and Chinese Manufacturing plants. [Redacted] Whilst [Redacted] has vowed to investigate allegations that it used forced labour at its Xinjiang plant, I have little confidence that Canadian Solar will resolve the ongoing matter of their products being manufactured in China under questionable circumstances. Thus, there appears to be a ‘Golden Thread’ from Chinese manufacturing plants, through Canadian Solar and Windel Energy to the Mallard Pass Project. Whilst that might be acceptable in some quarters, to agree this project knowing that the hardware was manufactured in China, will result in the UK Government directly condoning the activities and standards at the Xinjiang plant. Panel Cleaning. As an owner of a Solar Panels, I understand well the requirements of maintenance on the panels. Even on a modest domestic system (<4kWh), cleaning is essential to retain optimum efficiency. Cleaning the panels will require significant amounts of water to remove the dust and debris. I doubt very much if the company intend to use mains supplied water due to the cost (and volume required), thus, the only other sources would be wells drilled into the water-table or from the rivers surrounding and running through the proposed site. Quite apart from the availability of water in the summer necessary for crop growth, the water removed from the rivers for the cleaning process will pick up the dust that, in turn, find its way back into the rivers [as silt]. Water evaporation will only exacerbate the shortage of water available for farming, impacting food production further. As well as dust management, lichen growth on solar panels is a significant problem. Without regular cleaning, lichen establishes itself easily and quickly and, once established, the only option is to clean the panels with chemicals. My concerns on this matter are: • How do the company intent to keep the solar panels clean to ensure optimum efficiency? • How often will the panels be cleaned? • From where will they source water for cleaning? • How much water will they take from the local rivers & water-ways? • Have they calculated the percentage of water-loss through evaporation? • What will be the environmental impact of removing water from the local rivers? • What chemicals will be used to prevent build up or moss and lichen on the panels? • Are the cleaning chemicals bio-degradable/non-toxic? • What will the environmental impact be on the water table when 2100+ acres of solar panels are cleaned using their intended cleaning chemicals? Panel Maintenance. I appreciate that system failure is difficult to predict but, from previous experience of other systems of this size, what is the ‘Mean Time Between Failures’ (MTBF) of the major system components? Has the additional carbon footprint of calculated MTBF and scheduled maintenance been factored into the carbon-offset data for the duration of the working life of the farm? Compulsory Acquisition. I note that the company intends to make a Compulsory Acquisition of parts of the A6121 to allow them to do pretty much what they see fit to the existing utilities infrastructure. Moreover, there will be unacceptable disruption to the locals and all the commuter traffic that transits through Essendine on a daily basis. Land Reparation Costs. When all the land is returned to its present (agricultural) condition at the end of the lease period (cessation of use as a generation installation), will the land be able to produce food crops? (Will the company guarantee all contaminated ground is removed from the site and replaced by virgin (uncontaminated) soil thus allowing a return to agriculture? Construction Traffic. In terms of construction traffic, what mitigation will be put in place to ensure that vehicles that transit from metalled roads to [construction site] fields and back to metalled roads will not transfer mud & debris onto the public highway (presenting a road safety risk to the public)? How does the company intend to mitigate significant levels of construction traffic blocking single-lane rural roads where there are no passing places to allow oncoming traffic to get past easily? For those vehicles transiting from farmland to metaled roads, Will the company ensure all vehicles are thoroughly washed before they use the public highway? Wildlife Management. In areas that have tall fencing surrounding the solar fields, and a public road runs between two such fields, what mitigation will be in place to prevent ’funnelling’ of deer herds onto the public highway (road safety implications)? There is no indication of the type of fencing to be used but, any fencing that is intended to keep humans out, will also keep deer, badgers et all out thus, wildlife, unable to use their traditional pathways, are likely to become a safety hazard to drivers on the public highway.