Representation by Stuart James Menzies
- Date submitted
- 28 March 2023
- Submitted by
- Members of the public/businesses
FROM: STUART MENZIES TO: NATIONAL INFRASTRUCTURE PLANNING??OBJECTIONS TO THE INSTALLATION OF SOLAR FARMS ON UP TO 10000 ACRES OF LINCOLNSHIRE FARMLAND?? 1. GENERAL COMMENTS These solar farms should not be built next to or in view of residential houses, on prime farm land, in areas that will cause soil erosion or have an adverse effect on wildlife, streams or anywhere else that would interfere with the natural scenic beauty of our countryside. There will be a four year construction schedule for the Gate Burton Solar Project and three other similar projects planned for the West Lindsey District of Lincolnshire, meaning four Nationally Significant Infrastructure Projects (NSIPs) within a few miles of each other all being examined independently. These projects combined will transform the area into a 10,000 acre building site and ultimately this would be the largest solar complex in Europe. This is just not acceptable to the local community due to the impact all the construction work will have on the well being and mental health of residents of the whole area, and all four of these solar projects should be assessed together due to the massive impact they will have on the local infrastructure. On top of all the disturbance to the natural habitat of the wildlife and plants in installing the panels in the fields, there will be a massive disruption, disturbance and unnecessary damage to more farmland and plant/animal habitats by many miles of cable trenching across the countryside, to install the underground cables to the grid connection points at the existing Cottam National Grid substation. This development will have an adverse impact on the character of local countryside as well as major, irretrievable loss of wildlife, from the initial 2 years of disruption caused by heavy construction traffic and then throughout its operational life. These four solar projects and associated structures will dominate and not blend into the local landscape, plus the thousands of acres of solar panels on open farmland will be highly visible and very difficult to hide on the rolling countryside and next to main roads. Vast areas of farmland would be converted into a Solar and Energy Storage Park. We made the choice to live in or be surrounded by the countryside, if these proposals go ahead the psychological issues would be enormous for many people. Their lives being impacted by 4 years of construction on a 10,000 acre building site, a total landscape change and the oppression of 15 feet high solar panels looming over everywhere you look. These solar farms/panels will have a massive impact on rural homes due to land grabs for the installation of 15 feet high mechanised solar panels, vast battery storage containers and associated equipment, including CCTV being sited close to homes. These projects will change peoples rural lifestyle to one with an industrial outlook and a number of features associated with these solar farms were inadequately communicated in the early stages of Low Carbon’s engagement with the local communities. Consequently one begins to wonder what other information about the schemes has not been relayed accurately. The Gate Burton Solar Project will cover over 3,500 acres of farmland and because 3 other solar projects are proposed for the West Lindsey area up to 10000 acres of farmland could be lost to solar arrays, batteries and electrical transformers within 7 miles of each other. These projects will make West Lindsey the most solar farm dense region in Europe, and therefore the magnitude of these projects will cause total landscape domination in many local areas. This solar project, if approved, covers a large area of food producing farmland and will industrialise this land, and in fact the whole area, and has the potential to impact on employment and skill levels in the agricultural industry. Also, losing large areas of farmland will lead to a loss in food production capability, quite important right now bearing in mind the war in Ukraine and current food shortages in the UK. In fact this solar project will generate half the output of the current largest solar farm in Europe and thus will be a hugely inefficient use of productive farmland in the area. The loss of up to 10000 acres of farmland at a time when food security is a real issue both nationally and globally. The land should be left as food producing farmland and not decimated by these obscene monstrous solar panels. This precious commodity should not be used for these land hungry, inefficient solar projects that will provide little net gain in the UK's energy capacity. To install these solar farms on land capable of producing cereals around Gainsborough in Lincolnshire will be a totally inefficient use of food producing farmland and the projects should NOT be allowed to proceed on this basis. If the government is determined, in it’s quest for zero carbon, that solar farms are needed to be a major part of the energy mix, then solar panels should be compulsorily installed on the roofs of all new build factories and houses, and in time on all those similar buildings currently existing. Clearly installing solar panels on all buildings has the potential to reduce the energy costs for the owners and/or occupiers. According to the BRE National Solar Centre, in 2016 there was an estimated 250,000 hectares (617,764 Acres) of south facing commercial roof space in the UK. If utilised this could provide approximately half of the UK’s electricity demand, therefore surely it is ‘no brainer’ to install solar panels on all commercial buildings instead of decimating food producing rural farmland. Low Carbon state the Gate Burton solar project has the potential to generate around 500MW, which is equivalent to providing enough clean energy to power 160,000 homes. This is very misleading for the layman, because the output from Gate Burton solar farm will only ever be at 500MW for short periods on clear sunny days, so it will only be providing energy to 160,000 homes consistently for a few hours, mostly in summer time, when demand is lowest. In reality that level of output will not be achieved for the vast majority of time due to the solar panel capacity factor. Therefore their statement that infers the Gate Burton solar farm will provide 500MW consistently 24/365 is inaccurate and incorrect. As of June 2021, UK installed solar capacity was over 13.5GW, with the 72MW Shotwick Solar Farm being the largest in the country. Annual generation was slightly under 13TWh in 2020 (4.1% of UK electricity consumption). Peak generation was less than 10GW. Solar PV panels have a capacity factor of around 10% in the UK climate. The Department of Energy and Climate Change (DECC) assumes an average capacity factor of 9.7% for solar photovoltaics in the UK. Basically solar farms are an inefficient use of land when the contribution to the energy mix they make is considered. When one considers the electricity needs of this country to meet the future demand, planning and constructing solar farms with a capacity factor of less than 10% makes me wonder what the point is, especially with a solar panel efficiency of around 30% meaning vast acres of farm land are needed to install anything meaningful. The Grid system will struggle without the CCGTs for the foreseeable future with solar farms providing a minuscule contribution only when the sun is shining and/or light levels are high. The solar farms will be of absolutely no help in meeting demand during a tea time system peak in the middle of winter, I.e. when it is dark and very cold. Also, the solar farms capability to provide system frequency response or voltage regulation/MVAR provision, major requirements from a generator to ensure system stability, are both minimal I understand more than 60% of the world’s solar panels are made in China. Therefore, I expect much of the other equipment Low Carbon are likely to install at the Gate Burton Solar Farm, if it’s approved, e.g. switchgear, transformers, inverters, protection equipment, batteries etc., will most likely come from China or the Far East too. In 2021 China started building started building 33 gigawatts of coal-based power generation, according to the Helsinki based Centre for Research on Energy and clean Air (CREA). That is the most new coal-fired power capacity China has undertaken since 2016 and says CREA, three times more than the rest of the world combined. So, by installing solar panels and other equipment manufactured in China it seems Low Carbon is moving part of the UK’s carbon footprint to China and possibly elsewhere in the Far East. Also, transportation of all these goods from the Far East will cause a further increase in the global carbon footprint created by these solar projects. Nobody or company in this country with decent moral or ethical principles should be procuring anything from China right now, because to do so will support the Chinese global economic status and their capability to spy etc on the west and possibly invade Taiwan. Also, China’s human rights record is appalling and that is another reason companies in the UK should not be trading with them, but I believe it’s all about the money and the greed of the organisations involved. Low Carbon state a very large Battery Energy Storage System (BESS) for storing electricity on-site will be installed on farmland. These type of batteries are known, from problems elsewhere, to be a source of danger from chemical spillage and fire, therefore they should not be located near to any type of property or housing estates. If the project goes ahead it is essential, from a safety perspective, for these batteries to be located away from residential areas and close to the Grid connection point on a brownfield site The project plan is for the electricity stored in the BESS to be released into the national grid when it’s needed most. It may also enable energy to be imported from the national grid so it can be stored until it is needed. However, in terms of being able to support/improve Grid System stability at a time of critical need the battery capacity (50MW or so I believe) will be totally insignificant and thus will provide minimal help to the System, or the demands of the nation on a winter’s night when there is a howling gale and it is minus10 DegreesC and system stability is under stress. Within the Gate Burton Energy Park PEIR, paragraph 2.5.14, states there will be a total of 368 traffic movements per day during the peak construction period. So combining these numbers with the West Burton Solar Farm forecast average construction vehicle movements per day of 60, and that forecast number for the Cottam Solar Farm of 48 per day, plus the West Burton and Cottam average workers traffic movements, which are each 400/day, the total forecast vehicle movements for construction and workers traffic per day, for all three projects during the construction period is 1276. This is utterly ridiculous on the country roads, some very narrow, that it is proposed will be used for site access. Of these movements there will be heavy construction traffic and these have the potential to cause major damage to the country lanes being used and vibrational structural damage to some buildings close to the these roads. Totally outrageous and unacceptable! In addition Air Quality will be polluted and there will be noise and light pollution from all construction and workers traffic road movements, and site heavy machinery, this is unacceptable for the local communities and for Low Carbon to expect people to tolerate the massive disturbance to their live 2. THE DIRTY SIDE OF SO-CALLED GREEN ENERGY There are large production and waste problems associated with the massive use of solar panels. Solar panels require vast amounts of heavy metals which are usually mined in appalling conditions in third world countries. Going green is supposed to be about a cleaner and fairer planet, but clearly there is a toxic downside of renewable solar energy. Solar panels are made out of plastic, silicon, aluminium, glass and copper, with small amount of toxic materials such as lead and hexavalent chromium. The significant issue about the UK trying to meet emission targets is that large numbers of these solar panels could or will be needed to be manufactured. Generally solar panels have a 20 year life after which they may well be dumped and left to degrade. Recycling solar panels requires acids, which are also toxic, and energy intensive heavy machinery. Those attempting to recycle panels say it is cheaper to landfill than recover what value remains. If life expired solar panels etc., are sent to a dump somewhere in Africa, for example, children rip them and other electrical equipment apart to extract small traces of precious metals, exposing themselves to toxic levels of lead in the process. Building batteries, that are needed as back-up at solar farms, requires large amounts of cobalt often sourced from Congo in Africa where children dig it out of ground with their bare hands. There seems to be a great irony with regard to the UK pursuing a green energy future, because we appear to be concentrating more on renewables than we do on the one clean energy source that is proven to be sustainable and that is nuclear power. We are currently building one new 3.2GW nuclear power station at Hinkley Point but that will not be commissioned/operational until 2027 at the earliest. I believe plans are in place to build another new nuclear station at Sizewell, but it will take maybe 15 years for that to be fully operational. Clearly by appearing to opt for the development of solar farms in preference to deciding to build new nuclear power stations 10 or so years ago, the government appears to have chosen the wrong option in trying to ensure the UK has a sustainable, stable and reliable electricity supply system. 3. AGRICULTURAL LAND I understand the Environment Secretary is proposing to change the definition of “best and most versatile” agricultural land, to include lower grade 3b land, to try and ensure it can be used for growing crops and so stop solar farms being built on it. Land graded as 3b covers 29% of agricultural land and has the capability of producing high yields of a variety of crops. Security of food production is a critical issue for the UK and it should be ensured that valuable farm land is protected. Energy security can be achieved without compromising food production. There are many potential sites for the installation of solar panels/farms, including commercial roof space, brownfield sites and poorer grade land. Land is a finite resource and so should be used for high priority activities, of which surely food production comes ahead of solar energy, the government must ensure this is the case. It is outrageous that Solar Energy UK would appear to be putting profit ahead of sensible land use. Therefore, as the vast majority of Low Carbon Gate Burton planned solar project is planned for installation on grade 3b land, none should be given permission to proceed as there are proposals, pending or in place, to redefine lower grade 3b land to best and most versatile agricultural land for crop growing. 4. EXAMPLES OF INCORRECT ASSUMPTIONS IN LOW CARBON’S GATE BURTON SOLAR PROJECT PRELIMINARY ENVIRONMENTAL INSPECTION REPORT (PEIR) In Chapter 8 on Ecology and Nature Conservation Clause 8.4.3 states “The impact on flora is not affected by the duration of activity but rather the change or loss of any habitats. The impact on fauna is likely to be the same or less than has been assumed if the construction period is extended.” QUESTION - How can the impact on fauna be the same or less if the construction period is extended? The longer the construction period the more damage is being done to the whole range of flora and habitat within the area where construction is ongoing, and therefore it will take longer for the recovery to the status of today, I.e. before any work is started Clause 8.6.2 states “A desk study was undertaken to identify sites designated for their biodiversity value and records of protected and, or notable habitats and species (biodiversity features) and invasive non-native species that are relevant to the Scheme.” COMMENT ON ASSUMPTION - I do not think sitting in an office completing a desk study identifying sites for their biodiversity value etc., is going to reflect accurately biodiversity value and/or records of protected and notable habitats and species (biodiversity features) and invasive non-native species that are relevant to the Scheme. I think it would be much more reflective of the true situation on all these issues if entire field studies were completed to obtain totally accurate details of all the issues mentioned above. Clause 8.6.12 states “The Phase 1 Habitat survey followed the standard JNCC method ‘Handbook for Phase 1 habitat survey: A technique for environmental audit’ (Ref 8-40). In summary, this comprised walking over the habitat within the DCO Site and recording the habitat types and boundary features present.” COMMENT - I do not think a quick walk across the habitat of the DCO Site is going to provide complete and accurate details of the habitat present, a more comprehensive field study would provide more realistic data on this issue. Overall on Chapter 8 insufficient information is provided as surveys are in progress throughout 2022, therefore, how can anyone make a realistic, accurate and complete assessment on mitigation measures or comment about the adequacy of the measures. In Table 8-1 ‘Ecological surveys to characterise baseline conditions’ - there are far too many ‘NO’ comments in the column - “Information Available for Inclusion in this PEI Report Chapter.” In Table 8-13 ‘Determination of relevant ecological features - Habitats and Species’ - there are far too many NO answers in the column - “Potential for an effect to occur?”