Representation by Alison Simpson
- Date submitted
- 1 March 2023
- Submitted by
- Members of the public/businesses
The proposed building of an industrial scale solar plant on quality agricultural land and thereby destroying a valuable (some would now say, critical) renewable energy source of food production, The Mallard Pass Solar Farm proposal would seem wholly inappropriate. Size, location and loss of agricultural land & food security - The scale of the proposed development is (almost) too big to visualise: 1300 football fields' worth of largely agricultural / undeveloped land will be taken out of commission to be covered by solar panels that stand over 3 meters high! - Government policy is clear - ground mounted solar should not use Best and Most Versatile Land: almost 50% of the proposed panel area will use BMV land. - The government's Food Strategy policy paper (June 2022) seeks to maintain agricultural production, not reduce it. How does the proposed project align with these strategic policies. - It is not clear the extent, if any, of analysis to assess the impact on our country's food security of taking out the agricultural land for this project. Food security has become even more critical and in-focus since the Russia/Ukraine war and the very recent exposure of the food supply chain issues this country faces. - Food security, energy security & net zero. Where is the analysis of current and potential use and productivity vs. that likely under the proposed plan. - The proposal suggests that the bio-diversity under the panels will be more than arable crops, therefore it can achieve the 10% Bio-diversity Net Gain (BNG) target from the solar panel area alone. If that is the case then the scheme could have been designed over a far smaller area with a fraction of land required for mitigation and enhancement, with less adverse impacts. This also seems to miss the point that this higher bio-diversity will be 'new' ie introduced post construction rather than protection of the existing bio-diversity some of which will be unlikely to recover from the disruption from 2+ years of construction. Transparency of ownership and supply chain - The MPSF project is a foreign investment in the UK solar sector by Canadian Solar: an investment intended to deliver returns to their shareholders. Private investment into (public) infrastructure is to be encouraged, it should not be embraced without sufficient, appropriate, and thorough due diligence by all stakeholders – public, local and national government. This Planning process must be robust and transparent. Economics and benefit of the project - The extent of inconvenience, disruption and damage to the environment local to the MPSF site does not seem to be off-set by a confirmed reduction in overall energy prices (which are based on price of gas currently) consequently, the 'case' for this project remains unclear and unsupported for a local resident consumer as well as a national consumer. - What recourse will exist for any delay in delivery? - What contractual and legal obligations will be put in place for decommissioning of the site. Traffic & transport - The construction phase will take 2+ years with abnormal traffic coming through or past the outskirts of many local villages. This will create added noise, pollution, and damage to roads and associated verges, as well as extra risk for pedestrians, cyclists and horse-riders. It is also likely to disturb the bio-diversity. The large site will necessitate large volume of traffic that the local environment cannot support. Flooding - The creation of any large scale solar development would likely increase the flood risk to the local countryside, roads, villages, and properties over a wide area. MPSF have focussed on managing flood risk on the site only. This seems to require further investigation and assessment. Other areas that will be negatively impacted by the MPSF: - recreational amenity: Public rights of way may be moved or closed during construction phase (2+ years) and even after construction is complete there will likely be 2m high fencing, cctv, security lighting and the solar panels of 3.3 m height. The proposed screening mitigation measures will take up to 15 years to develop sufficiently - approximately the same time the first generation of panels will be coming to the end of their useful life! Solar energy has a part to play in supplying renewable energy and supporting the country's net zero target but only where appropriate. Installing solar panels on top of commercial buildings as well as new-build houses would go a long way in addressing the country's need whilst addressing the balance with other, critical factors, such as bio-diversity and food security. It is not clear what alternative approaches have or will be assessed in proposing the MPSF.