Representation by Lincolnshire County Council (Lincolnshire County Council)
- Date submitted
- 1 March 2023
- Submitted by
- Local authorities
Lincolnshire County Council (LCC), as a host authority, wishes to register as an Interested Party in connection with the Mallard Pass Solar Project (MPSP) as part of the development lies within our administrative area. LCC has engaged with the MPSP team throughout the pre-application stage and worked closely with the other host local authorities: Rutland County Council (RCC) and South Kesteven District Council (SKDC). All three authorities will be submitting their own relevant representation to ensure that the Examining Authority is aware of the matters of concern to those authorities. In due course each authority will submit an individual Local Impact Report (LIR). This representation identifies the main topic/aspects of the proposal which LCC has an interest in and which we are likely to want to discuss further as part of the Examination. A more detailed statement of the Council’s views and position on the project will be contained in the subsequent LIR. However, at this stage LCC intends to make representations in relation to the following: Landscape and Visual Impact - LCC has been involved in a number of meetings with the developer pre-submission and provided feedback in relation to the methodology and approach taken in assessing the landscape and visual impacts of the development. Whilst LCC has therefore been engaged with the developer to date we have yet to review the findings and conclusions made. As a result we intend to submit representations through our LIR which will set out our views insofar as the proposal affects Lincolnshire. Cultural Heritage - Insufficient evaluation has been undertaken to allow for an understanding of the archaeological potential or to provide the basis for reasonable mitigation to deal with the impacts of this development. Despite concerns having been raised during the pre-application stage the applicant has failed to provide a reasonable baseline assessment of the archaeological resource and the development’s impact upon it. Throughout the process we have advised on detailed specific requirements to provide a sufficient evidence base and therefore to allow for sufficient understanding of the site specific archaeological potential across the full extent of the proposed impact zone as is required by the NPPF, EIA Regulations and National Policy Statement EN-1. However, this has not been undertaken to the standard LCC would expect and therefore the Cultural Heritage section has been based upon only a limited amount of evaluation work and yet it is presented as the complete and full understanding of the archaeological resource across the site. The mitigation proposed is therefore uninformed and cannot be fit for purpose and LCC is of the view that further archaeological evaluation within the red line boundary is necessary to understand the extent, nature and significance of surviving archaeology so that appropriate mitigation can be determined. LCC has serious concerns about the approach and conclusions made with regard to the impacts of this proposal on cultural heritage assets within Lincolnshire. It is our view that the approach taken has been dismissive and expresses a wholesale devaluation of cultural heritage and the submission does not meet the evidential requirements as set out in the relevant policy and guidance including Infrastructure Planning (Environmental Impact Assessment) Regulations 2017 (Regulation 5 (2d)), National Planning Statement Policy EN1 (Section 5.8) and the National Planning Policy Framework. A much fuller and detailed explanation of our concerns will be provided as part of the subsequent LIR. Highways and Access - LCC as Local Highway Authority has been involved in a number of meetings with the developer pre-submission. The submitted highway details both faithfully record and update the pre-application discussions and meetings that have taken place. The Transport Assessment element of the Environmental Statement examines the conventional road transportation impacts of the proposed development, both during the construction phase – which will be the most impactful – and the operational phase. The initial plans for the construction phase have been refined and improved as now detailed in the Outline Construction Traffic Management Plan (OCTMP). Routing of HGVs have also been discussed and options considered. Highway improvement works are proposed as part of the development and these would need to be secured through Planning Obligations to make the proposal acceptable in planning terms. Temporary road closures will also be required for the installation of cables; also shown are temporary speed limits and temporary signalisation of junctions for works. The agreement and approval of these would be undertaken by LCC Streetworks and Permitting Team nearer the time, when other activities on the highway network are known, and full consideration of necessary diversion routes can be undertaken. We will submit a much fuller representation and views on the potential highway impacts of the proposal through our subsequent LIR. In addition to the above we are also likely to make representations in connection with the following: • Public Rights of Way – insofar as the proposal affects routes within Lincolnshire; • Surface Water Flooding and Drainage – as Lead Local Flood Authority for Lincolnshire; • Climate Change – LCC is will comments in respect of the conclusions made with regard the sustainability benefits of the development and the contribution it makes to reducing greenhouse gas emissions. • Impact and loss on agricultural land including Best and Most Versatile – insofar as the proposal affects Lincolnshire. Finally, the County Council as host authority is likely to be involved in 7 different Examinations in the second half of this year for a variety of different DCO applications. Some Officers will be involved in all of these Examinations and therefore it is requested that PINs take this into consideration when timetabling dates for specific Hearing sessions and submissions in order to avoid overlap and therefore ensure the County Council’s case is not prejudiced as a consequence of the number of Examinations taking place over such a short period of time.