Representation by Kerry Anne Hockham
- Date submitted
- 26 February 2023
- Submitted by
- Members of the public/businesses
I have a number of objections to the proposed Mallard Pass Solar Project development and would like to raise a number of points for consideration. While energy security is essential, so is food security. No amount of energy will help your constituents if we have no food to eat. We all understand that renewable energy is the direction the planet needs to go. No one is arguing with that. If the proposal was for silent angels, I.e. wind turbines, I would have no complaint or issue as the impact on the surrounding countryside and constituents would be minimal and the arable fields would still be used for good food production. LOCATION AND SIZE OF DEVELOPMENT The proposed development originally covered 906 hectares, which is approximately equivalent to 1700 football fields. Despite, Mallard Pass Solar Project having “reduced“ to a 2,105 acre site, equivalent to 1300 football fields, the external footprint is effectively the same as they have removed some Highway areas and all the existing site woodland areas from their responsibility and calculations. Yet despite this “reduction”, Mallard Pass Solar Project, still claim they will produce the same amount of power. The Project will stretch some 4.2 miles from end to end and will have a perimeter of 25 miles. It will directly impact up to 18 villages and constituents within a 3 mile radius. Many of these Villages are designated as Conservation. It will also be less than 1 mile from the historic town of Stamford, which in 1967, became the first Conservation town in the UK, and is also the home of Burghley House, an excellent example of Elizabethan Tudor architecture. Constituents who live in the area would be horrified to hear the village of Essendine being described as having a large ‘industrial’ footprint. There is a small area located in Essendine that has a few very small industrial units. However it needs to be stressed, these are located in one small area, unable to be seen from the roads whether you are driving or walking through the village. In fact, the only way to “see” these units is by using Google Earth! The reality is Mallard Pass Solar Project are wanting to install an industrial scale facility of thousands of black glass panels with associated buildings, fencing, CCTV, by destroying and digging up agricultural fields used for arable crops and woodland. Then, after covering the fields with black glass they wish to replant the woodland claiming they have increased the biodiversity. They are not doing this for the benefit or sole purpose of helping the UK move towards net zero but only to add to their bottom line and profit. Mallard Pass are not concerned their Project will be clearly seen by the naked eye of anyone living in the area from their kitchen window or anyone driving through the area, just by the sheer nature of the topography where the hills are higher than the roads you drive on. This area is currently 100% greenfield rural landscape and community of rolling countryside. The original justification and ‘selling the idea’ to your constituents for Mallard Pass Solar Project wanting to locate in this area was based on the location of the Ryhall substation. Mallard Pass stated that as this was already in situ, a substation would not be required. The substation they refer to was installed to support the electrification of the East Coast Railway. The East Coast Main line is 393 miles long and has land either side, effectively designated brownfield, which if developed would provide adequate land for solar development without further impacting any of the surrounding land. In theory it would only take a 32 metre depth either side of the entire track to provide the same area in hectares that Mallard Pass wish to remove from agricultural use. Such “brownfield development” would have much less impact than the proposed development. However, this type of development would not be attractive to Mallard Pass Solar Project as it would require them to ‘do a bit more work’ and does not fit in with their ‘quick buck, sell & move on, business plan’, which they have followed elsewhere in the world. Lincolnshire also, currently has many disused or partially disused RAF bases, some of which have substations. These could also be utilized, especially as despite the existence of a substation in Ryhall, Mallard Pass Solar Project quietly included a ‘new substation to also be installed’ after the public consultation had ended. Clearly the need for the Ryhall substation was a red herring as per their decision for location, and was more likely based on who could be influenced on selling/leasing land that does not require Mallard Pass to do any cleanup of brownfield first. VISUAL IMPACT AND LOSS OF SOCIAL AMENITY The development will fundamentally and permanently change the enjoyment of the countryside by constituents and the extensive wildlife in the area, despite Mallard Pass claiming they will “improve on Mother Nature”. Public Rights of Way may be moved or closed during the construction phase which will take several years. Attempts to mitigate the damage caused during and after the construction work will take decades to only partially cover up the impact on the landscape. It will be ‘Mother Nature’ who will actually rectify the damage to the environment decades later, not Mallard Pass Solar Project. While Mallard Pass may suggest they will install 5 miles of permissive routes through their Solar farm, this does not compensate, or ever will, for the negative experience of walking alongside and being surrounded by what will be an industrial plant. For a fact, no constituents want to or would enjoy walking between 3.2 metre high black glass panels, or behind the fencing that will be installed. HABITAT LOSS AND DISRUPTION Exactly what does Mallard Pass mean by “mitigation”? Despite being asked what does this mean, they have failed to give any answer. Mallard Pass claim the area underneath the panels will be more bio-diverse than arable crops and they will be able to achieve their 20% Bio-Diversity Net Gain target from the solar panel area alone. If what they claim has any truth in it, then they should also explain why they have not designed the scheme more sensitively, over a far smaller area with a fraction of the land required for mitigation and enhancement, with less adverse impacts. It is clear that the bio-diversity net gain is a tick box exercise for Mallard Pass, treating us all with contempt, and they are hoping that those who decide whether this project is allowed or not, will not notice the wool is being pulled over their eyes. Please note, for those who do not farm or are not gardeners, little grows in the shade, and even less to nothing, grows in compacted soil which will have been damaged due to the construction traffic, tracks being built, drilling, piling, concreting, noise and vibration, all of which will have adverse affect on the current bio-diversity. There are several fallow deer herds in the area which run and breed freely. If Mallard Pass goes ahead, deer will no longer be able to run freely, facing miles of security fencing blocking their natural routes. Not only is the welfare of the deer at risk, but that of road users too. Faced with a reduced area to graze, deer will be forced cross roads where once they would remain in the fields. They will also be pushed towards and into ancient woodlands in the area in search of food which will cause additional damage to the ancient woodlands, and in turn impacting on the bio diversity and species in those areas as well as inflicting more concentrated damage to farmers crops. Some badger setts are going to be removed altogether, those that remain will have to navigate their routes through badger gates. Brown hares are at risk of losing much of their habitat due to the security fencing restricting their access to their habitat. And we should not forget the birds of prey who hunt over these fields along with Muntjacs, red kites, jackdaws, woodpeckers, owls and cuckoos to name just a few animals that inhabit the area proposed, who will all have their habitats destroyed. FOOD PRODUCTION There is a clear policy conflict with this submission and with the Government who are seeking to protect and enhance the UK domestic production to maintain food security yet is encouraging the growth of renewable energy on valuable productive farmland. You cannot grow good crops for the people of this country out of low grade soil, but you can install solar panels on low grade soil! Mallard Pass insist that the green fields, which will be covered with huge panels of black glass on rolling countryside, will still be able to be farmed. This is not true. While Mallard Pass in their advertising, happily show sheep grazing in the fields under the panels, the reality is in this area approx 98% of the land is arable farming for food production, which is harvested, night and day, by massive combine harvesters. The remainder approx 2% is mixed farming. In fact in the vicinity where I live there is only 1 farmer, who keeps some sheep in a field. These sheep graze in the area outside the area being proposed by Mallard Pass. Therefore it is safe to say that Mallard Pass has deliberately targeted and earmarked fields that are currently only used for food or rapeseed oil production. The UK does not have food security for its people as recent and current experience is proving, due to weather, war and climate change. The original survey of the agriculture land proposed to be covered in solar panels was reported as being 53% Best and Most Versatile Land. However, not happy with the result of the original survey, Mallard Pass Solar Project commissioned a second Survey to be undertaken, which conveniently for them, reported that it was only 40.7% BMV. Bear in mind the company/persons who undertook the second survey were employed and paid by Mallard Pass Solar Project. It would be criminal to remove Best and Most Versatile land from food production. The Government has made it very clear to constituents that ground mounted solar should use previously developed land, contaminated land, industrial land and agriculture land of grade 3b, 4 and 5 NOT BMV land. Therefore Mallard Pass’s submission does not fulfill this criteria. With that in mind, this project should not be approved and Mallard Pass Solar Project be instructed to only submit projects in accordance with the Governments views. ACCESS - TRAFFIC DISRUPTION AND DAMAGE The Proposal claims that the access to the proposed site is good. This is not true. While the A1 is close by, the roads between the A1 and the site are narrow, single carriage with no kerbing, extensive potholes, twisting A and B roads, many with complete blind spots, and some of these roads pass local schools. They are not adequate for the scale of construction traffic which will be necessary. It does not appear that alternative locations anywhere else in the UK have been considered during the consultation. In fact, after the Public Consultation, Mallard Pass Solar Project added into their submitted proposal an additional new substation, plus compulsory purchase orders for every property in Essendine, which front the A6121 so Mallard Pass can have access through villagers properties for 2+years, during the construction at any time, blocking the villagers who live in these properties the ability to access to their own homes, as Mallard Pass cannot access the area they wish to develop. It is surprising that this has only just come out at this late stage in the process. Why was this not known earlier and those affected made aware? Mallard Pass has failed under the requirements to honestly and openly consult in a meaningful way with the community. SECURITY OF THE SITE The Solar panels and cabling that connects them and the auxiliary equipment includes large quantities of valuable materials. As such, the sites will be at very high risk of theft both in construction and after completion. Due to the topography of the site and the multiple different areas providing adequate security will be difficult. The proposed 2m high fencing will be an eyesore, any planting planned will take decades to cover them, but is also not high enough to prevent theft. I am therefore concerned that these will be heightened in the future making the current proposal worse. The proposed plan also includes security lighting and CCTV cameras installed at a height of 3.5m around the site. These alone will not be sufficient to protect a site of this scale which is in effect a large number of smaller areas. Therefore it is not unreasonable to assume that Mallard Pass Solar Project will supplement this in the future or indeed is already accounted for in their plans. With regard to the security lighting, please note in this part of the country there is no light pollution once you leave the boundaries of the villages. The introduction of high security lighting around a 25 mile perimeter will not enhance the area, but will certainly make the areas feel like Colditz. The information provided regarding security during the consultation is inadequate and therefore not meaningful. BATTERY STORAGE SAFETY Of major concern is the apparent removal of the battery storage Mallard Pass had planned to build opposite the existing sub-station. They have indicated that they are not building a battery storage facility “at this time”, which indicates they may, more likely than not, bring this back onto the agenda at a later date, most likely through the back door”. By excluding this now they feel constituents would be more amenable to the project as it stands and the installation of a battery storage in the future will hopefully just be rubber stamped. Any battery storage will be using lithium-ion batteries, which will be stacked up to 13 metres high. These are not foolproof and faults do occur due to mechanical damage, heat, internal short circuits and poor battery management. When a fault occurs it causes a chemical reaction which, unlike a normal fire, does not need oxygen to burn and is therefore very difficult to contain. The only way to stop the reaction is by using vast amounts of water - also a finite resource due to climate change. In addition the batteries emit toxic gas, mainly hydrogen fluoride after which explosive gases are given off that can cause substantial explosions. Safety regulations for battery storage are woefully inadequate and fails to catch-up with the speed of battery storage installation which is connected to large scale solar applications. Better regulations must be in place both to protect the potential toxic impact to the environment and residential areas. While this proposed installation is ‘in a rural area’ and not the middle of London, it no less important to protect the constituents of the 18 nearest villages and the town of Stamford, not to mention all the other villages, towns and city of Peterborough. Please note, the most likely area where any battery storage would be sited is near the sub stations which are essentially located in the middle of the village of Essendine. SOLAR PANEL EFFECTIVENESS Solar Panels are approximately 15% efficient whereas wind turbines are approximately 50% efficient. Wind turbines generate power throughout the day and night whereas solar panels only generate electricity during day light and produce best when the weather is crisp, in the low 20’s and clear skies with no clouds. A rare occurrence in Lincolnshire. Deployment of Wind turbines is significantly outstripping the use of solar in commercial facilities in the USA. Since Mallard Pass is proposed by [Redacted], a Company involved in the production and deployment of solar panels, no consideration has been given at all to any alternative technologies to provide renewable power. FLOOD RISK I have lived in Greatford for nearly 30 years and the area surrounding Greatford and Essendine has flooded a number of times. The idea, put forward by Mallard Pass, that covering 463 hectares with impermeable solar panels piled into the ground, will not impact the ability of the land where the panels are located to absorb water run off is ludicrous. In fact the compaction of land during construction, will not ‘miraculously un-compact itself’ and will actually increase the flood risk to areas already designated either Flood 1,2, or 3 zones. The Consultation and Mallard Pass Solar Project only deal with flooding within the confines of the proposed solar farm. They are taking no responsibility for increasing the flood risk to constituents whose properties/villages are downstream and who will be affected by the excess runoff they will create, if this is allowed to be installed. Mallard Pass have failed to explain how this will be addressed to the point of ignoring and absolving themselves of any responsibility. Their theoretical modelling in the environmental report does not pass the “reasonableness test” based on decades of living in the area, with the knowledge acquired. Please note, if a neighbour blocks a dyke/changes its path, and there is subsequent flood/damage to your property, that neighbour is responsible for any damage. The same should apply to company’s such as Mallard Pass Solar Project, who are well aware that their installation will cause flooding issues downstream destroying peoples lives and livelihoods. INDEPENDENCE OF UK ENERGY SUPPLY AND LIMITED CONTRIBUTION TO UK PLC [Redacted] use Chinese Producers in its supply chain. Canadian Solar was established by a Chinese citizen who went to Canada to study. Chinese Citizens do not easily move overseas and set up independent companies on their own. However the links between Canadian Solar and Chinese Government are not clear and need to be clarified to ensure that UK energy supply remains independent from foreign powers (ref European dependence on Russian Gas) The Financiers behind Windell Energy and Canadian Solar are also not clear. The only contribution to UK PLC from this development will be the power generated and the employment during construction. There is no guarantee the power generated will be supplied at a lower cost to the UK to constituents of the UK at a lower cost. In fact, unless the current pricing structure is uncoupled, it will be supplied at the same cost as gas generated electric and is highly unlikely to ever be supplied at a lower price compared to todays or several years ago. Large scale developments of this nature should aim to have an accelerator effect on the UK economy but this is a one off, with no associated industry benefiting. And indeed because electricity generated from renewables is charged to the consumer at the price of electricity generated from carbon fuels the only beneficiaries will be be the shareholders of the Mallard Pass Solar Project. The financial aspects of this project and the ownership structure of the Proposers need to be clarified. And finally, for years we have listened to people who have a ‘view of what Lincolnshire is like and is in the middle of nowhere’ having never travelled ‘north’ and bears no correlation to the reality of the county. Lower Lincolnshire is 40 minutes from London, by train, many constituents commute to London and beyond on a daily basis for work. It borders the counties of Rutland, Cambridgeshire, Northamptonshire, Leicestershire and Nottinghamshire. Available on YouTube video is the “Flyover of Mallard Pass” , which you can search and view yourselves or click on the link below and skip the ads. [Redacted] This is an excellent visualization showing the area being impacted from the sky, shows how vast and inappropriate this proposed project is, what the country will be losing , and will never regain, just so some foreigners can line their pockets at the expense of UK PLC.