Representation by Geoffrey Radley
- Date submitted
- 27 February 2023
- Submitted by
- Members of the public/businesses
I am concerned at the loss of productive arable land that would result from the construction of this very large solar array, especially as a substantial proportion of the area proposed for the solar panel arrays is ‘best and most versatile’ agricultural land. I am also concerned about the cumulative effect on agricultural production, given that other large solar arrays are proposed on agricultural land in the East Midlands. I suggest that permission should not be given for this and other large-scale solar arrays on good quality agricultural land unless and until it has been shown that the required energy cannot be generated by installing solar arrays in the built environment. Opportunities exist for this, such as on the roofs of the many large warehouses that exist or are under construction across the East Midlands. If, despite this, the Secretary of State concludes that it is in the national interest for this development to go ahead then the developers’ stated aim of achieving biodiversity net gain will not be achieved unless some significant shortcomings in the proposed mitigation measures are rectified. These issues are as follows: 1. Despite some mitigation measures, there is still a risk of damage to the species-rich grasslands of some road verges within and around the Order Limits, especially those included in the Ryhall Pastures and Little Warren Verges SSSI. The risk arises from increased traffic, particularly during the construction phase, and I do not think the mitigation measures proposed so far are adequate. Further details are given below of my concerns and suggested additional mitigation measures. 2. The Ecology and Biodiversity chapter of the Environmental Statement underestimates the importance of the area within the Order Limits for wintering birds feeding on the arable fields. As a result of this, no mitigation measures are proposed for these birds. I strongly feel that such mitigation should be provided, especially in view of the potential for this and other large solar arrays to have a cumulative impact on the area of farmland available for wintering birds to feed on. Further details are given below of my concerns and suggested additional mitigation measures. 3. There is a danger that the management set out under objective 4 of the outline Landscape and Ecology Management plan (Create a strong structural planting framework and protect, restore and maintain the existing vegetation network) could conflict with one aspect of the management set out under Objective 5 (Create greater opportunities for protected species and species of conservation concern). The potential conflict arises because skylarks and other ground-nesting birds are more vulnerable to predation when the fields in which they nest are overlooked by trees or tall hedges that can act as lookout posts for predators such as crows. Skylarks seem to know this and have been shown to avoid such fields when choosing nest sites. To avoid this conflict, it is important that the field boundaries around the retained arable areas are not used for additional tree planting, and that the height of any hedgerows is contained. 4. The management of the grassland areas and the land under the solar arrays that is proposed in the Outline Landscape and Ecology Management Plan will not secure the projected biodiversity and other benefits without substantial modification. Further details are given below of my concerns and suggested changes to the proposed management of these areas. 5. The works proposed for the West Glen River corridor represent a missed opportunity to mitigate downstream flood risks whilst also enhancing biodiversity. Further details are given below of my concerns and suggested additional mitigation measures. The commitment, given in the outline Landscape and Ecology Management Plan, to environmental monitoring and to using the results to modify the environmental management if necessary is very welcome. However, the results of the monitoring, and the actions taken as a result, should be made public. Not only would this allow independent scrutiny of the work, but it would also allow the lessons learned to be applied to other similar developments in future. The five yearly interval between monitoring is also too long, particularly in the early years when the new habitats are being established. Risk of damage to species-rich road verges – further details and proposed mitigation Many of the minor roads in and around the area within the Order Limits are narrow, so that two vehicles coming in opposite directions will often need to mount the verge to pass each other. This is particularly true of HGVs, but can also be the case with lighter vehicles, and even private cars. There is already evidence of extensive erosion of verge vegetation on some minor roads in the area, particularly the road from Uffington to Essendine, and I am concerned that traffic during the construction phase could exacerbate this. I am particularly concerned about the species-rich grassland of the road verges included in the Ryhall Pastures and Little Warren verges SSSI. The commitment in the outline Construction Management Plan to restricting HGVs to defined routes is welcome, but I note that it is not proposed to extend this restriction to LGVs. The Plan identifies that there will be a greater number of daily LGV trips than HGV trips, so I am concerned that there will still be considerable potential for increased verge erosion. The proposal to provide a central car park and shuttle bus for the up to 400 staff working on site during the construction period is also welcome, but I note that it is not proposed to define how these staff access the car park, so there is still a risk that the increased car traffic in the area will increase damage to species rich road verges in the vicinty. It would be disproportionate to apply the same level of restriction to cars and vans as to HGVs, but I would strongly urge that use of the road through the Ryhall Pastures and Little Warren Verges SSSI, and any other minor roads with species rich roadside verges should be prohibited for all construction-related vehicle movements. Impact on wintering birds – further details and proposed mitigation The survey on which the Ecology and Biodiversity chapter of the Environmental Statement is based took place over a single winter. This is unlikely to give a true picture of the importance over time of the area for wintering birds, as the use that birds make of arable fields in winter varies considerably from year to year depending on the cropping regime and other factors. In some years, when conditions are right, the area could support much larger numbers of birds, as shown by the surveyors recording a flock of 3000 starling on one occasion, feeding on a freshly ploughed field. Despite the limitations of the survey, it found that redwing, fieldfares, starlings and yellowhammers all use regularly use the site in considerable numbers in winter. I would add that I have also seen substantial numbers of mistle thrush and flocks of finches and other passerines feeding on arable fields in and around the Order Area in the winter months. The Ecology and Biodiversity chapter of the Environmental Statement argues that the numbers of wintering birds using the area of the proposed development are only of local significance, I would dispute this. Not only are peak bird numbers likely to be higher than the survey recorded in some years, but the area within the Order Limits is only a short distance from the well-established winter roosts around the former gravel pits to the south and east of the proposed development. I have regularly seen large flocks flying over our property to roost, coming from land to the north west of Greatford and going in the direction of these pits. If the land within the Order Area becomes unavailable to ground-feeding wintering birds they are likely to have to fly further between their roosts and their feeding grounds, with consequent increased energy expenditure. I am therefore concerned that the measures proposed to enhance the retained arable in the outline Landscape and Ecology Management Plan (oLEMP) do not include measures intended to benefit wintering birds. Also, whilst the commitment to provide skylark plots on the retained arable is welcome, it will not benefit the wintering birds and it will not, by itself, be sufficient to protect the skylark population. This is because skylark plots only address the birds’ need for safe nesting sites, not their need for reliable food supplies in winter and when raising chicks. Fortunately, there are well-proven measures that could be deployed on the retained arable areas that would help to mitigate the impact of the development on ground-feeding wintering birds, and would increase the chances that the skylark population will be maintained. The simplest of these is to leave arable areas fallow on a rotational basis, retaining the previous year’s crop stubble through the following winter and spring before recultivating in summer. This form of management has been a standard option under successive Defra agri-environment schemes. I would strongly argue that the developers should be obliged to include management for ground-feeding wintering birds in the Landscape and Ecology Management Plan as a condition of the consent. Grassland management – further details of concerns and proposed changes The outline Landscape and Ecology Management Plan (oLEMP) states that the areas of wildflower grassland to be established using calcareous species will be cut every two years on rotation in late summer. There has been extensive research on the establishment of species rich grasslands. This strongly suggests that, on the relatively fertile soils of former arable fields, this cutting regime will not be sufficient to prevent the grasslands becoming dominated by a small number of vigorous grasses, with the other sown plant species being eliminated as a result. To avoid this, the areas should be cut more frequently (whilst still allowing species to flower and set seed) and/or they should be included in the areas to be grazed by sheep in late summer and winter, using a grazing regime similar to that used on the nearby Barnack Hills and Holes National Nature Reserve. The oLEMP states that grassland under the solar arrays will either be managed by rotational sheep grazing in autumn and winter to allow for nesting birds or, if no grazing is possible, will be cut twice per year in April/May and September. Cutting in April/May would be disastrous for any ground-nesting birds, as was found during the early days of agricultural set-aside, so this should be avoided at all costs. Grazing by sheep is a much better option for managing these areas and I would urge that this should be a condition of the consent. Grazing by sheep would retain some agricultural production from the area and would avoid the considerable labour costs of cutting large areas in and amongst the panels. The stocking density would need to be relatively low to avoid the risk of soil compaction and consequent increased run-off. Because of this, the grazing period may need to be longer than envisaged in the oLEMP to avoid the vegetation becoming too tall and dense. Management of the West Glen River Corridor – further details of proposed enhancements to the mitigation package The outline Landscape and Ecology Management Plan envisages establishing wet woodland and constructing shallow scrapes in this river corridor. This will have some biodiversity benefits, but is likely to have little impact on the hydrology of the West Glen River. Downstream of the Order Limits, Parts of Greatford have long suffered periods of flooding from the West Glen River during times of peak flow. There are well established techniques for slowing the flow of previously canalized rivers such as the West Glen whilst also benefitting biodiversity. These include channel diversification and the creation of washlands. The Environment Agency has already done some preliminary studies into the feasibility of increasing flood storage upstream of Greatford. I suggest that the developers, in partnership with the Environment Agency, should build on the work already done to develop a mitigation scheme that increases flood storage as well as benefitting biodiversity.