Representation by Mallard Pass Action Group (Mallard Pass Action Group)
- Date submitted
- 28 February 2023
- Submitted by
- Non-statutory organisations
Mallard Pass Action Group (MPAG) - Relevant Representation MPAG object to the Mallard Pass Solar Farm application for the following reasons: 1. Scale. To date no solar farm has been constructed on this scale in the UK. Consideration needs to be given as to how the harmful impacts are likely to magnify compared to a typical smaller installation. This issue of scale also feeds directly into a number of the further concerns identified below. 2. Voice of the community. MPAG speak on behalf of the community. It is clear from the 1,042 consultation responses from a small rural population, that there is a significant level of opposition to this scheme across a wide range of issues. 3. Compulsory Acquisition rights. At no stage pre application were residents aware and/or clear of compulsory acquisition rights being requested, the justification and subsequent implications. Had this been apparent it would have been challenged. 4. Effects on landscape character and views / visual amenity including residential. A technical landscape and visual assessment and full review of the submitted information are being undertaken. We are advised that the applicant’s assessments are flawed, and as a result, levels of effects have been under-reported. The character of the open lightly undulating vista will be changed immeasurably and irreversibly creating an industrialised landscape and wholly undesirable place to live, work and enjoy recreation. 5. Recreation. The impact on recreation including walking, riding, cycling and other pursuits is ill judged as to the sensitivity on key receptors. There is a complete lack of understanding of the impacts on peoples’ health and well-being, as existing and proposed permissive PRoWs are adjacent to and/or surrounded by solar arrays, associated electrical infrastructure, tracks and fencing. 6. Site selection. There is no clear evidence of sequential testing and a fuller or sufficient review of the alternatives. The site and it’s layout was chosen primarily due to its proximity to the National Grid sub-station and has not fully considered the many negative impacts, as well as meeting all the planning guidelines. 7. BMV land. National and local policy clearly state Best & Most Versatile (BMV) land should not be developed on in preference to lower grade land and brownfield land. The level of BMV land loss is completely unacceptable. 8. BMV hypothesis. There are irregularities in the sampling and assessment methodologies rendering the results questionable. 9. Land grab. Mallard Pass has inappropriately secured far more land than necessary to utilise the existing capacity at the Ryhall sub-station. Why was this necessary given the huge amount of the site now being left to mitigation rather than on-going food production? 10. Land Use. Nationally there is much debate on this subject with competing demands for arable, livestock, environmental and regenerative schemes, bio fuels etc. To have a balanced argument the amount of energy generated needs to be balanced against the loss of food production and other implications. With an application that is not time limited, Mallard Pass can give no certainty or confidence when the land can return effectively to food production farming and its contribution to the National Grid. 11. Continued agricultural purposes. It is not realistic to assume that a site of this scale and layout can be managed for ongoing food production during operation. Baseline assumptions and a clearer plan taking account of likely worst case scenario needs to clarified. 12. Planning consent is not time limited. This has considerable implications for the assumptions laid out in the application across many of the metrics. Surely the efficacy of the application and the metrics provided can only validated if the application has a time limit. How can this application meaningfully now be classed as temporary? 13. Noise. There is concern that riders’ safety may be impacted by noise emitted from nearby solar stations, made worse by wind travel, and not fully taken into account in the assessment. 14. Glint & Glare. This has not been sufficiently assessed, especially with respect to cyclists and riders on some roads and bridleways and is a safety concern. 15. Bio-diversity. The limitations of the survey data, emphasis on desk work, and overall methodology underplay the extent of the number of species and habitats in the area, and the potential impacts to them through different phases of the scheme. Where is the data/research to validate the scale impacts on bio-diversity of such a large solar farm? 16. Construction. The impacts of installing over ½ million solar panels, a new sub-station and all the associated infrastructure are disproportionate, the local environment and community will be too adversely affected by the scale of this project. 17. Decommissioning: The draft DCO does not thoroughly consider decommissioning to ensure the land can be returned fully to its former state. 18. Carbon impact. The assumptions do not take into account all of the variables and worst case scenario given the unlimited time of the application. The figures are therefore open to interpretation and there is no clear guaranteed contribution to Net Zero. 19. Flood risk. The application does not properly consider the effects of off-site flooding exacerbated by the construction and operation of the solar farm. Evidence clearly shows the vulnerability of certain on and off-site areas. Climate change will add increasing pressures combined with the inevitable and irreversible effects on the soil of 2 years of construction. 20. Heritage. The solar farm is on the doorstep of the historic market town of Stamford and a very short distance from Burghley House. Its presence will only undermine the rural and historic setting of the area. The Sunday Times voted Stamford ‘best place to live’ in Midlands region in 2021, best in UK in 2013 and 2nd place in 2017, these accolades have boosted local tourism over the last 10 years. 21. Local businesses. Residents running nearby B&B or holiday lets will suffer a loss of business as no one wants to stay next or near to a solar farm, however attractive Stamford might seem to visit; disruption to local businesses from the 2 year construction work will also be harmful. 22. Community benefits. There are no discernible local benefits to this scheme, only harm to the local community. There are 8 villages adjacent to the site and at least 20 in total that will be negatively affected in some way; locals were led to assume their energy would be cheaper and the development might power up to 92,000 local homes, an incentive perhaps for people to get behind the scheme. Neither is the case. Market pricing is dictated by global gas wholesale prices not local energy generation, and the energy generated goes directly to the National Grid. 23. Consultation. The experience for the local community was considered wholly inadequate, unsatisfactory and frustrating for many locals seeking timely feedback and clarity on issues. 24. Transparency of information. There is an inconsistency in the presentation of some of the key statistics in the application which needs to be reviewed to ensure none of the key messages are misleading or misrepresentative. 25. Traffic. The traffic impacts have not been fully assessed or updated in the light of changes during the pre-application to final application stages, and as such the significance of the impacts have been underestimated causing significant disruption, damage and harm to the local area and communities. 26. Mental & physical health. The combined impacts on daily life to recreation, visual, residential, and socio-economic elements as a result of the construction activities, operational noise, new industrial landscape, increased flood risk, will serve to create mounting stress and upset within the local communities. 27. National Infrastructure. The measure of any such project should be what it delivers in totality. Whilst the need for energy is articulated, it is not matched with any detail on what it will deliver against the national need over what period of time. No business plan would (or should) be accepted based on such vague headline numbers. 28. National security. There is some concern that a national infrastructure project should consider all security issues with respect to sourcing, project management and funding. 29. Cumulative effect. There has been a failure to properly assess and mitigate the cumulative impact of the scheme alongside other planned local infrastructure projects. There are plans for substantial house building projects in the area which will use similar traffic routes as well as other solar projects. 30. We reserve the right to add or amend our representations in the light of new information becoming available. The running order of this representation does not signify the relative importance of any one issue.